Talking Points Regarding the Environmental Report 

1. Discussion: 

The draft response to request for additional information (RAI) 8a identified the assumed 

quantity for each type of construction equipment/vehicle listed in Tables RAI 8-a-1 and 

RAI 8-a-13. The final response to RAI 8a omitted this information. 

Clarification: 

Were the equipment quantities assumed in the draft response used to calculate the 

monthly horsepower-hours listed in Tables RAI 8-a-1 and RAI 8-a-13 of the final 

response? If not, please provide the correct quantity for each type of construction 

equipment / vehicle listed. 

Goal: 

Equipment quantities are needed to verify the applicant’s assumptions and to more 

accurately estimate potential emissions. 

2. Discussion: 

We are unable to verify the horsepower-hours (Hp-hrs) per month provided in Tables 

RAI 8-a-1 and RAI 8-a-13 of the final RAI response. The revised Environmental Report 

(ER) indicates that emission rates were estimated for a 10-hour workday assuming peak 

construction activity levels were maintained throughout the year. This equates to 208 

hours per month. However, the values in Tables RAI 8-a-1 and RAI 8-a-13 are less than 

the values that would be calculated using 208 hours per month. 

Clarification: 

Please provide the monthly hours of operation for each type of construction 

equipment/vehicle listed in Tables RAI 8-a-1 and RAI 8-a-13. 

Goal: 

The monthly hours of operation for construction equipment are needed to verify the 

applicant’s assumptions and to more accurately estimate potential emissions. 

3. 

A. Discussion: 

The revised ER Section 4.6 states that construction in Phase 1 will last 

approximately 18 to 24 months. 

Clarification:

Does this timeframe include preconstruction? 

B. Discussion: 

Tables RAI 8-a-1 and RAI 8-a-2 of the final RAI responses cover a 12-month period 

during Phase 1 construction. The timing of this 12-month period within the overall 18 

to 24 month Phase 1 construction timeframe is unclear. 
Clarification: 

Please clarify the timing of this 12-month period within the overall 18 to 24 month 

Phase 1 construction timeframe. Also, please provide assumptions for Phase I 

construction emissions that would occur outside the 12-month period described in 

Tables RAI 8-a-1 and RAI 8-a-2 (e.g., emissions would decrease after the 12 months 

provided because...). 

Goal: 

Assumptions and calculations are needed to verify the applicant’s assumptions and 

to more accurately estimate potential emissions. 

4. Discussion: 

We are unable to verify the emission factors provided in Table RAI 8-a-2 of the final RAI 

response. The revised ER Chapter 4, states that emission factors from FERC Docket 

PF06-13-000 and EPA-420-R-10-018 were used to estimate emissions of criteria 

pollutants and non-methane hydrocarbons from construction support vehicles and 

equipment. And AP-42 emission factors for diesel-powered construction equipment 

were used to estimate the total suspended particulates for these vehicles. But Table RAI 

8-a-2 of the final RAI response indicates that the values listed are AP-42 non-road 

emission factors for diesel-fired equipment with transient adjustment and deterioration 

factors applied. AP-42 emission factors for non-road sources are from work performed 

in the 1970s and EPA stopped using those emission factors in 1991. EPA currently 

recommends using their NONROAD model to estimate emissions from construction 

equipment and other non-road sources. EPA-420-R-10-018 (ER reference EPA 2010) is 

a technical report that describes and documents the development of exhaust emission 

factors used for compression ignition (CI) engines in the EPA’s NONROAD2008a 

emission inventory model. 

Clarification: 

Was the NONROAD model used to develop emission factors for the construction 

equipment or were emission factors from AP-42 used? 

If the NONROAD model was used, please provide the copies of the model runs, 

including input assumptions and output tables. 

If AP-42 or another document was used, please provide a copy of the reference 

document(s) and justification for its use. (AP-42 Volume II, which contains the emission 

factors for nonroad mobile sources is no longer available on the EPA website.) Also, 

please provide the original (unadjusted) emission factors, the transient adjustment 

factors, the deterioration factors, and the equations used to adjust the emission factors. 

Goal:

It is not clear what assumptions, calculations, or sources were used for the emission 

factors. The model runs, assumptions, and output tables are to more accurately 

estimate potential emissions. 

