**Resource Report 9 -- Air and Noise Quality**

**AES Sparrows Point LNG Terminal**

& Mid-Atlantic Express Pipeline

+------------------------------------------+-----------+---------------+
| **SUMMARY OF REQUIRED FERC REPORT        |           |               |
| INFORMATION**                            |           |               |
+------------------------------------------+-----------+---------------+
| **TOPIC**                                | **FERC    | **Report      |
|                                          | Re        | Reference or  |
|                                          | ference** | Not           |
|                                          |           | Applicable**  |
+------------------------------------------+-----------+---------------+
| 1.  Describe existing air quality in the | §         | Section 9.3.1 |
|     vicinity of the project              | 380       |               |
|                                          | .12(k)(1) |               |
|     -   Identify criteria pollutants     |           |               |
|         that may be emitted above        |           |               |
|         EPA-identified significance      |           |               |
|         levels.                          |           |               |
+------------------------------------------+-----------+---------------+
| 2.  Quantify the existing noise levels   | §         | Section 9.4.3 |
|     (day-night sound level (L~DB~) and   | 380       |               |
|     other applicable noise parameters)   | .12(k)(2) | Figure 9.4-1  |
|     at noise sensitive areas and at      |           |               |
|     other areas covered by relevant      |           | Appendix 9C   |
|     state and local noise ordinances.    |           |               |
|                                          |           |               |
| -   If new LNG terminal sites are        |           |               |
|     proposed, measure or estimate the    |           |               |
|     existing ambient sound environment   |           |               |
|     based on current land uses and       |           |               |
|     activities.                          |           |               |
|                                          |           |               |
| -   For existing LNG terminals (operated |           |               |
|     at full load), include the results   |           |               |
|     of a sound level survey at the site  |           |               |
|     property line and nearby             |           |               |
|     noise-sensitive areas.               |           |               |
|                                          |           |               |
| -   Include a plot plan that identifies  |           |               |
|     the locations and durations of noise |           |               |
|     measurements                         |           |               |
|                                          |           |               |
| -   All surveys must identify the time   |           |               |
|     of day, weather conditions, wind     |           |               |
|     speed and direction, engine load,    |           |               |
|     and other noise sources present      |           |               |
|     during each measurement.             |           |               |
+------------------------------------------+-----------+---------------+
| 3.  Quantify existing and proposed       | §         | Section 9.3.2 |
|     emissions of compressor equipment,   | 380       |               |
|     plus construction emissions,         | .12(k)(3) | Tables 9.3-4  |
|     including nitrogen oxides (NO~X~)    |           | to 9.3-6 and  |
|     and carbon monoxide (CO), and the    |           | 9.3-9         |
|     basis for these calculations.        |           |               |
|     Summarize anticipated air quality    |           | And Appendix  |
|     impacts for the project.             |           | 9A            |
|                                          |           |               |
| -   Provide the emission rate of NO~X~   |           |               |
|     from existing and proposed           |           |               |
|     facilities, expressed in pounds per  |           |               |
|     hour and tons per year from maximum  |           |               |
|     operating conditions, include        |           |               |
|     supporting calculations, emissions   |           |               |
|     factors, fuel consumption rate, and  |           |               |
|     annual hours of operation.           |           |               |
+------------------------------------------+-----------+---------------+
| 4.  Describe the existing compressor     | §         | N/A           |
|     units at each station where new,     | 380       |               |
|     additional, or modified compressor   | .12(k)(4) |               |
|     units are proposed, including the    |           |               |
|     manufacturer, model number, and      |           |               |
|     horsepower of the compressor units.  |           |               |
|     For proposed new, additional or      |           |               |
|     modified compressor units include    |           |               |
|     the horsepower, type and energy      |           |               |
|     source.                              |           |               |
+------------------------------------------+-----------+---------------+
| 5.  Identify any nearby noise-sensitive  | §         | Section 9.4.3 |
|     area by distance and direction from  | 380       |               |
|     the proposed compressor unit         | .12(k)(4) |               |
|     building/enclosure.                  |           |               |
+------------------------------------------+-----------+---------------+
| 6.  Identify any applicable state or     | §         | Section 9.4.2 |
|     local noise regulations.             | 380       |               |
|                                          | .12(k)(4) |               |
| -   Specify how the facility will meet   |           |               |
|     the regulations                      |           |               |
+------------------------------------------+-----------+---------------+
| 7.  Calculate the noise impact at        | §         | Section 9.4.4 |
|     noise-sensitive areas of the         | 380       |               |
|     proposed compressor unit             | .12(k)(4) |               |
|     modifications or additions,          |           |               |
|     specifying how the impact was        |           |               |
|     calculated, including manufacturer's |           |               |
|     data and proposed noise control      |           |               |
|     equipment.                           |           |               |
+------------------------------------------+-----------+---------------+

Additional Information

  --------------------------------------------------------- ----------------
  Provide copies of application for state air permits and   Copies of state
  agency determinations, as appropriate                     air permits and
                                                            agency
                                                            determinations
                                                            will be appended
                                                            to the Maryland
                                                            CFRA
                                                            Application, a
                                                            copy of which
                                                            will be filed
                                                            separately with
                                                            the FERC in
                                                            January 2007.

  For Major Stationary Sources of air emissions (as defined Copies of
  by EPA), provide copies of applications for permits to    permits to
  construct (and operate, if applicable) or for             construct and
  applicability determinations under regulations for the    applicability
  prevention of significant air quality deterioration and   determinations
  subsequent determinations.                                will be appended
                                                            to the Maryland
                                                            CFRA
                                                            Application, a
                                                            copy of which
                                                            will be filed
                                                            separately with
                                                            the FERC in
                                                            January 2007.

  Describe measures and manufacturer's specifications for   Descriptions of
  equipment proposed to mitigate impact to air and noise    measures to
  quality, including emissions control systems,             mitigate air
  installation of filters, mufflers, or insulation of       quality impacts
  piping and building, and orientation of equipment away    are provided in
  from noise-sensitive areas.                               Section 9.3.6.
                                                            Noise impact
                                                            mitigation
                                                            measures are
                                                            described in
                                                            Section 9.4.5..
                                                            AES will comply
                                                            with local,
                                                            state and
                                                            Federal noise
                                                            requirements.
                                                            Specifications
                                                            will be provided
                                                            as they become
                                                            available during
                                                            the detailed
                                                            design by the
                                                            2^nd^ Quarter of
                                                            2008.
  --------------------------------------------------------- ----------------

**TABLE OF CONTENTS**

Page

LIST OF TABLES [v](#__RefHeading___Toc155694772)

LIST OF FIGURES [vi](#__RefHeading___Toc155694773)

9.0 Air and Noise Quality [1](#air-and-noise-quality)

9.1 Introduction [1](#introduction)

9.2 Objective and Applicability [1](#objective-and-applicability)

9.3 Air Quality [2](#air-quality)

9.3.1 Existing Air Quality [2](#existing-air-quality)

9.3.2 Estimated Emissions from the Project
[3](#estimated-emissions-from-the-project)

9.3.3 Air Quality Regulatory Requirements
[12](#air-quality-regulatory-requirements)

9.3.4 Potential Air Quality Impacts of Proposed Project Due

to Construction
[23](#potential-air-quality-impacts-of-proposed-project-due-to-construction)

9.3.5 Potential Impact of Proposed Project Due to Facility Operation
[24](#potential-impact-of-proposed-project-due-to-facility-operation)

9.3.6 Mitigation of Air Quality Impacts
[2](#mitigation-of-air-quality-impacts)

9.4 Noise Quality [3](#noise-quality)

9.4.1 Noise Overview [3](#noise-overview)

9.4.2 Regulatory Overview [4](#regulatory-overview)

9.4.3 Existing Noise Levels [5](#existing-noise-levels)

9.4.4 Noise Impacts [6](#noise-impacts)

9.4.5 Noise Mitigation Measures [12](#noise-mitigation-measures)

9.5 References [13](#references)

**TABLES**

**FIGURES**

**Appendix 9A Emissions Calculations**

**Appendix 9B Air Quality Impact Analysis Calculations and CD of
Modeling Input and Output Files**

APPENDIX 9C Site Sound Survey and Noise Impact Evaluation

APPENDIX 9D Fugitive Dust Suppression and Monitoring Plan

APPENDIX 9E Resource Report 9 FERC Data Request Responsive Matrix

[]{#__RefHeading___Toc155694772 .anchor}LIST OF TABLES

**Table No. Title**

Table 9.3-1 National Ambient Air Quality Standards

Table 9.3-2 Interstate Air Quality Control Regions Attainment Status

Table 9.3-3 Ambient Monitor Data for Project Area Air Quality Control
Regions

Table 9.3-4 Construction Phase Emissions Summary

Table 9.3-5 Operating Phase Emissions Summary - Criteria Pollutants

Table 9.3-6 Operating Phase Emissions Summary - Hazardous Air Pollutants

Table 9.3-7 Air Quality Impact Analysis Emission Sources and Stack
Parameters Summary

Table 9.3-8 Source Groups Used in Modeling Analysis

Table 9.3-9 Summary of Maximum Air Quality Impacts By Model Scenario

Table 9.3-10 Comparison of Project Direct and Indirect Emissions With
County Emissions Inventory

Table 9.3-11 Summary of Relevant BACT/LAER Determinations from EPA RBLC
for Natural Gas Fired Boilers and Hot Water Heaters

Table 9.3-12 Summary of Relevant BACT/LAER Determinations from EPA RBLC
for Natural Gas Fired Combined Cycle Combustion Turbines

Table 9.4-1 State of Maryland Overall Environmental Noise Standards

Table 9.4-2 Maximum Allowable Noise Level (dBA) For Receiving Land

Use Categories

Table 9.4-3 Measured Daytime and Nighttime Noise Levels at Nearest Noise
Sensitive Area

Table 9.4-4 Dominant Noise Sources and Meteorological Conditions During
Noise Measurements

Table 9.4-5 Measured Noise Levels At Proposed Sparrows Point LNG
Terminal Property Boundaries

Table 9.4-6 Noise Levels Associated with Outdoor Construction

Table 9.4-7 Predicted Sound Levels at Nearest Noise Sensitive Areas and
Fenceline Locations Associated with Pile Driving Activities

Table 9.4-8 Predicted Sound Levels at Nearest Noise Sensitive Areas
Associated with HDD Activities

Table 9.4-9 Predicted Ldn Noise Levels at Nearest Noise Sensitive Areas
Associated with the Proposed LNG Terminal and Power Plant Facility

Table 9.4-10 Predicted Sound Levels at Nearest Noise Sensitive Areas and
Fenceline Locations Associated with the Proposed LNG Terminal and Power
Plant Facility

Table 9.4-11 Predicted Ldn Noise Levels at Nearest Noise Sensitive Areas
Associated with Construction and Maintenance Dredging Activities

Table 9.4-12 Predicted Sound Levels at Nearest Noise Sensitive Areas
Associated with Construction and Maintenance Dredging Activities

[]{#__RefHeading___Toc155694773 .anchor}LIST OF FIGURES

**Figure No. Title**

Figure 9.3-1 Wind Rose Plot

Figure 9.3-2 BPIP Model Setup, Building/Structure Identification

Figure 9.3-3 BPIP Model Setup, 3D Building Representation

Figure 9.3-4 AERMOD Model Setup, Showing Buildings, Fenceline, Plant
Boundary and Near-Field Receptors

Figure 9.3-5 AERMOD Model Setup, Polar Receptor Grid and Domain
Boundaries

Figure 9.4-1 Noise Sensitive Areas -- Sparrows Point LNG

Terminal Facility

Figure 9.4-2 Closest Noise Sensitive Area -- Susquehanna River HDD

Figure 9.4-3 Closest Noise Sensitive Area -- Back River HDD

  -------------------------------------------------------------------------
  **Term**        **Description**
  --------------- ---------------------------------------------------------
  \"              inches

  °F              degree Fahrenheit

  bbl             barrels

  bbl/h           barrels per hour

  AMSC            Area Maritime Security Committee

  ANSI            American National Standards Institute

  AOR             Area of Responsibility

  API             American Petroleum Institute

  ASME            American Society of Mechanical Engineers

  ATWS            Additional Temporary Workspace

  BIA             Bureau of Indian Affairs

  BIBI            Benthetic index of biotic integrity

  BMP             Best Management Practice

  BMS             Burner Management System

  BOG             boiloff gas

  Bscfd / bscfd   billion standard cubic feet per day

  Btu             British thermal unit

  Btu/(ft^2^hr)   British thermal unit per feet squared per hour

  C5 plus         pentane plus

  CCTV            closed circuit television

  CEQ             Council on Environmental Quality

  CFR             Code of Federal Regulations

  CO              carbon monoxide

  COE             U.S. Army Corps of Engineers

  COMAR           Code of Maryland Regulations

  COTP            Coast Guard Captains of the Port

  CROW            Construction right-of-way

  CWA             Clean Water Act

  cy              cubic yard

  CZMA            Coastal Zone Management Act of 1972

  DB&B            double block and bleed

  DCS             distributed control system

  DMRF            Dredge Material Recycling Facility

  Dth/day         Dekatherms per day

  EA              Environmental Assessment

  EIA             Energy Information Administration

  EIS             Environmental Impact Statement

  EPC             Engineering, Procurement and Construction

  ER              Environmental Report

  ERC             emergency release coupling

  ESA             Endangered Species Act of 1973

  ESD             emergency shutdown

  ESD-1           Pier Emergency Shutdown

  ESD-1-1         Activation of the unloading arm/vapor return arm ERCs on
                  Berth 1 and Berth 2

  ESD-2           Total Terminal Emergency Shutdown

  FAA             Federal Aviation Administration

  FBE             Fusion-Bonded Epoxy

  FEED            Front End Engineering Design

  FERC            Federal Energy Regulatory Commission

  FERC's Plan     FERC's Upland Erosion Control, Revegetation, and
                  Maintenance Plan

  FERC's          FERC's Wetland and Waterbody Construction and Mitigation
  Procedures      Procedures

  FM              Factory Mutual

  fps             feet per second

  ft              feet

  gpm             gallons per minute

  h               hour(s)

  H&MB            heat and material balance

  HAZID           Hazard Identification

  HAZOP           Hazard And Operability

  HDD             Horizontal Direction Drilling

  HDMS            Hazard Detection and Mitigation System

  HHV             higher heating value

  HID             High Intensity Discharge

  HIPPS           High Integrity Pipeline Protection System

  Hp / hp         horsepower

  HP              high pressure

  HTF             heat transfer fluid

  IESNA           Illuminating Engineering Society of North America

  in              inch

  inches H~2~O    inches of water

  inches Hg       inches of mercury

  inches Hg/h     inches of mercury per hour

  IP              intermediate pressure

  ISO             International Organization for Standardization

  Kts             knots

  kV              kilovolt

  kVA             kilovolt Ampere (one thousand Volt Amperes)

  LDC             Local Distribution Company

  LFL             lower flammability limit

  LHV             lower heating value

  LNG             Liquefied Natural Gas

  LNG Terminal    Sparrows Point LNG Import Terminal

  LOI             Letter of Intent

  LP              low pressure

  LTD             Level, Temperature, Density

  M&R             Metering and Regulator

  m^3^            cubic meters

  m^3^/hour       cubic meters per hour

  MAOP            Maximum Allowable Operating Pressure

  mbar            millibar

  mbar/hour       millibar per hour

  MCC             Motor Control Center

  mcf             million cubic feet

  MCMERG          Mid-Chesapeake Marine Emergency Response Group

  MCR             Main Control Room

  MDE             Maryland Department of the Environment

  MDNR            Maryland Department of Natural Resources

  Mg/l            Microgram per Liter

  MIS             Management Information System

  MLLW            mean low low water

  MLV             Mainline valve

  MMBtu/hr        million British thermal units per hour

  MMcf/day        million cubic feet per day

  MMscfd          million standard cubic feet per day

  MP              Milepost

  mph             miles per hour

  MW              megawatt

  N/A             not applicable

  NAS Pax River   Naval Air Station Patuxent River

  NAVD            North American Vertical Datum

  NDE / NDT       Nondestructive Examination / Nondestructive Testing

  NEC             National Electrical Code

  NEPA            National Environmental policy Act of 1969

  NFPA            National Fire Protection Association

  NGA / NGPA      Natural Gas Act / Natural Gas Policy Act

  NHPA            National Historic Preservation Act of 1969

  NMFS            National Marine Fisheries Service

  NOI             Notice of Intent

  No. ins         number of inches

  NOAA            National Oceanic and Atmospheric Administration

  NOx             nitrogen oxides

  NPDES           National Pollutant Discharge Elimination System

  NPL             National Priority List

  NPS             National Park Service

  NRCS            Natural Resources Conservation Service

  NRHP            National Register of Historic Places

  NSA             Noise Sensitive Area

  NWI             National Wetland Inventory

  NVIC            Navigation and vessel Inspection Circular

  O&M             Operations And Maintenance

  OBE             Operating Basis Earthquake

  OD              Outside Diameter

  OSHA            Occupational Safety and Health Administration

  P&ID            piping and instrumentation diagram

  PAH             Poly Aromatic Hydrocarbon

  PCB             Polychlorinated Biphyenyls

  PCMS            Plant Control and Monitoring System

  PCR             Platform Control Room

  PDEP            Pennsylvania Department of Environmental Protection

  PDM             Processed Dredged Material

  PIANC           Permanent International Association Navigation Congress

  PM              particulate matter

  POTW            Publicly-owned Treatment Works

  PPB / ppb       parts per billion

  PPM / ppm       parts per million

  PPT / ppt       Parts per trillion

  psf             pounds per square foot

  psig            pounds per square inch gauge

  PWSA            Preliminary water way suitability assessment

  PVC             Poly Vinyl Chloride

  QA              Quality Assurance

  QC              Quality Control

  RGS             Rigid Galvanized Steel (conduit)

  ROW             Right-of-Way

  RR              Resource Report

  RTD             resistance temperature detector

  RTU             remote terminal unit

  RUSLE           Revised Universal Soil Loss Equation

  SAV             Aquatic vegetation

  SCADA           Supervisory Control and Data Acquisition

  scfh            standard cubic foot (feet) per hour

  scfm            standard cubic foot (feet) per minute

  SCUBA           Self-contained Underwater Breathing Apparatus

  SHPO            State Historic Preservation Officer

  SIP             State Implementation Plan

  SIS             Safety Instrumented System

  SPCC            Spill Prevention, Control, and Countermeasure

  SSE             Safe Shutdown Earthquake

  SSURGO          Soil Survey Geographic

  STATSCO         State Soil Geographic

  SWPPP           Storm Water Pollution Prevention Plan

  Tcf             Trillion Cubic Feet

  TCP/IP          Transmission Control Protocol/Internet Protocol,

  THPO            Tribal Historic Preservation Office

  TMDL            Total Maximum Daily Load

  TOC             Total organic carbon

  Trap            Pig Launcher Receiver Facility

  UL              Underwriters Laboratories

  UPS             Uninterruptible Power Supply

  USCG            United States Coast Guard

  USDA            United States Department of Agriculture

  USDOE           United States Department of Energy

  USDOT           United States Department of Transportation

  USEPA / EPA     United States Environmental Protection Agency

  USFWS           U.S. Fish and Wildlife Service

  USGS            U.S. Geological Survey

  usg             United States gallons

  usgpm           United States gallons per minute

  V               voltage

  VOC             volatile organic compound

  WSA             Water way suitability assessment

  WWTP            Waste Water Treatment Plant

  §               Section
  -------------------------------------------------------------------------

# Air and Noise Quality

##  {#section .unnumbered}

## Introduction

AES Sparrows Point LNG, LLC (Sparrows Point LNG) proposes to construct,
own, and operate a new liquefied natural gas (LNG) import, storage, and
regasification terminal (LNG Terminal) at the Sparrows Point Industrial
Complex situated on the Sparrows Point peninsula east of the Port of
Baltimore in Maryland. LNG will be delivered to the LNG Terminal via LNG
marine traffic, offloaded from these ships to shoreside storage tanks,
regasified on the LNG Terminal site (Terminal Site), and transported to
consumers via pipeline. The LNG Terminal will have a regasification
capacity of 1.5 billion standard cubic feet of natural gas per day
(bscfd), with potential to expand to 2.25 bscfd. Regasified natural gas
will be delivered to markets in the Mid-Atlantic Region and northern
portions of the South Atlantic Region, through an approximately 88-mile,
30-inch outside diameter natural gas pipeline (Pipeline) to be
constructed and operated by Mid-Atlantic Express, LLC (Mid-Atlantic
Express). The Pipeline will extend from the LNG Terminal to
interconnections with existing natural gas pipeline systems near Eagle,
Pennsylvania. Together, the LNG Terminal and Pipeline projects are
referred to as the Sparrows Point Project or Project. Both Sparrows
Point LNG and Mid-Atlantic Express (hereinafter collectively referred to
as AES) are subsidiaries of The AES Corporation.

The Project footprint is located in the counties of Baltimore, Harford
and Cecil in Maryland, and in the counties of Lancaster and Chester in
Pennsylvania. The Terminal Site, which is located entirely within
Baltimore County, is a parcel located within a former shipyard. The
route proposed for the Pipeline (Pipeline Route), which crosses all of
the listed counties, includes industrial, commercial, agricultural, and
residential lands. Together, the Terminal Site and the Pipeline Route
comprise the Project Area.

As described in Section 1.10 of Resource Report 1, *General Project
Description*, The AES Corporation is considering the possibility of
building a combined cycle cogeneration power plant (Power Plant) on the
Terminal Site. The Power Plant would be configured with one F-Class
combustion gas turbine, one steam turbine, and associated auxiliaries.
It would operate only on natural gas and would produce approximately 300
megawatts (MW) of clean electric power within an area of high energy
demand. The Power Plant would be connected to the local utility electric
system via an overhead transmission line.

## Objective and Applicability

This Resource Report discusses the existing air and noise quality within
the vicinity of both the LNG Terminal and the Pipeline, the potential
impacts to air and noise quality associated with construction and
operation of the Project and the Power Plant, and the proposed measures
to avoid or minimize those impacts. For the purpose of this Resource
Report, Project Area also refers to all temporary and permanent
construction work spaces, including the construction rights-of-way,
storage yards, staging areas, dredging areas, and any additional work
spaces that are required to construct the Project.

