# 4. ENVIRONMENTAL CONSEQUENCES

# 

## 4.1 PROPOSED ACTION

## 

### 4.1.1 Land Use and Aesthetics

### 

#### 4.1.1.1 Land Use 

The proposed main plant would be confined to the area between the
existing Gilberton Power Plant and the Mahanoy State Correctional
Institution, and thus would not affect offsite land use. The ancillary
facilities would not affect offsite land use due to their small size
(i.e., a few acres) and location adjacent to ancillary facilities for
the existing power plant. As with the Gilberton Power Plant, the
proposed facilities would be consistent with existing land use plans and
local zoning. The limited in-migration of workers required for plant
construction and operation would not increase offsite land use for
residential purposes (Section 4.1.7.3).

The culm that would be used as feedstock for the proposed facilities
would be obtained from culm banks created during previous anthracite
mining in the region. Following culm removal from lands in the adjacent
valley and the region, these lands would be graded to minimize erosion
and revegetated. Although a reasonable estimate cannot be made of the
amount of land that would be reclaimed during the 3-year demonstration
period (because of uncertainty in the selection of culm banks to be used
and variations in bank dimensions), approximately 1,000 acres would be
reclaimed over the entire 26-year operating life of the proposed
facilities.

#### 4.1.1.2 Aesthetics

As part of the proposed facilities, five 200‑ft stacks and one 300‑ft
stack would be constructed. The five 200-ft stacks would be considerably
shorter than the existing 326-ft stack at the adjacent Gilberton Power
Plant, and the 300-ft stack would be slightly shorter. The new gasifier
and turbine buildings would be similar in size to the existing power
plant buildings. Consequently, the proposed facilities would appear as
an extension of the existing industrial character of the locale rather
than as an appreciable change in character. Depending on the viewpoint,
other power plants, strip mines, and culm piles could also be visible
(Section 3.1). Topography and vegetation would contribute in some
locations to the visual screening of the proposed facilities.

As with the Gilberton Power Plant (Section 3.1), stack emissions and
cooling tower plumes from the proposed facilities would occasionally be
visible. Under most meteorological conditions, the atmosphere would be
unsaturated and would provide enough mixing so that the water vapor from
the cooling towers would not condense. However, during meteorological
conditions when the atmosphere is nearly saturated, winds are light, and
mixing is very low (i.e., during some early morning hours), condensation
is possible, which would appear in the form of a cooling tower plume
and/or fog (Section 4.1.2.2).

The Federal Aviation Administration would regulate the marking and
lighting of temporary and permanent structures associated with the
proposed facilities (Section 7.1). Generally, construction cranes and
other elevated equipment require lighting if their height above the
ground exceeds 200 ft. The 300‑ft stack and perhaps the 200‑ft stacks
would require medium- or high-intensity flashing white obstruction
lights. The lights would operate at reduced intensity during the night.
Because this type of lighting is currently installed and operating on
the Gilberton Power Plant's stack, the additional lighting would be
consistent with the area's industrial appearance.

In summary, because the visual landscape of the area is already
conspicuously marked with industrial structures (Section 3.1), the
proposed facilities would not alter the industrial appearance of the
site and, accordingly, would not degrade the aesthetic character of the
area.

### 4.1.2 Atmospheric Resources and Air Quality

This section evaluates potential impacts to atmospheric resources that
could result from construction and operation of the proposed facilities.
Section 4.1.2.1 discusses effects of construction, including fugitive
dust associated with earthwork and excavation. Section 4.1.2.2 discusses
operational effects, including from emissions of criteria and hazardous
air pollutants, regional-scale acidic deposition, and global climate
change.

#### 4.1.2.1 Construction

During construction of the proposed facilities, temporary and localized
increases in atmospheric concentrations of NO~x~, CO, SO~2~, VOCs, and
particulate matter would result from exhaust emissions of workers'
vehicles, heavy construction vehicles, diesel generators, and other
machinery and tools. An average of about 50 vehicles ranging from
passenger vehicles to earthmovers would be used for construction
activities on the site, with a peak of about 75 vehicles. Construction
vehicles and machinery would be equipped with standard pollution-control
devices to minimize emissions. These emissions would be very small
compared to regulatory thresholds typically used to determine whether
further air quality impact analysis is necessary \[such as 40 CFR
Part 93.153(b)\].

Fugitive dust would result from clearing, excavation, and earthwork.
Most of this work would occur at the 75-acre main plant site. Minor
clearing and grading activities would occur at the approximately 1‑acre
site of the new beneficiation plant (or expansion of the existing
facility) in the adjacent valley to the north of the main plant area and
in new 12-ft wide corridors to accommodate conveyors and pipelines
(Section 2.1.5.1). After completion of the initial earthmoving
operations, gravel would be spread on the main access roads to mitigate
further dust generation. Near the end of the construction period, these
roads would be paved to minimize dust generated on the site by vehicular
traffic.

The impacts of fugitive dust on offsite ambient air concentrations of
particulate matter less than 10 m in aerodynamic diameter (PM‑10) were
modeled using the EPA-approved SCREEN3 air dispersion model, which is a
single source Gaussian plume model that predicts maximum ground-level
concentrations downwind from point, area, flare, and volume sources (EPA
1995a). SCREEN3, a screening version of the ISCST3 model, provides
conservative results (forming an upper bound) using a full range of 54
potential meteorological conditions (i.e., conditions representing
different combinations of atmospheric stabilities and wind speeds). This
screening meteorological data set typically results in appreciably
greater modeled concentrations compared to modeled concentrations using
actual meteorological data, which are not available at the proposed site
or a nearby representative location (Section 3.2.1). The SCREEN3 model
was run using flat terrain, which is conservative for a nonbuoyant
ground-level source such as fugitive dust generated during earthwork.
Conversion factors were used to adjust the maximum 1-hour concentrations
predicted by SCREEN3 to 24-hour and annual averages (EPA 1992), as
required for comparison with PM-10 standards (Section 3.2.2).

The temporary impacts of fugitive dust from construction activities on
offsite particulate concentrations would be localized because of the
relatively rapid settling of larger‑size fugitive dust particles. An
average emission factor of 1.2 tons of total suspended particulate
matter per acre per month was assumed (EPA 1985). Of these emissions,
roughly 30% of the mass would consist of PM‑10 (Kinsey and Cowherd
1992). To minimize fugitive dust emissions, water spray trucks would
dampen exposed soil with water as necessary, which was assumed would
reduce fugitive dust by 50% (EPA 1985). Because construction on the
75-acre main plant site would be staggered, the maximum area undergoing
heavy earthwork at any one time was assumed to be 10 acres.

The total concentrations, obtained by adding maximum modeled
concentrations (adjusted by the conversion factors) to their
corresponding background concentrations, were compared with the NAAQS
(Section 3.2.2). The background concentrations used (i.e., 54 g/m^3^ for
the 24-hour averaging period and 25 g/m^3^ for the annual average) were
recorded in 2003 at the nearest PM‑10 monitoring station, located in
Reading (Section 3.2.2). Consequently, the maximum modeled 24-hour
concentration should not exceed 96 g/m^3^ because when it is added to
the 54 g/m^3^ background concentration, the sum should not exceed the
NAAQS of 150 g/m^3^ \[96 (modeled) +54 (background) =150 (total)\].
Similarly, the maximum modeled annual concentration should not exceed
25 g/m^3^ because when it is added to the 25 g/m^3^ background
concentration, the sum should not exceed the NAAQS of 50 g/m^3^ \[25
(modeled) +25 (background) =50 (total)\].

During major construction, however, PM-10 concentrations typically
exceed the NAAQS near the edge of the disturbed area. For the proposed
construction, modeling results indicated that exceedances of the 24-hour
standard (i.e., maximum modeled 24-hour concentration greater than
96 g/m^3^) could occasionally occur up to 2,800 ft (about 0.5 mile) from
the nearest edge of the construction area if construction were as
intense and widespread as assumed. Because concentrations would decrease
as distances increase, no exceedances would be expected at greater
distances. No exceedances of the annual standard (i.e., maximum modeled
annual concentration greater than 25 g/m^3^) would be expected at
distances greater than about 2,100 ft (less than 0.5 mile) from the
nearest edge of the construction area. No exceedances would be expected
at any residential locations because no residences are within 0.5 mile
of the main plant area (Section 3.10). No exceedances would be expected
at any locations likely to be frequented by a member of the general
public. Exceedances could occasionally occur at the site of the Mahanoy
State Correctional Institution, located about 1,000 ft (0.2 mile) east
of the nearest edge of the main plant area. However, inmates and
employees would not be exposed to outside air except during periods of
outdoor activity, and therefore the overall risk that a person could be
harmed would be small.

Actual concentrations would likely be less than predicted because of the
conservative assumptions, including linking worst-case meteorological
conditions (occurring during the nighttime) with the emission factor
described above. Actual emissions during these nighttime meteorological
conditions would be considerably less because no machinery would be
operating and because of the low wind speed (about 2 miles per hour)
associated with worst-case meteorological conditions, which would
minimize exposed soil from becoming airborne.

A similar modeling analysis was not conducted for the impacts of
fugitive dust on offsite ambient air concentrations of PM-2.5. The
annual PM-2.5 background concentration of 16 g/m^3^ recorded in 2003 at
the closest monitoring station, located in Reading (Section 3.2.2),
exceeded the NAAQS of 15 g/m^3^, but Schuylkill County is designated as
a PM-2.5 attainment area (Section 3.2.2). Consequently, the Reading
monitoring station is not an accurate indicator of existing PM-2.5
concentrations in Schuylkill County, which has no monitoring station.
However, as with PM-10 concentrations, PM-2.5 concentrations from
fugitive dust emissions would be expected to exceed the NAAQS near the
edge of the disturbed area, but decrease to within the NAAQS in a short
downwind distance. Because the PM-2.5 concentrations at the Reading
monitoring station are greater than expected in Schuylkill County, PM-10
concentrations are also likely to be greater in Reading than in
Schuylkill County, which is another indication that the PM-10 modeling
analysis using Reading ambient air data is conservative.

During site preparation, open burning of cleared trees and other
vegetation would be conducted to reduce or eliminate the amount of
vegetation requiring removal off the site (Section 4.1.8). Open burning
would not be conducted during drought conditions in which advisories
have been issued by the Pennsylvania Department of Environmental
Protection. Non-hazardous construction waste would also be burned.
Particulate emissions generated during burning would be temporary and
intermittent. Although Mahanoy and West Mahanoy Townships have no
ordinances regarding open burning, the fire chiefs would be notified
prior to each occurrence so that they would be aware of the burning and
could provide guidance.

On March 18, 2005, the Pennsylvania Department of Environmental
Protection issued Air Quality Program Permit No. 54-399-034 for the
proposed facilities. The permit, which expires on March 31, 2010,
addresses open burning during preparation of the proposed site.
Specifically, the permit states that open burning of cleared trees and
other vegetation may not be visible outside the property, malodorous air
contaminants may not be detectable outside the property, and emissions
may not cause harm to human or animal health, vegetation, or property.

#### 4.1.2.2 Operation

This section discusses potential air quality impacts resulting from
operation of the proposed facilities. Based on a plant operating rate of
7,500 hours per year (an 85% capacity factor), air emissions from the
proposed facilities would total less than 100 tons per year for each of
the criteria pollutants (Section 2.1.6.1). Plant-wide SO~2~ emissions
from the proposed facilities would be about 29 tons per year, NO~x~
emissions would be about 70 tons per year, particulate emissions would
be about 23 tons per year, and CO emissions would be about 54 tons per
year. Volatile organic compound (VOC) emissions would be about 28 tons
per year (see footnote b of Table 2.1.1 for potential-to-emit annual
emissions included in the air permit application submitted to the
Pennsylvania Department of Environmental Protection). As a measure of
the magnitude of the expected emissions, a source (i.e., the proposed
facilities) with potential emissions under the threshold of 100 tons per
year for a specific pollutant would not be considered a major stationary
source of that pollutant, as defined by the Clean Air Act's Prevention
of Significant Deterioration (PSD) regulations (40 CFR Part 51.166).
Because the proposed facilities would be considered a minor new source
of all regulated pollutants by the Pennsylvania Department of
Environmental Protection, no modeling is required for regulatory
applications.

Air Quality Program Permit No. 54-399-034, issued by the Pennsylvania
Department of Environmental Protection for the proposed facilities,
establishes maximum allowable limits for total facility emissions during
any consecutive 12-month rolling period: 99.9 tons for SO~2~, 99.9 tons
for NO~x~, 99.9 tons for PM-10, 99.9 tons for CO, and 49.9 tons for
VOCs. The permitted limits, which are intentionally slightly larger than
the expected emissions, function as a cap to ensure that the proposed
facilities would be a minor new source of all regulated pollutants.

Emissions of air pollutants would be discharged primarily from five
200‑ft stacks located in the main plant area. The stacks would be
associated with the heat recovery steam generator (HRSG), F‑T product
work‑up area (2 stacks), thermal oxidizer, and tank truck loading area.
The HRSG stack would emit the most NO~x~ (43 tons per year), particulate
matter (21 tons per year), and CO (31 tons per year), while the thermal
oxidizer stack would emit the most SO~2~ (17 tons per year).
Infrequently, a 300‑ft emergency stack would flare quenched, raw
synthesis gas from the gasifier during start-ups and during unexpected
shut-downs, such as during loss of power or loss of cooling water.

Sources of air pollutants other than stacks would include plant
vehicular traffic and personal commuter vehicles. Approximately 50
vehicles ranging from passenger vehicles to tanker trucks would be used
during operations on the site. These vehicles would be equipped with
standard pollution-control devices to minimize emissions, which would be
very small compared to regulatory thresholds typically used to determine
whether further air quality impact analysis is necessary \[such as 40
CFR Part 93.153(b)\]. The small amount of traffic would not contribute
appreciably to ambient air pollutant concentrations in the area.
Additional particulate matter would be generated from handling and
transfer of anthracite culm, petroleum coke, limestone, and process
wastes and byproducts. To reduce these particulate emissions, the number
of handling and transfer points would be minimized, the conveyors and
material loading and unloading points would be enclosed, and wetting
systems and collection devices (e.g., baghouses) would be installed.

##### Predicted Concentrations of Criteria Pollutants

The ISCST3 atmospheric dispersion model (EPA 1995b) was used to estimate
maximum increases in ground-level concentrations of SO~2~, NO~2~, PM-10,
and CO. The analysis conservatively included emissions from all 5
process stacks operating simultaneously.[^1] Because exact stack
locations within the main plant area have not yet been determined, the
center of each appropriate process area (e.g., tank truck loading area)
was used for the stack coordinates. Maximum potential hourly emissions
and a 100% capacity factor were used in the modeling. All particulate
emissions were conservatively assumed to be less than or equal to 10 m
in aerodynamic diameter (PM-10) for comparison with the standards.
Initially, all NO*~x~* emissions were conservatively assumed to be in
the form of NO~2~ for comparison with the standard.

