## 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 Asse ssment (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 Co mpany an electric generation and transmission holding company.

The CRC would be designed to test and evaluate ca rbon dioxide (CO 2 ) control te chnologies for power generation f acilities, including CO 2 capture solvents, mass-transfer devices, lower cost water-gas shift reactors, scaled-up memb rane technologies, a nd improved means of compressing CO 2 . Additionally, the CRC would eval uate methods to integrate CO 2 capture technologies with other coal-b ased power plant systems by te sting both pre-combustion and post-combustion technologies. Th e CRC would provide the capabi lity to test these systemsunder a wide range of fuels, including bituminous and sub-bi tuminous coals, lignites and biomass/coal mixtures. The go al of the CRC project is to accelerate the development, optimization, and commerci alization of viable CO 2 control technologies.

The proposed action currently being evaluate d is for DOE to provide, through a 60-month cooperative agreement with Sout hern 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 compone nts and advanced power systems, including carbon (in the form of CO 2 ) capture technology, under realistic conditions using coalderived gas streams. A small component of th e CRC project would be located adjacent to

the E.C. Gaston Electr ic Generating Plant.

No major modifications to existing operationa l 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 in stallation of new components on existing

facilities in order to resear ch and develop carbon capture technologies, and, the continued operation of the PSDF facility for a period of 5 years.

Public Participation:

DOE encourages public particip ation 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 newspape rs; The Birmingham News and the Shelby County Reporter (see Appendix C). The NOA wa s published for 3 consecutive days and 1 week, respectively, beginning July 27, 2008. C opies of the Draft EA were available through the Harrison Regional Library System at select locations c hosen by the regional library director and at the PSDF facility. Th e 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 comm ents on the Draft EA were received

and the EA was finalized.U.S. Department of Energy Carbon Rese arch 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 Ac tion 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 Stan dards 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 Mate rials 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..........................................................................4-4U.S. Department of Energy Carbon Rese arch 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 Mate rials 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 A IR E MISSIONS C ALCULATIONS
APPENDIX B A GENCY C ORRESPONDENCE APPENDIX C N OTICE OF A VAILABILITYU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Table of Contents iii September 2008 LIST OF FIGURES

F IGURE 1-1: P ROJECT V ICINITY M AP ............................................................................ 1-2

F IGURE 1-2: PSDF/P LANT G ASTON S ITE M AP .............................................................. 1-3

F IGURE 2-1: PSDF P ROCESS F LOW D IAGRAM .............................................................. 2-3

F IGURE 2-2: P RE -C OMBUSTION CO 2 C APTURE D IAGRAM ........................................... 2-5

F IGURE 2-3: P OST -C OMBUSTION CO 2 C APTURE D IAGRAM ......................................... 2-7

F IGURE 2-4: O XY -C OMBUSTION CO 2 C APTURE D IAGRAM .......................................... 2-8

F IGURE 3-1: S OIL M AP OF P ROJECT A REA .................................................................... 3-1

F IGURE 3-2: E XISTING G ROUNDCOVER AT P ROPOSED P ROJECT S ITE ( PHOTO ) ..........3-2

F IGURE 3-3: A QUATIC F EATURES OF P ROJECT A REA ................................................... 3-3

F IGURE 3-4: U NNAMED T RIBUTARY ( PHOTO ) ................................................................ 3-4

F IGURE 3-5: D ISCHARGE TO U NNAMED T RIBUTARY ( PHOTO ) ...................................... 3-5

LIST OF TABLES

T ABLE 3-1: NAAQS AND A REA A IR Q UALITY ............................................................... 3-8

T ABLE 3-2: R EGIONAL A IR E MISSIONS .......................................................................... 3-9

T ABLE 4-1: P ROJECT E MISSIONS C OMPARED TO A PPLICABILITY T HRESHOLDS .........4-5

T ABLE 4-2: A NNUAL E MISSIONS C OMPARED TO R EGIONAL E MISSIONS ......................4-6

T ABLE 4-3: A IR Q UALITY R EGULATORY R EVIEW ......................................................... 4-7U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Table of Contents iv September 2008 LIST OF ABBREV IATIONS/ACRONYMS

AAC Alabama Administrative Code ADEM Alabama Department of Environmental Management AQCR Air Quality Control Region AQCR 004 Metropolitan Birm ingham Intrastate AQCR

BACT Best Availabl e 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

CH 4 Methane

CO Carbon Monoxide

CO 2 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 MegawattU.S. Department of Energy Carbon Rese arch 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 Standa rds for Hazardous Air Pollutants NETL National Energy Technology Laboratory

NHPA National Histor ic Preservation Act

NNSR Nonattainment New Source Review

N 2 O Nitrous Oxide

NO 2 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

O 3 Ozone OSHA Occupational Safety and Health Administration

PFCs Perfluorocarbons

PM Particulate Matter

PM 10 Particulate Matter < 10 microns in diameter

PM 2.5 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

SF 6 Sulfur Hexafluoride

SHPO State Historic Preservation Office SIP State Implementation Plan

SO 2 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/m 3 micrograms per meter cubed

UNFCC United Nations Framewor k 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 CompoundU.S. Department of Energy Carbon Rese arch 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 En vironmental Assessm ent (EA) to anal yze the potential environmental impacts of providing funding fo r the proposed Carbon Research Center (CRC) project to be located at the existing Powe r Systems Develo pment Facility (PSDF) near Wilsonville, Alabama. The PSDF is operated by Southern Company Services, In c., a wholly-owned subsidiary of Southern Comp any, an electric generation and transmission company.

The CRC would be designed to test and evaluate Ca rbon Dioxide (CO 2 ) control te chnologies for power generation f acilities, including CO 2 capture solvents, mass-transfer devices, lower cost water-gas shift reactors, scaled-up memb rane technologies, a nd improved means of compressing CO 2 . Additionally, the CRC would ev aluate means to integrate CO 2 capture technologies with other coal-b ased power plant systems by te sting both pre-combustion and post-combustion technologies. Th e CRC would provide the capabi lity to test these systems under a wide range of fuels, including bituminous, sub-bi tuminous coals, lignites and biomass/coal mixtures. The go al of the CRC project is to accelerate the development, optimization, and commerci alization of viable CO 2 control technologies.

1.1 B ACKGROUND

The PSDF is located on 16.6 acres of land, lo cated 1.5 miles northeast of the town of Wilsonville in Shelby County, Alabama. The PS DF 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 temperat ure, pressure, and contaminant conditions of a commercial embodiment. The PSDF is operated by Southern Company as a unique Research and Development (R&D) test faci lity under partial funding from DOE, on behalf of several industrial pa rtners such as Electric Powe r Research Institute (EPRI), KBR, Inc., Lignite Energy Council, and Peabody Energy. The PSDF project was initiated September 14, 1990. Upon completion of constr uction and commissioning, the first coalfired operations began in August 1996. Th e current funded Cooperative Agreement is currently set to e xpire on September 30, 2008. Howeve r, 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, constr uction, 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 th e 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 CO 2 ) 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 EnergyCarbon Research Center at PSDFNational Energy Technology LaboratoryEnvironmental AssessmentIntroduction1-2September 2008Figure 1-1. Project Vicinity MapU.S. Department of EnergyCarbon Research Center at PSDFNational Energy Technology LaboratoryEnvironmental AssessmentIntroduction1-3September 2008Figure 1-2. PSDF/Plant Gaston Site MapU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Introduction 1-4 September 2008 No major modifications to existing operationa l 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 inst alled, tested, and further developed.

1.2 P URPOSE AND N EED

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 CO 2 control technologies for coal-based power generation facilities. The proposed ac tion 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 envir onmental, supply, and re liability constraints of producing and using fossil resources, and, to develop efficient and effective CO 2 capture systems, which is one of the funda mental goals of NETL’s Carbon Sequestration Program (DOE, 2008; DOE, 2007).

NETL is a DOE national laboratory which devo tes the majority of its funding to R&D partnerships with industry, uni versity, 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; impr oving the environmental acceptability of energy production and use; increasing the comp etitiveness 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 Inform ation 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 be fore 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 effici ency 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 ut ilized going forward, the size of the U.S.

demand for low-cost electric ity will mandate continued an d expanded use of domestic coal-based power generation.

Of concern to many, however, about the use of coal is its e nvironmental impact, including the amount of carbon dioxide, CO 2 , emitted per unit of power generation. Many link CO 2 emissions to concerns over global climate change. Because of the growing concentration of CO 2 in the atmosphere, there is a growing sense of urgency to legislate restrictions on the emissions of CO 2 . However, cost-eff ective technologies to

enable coal use with reduced emissions of CO 2 are not commercially viable or available. To keep coal in the U.S. generation mix, significant advancements in CO 2 captureU.S. Department of Energy Carbon Rese arch 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 CO 2 capture technologies that are integrated with coal-based electricity generation and to demonstrate re liable operations of the integrated system.

