DOE/EA-1493 

ENVIRONMENTAL ASSESSMENT 

GREENIDGE MULTI-POLLUTANT CONTROL 

PROJECT 

AES GREENIDGE STATION

DRESDEN, NEW YORK

August 2004 

U.S. DEPARTMENT OF ENERGY
TABLE OF CONTENTS

LIST OF FIGURES ........................................................................................................ vii 

LIST OF TABLES.......................................................................................................... vii 

ACRONYMS AND ABBREVIATIONS ........................................................................ ix 

1. PURPOSE AND NEED FOR AGENCY ACTION ................................................ 1-1 

1.1 INTRODUCTION .......................................................................................... 1-1 

1.2 PROPOSED ACTION .................................................................................... 1-2 

1.3 PURPOSE....................................................................................................... 1-3 

1.4 NEED.............................................................................................................. 1-3 

1.5 NATIONAL ENVIRONMENTAL POLICY ACT STRATEGY .................. 1-3 

2. THE PROPOSED ACTION AND ALTERNATIVES............................................ 2-1 

2.1 PROPOSED ACTION .................................................................................... 2-1 

2.1.1 Project Location and Background ........................................................ 2-1 

2.1.2 Technology Description ....................................................................... 2-5 

2.1.3 Project Description................................................................................. 2-7 

2.1.4 Construction Plans................................................................................ 2-7 

2.1.5 Operational Plans ................................................................................. 2-8 

2.1.6 Resource Requirements........................................................................ 2-9 

2.1.6.1 Land Area Requirements ........................................................ 2-9 

2.1.6.2 Water Requirements.................................................................. 2-9 

2.1.6.3 Fuel and Sorbent Requirements.............................................. 2-12 

2.1.7 Outputs, Discharges, and Wastes ......................................................... 2-15 

2.1.7.1 Air Emissions.......................................................................... 2-15 

2.1.7.2 Liquid Discharges .................................................................. 2-15 

2.1.7.3 Solid Wastes........................................................................... 2-16 

2.1.7.4 Toxic and Hazardous Materials ............................................. 2-16 

2.2 ALTERNATIVES........................................................................................... 2-17 

2.2.1 No-Action Alternative.......................................................................... 2-17 

2.2.2 Alternatives Dismissed from Further Consideration............................ 2-19 

2.2.2.1 Alternative Sites...................................................................... 2-20 

2.2.2.2 Alternative Technologies........................................................ 2-20 

2.2.2.3 Other Alternatives................................................................... 2-20 

3. EXISTING ENVIRONMENT................................................................................. 3-1 

3.1 SITE DESCRIPTION, LAND USE, AND AESTHETICS............................ 3-1 

3.2 ATMOSPHERIC RESOURCES .................................................................... 3-1 

3.2.1 Climate ................................................................................................. 3-1 

3.2.2 Air Quality............................................................................................ 3-2 

3.3 SURFACE WATER RESOURCES ............................................................... 3-5 

3.3.1 Hydrology............................................................................................. 3-5 

3.3.2 Water Quality and Use ......................................................................... 3-6 

3.3.2.1 Water Quality.......................................................................... 3-6 

iii 
iv 

3.3.2.2 Water Use................................................................................ 3-6 

3.3.3 Effluent Discharges .............................................................................. 3-6 

3.3.4 Thermal Discharge ............................................................................... 3-7 

3.4 GEOLOGICAL RESOURCES....................................................................... 3-7 

3.4.1 Geology and Topography..................................................................... 3-7 

3.4.2 Geological Hazards ................................................................................ 3-8 

3.4.3 Geological Resources........................................................................... 3-8 

3.4.4 Groundwater......................................................................................... 3-9 

3.5 FLOODPLAINS AND WETLANDS........................................................... 3-10 

3.5.1 Floodplains ......................................................................................... 3-10 

3.5.2 Wetlands............................................................................................. 3-10 

3.6 ECOLOGICAL RESOURCES..................................................................... 3-10 

3.6.1 Terrestrial Ecology............................................................................. 3-10 

3.6.2 Aquatic Ecology................................................................................ 3-11 

3.6.3 Threatened and Endangered Species.................................................. 3-11 

3.6.4 Biodiversity .......................................................................................... 3-12 

3.7 CULTURAL RESOURCES ........................................................................... 3-12 

3.8 SOCIOECONOMICS..................................................................................... 3-13 

3.8.1 Population............................................................................................. 3-13 

3.8.2 Employment and Income...................................................................... 3-13 

3.8.3 Housing ................................................................................................ 3-15 

3.8.4 Water and Wastewater Services ........................................................... 3-16 

3.8.5 Local Government Revenues ............................................................... 3-16 

3.8.6 Environmental Justice .......................................................................... 3-16 

3.9 TRANSPORTATION AND NOISE .............................................................. 3-17 

3.9.1 Transportation ...................................................................................... 3-17 

3.9.1.1 Roads....................................................................................... 3-17 

3.9.1.2 Rail.......................................................................................... 3-17 

3.9.2 Noise..................................................................................................... 3-18 

4. ENVIRONMENTAL CONSEQUENCES .............................................................. 4-1 

4.1 ENVIRONMENTAL IMPACTS OF THE PROPOSED PROJECT ............. 4-1 

4.1.1 Land Use and Aesthetics ...................................................................... 4-1 

4.1.1.1 Land Use ................................................................................. 4-1 

4.1.1.2 Aesthetics................................................................................ 4-1 

4.1.2 Atmospheric Resources and Air Quality.............................................. 4-2 

4.1.2.1 Construction............................................................................ 4-2 

4.1.2.2 Operation ................................................................................ 4-2 

4.1.3 Surface Water Resources...................................................................... 4-6 

4.1.3.1 Construction............................................................................ 4-6 

4.1.3.2 Operation ................................................................................ 4-6 

4.1.4 Geological Resources........................................................................... 4-7 

4.1.4.1 Rock, Soils, and Mineral Resources ....................................... 4-7 

4.1.4.2 Groundwater ........................................................................... 4-7 

4.1.4.3 Geological Hazards................................................................. 4-8 

4.1.5 Floodplains and Wetlands .................................................................... 4-8 

4.1.5.1 Floodplains.............................................................................. 4-8 
v 

4.1.5.2 Wetlands ................................................................................. 4-8 

4.1.6 Ecological Resources ........................................................................... 4-8 

4.1.6.1 Terrestrial Ecology ................................................................. 4-8 

4.1.6.2 Aquatic Ecology ..................................................................... 4-9 

4.1.6.3 Threatened and Endangered Species ........................................ 4-9 

4.1.6.4 Biodiversity............................................................................... 4-9 

4.1.7 Waste Management ................................................................................ 4-9 

4.1.7.1 Construction.............................................................................. 4-9 

4.1.7.2 Operation ................................................................................ 4-10 

4.1.7.3 Hazardous Waste .................................................................... 4-13 

4.1.8 Cultural Resources ............................................................................... 4-14 

4.1.9 Socioeconomic Resources.................................................................... 4-14 

4.1.9.1 Population ............................................................................... 4-15 

4.1.9.2 Employment and Income ........................................................ 4-15 

4.1.9.3 Housing................................................................................... 4-16 

4.1.9.4 Water and Wastewater Services.............................................. 4-16 

4.1.9.5 Local Government Revenues.................................................. 4-16 

4.1.9.6 Environmental Justice............................................................. 4-17 

4.1.10 Transportation and Noise ..................................................................... 4-17 

4.1.10.1 Transportation......................................................................... 4-17 

4.1.10.2 Noise ....................................................................................... 4-18 

4.1.11 Electromagnetic Fields......................................................................... 4-20 

4.1.12 Human Health and Safety..................................................................... 4-20 

4.2 POLLUTION PREVENTION MEASURES.................................................. 4-21 

4.3 ENVIRONMENTAL IMPACTS OF NO ACTION....................................... 4-23 

5. IMPACTS OF COMMERCIAL OPERATION ...................................................... 5-1 

6. CUMULATIVE EFFECTS ..................................................................................... 6-1 

7. REGULATORY COMPLIANCE AND PERMIT REQUIREMENTS ................. 7-1 

7.1 FEDERAL REQUIREMENTS....................................................................... 7-1 

7.2 STATE REQUIREMENTS ............................................................................ 7-4 

8. IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES . 8-1 

9. THE RELATIONSHIP BETWEEN SHORT-TERM USES OF 

THE ENVIRONMENT AND LONG-TERM PRODUCTIVITY........................... 9-1 

10. REFERENCES ........................................................................................................ 10-1 