Because no wind data have been archived from a location near enough to
be representative of the proposed site (Section 3.2.1), maximum
concentrations were calculated for the same full range of 54 potential
meteorological conditions used by the SCREEN3 model (Section 4.1.2.1).
The ISCST3 model was run for each of these meteorological conditions for
each of 360 wind directions (at 1° compass intervals). Concentrations
were modeled at over 30,000 locations (receptors) along or outside the
WMPI property boundaries at a spacing of 650 ft and 1° compass intervals
at distances of up to 12 miles from the main plant area, as well as for
specified receptors along nearby public roads. Topography was included
in the modeling. Because the height of the proposed stacks would be at
least 2.5 times the height of the buildings in the main plant area
(i.e., Good Engineering Practice stack height), wake effects from
building downwash were not considered. Due to the absence of
representative wind data, conversion factors were used (as in Section
4.1.2.1) to adjust the maximum 1‑hour concentrations predicted by ISCST3
to 3-hour, 8-hour, 24-hour, and annual averages (EPA 1992) to facilitate
comparison with applicable averaging periods for SO~2~, NO~2~, PM‑10,
and CO standards (Section 3.2.2).

In this analysis, significant impact levels were used to measure the
significance of the maximum predicted concentrations (EPA 1990). The
significant impact levels are much more stringent than the NAAQS (Table
3.2.1) and PSD Class II increments (Table 3.2.2), and even more
stringent or the same as the PSD Class I increments (Table 3.2.2).
According to EPA guidelines (EPA 1990), a preliminary modeling analysis
using significant impact levels should include only the emissions
associated with the proposed facilities to determine if the facilities
would have a significant impact on ambient air quality. If the maximum
predicted concentrations are less than the significant impact levels,
additional modeling including other sources and background
concentrations is not required (EPA 1990).

Results indicate that maximum concentrations are predicted to be less
than their corresponding significant impact levels, with the exception
of the annual NO~2~ concentration, which has a value of 1.1 g/m^3^
versus a significant impact level of 1 g/m^3^ (Table 4.1.1). However,
NO~x~ emissions are composed of NO emissions, as well as NO~2~
emissions, and not all NO emissions convert to NO~2~ in the atmosphere.
Consequently, the analysis was refined by relaxing the initial
conservative assumption that all NO~x~ emissions were in the form of
NO~2~. EPA's Guideline on Air Quality Models (40 CFR Part 51,
Appendix W) recommends an approach using the ambient ratio method with a
NO~2~-to-NO~x~ ratio of 0.75 (the annual national default ratio) to more
accurately predict ambient NO~2~ concentrations in the area of concern.
Using this approach, the revised maximum annual NO~2~ concentration is
predicted to be 0.8 g/m^3^, which is less than its significant impact
level of 1 g/m^3^. Therefore, additional modeling including other
sources and background concentrations is not required for any of the
pollutants. Because of the conservative assumptions used in the
analysis, actual degradation of air quality should be even less than the
small amounts predicted.

+----------+----------+-----------+---------+----------+------------+
| **Table  |          |           |         |          |            |
| 4.1.1.   |          |           |         |          |            |
| Maximum  |          |           |         |          |            |
| p        |          |           |         |          |            |
| redicted |          |           |         |          |            |
| air      |          |           |         |          |            |
| p        |          |           |         |          |            |
| ollutant |          |           |         |          |            |
| concen   |          |           |         |          |            |
| trations |          |           |         |          |            |
| from     |          |           |         |          |            |
| proposed |          |           |         |          |            |
| project  |          |           |         |          |            |
| op       |          |           |         |          |            |
| erations |          |           |         |          |            |
| compared |          |           |         |          |            |
| to       |          |           |         |          |            |
| sig      |          |           |         |          |            |
| nificant |          |           |         |          |            |
| impact   |          |           |         |          |            |
| levels** |          |           |         |          |            |
+----------+----------+-----------+---------+----------+------------+
| A        | SO~2~    | NO~2~     | PM-10   | CO       | S          |
| veraging |          |           |         |          | ignificant |
| period   | (g/m^3^) | (g/m^3^)  | (       | (g/m^3^) | impact     |
|          |          |           | g/m^3^) |          | level      |
|          |          |           |         |          |            |
|          |          |           |         |          | (g/m^3^)   |
+----------+----------+-----------+---------+----------+------------+
| 1-hour   | \--      | \--       | \--     | 11.4     | 2,000      |
+----------+----------+-----------+---------+----------+------------+
| 3-hour   | 10.6     | \--       | \--     | \--      | 25         |
+----------+----------+-----------+---------+----------+------------+
| 8-hour   | \--      | \--       | \--     | 8.0      | 500        |
+----------+----------+-----------+---------+----------+------------+
| 24-hour  | 4.7      | \--       | 0.8     | \--      | 5          |
+----------+----------+-----------+---------+----------+------------+
| Annual   | 0.9      | 1.1       | 0.2     | \--      | 1          |
|          |          | (initial) |         |          |            |
|          |          |           |         |          |            |
|          |          | 0.8       |         |          |            |
|          |          | (revised) |         |          |            |
+----------+----------+-----------+---------+----------+------------+

Maximum concentrations for all pollutants were predicted to occur at the
same location on top of Locust Mountain, an undeveloped forested area
slightly over 3 miles north of the main plant area and immediately
northeast of Shenandoah. Concentrations at other locations, including
the nearby Mahanoy State Correctional Institution, would be less.
Concentrations would be negligible at the nearest PSD Class I area,
about 130 miles to the southeast (Section 3.2.2), because dispersion of
pollutants at that distance would reduce atmospheric concentrations to a
small fraction of the maximum modeled concentrations, which are
predicted to be less than PSD Class I increments at the location of
their maximum impact on Locust Mountain.

No significant impact levels or PSD increments currently exist for
PM‑2.5. However, assuming conservatively that all particulate emissions
are less than or equal to 2.5 m in aerodynamic diameter (PM‑2.5), the
maximum 24‑hour concentration of 0.8 g/m^3^ would be only 1% of the
corresponding NAAQS of 65 g/m^3^ (Table 3.2.1). Similarly, the maximum
annual concentration of 0.2 g/m^3^ would be about 1% of the
corresponding NAAQS of 15 g/m^3^ (Table 3.2.1). These small percentages
would not be expected to result in violations of the PM‑2.5 NAAQS, for
which Schuylkill County is in attainment (Section 3.2.2).

No appreciable Pb emissions would occur from operation of the proposed
facilities. Concentrations of Pb in recent years have been well below
NAAQS, largely because of the decreased use of leaded gasoline in
automobiles. Therefore, Pb emissions from the proposed facilities are
not evaluated further.

Ozone (O~3~) is not emitted directly from a combustion source but is
formed from photochemical reactions involving emitted VOCs and NO~x~.
Because the reactions involved can take hours to complete, O~3~ can form
far from the sources of its precursors (the VOCs and NO~x~ that initiate
its formation). Therefore, the contribution of an individual source to
O~3~ concentrations at any particular location cannot be readily
quantified. Stack emissions of NO*~x~* from the proposed facilities
would be about 70 tons per year, which would be less than 1% of
Schuylkill County's NO~x~ emissions inventory of 8,335 tons per year in
1999, the latest year with an available inventory. Stack VOC emissions
would be about 28 tons per year, which would be less than 0.4% of the
county's VOC emissions inventory of 7,840 tons per year in 1999. Because
the nearest O~3~ monitoring station is located in Reading, about 35
miles south-southeast of Gilberton (Section 3.2.2), existing ambient
O~3~ concentrations in the area are uncertain. The small percentage
increases in NO~x~ and VOC emissions would not be likely to degrade O~3~
concentrations sufficiently to cause violations in the O~3~ NAAQS, but
the magnitude of the degradation cannot be quantified.

##### Conformity Review

Schuylkill County is in attainment with NAAQS and state ambient air
quality standards for all pollutants (Section 3.2.2). Schuylkill County
was formerly designated as nonattainment for the 1-hour O~3~ standard,
but EPA revoked the standard on June 15, 2005. Although no longer
required, DOE performed a conformity review prior to June 15, 2005, to
assess whether a full-scale conformity determination was needed to
demonstrate that activities associated with the proposed project would
conform to applicable implementation plans for bringing the area into
attainment with the 1-hour O~3~ NAAQS (40 CFR Part 93, Subpart B). A
conformity determination was not required for O~3~ if the total of
direct and indirect emissions of O~3~ precursors (i.e., NO~x~ and VOC
emissions) resulting from the proposed project would be less than
appropriate thresholds \[40 CFR Part 93.153(c)\] and would also be less
than 10% of the emissions inventory for the nonattainment area \[40 CFR
Part 93.153(i)\].

Because Pennsylvania is part of an O~3~ transport region (Clean Air Act,
Title I, Part D, Section184), the appropriate thresholds in the
conformity review for O~3~ precursors were 100 tons per year for NO~x~
emissions and 50 tons per year for VOC emissions \[40 CFR
Part 93.153(b)\]. As indicated previously, plant-wide stack emissions of
NO*~x~* would be about 70 tons per year, and plant-wide stack VOC
emissions would be about 28 tons per year. While other project-related
emissions (e.g., plant vehicular traffic and personal commuter vehicles)
would cause slightly greater total emissions, the sums would be much
less than the thresholds (i.e., the incremental emissions from other
sources would be much less than 30 tons per year of NO~x~ emissions and
22 tons per year of VOC emissions). The total of direct and indirect
emissions would be about 1% of Schuylkill County's NO~x~ emissions
inventory of 8,335 tons per year and less than 1% of the county's VOC
emissions inventory of 7,840 tons per year in 1999. These percentages
were much less than the 10% threshold. Consequently, the conformity
review found that a conformity determination was not required.

##### Hazardous Air Pollutants

Trace emissions of other pollutants would include mercury, beryllium,
sulfuric acid mist, hydrochloric acid, hydrofluoric acid, benzene,
arsenic, and various heavy metals. As required by the F-T synthesis
process, the synthesis gas would be cleaned extensively using wet
scrubbing followed by acid gas removal using a Rectisol unit, prior to
sending the gas to the F‑T synthesis facilities and the combined‑cycle
power plant. Therefore, a high percentage of hazardous air pollutants
and trace elements in the synthesis gas would be removed, but no
estimates of the proposed facilities' emissions of these pollutants are
currently available. Part of the purpose of the proposed project is to
generate environmental data, including hazardous air pollutant
measurements, from the operation of the integrated technologies at a
sufficiently large scale to allow industries and utilities to assess the
project's potential for commercial application (Section 1.4).

Emissions of hazardous air pollutants (e.g., mercury) from the proposed
facilities would likely be very similar to emissions from
state-of-the-art integrated gasification combined-cycle facilities due
to the similarity in the technologies, including synthesis gas cleanup
equipment. Extensive characterization of trace elements during
demonstration of a Shell pilot-scale integrated gasification
combined-cycle plant from 1987 to 1991 indicated that scrubbing in the
synthesis gas cleanup train, upstream of the acid gas removal equipment,
was very effective in removing volatile trace elements (SAIC 2002).
Volatile trace elements were not detected in the clean product synthesis
gas or the acid gas, with the exception of lead in the clean synthesis
gas and selenium in the acid gas, which were present at less than 1% of
the total inlet feed rate to the gasifier.

Air Quality Program Permit No. 54-399-034, issued by the Pennsylvania
Department of Environmental Protection for the proposed facilities,
establishes maximum allowable limits for total facility emissions of
less than 10 tons for any single hazardous air pollutant (e.g., mercury)
and less than 25 tons altogether for any combination of hazardous air
pollutants during any consecutive 12‑month rolling period. The permitted
limits function as a cap to ensure that the proposed facilities would be
a minor new source of hazardous air pollutants under the National
Emissions Standards for Hazardous Air Pollutants regulations. Based on
the same averaging period, the permit also specifies a maximum allowable
limit of 100 tons for ammonia and 15 tons for sulfuric acid mist, which
are not designated as hazardous air pollutants under the National
Emissions Standards for Hazardous Air Pollutants regulations.

##### Visibility

Visibility, or background visual range, is defined as the maximum
distance a large, black object can be observed on the horizon. The
scenic quality of natural landscapes and their color, contrast, and
texture, are improved by good visibility. Visibility, as a measure of
clarity of the atmosphere, has been established as an important
air-quality-related value of national parks and wilderness areas that
are designated as PSD Class I areas. Because concentrations of
pollutants from the proposed facilities would be negligible at the
nearest PSD Class I area, about 130 miles to the southeast (Section
3.2.2), no degradation in visibility would be perceptible.

##### Acidic Deposition

Acid rain, the popular name for acidic deposition, occurs when SO~2~ and
NO~x~ are chemically transformed and transported in the atmosphere and
deposited on the earth's surface in the form of wet (rain, snow, fog) or
dry (particle, gas) deposition. SO~2~ and NO~x~ are readily oxidized in
the atmosphere to form sulfates and nitrates. Subsequently, the sulfates
and nitrates may form sulfuric acid and nitric acid when combined with
water, unless neutralized by other chemicals present. Acidic deposition
contributes to the acidification of lakes and damage to ecological
resources. SO~2~ and NO~x~ can be transported by the wind for hundreds
of miles from one region to another. Therefore, air over any given area
will contain some residual emissions from distant areas and infusions
received from nearby areas. This continuing depletion and replenishment
of emissions along the path of an air mass makes it extremely difficult
to determine relationships between specific sources of emissions and
acidic deposition at any particular location.

As a comparison to evaluate acidic deposition, stack SO~2~ emissions
from the proposed facilities would be about 29 tons per year, which
would be about 0.4% of Schuylkill County's SO~2~ emissions inventory of
8,046 tons per year in 1999. Stack emissions of NO*~x~* from the
proposed facilities would be about 70 tons per year, which would be less
than 1% of the county's NO~x~ emissions inventory of 8,335 tons per year
in 1999. Because these emissions are less than 1% of existing county
emissions, no perceptible changes in acidic deposition would be
expected.

##### Global Climate Change

A major worldwide environmental issue is the possibility of major
changes in the global climate (e.g., global warming) as a consequence of
increasing atmospheric concentrations of "greenhouse" gases (Mitchell
1989). The atmosphere allows a large percentage of incoming solar
radiation to pass through to the earth's surface and be converted to
heat energy (infrared radiation) that does not pass back through the
atmosphere as easily as the solar radiation passes in. The result is
that heat energy is "trapped" near the earth's surface. This phenomenon
is commonly called the greenhouse effect because of an analogy with the
glass in a greenhouse. However, the use of the term greenhouse effect to
describe these radiative processes is somewhat of a misnomer because the
main effect of the glass in a greenhouse is to act as a physical barrier
that keeps the warm air inside.

Greenhouse gases include water vapor, CO~2~, methane, nitrous oxide,
O~3~, and several chlorofluorocarbons. The greenhouse gases constitute a
small percentage of the earth's atmosphere; however, their collective
effect is to keep the temperature of the earth's surface about 60°F
warmer, on average, than it would be if no atmosphere existed. Water
vapor, a natural component of the atmosphere, is the most abundant
greenhouse gas. The second-most abundant greenhouse gas is CO~2~, which
has increased about 30% in concentration over the last century. Fossil
fuel burning is the primary contributor to increasing concentrations of
CO~2~ (DOE 1989). The increasing CO~2~ concentrations may have
contributed to a corresponding increase in globally averaged temperature
in the lower atmosphere (IPCC 1992).