1.3 S COPE OF THE EA

This DOE EA analyzes the environmental imp acts 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 knowle dge of the comparative environmental consequences of the several courses of actio n available to them. NEPA studies, and the documents recording their resu lts, such as this EA, focu s on providing input to the particular decisions faced by the relevant officials.

This EA identifies, describes, and evalua tes 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 envi ronment and environmental consequences of the action will be described in both site-specific and regi onal contexts. In instances where mitigation measures may lessen any potentially adverse imp acts, this EA identifies such measures that should be implemented to further minimize environmental impacts.

The following resource areas have been iden tified for study within this EA: soil and geology, water resources (inc luding groundwater, wetlands, a nd floodplains), air quality, biological resources (including threatened and endangered species), waste and hazardous materials management, human health and safe ty, cultural resources, and socioeconomics.

Resource areas considered but dismissed fo r further analysis are discussed below.

1.3.1 Resource Topics Dismissed from Further Analysis

Several resource topics and i ssues 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 Ac tion; 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 Rese arch 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 Pa rk Service, the U.S. Fish and Wildlife Service, and the U.S. Forest Service. Th e Act protects select ed rivers, and their immediate environments, which possess outstan dingly remarkable scenic, recreational, geologic, fish and wildlife, hi storic, cultural or other sim ilar 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 th e William B. Bankhead National Forest, approximately 50 miles northwest of Birm ingham (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, wi th 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 covere d 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 Ac tion would involve the installation of two concrete pads (one is es timated to measure 20’ x 40’, and the other is estimated to measure 30’ x 15’) within the pr ocess test facility and support structure area of the PSDF site. Project activities at Plant Gaston would ta ke 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’ ar ea for infrastructure and support systems.

The Proposed Action consists of a relatively small footprint of new site development at previously disturbed areas, which are alrea dy designated and actively used for industrial operations. No onsite land use changes woul d result from implementation of the Proposed Action. Additionally, no ch anges to vicinity land us e or land use designations would occur. Therefore, this topic is dismissed from further analysis.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Introduction 1-7 September 2008 If the PSDF is at any point slated fo r 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 particip ation 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 bise cts the property. Under the Proposed Action, the PSDF and Plant Gaston are anticipated to re ceive 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 dimini shing the quality of the environment. Noise levels heard by humans are dependent on seve ral variables, including distance, ground cover, and objects or barriers between the sour ce and the receiver, as well as atmospheric conditions. Certain land uses, f acilities, and the people associat ed 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 Wilsonvill e Elementary School, located approximately 2

miles southwest of the site.

Neither construction nor opera tion activities associated wi th the Proposed Action are anticipated to be audible offsite of the Pl ant Gaston property. Noise associated with the proposed CRC would contribute only an incr emental 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 equipm ent. Hearing protection equipment would be required for workers when sound levels that exceed Federal workplace standards. Provided the preceding steps ar e taken, no impacts from nois e are anticipated from the proposed project, and this t opic is therefore dismisse d 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 hum an health or environmental effects of their programs and policies on minorities and low-income populations and communities. Although the nearest resi dential areas to the PSDF include some levels of both low-U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Introduction 1-8 September 2008 income and high-minority populations, these leve ls are not disproportionately high and the Proposed Action is not anticipated to im pact these areas in any event due to the distance of the proposed faciliti es, the high dispersion rate of air emissions in the area, and the low level of changes to the socio economic environment of the area anticipated from this project. Therefore, this topic is dismissed from further analysis.

Recreation

The project area is contained enti rely within a secured utility plant site; there is no public access to, or use of, the natural resources lo cated 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 emissi ons from facilities operations) are not anticipated to have any impact on recreati on activities offsite of the proposed project area. Because the proposed project woul d not appreciably diminish recreation opportunities or the quality of r ecreation 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, CE Q regulations (40 CF R Parts 1500-1508), and DOE regulations for compliance with NEPA ( 10 CFR Part 1021). The EA also addresses all applicable laws and regulations, in cluding but not limited to the following:

• National Historic Pres ervation 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 R ecovery Act (RCRA), and

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

Implementation of the Proposed Action will he lp the DOE meet the goals and challenges put forth by the National Energy Policy, enact ed by the Energy Policy Act, as amended.U.S. Department of Energy Carbon Rese arch 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 A LTERNATIVE 1: P ROPOSED A CTION

– I MPLEMENTATION OF THE C ARBON
R ESEARCH C ENTER AT PSDF

The Proposed Action, providi ng funding for the implementation and operation of the Carbon Research Center (CRC) at the PSDF, is consistent with DOE’s goal to reduce

CO 2 emissions from coal-fueled power plants . The CRC would be designed to test and

evaluate CO 2 control technologies, including CO 2 capture solvents, mass-transfer devices, lower cost water-gas shift reacto rs, scaled-up membrane technologies, and improved means of compressing CO 2 . The CRC would also evaluate means to integrate

CO 2 capture technologies with other coal-bas ed 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 fu els, 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 CO 2 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 re maining 20% project cost.

Background

The Proposed Action is consistent with th e objectives of DOE and NETL to provide lower cost, reliable electrici ty while decreasing environm ental emissions, including carbon dioxide, from coal-fired power gene rating 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 an alyses to remain the backbone of U.S. electricity supply through 2050 an d 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 CO 2 carbon capture and storage to the point of cost-eff ective 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 pot ential to significantly aid in shortening the timeline from concept to demonstr ation for carbon control technologies.

An integrated carbon capture design for advan ced power systems is in its infancy, having never been put into practice fo r coal-fired power ge neration, and is consid ered a high risk endeavor for the power indus try. 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 CO 2 capture technologies in the recent past, the R&D has been mostly limited to laborator y- or bench-scale evaluations under ideal

conditions. Continued research and development is needed to validate these lab-scale efforts by testing and evaluating the promis ing alternative technologies under fieldU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-2 September 2008 conditions that would be expected in a worki ng plant. Specifically, large-scale testing and evaluation is needed to verify that t echnology commercializat ion is feasible. The

establishment of the CRC at the PSDF will he lp to fill the existing gap between the successful small-scale R&D and the commercial applications.

The CRC is proposing a broad array of tec hnology development activities, including precombustion CO 2 capture for Integrated Gasification Combined Cycle (IGCC) plants, post-combustion CO 2 capture for Pulverized Coal (PC) plants; and, emerging technologies such as oxy-combustion of CO 2. These R&D activitie s would support a pathway to a cost-effective advanced coal-generating plant with CO 2 capture. The flexibility and scale of the proposed CRC wo uld be well suited to test gas cleanup and

CO 2 capture technologies. The CRC could test mu ltiple 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 pow er plants. The CRC would support the development of cost-effective CO 2 capture technologies for advanced coal-fueled power plants as well as existing and ne w pulverized coal power plants.

PSDF

The PSDF is located on 16.6 acres of land, north east of the town of Wilsonville in Shelby County, Alabama. The PSDF property is located within the Plant Gast on 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 i ndustrial partners under funding from DOE, as a unique R&D test facility. The facility is large enough to produce commercially representative data while remaining suffici ently small for economic operation as a test facility. The effectiveness of the PSDF has be en established. It has already fulfilled a major DOE objective by accelerating developmen t of the Transport Gasifier to the demonstration phase.

The PSDF provides an engineering-scale testi ng 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 gasifi cation process produces he at, and this heat is reclaimed by steam boilers. The PSDF is adap table to a variety of technology research needs. The components being te sted are integrated into the plant, which exposes them to the requirements and rigors of real plant ope rating conditions and allows them to be scaled-up with confidence for commercial de monstration. Integrated operations allow the effects of system interactions to be unde rstood. 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 aver age 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 Carbon Research Center at PSDFNational Energy Technology LaboratoryEnvironmental AssessmentProposed Action and Alternatives 2-3September 2008Figure 2-1. PSDF Process Flow Diagram(Source: Southern Company, 2007)U.S. Department of Energy Carbon Rese arch 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 ope rations 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 peri od. The initial EA for the development, construction, and operation of the PSDF was issued with a Fi nding of No Significant Impact (FONSI) in 1993. The proposed action currently being eval uated is for DOE to provide, through a 60- month cooperative agreement with Southern Co mpany Services, Inc., financial assistance for the proposed development of the CRC Project at the PSDF plant. If approved, DOE would provide project assist ance to test components and advanced power systems, including carbon (in the form of CO 2 ) capture technology, unde r realistic conditions using coal-derived gas streams. A small component of the CRC project, the postcombustion CO 2 capture component, would be located at Plant Gaston.