With respect to the General Conformity Rule (Title I, Section 176(c) of
the Clean Air Act (CAA), codified in 40 CFR Part 51, Subpart W and 40
CFR Part 93, Subpart B), the portions of the Project considered Federal
Actions are the Pipeline (subject to Federal Energy Regulatory
Commission (FERC) Section 7 Certificate of Public Convenience and
Necessity), the LNG Terminal (subject to a FERC Section 3
authorization), and dredging activities associated with the LNG Terminal
(subject to a U.S. Army Corps of Engineers (COE) permits pursuant to
Section 404 of the Clean Water Act and Section 10 of the Rivers and
Harbors Act). However, as further discussed in Section 9.3.3, the
portions of the LNG Terminal and the Power Plant (if constructed) that
will be subject to New Source Review permitting under the CAA (i.e., the
hot water heaters, emergency engines, combustion turbines, and vent
heater) are not subject to the General Conformity Review process.
Therefore, only direct and indirect emissions from construction and
operation of the Pipeline, construction of the LNG Terminal, and vessel
activity and indirect emissions during operation of the LNG Terminal are
subject to General Conformity Review.

## Air Quality

### Existing Air Quality

#### Climate/Meteorology

The Chesapeake Bay, Delaware Bay and the Atlantic Ocean farther to the
east generally give mild winters and summers to the portion of the
Project Area encompassing the LNG Terminal and much of the Pipeline.
Although some of the Pipeline is located further inland and would be
less moderated by the effects of the Chesapeake and Delaware Bays,
climatologically statistics for Baltimore are considered generally
representative of the climate of the entire Project Area.

According to the National Oceanic and Atmospheric Administration (NOAA),
typical January daily temperatures range from a minimum of 23.4 degrees
Fahrenheit (ºF) to a maximum of 40.2ºF for the Project Area. July
temperatures typically range from a minimum of 66.8ºF to a maximum of
87.2ºF. The record minimum and maximum temperatures are -7ºF and 105ºF,
respectively. Typical morning relative humidity ranges from a low of
about 70 percent in the winter to a high of about 85 percent in the
early fall. Afternoon relative humidity is generally about 55 percent.
The annual average precipitation is about 41 inches and is evenly
distributed throughout the year. About one-third of the days have
precipitation totaling 0.01 inches or more. Winter precipitation is
generally associated with sub-mesoscale weather systems. The average
snowfall is about 20 inches per year. Summer precipitation tends to be
associated with thunderstorms. During the summer, the region is
generally under the influence of the Bermuda high-pressure system.
High-pressure systems are typically associated with low winds and
increased potential for air quality problems.

The prevailing wind direction is generally from the west northwest in
the Baltimore area. A southwest component becomes evident in winds
during the warmer months while a northwest component is characteristic
of the colder months. Figure 9.3-1 is a wind rose plot that represents
wind direction and wind speed data compiled by the Baltimore-Washington
International Airport for 1992, the most recent year for which a dataset
is readily available (U.S. Environmental Protection Agency (EPA) SCRAM
Surface Archived Data (TD-1440)).

#### Ambient Air Quality Standards

EPA has established primary and secondary national ambient air quality
standards for certain air pollutant emissions, including carbon monoxide
(CO), lead, nitrogen dioxide (NO~2~), ozone, particulate matter less
than 10 microns (PM~10~), particulate matter less than 2.5 microns
(PM~2.5~) and sulfur dioxide (SO~2~), which are referred to under the
CAA as \"criteria pollutants.\" National Ambient Air Quality Standards
(NAAQS) have been established for each of the criteria pollutants.
Standards are designated as primary or secondary. Primary standards are
set at levels designed to protect public health. Secondary standards are
set to protect welfare values such as vegetation, visibility and
property values. States are free to adopt standards more stringent than
the NAAQS. Maryland and Pennsylvania have adopted all of the NAAQS.
Table 9.3-1 summarizes the NAAQS as well as the corresponding Maryland
and Pennsylvania Ambient Air Quality Standards.

#### Ambient Air Quality Attainment Status

The LNG Terminal is proposed to be located in Baltimore County,
Maryland. The Pipeline Route is proposed to be located within portions
of the Maryland counties of Baltimore, Harford and Cecil and the
Pennsylvania counties of Lancaster and Chester. Baltimore County and
Harford County are contained in the Metropolitan Baltimore Intrastate
Air Quality Control Region (AQCR 115). Cecil County is contained in the
Eastern Shore Intrastate AQCR (114). Lancaster County and Chester County
are located in two different AQCRs, the South Central Pennsylvania
Intrastate AQCR (196) and the Metropolitan Philadelphia Interstate AQCR
(045), respectively. The EPA has designated all four of these AQCRs as
being either in attainment with the NAAQS or unclassifiable/attainment
for certain criteria air pollutants, including SO~2~, CO, and NO~2~.
With respect to the one-hour ozone (O~3~) standard (revoked as of June
25, 2005), the Metropolitan Baltimore, Eastern Shore AQCR and the
Metropolitan Philadelphia AQCR are classified as severe-15
non-attainment, whereas the South Central Pennsylvania AQCR is
classified as marginal non-attainment. With respect to the new 8-hour
ozone standard, both of the Maryland AQCRs and the Metropolitan
Philadelphia AQCR are classified as moderate non-attainment. The South
Central Pennsylvania AQCR is classified as marginal non-attainment for
the new 8-hour ozone standard. All four Project Area AQCRs have either
not been classified or are unclassifiable/attainment for particulate
matter less than 10 micrometers (PM~10~) and lead (Pb). For PM~2.5~, all
of the Project Area AQCRs have been classified as non-attainment, with
the exception of the Eastern Shore AQCR, which is
unclassifiable/attainment.[^1] For Total Suspended Particulate (TSP),
portions of the Metropolitan Baltimore AQCR that potentially include
part of the Pipeline route have been classified as nonattainment.
Although portions of both Project-affected AQCRs in Pennsylvania have
been classified as not meeting secondary standards or cannot be
classified, the Pipeline will not pass through those portions of the PA
AQCRs. The Eastern Shore AQCR in Maryland has been classified as better
than national standards with respect to TSP. Although TSP attainment
designations are listed in 40 CFR 81, there no longer are TSP NAAQS and
TSP-directed State Implementation Plan (SIP) programs. EPA revised the
primary and secondary NAAQS for particulate matter on July 1, 1987 by
eliminating TSP as the indicator for the NAAQS and replacing it with the
PM~10~ indicator. Table 9.3-2 summarizes the attainment status for each
of the AQCRs included in the Project Area.

Because each of the Project Area AQCRs is classified as non-attainment
with respect to the old one-hour ozone standard and had 1-hour design
values greater than or equal to 0.121 ppm, they are categorized as
\"subpart 2\" non-attainment with respect to the new 8-hour ozone
standard. As such, each of the AQCRs is subject to specific requirements
that must be incorporated into State Implementation Plans (SIP) for
attaining the national ozone air quality standards. In addition,
Maryland and Pennsylvania are considered part of the Ozone Transport
Region (OTR). The OTR encompasses eleven northeast states and the
District of Columbia, all of which have at least some areas not meeting
the NAAQS for ozone. Because ozone attainment is a region-wide problem
involving interstate transport of ozone precursors, projects locating in
all areas within the OTR must meet more stringent non-attainment new
source review requirements. The applicable emissions thresholds
triggering major new source review in the Metropolitan Baltimore
Intrastate AQCR are 25 tons per year (TPY) for either volatile organic
compounds (VOC) or nitrogen oxides (NO~X~). New stationary sources with
the potential to emit VOC or NO~X~ above these thresholds would be
classified as Major Stationary Sources subject to more stringent
Non-attainment New Source Review (NNSR) requirements.

#### Existing Ambient Air Quality Monitoring Data

Maryland Department of the Environment (MDE) and Pennsylvania Department
of Environmental Protection (PDEP) monitor ambient concentrations of
certain criteria pollutants at a number of monitoring stations located
in the Project Area AQCRs. The monitored data, which are available from
EPA's AirData website (http://www.epa.gov/air/data/reports.html), were
evaluated to determine representative air quality levels for the Project
Area. Monitoring stations with closest proximity to the Project Area are
located in Baltimore County, Harford County, and Cecil County in
Maryland and in Lancaster, Chester, Delaware and Montgomery Counties in
Pennsylvania. Table 9.3-3 summarizes the most recent three-year averages
of the data available from monitoring stations with the most
representative locations within the Project Area. The assumptions used
in developing the most representative three-year average concentrations
are also detailed in Table 9.3-3. The monitoring data demonstrates that
all monitored pollutants are meeting the NAAQS, with the exception of
one-hour and 8-hour average ozone concentrations in all four Project
Area AQCRs and annual average PM-2.5 concentrations in Baltimore County
in Maryland and Chester and Lancaster Counties in Pennsylvania.

### Estimated Emissions from the Project

Air pollutant emissions will result from construction of the proposed
Pipeline facilities, and from construction and operation of the proposed
LNG Terminal and nonjurisdictional facilities related to the LNG
Terminal (Power Plant). Emissions due to construction activities
associated with the Pipeline and LNG Terminal would result in temporary
increases in fugitive dust (PM~10~ and PM~2.5~) from disturbed soils, as
well as criteria pollutants (CO, NO~X~, SO~2~, PM~10~, PM~2.5~ and VOCs)
and some hazardous air pollutants (HAPs) from diesel and gasoline
powered construction equipment. Because EPA estimates that PM~2.5~
comprises 97 percent of particulate matter from diesel and gasoline
powered construction equipment and mobile sources, PM~2.5~, PM~10~ and
TSP are assumed to be equivalent for regulatory applicability
determination purposes. The same conservative assumption was used to
estimate PM~2.5~ emissions from combustion sources proposed for the
operational phase of the LNG Terminal and Power Plant, based on similar
EPA estimates (PM~2.5~ typically comprises greater than 90 percent of
combustion source PM~10~ and TSP emissions). In addition, ammonia
emissions have been estimated for construction and operational phase
equipment based on available emission factors as a PM~2.5~ precursor, in
order to address the potential that future SIP revisions to establish
control measures in PM~2.5~ nonattainment areas may require use of
precursor ammonia emissions for New Source Review and General Conformity
determinations.

Additional construction-related emissions would result from dredging
activities needed to expand the ship approach channel and turning basin
to support proposed marine terminal operations at the LNG Terminal.
Should the nonjurisdictional Power Plant be built, additional emissions
would result from construction activities during the construction period
for that facility. These additional construction emissions are addressed
separately in this section. Fugitive dust and other emissions from
construction activities generally do not contribute significantly to
increases in regional pollutant levels. However, the short-term effects
of construction emissions will be addressed in the General Conformity
Analysis, if applicable (see Section 9.3.3.10), to ensure compliance
with the respective SIPs in Maryland, Pennsylvania, and Virginia.

There will be no significant emissions resulting from the operation of
the proposed Pipeline because no compression facilities will be
installed. Emissions from operation of the LNG Terminal would primarily
involve criteria pollutants and HAPs from operation of the High
Temperature Fluid (HTF) heating system used to provide heat to the LNG
vaporizers and from LNG ship auxiliary power systems used during
offloading of LNG to the Terminal. Emissions will also result from
operation of emergency diesel engine powered fire water pumps, a diesel
engine powered standby electricity generator and other minor auxiliary
combustion equipment. Maintenance dredging activities would result in
periodic emissions, typically occurring over an approximately one-month
period at three-year intervals during the operational phase of the
Project. Additional emissions would result from operation of the
nonjurisdictional Power Plant, which would include an approximately
300-MW combined cycle cogeneration power plant at the Terminal Site.[^2]
Descriptions of construction activities and operational phase stationary
sources associated with each Project component are provided below along
with summaries of estimated emissions. Mobile source emissions
associated with marine vessels used during the LNG Terminal operation,
including LNG ship movements and hoteling, assist tug boats and U.S.
Coast Guard (USCG) escort and patrol boats, are also estimated and
discussed under LNG Terminal operations. Assumptions and detailed
emissions calculations are provided in Appendix 9A.

Emissions from construction and operation of the LNG Terminal, dredging
activities and Power Plant (if constructed) will occur entirely in
Maryland. Emissions from construction of the Pipeline will occur both in
Maryland and Pennsylvania. The distribution between Pipeline
construction emissions in Maryland and Pennsylvania is discussed in
Section 9.3.2.1. The potential for emissions from operation of the LNG
Terminal and Power Plant to result in ambient air quality impacts in
Maryland and certain downwind states is evaluated in Section 9.3.5.

#### Pipeline

##### Construction Emissions

The use of equipment to construct the Pipeline will result in temporary,
short-term emissions of certain air pollutants. These emissions will be
restricted to the construction period for the Pipeline and will
terminate once construction has been completed. Fugitive dust emissions
also may occur during construction, post-construction mitigation and
maintenance activities. These emissions will not result in significant
adverse impacts to the air quality within the vicinity of the Project
Area, and AES will not be required to obtain any federal, state, or
local authorizations for the temporary, short-term air pollutant
emissions that will be associated with construction of the Project.
Fugitive dust control measures, if required, will be implemented during
construction and operation of the Pipeline and are discussed in Section
9.3.6.

During construction of the Pipeline, the use of internal combustion
engines in trucks, dozers, trenchers, cranes, generators, compressors,
drilling rigs, pumps, other miscellaneous heavy construction equipment,
and worker commuting vehicles will result in emissions of NO~X~, SO~2~,
CO, PM~10~, PM~2.5~, VOC and HAPs. These emissions will not be
concentrated within any particular location of the Project Area. The
duration of the main construction period for the Pipeline will be about
10 to 12 months; therefore, the period during which air pollutant
emissions will occur in any particular location of the Project Area will
be substantially less than the total construction period. For example,
AES anticipates that Pipeline construction will progress at a rate of
approximately six to eight weeks per mile (from clearing through final
restoration). From a receptor basis, exposure to emissions from Pipeline
construction activities would occur at any one location for only the
limited period during which construction is active in the vicinity of
the receptor.

Fugitive dust emissions from activities such as grading, trenching,
backfilling, and vehicle traffic, will occur during construction
periods. Prior to revegetation of disturbed soil areas within the
Project Area, wind erosion of displaced soil may also generate fugitive
dust emissions. AES will use the mitigation measures identified in
Section 9.3.6 of this Resource Report to minimize the fugitive dust
emissions associated with construction of the Pipeline. These measures
may include the application of water or dust suppressants, covering of
haul trucks, use of paved roads to the extent possible, limiting vehicle
speed and stabilizing disturbed areas.

AES has estimated the actual emissions of criteria air pollutants that
will be associated with construction of the Pipeline based on the
assumptions and detailed calculations provided in Appendix 9A of this
Resource Report. AES\'s assumptions concerning the types, numbers and
operating schedules for the various construction equipment and
activities are based on information provided by potential construction
contractors for the Pipeline. Construction equipment will typically
include various combinations of cranes, backhoes, dozers, trenching
machines, graders and similar equipment. As required, horizontal
drilling rigs will also be used for installation of the Pipeline at
certain river and stream crossings. Emissions were estimated based on
the typical maximum number of major equipment types that may be in
operation at any one time. For the purpose of this analysis, all
equipment was assumed to be powered by diesel compression ignition (CI)
engines, as is typical for this type of equipment. Use of low-sulfur
diesel oil with a sulfur content of 0.05 weight percent (500 ppm) was
assumed, due to the fact that construction would begin after the
effective date (June 2007) for EPA's nonroad engine diesel fuel sulfur
standards applicable to all land-based nonroad, locomotive and marine
engine diesel fuel. Emission factors (grams of pollutant per brake
horsepower-hour) were derived using EPA procedures in \"Exhaust Emission
Factors for Nonroad Engine Modeling--Compression Ignition\" (June 15,
1998 and revised April 2004), which also is the basis for EPA's "NONROAD
Emissions Inventory Model" (draft June 8, 2000). Emission factors were
multiplied by typical in-use adjustment factors, also based on EPA's
non-road model, and by the estimated horsepower (\"HP\") for each type
of equipment that will be used to construct the Pipeline.

AES has calculated conservatively high estimates of the actual emissions
that will be associated with construction of the Pipeline. The emissions
estimates were calculated using emissions factors that are based on
1988-1996 model year engines. Engines for those years are anticipated to
have higher actual emissions than current model year engines because the
older engines are not subject to Tier 1, 2 or 3 emissions standards.[^3]

Indirect emissions were also estimated from motor vehicles associated
with workers commuting to and from the construction locations of the
Pipeline. Some commuting will also occur from inspection and maintenance
crews traveling to and from the Project Area during the Project's
operational phase, but will be significantly less than during the
construction phase. Emissions were conservatively estimated based on the
assumptions and calculations presented in Appendix 9A. A total of 80
workers conservatively were assumed to commute to the Pipeline
construction sites (two pipeline construction spreads) each day for a
total of 180 days. Emission factors were obtained from EPA AP-42,
Appendix J (1998) for light duty gasoline vehicles and trucks.

Table 9.3-4 summarizes the estimated emissions from construction
equipment including indirect emissions from material hauling trucks and
commuting construction workers. Emissions are summarized in total tons
during each year of the construction period by AQCR in the Maryland and
Pennsylvania portions of the Pipeline, by state, and for the entire
Pipeline construction project. As is typical of emissions from diesel
engines, actual emissions rates for pollutants SO~2~, PM~10~, PM~2.5~
and VOC are significantly lower than NO~2~ and CO emissions.

Based on this analysis, direct emissions from construction equipment,
indirect emissions from commuting construction workers and fugitive dust
emissions are not expected to significantly affect ambient air quality
in the Project Area. These emissions and impacts will be restricted to
the construction period, approximately 12 months, for the Pipeline, and
will terminate once construction has been completed. In addition, the
emissions will not be concentrated for any extended period within any
particular location along the Pipeline Route.

##### Operational Emissions

The operation of the Pipeline also will not result in any adverse
impacts to local ambient air quality, and AES will not be required to
obtain any federal, state, or local air quality authorizations for the
operation of the Pipeline. As previously stated, the Pipeline will not
involve the construction of new or modification of existing stationary
sources of air pollutant emissions in Maryland or Pennsylvania, such as
a compressor station. Limited fugitive dust emissions may occur during
periodic inspection or maintenance of the pipeline, particularly where
maintenance vehicles will travel on unpaved access roads. However, these
fugitive dust emissions will be minimal and will not have an adverse
impact on the local ambient air quality.

#### LNG Terminal

##### Construction Emissions

The use of equipment to construct the LNG Terminal will result in
temporary, short-term emissions of air pollutants that will be
restricted to the construction period for the LNG Terminal and will
terminate once construction has been completed. These emissions will not
result in significant adverse impacts to the air quality within the
vicinity of the Project Area, and AES will not be required to obtain any
federal, state, or local authorizations for the temporary, short-term
air pollutant emissions that will be associated with construction of the
LNG Terminal. Fugitive dust control measures, if required to be
implemented, are discussed in Section 9.3.6.

LNG Terminal construction activities can generally be categorized into
demolition, site preparation, terminal process construction, LNG tank
construction, and marine pier rehabilitation activities. Dredging and
reclamation activities associated with expansion of the LNG ship
approach channel and turning basin are also associated with LNG Terminal
construction, but are described separately in Section 9.3.2.3. During
construction activities associated with the LNG Terminal, the use of
internal combustion engines in various cranes, backhoes, dozers,
loaders, pavers, trucks, welders, generators, air compressors, pumps,
pile drivers, other miscellaneous heavy construction equipment, and
worker commuting vehicles will result in emissions of NO~X~, SO~2~, CO,
PM~10~, PM~2.5~, VOC and HAPs. The duration of the main construction
period for the LNG Terminal will be about 32 to 36 months.

Fugitive dust emissions from activities such as demolition, site
preparation, grading and vehicle traffic, will occur during construction
periods. Prior to paving or revegetation of disturbed soil areas within
the Project Area, wind erosion of displaced soil may also generate
fugitive dust emissions. AES will use the mitigation measures identified
in Section 9.3.6 of this Resource Report to minimize the fugitive dust
emissions associated with construction of the LNG Terminal. These
measures may include the application of water or dust suppressants,
covering of haul trucks, use of paved roads to the extent possible,
limiting vehicle speed and stabilizing disturbed areas.

AES has estimated the actual emissions of criteria air pollutants and
HAPs that will be associated with construction of the LNG Terminal based
on the assumptions and detailed calculations provided in Appendix 9A of
this Resource Report and as summarized in Section 9.3.2.1. AES\'s
assumptions concerning the types, numbers and operating schedules for
the various construction equipment and activities are based on
information provided by construction contractors being considered for
the Project.

Indirect emissions were also estimated from motor vehicles associated
with workers commuting to and from the LNG Terminal construction site.
Emissions were conservatively estimated based on the assumptions and
calculations presented in Appendix 9A. A total of 200 workers were
assumed to commute to the LNG Terminal construction site by light duty
gasoline vehicles each day for a total of 32 months. Four school buses
were also assumed to transport workers from a parking area located
within 1.5 miles from the site for a duration of 36 months. Emission
factors were obtained from EPA AP-42, Appendix J (1998) for light duty
gasoline vehicles and trucks.

Table 9.3-4 summarizes the estimated emissions from construction
equipment including indirect emissions from commuting construction
workers associated with LNG Terminal construction. Emissions are
summarized in total tons during each year of the construction period.
All emissions will occur in Baltimore County in AQCR 115.

Based on this analysis, direct emissions from construction equipment,
indirect emissions from commuting construction workers, and fugitive
dust emissions are not expected to significantly affect ambient air
quality in the Project Area. These emissions and impacts will be
restricted to the construction period for the LNG Terminal,
approximately 36-months, and will terminate once construction has been
completed.