11. LIST OF AGENCIES AND INDIVIDUALS CONTACTED ................................ 11-1 

APPENDIX A CONSULTATION LETTERS UNDER SECTION 7 OF THE 

ENDANGERED SPECIES ACT ........................................................ A-1 

APPENDIX B CONSULTATION LETTERS UNDER SECTION 106 OF THE 
vi 

NATIONAL HISTORIC PRESERVATION ACT .............................. B-1 

APPENDIX C PUBLIC PARTICIPATION LETTERS.............................................. C-1 
vii 

LIST OF FIGURES

 

2.1.1 Regional location map for the proposed project................................................ 2-1 

2.1.2 Site of Greenidge Station and Lockwood Landfill ............................................ 2-3 

2.1.3 Photograph of Greenidge Station, as viewed toward the northwest ................. 2-4 

2.1.4 Photograph of the site for the proposed project at Greenidge Station, 

as viewed toward the northwest......................................................................... 2-4 

2.1.5 A generalized diagram of the proposed multi-pollutant 

control system ...................................................................................................... 2-6 

2.1.6 Water flow diagram that depicts water requirements and discharges 

at Greenidge Station........................................................................................... 2-13 

3.2.1 Wind rose for Penn Yan, New York (1999-2003)............................................... 3-2 

LIST OF TABLES

2.1.1 Typical operating characteristics for Greenidge Station Unit 4 alone 

 and combined with Unit 3.................................................................................. 2-10 

2.1.2 Composition of bituminous coal consumed at Greenidge Station..................... 2-14 

3.2.1 National Ambient Air Quality Standards (NAAQS) for criteria pollutants ...... 3-4 

3.2.2 Allowable increments for Prevention of Significant Deterioration (PSD) 

 of air quality....................................................................................................... 3-5 

3.8.1 Population data for Yates County, Ontario County, and 

selected communities......................................................................................... 3-13 

3.8.2 Employment and income data for Yates County and 

 Ontario County in 2000 ..................................................................................... 3-13 

3.8.3 Employment by industry or economic sector in Yates County 

and Ontario County in 2000............................................................................... 3-14 

3.8.4 Housing data for Yates County, Ontario County, and 

selected communities in 2000............................................................................ 3-15 

3.8.5 Environmental justice data for the United States, the state of 

New York, Yates County, and the five Census Tracts within 

Yates County...................................................................................................... 3-17 

4.1.1 Ambient air quality standards impact analysis for the proposed project............. 4-4 

4.1.2 Prevention of Significant Deterioration (PSD) impact analysis for the 

proposed project................................................................................................... 4-4 

4.1.3 State Pollutant Discharge Elimination System (SPDES) 

permit limits and reported values for discharge from the 

Lockwood Landfill sedimentation/neutralization basin .................................... 4-11 

4.1.4 Selected data from monitoring of leachate collection drains at 

Lockwood Landfill during 2002 ........................................................................ 4-12 

4.2.1 Pollution prevention measures developed for the proposed project 

at Greenidge Station........................................................................................... 4-22 
ix 

ACRONYMS AND ABBREVIATIONS

ADT average daily traffic 

AES Applied Energy Services 

Btu British thermal unit 

CAA Clean Air Act 

CaCO3 calcium carbonate 

CDS circulating dry scrubber 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations

cfs cubic feet per second 

cm centimeter 

CO carbon monoxide 

CO2 carbon dioxide 

COE U.S. Army Corps of Engineers 

CWA Clean Water Act 

dB decibels 

dB(A) decibels as measured on the A-weighted scale 

DOE U.S. Department of Energy 

EA Environmental Assessment 

EIS Environmental Impact Statement 

EMF electromagnetic fields 

EPA U.S. Environmental Protection Agency 

EPCRA Emergency Planning and Community Right-to-Know Act 

ESP electrostatic precipitator 

ΕF degrees Fahrenheit 

FGD flue gas desulfurization 

FONSI Finding of No Significant Impact 

FR Federal Register

ft feet 

ft3

 cubic feet 

FWS U.S. Fish and Wildlife Service 

g the acceleration of gravity 

gpd gallons per day 

gpm gallons per minute 

H2O water 

HCl hydrogen chloride 

HF hydrogen fluoride 

Hg mercury 

in. inch 

lb pound 

Φg microgram 

Φm micrometer 

m3

 cubic meter 

mg milligram 

mg/L milligrams per liter 
x 

MGD million gallons per day 

MW megawatt 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NH3 ammonia 

NHPA National Historic Preservation Act of 1966 

NIOSH National Institute for Occupational Safety and Health 

NO2 nitrogen dioxide 

NOX oxides of nitrogen 

NPDES National Pollutant Discharge Elimination System 

NYSDEC New York State Department of Environmental Conservation 

O3 ozone 

ORNL Oak Ridge National Laboratory 

OSHA Occupational Safety and Health Administration 

Pb lead 

pH hydrogen-ion concentration notation 

PM-10 particulate matter less than 10 Φm in aerodynamic diameter 

PM-2.5 particulate matter less than 2.5 Φm in aerodynamic diameter 

PPE personal protective equipment 

PPII Power Plant Improvement Initiative 

ppm parts per million 

PSD Prevention of Significant Deterioration 

Pub. L. Public Law 

RCRA Resource Conservation and Recovery Act 

REL Recommended Exposure Limit 

SCR selective catalytic reduction 

SCREEN3 a screening air dispersion model 

sec second 

SGLP Synthetic Groundwater Leaching Procedure 

SHPO State Historic Preservation Officer 

SO2 sulfur dioxide 

SO3 sulfur trioxide 

SPCCP spill prevention, control, and countermeasures plan 

SPDES State Pollutant Discharge Elimination System 

SPL Sound Pressure Level 

TCLP toxic characteristic leaching procedure 

TWA time weighted average 

USC United States Code

USGS U. S. Geological Survey 

V2O5 vanadium pentoxide 

VOCs volatile organic compounds 

yd3 cubic yard 
DOE/EA-1493; August 2004 

1. PURPOSE AND NEED FOR AGENCY ACTION

1.1 INTRODUCTION 

 This environmental assessment (EA) has been prepared by the U.S. Department 

of Energy (DOE), in compliance with the National Environmental Policy Act of 1969 

(NEPA) as amended (42 USC 4321 et seq.), to evaluate the potential environmental 

impacts associated with constructing and operating an integrated multi-pollutant control 

system proposed by CONSOL Energy Inc. and AES Greenidge LLC. The EA will be 

used by DOE in making a decision on whether or not to provide cost-shared funding to 

design, construct, and demonstrate the proposed system at the existing 107-MW Unit 4 of 

Applied Energy Services’ (AES’s) Greenidge Station in Dresden, New York. DOE's 

share of the funding for the 4.5-year demonstration project is expected to be about $14.5 

million, while about $18.3 million would be provided by CONSOL and its project 

partners. The project has been selected by DOE under the Power Plant Improvement 

Initiative (PPII) to demonstrate the integration of technologies to reduce emissions of 

sulfur dioxide (SO2), oxides of nitrogen (NOx), sulfur trioxide (SO3), mercury (Hg), 

hydrogen chloride (HCl), and hydrogen fluoride (HF) from smaller (<300 MW) coalfired boilers. 

 The U.S. Congress established the PPII in Pub. L. 106-291, Department of the 

Interior and Related Agencies Appropriations Act for Fiscal Year 2001. Congress 

directed DOE to provide up to $95 million in cost-shared funding to demonstrate 

commercial-scale technologies that improve the reliability and environmental 

performance of existing and new coal-fired power plants in the United States. Congress 

expected the selected technologies to provide options by which coal plants could continue 

to generate low-cost electricity with improved performance and in compliance with 

stringent environmental standards. 

 The PPII Solicitation, issued in February 2001, required participants (i.e., the 

non-federal-government participant or participants) to offer projects having potential for 

demonstrating substantial improvements in power plant performance, leading to 

enhanced electric reliability. These improvements included increased efficiency of 

electricity production, reduced environmental impacts, and/or increased costcompetitiveness. The projects were also required to be applicable to a large portion of 

existing plants and and of commercial scale in order to enhance opportunities for timely 

deployment. 