No major modifications to existing operationa l 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 modifi cations 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 or der 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 CO 2 capture for IGCC plants;

• Post-combustion CO 2 capture for PC plants; and,

• Emerging technologies such as oxy-combustion of CO 2.

Pre-combustion CO 2 Capture

Pre-combustion CO 2 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 m onoxide (CO) andminor amounts of other gaseous constituents. The syngas is then processed in a watergas-shift reactor, which converts the CO to CO 2 and increases the CO 2 and H 2 mole concentrations to 40 pe rcent and 55 percent, respectively, in the s yngas stream. At this point, the CO 2 has a high partial pressure (and hi gh chemical potential), which improves the driving force for various types of separation and cap ture technologies. After CO 2 removal, the H 2 rich syngas can be converted to electrical or thermal power. One application is to use H 2 as a fuel in a combustion tu rbine to generate electricity. Additional electricity is generated by extrac ting the energy from the combustion turbine flue gas via a heat reco very steam generator. Figure 2-2 shows the rese arch pathways being pursued for pre-combustion CO 2 capture.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-5 September 2008 Figure 2-2. Pre-Combustion CO 2 Capture Diagram (Source: DOE, 2007)

The backbone of the CRC pre-combustion CO 2 capture technology development will be a high-pressure, flexible facility designed to te st an array of solven ts and contactors in a

CO 2 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 immediatel y north of the existing facili ty on previously disturbed land to accommodate Water Gas Shift equipmen t, 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 ft 2 ), with approximately 2 ft. depth for construction. The pad for the Gas Analyzer Bu ilding is projected to be 30’ x 15’ (450 ft 2 ), 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 dura tion of construction of the new pads required would be approximately 2-3 weeks each.U.S. Department of Energy Carbon Rese arch 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 verifyi ng and scale-up of f undamental R&D capture projects. To support the CO 2 capture test facility, development of water-gas shift is necessary. Current technology for water-gas sh ift 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 operati on 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 mu st be optimized in addition to the capture block. Including

CO 2 capture in an advanced coal power plant will increase the pl ant cost of electricity, so opportunities to reduce cost in every part of th e process will be explored. Although highest priority will be given to low-cost CO 2 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 co st increases due to the addition of CO 2 capture. These cost reduction projects include technology de velopment for syngas cleanup, particulate control, fuel cells, sensors and controls, materials, and feeders.

Post-Combustion CO 2 Capture

Post-combustion CO 2 capture is primarily applicable to conventional coal-fired power generation, but may also be applied to gas- fired generation using combustion turbines. Any CO 2 emissions reduction plan for coal-fuele d power generating plants must include post-combustion capture from pulverized coal plants due to their predominance in thegeneration 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 lowe r heats of regeneration and more compact, lower cost equipment.

In a typical coal-fired power generation system, fuel is burn ed with air in a boiler to produce steam; the steam drives a turbin e to generate electricity, as shown in Figure 2-3

. The boiler exhaust, or flue gas, consists mostly of nitrogen (N 2 ) and CO 2 . Separating CO 2 from this flue gas stream is challengi ng for several reasons, including the dilute concentrations and low pressure that CO 2 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 CO 2 capture processes.

Absorption processes based on chemical solven ts 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 appli cations, and no definitive analysis exists as to the actual costs for a full-scale capture plan t. Preliminary analysis conducted at NETL

indicates that CO 2 capture via amine scrubbing and co mpression to 2,200 psia could raise the cost of electricity from a new supercritical PC power pl ant by 65 percent, from 5.0 cents/kilowatt-hour (kWh) to 8.25 cents/kWh. So me amines that may be used at PSDFCRC for CO 2 capture testing include Mono ethanol amine (MEA), Methyl diethanol amine (MDEA), and proprietary hindered amines (chemical compounds containing anU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-7 September 2008 amine functional group surrounded by a crowde d steric environment). However, most solvents have not yet been identified, but wi ll be selected as research progresses and suppliers develop suitable solvents.

Figure 2-3. Post-Combustion CO 2 Capture Diagram (Source: DOE, 2007)

Post-combustion CO 2 capture as part of the CRC will be studied at Alab ama Power’s Plant Gaston Unit 5, as Plant Gaston is a conventi onal pulverized coal fired plant. Unit 5 is a Combustion Engineering designed, 880 MW Tangentially fired boiler equipped with Selective Catalytic Reduction to reduce NO

x emissions, Hot ESP for Particulate Matter collection, and a Chiyoda Thor oughbred 121 (CT-121) Limest one Forced Oxidation FGD system for SO 2 control. The post-combustion CO 2 capture R&D efforts as part of the Proposed Action will be designed to support the evaluation of a dvanced solvents, processes and concepts, advanced solid sorbents, and me mbrane based processes, both at bench scale and with the potential fo r scale up to ~1-2 MW

e equivalent. The CRC will work with NETL, EPRI, vendors, technology developers, a nd national labs to identify new solvents, sorbents, membranes, gas contactors, and ot her processes and equipment that may prove beneficial and support the overall goal of the CRC.

To capture CO 2 from the flue gas at Plant Gaston, two larger trains (1-MW capacity each) and 5 smaller trains (about 1-MW capacity to tal for all five) would be installed adjacent to Unit 5 of the plant in a previo usly developed area, identified in Figure 1-2 . Land

disturbance at Plant Ga ston would consist of the installa tion of new concrete foundations on an approximately 50’ x 150’ area (7,500 ft 2 ), and the utilization of an additional 50’ x 50’ area (2,500 ft 2 ) for infrastructure and support syst ems. 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 ap proximately 50 ft and would include a combination of pilings, casings, and area pads . The duration of cons truction of the new pads would be approximately 2-3 weeks each. The total potential operating capacity of proposed post-combustion pilot project is li mited to about 2-MW equivalent, due to operating and infrastructure costs. This projec t could be operated for extensive periods to fully characterize performance on real coal fired flue gas.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Proposed Action and Alternatives 2-8 September 2008 Oxy-Combustion of CO 2

The objective of oxygen-fired combustion is to combust co al in an enriched oxygen environment using pure oxygen diluted with recycled CO 2 or H 2 O ( Figure 2-4 ). The oxygen in the mixture will be largely consum ed during the combustion reactions. Under these conditions, the primary products of combustion are CO 2 and H 2 O, and the CO 2 can be captured by condensing the wate r in the exhaust stream.

Figure 2-4. Oxy-Combustion CO 2 Capture Diagram (Source: DOE, 2007)

Operating the Transport Combustor as a pre ssurized, circulating fl uid bed combustor may provide a useful alternative to current oxy-combustion testing. The current testing programs for O 2 -blown coal combustion rely on CO 2 recycle to control the combustor temperature. Operations and Maintenance costs for the recycle compressors are high, because the required recycle CO 2 flowrate is very high, essentia lly the same as the rate of

N 2 in the air-blown combustion process. Temperature control by circulating solids for a Transport Combustor is simple and prove n and will greatly re duce the amount of CO 2 to be recycled resulting in co st savings. The CRC test plan includes system modeling and economic analysis to evaluate the commerci al feasibility of operating the Transport Combustor in oxy-combustion mode. If mode ling results are positiv e, 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 A LTERNATIVE 2: N O A CTION A LTERNATIVE

Under the No Action alternat ive, 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 w ould be cancelled.U.S. Department of Energy Carbon Rese arch 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 CO 2 capture solutions for coal-based power generation.

2.3 A LTERNATIVES C ONSIDERED BUT D ISMISSED

CEQ regulations for implementing NEPA requi re that Federal agencies explore and objectively evaluate all reasonabl e alternatives to a proposed action and to briefly discuss the rationale for eliminating any alternatives th at are not considered in detail. For this project, research into solvent, sorbent, membrane, and oxy-combustion systems as a means to capture CO 2 generated from coal-burning gene rating 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 su bstantial capital costs in order to perform the proposed R&D activities. The PSDF represents a full scale resear ch facility with nearly all required infrastr ucture for the proposed activities already established.

The solvent, sorbent, membrane, and oxy- combustion systems id entified under the Proposed Action represent the in itial range of alternative CO 2 capture systems currently

under consideration for research at the PSDF. The proposed CO 2 capture systems selected for initial evaluation as part of the Proposed Action were selected after 1) creating an inventory of pot ential 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 equipmen t areas, and 4) screening based on such factors as cost/benefit, likelihood of technical success, schedule, availa bility of data to support performance targets, timely developmen t to commercial scale, and ability to integrate into the PSDF.