##### Operational Emissions

As discussed in Section 9.3.2, operation of the LNG Terminal will
involve the use of a HTF heating system to provide heat to the LNG
vaporizers. The HTF heating system will consist of four installed
natural gas-fired hot water heaters. Under normal operation, three hot
water heaters will be operating and one will be placed in hot standby
condition using a heating coil. The hot water heaters will typically be
rotated once per week to obtain even run time for each heater throughout
the year. If AES decides to construct and operate the Power Plant both
to provide heat to the LNG vaporizers and generate electricity for the
local utility electric system, the combined cycle Power Plant would
operate in lieu of or in conjunction with the hot water heaters,
depending on the operating scenario. Operational emissions associated
with the nonjurisdictional Power Plant are addressed separately in
Section 9.3.2.4. Another minor source of PM~10~ and PM~2.5~ emissions
only associated with the Power Plant is a cooling tower that would run
when there is insufficient LNG gas flow (sendout) to provide cooling for
the Power Plant Rankine cycle and the decision is made to nonetheless
operate the Power Plant. Such operation would be intermittent.

Based on the results of preliminary engineering design, four hot water
heaters are proposed for installation at the LNG Terminal to provide
heat required for LNG vaporization as part of the HTF heating system.
Three of the hot water heaters would normally be operated for the
equivalent of up to 8,760 hours per year at up to 100 percent rated
capacity with the fourth hot water heater operated in hot standby using
a heating coil. Each hot water heater would be rated at 345 million
British thermal units per hour (MMBtu/hr) maximum heat input and will be
fueled exclusively with natural gas. It was assumed that there would be
two catalyst malfunctions per hot water heater per year, lasting 48
hours each, resulting in uncontrolled emissions. Furthermore, it was
assumed that each hot water heater would undergo three cold iron
startups per year, each lasting one hour at an average of 15 percent
load before controls were effective. This was the operating scenario
used as a basis for the estimated short-term and annual potential
emissions. Table 9.3-5 summarizes maximum emission rates for the hot
water heaters based on these assumptions. Criteria pollutant emissions
factors were based on a review of recent Best Available Control
Technology (BACT) and Lowest Achievable Emission Rate (LAER)
determinations for similar types and sizes of natural gas-fired hot
water heaters, and from preliminary emissions guarantees from potential
vendors. The emissions control systems would include low-NO~X~ burners
and/or flue gas recirculation for preliminary NO~X~ control, selective
catalytic reduction (SCR) for final NO~X~ control, and oxidation
catalysts for CO control.

Minor and intermittent emission sources at the LNG Terminal, which will
only operate in the event of an emergency or electrical power
interruption, include several small diesel reciprocating engines used
for emergency fire water pumping and standby electricity generation.
Based on preliminary engineering, one 375 HP diesel engine driven
freshwater fire water pump and six 700 HP diesel engine driven salt
water fire water pumps are specified. In addition, one 2,000 kW diesel
engine driven emergency generator set is specified, capable of providing
100 percent standby power to maintain LNG circulation via operation of
one low pressure (LP) pump, terminal lighting, and all control systems,
and provide for the operation of all other necessary auxiliary systems.
The assumed worst-case operating scenario for these emergency standby
engines is 60 hr/yr per engine to conduct periodic testing and to allow
for an emergency event. Emissions were estimated based on engine
manufacturer performance and emissions data provided by Caterpillar,
Inc. for criteria pollutants other than SO~2,~ and on EPA AP-42 emission
factors for SO~2~ and hazardous air pollutants (see Appendix 9A). Short
term and annual emissions rates for the diesel engines are summarized in
Table 9.3-5.

In addition to the hot water heaters, fire water pumps and emergency
standby generator, a heated vent stack will be installed at the LNG
Terminal, which will only be used to heat boil off vapors from the LNG
Terminal if a power failure renders the vapor handling systems
inoperable. The heated vent stack will be a small (5.5 MMBtu/hr) natural
gas-fired combustion source and is assumed to operate no more than 50
hours per year. Emissions from the heated vent stack were estimated
based on vendor emission factors (see Appendix 9A) and are summarized in
Table 9.3-5.

Emissions from each of the LNG Terminal sources are summarized in Table
9.3-5 in comparison to major stationary source thresholds. For the
purposes of the major stationary source applicability determination, as
further discussed in Section 9.3.3.1, total potential emissions
associated with operation of the LNG Terminal include the combination of
emissions from stationary sources at the LNG Terminal with emissions
from LNG ships associated solely with LNG offloading activities while
the LNG ships are at berth. Assumptions used in estimating emissions
from LNG ships during offloading activities are further described in
Section 9.3.2.2.C. This analysis demonstrates that potential emissions
will be less than EPA major stationary source thresholds for each
regulated pollutant, with the exception of ozone precursor NO~X~
emissions. Therefore, as discussed in Section 9.3.3.1, the LNG Terminal
will be a major source with respect to NO~X~ emissions in an ozone
nonattainment area, and will be subject to NNSR permitting requirements.
The LNG Terminal will be considered a minor source with respect to VOC
and all attainment pollutants and, therefore, will not be subject to
NNSR for VOC or Prevention of Significant Deterioration (PSD) review for
any attainment pollutants.

As discussed in Section 9.3.3.1, AES will seek MDE permits for
construction of the emission sources and for NNSR approvals, as
applicable, to obtain enforceable limitations on potential emissions.
AES will seek permit limits on the number of operating hours and annual
diesel consumption for the emergency fire pumps and standby generator.
AES will also seek enforceable permit limitations to construct and/or
the NNSR approval for the hot water heaters to limit annual operations
and emissions from LNG ship offloading activities. AES will work with
MDE during the permitting process to develop permit conditions that will
be practically enforceable with LNG shippers.

##### Marine Vessel Emissions

Marine vessels used during LNG Terminal operation include LNG ships,
assist tugboats, security boats and USCG escort boats. For the purposes
of conservatively estimating marine vessel emissions, the estimated
annual emissions from these mobile sources are based on up to 180 LNG
ship arrivals of various capacity ships; three tug boats, and two
security or escort boats participating in the arrival, berthing and
departure of each LNG ship; and emissions during LNG offloading and
idling while stationary at berth (hoteling). AES estimates that LNG
ships will arrive at the Terminal Site with a typical frequency of two
to three ships per week depending on the capacity of the ship). Each
ship will remain stationary at the berth for a maximum of 24 hours,
about 12 to 18 hours of which will involve LNG transfer, depending on
the capacity of the ship and an average unloading rate of about 11,500
cubic meters per hour.

As discussed in Sections 9.3.2.2.B and 9.3.3.1, emissions from LNG ship
offloading operations have been combined with potential emissions from
stationary sources at the LNG Terminal for purposes of determining PSD
and NNSR permit applicability. Therefore, emissions from LNG offloading
operations were calculated separately from all other LNG ship and
associated marine vessel activity.

AES obtained information concerning the type of propulsion, power
generation, fuel types, operating scenarios and other parameters
necessary to estimate emissions during transit in Virginia and Maryland
state waters, and during berthing, hoteling and unloading activities at
the LNG Terminal. Based on this information, the current fleet of LNG
ships (182 within AES's design range of 125,000 to 217,000 cubic meter
capacity) exclusively run on conventional steam-electric power plants
for both propulsion and auxiliary power and are fueled with boil-off gas
or of heavy fuel oil. AES has also determined that there are currently
117 LNG ships on order or under construction within AES's design
capacity envelope for the LNG Terminal. These consist of 61 (52 percent)
steam powered ships and 57 (48 percent) ships that are powered by slow
speed or medium speed diesel engines for propulsion and auxiliary power.
The diesel engines can be fueled with low sulfur distillate (1.5 percent
sulfur), heavy fuel oil (2.7 percent sulfur) or dual fuel mixtures
(e.g., Marine Gas Oil (MGO,) typically consisting of 90 to 95 percent
natural gas and 5 to 10 percent low sulfur oil). Because AES will not
own or operate the LNG ships that will deliver LNG to the LNG Terminal,
a number of different power plant and fuel scenarios were evaluated in
order to conservatively estimate the range of emissions to be expected
from LNG ship movements and transfer operations. The scenarios evaluated
ranged from natural gas fired steam-electric power plants to diesel
engines firing 2.7 percent sulfur heavy fuel oil. An assumed mix of
technologies and fuels was then used to estimate annual emissions, based
on AES's evaluation of the representative levels of technologies and
fuels currently in use and projected to be in use in the LNG shipping
industry. Different sets of assumptions were also used to estimate
emissions from LNG offloading and hoteling operations at the LNG
Terminal and for LNG ships transiting in state waters. Detailed
assumptions used for all calculations are summarized in Appendix 9A. AES
believes these are conservative assumptions; however, the assumptions
may need to be refined in the future based on actual shipping
assignments and/or availability, actual ship operating conditions, and
trends in the industry for the various sizes of LNG ships.[^4]

It should be noted that EPA's nonroad engine diesel fuel sulfur
standards were not factored into this analysis for the LNG tanker ships
because the standards are not applicable to non-U.S. flagged ocean going
vessels. However, EPA's nonroad engine diesel fuel sulfur standards were
factored into the analysis of emissions from assist tug boats, as these
are U.S. flagged vessels that are subject to the EPA nonroad engine
diesel fuel sulfur standards. The applicable limits for marine diesel
engines are 500 ppm sulfur (0.05 percent) beginning June 1, 2007, and 15
ppm sulfur (0.0015 percent) beginning June 1, 2012.

The emission estimates based on the current assumptions and EPA emission
factors are presented in Appendix 9A, and the results are summarized in
Table 9.3-5. As discussed above, emissions from LNG ship unloading
operations are summed with LNG Terminal stationary sources for the major
source applicability determination. Estimates of annual emissions from
all marine vessel movements associated with LNG ship arrival, berthing,
and departure are separately summarized in Table 9.3-5, including a
breakdown by state for LNG ship and associated marine vessel movements
in Maryland and Virginia state waters for determining General Conformity
applicability.

#### Dredging and Reclamation

##### Construction Emissions

The LNG Terminal construction includes widening and deepening the
existing approach channel and turning basin at Sparrows Point to
accommodate the LNG ships. Dredging related construction activities
include both onshore and offshore equipment and processing. Onshore
activities include start-up and dredged material transfer and processing
operations, involving typical construction equipment, such as cranes,
backhoes, excavators, loaders, trucks and sweepers. Internal combustion
engines used to power this equipment will result in temporary emissions
of NO~X~, SO~2~, CO, PM~10~ and VOC. A dredged material recycling
facility (DMRF), as described in Section 1.5.1.2.A of Resource Report 1,
*General Project Description*, will also be constructed and operated at
the construction site, involving use of hoppers, conveyors, pug mills
for mixing additives, and stacking equipment. Pug mills and the additive
delivery system will be equipped with separate baghouse dust collectors
to control PM~10~ and PM~2.5~ emissions. Marine vessels and equipment
used for offshore dredging activities will include a clamshell dredge or
suitable alternative required by permit, in addition to tug boats,
survey/work boats, crew boats and inspecting/diving vessels. Diesel
engines used to power these vessels and the dredge will result in
temporary emissions of NO~X~, SO~2~, CO, PM~10~ and VOC. Indirect
emissions will also result from transfer of the processed dredged (PDM)
offsite with dump trucks and from workers commuting to the Terminal
Site. The duration of the dredging activities at the LNG Terminal has
been estimated at about two years.

AES will use the mitigation measures identified in Section 9.3.6 and
Appendix 9D, Fugitive Dust Suppression and Monitoring Plan, of this
Resource Report to minimize the fugitive dust emissions associated with
transfer of the PDM once it has been processed in the DMRF. These
measures may include the application of water or dust suppressants,
covering of haul trucks, use of paved roads to the extent possible,
limiting vehicle speed and stabilizing disturbed areas.

AES has estimated the actual emissions of criteria air pollutants
associated with dredging related activities at the LNG Terminal based on
the assumptions and calculations provided in Appendix 9A of this
Resource Report and as summarized in Section 9.3.2.1. AES\'s assumptions
concerning the types, numbers and operating schedules for the various
construction equipment, marine vessels and activities are based on
information provided by construction contractors being considered for
the Project.

Indirect emissions were also estimated from motor vehicles associated
with workers commuting to and from the LNG Terminal construction site
associated with dredging activities and from haul trucks and additive
supply trucks. Emissions were conservatively estimated based on the
assumptions and calculations presented in Appendix 9A. A total of 15
workers were assumed to commute to the LNG Terminal construction site by
light duty gasoline vehicles each day for a total of 24 months. A total
of 218 haul trucks and 27 additive supply trucks per day were assumed
for 276 days per year during the two-year dredging duration. Emission
factors were obtained from EPA AP-42, Appendix J (1998) for light duty
gasoline vehicles and trucks and heavy duty diesel haul and supply
trucks.

Table 9.3-4 summarizes the estimated emissions from construction
equipment, marine vessels, and material processing and indirect
emissions from PDM hauling and commuting construction workers associated
with dredging activities. Emissions are summarized in total tons during
the construction period. The estimated actual emissions of NO~2~ and CO
from the use of diesel CI engines in dredging related equipment over the
construction period are 268 and 83 tons, respectively. As is typical of
emissions from diesel engines, actual emissions rates for other
pollutants (SO~2~, PM~10~ and VOC) are significantly lower than NO~2~
and CO emissions.

To assess qualitatively the potential for odors and inhalation of
dredged sediments due to dredging and processing of the sediments, AES
obtained information from Clean Earth Dredging Technologies Inc.
(CEDTI), with whom AES is considering contracting for the dredging work
associated with the LNG Terminal. In CEDTI's experience, the dredged
material may appear (visually) to have a high organic content. However,
typical Total Organic Carbon results are around three to five percent.
Further, the odor of raw dredged material is minimal and not pervasive.
At the dredging site, the processing site and the storage/end use sites
there will be very little odor. The potential for ammonia odors exists
at the DMRF due to the addition of alkaline materials into the dredged
sediments, but this odor will dissipate rapidly and only be noticeable
within feet of the processed material. For example, CEDTI operates its
Jersey City, New Jersey processing facility within 1,000 feet of
high-end condominiums near Manhattan and has never received a complaint
or even a comment from neighbors or local regulators. Likewise, no
complaints have been made at any of CEDTI's end use sites. CEDTI does
not employ any odor suppression techniques at any of its current
facilities. Furthermore, CEDTI indicates that it is not aware of any
quantitative information available to estimate ammonia emissions from
operation of the DMRF. Therefore, the potential for ammonia emissions
from the proposed DMRF could not be evaluated quantitatively.

The majority of materials handled in the DMRF will be high
moisture-content dredged materials with little potential for dust
emissions. Dry additive filling, storage and transfer equipment will be
contained in enclosed structures with baghouse dust collectors for
high-efficiency dust control. As a result, PM~2.5~/PM~10~ emissions from
the DMRF will be negligible, with uncontrolled emissions currently
estimated at less than 1 TPY. Based on estimated uncontrolled
PM~2.5~/PM~10~ emissions, an Air Quality Permit to Construct will not be
required prior to construction of the DMRF additive material storage,
transfer, mixing and dust control equipment.

Based on this analysis, direct emissions from dredging activities,
indirect emissions from haul trucks and commuting construction workers,
and fugitive dust emissions, are not expected to significantly affect
ambient air quality in the Project Area. These emissions and impacts
will be restricted to the construction period, approximately 36 months,
for the LNG Terminal and will terminate once construction has been
completed.

##### Operational Emissions

Based on information provided by CEDTI, post-construction maintenance
dredging activities would result in periodic emissions, typically
occurring over an approximately one-month period at three-year intervals
during operation of the LNG Terminal. Estimates of emissions from
maintenance dredging activities are included in Appendix 9A and
summarized in Table 9.3-5. In addition, for a period of approximately 12
months following completion of the LNG Terminal construction, emissions
from transport of PDM to end-use sites will occur. This transportation
was factored into the overall emissions estimates for the DMRF.

#### Nonjurisdictional Facilities -- Power Plant

##### Construction Emissions

Any construction activities, equipment and emissions associated with the
Power Plant will be similar to those described in Section 9.3.2.2.A for
construction of the LNG Terminal. The use of equipment to construct the
Power Plant would result in temporary, short-term emissions of air
pollutants that would be restricted to the construction period for the
Power Plant and that would terminate once construction has been
completed. These emissions would not result in significant adverse
impacts to the air quality within the vicinity of the Project Area, and
AES would not be required to obtain any federal, state, or local
authorizations for the temporary, short-term air pollutant emissions
that will be associated with construction of the Power Plant. Fugitive
dust control measures, if required to be implemented, are discussed in
Section 9.3.6.

As with construction of the LNG Terminal, construction activities
associated with the Power Plant would involve the use of internal
combustion engines in various cranes, backhoes, dozers, loaders, pavers,
trucks, welders, generators, air compressors, pumps, pile drivers, and
other miscellaneous heavy construction equipment. These engines and
worker commuting vehicles would result in emissions of NO~X~, SO~2~, CO,
PM~10~ and VOC. The duration of the main construction period for the
Power Plant would be about 20 to 24 months.

The potential for fugitive dust emissions during construction periods
would be the same as discussed for the LNG Terminal construction. AES
would use the mitigation measures identified in Section 9.3.6 of this
Resource Report to minimize the fugitive dust emissions associated with
construction of the LNG Terminal.

AES has estimated the actual emissions of criteria air pollutants and
HAPs that would be associated with construction of the Power Plant,
based on the assumptions and detailed calculations provided in Appendix
9A of this Resource Report and as summarized in Section 9.3.2.1. AES\'s
assumptions concerning the types, numbers and operating schedules for
the various construction equipment and activities are based on
information provided by construction contractors being considered for
the Power Plant.

Table 9.3-4 summarizes the estimated emissions from construction
equipment potentially associated with the Power Plant construction.
Emissions are summarized in total tons during each year of the
construction period. All emissions would occur in Baltimore County in
AQCR 115.

Based on this analysis, direct emissions from construction equipment,
indirect emissions from commuting construction workers, and fugitive
dust emissions, are not expected to significantly affect ambient air
quality in the Project Area. These emissions and impacts would be
restricted to the construction period, approximately 24 months, for the
Power Plant and would terminate once construction has been completed.

##### Operational Emissions

If constructed and operated, the combined cycle Power Plant would
operate in lieu of or in conjunction with the hot water heaters,
depending upon the operating scenario. The Power Plant would be
configured with one combustion gas turbine (CGT) with a duct-fired heat
recovery steam generator (HRSG), which would operate only on natural
gas, and associated steam electric turbine and other auxiliary
facilities that are not sources of potential emissions. The output of
the Power Plant would be approximately 300 MW. The Power Plant would
require a gas supply from the LNG Terminal and installation and
operation of transmission lines to tie into the local utility system.
Another minor source of PM~10~ and PM~2.5~ emissions associated only
with the Power Plant would be a cooling tower, which would run
intermittently when there is insufficient LNG gas flow (sendout) to
provide cooling for the Power Plant Rankine cycle but the Power Plant
continues to operate.

AES is currently evaluating two alternate gas turbine vendors for supply
of major Power Plant components. Based on the results of preliminary
engineering design, a General Electric (GE) 7FA CGT and a Siemens
SGT6-5000 CGT are being considered. While performance specifications,
emissions, and controls are similar for each CGT, information for the
Siemens SCT6-5000 was used for emissions estimation purposes to provide
a more conservative analysis. The base case operating scenario involves
operation of the CGT with auxiliary duct firing in the HRSG at 100
percent loads for 8,760 hours per year and one of the LNG Terminal hot
water heaters running at idle standby (25 percent load). The alternate
operating scenario involves the CGT at 100 percent load, unfired HRSG,
one hot water heater at 100 percent load, and one hot water heater at
idle standby for 20 percent of the year with the base case operating
scenario for 80 percent of the year. The CGT and auxiliary burner in the
HRSG would be rated at maximums of 2,089 and 271 MMBtu/hr (LHV),
respectively. It is assumed that there would be two catalyst
malfunctions per year in the HRSG and hot water heater, lasting 48 hours
each, resulting in uncontrolled emissions. Furthermore, it was assumed
that the CTG/HRSG and hot water heaters would undergo three cold iron
startups per year with 300 minutes duration each. These operating
scenarios were used as the basis for the estimated short-term and annual
potential emissions from the Power Plant. Table 9.3-5 summarizes maximum
emission rates for the Power Plant based on these assumptions. Criteria
pollutant emissions factors were based on a review of recent BACT and
LAER determinations for similar types and sizes of natural gas fired
CTGs with HRSGs and from preliminary emissions guarantees from potential
vendors. The proposed emissions control systems would include dry
low-NO~X~ combustors (DLN) for initial NO~X~ control in the CTG, SCR for
final NO~X~ control and oxidation catalysts for CO control. The
emissions analysis demonstrates that potential emissions from the LNG
Terminal with Power Plant, when combined with potential emissions from
the LNG ship offloading operations, would be greater than EPA major
stationary source thresholds for NO~X~, VOCs and CO. Accordingly, the
LNG Terminal with the Power Plant will be required to undergo NNSR for
NO~X~ and VOCs and PSD review for NO~2~ and CO[^5].

The same minor and intermittent emission sources identified in Section
9.3.2.2.B associated with the LNG Terminal will still be associated with
the LNG Terminal if the Power Plant is constructed. Again, these sources
will only operate in the event of an emergency or electrical power
interruption, and include several small diesel reciprocating engines
used for emergency fire water pumping and standby electricity
generation. In addition, the heated vent stack discussed in Section
9.3.2.2.B will still be associated with the LNG Terminal if the Power
Plant is constructed.

### Air Quality Regulatory Requirements

The proposed Project would generate air emissions through both
short-term construction activities and long-term operation of the
stationary sources associated with the LNG Terminal and, if applicable,
the Power Plant. Emissions from all phases of construction and operation
of the Project would be subject to applicable federal and state air
regulations. This section evaluates applicability of specific air
regulations to emissions units and activities associated with the
Project.