Because CO~2~ is stable in the atmosphere and essentially uniformly
mixed throughout the troposphere and stratosphere, the climatic impact
does not depend on the geographic location of sources. Therefore, an
increase in CO~2~ emissions at a specific source is effective in
altering CO~2~ concentrations only to the extent that it contributes to
the global total of fossil fuel burning that increases global CO~2~
concentrations. The proposed facilities would increase global CO~2~
emissions by about 832,000 tons per year, which is about 0.003% of
global CO~2~ emissions of 26,713 million tons resulting from fossil fuel
combustion in the year 2000. Thus, increases from the proposed
facilities would be large in terms of number of tons per year but small
in comparison with global totals.

##### Scoping Concerns

During the scoping process, local residents expressed concern about the
potential for odorous emissions (Section 1.5). The potential for odor
would most likely result from emissions of hydrogen sulfide (H~2~S). For
the proposed facilities, however, nearly complete H~2~S removal from the
shifted synthesis gas, occurring in the acid gas removal plant using a
Rectisol unit, would be required by the downstream F‑T synthesis
process. Remaining concentrations would be as low as 1 to 5 ppm. The
captured H~2~S would be converted to marketable elemental sulfur in a
Claus sulfur recovery unit, a process which should remove approximately
99.99% of the sulfur from the recovered acid gas stream. Thus, odorous
emissions of H~2~S should not be perceptible. The gas stream exiting the
Rectisol unit would be sent to a thermal oxidizer to destroy any trace
contaminants prior to being released through a stack to the atmosphere.

As with state-of-the-art integrated gasification combined-cycle
facilities, odors from the proposed facilities should not be perceptible
due to the similarity in the technologies, including synthesis gas
cleanup equipment. In contrast, a slightly different technological
process removes about 75% of the sulfur from the gas stream at Sasol's
existing coal-to-oil facilities in Secunda, South Africa. The Secunda
facilities, built beginning in 1976, have averaged about 3 odor
complaints per month over the last year, primarily for H~2~S odors. The
rate of complaints is higher at Sasol's coal-to-oil facilities in
Sasolburg, South Africa, which have been operating since 1955, because
the process removes no sulfur.

Air Quality Program Permit No. 54-399-034, issued by the Pennsylvania
Department of Environmental Protection for the proposed facilities,
states that the proposed facilities may not emit into the atmosphere any
malodorous air contaminants from any source in such a manner that the
malodors are detectable outside the property.

During the scoping process, local residents also expressed concern about
the possibility of emissions from the proposed facilities creating
safety issues, such as fog affecting Interstate 81 (Section 1.5). The
primary source of any fog generated by the proposed facilities would be
the new bank of 12 mechanical-draft cooling towers. About 1,757 gpm of
water would evaporate from the cooling towers (Table 2.1.2), which could
condense in the atmosphere to form fog under certain meteorological
conditions. Interstate 81 is aligned in a west-southwest to
east-northeast orientation in a valley about 1 mile to the south of the
proposed site on Broad Mountain. Under most meteorological conditions,
the atmosphere would be unsaturated and would provide enough mixing so
that the water vapor from the cooling towers would not condense.
However, during meteorological conditions when the atmosphere is nearly
saturated, winds are light, and mixing is very low (i.e., during some
early morning hours), condensation is possible, which would appear in
the form of a cooling tower plume and/or fog. The fog would probably not
affect Interstate 81 due to the distance from the proposed site. No fog
resulting from existing Gilberton Power Plant operations has been
observed on Interstate 81. However, upon initial operation of the
proposed facilities, conditions at the interstate would be monitored and
flashing lights to warn motorists of fog would be installed, if
warranted.

Finally, a concern was expressed regarding airborne emissions resulting
from vehicles traveling over red anti-skid material applied to roads
(Section 1.5). This material is bottom ash from the existing Gilberton
Power Plant, which is applied to alleviate treacherous road conditions
during the winter. Because the bottom ash from the proposed facilities
would be in the form of a glass-like slag, which is not suitable as an
anti-skid material and would not be applied to the roads, this concern
would not become an issue.

### 4.1.3 Geology and Soils 

### 

#### 4.1.3.1 Mineral Resources

The proposed facilities would increase the removal and utilization of
the anthracite culm deposited on the landscape of the project area. The
facilities' estimated use of 4,711 tons (dry) of beneficiated culm per
day (about 1.7 million tons per year) equates to 2.7 times the culm
consumption of the existing Gilberton Power Plant. The proposed
facilities would increase total culm utilization by 20 to 140% over
levels during the period from 1993 to 2002, when anthracite culm
utilization in the state ranged from 1.2 to 8.4 million tons per year
(Figure 3.3.1).

#### 4.1.3.2 Soils

The proposed facilities would not affect any soil types classified as
prime farmland or Pennsylvania farmland of statewide importance. The
facilities' use of culm from mine waste dumps in the Mahanoy Creek
valley and surrounding region, together with the possible use of project
byproduct materials in reclaiming abandoned surface mines and spoil
areas, would accelerate the ongoing process of restoring soil
productivity in the region.

#### 4.1.3.3 Geologic Hazards

Construction and operation of the proposed facilities would not be
expected to increase or decrease the likelihood of ground surface
subsidence due to collapse of abandoned underground mine workings. The
facilities' use of water from the Gilberton mine pool would lower the
average water level in the mine pool, and thus reduce roof support in
the abandoned mine workings below Gilberton. However, this would not be
expected to increase the likelihood of collapse. Water levels would
remain within their current range (Section 3.4.3), and the state of
Pennsylvania has not observed any mine roof collapses or other
subsidence from several decades of pumping from the mine pools at
Gilberton and other locations in the region (Section 3.3.5.1).

Because the proposed main plant would be built over rock units that do
not contain coal, the plant would not be affected by subsidence from
mining activities. Subsidence could, however, affect product transfer
lines and related facilities in the valley of Mahanoy Creek. Abrupt
subsidence could rupture product transfer lines and release liquid fuel
product into the environment. Environmental consequences of such an
event would be similar to those from collision and rupture of a gasoline
truck, potentially including fire, explosion, and release of a toxic
material into surface waters and soils. Gradual subsidence also could
damage product lines and cause leakage, with similar but smaller
impacts. The possibility of abrupt subsidence has decreased over time
following the closure of underground mines, and will continue to
decrease in the future. The potential risks of product line leakage due
to gradual subsidence would be reduced by inspecting product lines
regularly and repairing any problems.

Although unlikely (as discussed in Section 3.3.5.2), seismic activity
also has the potential to cause accidental rupture of product lines and
containment systems associated with the proposed facilities. The
potential for accidental releases would be reduced by incorporating
seismic safety design features into the facilities.

By removing culm waste from the landscape to recover its energy value,
the proposed facilities would help to reduce the hazards associated with
culm waste, including the potential for culm bank fires. The proposed
facilities would not be expected to change either the likelihood of
fires or the feasibility and effectiveness of fire control in abandoned
underground mines.

### 4.1.4 Water Resources

### 

#### 4.1.4.1 Surface Water and Mine Pool

##### Construction

No change in the existing utilization or consumption of surface water or
mine pool water would occur during construction of the proposed
facilities. No dredge or fill material would be deposited in surface
streams.

Water quality could be affected by stormwater runoff from construction
sites. However, an erosion and sediment control plan would be developed
and implemented for the project, in accordance with NPDES discharge
permit PAR-105804R issued by the Schuylkill Conservation District.
Standard engineering practices such as silt fencing, straw bales,
revegetation of graded areas, and stormwater detention basins would be
implemented to control runoff, erosion, and sedimentation. If runoff
from the site drained to old strip mining pits on the north or south
slopes of Broad Mountain, any sediments would settle out in the pits
before the remaining water would seep to the underlying mine pools. If
runoff were directed toward tributaries of Mill Creek, it would be
routed through detention basins in which sediments would settle out
before the water would be released to a stream. Impacts attributable to
construction-related runoff would be minimal.

Accidental spills of construction materials such as solvents, paint,
caulk, oil, and grease that could contain hazardous substances would be
cleaned up in a timely manner and in accordance with a spill prevention,
control, and countermeasure plan and best management practices, thus
minimizing the potential for overland flow into streams.

##### Operation

**Water Quantity.** Operation of the proposed facilities would reduce
the water volume in the Gilberton mine pool and the volume of water
needed to be pumped from the mine pool and discharged to Mahanoy Creek
in order to prevent flooding. These changes would result in reduced
stream flow in the creek. During normal operation, the proposed
facilities would require about 4,160 gpm from the mine pool, including
about 2,740 gpm for cooling water, 1,030 gpm for processing in the main
plant, and 390 gpm supplied to the coal beneficiation plant
(Table 2.1.2). About 2,290 gpm would be consumed in processing or lost
to evaporation, and about 2,020 gpm (including about 150 gpm of
stormwater collected from the main plant area) would be discharged as a
blend of treated wastewater and uncontaminated water to the tailings
pond in the Mahanoy Creek valley and returned to the mine pool
(Table 2.1.2).

The net effect on mine pool water flux would be a reduction of 2,140 gpm
or 956 million gal per year (assuming operation of the facilities at an
85% capacity factor). This is 38% of the water volume currently pumped
to Mahanoy Creek from the Gilberton mine pool to control the mine pool
elevation. The state of Pennsylvania would be able to reduce pumping of
the mine pool by approximately 38%. The discharge of untreated mine pool
water to Mahanoy Creek would be reduced by the same percentage.

Reductions in pumping from the mine pool to Mahanoy Creek would reduce
the amount of water in the stream. Because the stream is not a source of
water supply (Section 3.4.4) due to poor water quality, the potential
impacts of reduced flow are limited to impacts on in-stream conditions.
Averaged over a year, streamflow in Mahanoy Creek would be reduced by
4.1 ft^3^/s, which is 43% of the assumed average flow at Girardville
(Section 3.4.1). Although measured streamflow at Gilberton and
Girardville sometimes is less than 4.1 ft^3^/s (Section 3.4.1), the
creek would not go dry from receiving less mine pool water. The creek's
minimum flows would continue to be maintained by continuous discharges
from mine openings in upstream portions of the watershed. Pumping is
more frequent during wet weather than dry weather, so discharge from the
Gilberton pump is not an important contributor to low flows in the
creek. Peak (flood) flows also are unlikely to be affected because the
state's pumps normally would not be operated during flood events.
Downstream at Ashland, the reduction in flow would be 6.5% of the
calculated average streamflow of 63 ft^3^/s. Because the only known uses
of Mahanoy Creek are in-stream uses, such as receipt of treated sewage,
no impacts on water availability would be expected from reductions in
pumping.

**Water Quality.** Project operation would indirectly affect water
quality in both Mahanoy Creek and the mine pool system. Treatment and
use of mine pool water, generation of liquid process wastes, and
treatment of plant wastewater would contribute to modifying the quality
of the water that would be discharged back into the mine pool. Reduced
operation of the state\'s pump would reduce the amount of poor quality
mine pool water entering the creek, but the dilution volume in the
stream would also be reduced.

Although wastewater discharge characteristics and discharge permit
requirements for the proposed facilities are not yet available, the
treated wastewater discharged to the tailings pond over the mine pool
would have near-neutral or slightly alkaline pH. Also, much of the
dissolved solids load from the mine pool would be removed, and most
organic constituents and nutrients added in plant processes would be
removed during wastewater treatment.

Intake water treatment would remove some dissolved substances. Water to
be used for cooling water would be treated to reduce iron concentrations
to less than 0.5 mg/L using aeration followed by lime treatment, after
which the water would be sent to a clarifier and finally filtered. These
processes should be effective in removing manganese as well as iron.
Both metals would be transferred to water treatment sludge, which would
be handled as a solid waste (Section 4.1.8.2). Assuming 99% removal of
iron and manganese from the 2,750 gpm of mine pool water obtained for
cooling, 1,400 lb of iron and 300 lb of manganese would be removed
daily. Water to be used for boiler feedwater and other purposes would
receive more extensive treatment (demineralization using ion exchange or
reverse osmosis) to remove almost all dissolved substances.
Demineralization would produce a concentrated wastewater stream
containing dissolved minerals removed from the mine pool water. This
concentrated wastewater would be treated in the wastewater treatment
units before being discharged (Section 2.1.8.2). Most of the iron,
manganese, and other metals would probably be removed from this
wastewater stream during processing (these substances would be
incorporated into wastewater sludge), but sulfate and other anions could
pass untreated into the wastewater discharge.

Discharge of treated effluent to the mine pool by seepage from the
tailings pond would be expected to improve mine pool water quality by
reducing concentrations of acidity and dissolved metals. Consequently,
water pumped from the mine pool to Mahanoy Creek would also improve in
quality. Water quality improvements to the creek cannot be quantified
due to uncertainty about chemical reactions occurring as water passes
from the tailings pond to the mine pool and through the mine pool before
discharge to the creek. If the treated effluent were discharged directly
to Mahanoy Creek, total manganese loading to the stream would be reduced
to below the state's proposed water quality targets for the stream
(Section 3.4.1). Loading of acidity and aluminum would also be reduced
because water processing in the facilities would remove substantial
amounts of these contaminants from the mine pool water, thus aiding in
meeting proposed water quality targets for these substances. The
potential amount of reduction in acidity and aluminum cannot be
determined because data are not available on the concentrations of
acidity and aluminum in the mine pool water. Reduced loadings of
manganese, acidity, aluminum, and iron would increase the potential for
Mahanoy Creek to provide suitable habitat for aquatic life.
Concentrations of sulfate in the stream could increase, but this
increase would not affect attainment of water quality criteria because
no water quality criteria exist for sulfate in waters designated for use
as aquatic habitat. Water quality in Mahanoy Creek would experience less
actual improvement because effluents would not be discharged directly to
the creek, but would instead be discharged to the tailings pond and
would pass through the mine pool before being pumped into the creek.
Water chemistry would be altered by mixing with mine pool water and by
chemical reactions with soil and rock as the water passes from the
tailings pond to the mine pool and through the mine pool. Metals are
relatively insoluble in water at neutral or alkaline pH, but reactions
with pyrite and other minerals in the soil and rock would be likely to
deplete the alkalinity in the water, increasing its acidity and allowing
some dissolution of metals to continue.

Although the facilities' wastewater treatment system would be designed
to treat organic residues (Section 2.1.6.2), effluents from the
facilities could contain residual amounts of organic compounds found in
process wastewaters. Toxic and carcinogenic substances, including
cyanides and polycyclic aromatic hydrocarbons (PAHs) such as pyrene,
might be present in low concentrations (SAIC 2002). Any adverse effects
of these substances on Mahanoy Creek water quality would probably be
undetectable because of the overriding impacts of acid mine drainage,
but their presence could add to the challenges involved in restoring
stream functions. Human exposure to these substances would be unlikely
to occur in the site vicinity because people do not use the stream
water. Downstream impacts would be reduced by natural degradation (for
example, of cyanides) and dilution.