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

continue to be screened a nd identified at least annually in order to accommodate new projects developed by DOE, i ndustry, and others, and, to acc ommodate 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 advi sory team consisting of DOE and other major co-funders of the proposed project.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-1 September 2008 3.0 AFFECTED ENVIRONMENT

3.1 G EOLOGY AND S OILS

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 ancien t 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 rela tively impermeable along these surfaces; thus, groundwater movement may be very slow throug h the shale. Both surface and subsurface information from available geological mapping so urces 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 in terpreted to be inactive and sealing.

The Coosa River Valley extends throughout th e northeastern portion of the state. Elevations near the project site typically rang e 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 Town ley-Urban Land Complex series ( see Figure 3-1 ).

Figure 3-1: Soil M ap of Project AreaU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-2 September 2008 F i g ure 3-2: Existin g Groundcover at Pro p osed Pro j ect Sit e 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 major ity 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 curren tly has 6-8 inches of aggregate on top of previous ly filled and graded land.

3.2 W ATER R ESOURCES

3.2.1 Surface Water

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

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

Yellowleaf Creek.

Coosa River

The Coosa River flows through a large section of Alabama; fr om 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 Pl ant 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 Ri ver 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 with in 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 (avera ging 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 pr ocess cooling water, potable water supplies, recreation, and hydropower generation. The designated uses es tablished by the Alabama Department of Environmental Management (ADEM) for the Coos a River within this reach are for Public Water Supply, Swimming, and Fish and Wildlife (ADEM, 2007a).U.S. Department of Energy Carbon Rese arch 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 am ount of a pollutant that a waterbody can receive and still meet water quality standard s for its designated use. Many pollutants have been assessed and given TMDLs, incl uding heavy metals, nutrients, turbidity and organic compounds. These water quality standa rds 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 Wa ters. It will then remain on this list until TMDL water quality standards are met. Curre ntly, 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 le vels of nutrients, organi c enrichment/dissolved oxygen (DO), and priority organi cs (PCBs). The most likely causes of these impairments are flow regulation and modi fication, contaminated sedime nts, and upstream sources (ADEM, 2007a). A TMDL to address the elev ated DO levels in the Coosa River was established in 2004, and a TMDL and commercia l fish ban to address the elevated PCB

levels was established in 2005.

Figure 3-3: Aquatic Feat ures of Project AreaU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-4 September 2008 F i g ure 3-4: Unnamed Tributar y 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 Yellowl eaf Creek flows on the southern side of the PSDF site and parallels the onsite rail road tracks prior to mee ting 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 lo cation for the PSDF and is therefore regularly monitored for a variety of potential contam inants (see below discussion under “Water Use and Discharge”). Currently, the discharg e in the unnamed tributary meets all of its National Pollution Discharge Elimination Sy stem (NPDES) water quality requirements.

Water Use & Discharge

The PSDF service water system consists of se parate 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 structur e 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 perm itting 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 Wate r Resources (OWR). A DBU requires the source and location of water withdrawal, the estimated amount as well as maximum quantity of the withdrawal a nd the primary use of the wate r to be diverted (ADEM, 2004). The Plant Gaston and PSDF property currently holds a joint approved DBU;

water withdrawal from the Plant Gaston inta ke 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 Rese arch 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, respecti vely (Alabama Power Company, 2003).

Water that is used throughout the plant processes is treate d 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 Cr eek and Coosa River receive discharged wastewater from Plant Gast on (ADEM, 2006b, 2007b). The existing facilities generate a total of approximately 825 m illion gpd from primarily the once-through cooling wastewater and ID Fan cooling wast ewater 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 retent ion of oil. This discharge occurs in comp liance with the facility’s existing NPDES perm it. Stormwater is conveyed to two drainage areas: one

north and one south of the facil ity. 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 re tainers 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 suspen ded solids, ammonia, and fecal coliform bacteria and dissolved oxygen; the wastewat er 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 co uld include runoff from the coal and limestone piles, process area wash water, sanitary wa stewater, process wastew ater, and general areaU.S. Department of Energy Carbon Rese arch 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, monitore d effluent characte ristics 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 dema nd, fecal coliform, ammonia, dissolved oxygen, total nitrogen, nitrat es, 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 Sh ale 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 ar e provided from two major aquifers: the Knox-Shady and the Fort Payne-Tuscumbia aquifers. Aqui fers in the region are typically associated with valleys that are separated by less perm eable rocks outcropping on ridges. The major source of recharge to the aquifers is rainfa ll, 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 presen t flows away from the project site (DOE, 1998).

3.2.3 Wetlands & Floodplains

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

forested/shrub wetlands in the immediate vicin ity of the sites, along both the Coosa River and Yellowleaf Creek . These types of wetlands are typically found adja cent to rivers and are areas that are waterlogged for much of th e year. Forested/shrub we tlands 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 Al abama will be able to purchase wetland and stream credits in this lo cation 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 Co mpany, 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-7 September 2008 3.3 A IR Q UALITY

Air quality is described by the concentration of various pollutants in the atmosphere. The significance of a pollutant con centration 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 a tmospheric concentrations that may occur and still protect public health and welfar e with a reasonable margin of safety.

This section is a description of ambient ai r quality in Shelby C ounty 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 St andards 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 USEP A 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 (PM 10 ), very fine particulate matter (PM 2.5 ), sulfur dioxide (SO 2 ), carbon monoxide (CO), nitrogen oxides (NO

x ), ozone (O 3 ), and lead. Short-term standards (1-, 8-, and 24-hour periods) have been established for pollutants contributing to acu te health effects, while long-term standards (annual averages) have been established for pollutant s contributing to chronic health effects. Based on the severity of th e pollution problem, nonattainmen t areas are categorized as marginal, moderate, serious, severe, or extrem e. Each state has the authority to adopt

standards stricter than thos e established under the federal program; however, the State of Alabama accepts the federal standards.

Federal regulations designate Air-Quality Co ntrol Regions (AQCRs) in violation of the NAAQS as “nonattainment” areas. Federal regulations designate AQCRs with levels below the NAAQS as “attainment” areas. “M aintenance” AQCRs are areas that have previously been designated “nonattainment,” and have been redesignated to “attainment” for a probationary period through implementa tion of maintenance plans. The PSDF, and therefore the CRC, is completely within the Metropolitan Birmingham Intrastate AQCR (AQCR 004) (40 CFR 81.144). The USEP A has designated Shelby County as

nonattainment for the PM 2.5 NAAQS, a maintenance area for the 8-hour O 3 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 memo rial 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 pr otected under the CAA, but identified for somewhat less stringent protection from air po llution damage than a Class I area. Shelby County is considered a Class II Area.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-8 September 2008 3.3.3 Local Ambient Air Quality

ADEM and Jefferson County Department of Health Ai r Pollution Control Program monitor the concentrations of criteria po llutants in AQCR 004. Mon itoring stations are located in Jefferson, Shelby, Sumter, Tuscaloosa, and Walker Counties. Worst case ambient air quality conditions can be estimat ed from maximum concentrations measured at these stations ( Table 3-1 ).

Table 3-1 NAAQS and Area Air Quality

Pollutant and Averaging Time Primary NAAQS 1 Secondary NAAQS 1 Monitored Data 2

CO

8-Hour Maximum 3 (ppm) 9 (None) 9

1-Hour Maximum 3 (ppm) 35 (None) 20

NO 2 Annual Arithmetic Mean (ppm) 0.053 0.053 (no data available)

Ozone

8-Hour Maximum 4 (ppm) 0.08 0.12 0.108

PM 2.5 Annual Arithmetic Mean 5 (μg/m 3 ) 15 15 20.3

24-Hour Maximum 6 (μg/m 3 ) 35 35 64

PM 10 Annual Arithmetic Mean 7 (μg/m 3 ) 50 50 56

24-Hour Maximum 3 (μg/m 3 ) 150 150 241

SO 2 Annual Arithmetic Mean (ppm) 0.03 (None) 0.003

24-Hour Maximum 3 (ppm) 0.14 (None) 0.014

3-Hour Maximum 3 (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 O 3 concentrations over each year must not exceed 0.08 ppm. 5 - The 3-year average of th e weighted annual mean PM 2.5 concentrations from must not exceed 15.0 ug/m 3

. 6 - The 3-year average of the 98th percentile of 24-hou r concentrations at each p opulation-oriented monitor must not exceed 65 ug/m 3

. 7 - The 3-year average of th e weighted annual mean PM 10 concentration at each monitor within an area must not exceed 50 ug/m 3

.

