DOE/EA-1616 

CARBON RESEARCH CENTER PROJECT 

AT SOUTHERN COMPANY SERVICES’ 

POWER SYSTEMS DEVELOPMENT FACILITY 

NEAR WILSONVILLE, ALABAMA 

FINAL ENVIRONMENTAL ASSESSMENT 

 

 

U.S. DEPARTMENT OF ENERGY 

Office of Fossil Energy 

National Energy Technology Laboratory 

SEPTEMBER 2008 

COVER SHEET 

Responsible Agency: U.S. Department of Energy 

Title: Carbon Research Center Project, Draft Environmental Assessment (DOE/EA1616) 

Location: Southern Company Services’ Power Systems Development Facility near 

Wilsonville, Alabama 

Contact: 

For further information about this 

Environmental 

Assessment, contact: 

Roy Spears, Document Manager 

National Energy Technology Laboratory 

U.S. Department of Energy 

3610 Collins Ferry Road 

P.O. Box 880 

Morgantown, WV 26507-0880 

(304) 285-5460 or fax (304) 285-4403 

For general information on the 

Department of Energy’s process for 

implementing the National

Environmental Policy Act, contact: 

Carol Borgstrom, Director 

Office of NEPA Policy and Compliance 

(GC-20) 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585-0103 

(202) 586-4600 or leave message at 

(800) 472-2756 

Abstract: 

The United States Department of Energy, National Energy Technology Laboratory (DOE 

NETL) prepared this Environmental Assessment (EA) to analyze the potential 

environmental impacts of providing funding for the proposed Carbon Research Center 

(CRC) project to be located at the existing Power Systems Development Facility (PSDF) 

near Wilsonville, Alabama. The PSDF is owned and operated by Southern Company 

Services, Inc., a subsidiary of Southern Company an electric generation and transmission 

holding company. 

The CRC would be designed to test and evaluate carbon dioxide (CO2) control technologies 

for power generation facilities, including CO2 capture solvents, mass-transfer devices, lower 

cost water-gas shift reactors, scaled-up membrane technologies, and improved means of 

compressing CO2. Additionally, the CRC would evaluate methods to integrate CO2 capture 

technologies with other coal-based power plant systems by testing both pre-combustion and 

post-combustion technologies. The CRC would provide the capability to test these systems 
under a wide range of fuels, including bituminous and sub-bituminous coals, lignites and 

biomass/coal mixtures. The goal of the CRC project is to accelerate the development, 

optimization, and commercialization of viable CO2 control technologies. 

The proposed action currently being evaluated is for DOE to provide, through a 60-month 

cooperative agreement with Southern Company Services, Inc., financial assistance for the 

proposed development of the CRC Project at the PSDF plant. If approved, DOE would 

provide project assistance to test components and advanced power systems, including 

carbon (in the form of CO2) capture technology, under realistic conditions using coalderived gas streams. A small component of the CRC project would be located adjacent to 

the E.C. Gaston Electric Generating Plant. 

No major modifications to existing operational permits for the PSDF are anticipated to be 

required as a result of the implementation of the proposed action; however, some minor 

modifications may be needed. No previously undisturbed ground would be developed and 

no significant adverse impacts are anticipated to result from implementation of the action. 

The project would primarily involve the installation of new components on existing 

facilities in order to research and develop carbon capture technologies, and, the continued 

operation of the PSDF facility for a period of 5 years. 

Public Participation: 

DOE encourages public participation in the NEPA process. Comments were invited on 

the Draft EA for this project for a period of 30 days after publication of the Notice of 

Availability (NOA) in two local newspapers; The Birmingham News and the Shelby 

County Reporter (see Appendix C). The NOA was published for 3 consecutive days and 

1 week, respectively, beginning July 27, 2008. Copies of the Draft EA were available 

through the Harrison Regional Library System at select locations chosen by the regional 

library director and at the PSDF facility. The public was encouraged to submit written 

comments regarding the proposed project to DOE by the close of the comment period on 

August 27, 2008. As of September 5, 2008, no comments on the Draft EA were received 

and the EA was finalized. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Table of Contents i September 2008 

TABLE OF CONTENTS 

1.0 INTRODUCTION.............................................................................................. 1-1

1.1 Background...................................................................................................... 1-1 

1.2 Purpose and Need ............................................................................................ 1-4 

1.3 Scope of the EA ............................................................................................... 1-5 

1.3.1 Resource Topics Dismissed from Further Analysis................................. 1-5 

1.3.2 Compliance with Laws and Executive Orders......................................... 1-8

2.0 PROPOSED ACTION AND ALTERNATIVE ACTIONS ............................2-1

2.1 Alternative 1: Proposed Action........................................................................2-1 

2.2 Alternative 2: No Action Alternative............................................................... 2-8 

2.3 Alternatives Considered but Dismissed........................................................... 2-9

3.0 AFFECTED ENVIRONMENT ........................................................................ 3-1

3.1 Geology and Soils............................................................................................ 3-1 

3.2 Water Resources .............................................................................................. 3-2 

3.2.1 Surface Water........................................................................................... 3-2 

3.2.2 Groundwater ............................................................................................ 3-6 

3.2.3 Wetlands & Floodplains .......................................................................... 3-6 

3.3 Air Quality ....................................................................................................... 3-7 

3.3.1 National Ambient Air Quality Standards and Attainment Status ............ 3-7 

3.3.2 Class I and II Areas..................................................................................3-7 

3.3.3 Local Ambient Air Quality ...................................................................... 3-8 

3.3.4 Regional Emissions.................................................................................. 3-9 

3.3.5 Greenhouse Gasses and Global Warming................................................ 3-9 

3.4 Biological Resources ..................................................................................... 3-10 

3.4.1 Vegetation.............................................................................................. 3-10 

3.4.2 Wildlife .................................................................................................. 3-10 

3.4.3 Threatened & Endangered Species ........................................................3-10 

3.5 Waste and Hazardous Materials Management............................................... 3-11 

3.5.1 Waste Management................................................................................ 3-11 

3.5.2 Hazardous Materials Management ........................................................ 3-11 

3.6 Human Health and Safety .............................................................................. 3-12 

3.7 Cultural Resources......................................................................................... 3-13 

3.8 Socioeconomics ............................................................................................. 3-13

4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

AND ALTERNATIVES................................................................................................. 4-1

4.1 Geology and Soils............................................................................................4-1 

4.1.1 Alternative 1: Proposed Action................................................................4-1 

4.1.2 Alternative 2: No Action..........................................................................4-2 

4.2 Water Resources .............................................................................................. 4-2 

4.2.1 Alternative 1: Proposed Action................................................................4-2 

4.2.2 Alternative 2: No Action..........................................................................4-4 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Table of Contents ii September 2008 

4.3 Air Quality ....................................................................................................... 4-4 

4.3.1 Alternative 1: Proposed Action................................................................4-4 

4.3.2 Alternative 2: No Action..........................................................................4-8 

4.4 Biological Resources ....................................................................................... 4-8 

4.4.1 Alternative 1: Proposed Action................................................................4-8 

4.4.2 Alternative 2: No Action..........................................................................4-9 

4.5 Waste and Hazardous Materials Management................................................. 4-9 

4.5.1 Alternative 1: Proposed Action................................................................4-9 

4.5.2 Alternative 2: No Action........................................................................4-10 

4.6 Human Health and Safety .............................................................................. 4-11 

4.6.1 Alternative 1: Proposed Action..............................................................4-11 

4.6.2 Alternative 2: No Action........................................................................4-12 

4.7 Cultural Resources......................................................................................... 4-12 

4.7.1 Alternative 1: Proposed Action..............................................................4-12 

4.7.2 Alternative 2: No Action........................................................................4-12 

4.8 Socioeconomics ............................................................................................. 4-12 

4.8.1 Alternative 1: Proposed Action..............................................................4-13 

4.8.2 Alternative 2: No Action........................................................................4-13 

4.9 Cumulative Impacts ....................................................................................... 4-13 

4.10 Mitigation Measures ...................................................................................... 4-14

5.0 LIST OF PREPARERS ..................................................................................... 5-1

6.0 REFERENCES................................................................................................... 6-1

APPENDICES 

APPENDIX A AIR EMISSIONS CALCULATIONS

APPENDIX B AGENCY CORRESPONDENCE 

APPENDIX C NOTICE OF AVAILABILITY 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Table of Contents iii September 2008 

LIST OF FIGURES 

FIGURE 1-1: PROJECT VICINITY MAP ............................................................................ 1-2 

FIGURE 1-2: PSDF/PLANT GASTON SITE MAP .............................................................. 1-3 

FIGURE 2-1: PSDF PROCESS FLOW DIAGRAM .............................................................. 2-3 

FIGURE 2-2: PRE-COMBUSTION CO2CAPTURE DIAGRAM ........................................... 2-5 

FIGURE 2-3: POST-COMBUSTION CO2CAPTURE DIAGRAM ......................................... 2-7 

FIGURE 2-4: OXY-COMBUSTION CO2CAPTURE DIAGRAM .......................................... 2-8 

FIGURE 3-1: SOIL MAP OF PROJECT AREA .................................................................... 3-1 

FIGURE 3-2: EXISTING GROUNDCOVER AT PROPOSED PROJECT SITE (PHOTO) ..........3-2 

FIGURE 3-3: AQUATIC FEATURES OF PROJECT AREA ................................................... 3-3 

FIGURE 3-4: UNNAMED TRIBUTARY (PHOTO) ................................................................ 3-4 

FIGURE 3-5: DISCHARGE TO UNNAMED TRIBUTARY (PHOTO) ...................................... 3-5 

LIST OF TABLES 

TABLE 3-1: NAAQS AND AREA AIR QUALITY............................................................... 3-8

TABLE 3-2: REGIONAL AIR EMISSIONS .......................................................................... 3-9

TABLE 4-1: PROJECT EMISSIONS COMPARED TO APPLICABILITY THRESHOLDS.........4-5 

TABLE 4-2: ANNUAL EMISSIONS COMPARED TO REGIONAL EMISSIONS......................4-6 

TABLE 4-3: AIR QUALITY REGULATORY REVIEW......................................................... 4-7 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Table of Contents iv September 2008 

LIST OF ABBREVIATIONS/ACRONYMS

AAC Alabama Administrative Code 

ADEM Alabama Department of Environmental Management 

AQCR Air Quality Control Region 

AQCR 004 Metropolitan Birmingham Intrastate AQCR 

BACT Best Available Control Technology 

BMP Best Management Practice 

BOD Biochemical Oxygen Demand 

CAA Clean Air Act 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, Compensation, Liability Act 

CFR Code of Federal Regulations 

CH4 Methane 

CO Carbon Monoxide 

CO2 Carbon Dioxide 

CRC Carbon Research Center 

CWA Clean Water Act 

DBU Declaration of Beneficial Use 

DHS Department of Homeland Security 

DOE U.S. Department of Energy 

EA Environmental Assessment 

EIA Energy Information Administration 

EO Executive Order 

EPRI Electric Power Research Institute 

ESA Endangered Species Act 

ESP Electrostatic Precipitator 

FGD Flue Gas Desulfurization 

FONSI Finding of No Significant Impact 

FY Fiscal Year 

GCR General Conformity Rules 

GHG Greenhouse Gas 

gpd gallons per day 

ha Hectare 

HAPS Hazardous Air Pollutants 

HAZMAT Hazardous Material 

HFCs Hydrofluorocarbons 

ID Induced Draft 

IGCC Integrated Gasification Combined Cycle 

kV Kilovolts 

KVA Kilovolt-Amperes or Kilovolt-Amps

MACT Maximum Achievable Control Technology 

MGD million gallons per day 

msl mean sea level 

MSW Municipal Solid Waste 

MW Megawatt 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Table of Contents v September 2008 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NETL National Energy Technology Laboratory 

NHPA National Historic Preservation Act 

NNSR Nonattainment New Source Review 

N2O Nitrous Oxide 

NO2 Nitrogen Dioxide 

NOx Nitrogen Oxides 

NOA Notice of Availability 

NPDES National Pollutant Discharge Elimination System 

NRCS Natural Resource Conservation Service 

NSPS New Source Performance Standards 

NSR New Source Review 

O3 Ozone 

OSHA Occupational Safety and Health Administration 

PFCs Perfluorocarbons 

PM Particulate Matter 

PM10 Particulate Matter < 10 microns in diameter 

PM2.5 Particulate Matter < 2.5 microns in diameter 

POL Petroleum, Oils and Lubricants 

PPA Pollution Prevention Act 

pph pounds per hour 

ppm parts per million 

PSD Prevention of Significant Deterioration 

PSDF Power Systems Development Facility 

RCRA Resource Conservation Recovery Act 

R&D Research and Development 

sf square foot 

SF6 Sulfur Hexafluoride 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

SPCC Spill Prevention Control and Countermeasures Plan 

SWPPP Storm Water Pollution Prevention Plan 

TMDL Total Maximum Daily Load 

tpy tons per year 

μm micrometer 

μg/m3 micrograms per meter cubed 

UNFCC United Nations Framework Convention on Climate Change 

USACE U.S. Army Corps of Engineers 

USDA U.S. Department of Agriculture 

USEPA U.S. Environmental Protection Agency 

VOC Volatile Organic Compound 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Introduction 1-1 September 2008 

1.0 INTRODUCTION 

The United States Department of Energy, National Energy Technology Laboratory (DOE 

NETL) prepared this Environmental Assessment (EA) to analyze the potential environmental 

impacts of providing funding for the proposed Carbon Research Center (CRC) project to be 

located at the existing Power Systems Development Facility (PSDF) near Wilsonville, 

Alabama. The PSDF is operated by Southern Company Services, Inc., a wholly-owned 

subsidiary of Southern Company, an electric generation and transmission company. 

The CRC would be designed to test and evaluate Carbon Dioxide (CO2) control technologies 

for power generation facilities, including CO2 capture solvents, mass-transfer devices, lower 

cost water-gas shift reactors, scaled-up membrane technologies, and improved means of 

compressing CO2. Additionally, the CRC would evaluate means to integrate CO2 capture 

technologies with other coal-based power plant systems by testing both pre-combustion and 

post-combustion technologies. The CRC would provide the capability to test these systems 

under a wide range of fuels, including bituminous, sub-bituminous coals, lignites and 

biomass/coal mixtures. The goal of the CRC project is to accelerate the development, 

optimization, and commercialization of viable CO2 control technologies. 

1.1 BACKGROUND

The PSDF is located on 16.6 acres of land, located 1.5 miles northeast of the town of 

Wilsonville in Shelby County, Alabama. The PSDF property is located within a utility 

plant site, Alabama Power Company’s E.C. Gaston Generating Plant (Plant Gaston). 

The PSDF is a facility designed and built to evaluate advanced coal-based power 

technologies at a scale large enough to provide meaningful data for scale-up and under 

conditions that adequately represent temperature, pressure, and contaminant conditions of 

a commercial embodiment. The PSDF is operated by Southern Company as a unique 

Research and Development (R&D) test facility under partial funding from DOE, on 

behalf of several industrial partners such as Electric Power Research Institute (EPRI), 

KBR, Inc., Lignite Energy Council, and Peabody Energy. The PSDF project was initiated 

September 14, 1990. Upon completion of construction and commissioning, the first coalfired operations began in August 1996. The current funded Cooperative Agreement is 

currently set to expire on September 30, 2008. However, research and development 

efforts at the PSDF, in the form of the CRC, are proposed for another 5-year period. 

The initial EA for the development, construction, and operation of the PSDF was issued 

with a Finding of No Significant Impact (FONSI) in 1993. The proposed action currently 

being evaluated is for DOE to provide, through a 60-month cooperative agreement with 

Southern Company Services, Inc., 80% of the cost share (an estimated total of 

$201,163,318) for the proposed development of the CRC Project at the PSDF plant. If 

approved, DOE would provide project assistance to test components and advanced power 

systems, including carbon (in the form of CO2) capture technology, under realistic 

conditions using coal-derived gas streams. A small component of the CRC project would 

be located at the adjacent E.C. Gaston Generating Plant (see Figures 1-1 and 1-2). 
U.S. Department of Energy Carb

National Energy Technology Laboratory Introduction 1-2 

Figure 1-1. Project Vicinity Map 
U.S. Department of Energy Carb

National Energy Technology Laboratory Introduction 1-3 

Figure 1-2. PSDF/Plant Gaston Site Map 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Introduction 1-4 September 2008 

No major modifications to existing operational permits for the PSDF are anticipated to be 

required as a result of the implementation of the proposed action. No previously 

undisturbed ground would be developed. The project would primarily involve the 

continued operation of the PSDF facility for a period of 5 years, while new components 

and carbon capture technologies are installed, tested, and further developed. 

1.2 PURPOSE AND NEED

The proposed agency action, providing funding to help establish the CRC at the PSDF 

near Wilsonville, Alabama, serves the purpose of accelerating the development, 

optimization, and commercialization of viable CO2 control technologies for coal-based 

power generation facilities. The proposed action would continue R&D activities at the 

PSDF for a period of 5 years. 

The need for the project is for DOE NETL to carry out research, development, and 

demonstration programs to resolve the environmental, supply, and reliability constraints 

of producing and using fossil resources, and, to develop efficient and effective CO2

capture systems, which is one of the fundamental goals of NETL’s Carbon Sequestration 

Program (DOE, 2008; DOE, 2007). 

NETL is a DOE national laboratory which devotes the majority of its funding to R&D 

partnerships with industry, university, and other government entities. NETL is committed 

to addressing the challenges put forth by the National Energy Policy, which include 

enhancing America’s energy security; improving the environmental acceptability of 

energy production and use; increasing the competitiveness and reliability of U.S. energy 

systems; and ensuring a robust U.S. energy future (DOE, 2008). 