#### 4.1.4.2 Groundwater 

Construction and operation of the proposed facilities would not change
groundwater use on Broad Mountain. Water for the facilities would be
drawn from the mine pool, not from sources on Broad Mountain. However,
the facilities' development could affect groundwater availability by
increasing the area of impervious surface, thus reducing groundwater
recharge to the aquifers on Broad Mountain. Water that previously would
infiltrate the soil to enter the groundwater under Broad Mountain would
instead become stormwater runoff and would be discharged to streams or
strip mining pits. Thus, this water would not be available to recharge
the aquifers on Broad Mountain.

Assuming that the project would prevent groundwater recharge of 15 in.
per year (Section 3.4) over 50 acres of the 75-acre site, the reduction
in recharge would be 2.7 million ft^3^ per year (39 gpm or almost 56,000
gal per day). Because the onsite septic system for disposal of sanitary
wastewater from the proposed facilities would replace some of this
recharge by discharging an estimated 4 gpm into the aquifer, the net
loss in recharge would be 35 gpm or 50,000 gal per day. For comparison,
this is about 60% of the combined volume of groundwater supplied by the
wells serving the Gilberton Power Plant and the Morea water system
(Section 3.4.4). This reduced recharge should not adversely affect users
of the Morea water system. Recharge from areas closer to the Morea well
(i.e., within a 1,000-ft radius) is estimated to be almost 4 million
ft^3^ per year (56 gpm or 80,000 gal per day), which is more than enough
to meet the needs of the Morea water system (20,500 gal per day).

The wells serving the Gilberton Power Plant are closer to the proposed
main plant site than the Morea well is to the main plant site, and thus
would be more likely to experience any impacts from reduced recharge. If
the reduced recharge affected the availability of groundwater to meet
the needs of the existing power plant, the facilities' owners would
address the situation by establishing a connection with one of the
public water suppliers identified in Section 3.4.4 (Gerald Choi, Nexant,
Inc., personal communication to Ellen Smith, ORNL, June 21, 2005).
Because other wells in the area are farther from the proposed facilities
than the Morea well is from the proposed facilities, they also should
not be affected by reduced recharge.

Most potential impacts to groundwater quality on Broad Mountain would be
avoided by implementing standard engineering practices, including
collection of potentially contaminated runoff and cleaning up accidental
spills in a timely manner. The proposed septic system for sanitary
wastewater disposal would discharge effluents to the aquifer, but these
effluents should not adversely affect groundwater quality. The septic
system would be designed and operated in accordance with permitting
requirements and would only receive wastewaters like those generated by
households. Silty sand soils, such as the soils found on Broad Mountain,
are usually effective in filtering and attenuating contaminants in
effluents from properly designed and maintained septic systems. Dilution
of the relatively small volume of septic effluent by the much larger
volume of natural groundwater recharge would minimize the impacts of any
contaminants that do reach groundwater.

### 4.1.5 Floodplains and Wetlands

### 

#### 4.1.5.1 Floodplains

The main plant would be located at an elevation well above the Federal
Emergency Management Agency's delineated 100- and 500-year floodplains
(Section 3.5.1). A new culm beneficiation plant or expansion of the
existing facility in the adjacent valley to the north of the main plant
area would also lie above the elevation of the 100- and 500-year
floodplains. The following project ancillary facilities, however, would
cross the 100- and 500-year floodplains of Mahanoy Creek: (1) two
product rundown pipelines to a railroad siding, (2) an expansion of the
coal conveyor from the culm beneficiation plant, and (3) a pipeline for
mine pool water. These structures would be placed atop an existing
trestle at an elevation above the level of the 100- and 500-year floods
(FEMA 1983, 1986). No new construction within the floodplain would be
required.

#### 4.1.5.2 Wetlands

Construction and operation of the proposed facilities would have no
adverse effects on wetlands because none are present on the project
site. Runoff and spills from the site would be controlled by standard
construction engineering practices and spill control procedures (Section
4.1.4).

### 4.1.6 Ecological Resources

### 

#### 4.1.6.1 Terrestrial Ecology

**Construction**

Approximately 75 acres of deciduous forest would be permanently lost to
construct the main plant. An additional 1.5 acres, which would be
cleared for ancillary structures, would revegetate to some extent. Loss
of this habitat, increased human activity in the main plant area,
increased traffic on local roads, and noise would be the most important
factors that would affect wildlife species.

The presence of construction crews and increased traffic would cause
some wildlife species to avoid areas next to the construction site
during the 30‑month construction period. Wildlife inhabiting the area
rely on native trees, shrubs, and groundcover for food and shelter and
would be affected by vegetation clearing. Burrowing and less mobile
species such as amphibians, some reptiles, and some small mammals could
be adversely affected during vegetation clearing and grading and other
site preparation activities. The loss of deciduous forest during
construction would displace some small mammals and songbirds from the
construction areas, but would not be expected to eliminate any wildlife
species from Broad Mountain because similar habitat is relatively common
along, and on both sides of, the ridge. Clearing for support facilities,
i.e., product rundown lines, mine pool water source and return lines,
and natural gas line, would create additional forest edge and introduce
habitat diversity as these areas partially revegetated. This would tend
to benefit edge-related wildlife species, while displacing
forest-related species from the new habitat.

Construction would temporarily modify the quality of the surrounding
habitat in the project area by the creation of noise. Noise levels at a
distance of 50 ft typically associated with earthmoving equipment range
from 73 to 96 dB(A), and 82 dB(A) for chain saws (FHWA 2005; Revelle and
Revelle 1974). Published results from several studies indicate that
small mammals and birds might be adversely affected by the maximum noise
levels produced by construction equipment (Luz and Smith 1976;
Brattstrom and Gondello 1983). White-tailed deer and other skittish
larger mammals would not use the areas near the proposed site during
construction activities because of noise and the presence of workers. No
long-term impacts on the hearing ability of wildlife species would be
expected from construction-generated noise.

Some unavoidable impacts on wildlife would occur as a result of
increased vehicular traffic. Construction traffic along the new access
road would increase the potential for roadkills for animals such as
turkeys, squirrels, and chipmunks.

Birds of prey passing through, or possibly otherwise using the area,
probably would not be adversely affected by the loss of prey base that
would be associated with the clearing of the total of 76.5 acres of
vegetation, due to the existence of much similar habitat nearby.
However, their foraging in areas next to construction sites might be
reduced due to increased human activity.

To mitigate impacts of construction to ecological resources, forest
clearing would be minimized to the extent practicable by clearing no
more land than absolutely necessary for construction. Best management
practices (BMPs) for sediment and erosion control, including use of silt
fence, straw bale structures, and geotextile materials would be employed
where appropriate. Excavated areas surrounding the proposed facilities
would be reseeded following construction, and where practicable, some
areas would be allowed to revert to forest.

**Operation**

The impacts on wildlife and vegetation from air emissions due to routine
operations should be minor. For the criteria air pollutants SO~2~,
NO~2~, PM-10, and CO, modeled estimates of increases in ground-level
concentrations due to project emissions are generally low (Table 4.1.1),
and actual degradation of air quality should be less than the amounts
predicted (Section 4.1.2.2). Although no estimates of project-related
hazardous air pollutants and trace elements are currently available, the
cleaning of synthesis gas would result in a high percentage of removal
(Section 4.1.2.2). Trace elements and organic compounds would be
released at low concentrations and would be diluted further by
atmospheric dispersion over a large geographic area, resulting in
deposition amounts that should be below levels known to be harmful to
wildlife and vegetation or to affect ecosystems through bio-uptake and
biomagnification in the food chain (Will and Suter 1995; Suter and Tsao
1996; Jones, Suter, and Hull 1997; Sample, Opresko, and Suter 1996).

The culm that would be used as feedstock for the proposed facilities
would be obtained from culm banks created during previous anthracite
mining in the region. Pennsylvania law (25 Pa. Code §88.181.243)
requires that remined culm banks be graded to minimize erosion and that
vegetation be successfully established for at least 5 years.
Consequently, operation of the proposed facilities would result in
reclamation of anthracite mined lands in the adjacent valley and the
region. Actively remining previously abandoned surface or deep mines is
encouraged by the Pennsylvania Department of Environmental Protection
(2004c) as the most efficient way to reclaim abandoned mine lands at no
cost to taxpayers. Although a reasonable estimate cannot be made of the
amount of land that would be reclaimed during the 3-year demonstration
period (because of uncertainty in the selection of culm banks to be used
and variations in bank dimensions), approximately 1,000 acres would be
reclaimed over the entire 26-year operating life of the proposed
facilities. Over the long term, the terrestrial habitat created on
reclaimed lands would offset the 76.5 acres of deciduous forest that
would be cleared for the proposed facilities.

#### 4.1.6.2 Aquatic Ecology

Impacts to aquatic habitats and fish from construction and operation of
the proposed facilities would be minor to negligible. No surface waters
are on or in the immediate vicinity of the proposed project site. Best
management practices (BMPs) for sediment and erosion control, including
use of silt fence, straw bale structures, and geotextile materials would
be employed during construction. Accidental spills of construction
materials such as solvents, paints, oil, grease, and hazardous
substances would be controlled in accordance with an appropriate spill,
prevention, control, and countermeasure plan. Thus, impacts to the
closest surface water body, a tailings pond along Mahanoy Creek more
than 0.25 mile from the proposed plant site, would be unlikely.

Operational water for the proposed facilities would be withdrawn from
the mine pool. Wastewater, including any contaminated runoff from the
project site, would be handled using a combination of stormwater
retention, wastewater treatment, oil recovery, biological treatment and
solids removal, and disposal. Wastewater treatments would include
equalization, API separator treatment for oil removal and recovery,
dissolved air flotation for additional oil removal, and biological
treatment. Spills at the project site and ancillary structures such as
the product rundown lines would be controlled consistent with a spill
control plan. Product rundown lines would be designed to withstand
flooding and earth slides. Potential for spill-related liquid effluents
to reach surface water bodies would be low.

Wastewater would be treated to meet effluent limits specified in a
Pennsylvania Department of Environmental Protection NPDES permit, and
would be blended with both treated and uncontaminated stormwater prior
to discharge to the tailings pond in the valley. The water in the
tailings pond would percolate back to the mine pool, which is pumped as
necessary by the Pennsylvania Department of Environmental Protection and
discharged to Mahanoy Creek. Due to consumptive use of water by the
proposed facilities, less state pumping of mine pool water would be
required and Mahanoy Creek stream-flow would be reduced (Section
4.1.4.1). Wastewater quality would be monitored to ensure compliance
with permitted effluent limits. The treated water discharged to the
tailings pond would be of higher quality (i.e., less acidic with lower
concentrations of dissolved metals) than the mine pool water. The effect
of returning some of this water on the water quality and aquatic ecology
of Mahanoy Creek, which is substantially altered due to acid mine
drainage, should be negligible to slightly beneficial.

Land reclamation following culm bank removal for project feedstock would
be expected to reduce acid mine drainage and pollution of streams and
rivers in the anthracite coal region (PDEP 2004c). Removal of culm banks
followed by grading and vegetation establishment would act to reduce
infiltration of rainwater and snowmelt into pyrite-bearing strata, thus
reducing acid mine drainage (Klemow 2000; Hawkins 1995).

#### 4.1.6.3 Threatened and Endangered Species

Because the proposed facilities would not be located within an area that
provides habitat for any endangered, threatened, candidate, special
concern, or rare species of bird, mammal, reptile, amphibian, fish,
aquatic invertebrate, or plant recognized by the state or federal
government, except for occasional transient individuals (Section 3.6.3),
it is unlikely that any such species would be affected by project
construction or operations.

In compliance with Section 7 of the Endangered Species Act of 1973, as
amended, DOE requested consultation with the U.S. Fish and Wildlife
Service regarding potential impacts of the proposed facilities on
threatened and endangered species. The U.S. Fish and Wildlife Service
response indicated that, with the exception of occasional transient
individuals, no federally-listed or proposed threatened or endangered
species are known to occur within the project impact area, and that no
biological assessment or further consultation under the Endangered
Species Act would be required (Appendix A).

#### 4.1.6.4 Biodiversity

About 75 acres of second-growth deciduous forest typical to the region
would be lost due to clearing and construction on the project site.
Given the predominance of this forest type in the region it is unlikely
that unique genetic information, or rare species or ecosystem
components, would be lost. Thus, discernable impacts to biodiversity
would not be expected.

### 4.1.7 Social and Economic Resources

The social and economic impacts of the proposed project would be most
noticeable during the 30‑month construction period, when an average of
516 workers would be on the site. These impacts would peak during a
6-month period when 1,000 workers would be on the site. The project
would also have short-term impacts from employment of 250 workers during
the 36-month demonstration period immediately following construction,
and long-term impacts from employment of 150 workers for operations
after completion of the demonstration (Sullivan 1997). This assessment
focuses primarily on the social and economic impacts of project
construction and long-term operations because construction would have
the largest impacts and operations would have the longest-lasting
impacts. The assessment focuses less on the social and economic impacts
of the 36-month demonstration period because they would be smaller than
those of the construction period and of shorter duration than those of
the operations period.

In addition to the direct jobs that would be created by project
construction and operations, a number of indirect and induced jobs would
be created. Indirect jobs are those created by businesses that provide
goods and services essential to the construction and operation of a
project. Induced jobs are those created "by the spending of the wages
and salaries of the direct and indirect employees on items such as food,
housing, transportation, and medical services" (NEPaA 2004b).

Using calculations based on the Northeastern Pennsylvania Alliance
*Economic Impact Model*, the average number of direct jobs during
project construction (516) could create as many as 181 indirect jobs and
175 induced jobs, for a total of 872 jobs in Schuylkill County (NEPaA
2004c). The peak number of direct jobs during construction (1,000) could
create as many as 351 indirect jobs and 338 induced jobs, for a total of
1,689 jobs in Schuylkill County (NEPaA 2004c).

Similarly, during long-term operation of the proposed facilities, the
150 direct jobs could create as many as 115 indirect jobs and 173
induced jobs in Schuylkill County (NEPaA 2004c). Thus, long-term project
operations could account for as many as 438 total jobs in Schuylkill
County. The employment multipliers for operational jobs are larger than
those for construction jobs because the operating period is much longer
than the construction period and, therefore, would likely result in more
workers permanently relocating to the area.

The following subsections discuss the potential socioeconomic impacts of
the proposed project, particularly those associated with direct,
indirect, and induced employment during project construction and
operations.

#### 4.1.7.1 Population

Because the proposed facilities would be located within a 1-hour drive
of some large labor markets with existing labor organizations (i.e.,
Reading, Allentown, and Wilkes-Barre), a minimal number of workers would
be expected to move to the project locale during construction and
operation. Therefore, this analysis assumes that most of the
construction and operations workers already reside in the project region
and would commute daily from their homes to the project site. Although
workers would be unlikely to relocate from outside the project region,
this analysis assumes as a conservative estimate that 10% of the peak
construction work force (100 workers) and 60% of the operations work
force (90 workers) would relocate. The analysis assumes a lower
percentage of relocating workers for construction than for operations
because the construction period would last only 30 months (i.e., the
shorter the work period, the less likely that workers would relocate).