With the exception of the eight-hour O 3 , 24-hour PM 2.5 , and 24-hour PM 10 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 four th highest daily maximum 8-hour average O 3 concentrations over each year has not exceeded 0.08 ppm; hence, the attainment status. The reported maximum of 64 micr ograms per cubic meter (μg/m 3 ) for the 24-hour PM 2.5 level exceed the standards of 35 μg/m 3 . However, it was only exceeded once; hence, the attainment status. The reported maximum of 241 μg/m 3 for the 24-hour PM 10 level exceeded the standards of 150 μg/m 3 . However, the 3-year average does not exceed 150;U.S. Department of Energy Carbon Rese arch 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 Metropolit an 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 PM 2.5 NAAQS; therefore no USEPA approved regional emissions budget is in place for PM 2.5 and its precursors. The SIP

revisions to address nonattainment conditions with respect to the PM 2.5 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

NO

x 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 gr eenhouse effect and global warming. Some greenhouse gases occur naturally in the atmo sphere, while others result from human activities such as the burning of fossil fu els. Federal agencies, states, and local communities have prepared GHG inventories and adopted policies that would result in a decrease of greenhouse gas emissions. Accord ing to the Kyoto Protocol and California Climate Action Registry, there are six GHGs: carbon dioxide (CO 2 ), nitrous oxide (N 2 O), methane (CH 4 ), hydrofluorocarbons ( HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6 ) (UNFCC, 2007;CARB, 2007). A lthough the direct GHG (CO 2 , CH 4 , and N 2 O) 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 CO 2 have increased globally by 35 percent. Within the United States, fuel combustion accounted for 94 percent of all CO 2 emissions releas ed in 2005. On a global scale, fossil fuel combus tion added approximately 30 x10 9 tons (27 x10 9 metric tons) of CO 2 to the atmosphere in 2004, of whic h the United States accounted for about 22 percent (USEPA, 2007a). DOE’s Energy Information Administration (EIA) report

indicates that U.S. CO 2 emissions have grown by an av erage of 1.2 percent annually since 1990 and energy-related CO 2 emissions constitute as much as 83 percent of the total

annual CO 2 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). WithU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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 B IOLOGICAL R ESOURCES

3.4.1 Vegetation

The PSDF is located in a region dominated by Oak-Pine forests. These ecosystems are characterized by numerous oaks (white, north ern, and southern red), and pines (loblolly pine being the most characteristic) in a rolling topography. The forest canopy also includes sourwood, sweetgum, and various hic kory 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 co ver which is developed and lacking any vegetation.

3.4.2 Wildlife

Species diversity for wildlife populations occu rring on the proposed proj ect 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 titm ouse, Carolina wren, brown thrasher, pine warbler, northern cardinal, rufous-sided to whee, and the eastern box turtle (DOE, 1998).

Aquatic species living in Yellowleaf Creek in clude a diverse fish community with 47 species representing 10 families. Yellowleaf Cr eek is also home to numerous snail and mussel species. The Coosa River is also hom e to a diversity of aquatic species; no other

river basin in North America has a higher percenta ge 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, catf ish, bluegill, a nd other sunfish (DOE, 1998; CRBI, No date).

3.4.3 Threatened & Endangered Species

Both the Coosa River and the Yellowleaf Creekare 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 spec ies include the Blue sh iner, 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, th e Cylindrical lioplax and the Interrupted rocksnail are both federally endangered sn ail 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 habita t for four threatened or endangered mussels; the Coosa Moccasinshell, Finelined pocketbook, Southern pigtoe, and TriangularU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-11 September 2008 kidneyshell. The designated cr itical 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, wher e it is attracted to the conditions caused by the turbulent intake water.

The Yellowleaf Mitigation Bank being estab lished 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 know n terrestrial plant or animal species found on the PSDF property or within the immediat e vicinity of the pr oject site (Southern Company, 2008).

3.5 W ASTE AND H AZARDOUS M ATERIALS M ANAGEMENT

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 Br owning-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 pa per are collected for recycling from the PSDF per year.

In addition to municipal waste, the PSDF ge nerates approximately 700 tons per year of coal ash and coal byproducts. This material is stored in two silo s 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 vari ety 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 Federa l Resource Conservation and Recovery Act (RCRA) and classified by the USEPA as a Sm all Quantity Generato r of Hazardous Waste (USEPA ID # ALR000000216). The hazardous wast es 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 andU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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 she d, where it is held for less than 180 days. The waste is then transported offsite for dis posal at Waste Management, Inc. located in Emelle, Alabama, which is a certified hazardou s waste treatment, storage, and disposal facility.

BMPs for managing all onsite hazardous and toxi c materials and waste are in place at the PSDF. These BMPs include proper storage fa cilities and locations for the chemicals, immediate response to spill and leaks, and pr oper disposal of the waste from spills and leaks. The PSDF has a Spill Prevention Contro l 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 ab ove 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 a nd methods used to minimize oil spills on nearby streams, and who is responsible for the pla n. 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 Cont rol. 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 us ers are allowed to work with the sources and a physical inventory of all sources must be taken at pe riodic intervals. The site has a designated Radiation Safety Officer who serves as th e overseer for the pr ogram. The program is subject to a state inspection and has had th ree inspections over th e life of the program.

3.6 H UMAN H EALTH AND S AFETY

Primary concerns to human health and safety at the PSDF include the exposure of workers to air emissions from the existing f acilities, 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 ai r 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 re gularly exposed to the existing ambient air quality which is heavily influenced by combustion activities at Plant Gaston.

The existing PSDF facility stores a limited nu mber 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 curre nt chemical storage and employee handling and safety requirements. Stor age 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 duri ng emergency conditions and power systemU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Affected Environment 3-13 September 2008 shutdowns. To prepare for emergencies, routine safety, emergency response, and emergency evacuation drills have been, a nd 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 (O SHAs) 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 coveri ng, and other appropria te attire, are ad hered to at the

industrial areas of the PSDF and Plant Gaston.

3.7 C ULTURAL R ESOURCES

Cultural and historic resour ces are protected by a variet y of laws and regulations, including the National Historic Preservati on 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 imp acts to cultural resources. The Section 106 process applies to any fede ral undertaking that has the pot ential to affe ct cultural

resources.

The Alabama Historical Commission is the state agency charged with safeguarding Alabama’s historic buildings and sites. Th e Commission administer s 12 historic sites.

There are no historic sites lo cated 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 remain s 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 s ites are located with in the project boundari es. 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, constr uction, and operation of the PSDF was issued with a FONSI in 1993. As part of this initi al EA, consultation with the Alabama SHPO took place in 1992. On October 26, 1992, SHPO de termined the project would not have

an adverse effect on identif ied historic properties.

3.8 S OCIOECONOMICS

The socioeconomic region of influence for the proposed action is a three county area around PSDF where the majority of construc tion and site worker s would reside andU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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 da ta), the population within this threecounty area was approximately 202,000. Approx imately 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. W ithin 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 Alabam a, 71% of the population was white, 26% black, and 1.7% Hispanic or La tino (USCB, 2006a, 2006b, 2000a, 2000b, 2000c).

The total civilian labor force for the re gion of influence was approximately 40,300 in 2000-2006; unemployment rates in both Shelby and Coosa C ounties were approximately 3.8 percent while Talladega Count y 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 educatio n, health care, and social services sector; the retail sector; and, the prof essional, scientific, and management sector. In Coosa County the top employment type is manufacturing, followed by retail, and construction. In Talladega, workers are also predominan tly 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 pe rsonal income in 2000 (most recent Census Bureau data available for entire region) wa s $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 pe rmanent construction employees and approximately 100 permanent Southern Company Services and Alabama Power Company employees. Fluctuations in employ ment levels at the PSDF change based on workload and construction status. During past construction pha ses, the number of construction employees has increased to approximately 70 during peak times (Southern Company, 2008).U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-1 September 2008 4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

AND ALTERNATIVES

4.1 G EOLOGY AND S OILS

4.1.1 Alternative 1: Proposed Action

The Proposed Action would involve ground di sturbance at two sm all areas on the existing PSDF site to accommodate the installation new pre-combustion CO 2 capture equipment, including tanks, pumps and other equipment. The primary area of

construction would be immediatel y north of the existing facili ty 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 ft 2 , with between an 8 inch an d 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 st ructure, where an existing 700 ft 2 pad would be modified to accommodate tanks and pumps for solvent storage, with approximately 2 ft. depth for construction. The tota l footprint of land di sturbance at the PSDF is estimated to be 1,950 ft 2

.