The demand for electric power in the U.S. and around the world shows continued, steady 

growth. According to DOE’s Energy Information Administration (EIA) Annual Energy 

Outlook, the coal share of total electricity generation in the U.S. remains between 48 

percent and 49 percent from 2006 through 2018 before increasing to 54 percent in 2030 

(EIA, 2008). Both the U.S. and world economies are linked to an abundant, reliable and 

cost-effective supply of electricity. While efforts are being expanded to manage the pace 

of electricity demand growth by energy efficiency and conservation programs, it is clear 

that new sources of electricity generation will be needed. While nuclear, natural gas and 

renewable sources of generation will be utilized going forward, the size of the U.S. 

demand for low-cost electricity will mandate continued and expanded use of domestic 

coal-based power generation. 

Of concern to many, however, about the use of coal is its environmental impact, 

including the amount of carbon dioxide, CO2, emitted per unit of power generation. 

Many link CO2 emissions to concerns over global climate change. Because of the 

growing concentration of CO2 in the atmosphere, there is a growing sense of urgency to 

legislate restrictions on the emissions of CO2. However, cost-effective technologies to 

enable coal use with reduced emissions of CO2 are not commercially viable or available. 

To keep coal in the U.S. generation mix, significant advancements in CO2 capture 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Introduction 1-5 September 2008 

technologies from coal-based power generation are needed. The proposed action aims to 

develop cost-effective CO2 capture technologies that are integrated with coal-based 

electricity generation and to demonstrate reliable operations of the integrated system. 

1.3 SCOPE OF THE EA 

This DOE EA analyzes the environmental impacts that would result from the Proposed 

Action and the No Action alternative. This EA was prepared in compliance with the 

National Environmental Policy Act of 1969 (P.L. 91-190), the Council of Environmental 

Quality Regulations dated 28 November 1978 (40 CFR Parts 1500-1508), and the DOE 

NEPA Implementing Procedures (10 CFR Part 1021). 

Key goals of NEPA are to help Federal agency officials make well-informed decisions 

about agency actions and to provide a role for the general public in the decision-making 

process. The study and documentation mechanisms associated with NEPA seek to 

provide decision-makers with sound knowledge of the comparative environmental 

consequences of the several courses of action available to them. NEPA studies, and the 

documents recording their results, such as this EA, focus on providing input to the 

particular decisions faced by the relevant officials. 

This EA identifies, describes, and evaluates the potential environmental impacts that 

would result from the implementation of the proposed action and the no action 

alternative, taking into consideration possible cumulative impacts from other actions. As 

appropriate, the affected environment and environmental consequences of the action will 

be described in both site-specific and regional contexts. In instances where mitigation 

measures may lessen any potentially adverse impacts, this EA identifies such measures 

that should be implemented to further minimize environmental impacts. 

The following resource areas have been identified for study within this EA: soil and 

geology, water resources (including groundwater, wetlands, and floodplains), air quality, 

biological resources (including threatened and endangered species), waste and hazardous 

materials management, human health and safety, cultural resources, and socioeconomics. 

Resource areas considered but dismissed for further analysis are discussed below. 

1.3.1 Resource Topics Dismissed from Further Analysis 

Several resource topics and issues were raised during internal DOE scoping for this 

project that were not considered to warrant detailed analysis in this EA because they 

were: 1) outside the scope of the Proposed Action; 2) already decided by law, regulation, 

or other higher level decisions; 3) irrelevant to the decision to be made; or 4) conjectural 

and not supported by scientific or factual evidence. The rationale for eliminating these 

issues is provided in the descriptions below. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Introduction 1-6 September 2008 

Wild and Scenic Rivers

The National Wild and Scenic Rivers Act is administered by four federal agencies; the 

Bureau of Land Management, the National Park Service, the U.S. Fish and Wildlife 

Service, and the U.S. Forest Service. The Act protects selected rivers, and their 

immediate environments, which possess outstandingly remarkable scenic, recreational, 

geologic, fish and wildlife, historic, cultural or other similar values. In the State of 

Alabama, there is only one National Wild and Scenic River, the Sipsey Fork of the Black 

Warrior River. The Black Warrior River is a tributary of the Tombigbee River in west 

central Alabama. 

The Sipsey Fork of the Black Warrior River originates at the confluence of Thompson 

and Hubbard creeks in southwestern Lawrence County. The Sipsey Fork flows in a south 

southeasterly direction until impacted by the impounded waters of Lewis-Smith 

Reservoir. The section of the tributary which is a designated wild and scenic river lies 

completely within the boundaries of the William B. Bankhead National Forest, 

approximately 50 miles northwest of Birmingham (ADCNR, 2008). The Sipsey Fork of 

the Black Warrior River and its watershed will not be affected by the proposed project in 

any way. Therefore, this topic is dismissed from further analysis. 

Land Use 

The PSDF occupies just over 16 acres of land within the Plant Gaston utility site. The 

land surrounding the site is primarily rural, with a few scattered residences within a half 

mile of the site line near Highway 25. The predominant land use in the vicinity of the 

property is forest and agricultural (timber, peach, and cotton production), although there 

are several industries located within the county. About 2.2 acres of the site are within the 

city limits of Wilsonville. 

Six acres of the PSDF are currently used for the process test facility and support 

structures; 3 acres are used for the covered coal and limestone storage piles and the 

sedimentation basin; and the remaining acres are used for parking lots, office space, a 

warehouse, and laydown areas. The Proposed Action would involve the installation of 

two concrete pads (one is estimated to measure 20’ x 40’, and the other is estimated to 

measure 30’ x 15’) within the process test facility and support structure area of the PSDF 

site. Project activities at Plant Gaston would take place entirely within the plant site, and 

would consist of the installation of new foundations on an approximately 50’ x 150’ area 

and the utilization of an additional 50’ x 50’ area for infrastructure and support systems. 

The Proposed Action consists of a relatively small footprint of new site development at 

previously disturbed areas, which are already designated and actively used for industrial 

operations. No onsite land use changes would result from implementation of the 

Proposed Action. Additionally, no changes to vicinity land use or land use designations 

would occur. Therefore, this topic is dismissed from further analysis. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Introduction 1-7 September 2008 

If the PSDF is at any point slated for decommissioning, it is expected that a 

Decontamination, Demolition, and Disposal (DD&D) Plan with a detailed description of 

the proposed decontamination, demolition, and disposal of both the pre-combustion and 

post-combustion facility, and, determinations of future land uses of the property will be 

developed in concert with NETL participation and approval. However, facility 

decommissioning and possible future land use are not within the scope of this EA. 

Traffic and Transportation 

Alabama Highway 25 provides principle access to the PSDF and Plant Gaston site, and 

the PSDF shares an existing access road off of Highway 25 to Plant Gaston. Additionally, 

a railroad which services Plant Gaston bisects the property. Under the Proposed Action, 

the PSDF and Plant Gaston are anticipated to receive the same amount of traffic as they 

are currently experiencing. No additional impacts to either traffic or transportation are 

anticipated to result. Therefore, this impact topic is dismissed from further analysis. 

Noise 

Noise is generally defined as unwanted sound. Noise can influence humans or wildlife by 

interfering with normal activities or diminishing the quality of the environment. Noise 

levels heard by humans are dependent on several variables, including distance, ground 

cover, and objects or barriers between the source and the receiver, as well as atmospheric 

conditions. Certain land uses, facilities, and the people associated with these noise levels 

are more sensitive to a given level of noise than other uses. Such “sensitive receptors” 

include schools, churches, hospitals, retirement homes, campgrounds, wilderness areas, 

hiking trails, and some species of threatened or endangered wildlife. The closest sensitive 

receptor to the project site is the Wilsonville Elementary School, located approximately 2 

miles southwest of the site. 

Neither construction nor operation activities associated with the Proposed Action are 

anticipated to be audible offsite of the Plant Gaston property. Noise associated with the 

proposed CRC would contribute only an incremental amount to the cumulative noise 

generated from Plant Gaston. Onsite impacts of noise during construction should be 

minimized by limiting construction activity to primarily daylight business hours and by 

using properly maintained and muffled equipment. Hearing protection equipment would 

be required for workers when sound levels that exceed Federal workplace standards. 

Provided the preceding steps are taken, no impacts from noise are anticipated from the 

proposed project, and this topic is therefore dismissed from further analysis. 

Environmental Justice 

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low Income Populations, requires all federal agencies to identify and 

address disproportionately high and adverse human health or environmental effects of 

their programs and policies on minorities and low-income populations and communities. 

Although the nearest residential areas to the PSDF include some levels of both low-
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Introduction 1-8 September 2008 

income and high-minority populations, these levels are not disproportionately high and 

the Proposed Action is not anticipated to impact these areas in any event due to the 

distance of the proposed facilities, the high dispersion rate of air emissions in the area, 

and the low level of changes to the socioeconomic environment of the area anticipated 

from this project. Therefore, this topic is dismissed from further analysis. 

Recreation 

The project area is contained entirely within a secured utility plant site; there is no public 

access to, or use of, the natural resources located on site. The closest designated outdoor 

recreation area, the Talladega National Forest, is located over 30 miles east of the site. 

The Proposed Action would not result in any impacts to public or recreational uses of the 

land. Furthermore, the offsite impacts of the Proposed Action (e.g. surface water 

withdrawals and discharges, and air emissions from facilities operations) are not 

anticipated to have any impact on recreation activities offsite of the proposed project 

area. Because the proposed project would not appreciably diminish recreation 

opportunities or the quality of recreation activities in the vicinity of the project area, this 

topic is dismissed from further analysis. 

1.3.2 Compliance with Laws and Executive Orders 

This project complies with the NEPA, CEQ regulations (40 CFR Parts 1500-1508), and 

DOE regulations for compliance with NEPA (10 CFR Part 1021). The EA also addresses 

all applicable laws and regulations, including but not limited to the following: 

• National Historic Preservation Act (NHPA), 

• Archeological Resources Protection Act (ARPA), 

• The Noise Control Act of 1972, as amended, 

• Addressing Environmental Justice (EO 12898) 

• Clean Air Act (CAA), 

• Clean Water Act (CWA), 

• Coastal Zone Management Act, 

• Protection of Wetlands (EO 11990), 

• Floodplain Management (EO 11988), 

• Endangered Species Act (ESA), 

• Pollution Prevention Act (PPA), 

• Resource Conservation and Recovery Act (RCRA), and 

• Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). 

Implementation of the Proposed Action will help the DOE meet the goals and challenges 

put forth by the National Energy Policy, enacted by the Energy Policy Act, as amended. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-1 September 2008 

2.0 PROPOSED ACTION AND ALTERNATIVE ACTIONS 

2.1 ALTERNATIVE 1: PROPOSED ACTION – IMPLEMENTATION OF THE CARBON 

RESEARCH CENTER AT PSDF 

The Proposed Action, providing funding for the implementation and operation of the 

Carbon Research Center (CRC) at the PSDF, is consistent with DOE’s goal to reduce 

CO2 emissions from coal-fueled power plants. The CRC would be designed to test and 

evaluate CO2 control technologies, including CO2 capture solvents, mass-transfer 

devices, lower cost water-gas shift reactors, scaled-up membrane technologies, and 

improved means of compressing CO2. The CRC would also evaluate means to integrate 

CO2 capture technologies with other coal-based power plant systems by testing both precombustion and post-combustion technologies. The CRC would provide the capability to 

test these systems under a wide range of fuels, including bituminous and sub-bituminous 

coals, lignites and biomass/coal mixtures. The goal of the CRC project is to accelerate the 

development, optimization, and commercialization of CO2 control technologies. 

The DOE funding provided would be 80% of total project cost, or $201,163,318 of the 

projected total 5 year project cost of $251,454,148. Southern Company and its industry 

partners, primarily EPRI, KBR, Inc., Lignite Energy Council, Luminant, and Arch Coal, 

Inc., would provide the remaining 20% project cost. 

Background 

 

The Proposed Action is consistent with the objectives of DOE and NETL to provide 

lower cost, reliable electricity while decreasing environmental emissions, including 

carbon dioxide, from coal-fired power generating plants. Coal, a readily available 

domestic fuel, currently accounts for approximately half of the electricity generated in the 

United States, and is projected by most analyses to remain the backbone of U.S. 

electricity supply through 2050 and beyond. However, sustaining coal as a viable option 

in light of possible future restrictions on carbon emissions entails increasing the 

efficiency and reducing the capital cost of coal utilization, and bringing CO2 carbon 

capture and storage to the point of cost-effective commercialization. By establishing the 

CRC at the PSDF and increasing efforts to make the facility available for third-party test 

and evaluation, the proposed program has high potential to significantly aid in shortening 

the timeline from concept to demonstration for carbon control technologies. 

An integrated carbon capture design for advanced power systems is in its infancy, having 

never been put into practice for coal-fired power generation, and is considered a high risk 

endeavor for the power industry. Commercially available non-integrated technologies 

(designed and built for other industries) would dramatically and unacceptably lower 

overall plant efficiency, while adding cost and complexity to the coal-fired plant. 

Although the DOE has sponsored alternative CO2 capture technologies in the recent past, 

the R&D has been mostly limited to laboratory- or bench-scale evaluations under ideal 

conditions. Continued research and development is needed to validate these lab-scale 

efforts by testing and evaluating the promising alternative technologies under field 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-2 September 2008 

conditions that would be expected in a working plant. Specifically, large-scale testing 

and evaluation is needed to verify that technology commercialization is feasible. The 

establishment of the CRC at the PSDF will help to fill the existing gap between the 

successful small-scale R&D and the commercial applications. 

The CRC is proposing a broad array of technology development activities, including precombustion CO2 capture for Integrated Gasification Combined Cycle (IGCC) plants, 

post-combustion CO2 capture for Pulverized Coal (PC) plants; and, emerging 

technologies such as oxy-combustion of CO2. These R&D activities would support a 

pathway to a cost-effective advanced coal-generating plant with CO2 capture. The 

flexibility and scale of the proposed CRC would be well suited to test gas cleanup and 

CO2 capture technologies. The CRC could test multiple projects in parallel with a wide 

range of test equipment sizes leading up to pre-commercial equipment sufficient to guide 

the design of full commercial scale power plants. The CRC would support the 

development of cost-effective CO2 capture technologies for advanced coal-fueled power 

plants as well as existing and new pulverized coal power plants. 

PSDF 

The PSDF is located on 16.6 acres of land, northeast of the town of Wilsonville in Shelby 

County, Alabama. The PSDF property is located within the Plant Gaston utility plant site. 

The PSDF can be used to screen research projects, perform pilot testing, and conduct 

testing at pre-commercial scale in an industrial setting. The PSDF is operated by 

Southern Company Services on behalf of industrial partners under funding from DOE, as 

a unique R&D test facility. The facility is large enough to produce commercially 

representative data while remaining sufficiently small for economic operation as a test 

facility. The effectiveness of the PSDF has been established. It has already fulfilled a 

major DOE objective by accelerating development of the Transport Gasifier to the 

demonstration phase. 

The PSDF provides an engineering-scale testing facility for key components of an IGCC 

power plant. IGCC plants are so called because they use synthetic gas which is produced 

in a gasification unit in the plant. The gasification process produces heat, and this heat is 

reclaimed by steam boilers. The PSDF is adaptable to a variety of technology research 

needs. The components being tested are integrated into the plant, which exposes them to 

the requirements and rigors of real plant operating conditions and allows them to be 

scaled-up with confidence for commercial demonstration. Integrated operations allow 

the effects of system interactions to be understood. These interactions can typically be 

missed in unintegrated testing. In addition to engineering-scale testing, the PSDF has 

slipstream testing capability over a wide range of flowrates for cost-effective technology 

screening (see Figure 2-1). The PSDF operates approximately 2,200 hours per year in 3 

or 4 distinct cycles of research (each cycle lasts an average of 550 hours, equivalent to 23 

days). Each operation cycle burns approximately 1,000 tons of various types of coal. 
U.S. Department of Energy Carbo

National Energy Technology Laboratory Proposed Action and Alternatives 2-3 

Figure 2-1. PSDF Process Flow Diagram 

(Source: Southern Company, 2007)
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-4 September 2008 

The PSDF project was initiated September 14, 1990. Upon completion of construction 

and commissioning, the first coal-fired operations began in August 1996. The current 

funded Cooperative Agreement is currently set to expire on September 30, 2008. 

However, research and development efforts at the PSDF, in the form of the CRC, are 

proposed for another 5-year period. The initial EA for the development, construction, and 

operation of the PSDF was issued with a Finding of No Significant Impact (FONSI) in 

1993. The proposed action currently being evaluated is for DOE to provide, through a 60-

month cooperative agreement with Southern Company Services, Inc., financial assistance 

for the proposed development of the CRC Project at the PSDF plant. If approved, DOE 

would provide project assistance to test components and advanced power systems, 

including carbon (in the form of CO2) capture technology, under realistic conditions 

using coal-derived gas streams. A small component of the CRC project, the postcombustion CO2 capture component, would be located at Plant Gaston. 

No major modifications to existing operational permits for either the PSDF or Plant 

Gaston are anticipated to be required as a result of the implementation of the proposed 

action. However, some minor permit modifications may be required. No previously 

undisturbed ground would be developed. The project would primarily involve the 

continued operation of the PSDF facility for a period of 5 years, with the installation of 

new components on existing facilities in order to research and develop carbon capture 

technologies. 

The R&D conducted at the CRC as the Proposed Action would consist of the following 

three components: 

• Pre-combustion CO2 capture for IGCC plants; 

• Post-combustion CO2 capture for PC plants; and, 

• Emerging technologies such as oxy-combustion of CO2.