Past experience with large, multi-year power plant construction and
refurbishment projects indicates that approximately 60% of the
in-migrating work force is accompanied by family, while the remaining
40% is not (NRC 1996). However, for this relatively small, 30-month
construction project, a more reasonable assumption is that only 40% of
the construction workers relocating to the area (40 workers) would be
accompanied by family. This analysis assumes that a higher percentage of
the operational workers relocating to the area (75% or 68 workers) would
be accompanied by family because the facilities\' operating period would
be much longer than the construction period.

Assuming that 60 construction workers would relocate without families
and that 40 construction workers would relocate with families, and
assuming an average family household size of 2.48 persons for
Pennsylvania (U.S. Census Bureau 2004b), the permanent population in the
project area (Schuylkill County) would increase by about 160 as a result
of direct construction employment. This population growth would
represent 0.11% of Schuylkill County\'s population in 2000.

Similarly, assuming that 68 operations workers would relocate with
families and that 22 operations workers would relocate without families,
and assuming an average family household size of 2.48 persons, the
permanent population in the project area would increase by about 190 as
a result of direct operations employment. This population growth would
represent 0.13% of Schuylkill County\'s population in 2000.

The indirect and induced jobs that could be created would be less
specialized than the direct construction and operations jobs, and would
be even more likely to be filled by existing area residents.
Accordingly, this analysis assumes that none of the indirect or induced
work force would relocate to the project area during project
construction or operations.

The potential impacts of project-related population growth are discussed
below in Sections 4.1.7.3 (Housing), 4.1.7.4 (Water and Wastewater
Services), and 4.1.7.5 (Public Services).

#### 4.1.7.2 Employment and Income 

The 1,689 total jobs (1,000 direct, 351 indirect, and 338 induced) that
could be created during the peak construction period (Section 4.1.9)
would represent 2.5% of the total labor force in Schuylkill County in
2000. Similarly, the 438 total new jobs (150 direct, 115 indirect, and
173 induced) that could be created during project operations would
represent 0.6% of the county\'s total labor force. Because most of the
direct, indirect, and induced jobs during construction and operations
would be filled by workers who currently reside within a 1-hour driving
distance of the proposed facilities, project construction would have a
short-term positive effect on employment in the region, and project
operations would have a long-term positive effect on employment in the
region.

Because most of the construction and operations work forces would reside
in the project region, project wages would have a positive effect on
total and per capita income in Schuylkill County. Based on the types and
numbers of occupations that would make up the construction work force
and the average annual salaries for those occupations in Schuylkill
County (PDLI 2003), the total direct payroll during the 6-month peak
construction period would be close to \$20 million. The total direct
payroll for the entire 30‑month construction period would be at least
twice as large as this \$20 million figure. Further, assuming only the
current minimum wage in Pennsylvania of \$5.15 per hour (U.S. Department
of Labor 2004) and 2,000 hours per work-year, the total payroll
generated by the indirect and induced jobs (356) over the 30-month
construction period would be over \$9 million.

Similarly, assuming that 150 employees would make up the operations work
force, and that the average annual salary for a \"power plant operator\"
in Schuylkill County is \$40,014 (PDLI 2003), the annual direct payroll
during project operations would be at least \$6 million. Further,
assuming only the current minimum wage in Pennsylvania (\$5.15 per hour)
and 2,000 hours per work-year, the annual payroll generated by the
indirect and induced jobs (288) during project operations would be
nearly \$3 million.

Overall, construction of the proposed facilities would have short-term
positive effects on employment and income in the region. Project
operations would also have positive effects on employment and income
and, provided that the demonstration were successful (Section 5), these
effects would last longer than the effects of construction. The
project\'s positive effects on employment and income would contribute to
the region\'s economic viability.

#### 4.1.7.3 Housing 

Because most of the direct, indirect, and induced jobs during project
construction and operations would be filled by workers who currently
reside within a 1-hour driving distance of the proposed facilities,
demand for housing in Schuylkill County would not increase appreciably.
Housing for the 100 new construction-related households (i.e., the
workers relocating with and without families) assumed as an upper bound
in this analysis would represent 1.4% of the 7,276 vacant housing units
in Schuylkill County in 2000. Similarly, the 90 new operations-related
households would represent 1.2% of the county\'s vacant housing in 2000.
These levels of increased demand would not be likely to have an adverse
effect on the availability or cost of housing in Schuylkill County,
particularly given the county\'s population decline since 1990.

Because the relatively small increase in demand for housing associated
with the proposed project would not likely affect housing availability
or cost in Schuylkill County, it also would not likely increase
residential property values. Conversely, because the proposed facilities
would be located between an existing power plant and a correctional
institution, project construction and operations would not likely
decrease residential property values in the county.

#### 4.1.7.4 Water and Wastewater Services

Because most of the direct, indirect, and induced jobs during project
construction and operations would be filled by workers who currently
reside within a 1-hour driving distance of the proposed facilities,
demand for water and wastewater services in Schuylkill County would not
increase appreciably. Mahanoy Township Authority and the Schuylkill
County Municipal Authority have abundant water supplies (Section 3.7.4),
which could easily meet the additional demand from 100 new
construction-related households and 90 new operations-related
households. Because of planned upgrades by the Greater Pottsville Area
Sewer Authority, the additional demand from the new households would not
exacerbate existing problems with the provision of wastewater services
in Pottsville (Section 3.7.4).

### 4.1.7.5 Public Services

### 

### Police Protection

As discussed in Section 4.1.7.1, population growth associated with
construction and operation of the proposed facilities would be minimal,
representing only about 0.1% of Schuylkill County\'s population in 2000.
Given such a small population increase, particularly in the context of
an ongoing population decrease in Schuylkill County (Section 3.7.1),
construction and operation of the facilities would not create an
additional need for police protection. In the unlikely event of an
accident associated with plant operations or the shipment of materials,
additional police resources would probably be required, most likely from
Pottsville and the Pennsylvania state police.

### 

### Fire Protection and Emergency Medical Services

As with police protection, the relatively small population increase and
housing demand associated with construction and operation of the
proposed facilities would not create an additional need for fire
protection or emergency medical services. In the unlikely event of an
accident associated with plant operations or the shipment of materials,
additional fire protection and emergency medical services would probably
be required, most likely from Pottsville and other parts of Schuylkill
County.

### Schools

Because population growth associated with construction and operation of
the proposed facilities would be minimal, little (if any) effect on
local schools would be experienced. This outcome is reinforced by
Schuylkill County projections, which indicate that by 2013 the Mahanoy
Area School District\'s total enrollment will decrease by more than 39%
for all grade levels, and the Pottsville Area School District\'s
enrollment will decrease by 5% for kindergarten--8th grade and by 23%
for 9th--12th grade (Section 3.7.5.3).

### Health Care

Given the small population growth associated with construction and
operation of the proposed facilities, particularly in the context of an
ongoing population decrease in Schuylkill County (Section 3.7.1),
construction and operation of the facilities would not create an
additional need for health care facilities. In the unlikely event of an
accident associated with plant operations or the shipment of materials,
the local health care facilities could be strained, and some accident
victims might need to be transported out of the immediate area for
treatment. The extent of the impact on local health care facilities and
the need to transport patients elsewhere would depend on the type and
size of the accident.

#### 4.1.7.6 Local Government Revenues

The proposed facilities would be located in one of Pennsylvania\'s
designated Keystone Opportunity Zones, which are geographical areas that
receive local and state approval for tax abatements for the purpose of
stimulating economic development. Because of this designation, local
real estate taxes (to Schuylkill County, Mahanoy Township, and the
Mahanoy Area School District) for the proposed project site and taxable
improvements would not be due until January 2014. Using 2003 real estate
tax rates and a projected assessed value on land and improvements, the
facilities\' annual real estate tax payments would be approximately
\$73,000 starting in 2014.

#### 4.1.7.7 Environmental Justice

As discussed in Section 3.7.7, Schuylkill County and eight of the nine
census tracts within 3 miles of the proposed facilities have lower
minority percentages than the United States and Pennsylvania. For Census
Tract 7, however, significant minority populations reside at the Mahanoy
and Frackville State Correctional Institutions. The Mahanoy State
Correctional Institution is immediately east of the proposed main plant
site, and its minority inmate population represents an "environmental
justice" population to which the adverse impacts of constructing and
operating the proposed facilities could be distributed
disproportionately. Serious air quality and health impacts to this
population would not be expected, however, because (1) air quality
impacts would not be appreciable with the exception of temporary
fugitive dust during construction, and (2) the Mahanoy State
Correctional Institution is a sealed facility in which inmates and
employees would not be exposed to outside air except during periods of
outdoor activity (Section 4.1.2.1).

Schuylkill County\'s population percentage below the poverty level is
lower than that of Pennsylvania and the United States. However, two
census tracts near the site of the proposed facilities have relatively
high poverty rates (Table 3.7.5). Census Tracts 5 and 6 have poverty
rates that exceed those of both Pennsylvania and the United States.
Therefore, the relatively large populations below the poverty level in
Census Tracts 5 and 6 represent "environmental justice" populations to
which the adverse impacts of constructing and operating the proposed
facilities could be distributed disproportionately. Serious air quality,
water quality, and health impacts to these populations would not be
expected, however, as discussed in Sections 4.1.2, 4.1.4, and 4.1.9. The
proposed project could have positive economic effects for these
populations by creating employment and income in the region (Section
4.1.7.2).

#### 4.1.7.8 Transportation

#### 

##### Roads

All of the 1,000 workers during the 6-month peak construction period
would access the project site from State Route 1008 (Morea Road). Most
of these workers would access State Route 1008 from its intersection
with State Route 61 in the town of Frackville. For this assessment, it
is assumed that the construction workers would commute to and from the
project site each day, and that the average vehicle would carry two
workers. Thus, as an upper bound, about 1,000 additional vehicle trips
(500 to the site and 500 from the site) would be generated each day
during the peak construction period.

Average daily traffic (ADT) on State Route 61 in Frackville is 10,186
vehicles, and ADT on State Route 1008 near the Gilberton Power Plant is
4,486 vehicles (Section 3.7.8.1). The 1,000 additional daily vehicle
trips for workers during the peak construction period would represent
increases of 10% and 22% over existing traffic on State Route 61 and
State Route 1008, respectively. Increases of this size on State Route 61
and State Route 1008 would likely cause traffic congestion and have an
appreciable impact on traffic flow and safety during morning and
afternoon commutes (Dave Gruber, Pennsylvania Department of
Transportation District 5, personal communication to James W. Saulsbury,
ORNL, May 26, 2004). In addition to these construction workers\'
vehicles, the number of construction delivery trucks accessing the
project site from State Route 61 and State Route 1008 would increase.
Because most of this construction-related traffic would occur during
peak morning and afternoon drive times, impacts to traffic flow and
safety on State Route 61 and State Route 1008 would be particularly
acute. WMPI personnel have committed to contacting the Pennsylvania
Department of Transportation to discuss potential mitigation options,
including signaling, road widening, and scheduling work hours and/or
deliveries to avoid periods of heavy traffic.

During the demonstration and long-term project operations, all of the
250 and 150 workers, respectively, would access the facilities from
State Route 1008 (primarily via State Route 61 in Frackville). It is
assumed for this assessment that each vehicle would carry one operations
worker. Thus, as an upper bound, about 500 additional vehicle trips (250
to the site and 250 from the site) would result each day from workers
commuting during the demonstration, while about 300 additional vehicle
trips (150 to the site and 150 from the site) would result each day from
workers commuting during long-term operations. In addition,
approximately 104 truck trips per day (52 to the site and 52 from the
site) would deliver culm to the site, 40 truck trips per day (20 to the
site and 20 from the site) would bring limestone, and 22 truck trips per
day (11 to the site and 11 from the site) would transport waste material
to an offsite landfill. Although liquid fuels produced by the proposed
facilities are planned to be shipped from the facilities solely by rail,
if the fuels should be shipped by truck, about 80 vehicle trips would be
required daily (40 to the site and 40 from the site). The impacts of
operations-related traffic would be less severe than those of
construction-related traffic but would be more long lasting. WMPI
personnel have committed to contacting the Pennsylvania Department of
Transportation to discuss potential mitigation options, including
signaling, road widening, and scheduling work hours and/or deliveries to
avoid periods of heavy traffic.

##### Railways 

The proposed facilities would affect the local rail system because the
project\'s liquid fuels would be shipped by rail. Rail transport would
require the construction of product pipelines to transport materials to
the nearest railroad siding in Gilberton, about 1 mile from the main
plant area, and construction of storage and loading facilities capable
of filling approximately eight tank car loads of product per day. Filled
tank cars would be stored on a siding. Once a week, a new supply of
empty tank cars would be delivered, and a train of filled tank cars
would be assembled and moved off the site. Rail shipments of this
magnitude would not have adverse impacts on the local rail system (James
G. Raffa, Vice President, Traffic, Reading Blue Mountain & Northern
Railroad Company, personal communication to James W. Saulsbury, ORNL,
September 9, 2004). Potential accidents associated with transport of
liquid fuels are discussed in Section 4.1.9.1.

#### 4.1.7.9 Cultural Resources 

In compliance with Section 106 of the National Historic Preservation Act
of 1966, as amended, DOE has consulted with the Pennsylvania SHPO
regarding a determination of the potential for impacts associated with
the proposed facilities on any historic resources that may be listed in
or eligible for the *National Register of Historic Places* or that may
have local importance. Impacts from construction and operation of the
facilities would not be likely because the SHPO has stated that no
historic or archaeological properties are listed or eligible for listing
on the *National Register* in the project area (Appendix B). The SHPO
has further stated that DOE's responsibility for consultation is
complete. However, the SHPO would be notified if any historic or
archaeological properties located at or near the project site are
detected.

### 4.1.8 Waste Management

### 

#### 4.1.8.1 Construction

Initial site grading would include land clearing, grubbing, stripping,
excavation, and placement of fill to establish rough grading elevations.
Excavated soil would be used onsite for fill. Topsoil and other soil
containing organic material would be stockpiled on the site and used in
final grading. Some timber could be salvaged and sold for pulpwood or
firewood, but the majority of the removed vegetation, including tree
stumps, would be managed as waste. Open burning on the site would
minimize the labor and transportation required to dispose of this
material, but would have short-term impacts in the surrounding area due
to smoke, odors, and increased airborne particles (Section 4.1.2.1). To
minimize the potential for fire to spread to nearby vegetation, burning
would not be scheduled during drought conditions in which advisories
have been issued by the Pennsylvania Department of Environmental
Protection. Alternatively, this material could be taken to a commercial
composting facility for recycling. Composting facilities that accept
land-clearing debris are located in Robesonia (Berks County), Bethlehem,
and the Philadelphia area (Section 3.8).

Waste from construction of the proposed facilities would include excess
materials, metal scraps, and pallets, crates, and other packing
materials. Excess supplies of new materials would be returned to
vendors, retained for future use, or transferred in settlement with
subcontractors (who could retain the items for use in future projects).
Surplus paint and other consumables, partial spools of electrical cable,
and similar leftover materials would also be retained for possible
future use in maintenance, repairs, and modifications (Section 2.1.6.3).