As part of the proposed post-combustion CO 2 capture research, an approximately 7,500

ft 2 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 ft 2 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 foot print of disturbance of approximately 10,000

ft 2 would occur as part of the post-combustion CO 2 capture research at Plant Gaston.

Each of the locations proposed for developm ent is relatively flat and firm with no potential for geologic instabilit y or subsidence. As discusse d 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 exp ected to be disturbed during the construction/development phase of the pr oposed action. Howeve r, all construction activities would occur on previously developed land that is covered with gravel, and the impact to native soils is considered ne gligible. A minimal amount of additional stormwater runoff can be expected to occu r during construction ac tivities and from the slight increase in impervious surface area of the sites. Al l 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 s hort, only 2-3 weeks each, and the construction activities would be pe rformed under the guidelines of the sites’ BMP Plan. Standard construction BMPs, such as installing perimeter silt fences, spreading straw and mulch to protect expos ed ground, covering stockpiles of earth orU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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 activi ties or operational chan ges 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 W ATER Q UALITY I MPACTS

4.2.1 Alternative 1: Proposed Action

Surface Water

General construction impacts associated with the development of the proposed pre- and post-combustion CO 2 capture research sites could af fect water resources by increased stormwater runoff from the sites during times of heavy rain, and, by contamination from construction activities infiltrating area soils a nd percolating down into the groundwater.

Increased stormwater runoff fr om developed sites can lead to increased erosion of exposed soils, which leads to increased turbidity in su rface waterbodies. The first flush of rains after a long dry period will carry pollutants deposited on pavement in to soils and water bodies, posing a risk of contaminating water an d 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 ft 2 (0.27 acres), which is cons iderably less than the one acre threshold that triggers the need for mo st individual construction site permits under the NPDES regulations enforced by ADEM (ADE M, No date-b). The small footprint of new disturbance, combined with the extent of existing land development and stormwater management practices, should aid in minimizi ng stormwater runoff during construction activities. Additionally, the existing berms be tween Plant Gaston and the Coosa River will help to minimize stormwater runoff during the construction of the post-combustion CO 2 capture facility near Plant Gaston Unit 5.

The Coosa River and Yellowleaf Creek are th e two nearby surface wate rbodies that have the potential to be impacted under the Proposed Action. Both the PSDF and Plant Gaston have existing NPDES permits that allow discha rge of pollutants to th ese waterbodies that meet limits established by the permit. Any new chemicals brought on site have the potential to be discharged through spills and acc idents. New solvents will be required for the implementation of the CRC. Operational ch anges in runoff are also likely to occur.

Runoff from the coal and lime stone storage areas will be collected and pumped to the 60,000 gallon collection basin. Runo ff 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 ar ea 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 th e plans being modified as necessary to accommodate the presence of the new solvents . Therefore, the potential harm to aU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-3 September 2008 receiving body should be mitigated by the sma ll 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 so lids settling, oil separa tion, 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 pr oposed 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 o ccur. These activitie s 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 proce ss 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 existi ng DBU would be required for the addition of CRC equipment. Water use at the PSDF is e xpected to remain similar to, or increase slightly from, current amounts. These leve ls 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 CO 2 capture research wa ter 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 CO 2 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 ba sin that collects any sp ills associated with process discharges, as well as st ormwater runoff from the site. This curbed area collects to a sump, which will be pumped e ither into existing yard drai ns (normal operation) or to storage containers in the event of a process sp ill or modification. The existing site drainage system carries runoff to the south into the ex isting coal pile runoff pond, where it is then pumped to the existing ash storage lake. The di scharge of the ash storage lake is monitored according to the existing Plant Gaston NPDES permit (Southern Company, 2008).

Current wastewater quantities are describe d in Section 3.2.1; th e 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 ga llons. Section 3.2.1 also describes the components of wastewater that are monito red; this monitoring will continue as no changes to the NPDES permit are expe cted (Southern Company, 2008). TheU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-4 September 2008 implementation of the Proposed Action is like ly 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 we tlands 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 surf ace water resources. Water withdrawal from the Plant Gaston

intake structure would conti nue to supply daily operations at Plant Gaston, which are estimated to require approximately 830 m illion gpd. Water withdrawal for the proposed operations at the PSDF and the projected post-combustion CO 2 capture research activities

at Plant Gaston are estimated at a co mbined average of 72,000 gpd (0.072 million gpd),

or less than 0.009% of total withdrawal. The de crease in water withdr awal and use if the CRC was not implemented and the PSDF were not in operation is considered negligible relative to the quantities withdr awn and used by Plant Gaston.

The existing NPDES permit woul d not require modification or replacement. The No Action Alternative is not expected to resu lt in impacts to the unnamed, intermittently flowing, tributary, Yellowleaf Creek, or th e Coosa River. Additionally, no impacts to groundwater or wetlands and fl oodplains can be expected from implementation of this

alternative.

4.3 A IR Q UALITY I MPACTS

4.3.1 Alternative 1: Proposed Action

Short-term and long term minor impacts to ai r quality would be expe cted as a result of implementation of the Proposed Action. Dire ct 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 genera te air pollutants during construction and introduce minor new stationary sources of pollu tants, such as a hot water heater and aU.S. Department of Energy Carbon Rese arch 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 a ssociated with the Proposed Action were estimated ( Table 4-1 ). The construction emissions would be generated by equipment use for site prepara tion and construction fo r 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 em issions estimates included:

• Heating emissions from hot water heat er and natural gas boilers, and

• Additional processing emission.

The general conformity rules (GCR) require fe deral 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 geogr aphic 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 NO

x ( Table 4-2 ). Pending the full implementation of the PM 2.5 NAAQS, there is no USEPA approved regional emission budget for PM 2.5 or SO 2 . 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 PM 2.5 or SO 2 would be regionally signi ficant. Detailed emissions calculations are located in Appendix A

.

Table 4-1 Project Emissions Compared to Applicability Thresholds

Annual Emissions

(Tons per Year)

Activity VOC NO

x SO 2 PM 2.5 Applicabilit y 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 NoU.S. Department of Energy Carbon Rese arch 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 NO

x 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 associat ed with the Proposed Action would be subject to federal and state air permitting regulat ions. ADEM oversees programs for permitting the construction and operation of new or modified stationa ry 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 (NNS R), prevention of significant deterioration (PSD), and new source performance standards (NSPS) for selected categories of industrial sources. In addition, under the Na tional Emission Standards for Hazardous Air Pollutants (NESHAP), new and modified sta tionary sources of air emissions may be subject to Maximum Achiev able Control Technology (MAC T) requirements if their potential to emit Hazardous Air Pollutants (HAP s) 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 Octobe r, 2003 (ADEM, 2003). The Title V PSDF air permit would not be affected by the new projec t. However, a modification or add-on to the existing facility air permit may be nece ssary. For example, a new steam boiler may have to be added for heating and process requ irements. 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 ow n individual permit requirements separate from the main gasifier permit. While a need to seek minor modifications may become necessary, it is anticipated th at no increase in emission limits to the existing permit would be sought. The pre-combustion facility is pr ojected to operate at a maximum of 2,500 hours per year.

Based on the facility’s potential to emit, Plan t Gaston Unit 5 is also a major source. The proposed post-combustion facil ity would not require modifi cation to the Plant Gaston Unit 5 existing Title V air permit. Flue gas that is processed through th e facility would be returned to the existing plant flue gas desulf urization (FGD) inlet du ct, 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 CO 2 is captured, it is expected that the traditional emissions of PM and acid gases (SO 2 and NO

x ) would be reduced th rough the addition ofU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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 sorb ent attrition and slip (from solid adsorbent based processes). Because the organic solven ts 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 effici ent in capturing PM. For these reasons, very little air emission is expected from the Po st-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 NNS R construction permit would not be required.

New Source Review (NSR) The potential emissions may exceed the minor NSR threshold. Therefore, a mi nor 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 regul ated 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. Therefor e, 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 accomp lished in full compliance with current Alabama regulatory requirements, through the us e of compliant practic es 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 AsphaltU.S. Department of Energy Carbon Rese arch 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 br eaks, 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 CO 2 air emissions would occur during routine operations at the PSDF, as described in Section 3.3. Additional so urces of emissions during research operations at the post-com bustion area adjacent to Plant Gaston could include compressors, which are often equipp ed 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 s ources would be very small. The majority of the CO 2 stream that would feed the system would otherwise be vented to the atmosphere without the Proposed Action. Therefore, CO 2 that is vented from the post-combustion unit during this pr oject 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 CO 2 emissions.