Pre-combustion CO2 Capture 

Pre-combustion CO2 capture relates to coal gasification plants, where fuel is converted 

into gaseous components by applying heat under pressure in the presence of steam. In a 

gasification reactor, the amount of air or oxygen available inside the gasifier is carefully 

controlled so that only a portion of the fuel burns completely. This “partial oxidation” 

process provides the heat necessary to chemically decompose the fuel and produce 

synthesis gas (syngas), which is composed of hydrogen, carbon monoxide (CO) and 

minor amounts of other gaseous constituents. The syngas is then processed in a watergas-shift reactor, which converts the CO to CO2 and increases the CO2 and H2 mole 

concentrations to 40 percent and 55 percent, respectively, in the syngas stream. At this 

point, the CO2 has a high partial pressure (and high chemical potential), which improves 

the driving force for various types of separation and capture technologies. After CO2

removal, the H2 rich syngas can be converted to electrical or thermal power. One 

application is to use H2 as a fuel in a combustion turbine to generate electricity. 

Additional electricity is generated by extracting the energy from the combustion turbine 

flue gas via a heat recovery steam generator. Figure 2-2 shows the research pathways 

being pursued for pre-combustion CO2 capture. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-5 September 2008 

Figure 2-2. Pre-Combustion CO2 Capture Diagram 

(Source: DOE, 2007) 

The backbone of the CRC pre-combustion CO2 capture technology development will be a 

high-pressure, flexible facility designed to test an array of solvents and contactors in a 

CO2 capture test facility. New construction to accommodate the facility at the PSDF will 

chiefly consist of two new concrete pads on the existing PSDF site. The primary area of 

construction would be immediately north of the existing facility on previously disturbed 

land to accommodate Water Gas Shift equipment, a new compressor, and a Gas Analyzer 

Building. This area is shown in Figure 3-2. The pad for the Water Gas Shift and 

compressor is projected to be 20’ x 40’ (800 ft2

), with approximately 2 ft. depth for 

construction. The pad for the Gas Analyzer Building is projected to be 30’ x 15’ (450 ft2

), 

with approximately 8” depth for construction. 

The second area of disturbance at the PSDF would be previously disturbed land on the 

north side of the PSDF process structure, where an existing 20’ x 35’ pad would be 

modified to accommodate tanks and pumps for solvent storage, with approximately 2 ft. 

depth for construction. The duration of construction of the new pads required would be 

approximately 2-3 weeks each. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-6 September 2008 

Slipstreams would be available with a range of gas flow rates and process conditions 

using actual syngas or flue gas for verifying and scale-up of fundamental R&D capture 

projects. To support the CO2 capture test facility, development of water-gas shift is 

necessary. Current technology for water-gas shift using fixed beds of catalyst with high 

steam requirements is capital intensive with high operating costs. Several options are 

being considered to reduce costs; combining water-gas shift operation in the particulate 

filtration process and two improved contactor devices. 

To gather information on the cost effectiveness of the tested technologies, all process 

blocks within the PSDF plant must be optimized in addition to the capture block. Including 

CO2 capture in an advanced coal power plant will increase the plant cost of electricity, so 

opportunities to reduce cost in every part of the process will be explored. Although highest 

priority will be given to low-cost CO2 capture process development, projects that reduce 

overall process capital cost and the cost of electricity will also be included in the CRC test 

plan to partially offset incremental cost increases due to the addition of CO2 capture. These 

cost reduction projects include technology development for syngas cleanup, particulate 

control, fuel cells, sensors and controls, materials, and feeders.

Post-Combustion CO2 Capture 

Post-combustion CO2 capture is primarily applicable to conventional coal-fired power 

generation, but may also be applied to gas-fired generation using combustion turbines. 

Any CO2 emissions reduction plan for coal-fueled power generating plants must include 

post-combustion capture from pulverized coal plants due to their predominance in the 

generation mix now and in the near future. For both new and existing power plants, postcombustion capture technology must be made more efficient and cost-effective by 

developing alternative solvents with lower heats of regeneration and more compact, 

lower cost equipment. 

In a typical coal-fired power generation system, fuel is burned with air in a boiler to 

produce steam; the steam drives a turbine to generate electricity, as shown in Figure 2-3. 

The boiler exhaust, or flue gas, consists mostly of nitrogen (N2) and CO2. Separating CO2

from this flue gas stream is challenging for several reasons, including the dilute 

concentrations and low pressure that CO2 is present at in the gas stream, and the presence 

of trace impurities in the flue gas which can degrade sorbents and reduce the 

effectiveness of certain CO2 capture processes. 

Absorption processes based on chemical solvents such as amines have been developed 

and deployed commercially in certain industries. To date, however, their use in PC power 

plants has been restricted to slipstream applications, and no definitive analysis exists as to 

the actual costs for a full-scale capture plant. Preliminary analysis conducted at NETL 

indicates that CO2 capture via amine scrubbing and compression to 2,200 psia could raise 

the cost of electricity from a new supercritical PC power plant by 65 percent, from 5.0 

cents/kilowatt-hour (kWh) to 8.25 cents/kWh. Some amines that may be used at PSDFCRC for CO2 capture testing include Mono ethanol amine (MEA), Methyl diethanol 

amine (MDEA), and proprietary hindered amines (chemical compounds containing an 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-7 September 2008 

amine functional group surrounded by a crowded steric environment). However, most 

solvents have not yet been identified, but will be selected as research progresses and 

suppliers develop suitable solvents. 

Figure 2-3. Post-Combustion CO2 Capture Diagram 

(Source: DOE, 2007) 

Post-combustion CO2 capture as part of the CRC will be studied at Alabama Power’s Plant 

Gaston Unit 5, as Plant Gaston is a conventional pulverized coal fired plant. Unit 5 is a 

Combustion Engineering designed, 880 MW Tangentially fired boiler equipped with 

Selective Catalytic Reduction to reduce NOx emissions, Hot ESP for Particulate Matter 

collection, and a Chiyoda Thoroughbred 121 (CT-121) Limestone Forced Oxidation FGD 

system for SO2 control. The post-combustion CO2 capture R&D efforts as part of the 

Proposed Action will be designed to support the evaluation of advanced solvents, processes 

and concepts, advanced solid sorbents, and membrane based processes, both at bench scale 

and with the potential for scale up to ~1-2 MWe equivalent. The CRC will work with 

NETL, EPRI, vendors, technology developers, and national labs to identify new solvents, 

sorbents, membranes, gas contactors, and other processes and equipment that may prove 

beneficial and support the overall goal of the CRC. 

To capture CO2 from the flue gas at Plant Gaston, two larger trains (1-MW capacity each) 

and 5 smaller trains (about 1-MW capacity total for all five) would be installed adjacent 

to Unit 5 of the plant in a previously developed area, identified in Figure 1-2. Land 

disturbance at Plant Gaston would consist of the installation of new concrete foundations 

on an approximately 50’ x 150’ area (7,500 ft2

), and the utilization of an additional 50’ x 

50’ area (2,500 ft2) for infrastructure and support systems. These areas would be located 

to the West of the existing Unit 5 ID fan yard and to the South and East of the new Unit 5 

FGD stack. Foundation depths would be approximately 50 ft and would include a 

combination of pilings, casings, and area pads. The duration of construction of the new 

pads would be approximately 2-3 weeks each. The total potential operating capacity of 

proposed post-combustion pilot project is limited to about 2-MW equivalent, due to 

operating and infrastructure costs. This project could be operated for extensive periods to 

fully characterize performance on real coal fired flue gas. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-8 September 2008 

Oxy-Combustion of CO2 

The objective of oxygen-fired combustion is to combust coal in an enriched oxygen 

environment using pure oxygen diluted with recycled CO2 or H2O (Figure 2-4). The 

oxygen in the mixture will be largely consumed during the combustion reactions. Under 

these conditions, the primary products of combustion are CO2 and H2O, and the CO2 can 

be captured by condensing the water in the exhaust stream. 

Figure 2-4. Oxy-Combustion CO2 Capture Diagram 

(Source: DOE, 2007) 

Operating the Transport Combustor as a pressurized, circulating fluid bed combustor may 

provide a useful alternative to current oxy-combustion testing. The current testing 

programs for O2-blown coal combustion rely on CO2 recycle to control the combustor 

temperature. Operations and Maintenance costs for the recycle compressors are high, 

because the required recycle CO2 flowrate is very high, essentially the same as the rate of 

N2 in the air-blown combustion process. Temperature control by circulating solids for a 

Transport Combustor is simple and proven and will greatly reduce the amount of CO2 to 

be recycled resulting in cost savings. The CRC test plan includes system modeling and 

economic analysis to evaluate the commercial feasibility of operating the Transport 

Combustor in oxy-combustion mode. If modeling results are positive, an engineering 

study will be conducted to determine the cost of modifying the Transport Combustor to 

operate in the oxy-combustion mode. Oxy-combustion test priority will then be 

determined in collaboration with NETL. 

2.2 ALTERNATIVE 2: NO ACTION ALTERNATIVE 

Under the No Action alternative, the DOE would not provide funding to establish the 

PSDF CRC. If DOE funding were eliminated to the PSDF CRC, the possible outcomes 

could include reduction in scope of work of the CRC, procuring other funding sources, or 

discontinuing the project. The most likely scenario, and the only scenario considered 

reasonable for the purposes of this analysis, is that the CRC project would be cancelled. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-9 September 2008 

There is no other facility available that could provide the flexibility and system integrated 

demonstration information at its size range that the proposed PSDF CRC would produce. 

Project cancellation would mean this facility is not available to provide accelerated 

development for lower cost and more efficient CO2 capture solutions for coal-based 

power generation. 

2.3 ALTERNATIVES CONSIDERED BUT DISMISSED

CEQ regulations for implementing NEPA require that Federal agencies explore and 

objectively evaluate all reasonable alternatives to a proposed action and to briefly discuss 

the rationale for eliminating any alternatives that are not considered in detail. For this 

project, research into solvent, sorbent, membrane, and oxy-combustion systems as a 

means to capture CO2 generated from coal-burning generating plants is proposed. No 

viable alternative locations for this research have been identified. The infrastructure in 

place at the PSDF is not currently developed at other R&D facilities and laboratories, and 

other locations would require the addition of substantial capital costs in order to perform 

the proposed R&D activities. The PSDF represents a full scale research facility with 

nearly all required infrastructure for the proposed activities already established. 

The solvent, sorbent, membrane, and oxy-combustion systems identified under the 

Proposed Action represent the initial range of alternative CO2 capture systems currently 

under consideration for research at the PSDF. The proposed CO2 capture systems 

selected for initial evaluation as part of the Proposed Action were selected after 1) 

creating an inventory of potential candidate technologies by evaluating a variety of 

sources (including the Clean Coal Technology Roadmaps from DOE and from EPRI, and 

the R&D Plan from CoalFleet), 2) discussions with organizations such as DOE and EPRI, 

3) evaluating highest cost capture equipment areas, and 4) screening based on such 

factors as cost/benefit, likelihood of technical success, schedule, availability of data to 

support performance targets, timely development to commercial scale, and ability to 

integrate into the PSDF. 

However, the five year plan of the proposed project is dynamic, and technologies will 

continue to be screened and identified at least annually in order to accommodate new 

projects developed by DOE, industry, and others, and, to accommodate adjustments to 

priorities in response to test results from the previous year. The ongoing technology 

screening is expected to evolve and will encompass further inventorying of potential 

candidate technologies, establishing/refining screening criteria and scoring/ranking for 

prioritization of testing. This will be done in association with established budgets and 

goals and in conjunction with a project advisory team consisting of DOE and other major 

co-funders of the proposed project. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-1 September 2008 

3.0 AFFECTED ENVIRONMENT 

3.1 GEOLOGY AND SOILS 

The PSDF/Plant Gaston site is located in a geologically complex portion of the Coosa 

Valley in Alabama. The Floyd-Parkwood shale, a dark gray fissile shale that underlies the 

site, has been extensively folded due to ancient tectonic activity. The majority of joints and 

faults that formed as a result of this folding have been filled with calcite. The presence of 

calcite may indicate that the shale is relatively impermeable along these surfaces; thus, 

groundwater movement may be very slow through the shale. Both surface and subsurface 

information from available geological mapping sources indicates that no faults intersect the 

proposed site. The nearest fault is southeast of the site and is beyond the range of any 

potential influence; this fault has been interpreted to be inactive and sealing. 

The Coosa River Valley extends throughout the northeastern portion of the state. 

Elevations near the project site typically range from between 400 and 500 feet (ADEM, 

2006a). Soils underlying the PSDF facility have been derived from the weathering of the 

Floyd shale; they are predominately of the Townley Silt Loam series, with a small 

portion of the site found on the Townley-Urban Land Complex series (see Figure 3-1). 

Figure 3-1: Soil Map of Project Area 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-2 September 2008 

Figure 3-2: Existing Groundcover at Proposed Project Site

Both soil types are 

found on slopes 

ranging from 4-25%; 

they are well drained 

with slow 

permeability. Soils 

are typically 20-40 

inches deep, with 

soft, consolidated 

bedrock beneath the 

soil consisting of 

Floyd shale. These 

soil types are formed 

and mostly found in 

forested areas. 

However, at the 

PSDF and Plant Gaston site location, the majority of land area has been converted to 

industrial uses (NRCS, 2007). Figure 3-2 illustrates the current ground cover in the 

immediate vicinity of a project site at the PSDF. This area currently has 6-8 inches of 

aggregate on top of previously filled and graded land. 

3.2 WATER RESOURCES

3.2.1 Surface Water 

Three surface water bodies are located within one-half mile of the PSDF (see Figure 3-

3). These include the Coosa River, Yellowleaf Creek, and an unnamed tributary to 

Yellowleaf Creek. 

Coosa River 

The Coosa River flows through a large section of Alabama; from the northeastern border 

with Georgia it travels south and converges with the Tallapoosa River in the middle of 

the state. Coosa River stream flow past Plant Gaston is completely regulated by the 

operation of the Logan Martin and Lay Dams at Coosa River Miles 99.5 and 51.3, 

respectively. The Plant Gaston/PSDF site is located near the northern portion of the Lay 

Dam Reservoir. The United States Geological Survey (USGS) water level gauge at Plant 

Gaston averages water level in the Coosa River adjacent to the plant to be between 13 

and 14 feet above stream gage level. Due to the damming both up and downstream of 

Plant Gaston, water level within the Coosa River does not fluctuate greatly throughout 

the year; water levels are typically highest in March (averaging 14.04 feet above stream 

gage level), and lowest in October (averaging 13.48 feet above stream gage level) 

(USGS, 2008). Primary water uses for the Coosa River between the Logan Martin and 

Lay Dams are for industrial process cooling water, potable water supplies, recreation, and 

hydropower generation. The designated uses established by the Alabama Department of 

Environmental Management (ADEM) for the Coosa River within this reach are for Public 

Water Supply, Swimming, and Fish and Wildlife (ADEM, 2007a). 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-3 September 2008 

Section 303 of the Clean Water Act (CWA) established Total Maximum Daily Loads 

(TMDL) as a calculation of the maximum amount of a pollutant that a waterbody can 

receive and still meet water quality standards for its designated use. Many pollutants 

have been assessed and given TMDLs, including heavy metals, nutrients, turbidity and 

organic compounds. These water quality standards and designated uses are promulgated 

under the CWA and enforced by each State. When a State deems a water body impaired, 

it is placed on the 303(d) List of Impaired Waters. It will then remain on this list until 

TMDL water quality standards are met. Currently, over 325 miles of rivers and streams 

in the Coosa River Basin, including the reach of the Coosa River adjacent to the project 

site, are included on the 303(d) List (ADEM, 2007a). The Coosa River near the project 

site is listed as impaired due to elevated levels of nutrients, organic enrichment/dissolved 

oxygen (DO), and priority organics (PCBs). The most likely causes of these impairments 

are flow regulation and modification, contaminated sediments, and upstream sources 

(ADEM, 2007a). A TMDL to address the elevated DO levels in the Coosa River was 

established in 2004, and a TMDL and commercial fish ban to address the elevated PCB 

levels was established in 2005. 

Figure 3-3: Aquatic Features of Project Area 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-4 September 2008 

Figure 3-4: Unnamed Tributary

Yellowleaf Creek and its Unnamed Tributary 

The Yellowleaf Creek is a 

generally southern flowing 

tributary to the Coosa River, and 

it meets the river immediately 

north of the Plant Gaston site. 

Flow direction of the Yellowleaf 

Creek in the immediate vicinity 

of the project site is affected by 

water levels in the Coosa River 

and the water withdrawals in the 

area, including those of Plant 

Gaston. At normal full pool, the 

water in Yellowleaf Creek is 

about 20 feet deep at the 

unnamed tributary discharge 

point (DOE, 1999). The reach of Yellowleaf Creek in the vicinity of the project area is 

included on the 303(d) List of Impaired Waters for the same reasons as described above 

for the Coosa River. 

An unnamed tributary to Yellowleaf Creek flows on the southern side of the PSDF site 

and parallels the onsite railroad tracks prior to meeting the Yellowleaf Creek (Figure 3-

4). The length of the unnamed tributary is approximately 2,400 feet. The tributary is 

shallow and flows only intermittently. There is limited water quality data available for 

this waterbody; however, it is a discharge location for the PSDF and is therefore regularly 

monitored for a variety of potential contaminants (see below discussion under “Water 

Use and Discharge”). Currently, the discharge in the unnamed tributary meets all of its 

National Pollution Discharge Elimination System (NPDES) water quality requirements. 

Water Use & Discharge 

The PSDF service water system consists of separate systems to provide process water and 

potable water. Process water used in the cooling towers, firewater system and utility 

washdown is supplied from the Yellowleaf Creek via the intake structure at Plant Gaston. 