Metal scrap not suitable for future use in the facilities would be
collected in dumpsters for resale to scrap dealers or recyclers. The
volume of metal scrap would be no more than one dumpster per month
during the period of peak scrap generation, with less generated during
the first six months and last three months of construction (Section
2.1.6.3).

Packaging materials and nonmetal components broken during installation
would be collected in dumpsters for offsite disposal. The largest volume
of solid waste requiring disposal would be packaging material, including
wooden pallets and crates, support cradles used for shipping of large
vessels and heavy components, and cardboard and plastic packaging. The
rate of generation for packaging waste would be up to two truckloads per
month (estimated to be about 18 cubic yards or 18 tons per month) during
construction (Section 2.1.6.3). The volume of broken nonmetal components
would be much smaller. The quantity and character of other wastes would
be typical of any work site. Office waste paper would be collected for
recycling, and miscellaneous work site waste (such as garbage from
workers' meals) would be collected for offsite disposal.

The commercially available municipal solid waste landfills in the region
(Section 3.8) should have ample capacity to receive and dispose of
project construction wastes. Because project construction waste
quantities would be small in comparison with the landfill capacities and
waste quantities routinely handled at these sites, management of these
wastes should have negligible impact.

During construction, no hazardous waste generation would be anticipated
(Section 2.1.6.3).

#### 4.1.8.2 Operation

##### Solid Waste

Solid wastes and byproducts generated by the operation of the proposed
facilities would include gasifier slag, fine solids, elemental sulfur,
and sludges from water and wastewater treatment (Section 2.1.6.3).

Slag generated by the gasifier would be a vitrified (glass) silicate
material formed when noncombustible solids found in coal and culm are
heated past the melting point and then cooled rapidly. No organic
compounds would be expected in this material. Slag, which would be black
in color and granular (sand-like) in form, would be generated at a rate
of 1,600 tons per day (wet weight) or 800 tons per day (dry weight). One
day's slag production would cover an acre of land to a depth of about 1
ft.

Commercial uses would be sought for the gasifier slag, which is
projected to have low bulk density, high shear strength, and good
drainage and filtering characteristics. Several potential uses have been
identified for this material, including lightweight construction
aggregate, asphalt roofing shingle granules, blasting grit, and pipe
bedding material (SAIC 2002). However, markets for this material have
not yet been established. Any slag that is not used commercially would
be used as fill material for surface mine reclamation at and near sites
where culm would be obtained (Section 2.1.6.3).

Contaminants potentially can leach into groundwater or surface water
when solid byproducts are used in the environment. Requirements of the
Pennsylvania residual waste management regulations (25 Pennsylvania Code
Chapter 287) are intended to prevent or reduce the potential for adverse
impacts from leaching of wastes (Strock 1996). Coal combustion residues
must be characterized for chemical composition and to verify that they
meet regulatory criteria for leachability. Materials must be retested
periodically to demonstrate that they continue to meet the criteria.
Coal combustion residues may be used as fill only in coal mining areas
(active or abandoned) or coal refuse disposal sites. Placement must be
at least 8 ft above the regional water table, but the regulations
provide for exemptions (e.g., placement in mine pools) upon
demonstration that no groundwater contamination would occur. Compliance
with these regulations would minimize the potential for adverse impacts
to water quality from management of the slag residue.

Characterization of coal ash from the existing Gilberton Power Plant
provides a basis for predicting the characteristics and leaching
behavior of coarse slag from the proposed facilities. Because both
facilities would use culm from the same sources, the slag and ash should
have similar chemical composition, but the vitrified gasifer slag would
have different physical and mechanical properties and would be less
leachable than the ash, which is formed at lower temperatures.
Table 4.1.2 presents results of chemical analysis and leachability
testing of Gilberton Power Plant ash. Leachability was tested using the
Synthetic Precipitation Leaching Procedure (SPLP), which simulates the
potential effects of leaching under acidic conditions typical of
rainfall in the eastern United States. Testing found the ash to be
highly alkaline (leachate pH was 10.48), a desirable characteristic for
reclamation of acidic mine wastes. All dissolved constituents in the ash
leachate were below maximum acceptable concentrations for beneficial
use, as specified under Pennsylvania residual waste management
regulations. Ash leachate concentrations of all constituents except
aluminum, antimony, arsenic, lead, and sulfate were also below the
applicable drinking water Maximum Contaminant Level Goal (MCLG) or
primary or secondary drinking water standards (for substances without
MCLGs). Due to the physical differences between slag and ash, leaching
of slag from the proposed facilities would be expected to result in much
lower contaminant concentrations. Thus, the risk of adverse impacts to
groundwater quality from using this material in mine reclamation would
be negligible. However, the relatively inert slag also would have less
value as a source of alkalinity for acidic mine reclamation.

About 200 tons of fine solids (dry basis) would be generated each day.
Some of this material might be captured and returned to the gasifier for
energy recovery (SAIC 2002), but the majority would be used in a
permitted ash disposal area on WMPI land as part of mine reclamation
(Section 2.1.6.3), subject to the same residual waste regulations that
would govern management of the slag. The fine solids would not be as
chemically inert as either slag or power plant bottom ash and would
contain 11% carbon (dry basis), as either unburned carbon or other
coal-derived organic constituents. The potential for impacts to water
quality from using this material in mine reclamation would be larger
than from similar use of the slag, but compliance with the residual
waste regulations would minimize the potential for adverse impacts to
water quality. Although it is expected that the majority of fine solids
would be applied on land as part of mine reclamation, this assessment
also considers the possibility that the material would not meet
regulatory criteria for use in mine reclamation, and therefore would be
taken for disposal in a commercial landfill, such as the facilities
identified in Section 3.8.

+------------+--------------+--------------+--------------+------------+
| **Table    |              |              |              |            |
| 4.1.2.     |              |              |              |            |
| Chemical   |              |              |              |            |
| analysis   |              |              |              |            |
| of         |              |              |              |            |
| Gilberton  |              |              |              |            |
| Power      |              |              |              |            |
| Plant coal |              |              |              |            |
| ash and    |              |              |              |            |
| S          |              |              |              |            |
| ynthetic** |              |              |              |            |
|            |              |              |              |            |
| **Pre      |              |              |              |            |
| cipitation |              |              |              |            |
| Leaching   |              |              |              |            |
| Procedure  |              |              |              |            |
| (SPLP)     |              |              |              |            |
| leachate** |              |              |              |            |
+------------+--------------+--------------+--------------+------------+
| C          | Ash          | Leachate     | Maximum      | Applicable |
| onstituent | c            | c            | acceptable   | drinking   |
|            | oncentration | oncentration | leachate     | water      |
|            |              | (mg/L)       | c            | criterion  |
|            | (mg/kg       |              | oncentration | (mg/L)     |
|            |  dry weight) |              | (mg/L)*^a^*  |            |
+------------+--------------+--------------+--------------+------------+
| Aluminum   | 36,300       | 3.14         | 5.0          | 0.2*^b^*   |
+------------+--------------+--------------+--------------+------------+
| Antimony   | 4            | \<0.04       | 0.15         | 0.006*^c^* |
+------------+--------------+--------------+--------------+------------+
| Arsenic    | 18.1         | 0.045        | 1.25         | 0.05*^d^*  |
+------------+--------------+--------------+--------------+------------+
| Barium     | 296          | 0.04         | 50           | 2*^c^*     |
+------------+--------------+--------------+--------------+------------+
| Boron      | 61           | 0.06         | 31.5         | ---*^e^*   |
+------------+--------------+--------------+--------------+------------+
| Cadmium    | 0.9          | \<0.005      | 0.13         | 0.005*^c^* |
+------------+--------------+--------------+--------------+------------+
| Chromium   | 57           | 0.08         | 2.5          | 0.1*^c^*   |
+------------+--------------+--------------+--------------+------------+
| Copper     | 51           | 0.02         | 32.5         | 1.3*^c^*   |
+------------+--------------+--------------+--------------+------------+
| Iron       | 24,300       | 0.21         | 7.5          | 0.3*^b^*   |
+------------+--------------+--------------+--------------+------------+
| Lead       | 58           | 0.05         | 1.25         | 0.005*^f^* |
+------------+--------------+--------------+--------------+------------+
| Manganese  | 120          | \<0.005      | 1.25         | 0.05*^b^*  |
+------------+--------------+--------------+--------------+------------+
| Mercury    | 0.2          | \<0.0002     | 0.05         | 0.002*^c^* |
+------------+--------------+--------------+--------------+------------+
| Molybdenum | \<1.0        | 0.05         | 4.38         | ---*^e^*   |
+------------+--------------+--------------+--------------+------------+
| Nickel     | 21           | \<0.01       | 2.5          | ---*^e^*   |
+------------+--------------+--------------+--------------+------------+
| Selenium   | 8.5          | 0.018        | 1.0          | 0.05*^c^*  |
+------------+--------------+--------------+--------------+------------+
| Zinc       | 37           | 0.05         | 125          | 5*^b^*     |
+------------+--------------+--------------+--------------+------------+
| Chloride   | NA*^g^*      | 1.78         | 2,500        | 250*^b^*   |
+------------+--------------+--------------+--------------+------------+
| Sulfate    | NA*^g^*      | 502          | 2,500        | 250*^b^*   |
+------------+--------------+--------------+--------------+------------+
| *Source*:  |              |              |              |            |
| WMPI PTY,  |              |              |              |            |
| LLC.       |              |              |              |            |
| Analysis   |              |              |              |            |
| reported   |              |              |              |            |
| by Hawk    |              |              |              |            |
| Mountain   |              |              |              |            |
| Labs,      |              |              |              |            |
| Inc., West |              |              |              |            |
| Hazleton,  |              |              |              |            |
| PA,        |              |              |              |            |
| December   |              |              |              |            |
| 12, 2003   |              |              |              |            |
|            |              |              |              |            |
| *^a^*Pe    |              |              |              |            |
| nnsylvania |              |              |              |            |
| residual   |              |              |              |            |
| waste      |              |              |              |            |
| management |              |              |              |            |
| re         |              |              |              |            |
| gulations, |              |              |              |            |
| (25        |              |              |              |            |
| Pe         |              |              |              |            |
| nnsylvania |              |              |              |            |
| Code       |              |              |              |            |
| Chapter    |              |              |              |            |
| 287). For  |              |              |              |            |
| most       |              |              |              |            |
| dissolved  |              |              |              |            |
| metals,    |              |              |              |            |
| maximum    |              |              |              |            |
| acceptable |              |              |              |            |
| conc       |              |              |              |            |
| entrations |              |              |              |            |
| were set   |              |              |              |            |
| at 25      |              |              |              |            |
| times the  |              |              |              |            |
| applicable |              |              |              |            |
| drinking   |              |              |              |            |
| water      |              |              |              |            |
| Maximum    |              |              |              |            |
| C          |              |              |              |            |
| ontaminant |              |              |              |            |
| Level Goal |              |              |              |            |
| (MCLG; a   |              |              |              |            |
| he         |              |              |              |            |
| alth-based |              |              |              |            |
| criterion  |              |              |              |            |
| e          |              |              |              |            |
| stablished |              |              |              |            |
| by federal |              |              |              |            |
| and state  |              |              |              |            |
| drinking   |              |              |              |            |
| water      |              |              |              |            |
| re         |              |              |              |            |
| gulations) |              |              |              |            |
| or         |              |              |              |            |
| secondary  |              |              |              |            |
| drinking   |              |              |              |            |
| water      |              |              |              |            |
| standard.  |              |              |              |            |
| For        |              |              |              |            |
| chloride   |              |              |              |            |
| and        |              |              |              |            |
| sulfate,   |              |              |              |            |
| the        |              |              |              |            |
| maximum    |              |              |              |            |
| conc       |              |              |              |            |
| entrations |              |              |              |            |
| are 10     |              |              |              |            |
| times the  |              |              |              |            |
| secondary  |              |              |              |            |
| drinking   |              |              |              |            |
| water      |              |              |              |            |
| standard.  |              |              |              |            |
|            |              |              |              |            |
| *^b^       |              |              |              |            |
| *Secondary |              |              |              |            |
| drinking   |              |              |              |            |
| water      |              |              |              |            |
| standard.  |              |              |              |            |
|            |              |              |              |            |
| *^c^*MCLG  |              |              |              |            |
|            |              |              |              |            |
| *^         |              |              |              |            |
| d^*Primary |              |              |              |            |
| standard;  |              |              |              |            |
| will       |              |              |              |            |
| change to  |              |              |              |            |
| 0.01 mg/L  |              |              |              |            |
| in January |              |              |              |            |
| 2006 (no   |              |              |              |            |
| MCLG).     |              |              |              |            |
|            |              |              |              |            |
| *^e^*Not   |              |              |              |            |
| currently  |              |              |              |            |
| regulated. |              |              |              |            |
| For        |              |              |              |            |
| nickel,    |              |              |              |            |
| MCLG and   |              |              |              |            |
| primary    |              |              |              |            |
| standard   |              |              |              |            |
| were set   |              |              |              |            |
| at 0.1     |              |              |              |            |
| mg/L until |              |              |              |            |
| remanded   |              |              |              |            |
| in 1995.   |              |              |              |            |
|            |              |              |              |            |
| *^f^*Pe    |              |              |              |            |
| nnsylvania |              |              |              |            |
| primary    |              |              |              |            |
| drinking   |              |              |              |            |
| water      |              |              |              |            |
| standard   |              |              |              |            |
| (no MCLG). |              |              |              |            |
|            |              |              |              |            |
| *^g^*NA =  |              |              |              |            |
| Not        |              |              |              |            |
| analyzed   |              |              |              |            |
+------------+--------------+--------------+--------------+------------+

Sludges from treatment of raw water and wastewater would total about 24
tons per day. Treatment of cooling water (to remove 1,700 lb per day of
iron and manganese) would generate about 11 tons per day of wet sludge,
while wastewater treatment would produce about 13 tons per day of wet
sludge. Provided that the requirements of the Pennsylvania residual
waste management regulations are met, these sludges would be placed in
Mahanoy Creek valley on WMPI land that is permitted for disposal of coal
byproducts under refuse reprocessing permit 54850202, issued by the
Office of Mineral Resources Management in the Pennsylvania Department of
Environmental Protection (Section 3.8). Although the sludges would
likely qualify under Pennsylvania regulations for placement on WMPI land
as part of mine reclamation, this assessment also considers the
possibility that both types of sludges would be taken for disposal in a
commercial landfill.

The placement of the proposed facilities' solid wastes and byproducts on
lands that were previously mined or covered with culm banks would
contribute to reclamation of surface-mined lands (i.e., contour grading
and vegetation establishment) (Section 4.1.6.1). Reclamation activities
and needs in the vicinity could easily absorb the volume of material
that would be generated during the 3‑year demonstration (Section 5
discusses corresponding potential impacts associated with commercial
operation following the demonstration). Standard engineering practices
such as silt fencing and straw bales would be employed during
reclamation to prevent adverse impacts to surface waters from runoff,
erosion, and sedimentation. Earthen berms or dikes could be needed to
provide effective management for the large quantities of wet sludge.
Periodic inspections by Pennsylvania Department of Environmental
Protection personnel would help in monitoring the integrity of
engineering controls to assure their effectiveness (Section 3.8).