#### New Source Review Requirements 

The NSR provisions of the CAA apply to new Major Stationary Sources or
Major Modifications to Major Stationary Sources under two separate
programs. For sources located in areas designated as attaining the
Ambient Air Quality Standards, with respect to a specific regulated
criteria pollutant, the requirements of the PSD program (40 CFR § 52.21)
apply. For Major Stationary Sources located in areas that do not attain
the Ambient Air Quality Standards, the requirements of the NNSR Program
(40 CFR Parts 51 and 52) apply to each non-attainment pollutant. The LNG
Terminal and Power Plant (if built) will involve construction and
operation of a new stationary source in Maryland. Evaluation of the
applicability of NSR regulations to these sources is discussed below.
Administration of NSR programs in Maryland is provided by MDE's
SIP-approved regulations promulgated under Code of Maryland Regulations
(COMAR) Section 26.11 with respect to the LNG Terminal. There will be no
modification of existing or construction of new stationary sources
associated with the Pipeline construction or operation in Maryland or
Pennsylvania, or dredging activities in Maryland. Therefore, NSR
regulations are not applicable to the Pipeline or dredging activities.

As discussed in Section 9.3.2.2.B., for the purposes of the major
stationary source applicability determinations under PSD and NNSR rules,
total potential emissions associated with operation of the LNG Terminal
are assumed to include the combination of emissions from stationary
emission units at the LNG Terminal with those emissions from LNG ships
associated solely with LNG offloading activities while the LNG ships are
at berth. The offloading activities are included in the major source
applicability determination because the transfer of fuels from LNG ships
is directly connected to the function of the LNG Terminal. This
conservative approach is consistent with EPA guidance provided in the
1990 Draft New Source Review Workshop Manual, as well as EPA policy
documents on this subject[^6].

##### PSD Requirements

MDE's approved SIP provides the authority to issue air permits in
accordance with federal PSD regulations (40 CFR § 52.21), which are
designed to ensure that the air quality in current attainment areas does
not significantly deteriorate beyond baseline concentration levels. The
PSD regulations specifically apply to the construction of EPA-defined
Major Stationary Sources and Major Modifications to existing Major
Stationary Sources in areas designated as attainment for at least one of
the following criteria pollutants: SO~2~, NO~2~, PM~10~, CO, O~3~, and
lead. In addition, pursuant to EPA's proposed implementation of PM~2.5~
standards, states are in the process of developing SIP revisions that
would include applicability and review criteria for PM~2.5~ emissions.
In the meantime, EPA has advised states to use the PM10 requirements as
a surrogate for PM2.5. For PSD purposes, a Major Stationary Source is
defined as one of 28 listed source categories with the potential to emit
100 TPY or more of any pollutant regulated under the CAA. A non-listed
Major Stationary Source is defined as a source with the potential to
emit 250 TPY or more of any regulated pollutant. PSD applies on a
pollutant-specific basis at Major Stationary Sources for each pollutant
with the potential to be emitted at greater than EPA-defined Significant
Emission Rates: 100 TPY CO; 40 TPY NO~X~, SO~2~ or VOC; 25 TPY TSP; 15
TPY PM~10~; 0.6 TPY Pb. For PM~2.5~, EPA has proposed to apply a
Significant Emission Rate of 10 TPY of direct PM~2.5~ emissions and 40
TPY of precursor SO~2~ emissions. If other precursors are included for
determination of major source applicability to PM~2.5~, a 40 TPY
Significant Emission Rate would be used for precursor NO~2~ emissions
and other Significant Emission Rate thresholds may apply to precursor
VOC and ammonia emissions, as determined by the state's SIP.

Based on the attainment status of the area (see Section 9.3.1.3) and on
projected emission levels (see Sections 9.3.2.2 and 9.3.2.4), the LNG
Terminal will not be considered a Major Stationary Source with respect
to the PSD regulations and is not subject to PSD review, regardless of
whether the 100 TPY or 250 TPY applicability threshold is determined to
apply (i.e., potential emissions of all attainment pollutants are below
100 TPY). [^7] However, if AES decides to construct and operate the
Power Plant, it would be subject to PSD review for NO~2~ and CO if the
100 TPY threshold applies but would not be subject to PSD review if the
250 TPY threshold is determined to apply in this case. AES is in the
process of contacting EPA and MDE to further evaluate PSD applicability
to the Power Plant and to request a formal determination. AES
anticipates that the contact and discussion with MDE will be completed
by the end of the first quarter of 2007.

If AES decides to construct and operate the Power Plant, it will apply
for the appropriate permits, as necessary. If PSD review is triggered,
all stationary sources at the premise must demonstrate compliance with
PSD requirements for each pollutant with potential emissions above
Significant Emission Rates. AES understands that, if it decides to
construct and operate the Power Plant, it will not be considered
separate from the LNG Terminal with respect to NSR requirements. Even if
AES applies for and receives permits for the LNG Terminal stationary
sources and subsequently submits applications for the Power Plant, the
combined emissions from the LNG Terminal and Power Plant will be used
for the purpose of PSD and NNSR applicability determinations. If PSD
review applies, all requirements will apply to LNG Terminal and Power
Plant sources.

PSD review for Major Stationary Sources and Major Modifications includes
the following: an assessment of the existing air quality; the use of
analytic dispersion models to demonstrate compliance with the NAAQS and
applicable PSD Increments; a demonstration that Best Available Control
Technology (BACT) has been applied to the subject emission sources; and
an assessment of the impact of new emissions on the environmental
resources such as soils and vegetation. If the source is located within
100 km (62 miles) of a federal Class I area, the impacts must be
evaluated at these areas based on the more stringent Class I PSD
increments. The PSD permit would contain emission limits and other
operating, monitoring, record keeping, and reporting requirements.

The air quality modeling includes emissions from the proposed Major
Stationary Source or Major Modification and other sources in the area to
ensure protection of the NAAQS and to prevent emission increases beyond
a specified amount, called a PSD Increment. Because the LNG Terminal and
associated LNG ship unloading operations, without the Power Plant, will
not be a Major Stationary Source subject to PSD review, an air quality
modeling demonstration is not required by MDE or EPA PSD regulations
specifically for that Project configuration. However, if it is
determined that the 100 TPY PSD applicability threshold applies to the
Power Plant, the Power Plant will trigger PSD review for the Power Plant
and the Terminal sources, including the air quality modeling
demonstrations. In that case, the results of the air quality dispersion
modeling analysis demonstrating compliance with the NAAQS and PSD
Increments will be included in the PSD permit application submitted to
the Maryland Public Service Commission (MPSC) for review by that agency
with input from MDE (see Section 9.3.3.1.C). If AES proceeds with the
Power Plant option, it is anticipated that the PSD permit application
for the Power Plant will be submitted to MPSC by April 2007, with copies
provided to FERC.

Separate from the potentially applicable PSD modeling requirements, AES
completed an air quality modeling analysis for both LNG Terminal options
(with and without the Power Plant) to satisfy the FERC Staff's
interpretation of its obligation under National Environmental Policy Act
(NEPA) to evaluate anticipated air quality impacts for the Project (see
Section 9.3.5). This modeling analysis includes an analysis of impacts
from the LNG Terminal with and without the Power Plant, and includes
impacts from LNG ship offloading operations. Separate model runs were
also performed to evaluate impacts of marine vessels associated with LNG
ship movements in the Project Area.

The emission limits contained in the PSD permit are required to
represent the BACT. BACT is determined on a case-by-case basis, taking
into account energy, environmental, and economic impacts and costs.
Based on a review of previous BACT and LAER determinations for other
combined cycle power plants, the proposed controls and emissions limits
for the Power Plant are considered representative of BACT. Further,
based on a review of previous BACT and LAER determinations for boiler
and hot water heater equipment, the proposed controls and emission
limits for the LNG Terminal are also considered representative of BACT.

The PSD program was designed to protect air quality in areas where
existing air quality was considerably better than the NAAQS. The program
established a set of increments of new air pollution that would be
allowed over a baseline level for three classes of areas. Class I areas
are areas of special national or regional value from a natural, scenic,
recreational, or historic perspective and include such areas as National
Parks, Fish and Wildlife Service Areas and National Wilderness Areas. In
addition to restrictive Class I PSD increments for SO~2~, PM and NO~2~,
select Class I areas were additionally protected through adoption of
visibility protection requirements. For a project meeting the PSD
regulatory definition of a Major Stationary Source or Major Modification
and with emission source(s) typically located within 100 km (62 miles)
of a Class I area, an impact analysis must be performed to demonstrate
that stringent Class I PSD increments will not be exceeded and that
other air quality related values (AQRVs) are not adversely impacted. The
nearest PSD Class I areas to the LNG Terminal and Power Plant site are
the Shenandoah National Park in Virginia (about 145 km southwest of the
LNG Terminal and Power Plant) and Brigantine National Wilderness Area in
southeastern New Jersey (about 193 km east of the site). The Power Plant
would be located more than 100 km (62 miles) from the nearest Class I
area and, as such, a Class I area impact analysis would not be
automatically triggered in this case. However, as part of the PSD review
process (if the Power Plant will be subject to PSD review), the MDE will
likely provide information on the Project's estimated emissions and
impacts to the Federal Land Manager responsible for overseeing the
nearest Class I areas.

##### Non-attainment New Source Review Requirements

The CAA established more stringent provisions for New Source Review of
Major Stationary Sources proposed to be located in non-attainment areas.
MDE regulations implementing those provisions are codified in COMAR
26.11.17. Because the LNG Terminal and Power Plant will be located in
Baltimore and the Baltimore AQCR has been designated as nonattainment
with respect to certain criteria air pollutants, the Project is
potentially subject to certain NNSR requirements if potential emissions
of NO~X~ or VOC will be greater than 25 TPY. In addition, the MDE may
establish requirements under NNSR for emissions of PM-2.5, for which the
Baltimore AQCR also has been classified as non-attainment.

Based on the attainment status of the area (see Section 9.3.1.3) and on
projected emission levels (see Section 9.3.2), the LNG Terminal will be
subject to NNSR for NO~X~ emissions and the Power Plant would be subject
to NNSR for NO~X~ and VOC emissions. Applicable NNSR permitting
requirements would include an emission limitation that represents LAER
for the source, obtaining NO~X~ equivalent emission reductions (offsets)
from existing sources in the area in the ratio of 1.3 to 1 for sources
located in Baltimore (although the one-hour standard has been rescinded
at the federal level, the area continues to be subject to the severe
nonattainment rules in Maryland's approved SIP, COMAR
26.11.17.03.B(3)(a)), and an alternatives analysis to demonstrate that
the benefits of the proposed source significantly outweigh the
environmental and social impacts.

##### State Permit to Construct Requirements

Pursuant to COMAR 26.11.02.09, all air pollution sources subject to PSD,
NNSR, NSPS, and National Emissions Standards for Hazardous Air
Pollutants (NESHAPS) requirements and all other sources, except those
specifically exempted in COMAR 26.11.02.10, are required to apply for
and obtain a permit to construct. Maryland is authorized by EPA through
its approved SIP to implement both the PSD and NNSR programs. Therefore,
in addition to the permit to construct, sources subject to PSD and/or
NNSR are required to obtain additional PSD and NNSR permits, called
Approvals. The purpose of the permit to construct is to ensure that any
new, modified, replaced or relocated source of air pollution complies
with all applicable State and federal air quality regulatory
requirements. The NNSR and PSD Approvals are required to enforce
applicable PSD and NNSR requirements. Therefore, the four hot water
heaters, six of the emergency fire water pumps, emergency generator, and
vent stack heater at the LNG Terminal will require permits to construct.

In the case of the Power Plant, which will be rated at greater than 70
MW and, as such, will be subject to review by the MPSC, AES will be
required to apply for a Certificate of Public Convenience and Necessity
from the MPSC instead of the MDE. The MPSC has been authorized and
SIP-approved to issue PSD and NNSR Approvals, with MDE input, for all
power plants in Maryland with a generating capacity greater than 70 MW.

#### MDE Title V and State Operating Permit Requirements

Under MDE's Title V Operating Permit regulations (COMAR 26.11.03), a
Title V permit is required for Major Stationary Sources (as defined
under COMAR 26.11.02.01). For Title V applicability purposes, a Major
Stationary Source is defined differently than a Major Stationary Source
under PSD review, with potential emissions thresholds established at 10
TPY for any individual HAP, 25 TPY for any combination of HAPs, 25 TPY
for NO~X~ or VOC in Baltimore and 100 TPY for any other regulated air
pollutant. Based on the estimated potential emissions from the LNG
Terminal as presented in Section 9.3.2, the LNG Terminal will be a Major
Stationary Source subject to Title V permitting. The owner or operator
of a source that becomes subject to the requirement to obtain a Part 70
permit must submit an application not later than 12 months after the
date that the source commences operations or becomes subject to the
requirements for a Part 70 permit, whichever is later (COMAR
26.11.03.02.B(4)). The purpose of the Title V operating permit is to
combine, into a single document, all the state and federal air quality
requirements applicable to all sources located on the same premise.
Title V is not intended to impose new substantive requirements above and
beyond the applicable federal and state requirements.

#### New Source Performance Standards Requirements

As natural gas-fired hot water heaters with heat inputs greater than 100
MMBtu/hr, the four proposed heaters at the LNG Terminal are subject to
Standards of Performance for Industrial-Commercial-Institutional Steam
Generating Units (NSPS, 40 CFR Part 60, Subpart Db). Although Subpart Db
contains emissions standards and/or control requirements for SO~2~ and
PM from boilers combusting coal, oil, wood and other fuels, it contains
no SO~2~ or PM standards applicable to natural gas fired boilers. The
most stringent Subpart Db NO~X~ emission standard applicable to gas
fired boilers with a low heat release rate is 0.1 pounds per million
British thermal unit (lb/MMBtu). The hot water heaters associated with
the LNG Terminal will be designed and operated in accordance with the
applicable Subpart Db NO~X~ emission standard. The proposed NO~X~
emission rate (less than 0.004 lb/MMBtu) would easily meet the
applicable emission standard. AES will also comply with the applicable
monitoring, record keeping and reporting requirements consistent with
Subpart Db.

The proposed CTG at the Power Plant would have a heat input greater than
10 MMBtu/hr and would be constructed after February 18, 2005. Therefore,
the CTG and associated HRSG would be subject to Standards of Performance
for Stationary Combustion Turbines (Subpart KKKK), which were
promulgated on July 6, 2006 and are applicable to combustion turbines
with a heat load input greater than or equal to 10 MMBtu/hr and that
were constructed, modified or reconstructed after February 18, 2005.
Stationary combustion turbines subject to Subpart KKKK are exempt from
requirements of Subpart GG, which is applicable to combustion turbines
constructed, modified, or reconstructed after October 3, 1977. In
addition, HRSGs subject to Subpart KKKK are exempt from the requirements
in Subparts Da, Db and Dc. Subpart KKKK sets emission limits for NO~X~
and SO~2~. For new CTGs firing natural gas at a heat input rate of
greater than 850 MMBtu/hr, such as the CTG proposed for the Power Plant,
the applicable NO~X~ emission limit would be 15 ppmvd at 15 percent
O~2~. The proposed NO~X~ emission limit, which will also be proposed to
meet BACT and LAER, is two ppmvd at 15 percent O~2~ and, therefore, the
CTG will easily meet the applicable limit in Subpart KKKK. The
continuous emission monitoring system (CEMS) proposed for the Power
Plant would also comply with the Subpart KKKK NO~X~ monitoring
requirements. The Subpart KKKK SO~2~ limit applicable to all CTGs
regardless of size or fuel type is 0.58 lb/MWh gross energy output or
fuel sulfur content of 0.05 percent by weight. The proposed CTG with
HRSG would be fueled exclusively with natural gas and will meet the fuel
sulfur content specification.

Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage
Vessels (Including Petroleum Liquid Storage Vessels) for Which
Construction, Reconstruction, or Modification Commenced After July 23,
1984, was reviewed for applicability to the LNG storage tanks at the LNG
Terminal. This subpart applies to storage vessels above 75 cubic meters
capacity used to store Volatile Organic Liquids (VOL). VOL is defined as
any organic liquid that can emit VOC as defined in 40 CFR § 51.100. The
only organic compounds with the potential to be emitted in trace amounts
from LNG storage tanks are methane and ethane, both of which are
specifically exempted in 40 CFR § 51.100 from the definition of VOC.
Therefore, this subpart is not applicable to the LNG storage tanks.

Subpart IIII, Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines, promulgated July 11, 2006, will
apply to emergency fire pump engines and the emergency standby generator
proposed for the LNG Terminal. The rule requires manufacturers of such
engines to meet emission standards that are phased in for the size, type
of engine application and model year of the engine. Owners and operators
of covered engines are required to configure, operate and maintain the
engines according to specifications and instructions provided by the
engine manufacturer and to maintain records demonstrating compliance.
AES will comply with the requirements applicable to owners and operators
of covered engines.

#### National Emissions Standards for Hazardous Air Pollutants Requirements

The NESHAPs, codified in 40 CFR Part 61, regulate HAP emissions. Part 61
was promulgated prior to the 1990 CAAA and regulates only eight types of
hazardous substances (asbestos, benzene, beryllium, coke oven emissions,
inorganic arsenic, mercury, radionuclides, and vinyl chloride). The
proposed LNG Terminal and Power Plant do not fall under one of the
source categories regulated by Part 61; therefore, the requirements of
Part 61 are not applicable to the Project.

#### National Emissions Standards for Hazardous Air Pollutants for Source Categories Requirements

Boilers and process heaters that are located at new or existing Major
Stationary Sources of HAPs must meet NESHAPs for Source Categories,
Subpart DDDDD - National Emission Standards for Industrial / Commercial
/ Institutional Boilers and Process Heaters, commonly referred to as
Boiler Maximum Achievable Control Technology (MACT) standards. Subpart
DDDDD emission limitations applicable to "large" (greater than 10
MMBtu/hr) gas fired boilers and process heaters include PM (0.03
lb/MMBtu), hydrogen chloride (0.0009 lb/MMBtu) and CO (400 ppm at three
percent O~2~). The hot water heaters at the LNG Terminal would be
classified as a large boiler or process heater under the regulations and
estimated emissions would easily comply with these limitations based on
vendor data and/or EPA emissions factors as summarized in Appendix 9A.
The HRSG at the Power Plant would be classified as a waste heat boiler,
which is not subject to the regulation, because the supplemental burners
to the HRSG would not be 50 percent or more of the total heat input to
the HRSG based on preliminary engineering design. Based on estimated
potential emissions of federal HAPs summarized in Table 9.3-6 and
Appendix 9A, the LNG Terminal and the Power Plant are not classified as
Major Stationary Sources of HAPs (i.e., those that have the potential to
emit 10 TPY or more of a single HAP or 25 TPY or more of a combination
of HAPs that are specifically listed in or pursuant to section 112(b) of
the CAA). Therefore, the proposed LNG Terminal and Power Plant will not
be subject to Subpart DDDDD*.*

Other NESHAPs for Source Categories, or MACT standards, potentially
applicable to Project stationary sources include Subpart ZZZZ (NESHAP
for Stationary Reciprocating Internal Combustion Engines) and Subpart
YYYY (NESHAP for Stationary Combustion Turbines). Both of these NESHAPs
are only applicable to Major Stationary Sources of HAPs. Based on
estimated potential HAP emissions, neither the proposed LNG Terminal nor
the Power Plant will be Major Stationary Sources of HAPs. Therefore,
these NESHAPs do not apply to the Project. Moreover, with regard to
Subpart YYYY, based on EPA's August 18, 2004 stay of effectiveness with
regard to applicability of this NESHAP to lean premix gas-fired turbines
and diffusion flame gas-fired turbines, Subpart YYYY would not apply to
the CTG proposed for the Power Plant, as the proposed CTG will be a lean
premix dry low-NO~X~ design.

#### Acid Rain Program, Clean Air Interstate Rule (CAIR) and Clean Air Mercury Rule (CAMR) Requirements

The Acid Rain Program is codified in 40 CFR Parts 72 through 78. This
program aims to reduce acid rain by reduction of SO~2~ and NO~X~ from
utility units that have a nameplate electricity generation capacity
greater than 25 MW. A "unit" is defined as a "fossil fuel-fired
combustion device" and "fossil fuel-fired" is defined as "the combustion
of fossil fuel, alone or in combination with any other fuel, independent
of the percentage of fossil fuel consumed in any calendar year". The hot
water heaters at the LNG Terminal will not be used to generate
electricity. However, the combined cycle Power Plant would have a
generation capacity greater than 25 MW and will be subject to Acid Rain
program requirements. If the Power Plant is constructed, the Acid Rain
permit application must be filed at least 24 months before the unit
commences operation. An affected unit is required to follow the
continuous emissions monitoring requirements of 40 CFR Part 75 and to
hold sufficient SO~2~ allowances to cover expected emissions of SO~2~
when operation commences. In the event that the Power Plant is
constructed, AES would apply for the Acid Rain Permits; install, certify
and operate the required monitoring systems; and comply with the
required emissions allowances, monitoring, and recordkeeping
requirements.

The Clean Air Interstate Rule (CAIR), 40 CFR Parts 96 and 97, requires
certain states, including Maryland, to achieve significant, phased
reductions in annual and ozone-season NOx emissions (as a precursor to
fine particulate matter (PM2.5) and ozone formation) and annual SO2
emissions (as a precursor to PM2.5 formation), consistent with
state-specific emissions budgets established by EPA.  To achieve those
reductions, affected states may choose to participate, to the extent
applicable, in cap and trade programs for annual NOx, ozone-season NOx
and annual SO2 emissions. Affected states must submit to EPA proposed
revisions to its State Implementation Plan (SIP) that include the
requisite NOx and SO2 emissions reductions and specify the CAIR-affected
sources and control mechanisms that will be required by the state. 
Alternatively, affected states may become subject to the CAIR Federal
Implementation Plans (FIPs), meaning that EPA would administer the CAIR
program for that state. Because the State of Maryland has not yet
submitted its CAIR SIP to EPA for review and approval or indicated its
intention to proceed under the CAIR FIP, it is not yet clear how the
State will comply with CAIR and whether the emissions reduction
requirements will apply to sources other than coal-fired electric
generating units.  However, if AES proceeds with construction of the
Power Plant, AES will comply with any CAIR requirements that may be
applicable to the natural gas-fired units at the plant.