In response to the solicitation, DOE received 24 proposals in April 2001 and 

selected 8 of the projects in September 2001 based on the following evaluation criteria: 

technical merits of the proposed technology (40%), commercial viability and market 

potential of the proposed technology (30%), and management approach and capabilities 

of the project team (30%). Along with the technical merits, DOE considered the 

participant’s funding and financial proposal; DOE budget constraints; environmental, 

health and safety implications; and program policy factors. Following selection, two of 

the projects were withdrawn by their participants in March 2002 and in October 2002. 

 Each project participant is required to finance at least 50% of the total cost of the 

project. After completion of a successful project demonstration, the participant would be 

obligated to repay the government’s financial contribution to ensure that taxpayers 

benefit from a successful project. The project participant takes primary responsibility for 

________________________________________________________________ 

1-1 
Greenidge Multi-Pollutant Control Project 

designing, constructing, and demonstrating the project. During project execution, the 

government oversees project activities, provides technical advice, assesses progress by 

periodically reviewing project performance with the participant, and participates in 

decision making at major project junctures. In this manner, the government ensures that 

schedules are maintained, costs are controlled, project objectives are met, and the 

government’s funds are repaid. 

 DOE expects to provide approximately $51 million for the 6 remaining projects. 

Private sector sponsors are expected to contribute nearly $61 million, exceeding the 50% 

private sector cost-sharing mandated by Congress. The host sites for the projects cover a 

large geographical cross-section of the United States, including Florida, Virginia, New 

York, Ohio, South Dakota, and Kansas. The duration of the demonstration projects 

ranges from slightly over a year to five years. 

1.2 PROPOSED ACTION 

 The proposed action is for DOE to provide cost-shared funding support for the 

design, construction, and demonstration of an integrated multi-pollutant control system at 

the existing 107-MW Unit 4 of AES’s coal-fired Greenidge Station in Dresden, New 

York. DOE's share of the funding for the 4.5-year demonstration project is expected to be 

about $14.5 million, while about $18.3 million would be provided by CONSOL and its 

project partners. The commercial-scale demonstration would allow utilities to make 

decisions regarding the integrated emissions control system as a viable commercial 

option. 

 CONSOL Energy Inc. and AES Greenidge LLC conceived and proposed the 

technologies in response to the DOE solicitation. Because DOE's role would be limited to 

providing the cost-shared funding for the proposed project, DOE's will decide whether or 

not to fund the project. DOE's limited involvement constrains the range of alternatives 

considered in the EA (Section 2.2), and DOE will make its decision based on those 

alternatives. 

1.3 PURPOSE 

 The purpose of the proposed project is to generate technical, environmental, and 

financial data from the design, construction, and operation of the proposed combination 

of technologies to allow industry to assess the project’s potential for commercial 

application. The proposed combination of technologies is designed to reduce the capital 

and operating costs of environmental controls for SO2, NOx, SO3, HCl, HF, Hg, and 

visible emissions. A demonstration indicating that the performance and cost targets are 

achievable at the 100-MW scale would convince potential customers in the smaller boiler 

market that the integration of these systems is not only feasible but economically 

attractive. 

1.4 NEED 

 The need for the proposed project is to address the Congressional mandate in 

Public Law 106-291 to demonstrate technologies at the commercial scale that improve 

the reliability and environmental performance of existing and new coal-fired power 

plants in the United States. DOE’s cost-shared funding would help reduce the financial 

risk to the project participant in demonstrating the proposed combination of technologies: 

________________________________________________________________________

1-2 
DOE/EA-1493; August 2004 

the single-bed selective catalytic reduction (SCR) system and the circulating dry scrubber 

(CDS). 

 The smaller boiler market is the target for the proposed combination of 

technologies. Currently, there are about 500 units in the United States less than 300 MW 

in size with a combined generating capacity of about 69,000 MW, which represents about 

25% of the installed coal-based generating capacity and almost 50% of the installed 

boilers. The 500 units are the target market for this combination of technologies because, 

based on information developed from potential purchaser interviews, the smaller boilers 

are likely to either switch fuel or be retired in the future. If only the 190 boilers less than 

110 MW are retired, the generating capacity would be reduced by up to 16,000 MW, 

which would exacerbate electricity and natural gas supply and distribution problems 

throughout the United States. Therefore, a strong incentive exists to commercialize 

technologies designed specifically to meet the environmental compliance needs of the 

smaller generating units. Because the SCR system is a low-cost option for controlling 

NOx emissions from smaller generators and allows greater fuel flexibility, such as cofiring coal and biomass, it provides a feasible alternative to retiring units as NOx

allocations are reduced and the NOx credit market tightens. 

1.5 NATIONAL ENVIRONMENTAL POLICY ACT STRATEGY 

 This EA has been prepared in compliance with NEPA for use by DOE decisionmakers in determining whether or not to provide cost-shared funding for the design, 

construction, and demonstration of the proposed project under the PPII solicitation. 

DOE’s policy is to comply fully with the letter and spirit of NEPA, which ensures that 

early consideration is given to environmental values and factors in federal planning and 

decision making. No action taken by DOE with regard to any proposal, including project 

selection or award, is considered a final decision prior to completion of the NEPA 

process. 

 For this proposed project, DOE has determined that an EA should be prepared to 

assess the significance of potential impacts resulting from the proposed action and 

reasonable alternatives. The purpose of the EA is to provide a sufficient basis for 

determining whether DOE should then prepare an Environmental Impact Statement (EIS) 

or should issue a Finding of No Significant Impact (FONSI). Based on the findings of 

this EA, if DOE determines that providing cost-shared funding would constitute a major 

federal action because the proposed project may significantly affect the quality of the 

human environment, then an EIS will be prepared to assess the potential impacts in more 

detail. However, if DOE determines that providing cost-shared funding would not 

constitute a major federal action because the proposed project would not significantly 

affect the quality of the human environment, then DOE will issue a FONSI. 

 The Oak Ridge National Laboratory (ORNL) has assisted DOE in preparing this 

EA and supporting documents for the proposed project. In independently assessing the 

issues and preparing the EA, ORNL has utilized information provided by DOE; other 

federal, state, and local agencies; the project participant team; and others. DOE is 

responsible for the scope and content of the EA and supporting documents and has 

provided direction to ORNL, as appropriate, in the preparation of these documents. 

The issues that have been identified and evaluated in the EA include land use, 

aesthetics, atmospheric resources, water resources, geological resources, floodplains, 

________________________________________________________________ 

1-3 
Greenidge Multi-Pollutant Control Project 

wetlands, ecological resources, waste management, cultural resources, socioeconomic 

resources, transportation, noise, electromagnetic fields, and human health and safety. 

Related evaluations include impacts of commercial operation, cumulative effects, 

regulatory compliance and permit requirements, irreversible or irretrievable commitments 

of resources, and the relationship between short-term uses of the environment and longterm productivity. The scope of the assessment includes upgrades and alterations to 

Greenidge Station that are not considered part of the proposed project (i.e., replacing the 

secondary superheater section, installing low-NOx burners, and potentially replacing the 

economizer and primary superheater sections) because they are inseparably linked with 

the proposed project (i.e., the integrated multi-pollutant control system would require 

much of the combined equipment, which would be installed concurrently).

________________________________________________________________________

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DOE/EA-1493; August 2004 

2. THE PROPOSED ACTION AND ALTERNATIVES

 This section discusses the proposed action, the no-action alternative (including 

four scenarios that would reasonably be expected to result as a consequence of the noaction alternative), and alternatives dismissed from further consideration. 

2.1 PROPOSED ACTION

 The proposed action is for DOE to provide support through cost-shared funding 

for the design, construction, and demonstration of an integrated multi-pollutant control 

system at the existing Unit 4 of AES’s coal-fired Greenidge Station in Dresden, New 

York (Section 1.2). The proposed action described in the following sections is DOE's 

preferred alternative. 

2.1.1 Project Location and Background

 The site for the proposed project is located at Greenidge Station, which is 

immediately southeast of Dresden, New York, along the western shore of Seneca Lake 

(Figure 2.1.1). The site is in a rural area of Torrey Township within Yates County. The 

nearest large town is Geneva, located about 15 miles to the north at the northern tip of 

Seneca Lake. Penn Yan, the county seat of Yates County, is located about 5 miles to the 

west of Greenidge Station. 

Greenidge 

Station 

Figure 2.1.1. Regional location map for the proposed project. 