Process water used for steam and closed-loop cooling water systems is supplied by Plant 

Gaston from their demineralized water system. Potable water for domestic and sanitary 

use is obtained from the City of Wilsonville public water supply and metered to 

determine consumption. In lieu of a permitting system, Alabama requires water users to 

declare the quantity of water withdrawn for use or consumption by submitting a 

Declaration of Beneficial Use (DBU) to the Alabama Department of Economic and 

Community Affairs (ADECA), Office of Water Resources (OWR). A DBU requires the 

source and location of water withdrawal, the estimated amount as well as maximum 

quantity of the withdrawal and the primary use of the water to be diverted (ADEM, 

2004). The Plant Gaston and PSDF property currently holds a joint approved DBU; 

water withdrawal from the Plant Gaston intake structure on the Yellowleaf Creek is 

estimated to be approximately 830 million gallons per day (gpd) for use at Plant Gaston, 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-5 September 2008 

Figure 3-5: Discharge to Unnamed Tributary 

and 0.031 million gpd for use at PSDF. The maximum quantities allowed under the DBU 

are 900 million gpd, and 0.5 million gpd, respectively (Alabama Power Company, 2003).

Water that is used throughout the plant processes is treated and discharged into area 

surface waters. The unnamed tributary receives NPDES-regulated discharged wastewater 

from the PSDF (see Figure 3-5), and both the Yellowleaf Creek and Coosa River receive 

discharged wastewater from Plant Gaston (ADEM, 2006b, 2007b). The existing facilities 

generate a total of approximately 825 million gpd from primarily the once-through 

cooling wastewater and ID Fan cooling wastewater of Plant Gaston (Southern Company, 

2008). A net of roughly 5 million gpd of withdrawn surface water is consumed by the 

facilities. 

Water discharges from 

the PSDF flow into the 

unnamed tributary; 

flow in the tributary is 

intermittent, and during 

summer months 

discharge percolates 

into the ground and/or 

evaporates before 

reaching Yellowleaf 

Creek. The unnamed 

tributary meets 

Yellowleaf Creek 

approximately 4,000 

feet upstream from the 

confluence of 

Yellowleaf Creek and 

the Coosa River. 

Current wastewater treatment operations at PSDF include water collection by drainage 

from bermed areas, where chemicals are stored and process activities take place. The 

wastewater is drained to a 60,000 gallon collection basin where the water can be adjusted 

for pH, solids settling, and retention of oil. This discharge occurs in compliance with the 

facility’s existing NPDES permit. Stormwater is conveyed to two drainage areas: one 

north and one south of the facility. The stormwater is tested for pH and suspended solids. 

Stormwater is not retained and its treatment relies on Best Management Practices (BMPs) 

such as vegetative cover, and rock barrier retainers and filters. Sanitary wastewater is 

collected by drainage to lift stations on site. The lift stations pump the sanitary 

wastewater to an activated sludge treatment unit. This unit has discharge limits for 

biological oxygen demand (BOD), total suspended solids, ammonia, and fecal coliform 

bacteria and dissolved oxygen; the wastewater is sampled on a routine basis by PSDF 

staff (Southern Company, 2008). 

With the exception of the stormwater runoff, the discharge primarily consists of process 

water. Effluent from the process water could include runoff from the coal and limestone 

piles, process area wash water, sanitary wastewater, process wastewater, and general area 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-6 September 2008 

runoff. Major contamination concerns from these types of runoff could include changes 

in pH, elevated levels of suspended solids, metals, oils, grease, and changes in biological 

oxygen demand (DOE, 1999). As such, monitored effluent characteristics of process 

water include flow levels, pH, chlorine, temperature, phosphorus, magnesium, oil and 

grease, total suspended solids, benzene, ethylbenzene, toluene, xylene, aluminum, 

naphthalene, sulfate, biochemical oxygen demand, fecal coliform, ammonia, dissolved 

oxygen, total nitrogen, nitrates, and nitrites (ADEM, 2006b). At the Plant Gaston, 

monitored effluent characteristics are similar: flow levels, pH, chlorine, oil and grease, 

total suspended solids, arsenic, copper, iron, manganese, phosphorus, ammonia, nitrate 

and nitrite, toxicity to ceriodaphnia, and toxicity to pimephales (ADEM, 2007b). 

3.2.2 Groundwater 

The PSDF is located on the Floyd-Parkwood Shale Formation. Data collected from the 

site investigation indicated that groundwater occurring in this formation is noncontinuous and that it is found either perched in the residual clay and decomposed shale 

or concentrated along joint and fault planes. 

Regional groundwater supplies are provided from two major aquifers: the Knox-Shady 

and the Fort Payne-Tuscumbia aquifers. Aquifers in the region are typically associated 

with valleys that are separated by less permeable rocks outcropping on ridges. The major 

source of recharge to the aquifers is rainfall, with an estimated surface recharge of 5 

inches per year. Most of the aquifers in the area are unconfined and may be susceptible 

to surface contamination. The formations which underlie the proposed PSDF site have 

little groundwater and groundwater that is present flows away from the project site (DOE, 

1998). 

3.2.3 Wetlands & Floodplains 

There are no wetlands on the proposed project sites. However, there are stretches of 

forested/shrub wetlands in the immediate vicinity of the sites, along both the Coosa River 

and Yellowleaf Creek . These types of wetlands are typically found adjacent to rivers and 

are areas that are waterlogged for much of the year. Forested/shrub wetlands are typically 

dominated by broadleaf, deciduous trees such as cottonwoods, walnuts and sycamores 

(USEPA, 2006). In early 2007, approximately 550 acres of wetland and stream habitat 

was permanently protected along Yellowleaf Creek. The Freshwater Land Trust of 

Birmingham established this Yellowleaf Mitigation Bank approximately 10-20 miles 

northwest of the proposed project site. Nineteen counties in Alabama will be able to 

purchase wetland and stream credits in this location to offset the use of these types of 

environments during development projects (Westervelt Company, 2007). 

The proposed project sites at the PSDF and Plant Gaston are not located within the 100-

year floodplain (Southern Company, 2008). However, there are floodplains associated 

with each of the water bodies discussed above, in the immediate vicinity of the sites (as 

illustrated in Figure 3-3). 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-7 September 2008 

3.3 AIR QUALITY

Air quality is described by the concentration of various pollutants in the atmosphere. The 

significance of a pollutant concentration is determined by comparing the concentration in 

the atmosphere to applicable national and/or state ambient air quality standards. These 

standards represent the maximum allowable atmospheric concentrations that may occur 

and still protect public health and welfare with a reasonable margin of safety. 

This section is a description of ambient air quality in Shelby County with respect to 

attainment of National Ambient Air Quality Standards (NAAQS), and identification of 

applicable air quality regulations to the PSDF. 

3.3.1 National Ambient Air Quality Standards and Attainment Status 

USEPA Region 4 and ADEM regulate air quality in Alabama. The Clean Air Act (CAA) 

(42 USC 7401-7671q), as amended, gives USEPA the responsibility to establish the 

primary and secondary NAAQS (40 CFR Part 50) that set acceptable concentration levels 

for seven criteria pollutants: fine particulate matter (PM10), very fine particulate matter 

(PM2.5), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx), ozone (O3), 

and lead. Short-term standards (1-, 8-, and 24-hour periods) have been established for 

pollutants contributing to acute health effects, while long-term standards (annual 

averages) have been established for pollutants contributing to chronic health effects. 

Based on the severity of the pollution problem, nonattainment areas are categorized as 

marginal, moderate, serious, severe, or extreme. Each state has the authority to adopt 

standards stricter than those established under the federal program; however, the State of 

Alabama accepts the federal standards. 

Federal regulations designate Air-Quality Control Regions (AQCRs) in violation of the 

NAAQS as “nonattainment” areas. Federal regulations designate AQCRs with levels 

below the NAAQS as “attainment” areas. “Maintenance” AQCRs are areas that have 

previously been designated “nonattainment,” and have been redesignated to “attainment” 

for a probationary period through implementation of maintenance plans. The PSDF, and 

therefore the CRC, is completely within the Metropolitan Birmingham Intrastate AQCR 

(AQCR 004) (40 CFR 81.144). The USEPA has designated Shelby County as 

nonattainment for the PM2.5 NAAQS, a maintenance area for the 8-hour O3 NAAQS, and 

attainment for all other criteria pollutants (40 CFR 81.301). 

3.3.2 Class I and II Areas 

Class I Areas, as defined in the CAA, are national parks over 6,000 acres (2,428 ha), 

national wilderness areas and national memorial parks over 5,000 acres (2,023 ha), and 

international parks that were in existence as of August 7, 1977. The nearest Class I area, 

the Sipsey Wilderness Area, is located approximately 95 miles northwest of the site. 

Class II Areas are areas of the country protected under the CAA, but identified for 

somewhat less stringent protection from air pollution damage than a Class I area. Shelby 

County is considered a Class II Area. 
U.S. Department of Energy Carbon Research Center at PSDF 

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Affected Environment 3-8 September 2008 

3.3.3 Local Ambient Air Quality 

ADEM and Jefferson County Department of Health Air Pollution Control Program

monitor the concentrations of criteria pollutants in AQCR 004. Monitoring stations are 

located in Jefferson, Shelby, Sumter, Tuscaloosa, and Walker Counties. Worst case 

ambient air quality conditions can be estimated from maximum concentrations measured 

at these stations (Table 3-1). 

Table 3-1 

NAAQS and Area Air Quality 

Pollutant and Averaging Time Primary 

NAAQS1

Secondary 

NAAQS1 Monitored Data2

CO 

8-Hour Maximum3 (ppm) 9 (None) 9 

1-Hour Maximum3 (ppm) 35 (None) 20 

NO2 

Annual Arithmetic Mean (ppm) 0.053 0.053 (no data available) 

Ozone 

8-Hour Maximum4 (ppm) 0.08 0.12 0.108 

PM2.5 

Annual Arithmetic Mean5 (μg/m3) 15 15 20.3 

24-Hour Maximum6 (μg/m3) 35 35 64 

PM10 

Annual Arithmetic Mean7 (μg/m3) 50 50 56 

24-Hour Maximum3 (μg/m3) 150 150 241 

SO2 

Annual Arithmetic Mean (ppm) 0.03 (None) 0.003 

24-Hour Maximum3 (ppm) 0.14 (None) 0.014 

3-Hour Maximum3 (ppm) - 0.5 0.032 

1 - Source: 40 CFR 50.1-50.12. 

2 - Source: USEPA, 2008. 

3 - Not to be exceeded more than once per year 

4 - The 3-year average of the fourth highest daily maximum 8-hour average O3 concentrations over each 

year must not exceed 0.08 ppm. 

5 - The 3-year average of the weighted annual mean PM2.5 concentrations from must not exceed 15.0 ug/m3

. 

6 - The 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor 

must not exceed 65 ug/m3

. 

7 - The 3-year average of the weighted annual mean PM10 concentration at each monitor within an area 

must not exceed 50 ug/m3

. 

With the exception of the eight-hour O3, 24-hour PM2.5, and 24-hour PM10 standards airquality measurements are below the NAAQS (USEPA, 2008). The reported maximum of 

0.103 parts per million (ppm) for the eight-hour level exceed the standards of 0.08 ppm. 

However, the 3-year average of the fourth highest daily maximum 8-hour average O3

concentrations over each year has not exceeded 0.08 ppm; hence, the attainment status. 

The reported maximum of 64 micrograms per cubic meter (μg/m3

) for the 24-hour PM2.5

level exceed the standards of 35 μg/m3

. However, it was only exceeded once; hence, the 

attainment status. The reported maximum of 241 μg/m3

 for the 24-hour PM10 level 

exceeded the standards of 150 μg/m3

. However, the 3-year average does not exceed 150; 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-9 September 2008 

hence, the attainment status. Notably, all the highest levels were monitored in Jefferson 

County. 

3.3.4 Regional Emissions 

As part of its State Implementation Plan (SIP) of the CAA, ADEM compiles a region 

wide emissions inventory of the Metropolitan Birmingham Intrastate AQCR, and sets 

regional emissions budgets. Table 3-2 lists the estimated total emissions for the region. 

Notably, the region has no applicable SIP for the PM2.5 NAAQS; therefore no USEPA 

approved regional emissions budget is in place for PM2.5 and its precursors. The SIP 

revisions to address nonattainment conditions with respect to the PM2.5 NAAQS are 

being developed and are expected to be approved by USEPA by 2009. 

Table 3-2 

Regional Air Emissions within the Metropolitan Birmingham Intrastate AQCR 

Criteria Pollutants Annual Emissions 

(Tons per Day) 

Volatile Organic 

Compounds (VOC) 112 

NOx 177 

 Source: ADEM, 2005. 

3.3.5 Greenhouse Gasses and Global Warming 

Greenhouse gases (GHG) are components of the atmosphere that are generally 

considered as contributing to the greenhouse effect and global warming. Some 

greenhouse gases occur naturally in the atmosphere, while others result from human 

activities such as the burning of fossil fuels. Federal agencies, states, and local 

communities have prepared GHG inventories and adopted policies that would result in a 

decrease of greenhouse gas emissions. According to the Kyoto Protocol and California 

Climate Action Registry, there are six GHGs: carbon dioxide (CO2), nitrous oxide 

(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur 

hexafluoride (SF6) (UNFCC, 2007;CARB, 2007). Although the direct GHG (CO2, CH4, 

and N2O) occur naturally in the atmosphere, human activities have changed their 

atmospheric concentrations. From the pre-industrial era (i.e., ending about 1750) to 2004, 

concentrations of CO2 have increased globally by 35 percent. Within the United States, 

fuel combustion accounted for 94 percent of all CO2 emissions released in 2005. On a 

global scale, fossil fuel combustion added approximately 30 x109 tons (27 x109 metric 

tons) of CO2 to the atmosphere in 2004, of which the United States accounted for about 

22 percent (USEPA, 2007a). DOE’s Energy Information Administration (EIA) report 

indicates that U.S. CO2 emissions have grown by an average of 1.2 percent annually 

since 1990 and energy-related CO2 emissions constitute as much as 83 percent of the total 

annual CO2 emissions. 

Since 1900, the Earth's average surface air temperature has increased by about 1.2 to 

1.4oF. The warmest global average temperatures on record have all occurred within the 

past 15 years, with the warmest two years being 1998 and 2005 (USEPA, 2007b). With 
U.S. Department of Energy Carbon Research Center at PSDF 

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Affected Environment 3-10 September 2008 

this in mind, the DOE while preserving their core operations is poised to support climatechange initiatives to reduce GHG emissions. 

3.4 BIOLOGICAL RESOURCES

3.4.1 Vegetation 

The PSDF is located in a region dominated by Oak-Pine forests. These ecosystems are 

characterized by numerous oaks (white, northern, and southern red), and pines (loblolly 

pine being the most characteristic) in a rolling topography. The forest canopy also 

includes sourwood, sweetgum, and various hickory species. The non-forested areas 

nearby contain numerous species of grasses and herbs including fescue, orchard grass, 

verbena, wild petunia, and honeysuckle (DOE, 1998). As discussed above, the 

immediate project area is small and limited to previously developed land (Southern 

Company, 2008). Figure 3-2 illustrates the current land cover which is developed and 

lacking any vegetation. 

3.4.2 Wildlife 

Species diversity for wildlife populations occurring on the proposed project site is limited 

due to previous development, existing use, and small general area of the site. Nearby 

resident upland species include white-tailed deer, gray squirrel, red-bellied woodpecker, 

blue jay, Carolina chickadee, tufted titmouse, Carolina wren, brown thrasher, pine 

warbler, northern cardinal, rufous-sided towhee, and the eastern box turtle (DOE, 1998). 

Aquatic species living in Yellowleaf Creek include a diverse fish community with 47 

species representing 10 families. Yellowleaf Creek is also home to numerous snail and 

mussel species. The Coosa River is also home to a diversity of aquatic species; no other 

river basin in North America has a higher percentage of endemic species than the Upper 

Coosa River. Closer to the project site, in the Lower Coosa River and Lay Lake, 

dominant fish species include sport fish such as bass, catfish, bluegill, and other sunfish 

(DOE, 1998; CRBI, No date). 

3.4.3 Threatened & Endangered Species 

Both the Coosa River and the Yellowleaf Creek are home to several state- or federallylisted threatened or endangered species. The Coosa River is home to several listed fish, 

mussel, and snail species. Listed fish species include the Blue shiner, Cherokee darter, 

Goldline darter, Etowah darter, Amber darter and others. Mussel species include the 

Finelined pocketbook, the Alabama and Coosa moccasinshells, the Southern clubshell 

and the Rayed kidneyshell. Additionally, the Cylindrical lioplax and the Interrupted 

rocksnail are both federally endangered snail species found in the Coosa River (CRBI, 

No date). 

Similar to the Coosa River, the Yellowleaf Creek has several state- or federally-listed 

threatened or endangered fish, mussel, and snail species. A 25-mile portion of Yellowleaf 

Creek is federally designated critical habitat for four threatened or endangered mussels; 

the Coosa Moccasinshell, Finelined pocketbook, Southern pigtoe, and Triangular 
U.S. Department of Energy Carbon Research Center at PSDF 

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Affected Environment 3-11 September 2008 

kidneyshell. The designated critical habitat ends 1.4 miles upstream of the Plant Gaston 

intake structure. The Tulotoma Snail (Tulotoma magnifica) is a federally listed 

endangered snail which is known to occur on the rip rap of the Plant Gaston intake 

structure on the bank of Yellowleaf Creek, where it is attracted to the conditions caused 

by the turbulent intake water. 