The Clean Air Mercury Rule establishes standards of performance for new
and existing coal-fired electric generating units pursuant to Section
111(d) of the Clean Air Act.  CAMR sets annual caps for mercury
emissions from such units and creates a market-based trading program.
States were required to submit SIP revisions to EPA by November 17,
2006, to implement the requirements of the CAMR.  Many states, including
Maryland, failed to meet the SIP submittal deadline and it is not yet
clear whether Maryland will develop a state plan to adopt the CAMR or
will become subject to the CAMR FIP, which was published by EPA on
December 8, 2006.  Under either scenario, the State\'s CAMR program is
not anticipated to apply to new, natural gas-fired electric generating
units, such as the units that would be installed at the Power Plant, if
constructed.  However, if AES proceeds with construction of the Power
Plant, AES will comply with any CAMR requirements that may be applicable
to the natural gas-fired units at the plant.

#### MDE Emission Standards

In addition to the MDE permit to construct, permit to operate and PSD
and NNSR Approval requirements, the following state emission standards
and other requirements were evaluated for applicability to the LNG
Terminal and Power Plant emission sources:

-   COMAR 26.11.05: Air Pollution Episode System -- This chapter
    requires sources designated by the Secretary or the Secretary\'s
    designee to submit standby emission reduction plans and to implement
    such plans if a designated level of air pollution is reached.
    Designated sources primarily include coal and oil fired electric
    power generating facilities, coal and oil fired steam producing
    facilities, large manufacturing industries and refuse incinerators.
    Any other source of air pollutants not specifically designated in
    the regulation may be required to submit standby plans, upon written
    request of the MDE, describing emission cutbacks to be taken if an
    air pollution Alert is called. Because the LNG Terminal and Power
    Plant do not involve emission sources specifically designated by
    regulation to prepare and submit standby plans, AES would not be
    subject to this requirement unless specifically requested by MDE.

-   COMAR 26.11.06: General Emission Standards, Prohibitions and
    Restrictions -- This chapter contains emissions standards and other
    requirements applicable to certain air pollution sources. Specific
    requirements pertain to visible emissions, emissions of particulate
    matter, CO, SO~2~, VOC and fluorides, and to odors and other
    nuisance air pollution. The proposed hot water heaters, diesel
    engines and vent stack heater at the LNG Terminal, and the CTG with
    HRSG at the Power Plant ,will be designed to meet all applicable
    standards and operate in compliance with applicable limitations.

-   COMAR 26.11.06.03.D: Particulate Matter from Materials Handling and
    Construction. This regulation requires reasonable precautions to
    prevent particulate matter from becoming airborne due to material
    handling, transport, or storage, or due to construction or
    demolition activities, use of roads and other activities. Reasonable
    precautions specified in the regulation include, but are not be
    limited to:

    -   Use of water or chemicals for control of dust in the demolition
        of existing buildings or structures, construction operations,
        the grading of roads, or the clearing of land.

    -   Application of asphalt, oil, water, or suitable chemicals on
        dirt roads, materials stockpiles, and other surfaces that can
        create airborne dusts.

    -   Installation and use of hoods, fans, and dust collectors to
        enclose and vent the handling of dusty materials. Adequate
        containment methods shall be employed during sandblasting of
        buildings or other similar operations.

    -   Covering, at all times when in motion, open-bodied vehicles
        transporting materials likely to create air pollution. Alternate
        means may be employed to achieve the same results as would
        covering the vehicles.

    -   The paving of roadways and their maintenance in clean condition.

    -   The prompt removal from paved streets of earth or other material
        which has been transported there by trucks or earth moving
        equipment or erosion by water.

AES will require its contractors to use the mitigation measures
identified in Section 9.3.6 of this Resource Report to minimize the
fugitive dust emissions associated with construction of the Pipeline,
LNG Terminal, Power Plant (if constructed), and during dredging
activities. These measures may include the application of water or dust
suppressants, covering of haul trucks, use of paved roads to the extent
possible, limiting vehicle speed and stabilizing disturbed areas.

-   COMAR 26.11.09: Control of Fuel-Burning Equipment, Stationary
    Internal Combustion Engines, and Certain Fuel-burning Installations
    -- This chapter contains emissions standards and other requirements
    applicable to certain fuel-burning equipment, including boilers,
    vent heater, and diesel engines at the LNG Terminal, and the CTG
    with HRSG at the Power Plant. Specific requirements pertain to
    visible emissions, emissions of particulate matter, SO~2~ and Major
    Stationary Sources of NO~X~. The proposed combustion equipment at
    the LNG Terminal and Power Plant will be designed to meet all
    applicable standards and operate in compliance with applicable
    limitations.

-   COMAR 26.11.15 and 26.11.16: Toxic Air Pollutants -- Fuel burning
    equipment as defined in COMAR 26.11.09.01, such as boilers and
    stationary internal combustion engines associated with the LNG
    Terminal, and the CTG with HRSG associated with the Power Plant, are
    exempt from the requirements of this chapter.

-   COMAR 26.11.17: Requirements for Major New Sources and Modifications
    -- This chapter applies to Major Stationary Sources and Major
    Modifications with respect to non-attainment pollutants NO~X~, VOC
    and CO. Based on estimated potential emissions from the LNG Terminal
    emission units, the requirements of this chapter apply to NO~X~, as
    the LNG Terminal will be a Major Stationary Source of NO~X~
    emissions when LNG ship offloading emissions are included. The LNG
    Terminal, even with offloading emissions, will not be a Major
    Stationary Source of VOC emissions and, therefore, will not be
    subject to the requirements of this chapter for VOC. In addition,
    the LNG Terminal will not be located in a non-attainment area for
    CO. However, based on estimated potential emissions, the LNG
    Terminal together with the Power Plant, and including LNG offloading
    emissions, will be a Major Stationary Source of NO~X~ and VOC and,
    therefore, will be subject to the NSR requirements in this chapter.
    The applicable requirements for sources subject to NSR are
    summarized in section 9.2.3.1.2.

-   COMAR 26.11.29 and 26.11.30: NO~X~ Reduction and Trading Program --
    These chapters apply to affected trading sources, which are defined
    as fossil fuel fired electric generating units that serve a
    generator with a name plate capacity greater than 25 MW or
    non-electric generating units that have a maximum design heat input
    greater than 250 MMBtu/hr. The proposed hot water heaters at the LNG
    Terminal are fossil fuel fired stationary boilers with a maximum
    design heat input of 345 MMBtu/hr and are, therefore, classified as
    non-electric generating units subject to the requirements. The CTG
    with HRSG at the proposed Power Plant would be a fossil fuel fired
    electric generating unit that would serve a generator with a name
    plate capacity of approximately 300 MW and will sell electricity.
    Therefore, the combined cycle Power Plant would also be subject to
    Maryland's NO~X~ Reduction and Trading Program. In general, COMAR
    26.11.29 requires an affected trading source to acquire sufficient
    NO~X~ allowances for the control period each year at least equal to
    the affected trading source's NO~X~ emissions for the control
    period. Allowances from a "set-aside pool" are made available by the
    MDE to accommodate new affected trading sources or "clean air
    projects", defined as a new or modified fossil fuel electric
    generator with state-of-the-art NO~X~ controls demonstrated to be
    more efficient than existing electric generation. An affected
    trading source must also install, operate, maintain, and certify a
    NOx CEM or other approved monitoring method in accordance with 40
    CFR Part 75, Subpart H and comply with the monitoring requirements
    in 40 CFR Part 96, Subpart H. COMAR 26.11.30 is referenced
    throughout Chapter 26.11.29 and establishes procedural requirements
    to implement Maryland's NO~X~ Reduction and Trading Program. The
    proposed hot water heaters at the LNG Terminal and combined cycle
    Power Plant will be designed to meet all applicable standards and
    operate in compliance with applicable monitoring and NO~X~ emissions
    trading requirements.

#### PDEP Emission Standards

The Pipeline will not involve the construction of new or modification of
existing stationary sources of air pollutant emissions in Pennsylvania,
such as a compressor station. Therefore, the portion of the Pipeline in
Pennsylvania will not be subject to PDEP air quality control regulations
with the exception of those concerning prohibition of certain fugitive
emissions (25 Pa.C.S. § 123.1). These requirements are similar in scope
and applicability to those Maryland regulations referenced in Section
9.3.3.7 for control of fugitive emissions (COMAR 26.11.06.03.D).

#### Control of Air Pollutant Emissions from Mobile Sources

As discussed in Section 9.3.2, during construction of the Project,
AES\'s contractors will use construction equipment that will result in
mobile source emissions of TSP, PM~10~, NO~X~, SO~2~, CO, and VOC. These
mobile sources would be subject to federal and state regulations and
standards applicable to the manufacturer, owner, or operator of the
equipment.

##### EPA Regulations for Mobile Source Emissions

EPA has adopted regulations for the control of air pollutant emissions
from nonroad, mobile source engines (See 40 CFR Parts 89, 90, 91, and 94
for requirements applicable to nonroad compression-ignition,
spark-ignition, marine spark-ignition and marine compression-ignition
engines, respectively). These regulations potentially apply to the
manufacturer, owner, or operator of certain of the equipment that will
be used to construct and operate the Project. AES will not manufacture,
own, or operate any construction equipment and, therefore, is not
required to obtain any authorizations from EPA for the air pollutant
emissions that will be associated with the use of equipment to construct
and operate the Project. In addition, the standards applicable to marine
compression-ignition engines (40 CFR Part 94) do not apply to engines on
foreign vessels. Any U.S. flagged or registered vessels equipped with
affected compression ignition engines manufactured after January 1, 2004
would meet all applicable requirements of this subpart; however, there
are currently no U.S. flagged LNG vessels.

EPA has also adopted regulations for control of nonroad, locomotive and
marine diesel fuel sulfur content (See 40 CFR Part 80, Subpart I) that
phase is significantly lower diesel fuel sulfur contents. The applicable
limits for marine diesel engines are 500 ppm sulfur (0.05 percent)
beginning June 1, 2007 and 15 ppm sulfur (0.0015 percent) beginning June
1, 2012. These limits will apply to assist tugs used during LNG tanker
ship deliveries to the LNG Terminal.

##### MDE Regulations for Mobile Source Emissions

MDE also has adopted regulations for the control of air pollutant
emissions from certain mobile sources (See COMAR 26.11.20). The MDE
regulations include visible emissions standards applicable to ships,
motor vehicle emissions control requirements, motor vehicle fuel
specifications, diesel vehicle emissions control requirements, heavy
duty diesel engine emissions standards and other requirements applicable
to certain mobile sources offered for sale or lease in Maryland. AES
will not sell or lease any mobile source equipment that may be used to
construct and operate the Project and, therefore, is not required to
obtain any authorizations from MDE for the air pollutant emissions that
will be associated with the use of equipment associated with the
Project. AES's contractors will be required to make an assessment of the
applicability of these requirements to their equipment and operations.

##### PDEP Regulations for Mobile Source Emissions

PDEP regulations at 25 Pa.C.S. § 126.50 adopt and incorporate by
reference certain provisions of the California Exhaust Emission
Standards and Test Procedures for Heavy-Duty Diesel Engines and
Vehicles. However, the Pennsylvania Heavy-Duty Diesel Emissions Control
Program specifically exempts heavy duty diesel engines for offroad use.
The PDEP regulations include heavy duty diesel engine emissions
standards, testing and other requirements applicable to certain mobile
sources offered for sale or lease in Pennsylvania. AES will not sell or
lease any mobile source equipment that may be used to construct and
operate the Pipeline in Pennsylvania and, therefore, is not required to
obtain any authorizations from PDEP for the air pollutant emissions that
will be associated with the use of mobile source equipment associated
with the Pipeline construction in Pennsylvania. AES's contractors will
be required to make an assessment of the applicability of these
requirements to their equipment and operations.

#### General Conformity of Federal Actions

Under the CAA, a general conformity determination is required for any
project constituting a federal action that is not otherwise subject to
NSR permitting and will be undertaken in a nonattainment or maintenance
area, and for which the emissions of certain air pollutants will exceed
applicable threshold rates. The portions of the LNG Terminal and the
Power Plant (if built) that will be subject to NSR permitting are not
subject to the general conformity review process. Therefore, only direct
and indirect emissions from construction of the LNG Terminal and Power
Plant, construction and operation of the Pipeline and from vessel
activity and indirect emissions during operation of the LNG Terminal and
Power Plant, are potentially subject to general conformity review. These
portions of the Project will be undertaken in Air Quality Control
Regions in Maryland, Pennsylvania, and Virginia (LNG ship movements in
State of Virginia waters only) that have been designated moderate or
marginal ozone nonattainment areas with respect to the 8-hour ozone
standard, and will be considered federal actions. As such, these
portions of the Project will require a general conformity determination
if the estimated actual emissions of NO~X~ or VOCs (as ozone precursors)
will exceed 100 TPY or 50 TPY, respectively. Based on the estimated
emissions summarized in Table 9.3-4, the portions of the Project subject
to general conformity review will have NO~X~ emissions originating both
in Maryland and Pennsylvania that will exceed these thresholds during
each year of construction of the Project, except 2010 in Pennsylvania.
In addition, VOC emissions from construction of the Project in Maryland
during 2009 are estimated to exceed the 50 TPY threshold. As summarized
in Table 9.3-5, marine vessel emissions originating in Maryland and
Virginia during operation of the Project will also exceed the applicable
NO~X~ thresholds. Therefore, separate conformity determinations must be
made for Maryland, Virginia and Pennsylvania.

The LNG Terminal facilities and the Pipeline are also within areas
designated as non-attainment for PM~2.5~ in Maryland and Pennsylvania.
Applicability is evaluated for direct emissions of PM~2.5~ as well as
precursor emissions, which include SO~2~, NO~X~, VOC and ammonia. As
such, the portions of the Project subject to conformity review will
require a general conformity determination if the estimated actual
direct PM~2.5~ or SO~2~ emissions will exceed 100 TPY, or if emissions
of NO~X~ (unless determined not to be a significant precursor), VOC or
ammonia (if determined to be significant precursors) will exceed 100
TPY, or if Pb emissions will exceed 25 TPY. Direct emissions of PM~2.5~
from those portions of the Project subject to conformity review will not
exceed the 100 TPY threshold in Maryland or Pennsylvania during
construction or operation of the Project. However, precursor SO~2~
emissions in Maryland due to LNG ship transit during LNG Terminal
operations are estimated to exceed the 100 TPY SO~2~ de minimis
threshold. In addition, if precursor NO~X~ emissions are required by the
applicable SIP to be included in the threshold determination, then NO~X~
emissions from construction of the Project in Maryland and Pennsylvania
(only for 2009), and for operation of the Project in Maryland (due to
LNG ship transit), will also trigger a PM~2.5~ general conformity
determination for PM~2.5~ precursor emissions in these states.
Therefore, separate conformity determinations for PM~2.5~ must be made
for Maryland and may also be necessary for Pennsylvania if precursor
NO~X~ emissions are included in the PM~2.5~ SIPs.

According to section 176(c)(1) of the CAA (40 CFR § 51.853 and Part 93,
Subpart B)[^8], a federal agency cannot approve or support any activity
that does not conform to an approved SIP. A conformity analysis must
show that the emissions would not cause or contribute to new violations
of the NAAQS in any area, increase the frequency or severity of any
existing violation of any NAAQS, or delay timely attainment of any NAAQS
or interim emission reductions. Options for demonstrating conformity
include demonstration that the project/action is specifically identified
and accounted for in the SIP; obtaining documentation from the State
that the emissions are included in the SIP; obtaining state commitment
to include the emissions in the SIP; mitigation of the emissions; or
offsetting the emissions using emissions reductions within the same
nonattainment area. Each of the affected states where a conformity
determination will be necessary will play important roles in the review
of emission inventories and consultation on specific emission mitigation
or offset requirements. Options for general conformity for affected
portions of Maryland, Virginia and Pennsylvania are under development.
AES submitted a preliminary draft general conformity determination for
review to MDE, Pennsylvania Department of Natural Resources (PA DNR) and
Virginia Department of Environmental Quality (VA DEQ) in January 2007.
Following consultations with MDE, PA DNR and VA DEQ, AES will submit a
refined draft conformity determination to the FERC, MDE, PA DNR and VA
DEQ which is currently anticipated to be completed by April, 2007.

#### EPA Chemical Accident Prevention Provisions and OSHA Process Safety Management

40 CFR Part 68, Chemical Accident Prevention Provisions, are Federal
regulations designed to prevent the release of hazardous materials in
the event of an accident and minimize impacts when releases do occur.
The regulations contain a list of substances and threshold quantities
for determining applicability of the rule to a facility. If a facility
stores, handles or processes one or more substances on this list and at
a quantity equal or greater than specified in the regulation, the
facility must prepare and submit a risk management plan (RMP). If a
facility does not have a listed substance on-site, or the quantity of a
listed substance is below the applicability threshold, the facility is
not required to prepare an RMP. However, it still must comply with
requirements of the general duty provisions in Section 112(r)(1) of the
1990 CAAA if it has any regulated substance of other extremely hazardous
substance on-site. The general duty of the provision is as follows:

> "The owners and operators of stationary sources producing, processing,
> handling and storing such substances have a general duty to identify
> hazards which may result from such releases using appropriate hazard
> assessment techniques, to design and maintain a safe facility taking
> such steps as are necessary to prevent releases, and to minimize the
> consequences of accidental releases which do occur."

With the exception of natural gas constituents (*e.g.*, methane, ethane,
propane, etc.), no regulated substance would be handled or stored in
quantities greater than the applicability threshold. Natural gas
pipelines are not covered if they are regulated by the U.S Department of
Transportation (USDOT) or an equivalent state natural gas program
certified by USDOT in accordance with 49 U.S.C § 60105. In addition,
storage of natural gas incidental to transportation (e.g., gas taken
from a pipeline during non-peak periods and placed in storage, then
returned to the pipeline when needed) is not covered. Consequently, an
RMP is not required for any portion of the Project. AES would be
required to maintain awareness of hazard issues and meet the goals of
the above-listed general duty provisions.

The applicability of the Occupational Safety and Health Administration
(OSHA) standard 29 CFR 1910.119, Process Safety Management of Highly
Hazardous Chemicals (PSM), to the Project was also evaluated. Based on
standard interpretations published by OSHA in response to questions on
PSM applicability to LNG facilities, OSHA has concluded that current
USDOT regulations in 49 CFR Parts 192 and 193 and enforced by the
Pipeline and Hazardous Materials Safety Administration cover LNG and gas
transmission and distribution processes, and that OSHA is precluded from
enforcing the PSM standard with respect to working conditions associated
with fire and explosion hazards of these processes. Therefore, the
Pipeline and LNG Terminal, which are subject to 49 CFR Parts 192 and
193, respectively, are not subject to the PSM regulations.

### Potential Air Quality Impacts of Proposed Project Due to Construction

Emissions associated with the construction of the Pipeline, LNG
Terminal, dredging activities and the nonjurisdictional Power Plant were
separately analyzed in Section 9.3.2 of this Resource Report, and the
estimated construction emissions are summarized by Project component, by
state, by AQCR, by year and for the entire Project in Table 9.3-4.
Construction emissions and impacts will be restricted to the
construction period, approximately three years in total, and will
terminate once construction has been completed. In addition, emissions
from Pipeline construction will not be concentrated for any extended
period within any particular location along the Pipeline route. Based on
this analysis, direct emissions from combustion equipment, indirect
emissions from commuting construction workers and from haul trucks, and
fugitive dust emissions are not expected to significantly impact ambient
air quality in the Project Area.

Project construction emissions will need to be further assessed to
support this conclusion in accordance with the General Conformity
requirements. As discussed in Section 9.3.3.10, the general conformity
determination for non-exempt federal actions must demonstrate compliance
with applicable provisions of the Maryland and Pennsylvania SIPs, such
that construction and operation of the proposed Project will not delay
attainment of the ozone and PM~2.5~ NAAQS. Mitigation measures required
to comply with general conformity include a demonstration of consistency
with applicable control measures and regulations that are relied upon in
the applicable SIP, a demonstration that direct and indirect emissions
have been identified and accounted for in the SIP attainment
demonstration or the emissions must be offset through a SIP revision or
other enforceable measure so that there is no net increase in emissions.
In addition, mitigation measures to suppress fugitive dust generation
during Project construction will be implemented as discussed in Section
9.3.6.

### Potential Impact of Proposed Project Due to Facility Operation

As discussed in Section 9.3.2, the LNG Terminal and nonjurisdictional
Power Plant (if built) will have permanent stationary sources of air
pollution resulting in long term air pollutant emissions. The Pipeline
and dredging activities associated with the LNG Terminal will not
involve the construction of new or modification of existing stationary
sources of air pollutant emissions and, therefore, will not have any
long term air quality impacts. The primary air emissions sources at the
proposed LNG Terminal will include natural gas fired hot water heaters
controlled with state-of-the art emissions control systems to meet
applicable LAER requirements for NO~X~, as described in Section 9.3.6.
Use of these controls to meet stringent emissions limitations will
minimize ambient impacts from the LNG Terminal. The LNG Terminal will
also include a number of small diesel engines used for emergency fire
water pumping and standby electricity generation that will only operate
during emergency conditions or electrical power interruptions.

If AES decides to construct the Power Plant, a CTG with HRSG would be
added to the LNG Terminal and would provide different operating
scenarios for the hot water heaters. Estimated potential emissions from
the LNG Terminal with the Power Plant would classify the premise as a
Major Stationary Source under EPA and MDE regulations and emissions from
all sources at the LNG Terminal and Power Plant would be required to
meet LAER for NO~X~ and VOC emissions and potentially BACT for CO
emissions. The proposed CTG with HRSG and the LNG Terminal hot water
heaters would each be equipped with state-of-the-art emission controls
to meet stringent LAER or BACT requirements, as applicable and as
described in Section 9.3.6, to minimize ambient impacts from the Power
Plant and LNG Terminal.