2-1 
2-2 

Greenidge Multi-Pollutant Control Project 

 Greenidge Station, which occupies a 153-acre site (Figure 2.1.2), currently 

consists of the 54-MW Unit 3 and the 107-MW Unit 4, which generate a total of 

approximately 161 MW (net) of electricity for the power grid. An additional 8 to 9 MW 

are produced to satisfy internal electrical needs at the station (the difference between 

gross MW and net MW). Figure 2.1.3 is a photograph of Greenidge Station, as viewed 

toward the northwest. The plant site is bounded on the east by Seneca Lake; on the north 

by the Keuka Lake Outlet; on the west by Route 14; and on the south by Ferro 

Corporation. A mix of agricultural, industrial, commercial, and residential land use exists 

in the vicinity. The main entrance to the plant is easily accessed from Route 14. In 

addition, AES hauls fly ash for disposal at its 143-acre Lockwood Landfill, which is 

located on the opposite side of Route 14 to the west-southwest of Greenidge Station 

(Figure 2.1.2). The equipment for the proposed project would occupy about 3 acres of 

land, which currently serves as a paved laydown area and contractor parking lot adjacent 

to the existing powerhouse for Units 3 and 4 (Figure 2.1.4). The 3-acre site was 

previously excavated and graded in preparation for construction of a new unit, but those 

plans have since been abandoned. 

 Units 1 and 2 of Greenidge Station were constructed for the New York State 

Electric & Gas Corporation in 1937 and 1939, respectively. The power plant expanded in 

1950 with the construction of Unit 3 to provide additional electricity needed in the area. 

Construction of Unit 4, the host unit for the proposed project, began in December 1951, 

and the unit was placed in service in December 1953. Units 1 and 2 were retired in the 

1980s at the end of their useful lifetime. The boilers and turbines were removed from the 

powerhouse but their two idle chimneys remain adjacent to the powerhouse. 

Consequently, Units 3 and 4 occupy part of the powerhouse, while the remaining area 

formerly housing Units 1 and 2 is empty. This unoccupied space is insufficient to house 

the equipment for the proposed project; in particular, the circulating dry scrubber (CDS) 

would be taller than the inside height of the powerhouse. Boilers 1 and 2 served the Unit 

1 steam turbine, Boiler 3 served the Unit 2 steam turbine, Boilers 4 and 5 serve the Unit 3 

steam turbine, and Boiler 6 serves the Unit 4 steam turbine. AES bought Greenidge 

Station from the New York State Electric & Gas Corporation in May 1999. The plant 

employs 44 people. 

 Units 3 and 4 burn eastern bituminous pulverized coal. Conveyors with a capacity 

of 300 tons per hour transport crushed coal to the powerhouse for storage in the bunkers 

prior to combustion in the 3 remaining boilers (Boilers 4, 5, and 6). All outside conveyors 

are enclosed on three sides for dust control. Unit 4 also currently uses waste wood as 

feedstock to provide up to 10% of the heat input to the furnace (and is permitted to 

combust up to 30% waste wood by total weight). Units 3 and 4 use once-through cooling 

for non-contact condensing of the steam exhausted from the steam turbine generators. 

Water for cooling is drawn from Seneca Lake, and the heated water is returned to the lake 

via a discharge channel and Keuka Outlet. Trains and trucks deliver materials to the 

plant (Section 2.1.6.3). 

For emissions control, neither Unit 3 nor Unit 4 is equipped with a scrubber, but 

Unit 3 uses two electrostatic precipitators (ESPs) for particulate control (one for each 

boiler), and another ESP serves Unit 4. To control NOx emissions, Unit 3 uses overfire air 

(air injected above the main combustion zone in a boiler for more complete combustion). 

In 1994, a gas reburn system was installed on Unit 4 to provide natural gas and overfire 
DOE/EA

Figure 2.1.2. Site of Greenidge Station and Lockwood Landfill. 
2-4 

Greenidge Multi-Pollutant Control Project 

Figure 2.1.3. Photograph of Greenidge Station, as viewed toward the northwest. 

Figure 2.1.4. Photograph of the site for the proposed project at Greenidge 

Station, as viewed toward the northwest. 
2-5 

DOE/EA-1493; August 2004

 

air for NOx control.1 When the complete system was operating, combustion of natural gas 

in Unit 4 provided about 15% of the total heat input to the boiler. Currently, overfire air 

is used without natural gas because the price of natural gas is very high. 

2.1.2 Technology Description 

 The proposed project would integrate a single-bed selective catalytic reduction 

(SCR) system for NOx control and a CDS for SO2, Hg, HCl, HF, and SO3 control. By 

reducing SO3 emissions, the CDS would also minimize visible emissions from the stack. 

This pollution control system is particularly suited for retrofitting smaller (<300 MW) 

coal-fired boilers that could be vulnerable to retirement or fuel switching under current 

environmental regulations. 

 The multi-pollutant control system is depicted in Figure 2.1.5. The NOx control 

system consists of commercially available low-NOx burners (not considered part of the 

proposed project because the technology is mature in the market), a single-bed SCR 

system in the flue gas duct, an ammonia (NH3) storage and vaporization system, and an 

ammonia injection system. The CDS system consists of a hydrator and hydrated lime 

feed system, the CDS vessel, an ESP or baghouse for particulate control, and a carbon 

injection system for Hg control. The CDS is expected to reduce fine particulate emissions 

because it agglomerates fine particulate matter into coarser material that would be 

collected in an ESP or baghouse. 

 The in-duct SCR system is a mostly passive technology with a minimal amount of 

moving parts, in which NOx reduction occurs via a chemical reaction with ammonia in 

the presence of a catalyst. Ammonia supply to the flue gas stream relies on an ammonia 

pump, control valves, and a dilution air blower. Ammonia flow is controlled by two NOx

analyzers in the flue gas. Because the technology is passive, negligible impact on station 

reliability is anticipated. 

 The CDS system uses an absorption tower that contains no moving parts. Because 

water containing a minimal amount of dissolved or suspended solids is sprayed into the 

system, feedline plugging, nozzle plugging, erosion, abrasion, and solids build-up are 

avoided. Because the injected water evaporates completely in the absorption tower, the 

process operates as a dry system. A mixture of hydrated lime and dry fly ash collected in 

the ESP or baghouse is injected into the absorption tower via an airslide. Gravity 

provides the force for injection because the bottom of the particulate control device is 

located higher above the ground than the injection point on the absorption tower. The 

initial feed rate of hydrated lime is determined by measuring the SO2 concentration in the 

inlet flue gas. The feed rate is adjusted by monitoring the SO2 concentration at the exit of 

the particulate control device. The gas temperature leaving the absorber controls the 

amount of flue gas cooling water injected through high-pressure flow nozzles into the 

absorber. Solids are discharged from the system at the same rate that hydrated lime, fly 

ash, and SO2 enter the system. 

1

 In a gas reburn system, coal and combustion air to the main burners are reduced and natural gas is injected 

to create a fuel-rich secondary combustion zone above the main burner zone, with final combustion air 

injected to create a fuel-lean burnout zone. The formation of NOx is inhibited in the main burner zone due 

to the reduced combustion intensity, and NOx is destroyed in the fuel-rich secondary combustion zone by 

conversion to molecular nitrogen. 
2-6 

Figure 2.1.5. A generalized diagram of the proposed multi-pollutant control system. 

BAGHOUSE OR

Greenidge Multi-Pollutant Control Project
DOE/EA-1493; August 2004

 The operating reliability of the CDS process is expected to be greater than flue 

gas desulfurization (FGD) processes currently in use because of its simplicity, minimal 

number of process components, and ease of control. In addition, because of a smaller 

number of components to be installed and the ability to construct the CDS system without 

affecting existing power plant operation, the time required to connect the system would 

be relatively short, which would minimize unit downtime. Another advantage of the CDS 

technology compared to traditional FGD systems is that it consumes less electricity. The 

CDS system would only require about 0.5% of unit power generation compared to an 

FGD process requirement for 0.7-1.5% of the generated power. 

 The goals of the proposed demonstration include both improved costcompetitiveness with current technologies (particularly for SO2, NOx, and Hg control on 

smaller coal-fired units) and greatly reduced Hg, SO3, and fine particulate emissions 

compared to conventional technologies. The following emissions targets have been 

established for the integrated technologies compared with uncontrolled emissions: a 95% 

reduction in emissions of SO2, SO3, HCl, and HF, a 60% to 90% reduction in Hg 

emissions, NOx emissions of less than 0.122 lb/MMBtu, and no visible emissions from 

the stack. 