If fine solids or sludges from the facilities failed to meet criteria
for land application, they could require disposal in an offsite
commercial landfill. Commercial landfill capacity in the region appears
to be sufficient to handle the additional waste volume (Section 3.8).
However, at any of the commercial landfills identified in Section 3.8,
management of both the fine solids (200 tons per day, dry basis) and
water and wastewater treatment sludge (up to 24 tons per day) would
require special clearance from the Pennsylvania Department of
Environmental Protection (Section 7.2) and could require modifications
of operating procedures to avoid adverse effects on landfill operations.
The additional waste would increase average daily waste volumes at
either of the two nearest landfills (Section 3.8) by more than 10%. If
sludges were transported to commercial landfills routinely, additional
dewatering would probably be conducted to reduce weight and the
potential for release of water after delivery. Special handling might
also be required before shipment or within the landfill to control the
release of water, which could affect the quantity and characteristics of
landfill leachate. At least 11 daily truck trips would be required to
deliver fine solids and sludge to the landfill. Roundtrip travel
distance would be more than 20 miles to the nearest landfill
(Commonwealth Environmental Services facility in Foster Township) and
more than 50 miles to the other facilities.

About 13 tons per day of byproduct elemental sulfur would be produced
and sold commercially. Sulfur has numerous uses in agriculture and
industry. More than 10 million tons are consumed in the United States
each year. This consumption exceeds domestic production, all of which is
byproduct material from environmental control systems (Ober 2002). Given
this domestic situation, the market should easily absorb the quantity
(about 4,000 tons) that the proposed facilities would generate each year
of the demonstration.

None of the proposed facilities' solid wastes and byproducts would be
expected to be hazardous as defined under RCRA. The EPA's Toxicity
Characteristic Leaching Procedure test would be performed to verify this
expectation. Any wastes subject to RCRA hazardous waste regulations
would be handled in accordance with standard procedures similar to those
currently implemented at the Gilberton Power Plant.

##### Liquid Waste

Operation of the proposed facilities would generate several different
liquid wastes requiring treatment or control. Liquid wastes from the
gasification and liquefaction processes would hold various impurities
collected in processing, offgas cleaning, and solid waste processing.
Process wastewaters would have high organic loadings and would require
treatment for substances including methanol and other alcohols,
formates, ammonia, formic and acetic acids, cyanides, sulfides, and
chlorides. Stormwater runoff collected from the facilities, coal piles,
and other areas would require removal of oil and grease and other
contaminants. Wastewater from demineralization of mine pool makeup water
would have high concentrations in dissolved substances removed from the
mine pool. Contaminants in wastewater released from the cooling water
system would include proprietary biocides, corrosion and scale
inhibitors (such as phosphates), chlorine, and other substances injected
into the makeup and circulating streams to inhibit corrosion and
fouling, together with high concentrations of dissolved solids (such as
sulfates) not removed during initial water treatment.

Several wastewater collection and treatment units would be used to
manage these liquid waste streams, based on technologies used
successfully in other industries. Stormwater collected from process
areas and stormwater from parking lots and other portions of the site
not used for processing or materials storage would be collected in two
separate lined retention basins. Wastewater from the gasification and
liquefaction processes would be combined with stormwater from process
areas in an equalization basin, then routed to a series of oil-water
separation units where droplets of oil and grease would be recovered and
oily sludge would be collected for disposal or recycling to the
gasification process. Effluent from this stage of treatment would be
mixed with non-oily wastewater streams and routed to a biological
treatment unit that would combine aeration with clarification in order
to treat wastewater with high levels of chemical and biological oxygen
demand. An example of this type of system is the Advent integrated
activated sludge system (Dorr-Oliver EIMCO, undated). This unit would be
designed to consume the organic compounds and nutrients in the
wastewater, yielding treated effluent for discharge and a biological
sludge for disposal. Treated effluent would be mixed with
non-process-area stormwater in an equalization basin for final settling
and testing prior to discharge to a tailings pond in Mahanoy Creek
valley.

Potential environmental impacts from liquid waste management would
include objectionable odors, discharge of incompletely treated
effluents, and the possibility of accidents involving fire or explosion
in oil-water separation units. Potential impacts from odor would be
controlled by treating all process wastewater within enclosed facilities
prior to discharge to the final equalization basin. Treatment system
upsets (e.g., if fluctuations in wastewater characteristics were to
cause a die-off of microorganisms in the biological treatment unit)
could result in release of incompletely treated water, causing odor
problems and water quality degradation off the site. The potential for
upsets could be minimized by designing the system with ample reserve
capacity, selecting treatment units that are demonstrated to tolerate a
wide range of wastewater characteristics, and controlling inflows to the
treatment system to maintain consistent wastewater characteristics.
Potential for explosion in oil-water separation units could be minimized
by using a nitrogen gas blanket over these units.

### 4.1.9 Human Health and Safety

### 

#### 4.1.9.1 Public Health

During construction of the proposed facilities, potential health impacts
to the public could result from fugitive dust emissions into the
atmosphere (Section 4.1.2.1). However, these emissions would occur over
a relatively short time period. WMPI would regularly use water spray
trucks to dampen the material in construction areas to suppress the
generation of dust.

Another potential health impact to the public would be associated with
operational air emissions from the proposed facilities, including SO~2~,
NO~x~, PM-10, CO, and hazardous air pollutants. Schuylkill County
currently experiences a higher average annual rate of deaths than
surrounding counties and Pennsylvania as a whole (Section 3.9.1).
Therefore, any increase in regional air emissions could potentially be
harmful to sensitive members of the general population. However, all
maximum ambient concentrations of criteria pollutants from the proposed
facilities were estimated to be less than their corresponding
significant impact levels, and Air Quality Program Permit No.
54-399-034, issued by the Pennsylvania Department of Environmental
Protection for the proposed facilities, establishes maximum allowable
limits to ensure that the proposed facilities would be a minor new
source of hazardous air pollutants (e.g., mercury) under the National
Emissions Standards for Hazardous Air Pollutants regulations
(Section 4.1.2.2).

With regard to potential accidents, a Hazard and Operability review or
Process Hazards Analysis would be conducted as part of the facility
operational safety requirements to identify and address potential
hazards and operability problems that could adversely impact the safety
of the facilities and nearby communities. The study would analyze
selected what-if scenarios for potential accidents and develop
preventive measures. A Risk Management Plan would identify safety
precautions needed to avoid catastrophic accidents. Because the proposed
facilities would produce and handle flammable fuels, equipment would be
designed, constructed, and operated to meet federally approved codes and
standards (e.g., American Petroleum Institute), which are enforced by
Occupational Safety and Health Administration (OSHA) administrative
mechanisms, design reviews, and regulatory inspections.

While catastrophic accidents would be possible, including accidents
involving fire and/or explosion, the probability of such an incident
would be remote. For example, flammable F-T fuels could be released from
the facilities as a consequence of a potential reactor vessel and/or
process tank failure. The estimated probability for such a potential
catastrophic vessel/tank failure is approximately one occurrence per
2,500 years (ConocoPhillips 2003). Failures would primarily be due to
cracks. Given a catastrophic failure, the probability that the failure
would result in fire or explosion is estimated to be one in 40;
consequently, the probability of fire or explosion caused by a
catastrophic vessel/tank failure would be about one occurrence per
100,000 years, which is a frequency of 1 x 10^-5^ per year
(ConocoPhillips 2003). Similarly, an analysis involving fire or
explosion resulting from the release of flammable F-T fuels due to
catastrophic pipe failure yields a frequency of approximately 1 x 10^-4^
per year, or one occurrence per 10,000 years (ConocoPhillips 2003).

With respect to potential accidents associated with transport of the
produced liquid fuels from the proposed facilities, the U.S. incidence
rate for a serious railcar accident involving hazardous materials
resulting in a release or injury is approximately 7 accidents per
million train-miles (ConocoPhillips 2003). For the proposed project,
because a train of filled tank cars would be moved off the site only
once per week (Section 4.1.7.8) and because fuels produced by the
proposed facilities would be transported to local distribution centers
and/or refineries within a 150-mile radius, a rail accident involving
the tank cars would be very unlikely.

The facilities would have onsite firefighting and emergency response
capabilities with an approved Emergency Response Plan in place to ensure
that, in the event of fire, hazardous material release, or medical
emergency, facility personnel would be able to respond quickly and
effectively so that personal injuries, environmental damage, and/or
property damage would be minimized. Facility personnel would be fully
trained in Hazard and Operability response, along with other safety
training such as injury and emergency reporting procedures, location and
use of firefighting equipment, and proper methods of handling chemicals
and catalysts at the facilities.

#### 4.1.9.2 Electromagnetic Fields

The proposed facilities would tap into the existing Hauto-Frackville #3
69kV transmission line. The new generators would be connected to the
69kV line by constructing a short (less than 100-yard) 69kV interconnect
from the new generators to the existing transmission line. The
interconnect would operate far from any residence. Because no new
transmission line would be built, no perceptible changes to existing EMF
levels would occur. Consequently, EMF-related health effects, if they
exist, would continue unchanged and small (NRC 1997).

#### 4.1.9.3 Worker Health and Safety

Potential health impacts to workers during construction of the proposed
facilities would be limited to the normal hazards associated with
construction (i.e., no unusual situations would be anticipated that
would make the proposed construction activities more hazardous than
normal for a major industrial construction project). Most accidents in
the construction industry result from overexertion, falls, or being
struck by equipment (NSC 2003). Construction-related illnesses would
also be possible (e.g., exposure to chemical substances from spills).

The Bureau of Labor Statistics reported 1,126 fatalities and 408,300
nonfatal occupational injuries and illnesses in the United States in
2003 for the construction industry (Section 3.9.3). During the same
year, Pennsylvania recorded 39 construction-related fatalities. Based on
the national statistics applied to an average of 516 workers on the
site, the proposed project could expect 0.2 fatalities and 79 nonfatal
injuries and illnesses during the 30-month period of construction.

The proposed facilities would be subject to the OSHA General Industry
Standards (29 CFR Part 1910) and the OSHA Construction Industry
Standards (29 CFR Part 1926). During construction and operation of the
proposed facilities, risks would be minimized by WMPI's adherence to
procedures and policies required by OSHA and the state of Pennsylvania.
These standards establish practices, chemical and physical exposure
limits, and equipment specifications to preserve employee health and
safety. Construction permits and safety inspections would be employed to
minimize the frequency of accidents and further ensure worker safety.
Construction equipment would be required to meet all applicable safety
design and inspection requirements, and personal protective equipment
would be used when needed to meet regulatory and consensus standards.

The Bureau of Labor Statistics reported 32 fatalities and 24,500
nonfatal occupational injuries and illnesses in the United States in
2003 for the utilities industry (Section 3.9.3). During the same year,
Pennsylvania recorded no utilities-related fatalities. Based on the
national statistics applied to 250 workers during operations, the
proposed project could expect 0.04 fatalities and 32 nonfatal injuries
and illnesses during the 36‑month period of demonstration. To maximize
worker safety, operations would be managed from a control room. All
instruments and controls would be designed to ensure safe start-up,
operation, and shut down. The control system would also monitor
operating parameters and perform reporting functions. Control stations
would be placed at remote locations at which operator attention would be
required. Therefore, the overall design, layout, and operation of the
facilities would minimize human hazards. Compliance with the Federal
Occupational Safety and Health Standards, as well as safety standards
specified by the state of Pennsylvania and WMPI PTY, LLC, would help
maintain occupational safety.

WMPI PTY, LLC, would develop supplemental detailed procedures for
inclusion in the proposed facilities' Occupational Safety and Health
Program to assure compliance with OSHA and EPA regulations and serve as
a guide for providing a safe and healthy environment for employees,
contractors, visitors, and the community. These procedures would include
job procedures describing proper and safe manners of working within the
facilities (e.g., handling and storage of ammonia would comply with
29 CFR 1910.111), appropriate personal protective equipment (complying
with 29 CFR 1910.132), and appropriate hearing conservation protection
devices. The manual would be used as a reference and training source and
would include accident reporting and investigation procedures, emergency
response procedures, toxic gas rescue-plan procedures, hazard
communication program provisions, material safety data sheet
accessibility, medical program requirements, and initial and refresher
training requirements. In addition, supplemental provisions would be
added to the proposed facilities' Contingency Plan for Hazardous Waste,
Spill Prevention Control and Countermeasures Plan, Hazardous Substances
Response Procedures, and Air Pollution Emergency Episode Plan.

#### 4.1.10 Noise

During construction of the proposed facilities, the principal sources of
noise would be from construction equipment and material handling. The
amount and type of construction equipment would vary depending on the
specific construction activity occurring at that time (e.g., site
excavation, structural steel/mechanical/electrical equipment erection
and installation, piping, fabrication, etc.). Construction activity
would primarily occur within 6 acres of the 75-acre main plant site.

The proposed facilities would be built next to the existing Gilberton
Power Plant. To mitigate the impacts of construction noise, employees
and contractors would be responsible for ensuring that exhaust mufflers
and engine enclosures are in place and in good working order for all
industrial trucks and other pieces of construction-related equipment. An
exhaust muffler is a device that deadens the noise of escaping gases or
vapors through which the exhaust gases of an internal-combustion engine
are passed. An engine enclosure silences low‑frequency noise radiated
from the engine. Exhaust mufflers and engine enclosures are commonly
used, and are commercially available from many different manufacturers.
All construction equipment would be properly maintained.

During operation of the proposed facilities, the principal sound sources
would include equipment like the combustion turbine/generator, steam
turbine/generator, heat recovery systems, turbine air inlets, exhaust
stacks, cooling towers, pumps (e.g., feed, circulating, etc.), and
compressors.

These sound sources would be enclosed and acoustically insulated. Noise
sources within the buildings would be fitted with sound-attenuating
enclosures or other noise dampening measures that would meet all state
and federal regulations and WMPI PTY, LLC noise standards (WMPI PTY,
LLC, e-mail to Robert L. Miller, ORNL, May 30, 2004). During maintenance
or repair events, workers would be required to wear hearing protection
equipment.

The proposed project site's highest sound level measurement was
documented at 55 dB(A) in March 2003 (Section 3.10). For comparison,
55 dB(A) is the approximate level of a quiet subdivision during daylight
hours. This level is also given by the EPA as a guideline upper limit
with an adequate margin of safety for protection from activity
interference and annoyance during the daytime in outdoor locations "in
which quiet is a basis for use" (EPA 1974).

To analyze the incremental noise effects resulting from the proposed
facilities, a doubling rule was used, which provides the most convenient
way to perform simple arithmetic functions involving logarithmic
measurements, such as dB measurements (MPCA 1999). The doubling rule
provides an accurate estimate of the effect of distance and multiple
sources on measured sound pressure levels. To estimate the highest sound
level during simultaneous operation of the Gilberton Power Plant and the
proposed facilities, the sound generated by the two facilities was
assumed to be equal. According to Goodfriend and Associates (1971),
power plant sound levels are similar due to comparable noise sources
such as induced- and forced-draft fans, turbine generators, and air
compressors. A doubling of sound energy yields an increase of 3 dB (MPCA
1999), indicating that the proposed site's highest sound level
measurement would be 58 dB(A). As a basis for evaluating an increase of
3 dB, a change in sound level of plus or minus 1 dB is not perceptible
to the human ear, a change in sound level of plus or minus 3 dB is the
threshold of perception to the human ear, and a change of plus or minus
5 dB is clearly noticeable to the human ear (MPCA 1999).