 
5. Discussion: 

In the revised ER, all gas powered vehicles and construction equipment have been 

removed. 

Clarification: 

Is this correct? Will the gas pumping station also be removed? 

Goal: 

Needed to properly estimate emissions. 

6. Discussion: 

The emission estimate for each pollutant listed in Table 4-15 of the March 31, 2011 

(final) response to RAI 9a is less than the corresponding estimate provided in Table 

RAI 9-a of the February 16, 2011 (draft) response to RAI 9a. While we were able to 

reproduce the estimates provided in Table RAI 9-a of the draft response to RAI 9a, we 

could not reproduce the revised estimates in the final response. No reason was 

provided to explain the changes to the emission estimates in the final response. 

With the exception of NO2, the same emission factors were used in both the draft 

response and the final response. (The emission factor for NO2 was changed from 1E-4 

to 1E-5 in the final response, which appears to be an error.) Both the draft response and 

the final response indicate that one boiler would operate for 8,760 hr/yr and that 

emissions are uncontrolled. However, the emission estimates in the final response for 

PM, CO, and NO2 (if an emission factor of 1E-4 is used for NO2) are about 20% of the 

corresponding estimated emissions in the draft response; and the emission estimate for 

SOx is about 25% estimated SOx emissions in the draft response. The draft response 

provided assumptions for fuel heating value (Btu/scf), boiler heat rate (MMBtu/hr) which 

are needed to determine the hourly fuel consumption rate (scf/hr). The final response 

did not include this information. 

Clarification: 

Please provide a complete list of the assumptions used to calculate the Boiler emissions 

provided in Table 4-15 of the final response to RAI 9a. This list should include fuel 

heating value (Btu/scf), boiler heat rate (MMBtu/hr), annual runtime (hr/year), and 

whether the boiler is assumed to operate at full capacity. If the boiler is assumed to 

operate at less than full capacity please describe how that affects the heat rate. If the 

use of control devices is assumed, please describe how the controlled emissions were 

calculated and include assumptions regarding the control devices (e.g., pollutant 

controlled, device type, control efficiency) 

Goal: 

The assumptions and calculations will provide data to more accurately estimate potential 

emissions. 

 
7. Discussion: 

The annual boiler emissions for Phase 2 are approximately three times greater than the 

boiler emissions for Phase 1 (Tables 4-25 and 4-18 in the ER, respectively). The 

assumptions for both Phase 1 and Phase 2 indicate that one boiler with a steam 

generation rate of 10,000 lb/hr would operate for 8,760 hr/yr and that emissions are 

uncontrolled. 

Clarification: 

Please explain why the Phase 2 boiler emissions are three times greater than the Phase 

1 boiler emissions and a complete list of the assumptions used to calculate the annual 

boiler emissions provided in Tables 4-18 and 4-25 of the ER. This list should include 

fuel heating value (Btu/scf), boiler heat rate (MMBtu/hr), annual runtime (hr/year), and 

whether the boiler is assumed to operate at full capacity. If the boiler is assumed to 

operate at less than full capacity please describe how that affects the heat rate. If the 

use of control devices is assumed, please describe how the controlled emissions were 

calculated and include assumptions regarding the control devices (e.g., pollutant 

controlled, device type, control efficiency). 

Goal:

Assumptions and calculations are needed to properly assess emissions presented by 

the applicant. 

8. Discussion: 

Emission estimates for CO2 and VOCs were omitted from Table 4-15 of the final 

response to RAI 9a. No reason was provided for omitting this information and we are 

unable to calculate this number. 

Clarification: 

Please provide the omitted emission estimates and include a complete list of the 

assumptions used to calculate those emissions. 

Goal: 

Assumptions and calculations are needed to properly assess emissions presented by 

the applicant. 

9. Discussion: 

Response to RAIs (Table 3-59) shows several types of low-level radioactive waste 

(LLW) being generated during construction; however, we do not see a reason why 

construction would generate LLW, and the applicant stated in earlier discussion with 

NRC that no LLW would be generated during construction. 

Clarification: 

Please clarify the use of the term LLW as applied to construction. 

Goal: 

Need accurate information about waste types to assess impacts.