Regardless of whether a PSD air quality impact analysis is required for
the LNG Terminal, AES has completed an air quality modeling analysis of
both LNG Terminal options (with and without the Power Plant) to satisfy
the FERC Staff's interpretation of its obligation under NEPA to evaluate
potential air quality impacts associated with the Project. This modeling
analysis includes an evaluation of impacts from the LNG Terminal with
and without the Power Plant, and a cumulative analysis of impacts from
the LNG Terminal including LNG ship offloading operations. Separate
model runs were also performed to evaluate the combined effects of the
LNG Terminal and Power Plant scenarios with LNG ship offloading,
hoteling operations and marine vessels associated with LNG ship
movements in the Project Area, specifically assist tugs and USCG
security and patrol boats within the safety and security zone. The
modeling assumptions, procedures and results are summarized in this
Resource Report. A compact disk containing all modeling input and output
files is also provided in Appendix 9B. In the event that AES decides to
construct and operate the Power Plant and is required to perform an air
quality impact analysis satisfying all requirements for PSD review, AES
will perform the required PSD modeling analyses and submit a detailed
modeling report as part of the permit application to the MPSC and MDE.

#### Air Quality Modeling Analysis

Atmospheric dispersion modeling was performed to evaluate impacts to air
quality due to operation of the Project. The modeling was conducted in
accordance with objectives and procedures to satisfy NEPA impact
assessment criteria, as discussed in several teleconferences with the
FERC Staff. In addition, modeling guidance and meteorological input data
were obtained through consultation with MDNR's subcontractor,
Environmental Resources Management, Inc. (ERM)), responsible for review
of air quality impact analyses under MPSC's consolidated licensing
program for power plants.

##### Scope and Objectives of Modeling Analysis

Based on the consultation with FERC Staff, three distinct scenarios were
modeled for each of the LNG Terminal operating phase options (i.e., with
and without the Power Plant):

> [(Option 1) Without Power Plant:]{.underline}

-   LNG Terminal emission sources only

-   LNG Terminal emission sources plus LNG ship offloading emissions

-   LNG Terminal emission sources, LNG ship offloading plus all other
    marine vessels within the safety and security zone

> [(Option 2) With Power Plant:]{.underline}

-   LNG Terminal and Power Plant emission sources only

-   LNG Terminal and Power Plant emission sources plus LNG ship
    offloading emissions

-   LNG Terminal and Power Plant emission sources, LNG ship offloading
    plus all other marine vessels within the safety and security zone

The scenarios were identified in this manner consistent with FERC
Staff's interpretation of its obligation under NEPA to evaluate
potential impacts from both primary and secondary emission sources
associated with the Project. FERC Staff further advised that the
secondary mobile emission sources included in the modeling should be
geographically limited from the turning basin to the berth and include
emissions from all LNG ship transit, maneuvering, and hoteling
operations, and assist tugs, security and patrol vessel operations in
this restricted area. Since the USCG has not yet determined the
preliminary extent of the safety and security zone, it was assumed for
the purposes of the modeling analysis that it would be defined by a
minimum radius of 500 yards from the LNG ship berth. In addition, the
USCG will establish a safety and security zone around each LNG ship
while it is in transit. For purposes of the modeling analysis and
determining the LNG Terminal "fenceline" for restricted public access,
this safety and security zone was also assumed to extend 500 yards from
each side of the LNG ship. If the safety and security zone ultimately
established by the USCG is greater than these assumptions, it would
reduce the impacts at fenceline receptors.

Further following FERC Staff guidance to comply with NEPA impact
assessment requirements, the modeled impacts were first compared to EPA
PSD Significant Impact Levels (SILs). If maximum predicted impacts are
less than the applicable SILs, FERC Staff presumes that the source will
not cause or significantly contribute to a PSD Increment or NAAQS
violation and no further impact assessment is required. If the predicted
impacts are greater than SILs, then maximum impacts are added to
representative ambient background concentrations and evaluated for
compliance with the NAAQS. In addition, if predicted impacts are greater
than SILS, FERC Staff has advised AES that it must complete a
qualitative cumulative impact analysis by comparing potential emissions
from the Project and other new or reasonably foreseeable projects in the
region with regional emission inventories.

##### Model Selection

AERMOD (Version 04300), incorporating Plume Rise Model Enhancement
(PRIME) downwash algorithms was used in the refined modeling analyses
for simple and elevated terrain. The AERMOD model was run using the
Lakes Environmental ISC-AERMOD View (version 5.4.0) interface for EPA's
ISC and AERMOD models. AERMOD is an EPA-approved refined dispersion
model for evaluating impacts of land-based stationary sources. AERMOD
with PRIMEPRME is one of the listed refined dispersion models in EPA's
*Guideline on Air Quality Models (*40 CFR Part 51 Appendix W, November
2005) that are required to be used for SIP revisions for existing
sources and for NSR and PSD programs.

AERMOD with PRIME includes improved building downwash algorithms capable
of modeling receptors in both the near-building wake (cavity) and
far-building wake regions. The PRIME algorithm takes into account the
distance from each building or structure to potentially affected sources
in that building's region of influence. The inclusion of the cavity
predictions within AERMOD removes a modeling discontinuity that existed
with AERMOD without the PRIME algorithm and obviates the need for
additional cavity impact analysis using the SCREEN3 or other calculation
procedures.

Default AERMOD control options used in the modeling analysis consistent
with EPA recommendations include the following:

-   Final plume rise at all receptors

-   Stack-tip downwash

-   Buoyancy-induced dispersion

-   Calm wind processing routine

-   Default wind profile exponents

-   Default vertical potential temperature gradients

##### Emissions and Source Parameters

The emissions and operating scenarios of all sources included in the
modeling analysis are described in Section 9.3.2. The specific primary
and secondary (mobile marine vessel) emission sources associated with
the LNG Terminal, LNG ships and nonjurisdictional Power Plant are
summarized as follows:

> [LNG Terminal:]{.underline}

-   Four hot water heaters

-   One Fresh water emergency diesel engine fire pump

-   Six salt water emergency diesel engine fire pumps

-   One emergency diesel engine standby generator

-   One heated vent stack

-   LNG ship offloading operations

> [Marine Vessels Associated with LNG Ships:]{.underline}

-   LNG ship hoteling operations at berth and in safety and security
    zone

-   Three assist tug boats in safety and security zone

-   Two security and patrol boats in safety and security zone

> [Non-Jurisdictional Power Plant:]{.underline}

-   One Combined cycle combustion turbine with heat recovery steam
    generator (CTG/HRSG)

-   One Cooling tower

Detailed assumptions and calculations used to develop emission rates,
operating scenarios and other stack parameters are provided in Appendix
9A for each of the emission sources. Table 9.3.7 summarizes the
emissions and source parameters used for AERMOD input.

Different source groups were set up in the model in order to predict
impacts for each of the modeling scenarios identified in Section
9.3.5.1.A for each of the LNG Terminal options (with and without the
Power Plant). These source groups are identified in Table 9.3-8. The
source identification numbers (IDs) listed in the table correspond to
the stack numbers identified in Table 9.3-7. Additional notes and
conservative assumptions used in the modeling are also summarized in
Table 9.3-8. For example, worst-case operating assumptions for the hot
water heaters and CTG assume air pollution control system malfunction
conditions in one of the hot water heaters for short-term average
emission rates, and startup conditions are factored into the annual
emission rates. With respect to the CTG/HRSG, the worst-case short-term
emission rates from the two CTG manufacturers under consideration were
used as model input. In addition, worst-case emissions are based on
continuous operation of the CTG and HRSG at 100 percent load at an
ambient temperature of -7ºF. In the event that AES decides to construct
and operate the Power Plant and it is determined to be subject to PSD
review, an analysis of impacts over a range of operating loads and
ambient temperatures will be conducted as part of the PSD modeling
analysis in order to verify the worst-case impact scenario.

##### Good Engineering Practice (GEP) Stack Height Analysis

Building and structure dimensional data for the GEP stack height, cavity
and downwash analyses are summarized in Appendix 9B, Table 9B-1. The
dimensional data for all significant buildings/structures as well as the
layout and orientations on site are based on the site plan and general
arrangement plans presented in Resource Report 13, *Engineering and
Design Material*. In addition, typical dimensions of LNG ships for input
to the models were obtained from plan and elevation drawings and
photographs of a range of actual LNG ships currently in use. For
purposes of the modeling analyses, two LNG ships were assumed to be at
berth at the same time, one in the process of offloading and the other
hoteling.[^9] To cover the range of sizes of LNG ships that could be
accommodated at the LNG Terminal, one ship was assumed to be a 138,000
cubic meter capacity and the other was assumed to be 210,000 cubic meter
capacity.  In addition, for modeling purposes, an additional position
for a 210,000 cubic meter LNG ship in the tuning basin was assumed for
one of the two ships at the terminal.  The additional position was
assumed so that maximum potential emissions from the assist tugs and
security and patrol boats operating during the berthing process could be
conservatively modeled accounting for the downwash, cavity and wake
effects that would result while an LNG ship is at that location.

The buildings and structures were processed using the EPA Building
Profile Input Program (BPIP, version 04274) to determine GEP stack
heights as well as direction-specific building heights and widths for
each 10-degree azimuth direction for each source included in the
modeling analysis. BPIP input and output files are included in the
modeling CD provided in Appendix 9B. Figure 9.3-2 depicts the BPIP model
setup for the identified significant buildings or structures on site.
Figure 9.3-3 is a three-dimensional representation of the significant
buildings and structures.

GEP stack height calculations were performed with the BPIP program based
on the building/structure dimensions and the methodology described in
EPA's [Guideline for Determination of Good Engineering Practice Stack
Height (Technical Support Document for the Stack Height Regulations
(June 1985).]{.underline} The GEP stack height calculated for all
stacks, with the exception of the assist tugs and security and patrol
vessels was approximately 130 meters (427 feet), with some variation due
to differences in stack and building/structure base elevations. The
significant structures affecting the GEP stack height for each of these
stacks were the LNG storage tanks, each with a height of 51.65 meters
(169.5 feet). The GEP stack height calculated for the assist tugs and
security and patrol vessels was approximately 94 meters (308 feet),
based on the dimensions of the LNG ship in the turning basin. Each of
the proposed stack heights is less than the calculated GEP stack
heights, and the stacks are also located within the 5L zone of influence
from the significant structures. Therefore, downwash and cavity zone
impact analyses, incorporated in the AERMOD with PRIME model, were
performed based on the dimensions of the controlling structures.

##### Meteorological Data and Site Characteristics

For refined modeling, the *Guideline on Air Quality Models* recommends
one year of on-site data or 5 years of off-site representative data. For
this modeling analysis, 5 consecutive years of meteorological data were
provided by MPSC's air quality consultant (ERM) from the closest and
most representative National Weather Service (NWS) stations to the LNG
Terminal site. Surface data from NWS Station \# 93721 (Baltimore
Washington International Airport - BWI) and upper air data from NWS
Station \# 93734 (Sterling, Virginia), both for the years 1990 to 1994,
were selected for input to AERMET, a meteorological pre-processor
program used in conjunction with AERMOD. BWI is located approximately 15
km (9.3 miles) southwest of the Terminal Site. AES concurs with ERM in
considering this station to have surface meteorological data and land
use characteristics that are representative of the Terminal Site.
Selection of BWI surface data is justified on the basis of spatial and
climatological (temporal) representativeness, as well as the ability of
the selected site parameters to characterize the transport and
dispersion conditions in the area of concern. The representativeness of
the data is demonstrated based on: (1) The proximity of the
meteorological monitoring site to the area under consideration (BWI is
within the modeling domain and only 15 km from the emission sources);
(2) the similarity in the complexity of the terrain (both BWI and the
area surrounding the LNG Terminal have relatively flat terrain and have
similar urban land use); (3) the exposure of the meteorological
monitoring site; and (4) the period of time during which data are
collected.

ERM processed the raw data with AERMET (Version 04300), the
meteorological preprocessor for AERMOD. In accordance with EPA guidance
(*AERMOD Implementation Guide, September 27, 2005*), ERM developed the
season and sector specific surface inputs (albedo, Bowen ratio, and
roughness length) through the use of an in-house software program that
assigned these parameters based on land use within a 3 km area
surrounding the BWI airport divided into 12 equally-spaced sectors. Land
use information was extracted from USGS Composite Theme Grid (CTG)
files, and parameter values were assigned based on Tables 4-1 through
4-3 presented in the AERMOD user\'s guide. The site characteristics by
sector and season developed with this approach are summarized in
Appendix 9B, Table 9B-4. Land use surrounding BWI is predominately
characterized as urban. Therefore, the urban dispersion option was used
for the AERMOD modeling and the default value of 1.0 was used for the
urban roughness length. In addition, all land-based stationary sources
associated with the LNG Terminal were listed as urban sources.

##### Receptors and Terrain Data

A non-uniform polar grid receptor network was initially set up in AERMOD
using rings of receptors spaced at 10 degree intervals on 36 radials
originating at the approximate center of the LNG Terminal emission
sources. A total of 19 receptor rings were defined at the following
distances in meters from the origin:

-   0 -- 2 km with 100 meter spacing

-   2 -- 5 km with 500 meter spacing

-   5 -- 10 km with 1,000 meter spacing

-   10 -- 16 km with 2,000 meter spacing

The extent of the receptor network was believed to be sufficient to
identify the significant impact area with sufficient resolution. In
order to import terrain elevations associated with each of the
receptors, the polar grid was converted into discrete Cartesian
receptors.

The portion of the LNG Terminal located on land will be fenced and not
accessible to the general public. In addition, the general public will
be restricted access to areas over water surrounding the LNG ships at
berth and while in transit. As discussed in Section 9.3.5.1.A., the USCG
has not yet determined the preliminary extent of the excluded safety and
security zone. However, for the purposes of the modeling analysis, it
was assumed that it would be defined by a minimum radius of 500 yards
from the LNG ship berth. In addition, the USCG will establish a safety
and security zone around each LNG ship while it is in transit. For
purposes of the modeling analysis and determining the "fenceline" for
restricted public access, this safety and security zone was also assumed
to extend 500 yards from each side of the LNG ship. If the safety and
security zone ultimately established by the USCG is greater than these
assumptions, it would reduce the impacts at fenceline receptors.

A total of 56 discrete receptors were placed along the proposed
"fenceline", including 26 primary receptors at each node of the
fenceline polygon and 30 receptors at intermediate points between nodes.
Discrete Cartesian receptors located within the plant boundary were
eliminated, since the property will not be accessible by the general
public. Figure 9.3-4 depicts the near-field receptors, fenceline and
plant boundary receptors, with those within the plant boundary
eliminated. Figure 9.3-5 depicts the entire receptor network within the
modeling domain boundaries.

Terrain elevations at each of the receptor points were specified by
importing 7.5 minute USGS Digital Elevation Model (DEM) data into
ISC-AERMOD View interface. The DEM data was obtained from
www.webgis.com. UTM Zone 18 (NAD27) was used as the common reference for
model setup. The method used to select the elevation for each receptor
involved importing the highest elevation from within a bounding polygon,
where the bounding polygon is defined by half the distance to adjacent
receptor grid nodes.

##### Background Air Quality

Modeled pollutant concentrations are added to background air quality
data to evaluate compliance with NAAQS. Background air quality data are
conservatively used to account for pollutant concentrations that are
otherwise not accounted for in single-source or multiple-source modeling
analyses. Representative background concentrations were obtained from
the average of the most recent available three years of monitoring data
(2003-2005) at the three monitoring sites nearest to the LNG Terminal
site. Table 9.3-3 (and Appendix 9B Table 9B-5, with all values converted
to µg/m^3^) summarizes the background ambient data and the monitoring
sites determined to be most representative of the LNG Terminal modeling
domain in AQCR 115.

##### Model Results

The AERMOD model was used to predict maximum ambient air quality impacts
for each of the scenarios identified in Section 9.3.5.1.A for the LNG
Terminal with and without the Power Plant. Model results are summarized
for each of the scenarios in Table 9.3-9. Following FERC Staff guidance,
maximum impacts were first compared to EPA SILs. If impacts were
estimated to exceed the respective SILs, representative ambient
background concentrations were then added to modeled impacts and the
total concentrations were compared to NAAQS. As summarized in Table
9.3-9, estimated impacts from the LNG Terminal stationary sources with
and without the Power Plant are less than respective SILs for SO~2~, CO
and Pb. When LNG ship offloading emissions are added, only CO and Pb
impacts are less than the respective SILs. When secondary (marine
vessel) sources are added to the modeling scenarios, only Pb impacts are
lower than the SIL. However, when representative ambient background
concentrations are added to modeled impacts, compliance with all
applicable NAAQS is demonstrated for all pollutants currently included
in the Maryland SIP, as shown in Table 9.3-9.

The offsite areas where maximum modeled impacts are predicted to exceed
the SILs occur in close proximity to the LNG Terminal. Even with the
worst-case scenario involving all LNG Terminal and Power Plant sources,
LNG ship offloading and marine vessels, the maximum distances to SILs
were all within 1,500 meters from the approximate center of the
land-based LNG Terminal sources (within 1,250 meters from the property
line) for all pollutants except CO and within 3,000 meters from the
center (1,800 meters from the property line) for CO. CO impacts above
SILs were exclusively due to estimated emissions from outboard gasoline
engines used in security and patrol boats, which have relatively high CO
emission factors relative to all other modeled sources.

However, representative 24-hour and annual average PM~2.5~ ambient
background concentrations currently exceed the applicable AAQS and AQCR
115 has been designated nonattainment for PM~2.5~. AES understands that
Maryland is currently developing a SIP revision to address the NNSR
requirements applicable to the annual average standard. However, due to
the recent final rule revising the PM~2.5~ 24-hour standard from 65 to
35 µg/m^3^ (effective December 18, 2006), nonattainment designations
with respect to the 24-hour standard are pending, as are further SIP
revisions to incorporate NNSR requirements for the revised PM~2.5~
24-hour standard. In addition, an EPA final rule on implementation of
the PM~2.5~ standards during the transition period while SIPs are under
development is still pending. Therefore, AES understands that
demonstration of compliance with the NAAQS currently does not include an
analysis of potential PM~2.5~ impacts.

##### Cumulative Impacts Analysis

AES understands that the FERC Staff requires a qualitative cumulative
impact analysis where predicted impacts associated with a proposed
project exceed the SILs. AES further understands that additional FERC
guidance for performing such an analysis is pending as some of the
details are being worked out with EPA and affected states. Other similar
FERC-jurisdictional projects have performed qualitative cumulative
impact analyses by comparing potential direct and indirect emissions
from the proposed project under review and other new or reasonably
foreseeable projects in the region with regional emission inventories.
Based on consultation with FERC Staff, AES understands that FERC Staff
likely will use the predicted significant impact area (offsite areas
where maximum modeled impacts are predicted to exceed the SILs) to
define the geographic region for which AES must identify other new and
reasonably foreseeable projects to be included in the cumulative impacts
analysis. Pending further guidance, AES also understands that a
reasonable approach for assessing the regional significance of
cumulative emissions is to compare them to a preliminary threshold
equivalent to 10 percent of the county-wide annual emission inventory. A
project would not be considered regionally significant if the cumulative
emissions were predicted to be less than 10 percent of the existing
county inventory.

As discussed in Section 9.3.5.1.H., the worst-case significant impact
area based on the modeling results for the scenario involving all
primary and secondary emission sources extends less than 3,000 meters
for CO and less than 1,500 meters for all other pollutants from the
approximate LNG Terminal center point. Furthermore, the modeled
significant impact area for CO occurs entirely over water to the west of
the LNG Terminal site and the significant impact area for other
pollutants occurs over the Sparrows Point Industrial Complex to the east
of the LNG Terminal property lines. AES has not identified any new or
reasonably foreseeable projects located in these significant impact
areas determined by the modeling. Therefore, potential emissions from
the Project alone were compared to the most recent available Baltimore
County emission inventory (2001) data available from USEPA
(http://www.epa.gov/air/data/geosel.html). The Baltimore County emission
inventory is summarized in Appendix B Table 9B-9 and the comparison of
Project direct and indirect emissions to the County inventory is
summarized in Table 9.3-10. The analysis shows that worst-case Project
emissions (including the LNG Terminal, Power Plant, LNG offloading and
indirect emissions associated with the Project in MD) are estimated to
be considerably less than 10 percent of the Baltimore County emission
inventory for all pollutants, with the exception of ammonia. Maximum
ammonia emissions, due primarily to worst-case ammonia slip emissions
from the Power Plant SCR system used to control NO~X~ emissions, are
estimated to be 11.8 percent of the Baltimore County ammonia emissions
inventory. Based on this analysis, worst-case direct and indirect
emissions from the Project are not considered regionally significant
because the significant impact areas are predicted to be close to the
LNG Terminal, no other new or reasonably foreseeable sources are
expected to be located within the small significant impact area and
total Project direct and indirect emissions would be a small percentage
of the Baltimore County emissions inventory.

##### Cooling Tower Impact Analysis

If AES decides to construct and operate the Power Plant, a mechanical
draft evaporative cooling tower will be used to remove waste heat from
the steam condenser cooling water when the Power Plant is operated
without LNG send-out (expected to be less than 33 percent of the time if
the Power Plant is constructed and operated). Mechanical draft cooling
towers can produce environmental impacts due to the liquid water plume
coming directly from the tower (known as "drift"), as well as from the
secondary liquid water formation caused by the condensation of water
vapor ("fogging"). These impacts include: local shading of the sun due
to a visible plume, fogging at ground level and ice build-up, and
deposition of dissolved salt particles.

A detailed modeling analysis of cooling tower impacts was performed to
evaluate the potential for these impacts from operation of the Project
using the Seasonal/Annual Cooling Tower Impact (SACTI) model (Version
09-01-86). The SACTI model was funded by the Electric Power Research
Institute (EPRI). It is based on studies conducted by Argonne National
Laboratory that evaluated the theory and performance of over 30 cooling
tower plume and drift models. The SACTI model was used for this analysis
because it is a validated cooling tower plume and drift model that has
been widely used in preparing environmental assessments of cooling
towers for regulatory purposes. The SACTI model uses cooling tower
design and operational data along with hourly meteorological data to
predict the probable impact of cooling tower plumes.

The results of the analysis are summarized in Table 9.3-12. In summary,
the Power Plant cooling tower was evaluated for environmental impacts
using the SACTI model. Based on this analysis, no adverse off-site
environmental effects are expected.