The center of the proposed main plant would be about 2,600 ft west of
the Mahanoy State Correctional Institution. The increase in noise levels
(i.e., 3 dB) would probably be imperceptible because of (1) the distance
between the prison and the proposed project site, (2) planned noise
attenuation measures, (3) natural and man-made terrain features and
structures, and (4) the limited period during which the inmates are
allowed outside the sealed prison. No perceptible change in noise
associated with the proposed facilities would be expected at the nearest
residence, located 3,600 ft southeast of the proposed main plant, or
other offsite locations.

## 4.2 POLLUTION PREVENTION AND MITIGATION MEASURES

Pollution prevention and mitigation measures have been incorporated by
WMPI as part of the design of the proposed project. The proposed
facilities' use of anthracite culm as feedstock would allow reclamation
of land currently stockpiled with culm and would provide a beneficial
use for the material at operating mines. Also, the quality of water
returned to the mine pool following use by the proposed facilities would
be improved. WMPI plans to sell the coarse slag and elemental sulfur as
byproducts to offsite customers. In addition, mitigation measures have
been developed to minimize potential environmental impacts. Table 4.2.1
lists the pollution prevention and mitigation measures that WMPI would
provide during the construction and operation of the proposed
facilities.

## 4.3 ENVIRONMENTAL IMPACTS OF NO ACTION 

Under the no-action alternative, DOE would not provide cost-shared
funding to demonstrate the commercial-scale integration of coal
gasification and F‑T synthesis technologies to produce electricity,
steam, and liquid fuels. At the site of the proposed project, it is
reasonably foreseeable that no new activity would occur (Section 2.2.1).
Thus, under the no-action alternative, no construction or operation of
the proposed facilities would occur. No site preparation would be
required, such as clearing of trees and other vegetation, site leveling,
and the construction of onsite roads, parking lots, fences, and
stormwater drainage areas. No employment would be provided for
construction workers in the area or for operators of the proposed
facilities. No resources would be required and no discharges or wastes
would occur. This scenario would not contribute toward the removal of
anthracite culm, which is stacked locally in numerous piles that were
set aside during previous mining of anthracite coal because of their
inadequate quality.

Current environmental conditions at the site would not change.
Specifically, air quality in the area would remain the same, and no
changes would occur to existing geologic and soil conditions in the
area. No changes would occur to the quantity and quality of surface
water and groundwater and the availability of water supplies in the
area. Ecological resources would remain the same. No changes would
result to the current management of solid and hazardous waste in the
proposed project area.

The adjacent Gilberton Power Plant would continue to operate without
change. Levels of resources used and emissions, effluents, and wastes
discharged would remain the same. The generation and beneficial reuse of
bottom ash and other byproducts from the existing plant would continue,
including the sale of bottom ash as an anti-skid material for roads and
as construction fill or aggregate.

+-------------+--------------------------------------------------------+
| **Table     |                                                        |
| 4.2.1.      |                                                        |
| Pollution   |                                                        |
| prevention  |                                                        |
| and         |                                                        |
| mitigation  |                                                        |
| measures**  |                                                        |
|             |                                                        |
| **developed |                                                        |
| for the     |                                                        |
| proposed    |                                                        |
| f           |                                                        |
| acilities** |                                                        |
+=============+========================================================+
| En          | Pollution prevention or mitigation measure             |
| vironmental |                                                        |
|             |                                                        |
| issue       |                                                        |
+-------------+--------------------------------------------------------+
| Atmospheric | During construction, water spray trucks would dampen   |
| resources   | exposed soil with water as necessary to minimize the   |
| and air     | occurrence of fugitive dust during construction        |
| quality     | activities.                                            |
|             |                                                        |
|             | During site preparation, cleared vegetation and        |
|             | non-hazardous construction waste would be burned. The  |
|             | fire chiefs of Mahanoy and/or West Mahanoy Townships   |
|             | would be notified prior to each occurrence. Open       |
|             | burning would not be conducted during drought          |
|             | conditions in which advisories have been issued by the |
|             | Pennsylvania Department of Environmental Protection.   |
|             |                                                        |
|             | During construction and operation, vehicles and        |
|             | machinery would be equipped with standard              |
|             | pollution-control devices to minimize emissions.       |
|             |                                                        |
|             | To reduce particulate emissions from handling and      |
|             | transfer of anthracite culm, petroleum coke, and       |
|             | limestone, the number of handling and transfer points  |
|             | would be minimized, the conveyors and material         |
|             | unloading points would be enclosed, and wetting        |
|             | systems and collection devices (e.g., baghouses) would |
|             | be installed.                                          |
|             |                                                        |
|             | A very high percentage of trace elements in the        |
|             | synthesis gas would be removed because the integrated  |
|             | technologies would require extensive cleaning of the   |
|             | synthesis gas using wet scrubbing followed by acid gas |
|             | removal using a Rectisol unit.                         |
|             |                                                        |
|             | Odorous emissions of hydrogen sulfide (H~2~S) should   |
|             | not be perceptible because H~2~S would be removed from |
|             | the shifted synthesis gas in the acid gas removal      |
|             | plant using a Rectisol unit and would be converted to  |
|             | marketable elemental sulfur in a Claus sulfur recovery |
|             | unit, a process which should remove approximately      |
|             | 99.99% of the sulfur from the gas stream. The gas      |
|             | stream exiting the Rectisol unit would be sent to a    |
|             | thermal oxidizer to destroy any trace contaminants     |
|             | prior to being released through a stack to the         |
|             | atmosphere.                                            |
|             |                                                        |
|             | Upon initial operation, conditions at Interstate 81    |
|             | would be monitored and flashing lights to warn         |
|             | motorists of fog would be installed, if warranted.     |
+-------------+--------------------------------------------------------+
| Geological  | The proposed facilities would increase the removal and |
| resources   | utilization of anthracite culm deposited on the        |
|             | landscape of the surrounding area, which would         |
|             | accelerate the ongoing process of restoring soil       |
|             | productivity and would help to reduce the potential    |
|             | for culm bank fires.                                   |
|             |                                                        |
|             | Product rundown lines would be designed to withstand   |
|             | flooding and earth slides. The potential risks of      |
|             | product line leakage due to gradual subsidence would   |
|             | be reduced by inspecting product lines regularly and   |
|             | repairing any problems.                                |
|             |                                                        |
|             | The potential for accidental releases from seismic     |
|             | activity would be reduced by incorporating seismic     |
|             | safety design features into the facilities.            |
+-------------+--------------------------------------------------------+

+-------------+--------------------------------------------------------+
| **Table     |                                                        |
| 4.2.1.      |                                                        |
| Continued** |                                                        |
+=============+========================================================+
| En          | Pollution prevention or mitigation measure             |
| vironmental |                                                        |
|             |                                                        |
| issue       |                                                        |
+-------------+--------------------------------------------------------+
| Water       | During construction, standard engineering practices    |
| resources   | such as silt fencing, straw bales, and revegetation of |
|             | graded areas would be implemented to control runoff,   |
|             | erosion, and sedimentation that could affect other     |
|             | watersheds.                                            |
|             |                                                        |
|             | Accidental spills of construction materials such as    |
|             | solvents, paint, caulk, oil, and grease that could     |
|             | contain hazardous substances would be cleaned up in a  |
|             | timely manner and in accordance with a Spill           |
|             | Prevention, Control, and Countermeasure Plan and Best  |
|             | Management Practices Plan, thus minimizing the         |
|             | potential for overland flow into streams.              |
|             |                                                        |
|             | The state of Pennsylvania would be able to reduce by   |
|             | approximately 38% its pumping of water from the        |
|             | Gilberton mine pool to Mahanoy Creek to control the    |
|             | mine pool elevation.                                   |
|             |                                                        |
|             | Discharge of treated effluent to the mine pool would   |
|             | be expected to reduce concentrations of acidity and    |
|             | dissolved metals in the mine pool, and thus also in    |
|             | the water pumped to Mahanoy Creek from the mine pool.  |
+-------------+--------------------------------------------------------+
|             | Development of the proposed facilities could affect    |
|             | groundwater availability by increasing the area of     |
|             | impervious surface, thus reducing groundwater recharge |
|             | to the aquifers on Broad Mountain. If the reduced      |
|             | recharge affected the availability of groundwater to   |
|             | the well serving the Gilberton Power Plant, the        |
|             | facilities' owners would address the situation by      |
|             | establishing a connection with one of the public water |
|             | suppliers.                                             |
|             |                                                        |
|             | Most potential impacts to groundwater quality on Broad |
|             | Mountain would be avoided by implementing standard     |
|             | engineering practices, including collection of         |
|             | potentially contaminated runoff and cleaning up        |
|             | accidental spills in a timely manner. The proposed     |
|             | septic system would be designed and operated in        |
|             | accordance with permitting requirements and would only |
|             | receive wastewaters similar to those generated by      |
|             | households.                                            |
+-------------+--------------------------------------------------------+
| Ecological  | Excavated areas surrounding the proposed facilities    |
| resources   | would be reseeded following construction, and          |
|             | compatible areas would be allowed to revert to         |
|             | forested conditions.                                   |
|             |                                                        |
|             | During reclamation of culm banks, the land surface     |
|             | would be graded to minimize erosion, and vegetation    |
|             | would be established. Over the long term, the          |
|             | terrestrial habitat created on reclaimed lands would   |
|             | offset the 76.5 acres of deciduous forest that would   |
|             | be cleared for the proposed facilities.                |
+-------------+--------------------------------------------------------+
| Traffic     | Additional construction- and operations-related        |
|             | traffic, which would affect traffic flow and safety on |
|             | State Route 61 and State Route 1008, could be          |
|             | mitigated by signaling, road widening, or scheduling   |
|             | work hours and/or deliveries to avoid periods of heavy |
|             | traffic.                                               |
+-------------+--------------------------------------------------------+

+-------------+--------------------------------------------------------+
| **Table     |                                                        |
| 4.2.1.      |                                                        |
| Continued** |                                                        |
+=============+========================================================+
| En          | Pollution prevention or mitigation measure             |
| vironmental |                                                        |
|             |                                                        |
| issue       |                                                        |
+-------------+--------------------------------------------------------+
| Waste       | Excess supplies of new materials would be returned to  |
| management  | vendors, retained by the facilities for future use, or |
| (solid)     | transferred in settlement with subcontractors (who     |
|             | could retain the items for use in future projects).    |
|             | Surplus paint and other consumables, partial spools of |
|             | electrical cable, and similar leftover materials would |
|             | also be retained for possible future use in            |
|             | maintenance, repairs, and modifications.               |
|             |                                                        |
|             | Metal scrap not suitable for future use in the         |
|             | facilities would be collected for resale to scrap      |
|             | dealers or recyclers.                                  |
|             |                                                        |
|             | The gasifier slag would be marketed for sale.          |
|             | Potential uses include lightweight construction        |
|             | aggregate, asphalt roofing shingle granules, blasting  |
|             | grit, and pipe bedding material. Any slag not used     |
|             | commercially would be used as fill material for mine   |
|             | reclamation. Compliance with 25 Pennsylvania Code      |
|             | Chapter 287 would minimize the potential for adverse   |
|             | impacts to water quality from beneficial reuse of slag |
|             | and other byproducts.                                  |
|             |                                                        |
|             | Some fine solid material could be captured and         |
|             | returned to the gasifier for energy recovery. The      |
|             | majority of the material would be placed on WMPI land  |
|             | that is permitted for disposal of coal byproducts as   |
|             | part of mine reclamation.                              |
|             |                                                        |
|             | Sludges from treatment of raw water and wastewater     |
|             | would be placed on WMPI land that is permitted for     |
|             | disposal of coal byproducts as part of mine            |
|             | reclamation.                                           |
|             |                                                        |
|             | Sulfurous compounds would be converted during          |
|             | processing to marketable elemental sulfur.             |
+-------------+--------------------------------------------------------+
|             | The proposed facilities' solid wastes and byproducts   |
|             | would not likely be hazardous as defined under RCRA.   |
|             | The EPA's Toxicity Characteristic Leaching Procedure   |
|             | test would be performed to verify this. Any wastes     |
|             | subject to RCRA hazardous waste regulations would be   |
|             | handled in accordance with standard procedures similar |
|             | to those currently employed at the Gilberton Power     |
|             | Plant.                                                 |
+-------------+--------------------------------------------------------+
| Waste       | Potential impacts from odor would be controlled by     |
| management  | treating all process wastewater within enclosed        |
| (liquid)    | facilities prior to discharge to the final             |
|             | equalization basin.                                    |
|             |                                                        |
|             | The potential for upsets in biological treatment units |
|             | could be minimized by designing the system with ample  |
|             | reserve capacity, selecting treatment units that are   |
|             | demonstrated to tolerate a wide range of wastewater    |
|             | characteristics, and controlling inflows to the        |
|             | treatment system to maintain consistent wastewater     |
|             | characteristics.                                       |
|             |                                                        |
|             | Potential for explosion in oil-water separation units  |
|             | could be minimized by using a nitrogen gas blanket     |
|             | over these units.                                      |
+-------------+--------------------------------------------------------+

+-------------+--------------------------------------------------------+
| **Table     |                                                        |
| 4.2.1.      |                                                        |
| Concluded** |                                                        |
+=============+========================================================+
| En          | Pollution prevention or mitigation measure             |
| vironmental |                                                        |
|             |                                                        |
| issue       |                                                        |
+-------------+--------------------------------------------------------+
| Worker      | During construction and operation, risks would be      |
| health and  | minimized by WMPI's adherence to procedures and        |
| safety      | policies required by OSHA and the state of             |
|             | Pennsylvania. These standards establish practices,     |
|             | chemical and physical exposure limits, and equipment   |
|             | specifications to preserve employee health and safety. |
+-------------+--------------------------------------------------------+
| Noise       | Employees and contractors would be responsible for     |
|             | ensuring that exhaust mufflers and engine enclosures   |
|             | are in place and in good working order for all         |
|             | industrial trucks and other pieces of                  |
|             | construction-related equipment.                        |
|             |                                                        |
|             | During operation, the principal sound sources (i.e.,   |
|             | combustion turbine/generator, steam turbine/generator, |
|             | heat recovery systems, turbine air inlets, exhaust     |
|             | stacks, cooling towers, pumps, and compressors) would  |
|             | be enclosed and acoustically insulated. Noise sources  |
|             | within the buildings would be fitted with              |
|             | sound-attenuating enclosures or other noise dampening  |
|             | measures that would meet all state and federal         |
|             | regulations.                                           |
|             |                                                        |
|             | During maintenance/repair events, workers would be     |
|             | required to wear hearing protection equipment.         |
+-------------+--------------------------------------------------------+

## 

[^1]: The SCREEN3 model was not used because it is limited to simulating
    atmospheric transport and dispersion of air emissions from a single
    source.