The Yellowleaf Mitigation Bank being established northwest of the PSDF plans to 

provide permanent protection for four federally threatened or endangered mussel species, 

one state-listed mussel species, one endangered snail species, and one special concern 

plant species as determined by federal and state natural resource agencies (Westervelt 

Company, 2007). Though there are several state and federally listed aquatic species found 

in the vicinity of the project site, there are no known terrestrial plant or animal species 

found on the PSDF property or within the immediate vicinity of the project site (Southern 

Company, 2008). 

3.5 WASTE AND HAZARDOUS MATERIALS MANAGEMENT 

3.5.1 Waste Management 

The PSDF generates approximately 25 tons of municipal solid waste per year. Municipal 

waste generated at the PSDF is transferred to the Pineview Regional Landfill in Dora, 

Alabama, which is owned and managed by Browning-Ferris Industries (BFI). Materials 

such as office paper, cardboard, plastics, and metals are collected at the PSDF and 

transported for recycling whenever possible. Between 2-3 tons of paper are collected for 

recycling from the PSDF per year. 

In addition to municipal waste, the PSDF generates approximately 700 tons per year of 

coal ash and coal byproducts. This material is stored in two silos capable of holding 100 

cubic yards each. Unused coal slated for site removal, and coal ash generated by the 

PSDF, are either transferred to the adjacent Plant Gaston coal pile for combustion with 

their coal, or sent to the Pineview Regional Landfill for disposal via a contracted vendor. 

Coal ash generated by Plant Gaston is disposed of onsite at a permitted ash landfill. Prior 

to use, coal and limestone are stored in a covered concrete bunker at the PSDF. 

3.5.2 Hazardous Materials Management 

The PSDF currently uses and manages a variety of hazardous and toxic substances, 

including propane, nitrogen, acids, bases, Heat Transfer Fluid, oxygen, and hydrogen. In 

compliance with new Department of Homeland Security (DHS) regulations designed to 

address a possible terrorism attack, Southern Company has inventoried and disclosed the 

chemicals stored at the site which exceed DHS threshold amounts. The DHS regulations 

apply to the PSDF because the facility exceeds the threshold for propane. 

The PSDF is also permitted under the Federal Resource Conservation and Recovery Act 

(RCRA) and classified by the USEPA as a Small Quantity Generator of Hazardous Waste 

(USEPA ID # ALR000000216). The hazardous wastes currently generated at the PSDF 

include laboratory spent solvents, waste fuel, and spent paint thinner/cleaning solvents, 

and a combined total of about 4 tons/year of wastes are produced. Liquid hazardous and 
U.S. Department of Energy Carbon Research Center at PSDF 

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Affected Environment 3-12 September 2008 

toxic waste generated at the PSDF is collected in three satellite accumulation sites in 

metal drums and then moved to a covered shed, where it is held for less than 180 days. 

The waste is then transported offsite for disposal at Waste Management, Inc. located in 

Emelle, Alabama, which is a certified hazardous waste treatment, storage, and disposal 

facility. 

 

BMPs for managing all onsite hazardous and toxic materials and waste are in place at the 

PSDF. These BMPs include proper storage facilities and locations for the chemicals, 

immediate response to spill and leaks, and proper disposal of the waste from spills and 

leaks. The PSDF has a Spill Prevention Control and Countermeasures Plan (SPCC) in 

place, which was prepared in accordance with good engineering practices to comply with 

USEPA’s Oil Pollution Prevention Regulations, CFR Title 40 Part 112. The plan was 

implemented at the PSDF due to single above ground oil storage tank with an 

approximately 6,000 gallon capacity. The SPCC outlines how the PSDF would respond 

to significant oil spills, the strategies and methods used to minimize oil spills on nearby 

streams, and who is responsible for the plan. Spill prevention strategies used at PSDF 

include bermed tank and storage pads, oil spill supplies, and employees trained to 

respond to oil spills. 

The PSDF is licensed to possess radioactive sources through the Alabama Department of 

Public Health, Office of Radiation Control. The PSDF license number is 1230. For 

handling and using radioactive materials, the PSDF adheres to the principle of As Low 

As Reasonably Achievable (ALARA) for employees at the site. As part of the program, 

only trained and authorized users are allowed to work with the sources and a physical 

inventory of all sources must be taken at periodic intervals. The site has a designated 

Radiation Safety Officer who serves as the overseer for the program. The program is 

subject to a state inspection and has had three inspections over the life of the program. 

3.6 HUMAN HEALTH AND SAFETY

Primary concerns to human health and safety at the PSDF include the exposure of 

workers to air emissions from the existing facilities, chemicals stored onsite, and process 

gases. Section 3.3.1 discusses monitored air emissions and their potential impacts on 

human health. National and state ambient air quality standards represent the maximum 

allowable atmospheric concentrations that may occur and still protect public health and 

welfare with a reasonable margin of safety; these are also presented in Section 3.1. PSDF 

employees living in and around this area are regularly exposed to the existing ambient air 

quality which is heavily influenced by combustion activities at Plant Gaston. 

The existing PSDF facility stores a limited number of materials or chemicals which could 

potentially pose a risk to employees or others with respect to safety and health. See 

Section 3.5 for detailed description of current chemical storage and employee handling 

and safety requirements. Storage facilities for the materials required to operate the 

facility, including nitrogen, oxygen, acids, bases, and propane, are designed to minimize 

this risk in addition to being designed for spill containment and the control of releases. 

Current operational risks due to the accidental release of process gases are minimal. The 

flare, which is an integral part of the PSDF, is used as a relief device for venting and 

destroying gases from the gasifier during emergency conditions and power system 
U.S. Department of Energy Carbon Research Center at PSDF 

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Affected Environment 3-13 September 2008 

shutdowns. To prepare for emergencies, routine safety, emergency response, and 

emergency evacuation drills have been, and will continue to be, conducted among the 

existing facility employees. 

Existing operational noise levels are considered to be within the range of light industrial 

activities; typically not rising above 63 dB. This is well below the Occupational Safety 

and Health Administration’s (OSHAs) limit of workers being exposed to not more than 

90 dB over an 8-hour workday (OSHA, 2008). In areas of the PSDF where noise levels 

reach above 85 dB, employees are required to wear hearing protection. In addition, 

OSHA regulations which specify appropriate protective measures for all employees, 

including hardhats, eye covering, and other appropriate attire, are adhered to at the 

industrial areas of the PSDF and Plant Gaston. 

3.7 CULTURAL RESOURCES

Cultural and historic resources are protected by a variety of laws and regulations, 

including the National Historic Preservation Act, as amended, and the Archaeological 

Resources Protection Act. Section 106 of the National Historic Preservation Act and 

implementing regulations (36 CFR 800) outline the procedures to be followed in the 

documentation, evaluation, and mitigation of impacts to cultural resources. The Section 

106 process applies to any federal undertaking that has the potential to affect cultural 

resources. 

The Alabama Historical Commission is the state agency charged with safeguarding 

Alabama’s historic buildings and sites. The Commission administers 12 historic sites. 

There are no historic sites located within Shelby County; the historic site closest to the 

PSDF is the Confederate Memorial Park in Chilton County, located due south of Shelby 

County (AHC, 2008). The Confederate Memorial Park is the site of Alabama's only Old 

Soldiers Home for Confederate Veterans. 

Though not regulated by the State as a historic site, the remains of three Confederate forts 

which were constructed in 1863 by Confederate troops under the command of Major 

W.T. Walthall, Commander of the military post at Talladega, exist approximately one 

mile from the PSDF on the Plant Gaston property. 

No recorded archaeological sites are located within the project boundaries. There are no 

State-designated scenic highways in the Wilsonville area, and no local programs exist for 

designating scenic areas or vistas in the area. 

The initial EA for the development, construction, and operation of the PSDF was issued 

with a FONSI in 1993. As part of this initial EA, consultation with the Alabama SHPO 

took place in 1992. On October 26, 1992, SHPO determined the project would not have 

an adverse effect on identified historic properties. 

3.8 SOCIOECONOMICS

The socioeconomic region of influence for the proposed action is a three county area 

around PSDF where the majority of construction and site workers would reside and 
U.S. Department of Energy Carbon Research Center at PSDF 

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Affected Environment 3-14 September 2008 

where socioeconomic impacts are most likely to occur. The three counties are Shelby, 

Coosa, and Talladega Counties in Alabama. The closest municipality is Wilsonville, 

Alabama, located just west of the project site. 

Between 2000-2006 (based on Census Bureau data), the population within this threecounty area was approximately 202,000. Approximately 58% of the population is found 

within Shelby County, 5% in Coosa County, and 36% in Talladega County. Wilsonville, 

Alabama had a population of 1500 in 2000. Within Shelby County, approximately 85% 

of the population is white, 9% black, and 3% Hispanic or Latino. In Coosa County, 63% 

are white, 34% black, and 1.3% Hispanic or Latino, and in Talladega County, 

approximately 62% of the population is white, 30% black, and 1% Hispanic or Latino. 

The average demographics in the U.S. at this time were 75% white, 12.3% black, and 

12.5% Hispanic or Latino. Within Alabama, 71% of the population was white, 26% 

black, and 1.7% Hispanic or Latino (USCB, 2006a, 2006b, 2000a, 2000b, 2000c). 

The total civilian labor force for the region of influence was approximately 40,300 in 

2000-2006; unemployment rates in both Shelby and Coosa Counties were approximately 

3.8 percent while Talladega County had an unemployment rate of 9.5%. Comparatively, 

the unemployment rate was 4.6% in the United States and 3% in Alabama. The top three 

job types in Shelby County include the education, health care, and social services sector; 

the retail sector; and, the professional, scientific, and management sector. In Coosa 

County the top employment type is manufacturing, followed by retail, and construction. 

In Talladega, workers are also predominantly employed in manufacturing, education, 

health care, and social services, and retail. In Wilsonville, the top employment type is 

management and professional, followed by sales and office occupations, and 

construction. The average per capita personal income in 2000 (most recent Census 

Bureau data available for entire region) was $19,700 for the region of influence. For the 

same year, the per capita personal income was $21,875 for the United States, and $18,189 

for Alabama (USCB, 2006a, 2006b, 2000a, 2000b, 2000c). 

The PSDF usually has between 30-40 permanent construction employees and 

approximately 100 permanent Southern Company Services and Alabama Power 

Company employees. Fluctuations in employment levels at the PSDF change based on 

workload and construction status. During past construction phases, the number of 

construction employees has increased to approximately 70 during peak times (Southern 

Company, 2008). 
U.S. Department of Energy Carbon Research Center at PSDF 

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Environmental Consequences 4-1 September 2008 

4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION 

AND ALTERNATIVES 

4.1 GEOLOGY AND SOILS

4.1.1 Alternative 1: Proposed Action 

The Proposed Action would involve ground disturbance at two small areas on the 

existing PSDF site to accommodate the installation new pre-combustion CO2 capture 

equipment, including tanks, pumps and other equipment. The primary area of 

construction would be immediately north of the existing facility on previously disturbed 

land; this area is shown in Figure 3-2. The footprint of disturbance in this area is 

projected to be a total of 1,250 ft2, with between an 8 inch and 2 ft depth for construction. 

The second area of disturbance at the PSDF would be previously disturbed land on the 

north side of the PSDF process structure, where an existing 700 ft2 pad would be 

modified to accommodate tanks and pumps for solvent storage, with approximately 2 ft. 

depth for construction. The total footprint of land disturbance at the PSDF is estimated to 

be 1,950 ft2. 

As part of the proposed post-combustion CO2 capture research, an approximately 7,500 

ft2 previously disturbed area located adjacent to Plant Gaston Unit 5 would be further 

developed to install new concrete foundations. An additional previously disturbed area 

approximately 2,500 ft2 would be utilized for infrastructure and support systems. 

Foundation depths would be approximately 50 ft and would include a combination of 

pilings, casings, and area pads. A total footprint of disturbance of approximately 10,000 

ft2 would occur as part of the post-combustion CO2 capture research at Plant Gaston. 

Each of the locations proposed for development is relatively flat and firm with no 

potential for geologic instability or subsidence. As discussed in Section 3.1, the proposed 

area has very little to no potential for future faulting to occur. Geological resources are 

not expected to be impacted if the proposed action were implemented. 

A limited amount of soils can be expected to be disturbed during the 

construction/development phase of the proposed action. However, all construction 

activities would occur on previously developed land that is covered with gravel, and the 

impact to native soils is considered negligible. A minimal amount of additional 

stormwater runoff can be expected to occur during construction activities and from the 

slight increase in impervious surface area of the sites. All site runoff during construction 

activities would be permitted by ADEM’s state-issued general NPDES permit for 

construction activities of less than one acre. During operation, runoff would be permitted 

by the site’s operations NPDES permit and all existing stormwater permit conditions 

would continue to be met. 

The duration of construction of the new pads required would be short, only 2-3 weeks 

each, and the construction activities would be performed under the guidelines of the sites’ 

BMP Plan. Standard construction BMPs, such as installing perimeter silt fences, 

spreading straw and mulch to protect exposed ground, covering stockpiles of earth or 
U.S. Department of Energy Carbon Research Center at PSDF 

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Environmental Consequences 4-2 September 2008 

soils, and so forth, will help further minimize runoff, erosion and impacts to on-site and 

off-site soils during construction activities. Overall impacts to geologic resources and 

soils from the Proposed Action are considered negligible. 

4.1.2 Alternative 2: No Action 

Under the No Action Alternative, no impacts to geologic resources or soils would be 

expected to occur. No construction activities or operational changes would occur that 

would impact soils. The possible decommissioning of the PSDF and demolition of 

facilities is not part of the scope of this EA. 

4.2 WATER QUALITY IMPACTS

4.2.1 Alternative 1: Proposed Action 

Surface Water 

General construction impacts associated with the development of the proposed pre- and 

post-combustion CO2 capture research sites could affect water resources by increased 

stormwater runoff from the sites during times of heavy rain, and, by contamination from 

construction activities infiltrating area soils and percolating down into the groundwater. 

Increased stormwater runoff from developed sites can lead to increased erosion of exposed 

soils, which leads to increased turbidity in surface waterbodies. The first flush of rains 

after a long dry period will carry pollutants deposited on pavement into soils and water 

bodies, posing a risk of contaminating water and harming aquatic life. The total footprint 

of disturbance associated with the proposed action at all PSDF and Plant Gaston locations 

is estimated to be approximately 11,950 ft2 (0.27 acres), which is considerably less than the 

one acre threshold that triggers the need for most individual construction site permits under 

the NPDES regulations enforced by ADEM (ADEM, No date-b). The small footprint of 

new disturbance, combined with the extent of existing land development and stormwater 

management practices, should aid in minimizing stormwater runoff during construction 

activities. Additionally, the existing berms between Plant Gaston and the Coosa River will 

help to minimize stormwater runoff during the construction of the post-combustion CO2

capture facility near Plant Gaston Unit 5. 

The Coosa River and Yellowleaf Creek are the two nearby surface waterbodies that have 

the potential to be impacted under the Proposed Action. Both the PSDF and Plant Gaston 

have existing NPDES permits that allow discharge of pollutants to these waterbodies that 

meet limits established by the permit. Any new chemicals brought on site have the 

potential to be discharged through spills and accidents. New solvents will be required for 

the implementation of the CRC. Operational changes in runoff are also likely to occur. 

Runoff from the coal and limestone storage areas will be collected and pumped to the 

60,000 gallon collection basin. Runoff from the storage piles is expected to be minor and 

is estimated to be approximately 5,000 gallons per year. Sheds cover the storage areas 

and runoff from that area is limited to the area immediately in front of the shed. ADEM 

will be informed of the presence of the new solvents; their use will be managed by BMP 

plans that are already in place, with the plans being modified as necessary to 

accommodate the presence of the new solvents. Therefore, the potential harm to a 
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Environmental Consequences 4-3 September 2008 

receiving body should be mitigated by the small size of the proposed disturbance, by the 

BMP plans that are already in place, and by the existing treatment capabilities for some 

of the discharges such as solids settling, oil separation, pH adjustment, storage containers, 

and storage locations. It is not anticipated that a modification of the NPDES permit 

would be required for the addition of CRC-related construction and operations. 

Neither the water quality of Coosa River, nor the unnamed tributary to Yellowleaf Creek, 

are expected to be impacted as a result of the proposed action. 

Water Use & Discharge 

During construction associated with the CRC, some runoff would be expected, but would 

likely be minimal and of short duration. The duration of construction of the new pads 

required would only be 2-3 weeks each, and the area of the new pads of such a small size, 

that negligible increases to runoff should occur. These activities would be performed 

under the guidelines of the PSDF BMP Plan. Construction activities associated with the 

Proposed Action are not likely to have more than short-term, minor impacts on nearby 

surface waters. 

Once the CRC is operational, potable and process water will continue to come from the 

City of Wilsonville and the Yellowleaf Creek via the Plant Gaston intake structure, 

respectively. No modification of the existing DBU would be required for the addition of 

CRC equipment. Water use at the PSDF is expected to remain similar to, or increase 

slightly from, current amounts. These levels are estimated to be approximately 37,000 

gpd; with a maximum quantity of 76,000 gpd. The majority of the water required for the 

pre-combustion facilities is already necessary for daily operations at PSDF; therefore this 

increase is negligible. Post-combustion CO2 capture research water requirements will 

add an additional 35,000 gpd estimated usage, with a maximum usage quantity of 49,000 

gpd (Southern Company, 2008). The 35,000 gpd of water needed for the postcombustion CO2 capture facilities at Plant Gaston Unit 5 will be in addition to the nearly 

830 million gpd required for operation of the PSDF/Plant Gaston facilities. It is 

anticipated that this will not result in any impact to either the Yellowleaf Creek or the 

Coosa River. 