4.3.2 Alternative 2: No Action

Selecting the No Action Alternative would re sult in negligible impacts to ambient airquality conditions. No construction would be undertaken and facility operations would be suspended. The relatively minute release of CO 2 from PSDF operations would not occur. Ambient air-quality conditions would remain as described in Sections 3.3.1. Indirectly, selecting the No Action Alte rnative, meaning that th e proposed CRC would not be established and this project is not carried out in any setting, would de lay planned largerscale CO 2 reduction projects indefinitely. The increased understanding of CO 2 reduction technologies would not be gained.

4.4 B IOLOGICAL R ESOURCES

4.4.1 Alternative 1: Proposed Action

Vegetation and Wildlife

As discussed above, all components of th e Proposed Action will be occurring on previously developed land that is lacking vegetative cove r and likely not habitat for wildlife. No impacts to terrestrial wildlife an d 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 Rese arch 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 Stat e or Federally listed threatened or endangered species are anticipated to occur. Negligible impacts to water quality, water quantity, and the water velocity in the inta ke structure on Yellowl eaf Creek, would occur

as a result of constructi on 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 re sult in no impacts to listed species. On June 24, 2008, the USFWS responded with concurre nce 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 W ASTE AND H AZARDOUS M ATERIALS M ANAGEMENT

4.5.1 Alternative 1: Proposed Action

The amount of municipal solid waste (25 t ons/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 woul d continue to be di sposed 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 th e same under the Proposed Action, or to increase as a result of an increase in spent so lvents from CRC R&D efforts.

New substances that are anticipated to be stor ed 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, catalyst s containing metals such as nickel and cobalt, hydrogen sulfide, and sulfur dioxide. The solvents will be used for CO 2 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-10 September 2008 CRC for CO 2 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 crowde d steric environment). However, most solvents have not yet been identified, but wi ll 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 th e 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 f ilters 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 Un it 5, they would be combusted along with fuel. The primary impurities contained in the solvents would be salts of SO 2 and NOx,, and because the existing Unit 5 facility is equipped with high efficiency SCR and FGD for

NO

x and SO 2 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 proj ected for year 1, incr easing to a maximum of approximately 68,000 lb/yr afte r 5 years. If all spent solvents test ed 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 licen sed 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 be fore storage and use. All applicable safe handling, storage, use, and disposal precau tions would be observed and adhered to. Though the quantity of hazardous and toxic materi als would likely increase as a result of this alternative, it is not antic ipated 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 w ould be no additional waste generated, and no

new hazardous or toxic substances would be st ored 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-11 September 2008 4.6 H UMAN H EALTH AND S AFETY

4.6.1 Alternative 1: Proposed Action

The worker safety program requirements applicab le 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 construc tion activities, the impacts to human health (workers and the public) can be expected to be minor, adve rse, and short-term (See Section 4.3). Following the mitigation measures and BMPs will reduce the adverse impacts to human health from air qualit y. 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 tra ffic accidents in and around the project site

would be minimal. This area is not heav ily trafficked, and the additional number of temporary workers would be well within th e range typically expe rienced during other construction projects at the PSDF. Overall, im pacts to human health are expected to be negligible to minor, adverse, and lasti ng only the duration of the construction.

Once the proposed CRC facilities are operationa l, OSHA procedures would continue to be followed to minimize worker exposure. These may include warning systems and alarms to detect exposures and spills, as we ll as informing the proper authorities of any incidents. The PSDF Safety Program has nume rous worker safety and health programs to mitigate potential harm or exposure of employees such as: Respiratory Protection, Hearing Conservation, Bloodborne Pathoge ns, Scaffold Program, Fall Protection Program, Personal Protective Equipment, a Hazmat Response Team, Confined Space Rescue Team, a First Responder Group, and employ ees 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 us e 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 trai ning of workers to allow op eration and testing of the equipment and otherwise ensure affected personnel are informed of the changes or additions (Southern Company, 2008). In addition, the existin g Material Safety Data Sheets and Personal Protective Equipment require ments 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, operationa l noise levels are not expected to change; hearing protection will cont inue to be required in al l high noise areas (Southern Company, 2008).

The existing PSDF has not had a lost-time inju ry since the safety record began on August 1, 1995. Job Safety Briefings are held before any non-routine job be gins 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 theU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-12 September 2008 new facility components. Given the small si ze of risks and additional exposures, overall impact to human health from the proposed ac tion 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 pr ocess gases as well as to air emissions throughout the construction process would not occur. Any emissions

released from the PSDF from alternative resear ch 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 Altern ative can be expected to be negligible.

4.7 C ULTURAL R ESOURCES

4.7.1 Alternative 1: Proposed Action

Consultation regarding the Proposed Acti on 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 resour ces listed on or eligib le for the National Re gister 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 si gnificance be discovered, however, during development of the sites to be used for the CRC CO 2 capture R&D efforts, the SHPO would be notified immediately. If any historica lly 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 step s would be taken, and th at 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 ar eas 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 S OCIOECONOMICS

The threshold level of signifi cance for socioeconomic resources is the potential of the project to result in a substant ial population or employment in crease or decrease in the region of influence.U.S. Department of Energy Carbon Rese arch 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 ne w 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 histor ical 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 constr uction phases of the CRC. Therefore, it is expected the temporary workforce populati on 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 operato rs for the 5 year pr oject period. This slight increase in employment levels may have a slight, benefi cial impact on area socioeconomics. Overall impacts to socio economics from the implementation of the Proposed Action are expected to be beneficial and minimal. Employment levels are anticipated to be within the typical fluctuati on of workforce numbers s een at this site.

4.8.2 Alternative 2: No Action

It is not known at this time whether or not cancellation of th e CRC project would translate into potential site layoffs. If any la yoffs were to occur, the impacts from the No

Action alternative would be adverse and in proportion to the scaled own of the site’s workforce. Additionally, the No Action alte rnative would not have the benefits of potentially developing more co st-effective and affordable CO 2 capture technology, which could ultimately result in wide spread beneficial economic impacts to coal based power generation facilities which seek to reduce their CO 2 emissions.

4.9 C UMULATIVE I MPACTS

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, regard less of who undertake s these other actions. Cumulative impacts can result from indivi dually minor, but collectively significant, actions. This cumulative impacts section of the EA addresses only the cumulative effects arising from considering the Proposed Acti on in combination with other ongoing actions at, or in the vicinity of, the PSDF and Plant Gaston.

No development, with the exception of what ha s 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 develo pments proposed there, are considered negligible.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Environmental Consequences 4-14 September 2008 In a regional context, the greater Wilsonville area is expe riencing 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 minima l, 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 anticipat ed to result within a regional context.

Water quality in both major surface waterbodi es adjacent to the PSDF and Plant Gaston sites, the Yellowleaf Creek and the Coos a River, are currently impaired. TMDLs developed for the waterbodies address the lack of DO by putting re strictions on new sources of ammonia and oxygen-de pleting nutrients in the wate rbodies, and, they address the elevated level of PCBs by restricting ne w 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 wa terbodies. 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 pr oject 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 significan t stationary, area, and mobile emission sources in the development of this plan. Es timated emissions gene rated 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 sc ale, the proposed project has the potential to contribute long-term, major beneficial impacts towards the future reduction of domestic and global CO 2 emissions by providing key R&D activitie s in the efforts to develop costeffective and efficient CO 2 capture technology.

4.10 M ITIGATION M EASURES

All future actions proposed as part of this project should employ the following mitigation

measures to ensure that environmental im pacts from construction and operation of the project are minimized to the greatest exte nt possible. Adheren ce to the following mitigation measures, in conjunction with adhe rence to all applicable and appropriate local, state, and federal regul ations and permits, should ensu re that the development and operation of the PSDF-CRC has no signifi cant impacts to the environment.

Soil

• Incorporate and maintain BMPs at all co nstruction sites; BMPs typically consist

of various erosion and sediment control meas ures such as silt fences, straw bales, and other temporary measures to be pl aced in ditches and along portions of theU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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 ha s stabilized. Regular inspections of the

erosion and sediment control measures should be performed after any storm

event.

• Store and maintain all fuel s in a designated equipment staging area to reduce the potential for soil contamination. Closel y monitor the fueling operation, and have an emergency spill kit containing absorptio n 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 th e extent practicable, sediment runoff from the site should be captured and prev ented from entering area surface water

bodies.