> Table 9.3-12 -- Summary of Cooling Tower Impact Analysis Results

  ----------------------- ----------------------- -----------------------
  Cooling Tower Impact    Estimated Impacts       Estimated Location and
  Description             (units based on 5 years Extent of Impacts
                          of hourly meteorology)  

  Plume Fogging           7.2 hours per year      Predominantly within
                                                  600 meters
                                                  west-south-west of the
                                                  cooling tower.

  Rime Icing              0 hours per year        No icing is expected to
                                                  occur.

  Salt Deposition         Maximum 7,231           Predominantly within
                          kg/km^2^-month on site  100 meters of tower and
                                                  on site.

  Plume Shadowing         Maximum 200             Predominantly within
                          hours/5-years           200 meters
                                                  west-north-west of
                                                  tower and on site.

  Plume Visibility        Plume typically visible Visible plume
                          on site when cooling    predominantly located
                          tower is operating      onsite with dimensions
                          (max. 33% of time only  less than 100 meters in
                          if Power Plant is       length, 20 to 30 meters
                          operated)               in height and 10-15
                                                  meters in radius.
  ----------------------- ----------------------- -----------------------

### Mitigation of Air Quality Impacts

#### Construction Air Quality Impacts Mitigation

The construction of the Project will result in minor, short-term impacts
to local ambient air quality. AES has developed the Fugitive Dust
Suppression and Monitoring Plan included as Appendix D to control
fugitive dust emissions associated with project construction and
operation. A summary of the actions that may be used to minimize these
impacts is as follows:

-   Require contractors to meet all federal, state and local air quality
    regulations and emission standards applicable to their equipment;

-   Apply water or dust suppressants to disturbed areas, as necessary,
    to reduce vehicle traffic dust;

-   Cover open hauling trucks with tarps, as necessary;

-   Use paved roads for construction vehicle traffic, wherever
    practical;

-   Limit vehicle speeds as required to reduce dust generation;

-   Respond promptly to any significant particulate emission concerns
    that occur during construction by evaluating the source of emissions
    and ensuring all practicable mitigation measures are being
    implemented; and

-   Upon completion of construction activity, stabilize disturbed areas.

In addition, mitigation measures required to comply with general
conformity will be implemented. These measures include a demonstration
of consistency with applicable control measures and regulations that are
relied upon in the SIP, a demonstration that direct and indirect
emissions have been identified and accounted for in the SIP attainment
demonstration or the emissions must be offset through a SIP revision or
other enforceable measure so that there is no net increase in emissions.

#### Operational Air Quality Impacts Mitigation

The emissions control systems proposed for the hot water heaters at the
LNG Terminal would include low-NO~X~ burners and/or flue gas
recirculation for preliminary NO~X~ control, SCR for final NO~X~ control
and oxidation catalysts for CO control. The proposed emissions controls
and stringent emissions limitations were determined from a review of
recent BACT and LAER determinations for similar boilers and preliminary
vendor guarantees; they are considered to be state-of-the-art for these
types of sources. A tabular summary of the most relevant BACT/LAER
determinations from EPA's RACT/ / BACT/ / LAER Clearinghouse (RBLC) is
presented in Table 9.3-11. The proposed NO~X~, CO, and VOC emissions
levels from the hot water heaters are 3, 10, and 10 ppmvd at three
percent O~2~, respectively. As discussed in Section 9.3.3, these
emissions levels will easily comply with applicable federal and state
emission standards. The exclusive use of natural gas in these combustion
sources will also minimize emissions and impacts of SO~2~ and
PM~10~/PM~2.5~.

The emissions control systems proposed for the CTG with HRSG at the
Power Plant would include dry low-NO~X~ combustors (DLN) for initial
NO~X~ control in the CTG, SCR for final NO~X~ control and oxidation
catalysts for CO control. The proposed emissions controls and stringent
emissions limitations were determined from a review of recent BACT and
LAER determinations obtained from EPA's RBLC for similar combined cycle
power plants (see Table 9.3-12) and preliminary vendor guarantees; they
are considered to be state-of-the-art for these types of sources. The
proposed NO~X~, CO, and VOC emissions levels from the CTG with HRSG are
2, 3, and 5 ppmvd at three percent O~2~, respectively. As discussed in
Section 9.3.3, these emissions levels will comply with applicable
federal and state emission standards. The exclusive use of natural gas
in these combustion sources will also minimize emissions and impacts of
SO~2~ and PM~10~/PM~2.5~.

## Noise Quality

The construction and operation of the Project will generate noise. AES
will utilize noise control measures, as necessary, to reduce the
potential noise quality impacts to nearby sensitive receptors associated
with the Project, consistent with applicable requirements under federal,
state, and local regulations and ordinances. This section 9.4 of
Resource Report 9:

-   Outlines applicable federal, state, and local noise standards;

-   Identifies noise sensitive areas (NSAs) and areas of concern
    identified in the applicable standards;

-   Quantifies existing background noise levels;

-   Characterizes the potential noise levels associated with
    construction and operation of the Project and the potential impacts
    of those levels on nearby sensitive receptors; and,

-   Outlines potential mitigation measures that may be implemented
    during construction and operation of the Project.

### Noise Overview

Sound is a physical phenomenon consisting of minute vibrations that
travel through a medium, such as air, and are sensed by the human ear.
Human response to noise varies according to the type and characteristics
of the noise source, distance between source and receiver, and receiver
sensitivity. Sound levels are expressed in units of decibels. The term
decibel (dB) implies a logarithmic ratio of the measured pressure to a
reference pressure. This reference pressure refers to a pressure just
barely detectable by the human ear. The human ear responds differently
to sounds at different frequencies. To adjust for the different
\"loudness\" levels as perceived by humans, a standard "A" weighting
curve (dBA) is applied to measured sound levels.

Because noise levels can vary over a given time period, they are further
quantified using different time weighted sound metrics. Two of these
metrics commonly used to relate the time-varying quality of
environmental noise to its known effects on people are the equivalent
sound level (Leq) and the day-night sound level (Ldn). Leq is an average
of sound energy over a given time expressed in dB. Ldn is a weighted
24-hour average of sound energy that takes into account the time of day
the noise is encountered. Late night and early morning (10:00 p.m. to
7:00 a.m.) noise exposures are adjusted by 10 dB, to account for
people's greater sensitivity to sound during the nighttime hours.

### Regulatory Overview

In 1974, EPA published "Information on Levels of Environmental Noise
Requisite to Protect Public Health and Welfare with an Adequate Margin
of Safety" (EPA 1974). This publication evaluates the effects of
environmental noise with respect to health and safety. The document
provides information to help agencies develop noise standards and
regulations. EPA recommends that Ldn should not exceed 55 dBA to protect
public welfare. FERC has adopted the EPA's recommendations and requires
that the sound attributable to new facilities (including LNG terminals)
not exceed an Ldn of 55 dBA at the nearest NSA (18 CFR §
380.12(k)(4)(v)(A)); unless such NSAs are established after facility
construction. FERC also require that a project not result in a
perceptible increase in vibration at any NSA (18 CFR §
380.12(k)(4)(v)(B)).

The State of Maryland's Environmental Noise Act of 1974 limits noise to
that level which will protect the health, general welfare, and property
of the people of the State. The State of Maryland limits both the
overall noise environment and the maximum allowable noise level for
residential, industrial, and commercial areas. For residential
activities, the overall noise levels are the same as the FERC standard
(55 dBA Ldn). Construction and demolition activities are exempt from the
limits outlined in Tables 9.4-1 and 9.4-2 during the daytime hours. For
construction and demolition activities a person may not cause or permit
noise levels which exceed 90 dBA during daytime hours (7:00 a.m. to
10:00 p.m.) or levels specified in Table 9.4-2 during nighttime hours.
In addition, while the regulations specify a maximum allowable noise
level for pile driving activities, that standard does not apply between
the hours of 8:00 a.m. and 5:00 p.m. (COMAR 26.02.03).

**Table 9.4-1\
State of Maryland Overall Environmental Noise Standards**

+-------------------------------------+------------------+-------------+
| **Zoning District**                 | **Level**        | **Measure** |
|                                     |                  |             |
|                                     | **(dBA)**        |             |
+-------------------------------------+------------------+-------------+
| Industrial                          | 70               | Leq(24)     |
+-------------------------------------+------------------+-------------+
| Commercial                          | 64               | Ldn         |
+-------------------------------------+------------------+-------------+
| Residential                         | 55               | Ldn         |
+-------------------------------------+------------------+-------------+

Source: Code of Maryland Regulations (COMAR), Title 26.02.03.

**Table 9.4-2\
Maximum Allowable Noise Levels (dBA) For Receiving Land Use Categories**

  ------------------ ------------------ ------------------ -----------------
  **Day/Night**      **Industrial**     **Commercial**     **Residential**

  Day                75                 67                 65

  Night              75                 62                 55
  ------------------ ------------------ ------------------ -----------------

Source: Code of Maryland Regulations (COMAR), Title 26.02.03.

Note: Daytime construction noise limits are 90 dBA for all land use
categories.

The State of Maryland's noise standard also states a person may not
cause or permit, beyond the property line of a source, vibration of such
direct intensity to cause another person to be aware of the vibration by
such direct means as sensation of touch or visual observation of moving
objects. This is consistent with the FERC regulation (18 CFR §
380.12(k)(4)(v)(B)).

Although Baltimore County, Maryland maintains a planning noise
ordinance, the local code does not set strict noise levels or standard
not to be exceeded. It does prohibit the establishment of a facility or
activity that will generate noise levels that would interfere with the
welfare of other nearby land uses (Baltimore County 2006). Both the
federal and the state noise regulations are more restrictive and concise
than the local ordinance.

### Existing Noise Levels

FERC identifies residences, schools, hospitals, churches, and similar
uses as NSAs (18 CFR § 380.12(k)(4)). Figure 9.4-1 identifies the
nearest NSAs and land uses near the Terminal Site. There are no NSAs
within one mile of the proposed LNG Terminal. The nearest NSA (NSA#1) is
a Dundalk residence approximately 5,450 feet north of the proposed
Terminal Site (distances provided from the Terminal). The other NSAs
identified include:

-   Edgemere residence (NSA#2) (9,400 feet east);

-   Residential Neighborhood adjacent to Veterans Affairs (VA) medical
    center south of Edgemere (NSA#3) (14,100 feet southeast); and

-   Fort Armistead Park South of the Francis Scott Key Bridge (NSA#4)
    (9,650 feet west).

Ambient noise monitoring was completed over a 24-hour period from
October 22 to 23,, 2006. Details regarding these measurements
(monitoring duration, equipment, ambient conditions, etc) are included
in Appendix 9C, Sparrows Point Project - Site Sound Survey and Noise
Impact Evaluation. The monitoring locations are presented on Figure
9.4-1 and the measured daytime and nighttime ambient Leq levels and the
Ldn levels are summarized in Table 9.4-3. In addition to noise level
measurements, AES identified and recorded the contributing noise
sources, along with the prevailing meteorological conditions (Table
9.4-4). Specifically, as shown on Figure 9.4-1, there is a large
interstate highway (I-695) located north between the LNG Terminal Site
and NSA #1 and industrial (steel mill) operations located northeast
between the LNG Terminal Site and NSA #2. As anticipated, these sources
dominated the existing noise environment at these locations.

> **Table 9.4-3\
> Measured Daytime and Nighttime Noise Levels at Nearest NSA**

+----+--------------------+------------+--------+---------+----------+
| *  | **NSA              | **Distance | **Leq  | **Leq   | **Est    |
| *N | Description**      | and        | Day    | Nigh    | imated** |
| SA |                    | D          | time** | ttime** |          |
| ** |                    | irection** |        |         | *        |
|    |                    |            |        |         | *Overall |
|    |                    |            |        |         | Ldn**    |
+----+--------------------+------------+--------+---------+----------+
| 1  | Dundalk residence  | 5,450      | 67.4   | 58.1    | 67.7     |
|    |                    | Feet\      |        |         |          |
|    |                    | north      |        |         |          |
+----+--------------------+------------+--------+---------+----------+
| 2  | Edgemere residence | 9,400      | 65.3   | 53.1    | 64.6     |
|    |                    | Feet\      |        |         |          |
|    |                    | east       |        |         |          |
+----+--------------------+------------+--------+---------+----------+
| 3  | Residential        | 14,100     | 52.5   | 51.37   | 58.0     |
|    | Neighborhood       | Feet       |        |         |          |
|    | Adjacent to VA     | southeast  |        |         |          |
|    | medical center     |            |        |         |          |
+----+--------------------+------------+--------+---------+----------+
| 4  | Fort               | 9,650 Feet | 53.4   | NA\*    | 59.8     |
|    | Armistead Park     | west       |        |         |          |
+----+--------------------+------------+--------+---------+----------+

> NA = Not available
>
> \*nighttime access to the site restricted
>
> **Table 9.4-4\
> Dominant Noise Sources and Meteorological Conditions During Noise
> Measurements**

+---+------------------+--------------+----------------------------+---+
| * | **NSA            | **Me         | **Dominant Sources of      |   |
| * | Description**    | teorological | Noise**                    |   |
| N |                  | Conditions** |                            |   |
| S |                  |              |                            |   |
| A |                  |              |                            |   |
| * |                  |              |                            |   |
| * |                  |              |                            |   |
+---+------------------+--------------+----------------------------+---+
| 1 | Dundalk          | Partly       | Freeway traffic            |   |
|   | residence        | Cloudy\      |                            |   |
|   |                  | 50-70 ºF     | Local roadway traffic      |   |
|   |                  |              |                            |   |
|   |                  | north wind   | Heavy truck noise          |   |
|   |                  | 0-3 mph      |                            |   |
|   |                  |              | Vegetation / wind noise    |   |
|   |                  |              |                            |   |
|   |                  |              | Mid-altitude aircraft      |   |
|   |                  |              | overflights                |   |
+---+------------------+--------------+----------------------------+---+
| 2 | Edgemere         | Partly       | Distant industrial noise   |   |
|   | residence        | Cloudy 60-70 |                            |   |
|   |                  |              | Warning horns              |   |
|   |                  | northeast    |                            |   |
|   |                  | wind 0-3 mph | Local roadway traffic      |   |
|   |                  |              |                            |   |
|   |                  |              | Dog barking                |   |
|   |                  |              |                            |   |
|   |                  |              | Mid-altitude aircraft      |   |
|   |                  |              | overflights                |   |
+---+------------------+--------------+----------------------------+---+
| 3 | Residential      | Partly       | Distant Steady State       |   |
|   | Neighborhood     | Cloudy\      | Industrial Noise           |   |
|   | adjacent to      | 60-70 ºF     |                            |   |
|   | Veterans Affairs |              | Wind and Vegetation Noise  |   |
|   | (VA) medical     | east wind    |                            |   |
|   | center           | 0-5 mph      | Water and Wave Noise       |   |
|   |                  |              |                            |   |
|   |                  |              | Mid-altitude aircraft      |   |
|   |                  |              | overflights                |   |
|   |                  |              |                            |   |
|   |                  |              | Local Vehicle Traffic      |   |
+---+------------------+--------------+----------------------------+---+
| 4 | Fort             | Partly       | Wind and Vegetation Noise  |   |
|   | Armistead Park   | Cloudy\      |                            |   |
|   |                  | 60-70 ºF     | Water and Wave Noise       |   |
|   |                  |              |                            |   |
|   |                  | southwest    | Mid-altitude aircraft      |   |
|   |                  | wind 0-6 mph | overflights                |   |
|   |                  |              |                            |   |
|   |                  |              | Local Vehicle Traffic      |   |
|   |                  |              |                            |   |
|   |                  |              | Nearby Railroad Whistle    |   |
|   |                  |              | Stop                       |   |
+---+------------------+--------------+----------------------------+---+

For comparison to the State of Maryland noise standards, additional
fenceline ambient noise measurements at the proposed Terminal Site
property boundaries were taken (Table 9.4-5) on October 23, 2006. During
these measurements, the weather was partly cloudy, 50-60 ºF, with winds
ranging from 5 to 10 miles per hour (generally off the water from the
west). Existing sources of noise included non-road vehicles, steam
exhaust from steel mill, perimeter road traffic, wind, distant
industrial activities, and mid-altitude aircraft overflights.

> **Table 9.4-5\
> Measured Noise Levels At Proposed Sparrows Point LNG Terminal Property
> Boundaries**

+-------------+------------------------+-------------------+----------+
| **Fenceline | > **Description**      | > **Adjacent Land | >        |
| Locations** |                        | > Use**           |  **Leq** |
+-------------+------------------------+-------------------+----------+
| 5           | > southern property    | > Industrial      | > 57.9   |
|             | > boundary             |                   |          |
+-------------+------------------------+-------------------+----------+
| 6           | > eastern property     | > Industrial      | > 58.4   |
|             | > boundary             |                   |          |
+-------------+------------------------+-------------------+----------+
| 7           | > northern property    | > Industrial      | > 62.4   |
|             | > boundary             |                   |          |
+-------------+------------------------+-------------------+----------+

### Noise Impacts

Construction and operation of the Project will have no significant
impacts on any NSA, including the closest NSA located within 5,450 feet
of the Terminal Site. Noise levels will be below both the federal and
state noise control standards. AES intends to comply with all applicable
local and state noise regulations outlined in Section 9.4.3. The
potential noise impacts associated with the following activities were
assessed:

-   LNG Terminal and Power Plant construction, and Pipeline construction
    and commissioning, along the construction right-of-way - including
    heavy machinery and Horizontal Directional Drilling (HDD)
    operations;

-   Operation of Pipeline facilities including mainline valve facilities
    and interconnection tie-in locations;

-   Operation of the LNG Terminal and Power Plant (including major
    sheltered and unsheltered noise producing equipment) ; and,

-   Dredging operations.

This noise impact evaluation considered significant sound sources
associated with the proposed LNG Terminal and optional cogeneration
facility that could affect nearby NSAs. All significant sources of
noise, their contribution to the overall noise environment, and maximum
sound level were estimated for comparison to the FERC and Maryland noise
standards. Details of this evaluation are included in Appendix 9C,
Sparrows Point Project - Site Sound Survey and Noise Impact Evaluation.

#### Construction

The most likely sources of noise generation during the construction
phase of the Project are trenching and pipelaying activities, pile
driving and dredging during the construction of the LNG Terminal, and
HDD operations at waterbody crossings. The specific impact of
construction activities on the nearest receptors will vary during the
construction period depending on the type, number, and loudness of
equipment in use at any given time.

Individual pieces of construction equipment typically generate noise
levels of 80 to 90 dBA at a distance of 50 feet. With multiple items of
equipment operating concurrently, noise levels can be relatively high
during daytime periods at locations within several hundred feet of
active construction sites. The zone of relatively high construction
noise levels typically extends to distances of 400 to 800 feet from the
site of major equipment operations. Locations more than 1,000 feet from
construction sites seldom experience substantial levels of construction
noise. Table 9.4-6 presents typical noise levels (dBA at 50 feet) that
EPA has estimated for the main phases of outdoor construction.

> **Table 9.4-6\
> Noise Levels Associated with Outdoor Construction**

  ------------------------------------ ----------------------------------
  **Construction Phase**               **Leq (dBA) at 50 feet from
                                       Source**

  Ground Clearing                      84

  Excavation, Grading                  89

  Foundations                          78

  Structural                           85

  Finishing                            89
  ------------------------------------ ----------------------------------

> Source: US EPA, 1971.

Trenching and pipelaying activities will cause temporary increases in
ambient noise levels near the construction areas. The majority of the
trenching and pipelaying activities will be conducted during daytime
hours. At certain locations where traffic and/or road-use restrictions
will affect the construction schedule, construction will proceed during
late evening hours. Equipment will not be fixed in one location for long
durations, but will progress along the construction right-of-way.
Trenching and pipelaying noise will be temporary, and will subside at
any particular location as construction progresses to subsequent
segments of the Pipeline.

Since individual pieces of construction equipment typically generate
noise levels of 80 to 90 dBA at a distance of 50 feet (Table 9.4-6), it
is anticipated that levels greater than 90 dBA will be experienced where
construction activities will be undertaken within 50 feet of a
residence. Noise levels are expected to exceed the State of Maryland's
noise standards (90 dBA) and the use of appropriate mitigation measures
will be required. As previously indicated any potential impacts
associated with these levels are anticipated to be temporary in nature
based on transient and mobile nature of the construction equipment and
the relatively short time of pipeline construction work sequencing
adjacent to any given residential structure. As outlined in Resource
Report 8, *Land Use, Recreation and Aesthetics*, AES will incorporate
residential mitigation measures for properties where construction will
occur within 50 feet of a residence. In addition, AES will file
site-specific residential mitigation plans for properties where
construction will occur within 25 feet of a residence. These plans will
include reporting, monitoring, and mitigation procedures to address
specifically noise issues. The period of construction near the
residences will be compressed as much as possible to reduce adverse
noise effects to nearby residents.

Construction of the LNG Terminal and Power Plant will similarly cause
temporary increases in ambient noise levels. The majority of the
construction will be conducted during daytime hours and will be
temporary in nature. Pile driving for the LNG storage tank foundations
and the pier will generate the most intense noise associated with
construction of the proposed facilities. Estimated noise levels
associated with the pile driving activities at NSAs are not anticipated
to exceed the 90 dBA daytime threshold outlined in the State of Maryland
noise regulations (Table 9.4-7). In addition, pile-driving activities
are specifically exempted from the noise regulation between the hours of
8:00 a.m. and 5:00 p.m. Pile driving activities are intermittent by
nature and will not be conducted during nighttime hours (10:00 p.m. to
7:00 a.m). All other construction activities are anticipated to be
quieter than the pile driving activities, and subsequently will not have
an adverse effect on nearby land uses or NSAs.