2.1.3 Project Description 

 The proposed project would integrate the technologies described in Section 2.1.2 

into the existing 107-MW Greenidge Unit 4. Because of the additional particulate loading 

resulting from the injection of lime and powdered activated carbon, a new ESP or new 

baghouse would replace the existing ESP at Unit 4. The successful bidder providing the 

equipment would decide whether to install an ESP or a baghouse; however, the 

equipment selection is inconsequential for this analysis in this EA because the 

specifications for particulate control would be identical in either case. Bottom ash would 

continue to be sold to municipalities to provide road traction during winter driving 

conditions. Disposal of fly ash would continue at AES’s nearby Lockwood Landfill, 

while commercial application of the material would be pursued (e.g., cinder blocks, 

stabilization agent). 

 Because Greenidge Unit 4 currently uses waste wood as feedstock to provide up 

to 10% of the heat input to the furnace (and is permitted to combust up to 30% waste 

wood by total weight), the proposed project would determine the effect of biomass firing 

on the performance of the integrated pollution control technologies. In addition, the 

project would quantify the magnitude of cabon dioxide (CO2) emissions reductions and 

fuel cost reductions associated with using waste wood as feedstock. 

2.1.4 Construction Plans 

 Construction activities associated with the proposed project would include 

foundation laying, steel fabrication, piping installation, and electrical wiring installation. 

Construction would begin about April 2005 and continue until April 2006, at which time 

a major outage would be conducted to tie in the equipment for the proposed project to the 

existing Unit 4, as well as tying in some other modifications. Upgrades and alterations to 

Greenidge Station, which are not part of the proposed project but which are required by 

the integrated multi-pollutant control system or are important features in the overall 

renovation, include replacing the secondary superheater section, installing low-NOx

2-7 
Greenidge Multi-Pollutant Control Project

burners, and potentially replacing the economizer and primary superheater sections. The 

duration of the Unit 4 outage would be about 2 months. If construction progress were 

insufficient to begin the outage in April 2006, the flexibility would exist to perform the 

outage in the fall of 2006. The timing of the Unit 4 outage would correspond with 

periodic maintenance outages scheduled for the spring and fall to avoid the peak load 

periods during the summer and winter. Startup and checkout of the integrated multipollutant control system would begin in June 2006 and be completed in September 2006. 

 About 20 to 30 construction workers would be involved with excavation and 

laying foundations during the initial construction at the site. Approximately 100 to 150 

workers would be required during the peak construction period of tying in the equipment. 

Due to carpooling, about 75 construction workers’ vehicles would be parked daily at the 

station during this peak period. 

 Locally obtained construction materials would include crushed stone, sand, and 

lumber for the proposed facilities and temporary structures such as enclosures, forms, and 

scaffolding. Components of the facilities would include structural steel, concrete, piping, 

ductwork, insulation, and electrical cable. 

 During construction, major components and fabricated equipment would be 

delivered to the site by truck. About 15 trucks would be expected to deliver materials 

daily for the proposed project during peak construction periods (i.e., during concrete 

foundation pouring). Approximately one truck per week would haul away construction 

debris to a municipal landfill (Section 2.1.7.3). 

 Land requirements during construction and operation are discussed in 

Section 2.1.6.1. 

2.1.5 Operational Plans 

 Demonstration of the proposed project would be conducted within the 4.5-year 

period of the cooperative agreement covering September 2004 through February 2009. 

The actual performance testing and monitoring would occur during the 12-month period 

from September 2006 until September 2007. The level of staffing at Greenidge Station 

would remain at 44 employees during the demonstration. As with current practice, 4 plant 

workers would be on duty during each of four rotating 12-hour shifts, in addition to 

maintenance workers, managers, and administrative staff working regular hours. 

 If the demonstration is successful, commercial operation would follow 

immediately without change from the demonstration period (Section 5). The details of 

injection rates and control levels for the proposed project would be determined during the 

demonstration. Long-term staffing would not be expected to change from existing levels. 

The integrated multi-pollutant control system would be designed for a lifetime of 20 

years. 

 Unit 4 would be expected to operate at generally the same power level and 

percentage of time as under current conditions, maintaining a combustion efficiency of 

about 32% and a capacity factor of about 80%. Operation of the proposed project would 

require about 1 MW of electricity generated by Greenidge Station. Because Units 3 and 4 

are usually at their peak capacity when they’re operating, the loss of 1 MW to the 

electrical grid would likely be offset by other power plants within the grid. However, 

because the amount is very small compared with regional electrical capacity, the offset 

would barely be perceptible and is not evaluated further. 

2-8 
2-9 

DOE/EA-1493; August 2004

2.1.6 Resource Requirements 

 Table 2.1.1 displays the operating characteristics, including resource 

requirements, for the existing Greenidge Station compared with the plant after 

implementation of the proposed project. 

2.1.6.1 Land Area Requirements 

 A portion of the 3-acre, previously disturbed site for the proposed project would 

be used temporarily during construction activities for equipment/material laydown, 

storage, assembly of site-fabricated components, staging of material, and facilities to be 

used by the construction workforce (i.e., offices and sanitary facilities). Other smaller 

vacant, cleared areas around the site would also be used as staging and/or fabrication 

areas. 

 The permanent structures, including surrounding access space, for the proposed 

project would occupy a total of about 3 acres of land. Limited site clearing and grading 

would be required because the land currently serves as a paved laydown area and 

contractor parking lot adjacent to the existing powerhouse for Units 3 and 4. A new 

paved parking lot would likely be built on vacant, cleared land near the powerhouse to 

compensate for the loss of the existing lot. 

2.1.6.2 Water Requirements 

 Water would be used during construction of the proposed project for various 

purposes, including personal consumption and sanitation, concrete formulation and 

preparation of other mixtures needed to construct the facilities, equipment washdown, 

general cleaning, dust suppression, and fire protection. Potable water used during 

construction would be supplied by the Penn Yan municipal water system, which provides 

water to Dresden, while service water would be drawn from the underground conduit that 

supplies Unit 3 cooling water and plantwide service water (i.e., water used for auxiliary 

equipment cooling, equipment washing, and demineralization). Combined potable and 

service water use during construction would average about 1 gallon per minute (gpm). 

Drinking water also would be provided using bottled water. Portable toilets would 

minimize requirements for additional sanitary water. 

 During demonstration of the proposed project, Greenidge Station cooling water 

and service water would continue to be provided by Seneca Lake, while potable water 

would continue to be supplied by the Penn Yan municipal water system. For part of its 

water needs, Greenidge Station is equipped with an 8-ft diameter gravity-fed intake pipe 

that extends underwater approximately 700 ft beyond the shoreline to a lake-bottom 

intake structure. Beneath the shoreline, the pipe feeds into an underground concrete 

tunnel that conveys the water to the powerhouse. At the powerhouse, most of the water is 

pumped for use as noncontact cooling water to condense the steam exhausted from the 

Unit 3 steam turbine, while the remaining water is pumped for use as service water by the 

entire plant. The cooling water is returned to the lake after passing through the Unit 3 

condenser, while the service water undergoes treatment prior to discharge to the C pond 

(Figure 2.1.2). Unit 4 is equipped with a separate intake structure, intake pipeline, pump 

house, and discharge pipeline used exclusively for its cooling water. A 7-ft diameter 

intake pipe extends approximately 650 ft beyond the Seneca Lake shoreline above the 

lake surface, terminating in a submerged intake structure about 25 ft below the lake 
Greenidge Multi-Pollutant Control Project

Table 2.1.1. Typical operating characteristics for Greenidge Station Unit 4 alone and combined w

Unit 4 Unit

Operating characteristics 2002 base year 

Including the 

proposed project 2002 base year 

Generating capacity (net), MW 107 106 161 Capacity factor, %a 80 No change 80 Size of power plant site, acres 153 No change 153 Size of project site, acres 3 Size of nearby Lockwood Landfill, acres 143 No change 143 Bituminous coal consumption, tons/year 290,000 No change 450,000 Wood consumption, tons/year 11,450 No change 11,450 No. 2 fuel oil consumption, gallons/year 49,000 No change 120,000 Lime, tons/year 0 18,940 0 Ammonia, tons/year 0 128 0 Activated carbon, tons/year 0 43 0 Air emissions, tons/year  Sulfur dioxide (SO2)  Oxides of nitrogen (NOx)  Particulate matter (PM-10)  Particulate matter (PM-2.5)  Carbon monoxide (CO)  Volatile organic compounds (VOCs)  Hydrogen chloride (HCl)  Hydrogen fluoride (HF)  Mercury (Hg)  Ammonia (NH3)  Carbon dioxide (CO2) 

13,369 

1,820 

63 28 74 15 

276 

33 

0.012 0 

900,000 

602 660 

63 28 74 15 14 

2 0.005 0.14 

900,000 b 

19,450 

3,190 

95 42 92 18 

409 

50 

0.018 0 

1,300,000 

2-10 
DOE/EA

Table 2.1.1. concluded. 