The CRC will be developed within a curbed basin that collects any spills associated with 

process discharges, as well as stormwater runoff from the site. This curbed area collects to 

a sump, which will be pumped either into existing yard drains (normal operation) or to 

storage containers in the event of a process spill or modification. The existing site drainage 

system carries runoff to the south into the existing coal pile runoff pond, where it is then 

pumped to the existing ash storage lake. The discharge of the ash storage lake is monitored 

according to the existing Plant Gaston NPDES permit (Southern Company, 2008). 

Current wastewater quantities are described in Section 3.2.1; the non-contact cooling 

water system, and process water systems will both result in additional wastewater once 

the CRC is operational. Non-contact cooling water will increase to 827,000 gallons and 

process water will increase to 1,250,000 gallons. Section 3.2.1 also describes the 

components of wastewater that are monitored; this monitoring will continue as no 

changes to the NPDES permit are expected (Southern Company, 2008). The 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-4 September 2008 

implementation of the Proposed Action is likely to have no more than minor, adverse 

impacts on surface waters due to operational changes in runoff; no impacts to surface 

water quantity or water levels within any waterbodies are expected. 

Groundwater 

As described above, the proposed action will require the use of additional water 

resources. However, none of the additionally required water is expected to come from 

groundwater or be discharged underground. No impacts to groundwater resources within 

the vicinity of the proposed project site are expected. 

Wetlands & Floodplains 

Under the Proposed Action, no impacts to wetlands or floodplains are expected. No 

construction or operational activities or changes will occur in or adjacent to wetland or 

floodplain areas. 

4.2.2 Alternative 2: No Action 

If the No Action Alternative were to be implemented, negligible impacts would be 

anticipated to occur to surface water resources. Water withdrawal from the Plant Gaston 

intake structure would continue to supply daily operations at Plant Gaston, which are 

estimated to require approximately 830 million gpd. Water withdrawal for the proposed 

operations at the PSDF and the projected post-combustion CO2 capture research activities 

at Plant Gaston are estimated at a combined average of 72,000 gpd (0.072 million gpd), 

or less than 0.009% of total withdrawal. The decrease in water withdrawal and use if the 

CRC was not implemented and the PSDF were not in operation is considered negligible 

relative to the quantities withdrawn and used by Plant Gaston. 

The existing NPDES permit would not require modification or replacement. The No 

Action Alternative is not expected to result in impacts to the unnamed, intermittently 

flowing, tributary, Yellowleaf Creek, or the Coosa River. Additionally, no impacts to 

groundwater or wetlands and floodplains can be expected from implementation of this 

alternative. 

4.3 AIR QUALITY IMPACTS

4.3.1 Alternative 1: Proposed Action 

Short-term and long term minor impacts to air quality would be expected as a result of 

implementation of the Proposed Action. Direct and indirect air emissions would not 

exceed applicability thresholds, be “regionally significant,” or contribute to a violation of 

any federal, state, or local air regulation. 

Estimated Emissions and General Conformity 

Implementing the Proposed Action would generate air pollutants during construction and 

introduce minor new stationary sources of pollutants, such as a hot water heater and a 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-5 September 2008 

gas-fired boiler for heating. All direct and indirect emissions associated with the 

Proposed Action were estimated (Table 4-1). The construction emissions would be 

generated by equipment use for site preparation and construction for the new facilities, 

including: 

• The pad for the Water Gas Shift and compressor (20’ x 40’ x 2’), 

• The pad for the Gas Analyzer Building (30’ x 15’ x 8”), 

• The proposed Gas Analyzer Building itself, 

• The pad for post combustion infrastructure and support systems (50’ x 50’ x 10’), 

• The pad for post combustion gas capture system (50’ x 150’ x 50’), 

• Minor surface paving, and 

• Minor storm water and sewer upgrades. 

The facility’s operational emissions estimates included: 

• Heating emissions from hot water heater and natural gas boilers, and 

• Additional processing emission. 

The general conformity rules (GCR) require federal agencies to determine whether their 

action(s) would increase emissions of criteria pollutants above preset threshold levels (40 

CFR 93.153(b) and AAC 335-3-17-.02). These de minimis (of minimal importance) rates 

vary depending on the severity of the nonattainment and geographic location. To 

determine the applicability of the GCR to the Proposed Action, estimated air emissions 

from construction and operational activities were estimated and compared to the 

applicability thresholds under the GCR and the regional emission budgets. Emissions are 

expected to be below the applicability threshold for all criteria pollutants (Table 4-1), and 

would not be regionally significant for VOC and NOx (Table 4-2). Pending the full 

implementation of the PM2.5 NAAQS, there is no USEPA approved regional emission 

budget for PM2.5 or SO2. Due to the limited size and scope of the Proposed Action when 

compared to the overall regional activity, it is not anticipated that emissions of PM2.5 or 

SO2 would be regionally significant. Detailed emissions calculations are located in 

Appendix A. 

Table 4-1 

Project Emissions Compared to Applicability Thresholds 

Annual Emissions 

(Tons per Year) 

Activity VOC NOx SO2 PM2.5

Applicability 

threshold 

Would 

emissions 

exceed 

applicability

levels? 

[Yes/No] 

Construction 0.9 5.5 0.0 0.3 100 No 

Operations 1.0 21.0 17.0 3.4 100 No 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-6 September 2008 

Table 4-2 

Annual Emissions Compared to Regional Emissions 

Criteria Pollutant or Precursor 

VOC NOx

Project Emissions (tpd) 0.003 0.057 

Regional Emissions (tpd) 112 177 

Percent Regional Emissions <0.01% <0.01% 

Regionally Significant? No No 

 Source: ADEM, 2005. 

 tpd = tons per day 

Regulatory Review 

Stationary sources of air emissions associated with the Proposed Action would be subject 

to federal and state air permitting regulations. ADEM oversees programs for permitting 

the construction and operation of new or modified stationary source air emissions for 

many industries and facilities that emit regulated pollutants in Alabama. 

The permit rules and standards are found in Division 3 of the ADEM Administrative 

Code. These requirements include, but are not limited to, minor new source review 

(NSR), nonattainment new source review (NNSR), prevention of significant deterioration 

(PSD), and new source performance standards (NSPS) for selected categories of 

industrial sources. In addition, under the National Emission Standards for Hazardous Air 

Pollutants (NESHAP), new and modified stationary sources of air emissions may be 

subject to Maximum Achievable Control Technology (MACT) requirements if their 

potential to emit Hazardous Air Pollutants (HAPs) exceeds either 10 tons per year of a 

single HAP, or 25 tons per year of all regulated HAPs. 

Based on the facility’s potential to emit, PSDF is a major emissions source. A facility 

wide Title V permit was issued in October, 2003 (ADEM, 2003). The Title V PSDF air 

permit would not be affected by the new project. However, a modification or add-on to 

the existing facility air permit may be necessary. For example, a new steam boiler may 

have to be added for heating and process requirements. In these cases, the Air Division of 

ADEM would be contacted and the necessary application material submitted for a 

review. The steam boiler would carry its own individual permit requirements separate 

from the main gasifier permit. While a need to seek minor modifications may become 

necessary, it is anticipated that no increase in emission limits to the existing permit would 

be sought. The pre-combustion facility is projected to operate at a maximum of 2,500 

hours per year. 

Based on the facility’s potential to emit, Plant Gaston Unit 5 is also a major source. The 

proposed post-combustion facility would not require modification to the Plant Gaston 

Unit 5 existing Title V air permit. Flue gas that is processed through the facility would be 

returned to the existing plant flue gas desulfurization (FGD) inlet duct, where it would be 

contacted again through the FGD as a final filter for the gas stream. Due to the chemistry 

and processes in which flue gas CO2 is captured, it is expected that the traditional 

emissions of PM and acid gases (SO2 and NOx) would be reduced through the addition of 
U.S. Department of Energy Carbon Research Center at PSDF 

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Environmental Consequences 4-7 September 2008 

this facility. The only expected incremental emissions can be attributed to possible VOC 

slip (from solvent based processes) or sorbent attrition and slip (from solid adsorbent 

based processes). Because the organic solvents used in these processes are aqueous 

based, any VOC should be captured at a high efficiency in the existing Unit 5 FGD. 

Furthermore, the FGD design is highly efficient in capturing PM. For these reasons, very 

little air emission is expected from the Post-Combustion facility. Unit 5 would continue 

to be monitored to assure compliance with its existing Title V air permit. 

Table 4-3 

Air Quality Regulatory Review for Proposed Stationary Sources 

Regulation Project Status 

Nonattainment New 

Source Review (NNSR) 

The potential emissions would not exceed the NNSR 

thresholds. Therefore, a NNSR construction permit would 

not be required. 

New Source Review 

(NSR) 

The potential emissions may exceed the minor NSR 

threshold. Therefore, a minor NSR construction and 

temporary operating permit may be required. 

Prevention of Significant 

Deterioration (PSD) 

The proposed project would not result in a significant net 

emissions increase of any regulated pollutant, as defined by 

AAC 335-3-14-.04 (2)(c) and (w). Accordingly, the project 

would not be subject to PSD review. 

Title V Permitting 

Requirements 

Major modification threshold would not be exceeded. The 

PSDF and the Plant Gaston Unit 5 Title V Air Permits 

would not need updating. 

National Emission 

Standards for Hazardous 

Air Pollutants (NESHAP) 

Potential HAP emissions are not anticipated to exceed 

NESHAP thresholds. Therefore, the use of MACT would 

not be required. 

New Source Performance 

Standards (NSPS) 

Any new boilers rated greater than one million BTU 

installed would have to comply with NSPS. 

tpy = tons per year 

The construction projects would be accomplished in full compliance with current 

Alabama regulatory requirements, through the use of compliant practices and/or products. 

Some applicable sections may include: 

• AAC 335-3-3-.01 - Open Burning 

• AAC 335-3-4-.01 - Visible Emissions 

• AAC 335-3-4-.02 - Fugitive Dust and Fugitive Emissions 

• AAC 335-3-6-.32 - Surface Coating 

• AAC 335-3-6-.34 - Cutback and Emulsified Asphalt 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-8 September 2008 

Construction activities are expected to cause some localized dust. Standard mitigation 

techniques such as watering, erecting wind breaks, and using covers where practicable 

would be employed to minimize fugitive dust. 

Greenhouse Gasses and Global Warming 

Because operation of the PSDF is an integral part of research and development activities 

for the Proposed Action, release of CO2 air emissions would occur during routine 

operations at the PSDF, as described in Section 3.3. Additional sources of emissions 

during research operations at the post-combustion area adjacent to Plant Gaston could 

include compressors, which are often equipped with automatic blowdown valves that 

depressurize compressors, bottles, separators, and interconnecting lines in the event of a 

shutdown. It is expected that emissions due to these additional sources would be very 

small. The majority of the CO2 stream that would feed the system would otherwise be 

vented to the atmosphere without the Proposed Action. Therefore, CO2 that is vented 

from the post-combustion unit during this project are emissions that would otherwise 

have occurred if the compression unit, pipeline, and CRC were not in place. Therefore, 

these sources of fugitive emission would not increase overall CO2 emissions. 

4.3.2 Alternative 2: No Action 

Selecting the No Action Alternative would result in negligible impacts to ambient airquality conditions. No construction would be undertaken and facility operations would be 

suspended. The relatively minute release of CO2 from PSDF operations would not occur. 

Ambient air-quality conditions would remain as described in Sections 3.3.1. Indirectly, 

selecting the No Action Alternative, meaning that the proposed CRC would not be 

established and this project is not carried out in any setting, would delay planned largerscale CO2 reduction projects indefinitely. The increased understanding of CO2 reduction 

technologies would not be gained. 

4.4 BIOLOGICAL RESOURCES

4.4.1 Alternative 1: Proposed Action 

Vegetation and Wildlife 

As discussed above, all components of the Proposed Action will be occurring on 

previously developed land that is lacking vegetative cover and likely not habitat for 

wildlife. No impacts to terrestrial wildlife and vegetation are expected to result from the 

implementation of the Proposed Action. Aquatic species living in the unnamed tributary, 

Yellowleaf Creek, and the Coosa River are not likely to be impacted by the change in 

discharge coming from the activities associated with the Proposed Action, as discussed in 

Section 4.2.1.2. Although minor changes in water discharge will occur, these changes are 

not enough to warrant a modified or new NPDES permit. Changes in water discharge are 

not expected to result in more than negligible impacts to the nearby aquatic 

environments. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-9 September 2008 

Threatened and Endangered Species 

Under the Proposed Action, no impacts to State or Federally listed threatened or 

endangered species are anticipated to occur. Negligible impacts to water quality, water 

quantity, and the water velocity in the intake structure on Yellowleaf Creek, would occur 

as a result of construction and operation of the CRC. As a result, no impacts are 

anticipated to occur to the Tulotoma Snail which is found on the riprap of the intake 

structure. 

Consultation regarding the Proposed Action was initiated with the USFWS on June 2, 

2008, to ensure that the proposed project would result in no impacts to listed species. On 

June 24, 2008, the USFWS responded with concurrence that the project as described will 

have “no significant impact on fish and wildlife resources”. A copy of the consultation 

letter with USFWS’ stamped concurrence can be found in Appendix B. 

4.4.2 Alternative 2: No Action 

The No Action Alternative will not result in any impacts to wildlife or vegetation, as no 

construction activities or facility development is expected to occur. Additionally, the No 

Action Alternative is not anticipated to result in any impacts to threatened or endangered 

species found in the vicinity of the area. 

4.5 WASTE AND HAZARDOUS MATERIALS MANAGEMENT

4.5.1 Alternative 1: Proposed Action 

The amount of municipal solid waste (25 tons/yr) and coal ash waste (700 tons/yr) 

currently generated by the PSDF is expected to remain the same if the Proposed Action is 

implemented. The municipal solid waste would continue to be disposed of at the 

Pineview Regional Landfill, while the addition of a solids wetting system to the solids 

discharge silo in the latter part of 2007 to eliminate dusting allows all of the coal and 

coal-derived ash from the PSDF to be placed on the coal pile at the adjacent Alabama 

Power Company power plant. The quantity of coal byproducts and ash sent to the 

Pineview Regional Landfill is expected to be near zero under the Proposed Action. 

The amount of hazardous waste currently generated by the PSDF (4 tons/yr) from 

laboratory spent solvents, waste fuel, and spent paint thinner/cleaning solvents, is 

expected to either remain the same under the Proposed Action, or to increase as a result 

of an increase in spent solvents from CRC R&D efforts.

New substances that are anticipated to be stored and used at the PSDF as part of the CRC 

include several hazardous or toxic substances, such as solvents (amine derivatives and 

amine compounds), anhydrous ammonia, catalysts containing metals such as nickel and 

cobalt, hydrogen sulfide, and sulfur dioxide. The solvents will be used for CO2 absorption 

in liquid-gas contacting devices being tested. 

Amines, salts of strong organic bases, are organic compounds and a type of functional 

group that contains nitrogen as the key atom. Some amines that may be used at PSDF-
U.S. Department of Energy Carbon Research Center at PSDF 

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Environmental Consequences 4-10 September 2008 

CRC for CO2 capture testing include Mono ethanol amine (MEA), Methyl diethanol 

amine (MDEA), and proprietary hindered amines (chemical compounds containing an 

amine functional group surrounded by a crowded steric environment). However, most 

solvents have not yet been identified, but will be selected as research progresses and 

suppliers develop suitable solvents. 

Upon completion of testing of amine-based and other test solvents, if they are no longer 

needed for future testing, the solvents (and the cartridge filters utilized with the solvents, 

to remove impurities from the solvent system and improve the life of the solvent) will 

have to be collected and stored and then characterized as either hazardous or nonhazardous. Spent solvents and their cartridge filters will either be disposed of at a 

licensed waste management facility, sent to Plant Gaston’s Unit 5 for combustion, or, if 

feasible, safely transported back to the vendor for recycling. If the solvents and cartridge 

filters are disposed of at Plant Gaston Unit 5, they would be combusted along with fuel. 

The primary impurities contained in the solvents would be salts of SO2 and NOx,, and 

because the existing Unit 5 facility is equipped with high efficiency SCR and FGD for 

NOx and SO2 control, this proposed disposal method is considered the most 

environmentally friendly and safe approach. 

It is assumed that this quantity of solvents will increase each year as processes are added 

for testing and the number of hours operation for each process is established. An initial 

quantity of approximately 12,000 lb/yr is projected for year 1, increasing to a maximum 

of approximately 68,000 lb/yr after 5 years. If all spent solvents tested are found to be 

hazardous wastes that can not be combusted nor recycled, they will add an additional 6 

tons/year of hazardous waste to be safely disposed of in a licensed waste management 

facility, bringing the total facility wide amount of hazardous waste generated by the 

PSDF to approximately 10 tons/yr. 

Each new chemical brought onsite to the PSDF or Plant Gaston as part of the CRC would 

be thoroughly investigated and classified before storage and use. All applicable safe 

handling, storage, use, and disposal precautions would be observed and adhered to. 

Though the quantity of hazardous and toxic materials would likely increase as a result of 

this alternative, it is not anticipated that this increase would result in more than negligible 

impacts to proper management of the materials. 