**Table 9.4-7**

**Predicted Sound Levels at Nearest Noise Sensitive Areas and Fenceline
Locations Associated with Pile Driving Activities**

+-------------+-----------------+------------+------------+------------+
| **NSA/**    | **Distance and  | *          | **Maryland | **Exceeds  |
|             | Direction**     | *Predicted | Maximum    | Maryland   |
| **Fenceline |                 | Pile       | Allowable  | Noise      |
| Location**  |                 | Driving    | Noise      | Limits     |
|             |                 | Sound      | Limits     | \[         |
|             |                 | Level Leq  | (dBA)\***  | Yes/No\]** |
|             |                 | (dBA)**    |            |            |
+-------------+-----------------+------------+------------+------------+
| 1           | 5,450 Feet      | 63         | 90 (55)    | No         |
|             | north           |            |            |            |
+-------------+-----------------+------------+------------+------------+
| 2           | 9,400 Feet east | 58         | 90 (55)    | No         |
+-------------+-----------------+------------+------------+------------+
| 3           | 14,100 Feet     | 55         | 90 (55)    | No         |
|             | southeast       |            |            |            |
+-------------+-----------------+------------+------------+------------+
| 4           | 9,650 Feet west | 58         | 90 (55)    | No         |
+-------------+-----------------+------------+------------+------------+
| 5           | southern        | 81         | 90 (75)    | No         |
|             | property        |            |            |            |
|             | boundary        |            |            |            |
+-------------+-----------------+------------+------------+------------+
| 6           | eastern         | 86         | 90 (75)    | No         |
|             | property        |            |            |            |
|             | boundary        |            |            |            |
+-------------+-----------------+------------+------------+------------+
| 7           | northern        | 84         | 90 (75)    | No         |
|             | property        |            |            |            |
|             | boundary        |            |            |            |
+-------------+-----------------+------------+------------+------------+

> \*daytime limit (nighttime limit)

The Project is anticipated to involve the installation of HDD segments
at two river crossings: Susquehanna River (MP 44) and Back River (MP 9)
locations. The entry and exit points for the HDDs sites are shown on the
Project Alignment Sheets (Appendix 1D), with approximate locations of
the closest NSAs shown on Figures 9.4-2 and 9.4-3.

The expected noise impacts from the HDD operations have been quantified
using the best information available at this time (regarding typical HDD
rig and equipment for drill crossings of this magnitude) and are
tabulated below (Table 9.4-8).

**Table 9.4-8**

**Predicted Sound Levels at Nearest Noise Sensitive Areas Associated
with HDD Activities**

  ------------------ ------------------ ------------ --------- ---------------- ---------
  ** **              ** **              **No                   **w/Barriers**   
                                        Barrier **                              

  **Case**           **Distance to      **Leq        **Ldn     **Leq (dBA)**    **Ldn
                     Nearest NSA        (dBA)**      (dBA)**                    (dBA)**
                     \[feet\]**                                                 

  1: Susquehanna -   300                71           77        52               58
  Entrance                                                                      

  2: Susquehanna -   600                55           62        37               44
  Exit                                                                          

  3: Back River      800                61           68        43               49
  -Entrance                                                                     

  4: Back River -    300                62           68        44               50
  Exit                                                                          
  ------------------ ------------------ ------------ --------- ---------------- ---------

Noise associated with HDD activities at the Susquehanna entrance
location are expected to exceed the FERC 55 Ldn guidelines. With the
installation of proper sound-dampening barriers, noise at all other HDD
locations is not anticipated to exceed either state of federal noise
limits. HDD activities normally proceed according to a 24-hour schedule.
Although this will introduce nighttime noise at HDD sites, the 24-hour
construction schedule will limit the overall duration of noise
associated with these activities. Any adverse effects that will occur
during HDD operations will be of a temporary nature and cease with
completion of HDD activities.

AES is currently in the process of evaluating potential mitigation
measures due to noise impacts associated with the HDD sites including,
but not limited to, the use of mufflers, sound barriers, and equipment
and work area enclosures. To comply with state and federal noise
standards, sound generating equipment would be partially enclosed with
noise barriers at all HDD locations. In addition, at the Susquehanna
entrance location, noise monitoring will be conducted in the early
stages of construction to confirm whether the construction noise level
exceeds the 55 Ldn guidance value (EPA, 1974). If necessary, additional
noise control measures will be implemented to reduce construction noise
levels to comply with the FERC noise standard. The following mitigation
measures also can be employed, if and as necessary, to address noise
impacts identified at HDD entry and exit locations:

-   Enclose Power Unit -- The drilling rig power unit would be enclosed;

-   Enclose mud pumps and engines - The mud pumps and engines would be
    partially or totally enclosed;

-   Enclose generator sets - Generator sets would be totally enclosed or
    acoustically packaged generators would be used;

-   Modify back-up alarms - Back-up alarms on mobile equipment would be
    modified;

-   Restrict the use of mobile equipment - Use of mobile equipment would
    be restricted during nighttime hours;

-   Temporary hay bales as noise barriers - Hay bales would be placed on
    site as a temporary noise barrier when required;

-   Place silencers on equipment -- Silencers would be placed on all
    equipment where possible; and/or

-   Addressing individual NSA landowner's impacts on a case by case
    basis with measures up to or including provisions for temporary
    lodging.

#### Pipeline Facilities Operation

The aboveground facilities proposed for the Project include nine
mainline valve facilities, and three interconnection tie-in locations
with the Columbia, Transco and TETCO systems. The mainline valve
facilities and interconnection tie-in locations will not have loud
equipment and will not generate substantial noise during their
operation. The Project will not involve the operation of any compressor
facilities; therefore, the only detectable noise that will result from
operation of the Pipeline facilities will be that associated with
intermittent maintenance activity or pressure regulation equipment.
Adverse noise effects associated with maintenance activities will be
short-term and generally will not be considered significant. AES will
evaluate potential impacts and implement mitigating measures (as
necessary) associated with the pressure regulating equipment during the
detailed engineering.

#### LNG Terminal Facilities Operation

[]{.mark}

AES modeled noise levels that would be generated by operation of the
proposed LNG Terminal and Power Plant. The model receptors were the same
NSA locations where ambient noise monitoring was performed to allow a
direct comparison with existing noise levels. Sound level data for the
proposed equipment were obtained from vendors, calculated using
empirical formulas based on process and mechanical equipment data, or
from similar projects, and are outlined in Appendix 9C.

Equipment noise levels for the proposed LNG Terminal and Power Plant
were combined with the ambient noise levels to estimate future noise
levels. Noise levels were subsequently assessed with regard to FERC and
the State of Maryland noise standards. The LNG Terminal and Power Plant
are in the design stages. Therefore, a complete equipment list and
associated manufacturers specifications are not finalized. However, the
major noise producing equipment associated with the LNG Terminal and
Power Plant will include turbines, transformers, heaters, pumps,
compressors, and emergency generator(s). Much of the noise producing
equipment will be contained inside shelters that will be fabricated with
noise reducing material. Other potential noise sources such as the
natural gas send-out equipment, booster air compressor, and nitrogen
compressor will not be contained inside shelters; however, their noise
levels are not expected to contribute significantly to the noise
environment at nearby NSAs.

Table 9.4-9 presents the results of the modeling along with a comparison
with existing ambient levels, the expected noise attributable to the
proposed facility, and the increase in ambient levels as a result of
adding the LNG Terminal and Power Plant. The results of the noise impact
analysis indicate that the noise attributable to the project would be
lower than the FERC and State of Maryland's sound level requirement of
55 dBA Ldn at the nearest NSAs. In addition, additional noise due to the
proposed facility at all NSAs would be indistinguishable over the
existing noise environment. This would be due primarily to the high
levels of existing noise at the NSA, the distance between the NSAs and
the proposed facility, and the housing of potentially loud equipment.
Noise mitigation of the equipment would consist of manufacturer-supplied
intake and exhaust mufflers/silencers, and enclosures, if required.
Actual results may be different from those obtained from modeling;
therefore, a post-construction sound survey will be completed within 60
days of the LNG Terminal's commissioning and service date.

**Table 9.4-9**

**Predicted Ldn Noise Levels at Nearest Noise Sensitive Areas Associated
with the Proposed LNG Terminal and Power Plant Facility**

  --------- -------------------- -------------- -------------- --------------
  **NSA**   **Distance and       **Existing     **Predicted    **Ambient +
            Direction**          Ambient Ldn    Facility       Facility Ldn
                                 (dBA)**        Contribution   (dBA)**
                                                Ldn (dBA)**    

  1         5,450 Feet north     68             45             68

  2         9,400 Feet east      65             37             65

  3         14,100 Feet          58             31             58
            southeast                                          

  4         9,650 Feet west      60             37             60
  --------- -------------------- -------------- -------------- --------------

The results of the noise impact analysis also indicate that the noise
attributable to the LNG Terminal and Power Plant would be lower than the
State of Maryland's maximum allowable limits (Tables 9.4-9 and 9.4-10).

**Table 9.4-10**

**Predicted Sound Levels at Nearest Noise Sensitive Areas and Fenceline
Locations Associated with the Proposed LNG Terminal and Power Plant
Facility**

  ----------------- ---------------- ------------- ------------- --------------
  **NSA/Fenceline   **Distance and   **Predicted   **Maryland    **Exceeds
  Location**        Direction**      Facility      Maximum       Maryland Noise
                                     Sound Level   Allowable     Limits
                                     Leq (dBA)**   Noise Limits  \[Yes/No\]**
                                                   (dBA)\***     

  1                 5,450 Feet north 39            65 (55)       No

  2                 9,400 Feet east  31            65 (55)       No

  3                 14,100 Feet      25            65 (55)       No
                    southeast                                    

  4                 9,650 Feet west  30            65 (55)       No

  5                 southern         62            75 (75)       No
                    property                                     
                    boundary                                     

  6                 eastern property 74            75 (75)       No
                    boundary                                     

  7                 northern         67            75 (75)       No
                    property                                     
                    boundary                                     
  ----------------- ---------------- ------------- ------------- --------------

> \*daytime limit (nighttime limit)

The proposed site for the LNG Terminal is in a historically industrial
area. Previous and current land uses at, or directly adjacent to, the
site include industrial shipyard repair, the former steel mill, ship
decommissioning activities, and an existing power generation facility.
These types of activities typically generate industrial noise similar to
those associated with the proposed facility. There will be no change in
the associated land use category (industrial) and no significant change
in the overall noise environment when compared to historical use of the
site.

This analysis is very conservative in that it assumes that many pieces
of equipment are running at full power, simultaneously, 24 hours a day.
It further assumes the surface between the proposed facility and NSA to
be a hard surface. It also does not account for noise attenuation due
intervening vegetation, other buildings or berms, or masking due to
other industrial noises present.

#### Dredging Operations

The Project includes widening and deepening the existing approach
channel and turning basin at Sparrows Point to accommodate the larger
ships expected at the LNG Terminal than have utilized the existing
shipyard, floating dry dock and graving yard/coal channel (south of the
proposed LNG Terminal Site). The approach channel expansions will be
performed primarily by use of mechanical clamshell dredge or an
environmental bucket technology, if required, with some limited areas
near shore excavated by backhoe dredge.

Dredging will be completed on a 24-hour basis and will occur closest to
NSA#1 and NSA#2, as compared to other Project construction activities. A
detailed noise analysis of dredging activities was performed and results
are outlined below (Table 9.4-11). Noise attributable to the dredging
activities is not anticipated to exceed either the federal or state
noise control standards. Additional noise related to dredging activities
associated with the LNG Terminal at all NSAs would be indistinguishable
over the existing noise environment. This analysis includes a review of
both initial construction and future maintenance dredging activities.

**Table 9.4-11**

**Predicted Ldn Noise Levels at Nearest Noise Sensitive Areas Associated
with Construction and Maintenance Dredging Activities**

  --------- --------------------- -------------- -------------- --------------
  **NSA**   **Distance and        **Existing     **Predicted    **Ambient +
            Direction**           Ambient Ldn    Dredging       Facility Ldn
                                  (dBA)**        Contribution   (dBA)**
                                                 Ldn (dBA)**    

  1         5,200 Feet north      68             49             68

  2         10,600 Feet east      65             38             65

  3         14,900 Feet southeast 58             32             58

  4         11,700 Feet west      60             36             60
  --------- --------------------- -------------- -------------- --------------

In addition, the results of the noise impact analysis indicate that the
noise attributable to the dredging activities at the NSAs would be lower
than the State of Maryland's maximum allowable limits (Table 9.4-12).

> **Table 9.4-12**
>
> **Predicted Sound Levels at Nearest Noise Sensitive Areas Associated
> with Construction and Maintenance Dredging Activities**

  ----------------- ---------------- ------------- ------------- --------------
  **NSA/Fenceline   **Distance and   **Predicted   **Maryland    **Exceeds
  Location**        Direction**      Sound Level   Maximum       Maryland Noise
                                     Leq (dBA)**   Allowable     Limits
                                                   Noise Limits  \[Yes/No\]**
                                                   (dBA)\***     

  1                 5,200 Feet north 42            90 (55)       No

  2                 10,600 Feet east 31            90 (55)       No

  3                 14,900 Feet      26            90 (55)       No
                    southeast                                    

  4                 11,700 Feet west 30            90 (55)       No
  ----------------- ---------------- ------------- ------------- --------------

> \*daytime limit (nighttime limit)

### Noise Mitigation Measures

As part of the LNG Terminal and Pipeline design activities AES is
continuing to evaluate noise control measures to be implemented at the
LNG Terminal and construction activities associated with the proposed
Project. The following is a list of some of the noise control measures
AES is evaluating. This list of noise mitigation measures is not an
exhaustive list. AES proposes to prevent or minimize noise effects from
construction and operation of the Project by:

-   Limiting construction primarily to normal weekday daylight or
    business hours, specifically in areas adjacent to noise sensitive
    land uses such as residential areas, recreational areas, and any
    off-post areas, with the exception of HDDs;

-   Ensuring construction equipment mufflers will be properly maintained
    and in good working order;

-   Coordinating with residence owners and/or tenants prior to
    unavoidable construction activities in residential areas;

-   Designing the HDD to minimize potential noise and duration of
    construction;

-   Designing the LNG Terminal and Power Plant, through building and
    other equipment specifications (such as silencers, mufflers,
    engineered sound enclosures, etc), to mitigate noise and meet or
    exceed both FERC and the State of Maryland noise standards
    (information will be incorporated in noise analysis, as available,
    and will be submitted to FERC as the final project detailed design
    is completed);

-   Enclosing most major noise generating equipment within suitable
    shelters at the LNG Terminal;

-   Within 60 days of completion, performing a post-construction sound
    survey at the Terminal Site. If the noise attributable to the
    operation of the terminal or power generation facility does not
    fully comply with federal, state and local noise regulations,
    additional noise controls will be installed within one year of the
    in-service date to meet this level.

-   Sound generating equipment would be partially enclosed with noise
    dampening barriers at all HDD; and

-   At the Susquehanna entrance location noise monitoring will be
    conducted in the early stages of construction, and, if necessary,
    additional noise control measures identified in Section 9.4.4.1 will
    be implemented to reduce noise to meet the FERC noise standards.

## References

1.  40 CFR § 52.21 - Prevention of Significant Deterioration

2.  40 CFR Part 60, Subpart A - General Provisions

3.  40 CFR Part 60, Subpart Db - Standards of Performance for
    Industrial-Commercial-Institutional Steam Generating Units

4.  40 CFR Part 60, Subpart KKKK - Standards of Performance for
    Stationary Combustion Turbines

5.  40 CFR Part 60, Subpart IIII, Standards of Performance for
    Stationary Compression Ignition Internal Combustion Engines

6.  40 CFR Part 63, Subpart DDDDD - National Emission Standards for
    Hazardous Air Pollutants for Industrial, Commercial, and
    Institutional Boilers and Process Heaters

7.  40 CFR Part 68 -- Chemical Accident Prevention Provisions

8.  40 CFR Part 72 - Permits Regulation (Acid Rain Program)

9.  40 CFR Part 75 - Continuous Emission Monitoring (Acid Rain Program)

10. 40 CFR Part 51 Appendix W, *Guideline of Air Quality Models*
    (November 2005)

11. AERMOD Implementation Guide, USEPA, September 27, 2005

12. AERMOD User's Guide (US EPA, 2004)

13. American National Standard Institute (ANSI). 2003. American National
    Standard Quantities and Procedures for Description and Measurement
    of Environmental Sound. Part 3: Short-term measurements with an
    observer present. ANSI S 12.9-1993 (R2003)/Part 3.

14. Baltimore County (2006). 1998 Baltimore County Zoning Regulations
    Edition, v15 Updated 02-15-2006.

15. Code of Maryland Regulations (COMAR). Title 26 Subtitle 02 Chapter
    03 Control of Noise Pollution

16. Guideline for Determination of Good Engineering Practice Stack
    Height (Technical Support Document for the Stack Height Regulations
    (USEPA, June 1985).

17. National Climatic Data Center (NCDC), surface meteorological data
    for National Weather Service station located at Baltimore-Washington
    International Airport.

18. Title 26, Subtitle 11 of the Code of Maryland Regulations:

19. Chapter 01 -- General Administrative Provisions

20. Chapter 02 -- Permits, Approvals and Registration

21. Chapter 03 -- Permits, Approvals and Registrations -- Title V
    Sources

22. Chapter 04 -- Ambient Air Quality Standards

23. Chapter 05 -- Air Pollution Episode System

24. Chapter 06 -- General Emission Standards, Prohibitions and
    Restrictions

25. Chapter 09 -- Control of Fuel-Burning Equipment, Stationary Internal
    Combustion Engines and Certain Fuel-Burning Installations

26. Chapter 15 -- Toxic Air Pollutants

27. Chapter 17 -- Requirements for Major New Sources and Modifications

28. Chapter 20 -- Mobile Sources

29. Chapter 26 -- Conformity

30. U.S. Environmental Protection Agency (USEPA). 1971. Noise from
    Construction Equipment and Operations, Building Equipment, and Home
    Appliances. Publication NTID300.1. Washington, D.C.

31. U.S. Environmental Protection Agency (USEPA), 1974. Information on
    Levels of Environmental Noise Requisite to Protect Public Health and
    Welfare with an Adequate Margin of Safety, EPA-550/9-74-004. Office
    of Noise Abatement and Control, Washington, D.C.

32. USEPA AirData website: http://www.epa.gov/air/data/reports.html

33. U.S. Department of Housing and Urban Development (HUD). 1985. The
    Noise Guidebook. HUD 953-DPC.

34. Worker's Compensation Board of British Columbia (WCB). 2000.
    Construction Noise. ARCS Reference No: 0135-20

APPENDIX 9A

Emissions Calculations

**Appendix 9B**

**Air Quality Impact Analysis Calculations and CD of Model Input and
Output Files**

**Appendix 9c**

Site Sound Survey and Noise Impact Evaluation

**Appendix 9d**

Fugitive Dust Suppression and Monitoring Plan

APPENDIX 9E

FERC Data Request Response Matrix

[^1]: Effective December 18, 2006, EPA revised the 24-hour PM~2.5~ NAAQS
    from 65 to 35 µg/m^3^ and revoked the 24-hour PM~10~ NAAQS.
    Therefore, revised nonattainment designations are pending based on
    review of monitored PM~2.5~ 24-hour ambient data in comparison to
    the revised NAAQS.

[^2]: As described in Sections 9.3.2.2 and 9.3.2.4, if AES decides to
    construct and operate the Power Plant both to provide heat to the
    LNG vaporizers and generate electricity for the local utility
    electric system, the combined cycle Power Plant would operate in
    lieu of or in conjunction with the hot water heaters, depending on
    the operating scenario.

[^3]: The first Federal standards (Tier 1) for off-road diesel engines
    were adopted in 1994 for engines over 50 hp, to be phased in from
    1996 to 2000. Tier 2/Tier 3 standards were adopted in 1998, with
    phase-in of increasingly more stringent standards between 2000 and
    2008.

[^4]: AES will attempt to negotiate LNG terminalling contracts under
    which tankers will operate preferably with natural gas and
    alternately with low sulfur marine diesel while stationary at the
    LNG Terminal, in order to minimize emissions and air quality
    impacts. At this time, AES cannot predict the success it will have
    in negotiating such contracts. Accordingly, the conservative
    assumptions outlined above and in more detail in Appendix 9A are
    even more appropriate at this time.

[^5]: Section 9.3.3.1.A discusses the potential applicability of the 100
    TPY PSD threshold for listed source categories and the 250 TPY
    threshold for non-listed sources

[^6]: Letter from John Calcagni, EPA AQMD to Ken Waid, January 8, 1990
    re: clarification on questions concerning "secondary emissions" as
    defined in 40 CFR 52.21(b); Letter from Charles Sheehan, EPA
    Regional Counsel to Michael Cathey, October 28, 2003.

[^7]: The 28 listed source categories subject to PSD review for which a
    100 TPY applicability threshold would apply include fossil fuel
    boilers (or combination of them) totaling more than 250 million Btu
    per hour heat input and fossil fuel-fired steam electric plants of
    more than 250 million Btu per hour heat input. AES has not yet
    determined through consultation with MDE whether these source
    categories potentially would include the CTG with auxiliary fired
    HRSG and four hot water heaters. However, certain recent air quality
    impact analyses have not treated similar sources at LNG terminals as
    falling within one of the 28 listed source categories. For example,
    the FERC DEIS for the Broadwater Energy floating LNG storage and
    regasification unit (November 2006) was assumed not to be one of the
    listed 28 source categories and, on that basis, a 250 TPY
    applicability threshold was applied. Similarly, the DEIS for the
    Gulf LNG Energy Project discusses a May 1, 2006 applicability
    determination issued by the Mississippi Department of Environmental
    Quality indicating that the proposed LNG terminal would not be
    treated as one of the 28 listed source categories. On that basis,
    the terminal would not trigger PSD review as long as the potential
    to emit for all stationary sources at the terminal would not exceed
    250 TPY for any attainment criteria pollutant.

[^8]: Maryland, Pennsylvania and Virginia have approved general
    conformity regulations (COMAR 26.11.26.09, 25 Pa.C.S. § 127.802 and
    VAC 5 Chapter 160, respectively). Maryland and Pennsylvania General
    Conformity regulations adopt and incorporate 40 CFR Part 93, Subpart
    B by reference. Virginia has adopted its own General Conformity
    regulations.

[^9]: While berthing of two ships at one time is contemplated in the
    design of the LNG Terminal, offloading of cargo will only be
    possible from one ship at a time.