Unit 4 Unit

Operating characteristics 2002 base year 

Including the 

proposed project 2002 base year 

Water use, gpm  Noncontact cooling water  Service water  Potable water 

68,000 

0 1.2 

No change 

93 

No change 

93,000 

500 112 

Effluents, gpm  Noncontact cooling water  Treated wastewater to Seneca Lake 

68,000 

0.7 

No change 

 No change 

93,000 

1 

Solid waste, tons/year  Bottom ash  Fly ash 

5,800 

40,000 

No change 

70,000 

8,700 

59,000 

a Capacity factor is the ratio of the energy output during a period of time to the energy that would have been produced if the equipm

maximum power during that period. 

b CO2 emissions would probably not change substantially from the current level because the circulating dry scrubber (CDS) would 

CO2 emissions but the decrease would probably be offset by the reduced boiler thermal efficiency resulting from the new low-NOx burn

of the proposed project). 
Greenidge Multi-Pollutant Control Project

surface. The cooling water is returned to Seneca Lake from the units’ separate discharge 

pipelines via a common discharge channel north of the powerhouse that flows northward 

into Keuka Outlet, which was formerly part of the canal system. Keuka Outlet, in turn, 

flows eastward into Seneca Lake. The actual increase in cooling water temperature 

resulting from the heat transfer to condense the steam exhausted from the turbines is 

about 18-20°F. Figure 2.1.6 is a water flow diagram that depicts current water 

requirements and discharges at Greenidge Station. 

 During the demonstration, the total flow of once-through, noncontact cooling 

water required to operate both units of the power plant at full load would continue to 

average 93,000 gpm. Potable water needs for the power plant would continue to be about 

1.2 gpm. The plant’s requirements for service water would increase from the current level 

of about 500 gpm to a level of 593 gpm because of the additional water needed for the 

lime hydrator and for the CDS. The lime hydrator would use about 7 gpm and the CDS 

would use approximately 86 gpm. The water would be drawn from Seneca Lake using 

the underground conduit that supplies Unit 3 cooling water and plantwide service water. 

The water would be consumed during the proposed processes rather than being returned 

to the lake. This additional water would represent approximately 0.1% of Greenidge 

Station’s current water use supplied by the lake and about 15% of the plant’s 

consumptive use. 

2.1.6.3 Fuel and Sorbent Requirements 

 The current fuel requirements of Greenidge Station would continue at 

approximately the same level during the demonstration of the proposed project. The plant 

annually burns about 450,000 tons of eastern bituminous coal. Currently, approximately 

90-93% of the coal is shipped by rail to the plant from mines near Wana, West Virginia, 

in Monongalia County near the southwestern corner of Pennsylvania, about 275 miles to 

the southwest of Greenidge Station. A train of 50 rail cars delivers coal to the station 

approximately twice weekly. Coal is dumped from the bottom of the rail cars into 

hoppers below the tracks. Occasionally, a train of 100 cars transports coal to the Dresden 

area, with 50 rail cars being delivered to Greenidge Station and the remaining 50 cars 

being held at a railroad siding immediately north of Dresden. The rail cars at the siding 

are switched with the rail cars at the power plant after the initial 50 cars have been 

unloaded. 

 The remaining 7-10% of the coal, about 30,000 to 35,000 tons annually, is 

currently delivered by truck from the Fisher Mining Company’s Thomas mine near 

English Center, Pennsylvania, about 100 miles to the south of Greenidge Station. About 

1,300 loads are delivered annually (i.e., about 25 loads per week) in 25-ton trucks, which 

dump the coal directly on a coal storage pile. The two coals are segregated within the 

storage pile and blended at the power plant to reduce the overall sulfur content of the 

higher-sulfur coal delivered by train using the lower-sulfur coal delivered by truck. While 

Fisher Mining Company currently is the only supplier of coal by truck, other small mines 

in the region could also supply lower-sulfur coal. Table 2.1.2 presents an analysis of the 

composition of the two types of coal. 

During demonstration of the proposed project, the lower-sulfur coal would 

probably not be required for Unit 4 because the CDS would reduce SO2 emissions from 

2-12 
2-13 

DOE/EA-1493; August 2004

Figure 2.1.6. Water flow diagram that depicts water requirements and 

discharges at Greenidge Station. 
Greenidge Multi-Pollutant Control Project

Table 2.1.2. Composition of bituminous coal consumed at 

Greenidge Station 

Characteristic 

Monongalia 

coal typical 

value 

Fisher 

 coal typical 

value 

Higher heating value, Btu/lb 13,097 11,800 

Analysis, % by weight 

 Moisture 

 Carbon 

 Hydrogen 

 Nitrogen 

 Sulfur 

 Ash 

 Oxygen 

 Chlorine 

5.80 

72.17 

4.79 

1.36 

2.90 

7.85 

5.04 

0.10 

7.63 

67.86 

3.86 

1.55 

0.91 

13.47 

4.72 

0.07 

unblended, higher-sulfur coal by approximately 95%. Consequently, Unit 4 would 

require about the same amount of coal, but about 2 additional trains of 100 rail cars each 

would deliver coal annually to offset about 850 loads no longer delivered by truck. Unit 3 

would continue to require about 450 truck loads per year of lower-sulfur coal to blend 

with higher-sulfur coal at the power plant to reduce the overall sulfur content. 

 Unit 4 also uses waste wood as feedstock in the combustor. The waste wood 

currently provides up to 10% of the total heat input to the boiler, which amounts to about 

11,450 tons of wood annually. The waste wood is in the form of particle board that is 

transported by truck from a furniture manufacturer in Jamestown, New York, about 150 

miles to the west-southwest of Greenidge Station. One truck per day usually delivers the 

waste wood. The arrangement is mutually beneficial because the furniture manufacturer 

avoids the cost of landfill disposal of the waste wood, while Unit 4 uses the wood as fuel. 

 About 120,000 gallons (gal) of No. 2 fuel oil are consumed annually at the plant 

for ignition and warm-up of the units. The fuel is delivered to the plant site by tanker 

trucks. 

 During demonstration of the proposed project, annual consumption of lime for the 

CDS and ammonia for the SCR system would be about 18,940 tons and 128 tons, 

respectively. The lime would probably be delivered by truck from Bellefonte, 

Pennsylvania, about 170 miles to the south-southwest of Greenidge Station. About 1,000 

loads would be delivered annually in 20-ton trucks. The lime could possibly be shipped 

by rail rather than truck. Ammonia would probably be delivered by truck from 

Allentown, Pennsylvania, about 200 miles to the south-southeast of the power plant. 

About 6 loads would be delivered annually in 20-ton tanker trucks. Annual consumption 

of powdered activated carbon for Hg control would be approximately 43 tons. About 3 

loads would be delivered annually in 20-ton trucks. A supplier of the carbon has not yet 

been identified. 

2.1.7 Outputs, Discharges, and Wastes 

2-14 
DOE/EA-1493; August 2004

Table 2.1.1 includes a summary of discharges and wastes for the existing Greenidge 

Station compared with the plant after implementation of the proposed project.

2.1.7.1 Air Emissions 

 Air emissions from Greenidge Station would generally decrease or continue at the 

same level during the demonstration of the proposed project. SO2 emissions would 

decrease from 19,450 tons per year currently to 6,683 tons per year. NOx emissions 

would decrease from 3,190 tons per year currently to 2,030 tons per year. Because of the 

additional particulate loading resulting from the injection of lime and powdered activated 

carbon, a new, more efficient ESP or new baghouse would replace the existing ESP at 

Unit 4. Consequently, plantwide PM-10 and PM-2.5 emissions would probably decrease 

compared with current annual emissions of 95 and 42 tons, respectively. However, it is 

assumed in this analysis that particulate emissions would continue at the same level 

because the additional particulate loading would at least partially offset (1) the improved 

efficiency of the ESP or baghouse and (2) the probably discontinuation of Unit 4’s use of 

higher-ash coal from the Fisher Mining Company (Table 2.1.2). CO and volatile organic 

compound (VOC) emissions would also be expected to remain at the same level (i.e., 92 

and 18 tons per year, respectively). Plantwide Hg emissions would decrease from about 

36 lb per year currently to about 22 lb per year because of the powdered activated carbon 

injected into the recycle stream or into the CDS. Due to ammonia (NH3) injection into the 

flue gas, NH3 emissions would increase from near zero to about 280 lb per year. 