4.5.2 Alternative 2: No Action 

Under the No Action alternative, there would be no additional waste generated, and no 

new hazardous or toxic substances would be stored or used on site. While ultimate use of 

the PSDF, if the CRC project is cancelled, cannot be determined at this time, it is 

anticipated that the amount of waste generated from the site would decrease and that the 

resultant impacts associated with the No Action alternative on waste and hazardous 

materials management would be negligible. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-11 September 2008 

4.6 HUMAN HEALTH AND SAFETY

4.6.1 Alternative 1: Proposed Action 

The worker safety program requirements applicable at the project site location include the 

“construction” and “general industry” standards of the federal OSHA 29 CFR 1910 and 

1926. These standards include walking-working surfaces, means of ingress and egress, 

operation of power equipment, adequate ventilation, noise exposure controls, fire 

protection, and electrical equipment safeguards. Because of the level and duration of air 

quality degradation expected during construction activities, the impacts to human health 

(workers and the public) can be expected to be minor, adverse, and short-term (See 

Section 4.3). Following the mitigation measures and BMPs will reduce the adverse 

impacts to human health from air quality. Workers would follow OSHA procedures, 

which would further reduce the impact to human health. With the addition of only 30-70 

extra temporary employees, the risk of traffic accidents in and around the project site 

would be minimal. This area is not heavily trafficked, and the additional number of 

temporary workers would be well within the range typically experienced during other 

construction projects at the PSDF. Overall, impacts to human health are expected to be 

negligible to minor, adverse, and lasting only the duration of the construction. 

Once the proposed CRC facilities are operational, OSHA procedures would continue to 

be followed to minimize worker exposure. These may include warning systems and 

alarms to detect exposures and spills, as well as informing the proper authorities of any 

incidents. The PSDF Safety Program has numerous worker safety and health programs to 

mitigate potential harm or exposure of employees such as: Respiratory Protection, 

Hearing Conservation, Bloodborne Pathogens, Scaffold Program, Fall Protection 

Program, Personal Protective Equipment, a Hazmat Response Team, Confined Space 

Rescue Team, a First Responder Group, and employees trained in First Aid and CPR. 

There is always some potential for a worker to be exposed to chemicals. Section 4.5 

discusses the changes in hazardous materials use and subsequent risk to employees as a 

result of the proposed action. Changes to existing processes and equipment, addition of 

new processes or equipment, or introduction of new chemicals (solvents, sorbents, etc.) 

would require appropriate training of workers to allow operation and testing of the 

equipment and otherwise ensure affected personnel are informed of the changes or 

additions (Southern Company, 2008). In addition, the existing Material Safety Data 

Sheets and Personal Protective Equipment requirements would remain in place to ensure 

that employees are prepared to handle any required chemicals. As discussed in Section 

4.3, operational PSDF air emissions are not expected to change as a result of the CRC. It 

can be expected that workers will continue to be exposed to the same ambient air quality 

as they currently are. Additionally, operational noise levels are not expected to change; 

hearing protection will continue to be required in all high noise areas (Southern 

Company, 2008). 

The existing PSDF has not had a lost-time injury since the safety record began on August 

1, 1995. Job Safety Briefings are held before any non-routine job begins on a daily basis 

or as needed. It can be assumed that these procedures will remain in tact and that all 

personnel will be properly trained or briefed to ensure their safety while operating the 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-12 September 2008 

new facility components. Given the small size of risks and additional exposures, overall 

impact to human health from the proposed action can be expected to be adverse, longterm and negligible to minor. 

4.6.2 Alternative 2: No Action 

Under the No Action Alternative, risks from accidents, exposure to process gases as well 

as to air emissions throughout the construction process would not occur. Any emissions 

released from the PSDF from alternative research projects can be expected to be at the 

level they’re at now, or less, with the addition of efficiency upgrades. The overall impacts 

to human health from the No Action Alternative can be expected to be negligible. 

4.7 CULTURAL RESOURCES

4.7.1 Alternative 1: Proposed Action 

Consultation regarding the Proposed Action was initiated with the Alabama State 

Historic Preservation Officer (SHPO) on June 2, 2008. On June 27, 2008, the Alabama 

Deputy SHPO sent a reply letter stating that “the project activities will have no effect on 

any known cultural resources listed on or eligible for the National Register of Historic 

Places”. A full copy of this response letter can be found in Appendix B. It is anticipated 

that the proposed project would not result in any impacts to cultural or historic resources, 

as no previously undisturbed land would be developed. 

Should any item of potential archaeological significance be discovered, however, during 

development of the sites to be used for the CRC CO2 capture R&D efforts, the SHPO 

would be notified immediately. If any historically or culturally significant materials or 

artifacts were to be unearthed, activities would halt immediately and not resume until 

consultation with the SHPO has been completed, in accordance with 36 CFR 800.13. 

With the understanding that the preceding steps would be taken, and that the potential for 

the discovery of any significant cultural resources is extremely low, it is anticipated that 

no impacts to cultural resources would occur. 

4.7.2 Alternative 2: No Action 

Under the No Action Alternative, no new areas of the PSDF or Plant Gaston Unit 5 

would be developed as part of the CRC, and as a result, no impacts are anticipated to 

occur to cultural or historic resources. 

4.8 SOCIOECONOMICS

The threshold level of significance for socioeconomic resources is the potential of the 

project to result in a substantial population or employment increase or decrease in the 

region of influence. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-13 September 2008 

4.8.1 Alternative 1: Proposed Action 

As PSDF’s mission is changed to that of PSDF-CRC, and as new R&D efforts are 

designed and implemented as part of the Proposed Action, changes to the number of 

design and construction personnel will occur on a temporary basis. However, any 

increases would not be different than historical employment levels at the PSDF, when 

larger projects have been implemented. Historically PSDF has employed approximately 

32 construction workers at any one time for normal workload. This number has 

increased to approximately 70 construction workers during peak construction periods. 

No change is expected for the various construction phases of the CRC. Therefore, it is 

expected the temporary workforce population would vary from approximately 30 to 

approximately 70. The initial construction work for the CRC would last approximately 3 

months and future construction phases would last approximately 3 months as well. 

The implementation of the Proposed Action would also result in the hiring of up to 10 

full-time process engineers and systems operators for the 5 year project period. This 

slight increase in employment levels may have a slight, beneficial impact on area 

socioeconomics. Overall impacts to socioeconomics from the implementation of the 

Proposed Action are expected to be beneficial and minimal. Employment levels are 

anticipated to be within the typical fluctuation of workforce numbers seen at this site. 

4.8.2 Alternative 2: No Action 

It is not known at this time whether or not cancellation of the CRC project would 

translate into potential site layoffs. If any layoffs were to occur, the impacts from the No 

Action alternative would be adverse and in proportion to the scaledown of the site’s 

workforce. Additionally, the No Action alternative would not have the benefits of 

potentially developing more cost-effective and affordable CO2 capture technology, which 

could ultimately result in widespread beneficial economic impacts to coal based power 

generation facilities which seek to reduce their CO2 emissions. 

4.9 CUMULATIVE IMPACTS

CEQ regulations (40 CFR 1508.7) require an analysis of the cumulative impacts resulting 

from the incremental impact of an action when added to other past, present, and 

reasonably foreseeable future actions, regardless of who undertakes these other actions. 

Cumulative impacts can result from individually minor, but collectively significant, 

actions. This cumulative impacts section of the EA addresses only the cumulative effects 

arising from considering the Proposed Action in combination with other ongoing actions 

at, or in the vicinity of, the PSDF and Plant Gaston. 

No development, with the exception of what has been disclosed within this EA as part of 

the CRC, is proposed to take place at the PSDF within the foreseeable future. The only 

developments proposed at Plant Gaston are a new limestone processing plant and a new 

air siren system. Cumulatively, the impacts of implementing the Proposed Action at Plant 

Gaston, in conjunction with the other developments proposed there, are considered 

negligible. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-14 September 2008 

In a regional context, the greater Wilsonville area is experiencing a slight increase in 

population and growth, and it can be expected that there will be some amount of new 

development taking place in the region in the foreseeable future. However, the 

development impacts of the CRC are minimal, as less than one acre of previously 

disturbed land is proposed to be developed. As a result, no cumulative impacts to land 

use, or to soils and geology, are anticipated to result within a regional context. 

Water quality in both major surface waterbodies adjacent to the PSDF and Plant Gaston 

sites, the Yellowleaf Creek and the Coosa River, are currently impaired. TMDLs 

developed for the waterbodies address the lack of DO by putting restrictions on new 

sources of ammonia and oxygen-depleting nutrients in the waterbodies, and, they address 

the elevated level of PCBs by restricting new sources of PCBs. The proposed project is 

not anticipated to contribute new or elevated sources of substances that decrease the DO 

or elevate the PCB concentrations in the waterbodies. However, continued operation and 

discharge of various process waters and wastewaters from both the PSDF and Plant 

Gaston facilities continues to pose a threat to water quality in the vicinity of the project 

area. Conversely, continued operation of the intake structure provides important habitat 

for a federally endangered species that requires turbulent waters for survival, in an area 

which has been so extensively hydrologically modified that almost no free flowing 

conditions of the Coosa River exist near the project site. As a result of the incremental 

contribution of water intake and discharge from the facility operation proposed under this 

action, both long-term minute adverse and beneficial cumulative impacts to water 

resources and biological resources would result, respectively. 

On an airshed level, the State of Alabama takes into account the effects of all past, 

present, and reasonably foreseeable emissions during the development of the SIP. The 

State of Alabama accounts for all significant stationary, area, and mobile emission 

sources in the development of this plan. Estimated emissions generated by the Proposed 

Action would be de minimis and would not be regionally significant. Therefore, it is not 

anticipated that the Proposed Action would contribute significantly to adverse cumulative 

effects to air quality. On an even larger scale, the proposed project has the potential to 

contribute long-term, major beneficial impacts towards the future reduction of domestic 

and global CO2 emissions by providing key R&D activities in the efforts to develop costeffective and efficient CO2 capture technology. 

4.10 MITIGATION MEASURES

All future actions proposed as part of this project should employ the following mitigation 

measures to ensure that environmental impacts from construction and operation of the 

project are minimized to the greatest extent possible. Adherence to the following 

mitigation measures, in conjunction with adherence to all applicable and appropriate 

local, state, and federal regulations and permits, should ensure that the development and 

operation of the PSDF-CRC has no significant impacts to the environment. 

Soil 

• Incorporate and maintain BMPs at all construction sites; BMPs typically consist 

of various erosion and sediment control measures such as silt fences, straw bales, 

and other temporary measures to be placed in ditches and along portions of the 
U.S. Department of Energy Carbon Research Center at PSDF 

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Environmental Consequences 4-15 September 2008 

site perimeter to control erosion during construction activities. These temporary 

erosion prevention measurements should be maintained in place until the site 

vegetation is firmly established and soil has stabilized. Regular inspections of the 

erosion and sediment control measures should be performed after any storm 

event. 

• Store and maintain all fuels in a designated equipment staging area to reduce the 

potential for soil contamination. Closely monitor the fueling operation, and have 

an emergency spill kit containing absorption pads, absorbent material, a shovel or 

rake, and other cleanup items, readily available on site in the event of an 

accidental spill. 

Water Resources 

• Place erosion control structures around construction site perimeters during all 

construction and demolition activities. To the extent practicable, sediment runoff 

from the site should be captured and prevented from entering area surface water 

bodies. 

Air Quality 

• Continue to implement reasonable measures, such as applying water to exposed 

surfaces or stockpiles of dirt, when windy and/or dry conditions promote 

problematic fugitive dust emissions. Adhering to these BMPs would minimize 

any fugitive dust emissions. 

Waste Management 

• Continue to recycle and/or reuse as many materials as possible during the 

construction and operation phases of the project in order to minimize the amount 

of waste generated by the facilities. All hazardous waste and materials stored 

and/or generated at the development should be properly and uniformly labeled 

and housed in appropriate storage facilities. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Preparers 5-1 September 2008 

5.0 LIST OF PREPARERS 

The contractor responsible for preparing this EA: 

Mangi Environmental Group 

 7915 Jones Branch Drive, Suite 2300 

 McLean, VA 22102 

 703-760-4801 

The following Mangi Environmental Group personnel and subcontractors were principal 

contributors to this EA: 

Name and Document Contribution Associated Professional Expertise

Anna Lundin, 

MS Environmental Engineering 

Project Management, Waste/Hazmat 

Mgmt, Cultural Resources 

10 years experience: Watershed analyses, Phase I/II 

environmental site assessments, Environmental 

Baseline Surveys, EAs/EISs 

Kezee Procita, 

Masters in Environmental Studies 

Soil, Water, Biological Resources 

6 years experience: Wetlands studies, statistics, 

GIS, groundwater studies, geological and 

hydrogeological science 

Mark Blevins, MS Geography 

Mapping, GIS-based data & analysis 

5 years experience: GIS specialist: ArcGIS 8.3 - 

9.1, ArcVIEW 3.2, GPS: Trimble GeoExplorer, 

Garmin GPS III – V Plus, Pathfinder Office 

software 

Jim Mangi, Ph.D., Ecology 

Project Oversight 

30 years experience: recognized as a NEPA expert; 

has assisted the U.S. Army and five other Federal 

and State agencies in the development of their 

NEPA regulations and guidance. 

Timothy Lavallee, P.E. 

LPES, Inc. Engineering and Planning 

Air Quality

15 Years of Experience 

M.S., Environmental Health, Tufts University, 

Medford, Massachusetts. 

B.S., Mechanical Engineering, Northeastern 

University, Boston, Massachusetts. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

References 6-1 September 2008 

6.0 REFERENCES 

(ADCNR, 2008). Alabama Department of Conservation and Natural Resources. Upper 

Sipsey Fork. Outdoor Alabama. 2008. Accessed at: 

http://www.outdooralabama.com/Fishing/freshwater/where/rivers/usf/

(ADEM, No date-a). Alabama Department of Environmental Management. No date 

provided. Map of Alabama’s Surface Water Classifications: Coosa River. Accessed June 

2008 at: http://www.adem.state.al.us/WaterDivision/WQuality/WQUseClass.htm. 

(ADEM, No date-b). Alabama Department of Environmental Management. No date 

provided. Permitting Requirements: Construction & Non-coal, Non-metallic Mining, 

Processing Sites, and Associated Areas. Accessed June 2008 at: 

http://www.adem.state.al.us/FieldOps/Permitting/Construction/Construction.htm. 

(ADEM, 2007a). Alabama Department of Environmental Management. 2007. Alabama 

303(d) List for 2006. Accessed June 2008 at: 

http://www.adem.state.al.us/WaterDivision/WQuality/303d/2006%20Alabama%20303(d

)%20List%20(Final).pdf. 

(ADEM, 2007b). Alabama Department of Environmental Management. 2007. Alabama 

Power Company - Gaston Final NPDES Permit. Wilsonville, Alabama. 

(ADEM, 2006a). Alabama Department of Environmental Management. 2006. Integrated 

Water Quality Monitoring & Assessment Report. Accessed June 2008 at: 

http://www.adem.state.al.us/WaterDivision/WQuality/305b/WQ305bReport.htm. 

(ADEM, 2006b). Alabama Department of Environmental Management. 2006. NPDES 

Final Draft Permit for Power Systems Development Facility. ADEM Water Division. 

Wilsonville, Alabama. 

(ADEM, 2005). Alabama Department of Environmental Management. 2005. The 

Redesignation Request and Maintenance Demonstration: Birmingham 8-Hour Subpart 1 

Ozone Nonattainment Area. 

(ADEM, 2004). Alabama Department of Environmental Management. 2007. Tallapoosa 

River Basin Management Plan. Section 3: Regulatory Considerations – Water 

Withdrawals. Accessed June 2008 at: 

http://www.adem.state.al.us/Education%20Div/Nonpoint%20Program/ManagePlan/Basin

Plans/Tallapoosa/007_Section3.pdf. 

(ADEM, 2003). Alabama Department of Environmental Management. 2003. Major 

Source Operation Permit Power Systems Development Facility Wilsonville, Alabama. 

Permit Number 411-0023. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

References 6-2 September 2008 

(AHC, 2008). Alabama Historical Commission. 2008. Historical Sites. Accessed at: 

http://www.historical.alabama.gov/statemap.aspx?sm=g_a

(Alabama Power, 2007). Alabama Power. 2007. Lay Dam. Accessed June 2008 at: 

http://www.alabamapower.com/lakes/lay.asp. 

(Alabama Power Company, 2003). Alabama Power Company. 2003. Coosa/Warrior 

Relicensing Project, E4 – Water Quantity, Water Use, and Water Withdrawals. Accessed 

June 2008 at: 

http://www.alabamapower.com/hydro/pdfs/Water_Withdrawal_Issue_Report.pdf. 

 

(CARB, 2007). California Air Resource Board. 2007. Regulation for the Mandatory 

Reporting of Green House Gas Emissions (Draft). 

(CRBI, No date). Coosa River Basin Initiative. No date provided. About the Coosa River. 

Accessed June 2008 at: http://www.coosa.org/about-the-coosa. 

(Davis and Cornwell, 1998). Davis, Mackenzie and Cornwell, David. 1998. Introduction 

to Environmental Engineering, Third Edition. Boston, MA; McGraw Hill Companies, 

Inc. 

(DOE, 2008). U.S. Department of Energy, Office of Fossil Energy, National Energy 

Technology Laboratory. About NETL: Mission and Overview. Accessed June 2008 at: 

http://www.netl.doe.gov/about/mission.html

(DOE, 2007). U.S. Department of Energy, Office of Fossil Energy, National Energy 

Technology Laboratory. Carbon Sequestration Technology Roadmap and Program Plan. 

April 2007. 

(DOE, 1999). U.S. Department of Energy, Federal Energy Technology Center. Power 

Systems Development Facility. Environmental Assessment. Update to DOE/EA-0865. 

February, 1999. 

(DOE, 1993). U.S. Department of Energy, Morgantown Energy Technology Center. 

Power Systems Development Facility. Environmental Assessment. DOE/EA-0865. June, 

1993. 

(EIA, 2008). Energy Information Administration; Official Energy Statistics from the U.S. 