Air Quality

• Continue to implement reasonable measur es, 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 pr oject in order to minimize the amount of waste generated by the f acilities. All hazardous waste and materials stored and/or generated at the development s hould be properly and uniformly labeled and housed in appropriate storage facilities.U.S. Department of Energy Carbon Rese arch 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 pers onnel 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: recogni zed 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

References 6-1 September 2008 6.0 REFERENCES

(ADCNR, 2008). Alabama Depart ment of Conservation and Natural Resources. Upper Sipsey Fork. Outdoor Alabama. 2008. Accessed at: http://www.outdooralabama.com/Fishi ng/freshwater/where/rivers/usf/

(ADEM, No date-a). Alabama Department of Environmental Management. No date provided. Map of Alabama’s Surface Water Cl assifications: Coosa Ri ver. Accessed June

2008 at: http://www.adem.state.a l.us/WaterDivision/WQuality/WQUseClass.htm

.

(ADEM, No date-b). Alabama Department of Environmental Management. No date provided. Permitting Requirements: Constructi on & Non-coal, Non-metallic Mining, Processing Sites, and Associated Areas. Accessed June 2008 at: http://www.adem.state.al.us/FieldOps/ Permitting/Constructio n/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 E nvironmental Management. 2006. Integrated Water Quality Monitoring & Assessment Report. Accessed June 2008 at: http://www.adem.state.al.us/WaterDi vision/WQuality/305b/WQ305bReport.htm

.

(ADEM, 2006b). Alabama Department of Environmental Management. 2006. NPDES Final Draft Permit for Power Systems De velopment Facility. ADEM Water Division. Wilsonville, Alabama.

(ADEM, 2005). Alabama Department of Environmental Management. 2005. The Redesignation Request and Maintenance Dem onstration: Birmingham 8-Hour Subpart 1
Ozone Nonattainment Area.

(ADEM, 2004). Alabama Department of E nvironmental Management. 2007. Tallapoosa River Basin Management Plan. Section 3: Regulatory Considerations – Water

Withdrawals. Accessed June 2008 at: http://www.adem.state.al.us/Education%20D iv/Nonpoint%20Program/ManagePlan/Basin Plans/Tallapoosa/007_Section3.pdf

.

(ADEM, 2003). Alabama Department of Environmental Management. 2003. Major Source Operation Permit Power Systems D evelopment Facility Wilsonville, Alabama

. Permit Number 411-0023.U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

References 6-2 September 2008 (AHC, 2008). Alabama Historical Commi ssion. 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). Alabam a Power Company. 2003. Coosa/Warrior Relicensing Project, E4 – Water Quantity, Wa ter 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 Ba sin 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 Ed ition. Boston, MA; McGraw Hill Companies,

Inc.

(DOE, 2008). U.S. Department of Ener gy, Office of Fossil Energy, National Energy Technology Laboratory. About NETL: Missi on and Overview. Accessed June 2008 at: http://www.netl.doe.gov/about/mission.html

(DOE, 2007). U.S. Department of Ener gy, Office of Fossil Energy, National Energy Technology Laboratory. Carbon Sequestration Technology Roadmap and Program Plan. April 2007.

(DOE, 1999). U.S. Department of Ener gy, Federal Energy Technology Center. Power Systems Development Facility. Environmental Assessment. Update to DOE/EA-0865. February, 1999.

(DOE, 1993). U.S. Department of Ener gy, Morgantown Energy Technology Center. Power Systems Development Facility. Envi ronmental Assessment. DOE/EA-0865. June,

1993.

(EIA, 2008). Energy Information Administration; Official Energy Statis tics from the U.S. Government; USDOE. Annual Energy Outl ook 2008 (Revised Early Release). March 2008. Report #:DOE/EIA-0383(2008). Accessed at: http://www.eia.doe.gov/oiaf/aeo/

(NRCS, 2007). Natural Resources Conservati on 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

References 6-3 September 2008 (OSHA, 2008). Occupational Safety and Hea lth Administration – US Department of Labor. Occupational Noise Exposure: 29 CFR 1910.95. Accessed June 2008 at: http://www.osha.gov/pls/oshaweb/owadis p.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 Compa ny, Inc. PSDF-CRC Draft Environmental Questionnaire. June, 2008.

(Southern Company, 2007). Southern Compa ny, Inc. Power Systems Development Facility; Overview . 2007. Accessed at: http://psdf.southern co.com/overview.html

(USCB, 2006a). US Census Bureau. Shelby County, Alabama Fact Sheet. Accessed June

2008 at: http://factfinder.census.gov/servlet/AC SSAFFFacts?_event=Search&geo_id=&_geoCont ext=&_street=&_county=shelby+county&_cityTown=shelby+county&_state=04000US0 1&_zip=&_lang=en&_ss e=on&pctxt=fph&pgsl=010

.

(USCB, 2006b). US Census Bureau. Tallade ga County, Alabama Fact Sheet. Accessed

June 2008 at: http://factfinder.census.gov/servlet/AC SSAFFFacts?_event=Search&geo_id=05000US01 117&_geoContext=01000US%7C04000US01%7C05000US01117&_street=&_county=t alladega+county&_cityTown=talladega+c ounty&_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 C oosa County, Alabama Fact Sheet. Accessed

June 2008 at: http://factfinder.census.gov/servlet/SA FFFacts?_event=Search&geo_id=&_geoContext= &_street=&_county=coosa+county&_cityTown=coosa+county&_state=04000US01&_zi p=&_lang=en&_sse=on&pctxt=f ph&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_na me=DEC_2000_SF3_U_DP3&- ds_name=DEC_2000_SF3_U&-_lang=en &-redoLog=false&-_sse=on

.

(USCB, 2000c). US Census Bureau. 2000. Stat e of Alabama Factsheet. Accessed June

2008 at: http://factfinder.census.gov/servlet/SA FFFacts?_event=Search&geo_id=05000US01037 &_geoContext=01000US%7C04000US01%7C0 5000US01037&_street=&_county=&_ciU.S. Department of Energy Carbon Rese arch 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&_subme nuId=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. Envir onmental 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 Pr otection Agency. 2007. Climate Change

Website. URL : http://www.epa.gov/climatechan ge/basicinfo.html#emissions . Accessed August 31, 2007.

(USEPA, 2006). U.S. Environmental Prot ection Agency. 2006. Wetland Types. Accessed

June 2008 at: http://www.epa.gov/owow/wetlands/types/

.

(USEPA, 2004). US Environmental Prot ection 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 Su rvey. 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 Framew ork Convention on Climate Change. 2007. Kyoto Protocol Reference Manual on A ccounting of Emissions and Assigned Amounts.

(Westervelt Company, 2007). The Wester velt 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix A A-1 September 2008 

## APPENDIX A

AIR EMISSIONS CALCULATIONSU.S. Department of Energy Carbon Rese arch 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 NO

x VOC SO

x PM 10 PM 2.5 CO 2 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 NO

x VOC SO

x PM 10 PM 2.5 CO 2 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 406.5493U.S. Department of Energy Carbon Rese arch 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 NO

x VOC SO

x PM 10 PM 2.5 CO 2 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 NO

x VOC SO

x PM 10 PM 2.5 CO 2 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 NO

x VOC SO

x PM 10 PM 2.5 CO 2 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 NO

x VOC SO

x PM 10 PM 2.5 CO 2 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 602.6U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix A A-4 September 2008 

### Operational Emissions

The tables below show the potential emissi ons calculations and the actual emissions calculations from 2003 through 2007 for N itrogen 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 calculat e 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 em it 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 Synthe tic 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 th e 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 Emissi on Rates in Pounds per Hour for NO 2 , SO 2 , CO, PM, and VOCs, 2003 through 2007 and Five Year Average

Pollutant 2003 2004 2005 2006 2007 Total Five Year Average

NO 2 15.5 21.6 26.7 19.4 32.9 116.1 23.2

SO 2 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

NO 2 23.3 16.1 23.7 14.7 12.3 90.1 18.0

SO 2 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 0.5U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix A A-5 September 2008 Table A-9. Potential Total Facility Emission s versus Actual Tota l 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

NO 2 101.6 18.0 86.3 0 187.9 18.0

SO 2 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 em ission factors from compliance

tests from 2003 to 2007:

NO 2 = 23.2 lbs/hr x 24 hr/day x 365 days/yr x 1 Ton/2000 lbs = 101.6

SO 2 = 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 av erage 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 :

NO 2 = 19.7 lbs/hr x 24 hrs/day x 365 days/yr x 1 Ton/2000 lbs = 86.3

SO 2 = 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 Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix B B-1 September 2008 

## APPENDIX B

AGENCY CORRESPONDENCEU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix B B-2 September 2008U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix B B-3 September 2008U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix B B-4 September 2008U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix C C-1 September 2008 

## APPENDIX C

NOTICE OF AVAILABILITYU.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

Appendix C C-2 September 2008U.S. Department of Energy Carbon Rese arch Center at PSDF National Energy Technology Laboratory Environmental Assessment

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