Plantwide HCl and HF emissions would decrease to about 147 and 19 tons per year, 

respectively, compared with current emissions of 409 and 50 tons per year, respectively. 

SO3 emissions are expected to decrease by the same percentage as SO2 emissions, 

but current and future emissions are not known. Trace emissions of other pollutants 

would include beryllium, sulfuric acid mist, benzene, arsenic, and various heavy metals. 

CO2 emissions would probably not change substantially from the current level of 

1,300,000 tons per year because the CDS would be expected to decrease CO2 emissions 

but the decrease would probably be offset by an increase due to a change in combustion 

characteristics associated with the new low-NOx burners (not part of the proposed 

project). Although CO2 is not considered an air pollutant, CO2 emissions contribute to the 

greenhouse effect that is suspected to cause global warming and climate change (Mitchell 

1989). 

As discussed in Section 2.1.6.3, Unit 4 has the capability of co-firing coal with 

waste wood in the form of particle board, which is bonded with urea-formaldehyde. The 

wood contains less than 0.1% (by weight) formaldehyde, which is suspected of 

carcinogenic potential in humans. Emissions of organic compounds, including 

formaldehyde, are typically very low in power plant boilers because nearly complete 

combustion is attained by the high combustion temperatures and relatively long fuelresidence times. A formaldehyde emission analysis was performed by stack sampling at 

another New York power plant that co-fires coal with waste wood containing ureaformaldehyde (Lindsey 2004). As part of the analysis, the study included blanks to 

measure the ambient levels of formaldehyde in reagent solutions prior to the introduction 

of material collected from stack sampling. A statistical review of the data collected 

during the study concluded that formaldehyde levels during co-firing operation were 

indistinguishable from the laboratory blank levels. Also, formaldehyde emissions from 

2-15 
Greenidge Multi-Pollutant Control Project

100% coal-fired operation were indistinguishable from emissions during co-firing 

operation, both of which were nearly undetectable (Lindsey 2004). During the 

demonstration of the proposed project, formaldehyde emissions would be expected to 

remain very low. 

2.1.7.2 Liquid Discharges 

 The proposed project would not affect liquid effluent at Greenidge Station. The 

discharge of once-through, noncontact cooling water with both units operating at full load 

would continue to average 93,000 gpm. The cooling water from the units is discharged 

from separate pipelines to Seneca Lake via a common discharge channel and Keuka 

Outlet (Section 2.1.6.2). About 1 gpm of backwash effluent from the reverse osmosis 

system would continue to be discharged to C Pond (a settling pond) and ultimately to 

Seneca Lake. Floor drains and other collection sumps collect water potentially comingled with oil. Oil is captured by oil-adsorbent cloth on the surface of the sumps and 

the water is discharged to C Pond. The oil-adsorbent cloth is replaced periodically and 

transported from the site by a licensed waste management contractor to authorized 

facilities for disposal. 

 Stormwater runoff from the lined coal pile storage area is collected in the surge 

basin, conveyed periodically to the wastewater plant for treatment, and discharged to C 

Pond. Stormwater runoff from the lined Lockwood Landfill is captured using an 

underground leachate collection system that conveys the water to an adjacent 

sedimentation pond where it is sampled and treated, if necessary. 

2.1.7.3 Solid Wastes 

 Non-hazardous solid wastes generated at Greenidge Station include used office 

materials, empty material containers, and coal combustion ash. Non-hazardous solid 

wastes, with the exception of coal combustion ash, are removed from the site at regular 

intervals by a waste management contractor and transported for disposal at the Ontario 

County municipal landfill in Flint, New York, about 15 miles to the north-northwest of 

Greenidge Station, or at the Seneca Meadows municipal landfill in Seneca Falls, New 

York, about 20 miles to the northeast of the station. As part of the proposed project, the 

existing Unit 4 ESP may be dismantled and the metal plating sold for scrap. The 

remaining material from the ESP would go to a municipal landfill. 

 The power plant currently generates about 8,700 tons per year of bottom ash and 

59,000 tons per year of fly ash (the latter amount includes water used to wet the ash for 

transport). During the demonstration of the proposed project, the amount of bottom ash 

produced would not change, while the quantity of fly ash collected would increase to a 

yearly maximum of 89,000 tons due to the addition of Unit 4’s new, more efficient ESP 

or new baghouse, which would capture additional fly ash resulting from the injection of 

lime and powdered activated carbon. 

 Currently, all bottom ash is sold to municipalities to apply on roads for vehicle 

traction during treacherous winter conditions. Until sold, the bottom ash is stored in a 

settling pond and excavated as needed. Although some fly ash was sold until about 1995, 

all fly ash is currently trucked to the nearby AES-owned, double-lined Lockwood 

Landfill (Figure 2.1.2) for disposal. On average, 6 truck loads are transported daily from 

the fly ash silo to the landfill. Capacity at the landfill is sufficient for a remaining lifetime 

2-16 
DOE/EA-1493; August 2004

of more than 20 years. During the demonstration, bottom ash would continue to be sold 

to municipalities, and fly ash would be trucked to Lockwood Landfill. In addition, a 

commercial application for the fly ash would be pursued (e.g., cinder blocks, stabilization 

agent). If successfully implemented in the marketplace, the commercial application 

would reduce the amount of fly ash requiring disposal at the landfill to less than 89,000 

tons per year. 

 Fly ash transported to the landfill is conditioned with water to control dust and 

allow compaction. Ash is transported to the landfill site in covered trucks. Most of the 

short haul road is on AES property. The working face at the landfill is oriented in a 

direction to minimize fugitive dust. 

2.1.7.4 Toxic and Hazardous Materials 

 During operation, Greenidge Station requires potentially toxic or hazardous 

materials, such as chlorine and solvents, and generates potentially toxic or hazardous 

materials, including waste paints, oils, used rags, and empty material containers. All 

chemicals are properly labeled and stored according to local fire codes and Occupational 

Safety and Health Administration (OSHA) requirements. Chlorine is used for water 

filtration, while the solvents are used primarily in maintenance activities. Hazardous 

wastes generated during operation are removed from the site at regular intervals by a 

licensed waste management contractor and transported to authorized facilities for 

disposal. All toxic and hazardous materials are transported by truck to and from the 

station. 

 The power plant has in place a program to reduce, reuse, and recycle materials to 

the extent practicable. All light bulbs are treated as hazardous waste and disposed of in 

properly licensed facilities. The plant has a Spill Prevention, Control, and 

Countermeasures Plan (SPCCP) (40 CFR Part 112) that addresses the accidental release 

of materials to the environment. 

 With the exception of ammonia used in the SCR process, the proposed project 

would not affect the power plant's requirements for or generation of toxic and hazardous 

materials. Proper precautions would be taken during ammonia storage and handling to 

minimize the risk of an accidental release of ammonia. The ammonia would be stored in 

a cylindrical tank with secondary containment of sufficient volume to hold the entire 

contents of the tank in the unlikely event of a rupture. A SPCCP would be developed for 

ammonia, and the ammonia storage would comply with Emergency Planning and 

Community Right-to-Know Act (EPCRA) notification requirements. The ammonia 

would be transported by truck to the station (Section 2.1.6.3). 

2.2 ALTERNATIVES 

 The goals of a federal action establish the limits of its reasonable alternatives 

under the NEPA process. Congress established the PPII with a specific goal— to 

demonstrate commercial-scale technologies that improve the reliability and 

environmental performance of existing and new coal-fired power plants in the United 

States. DOE’s purpose in considering the proposed action (to provide cost-shared 

funding) is to demonstrate the viability of the integrated multi-pollutant control system in 

achieving the goal for the program. Reasonable alternatives to this proposed action must 

be capable of meeting this purpose. 

2-17 
Greenidge Multi-Pollutant Control Project

 Congress also directed DOE to pursue the goals of the legislation by providing 

partial funding for projects owned and controlled by nonfederal-government participants. 