Government; USDOE. Annual Energy Outlook 2008 (Revised Early Release). March 

2008. Report #:DOE/EIA-0383(2008). Accessed at: http://www.eia.doe.gov/oiaf/aeo/

(NRCS, 2007). Natural Resources Conservation Service. 2007. Official Soil Series 

Description: Townley Series. Accessed June 2008 at: 

http://www2.ftw.nrcs.usda.gov/osd/dat/T/TOWNLEY.html. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

References 6-3 September 2008 

(OSHA, 2008). Occupational Safety and Health Administration – US Department of 

Labor. Occupational Noise Exposure: 29 CFR 1910.95. Accessed June 2008 at: 

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9735&p_table=STAN

DARDS

(Rivers of Alabama, 2008). Rivers of Alabama. The Coosa River; Physical Description 

and Species Diversity. Accessed June 2008 at: 

http://www.riversofalabama.org/Coosa/COO_Species_Diversity.htm. 

(Southern Company, 2008). Southern Company, Inc. PSDF-CRC Draft Environmental 

Questionnaire. June, 2008. 

(Southern Company, 2007). Southern Company, Inc. Power Systems Development 

Facility; Overview. 2007. Accessed at: http://psdf.southernco.com/overview.html

(USCB, 2006a). US Census Bureau. Shelby County, Alabama Fact Sheet. Accessed June 

2008 at: 

http://factfinder.census.gov/servlet/ACSSAFFFacts?_event=Search&geo_id=&_geoCont

ext=&_street=&_county=shelby+county&_cityTown=shelby+county&_state=04000US0

1&_zip=&_lang=en&_sse=on&pctxt=fph&pgsl=010. 

(USCB, 2006b). US Census Bureau. Talladega County, Alabama Fact Sheet. Accessed 

June 2008 at: 

http://factfinder.census.gov/servlet/ACSSAFFFacts?_event=Search&geo_id=05000US01

117&_geoContext=01000US%7C04000US01%7C05000US01117&_street=&_county=t

alladega+county&_cityTown=talladega+county&_state=04000US01&_zip=&_lang=en&

_sse=on&ActiveGeoDiv=geoSelect&_useEV=&pctxt=fph&pgsl=050&_submenuId=fact

sheet_1&ds_name=ACS_2006_SAFF&_ci_nbr=null&qr_name=null®=null%3Anull

&_keyword=&_industry=. 

(USCB, 2000a). US Census Bureau. 2000 Coosa County, Alabama Fact Sheet. Accessed 

June 2008 at: 

http://factfinder.census.gov/servlet/SAFFFacts?_event=Search&geo_id=&_geoContext=

&_street=&_county=coosa+county&_cityTown=coosa+county&_state=04000US01&_zi

p=&_lang=en&_sse=on&pctxt=fph&pgsl=010&show_2003_tab=&redirect=Y (Coosa 

County) 

(USCB, 2000b). US Census Bureau. 2000. Wilsonville town, Alabama Factsheet. 

Accessed June 2008: http://factfinder.census.gov/servlet/QTTable?_bm=y&-

geo_id=16000US0182848&-qr_name=DEC_2000_SF3_U_DP3&-

ds_name=DEC_2000_SF3_U&-_lang=en&-redoLog=false&-_sse=on. 

(USCB, 2000c). US Census Bureau. 2000. State of Alabama Factsheet. Accessed June 

2008 at: 

http://factfinder.census.gov/servlet/SAFFFacts?_event=Search&geo_id=05000US01037

&_geoContext=01000US%7C04000US01%7C05000US01037&_street=&_county=&_ci
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

References 6-4 September 2008 

tyTown=&_state=04000US01&_zip=&_lang=en&_sse=on&ActiveGeoDiv=geoSelect&

_useEV=&pctxt=fph&pgsl=050&_submenuId=factsheet_1&ds_name=DEC_2000_SAF

F&_ci_nbr=null&qr_name=null®=null%3Anull&_keyword=&_industry= 

(USEPA, 2008). U.S. Environmental Protection Agency. 2008. USEPA AirDATA 

Website. URL: http:www.epa/air/data. Accessed: June 13, 2008. 

(USEPA, 2007a). U.S. Environmental Protection Agency. 2007. Inventory of US 

Greenhouse Gas Emissions and Sinks: 1990–2005. EPA 430-R-07-002. April 15. 

(USEPA, 2007b). U.S. Environmental Protection Agency. 2007. Climate Change 

Website. URL: http://www.epa.gov/climatechange/basicinfo.html#emissions. Accessed 

August 31, 2007. 

(USEPA, 2006). U.S. Environmental Protection Agency. 2006. Wetland Types. Accessed 

June 2008 at: http://www.epa.gov/owow/wetlands/types/. 

(USEPA, 2004). US Environmental Protection Agency. 2004. TMDL – Coosa River 

Listed Water Information for the 2004 Cycle. Accessed June 2008 at: 

http://oaspub.epa.gov/tmdl/enviro.control?p_list_id=GA-R031501050104&p_cycle=. 

(USGS, 2008). United States Geological Survey. 2008. Surface-Water Monthly Statistics. 

USGS Gauge 02407526 Coosa River at Gaston Steam Plant. Accessed June 2008 at: 

http://waterdata.usgs.gov/nwis/monthly/?referred_module=sw&site_no=02407526&

amp;por_02407526_1=847064,00065,1,1993-10,2007-

09&format=html_table&date_format=YYYY-MMDD&rdb_compression=file&submitted_form=parameter_selection_list. 

(UNFCC, 2007). United Nations Framework Convention on Climate Change. 2007. 

Kyoto Protocol Reference Manual on Accounting of Emissions and Assigned Amounts.

(Westervelt Company, 2007). The Westervelt Company. 2007. Yellowleaf Mitigation 

Bank Opens in Shelby County, Alabama. Accessed June 2008 at: 

http://www.westervelt.com/environmental-banking/yellowleaf-mitigation-bank-opens-inshelby-county-al.html. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix A A-1 September 2008 

APPENDIX A 

AIR EMISSIONS CALCULATIONS 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix A A-2 September 2008 

Construction Emissions 

Table A-1. Heavy Equipment

Construction Equipment Use

Equipment Type 

Number 

of Units 

Days 

on Site 

Hours 

Per Day 

Operating 

Hours 

Excavators Composite 2 60 7 840 

Rubber Tired Dozers Composite 1 60 7 420 

Graders Composite 1 60 7 420 

Trenchers Composite 1 60 7 420 

Concrete/Industrial Saws Composite 1 30 7 210 

Plate Compactors Composite 2 60 7 840 

Air Compressors 2 90 4 720 

Cement and Mortar Mixers 2 90 7 1260 

Cranes 1 120 7 840 

Generator Sets 2 180 7 2520 

Tractors/Loaders/Backhoes 2 180 7 2520 

Paving Equipment Composite 1 30 7 210 

Pavers Composite 1 30 7 210 

 

Construction Equipment Emission Factors (lbs/hour) 

Equipment CO NOx VOC SOx PM10 PM2.5 CO2

Excavators Composite 0.5828 1.3249 0.1695 0.0013 0.0727 0.0727 119.6 

Rubber Tired Dozers Composite 1.5961 3.2672 0.3644 0.0025 0.1409 0.1409 239.1 

Graders Composite 0.6561 1.6191 0.1936 0.0015 0.0840 0.0840 132.7 

Trenchers Composite 0.5080 0.8237 0.1851 0.0007 0.0688 0.0688 58.7 

Concrete/Industrial Saws Composite 0.4411 0.7263 0.1460 0.0007 0.0610 0.0610 58.5 

Plate Compactors Composite 0.0263 0.0328 0.0052 0.0001 0.0021 0.0021 4.3 

Air Compressors 0.3782 0.7980 0.1232 0.0007 0.0563 0.0563 63.6 

Cement and Mortar Mixers 0.0447 0.0658 0.0113 0.0001 0.0044 0.0044 7.2 

Cranes 0.6011 1.6100 0.1778 0.0014 0.0715 0.0715 128.7 

Generator Sets 0.3461 0.6980 0.1075 0.0007 0.0430 0.0430 61.0 

Tractors/Loaders/Backhoes 0.4063 0.7746 0.1204 0.0008 0.0599 0.0599 66.8 

Paving Equipment Composite 0.4616 0.9857 0.1479 0.0008 0.0681 0.0681 69.0 

Pavers Composite 0.5874 1.0796 0.1963 0.0009 0.0769 0.0769 77.9 

Source: CARB, 2007. 

Construction Equipment Emissions (tons) 

Equipment CO NOx VOC SOx PM10 PM2.5 CO2

Excavators Composite 0.2448 0.5565 0.0712 0.0006 0.0305 0.0305 50.2241 

Rubber Tired Dozers Composite 0.3352 0.6861 0.0765 0.0005 0.0296 0.0296 50.2122 

Graders Composite 0.1378 0.3400 0.0406 0.0003 0.0176 0.0176 27.8761 

Trenchers Composite 0.1067 0.1730 0.0389 0.0001 0.0145 0.0145 12.3315 

Concrete/Industrial Saws Composite 0.0463 0.0763 0.0153 0.0001 0.0064 0.0064 6.1387 

Plate Compactors Composite 0.0111 0.0138 0.0022 0.0000 0.0009 0.0009 1.8118 

Air Compressors 0.1361 0.2873 0.0444 0.0003 0.0203 0.0203 22.8986 

Cement and Mortar Mixers 0.0282 0.0414 0.0071 0.0001 0.0028 0.0028 4.5663 

Cranes 0.2525 0.6762 0.0747 0.0006 0.0300 0.0300 54.0402 

Generator Sets 0.4361 0.8795 0.1354 0.0009 0.0542 0.0542 76.8508 

Tractors/Loaders/Backhoes 0.5120 0.9759 0.1517 0.0010 0.0754 0.0754 84.1760 

Paving Equipment Composite 0.0485 0.1035 0.0155 0.0001 0.0072 0.0072 7.2398 

Pavers Composite 0.0617 0.1134 0.0206 0.0001 0.0081 0.0081 8.1833 

Total Equipment Emissions 2.3568 4.9228 0.6941 0.0046 0.2975 0.2975 406.5493 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix A A-3 September 2008 

Table A-2. Painting

VOC Content 1.25 lbs/gallon 

Coverage 400 sqft/gallon 

Emission Factor 0.003125 lbs/sqft 

Building/Facility Wall Surface VOC [lbs] VOC [tons] 

Gas Analyzer Building 4500 14.1 0.0070 

Total 4500 14.1 0.0070 

Table A-3. Transportation of Concrete

Volume of Concrete (Cubic Yards) 538.9 Pad 1 Pad 2 Pad 3 Pad 4 

Truck Capacity (Cubic Yards) 10 Length 20 30 50 50 

Number of Deliveries 54 Width 40 15 50 150 

Number of Trips 2 Depth 2 1 5 50 

Miles Per Trip 30 Volume 59.3 16.7 463.0 

Total Miles 3233.3 

Pollutant CO NOx VOC SOx PM10 PM2.5 CO2

Emission Factor (lbs/mile) 0.0136 0.0446 0.0035 0.0000 0.0022 0.0019 4.2 

Total Emissions (lbs) 44.02 144.14 11.37 0.13 6.97 6.14 13650.6 

Total Emissions (tons) 0.0220 0.0721 0.0057 0.0001 0.0035 0.0031 6.8 

Source: CARB, 2007. 

Table A-4. Delivery of Equipment and Supplies

Number of Deliveries 2 

Number of Trips 2 

Miles Per Trip 30 

Days of Construction 230 

Total Miles 27600 

Pollutant CO NOx VOC SOx PM10 PM2.5 CO2

Emission Factor (lbs/mile) 0.0219 0.0237 0.0030 0.0000 0.0009 0.0007 2.7 

Total Emissions (lbs) 605.80 654.47 82.60 0.71 23.63 20.41 75056.4 

Total Emissions (tons) 0.3029 0.3272 0.0413 0.0004 0.0118 0.0102 37.5 

Source: CARB, 2007. 

Table A-5. Worker Commutes

Number of Workers 20 

Number of Trips 2 

Miles Per Trip 30 

Days of Construction 230 

Total Miles 276000 

Pollutant CO NOx VOC SOx PM10 PM2.5 CO2

Emission Factor (lbs/mile) 0.0105 0.0011 0.0011 0.0000 0.0001 0.0001 1.1 

Total Emissions (lbs) 2911.37 304.40 297.86 2.97 23.48 14.61 303470.9 

Total Emissions (tons) 1.4557 0.1522 0.1489 0.0015 0.0117 0.0073 151.7 

Source: CARB, 2007. 

Table A-6. Total Construction Emissions (tons)

Activity/Source CO NOx VOC SOx PM10 PM2.5 CO2

Construction Equipment 2.3568 4.9228 0.6941 0.0046 0.2975 0.2975 406.5 

Painting 0.0000 0.0000 0.0070 0.0000 0.0000 0.0000 0.0 

Transportation of Concrete 0.0220 0.0721 0.0057 0.0001 0.0035 0.0031 6.8 

Delivery of Equipment and Supplies 0.3029 0.3272 0.0413 0.0004 0.0118 0.0102 37.5 

Worker Commutes 1.4557 0.1522 0.1489 0.0015 0.0117 0.0073 151.7 

Total Construction Emissions 4.1374 5.4743 0.8971 0.0065 0.3245 0.3181 602.6 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix A A-4 September 2008 

Operational Emissions 

The tables below show the potential emissions calculations and the actual emissions 

calculations from 2003 through 2007 for Nitrogen Dioxide, Sulfur Dioxide, Carbon 

Monoxide, Particulate matter, and Volatile Organic Compounds (VOC). The calculations 

are based on emission factors obtained from air compliance testing for the respective 

years shown in Table A-7. The actual emissions are shown in Table A-9. The average of 

the Emission Factors was then used to calculate potential emissions shown in Table A-8. 

Based on the average emission factors for each of the respective pollutants, Nitrogen 

Dioxide and Sulfur Dioxide potential to emit exceeds the 100 tons per year threshold. 

Therefore the facility must submit a permit application for a major source. However, the 

facility could opt for a Synthetic Minor Operation Permit (SMOP) should it elect to take 

restrictions to keep Sulfur Dioxide and Nitrogen Dioxide below the 100 tpy thresholds. 

The PSDF has elected not to apply for the SMOP even though the reduced hours of 

operations over the past five years show a trend that could support the SMOP. 

Table A-7. Five Year Hourly Emission Rates in Pounds per Hour for NO2, SO2, CO, 

PM, and VOCs, 2003 through 2007 and Five Year Average 

Pollutant 2003 2004 2005 2006 2007 Total Five Year Average 

NO2 15.5 21.6 26.7 19.4 32.9 116.1 23.2 

SO2 21.8 17.3 11.9 16.3 18.6 85.9 17.2 

CO 0.1 0 0 0.1 0 0.20 0.04 

PM 6.1 4.2 0.3 1.1 0.3 12.0 2.4 

VOC 0.1 0 2.0 0 1.2 3.3 0.7 

Table A-8. Five Year Emission Summaries in Tons per Year, 2003 through 2007 and 

Five Year Average 

Pollutant 2003 2004 2005 2006 2007 Total Five Year Average 

NO2 23.3 16.1 23.7 14.7 12.3 90.1 18.0 

SO2 14.7 14.7 10.9 7.9 8.5 56.7 11.3 

CO 0.03 0.22 0 0.03 0.03 0.4 0.08 

PM 3.2 3.7 0.5 0.4 0.4 12.8 2.6 

VOC 0.06 0.02 1.7 0.8 0.1 2.6 0.5 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix A A-5 September 2008 

Table A-9. Potential Total Facility Emissions versus Actual Total Facility Emissions 

in Tons per Year 

KBR Process Alternate (Foster Wheeler) 

Process 

Total Facility5 

Pollutant Potential 

1 

Actual 

2 

Potential 3 Actual 4 Potential Actual

NO2 101.6 18.0 86.3 0 187.9 18.0 

SO2 75.3 11.3 47.7 0 123.0 11.3 

CO 0.2 0.06 0.9 0 1.1 0.06 

PM 10.5 1.6 8.8 0 19.3 1.6 

VOC 3.1 0.5 0 0 3.1 0.5 

1. Potential KBR process emissions are calculated from average emission factors from compliance 

tests from 2003 to 2007: 

NO2 = 23.2 lbs/hr x 24 hr/day x 365 days/yr x 1 Ton/2000 lbs = 101.6

 SO2 = 17.2 lbs/hr x 24 hr/day x 365 days/yr x 1 Ton/2000 lbs = 75.3

 CO = 0.04 lb/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 0.2

 PM = 2.4 lbs/hr x 24 hrs/day x 365 days/yr x 1Ton/2000 lbs = 10.5

 VOC = 0.7 lb/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 3.1

2. The KBR process actual annual emissions are the average annual emissions from 2003 to 2007. 

3. During one particular compliance test, syngas was produced in the KBR gasifier and sent to the 

combustion turbine. These emissions are used as representative of the alternate (Foster Wheeler) 

process had it operated : 

NO2 = 19.7 lbs/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 86.3

 SO2 = 10.9 lbs/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 47.7

 CO = 0.2 lb/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 0.9

 PM = 2.0 lbs/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 8.8

 VOC = 0 lbs/hr x 24 hrs/day x 365 days/yr x 1Ton/2000 lbs = 0

4. The Foster Wheeler process was not operated. 

5. Total facility emissions are the sum of KBR process emissions and alternate process emissions. 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix B B-1 September 2008 

APPENDIX B 

AGENCY CORRESPONDENCE 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix B B-2 September 2008 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix B B-3 September 2008 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix B B-4 September 2008 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix C C-1 September 2008 

APPENDIX C 

NOTICE OF AVAILABILITY 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix C C-2 September 2008 
U.S. Department of Energy Carbon Research Center at PSDF 

National Energy Technology Laboratory Environmental Assessment

Appendix C C-3 September 2008 
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