This statutory requirement places DOE in a much more limited role than if the federal 

government were the owner and operator of the project. In the latter situation, DOE 

would ordinarily be required to review a wide variety of reasonable alternatives to the 

proposed action. However, in dealing with a nonfederal applicant, the scope of 

alternatives is necessarily more restricted. It is appropriate in such cases for DOE to give 

substantial weight to the needs of the proposer in establishing reasonable alternatives to 

the proposed action. Moreover, under the PPII, DOE’s role is limited to approving or 

disapproving the project as proposed by the participant. 

 Thus, the only reasonable alternative to the proposed action is the no-action 

alternative, including four scenarios reasonably expected as a consequence of the noaction alternative (Section 2.2.1). 

2.2.1 No-Action Alternative 

 Under the no-action alternative, DOE would not provide cost-shared funding to 

demonstrate the integrated multi-pollutant control system. Without DOE participation, 

the proposed project would be canceled, and the proposed combination of technologies 

would probably not be demonstrated elsewhere. Consequently, commercialization of the 

integrated multi-pollutant control system could be delayed or might not occur because 

utilities and industries tend to use known and demonstrated technologies over new, 

unproven technologies. At the site of the proposed project, four reasonably foreseeable 

scenarios could result. None of these scenarios would contribute to the PPII goal of 

demonstrating technologies at the commercial scale that improve the reliability and 

environmental performance of existing and new coal-fired power plants in the United 

States. 

 First, AES could shut down Greenidge Station. Because the plant is expected to 

be subject to more stringent emissions standards, mothballing or dismantling the plant 

would be one option available to the owners rather than installing expensive, 

commercially available emissions control equipment to comply with upcoming standards. 

Under this scenario, no construction activities would be undertaken, and no employment 

would be provided for construction workers in the area except for some limited activity 

associated with mothballing or dismantling the plant. Existing operations would cease, no 

electricity would be generated at the Greenidge site, and power plant workers would lose 

their jobs. Resource requirements and discharges and wastes would also cease. Current 

environmental conditions at the site would tend to revert back to conditions prior to plant 

operation, and existing impacts would be reduced. 

 However, to meet the existing regional demand for electricity, more electricity 

would need to be generated at one or more other sites to offset the elimination of 

electrical generation at Greenidge Station. While the exact location or locations are 

uncertain, the sites are likely to be at existing under-utilized power plants that have 

excess available capacity because they are costly and inefficient to operate. This rationale 

is based on the premise that, to meet demand, electric utilities typically dispatch 

electricity according to operating cost, starting with the least costly. The under-utilized 

plants would also tend to be older and generate greater quantities of air emissions, liquid 

discharges, and solid wastes. Therefore, while current environmental impacts would be 

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DOE/EA-1493; August 2004

reduced at the Greenidge site, impacts would likely increase at the site(s) where electrical 

generation would increase to compensate for shutting down Greenidge Station. 

 Second, AES could install commercially available pollution controls to comply 

with future emissions standards. Under this scenario, operations would remain essentially 

the same as for the existing plant. Electricity would be generated at approximately the 

same rate. Resource requirements and discharges and wastes would generally be the 

same, except that air emissions would be reduced because of the enhanced pollution 

controls and solid wastes would likely increase due to the captured air emissions. 

Additional solid wastes would likely be recycled or sold as a usable product. Because this 

scenario and the proposed project involve the installation of new pollution controls on an 

existing unit, construction activities associated with this scenario would be similar in 

scale to those of the proposed project. With the exception of improving air quality, there 

would be minimal change in current environmental conditions at the site and the impacts 

would remain very similar to existing conditions. 

 Third, AES could switch to using natural gas rather than coal at Greenidge 

Station, while maintaining most of the current equipment such as the boilers, turbines, 

ductwork, and chimneys. The need for some of the existing infrastructure such as the coal 

handling facilities and ash silos would be reduced or eliminated, depending on whether 

Unit 4 alone or both units were switched. Because a new 14-mile natural gas pipeline 

would need to be constructed to deliver the fuel, construction activities would probably 

be at a slightly greater level than those associated with the proposed project. Because of 

pipeline construction, disturbance beyond the Greenidge site would be greater under this 

scenario. Electricity would be generated at approximately the same rate. Resource 

requirements and discharges and wastes would generally be smaller because of the type 

of fuel and because the converted facility would be more efficient than the existing plant 

due to a new gas-fired delivery system and other upgrades. Air emissions, particularly 

SO2 emissions, would be considerably less because a new gas-fired delivery system 

would burn more efficiently and cleanly than an aging coal-fired power plant with limited 

emissions controls. Ash generation would be reduced or eliminated at the power plant, 

depending on whether Unit 4 alone or both units were switched. Current environmental 

conditions and impacts at the site would be expected to improve. 

 Finally, AES could purchase emissions allowances (e.g., SO2, NOx) as a 

compliance strategy for future emissions standards. By purchasing emissions allowances, 

AES would be compensating another utility or utilities for overcomplying with the 

standards while allowing the region as a whole to meet the limits for those emissions. 

Under this scenario, the existing power plant would continue to operate without change. 

No construction activities would be undertaken, and existing operations would remain 

essentially the same. Electricity would be generated at the same rate. Resource 

requirements and discharges and wastes would be the same. There would be negligible 

change in current environmental conditions at the site and the impacts would remain very 

similar to existing impacts. This scenario would not provide employment for construction 

workers in the area. 

2.2.2 Alternatives Dismissed from Further Consideration 

 The following sections discuss alternatives that were initially identified and 

considered by the project participant. Because DOE’s role is limited to providing the 

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Greenidge Multi-Pollutant Control Project

cost-shared funding for the selected project, DOE is limited to either accepting or 

rejecting the project as proposed by the participant, including the proposed technology 

and site. As such, reasonable alternatives to the proposed project are narrowed and the 

following alternatives have been dismissed from further consideration. 

2.2.2.1 Alternative Sites 

 CONSOL Energy initially considered additional sites during their site selection 

process. Site selection was governed primarily by benefits that could be realized by the 

companies participating in the project. An existing plant site was preferred because the 

cost associated with construction of the project and a new power plant at an undeveloped 

site would be much higher and the environmental impacts likely would be much greater 

than at an existing facility. The site selected for the project had to provide the maximum 

benefit to the companies by closely meeting the project’s technical needs and integrating 

with existing infrastructure. No other sites were considered after AES’s Greenidge 

Station in Dresden, New York, was identified as a candidate to host the project. Based on 

the above considerations, other sites are not reasonable alternatives and are not evaluated 

in this EA. 

2.2.2.2 Alternative Technologies 

 Other technologies have been dismissed as not reasonable. The proposed project 

was selected to demonstrate the operation of an integrated multi-pollutant control system 

on a coal-fired power plant. Other PPII projects were selected to demonstrate other coalbased technologies. The preselection reviews included environmental comparisons of 

proposals. The projects selected for demonstration are not considered alternatives to each 

other. 

 The use of other technologies and approaches which are not applicable to coal 

(e.g., natural gas, wind power, solar energy, and conservation) would not contribute to 

the PPII goal of demonstrating technologies at the commercial scale that improve the 

reliability and environmental performance of existing and new coal-fired power plants in 

the United States. 

2.2.2.3 Other Alternatives 

 Other alternatives, such as delaying or reducing the size of the proposed project, 

have been dismissed as not reasonable. Delaying the project would not result in any 

change of environmental impacts once the project were implemented but would adversely 

delay reductions in air emissions from the existing power plant and adversely affect the 

PPII goal of demonstrating technologies at the commercial scale for potential customers 

in the smaller boiler market. The design size for the proposed combination of 

technologies was selected because it is considered to be typical of the smaller boiler 

market; the size is large enough to show utilities that the technology, once demonstrated 

at this scale, could be applied without further scale-up to many units of similar size. A 

demonstration indicating that the performance and cost targets are achievable at the 100-

MW scale would convince potential customers that the integration of these systems is not 

only feasible but economically attractive (Section 1.3). 

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DOE/EA-1493; August 2004 

3. EXISTING ENVIRONMENT

3.1 SITE DESCRIPTION, LAND USE, AND AESTHETICS 

 The proposed project would be located at Greenidge Station in Yates County, 

New York, along the western shore of Seneca Lake (Figure 2.1.1). The equipment and 

surrounding access space for the proposed project would occupy a total of about 3 acres 

of land, which currently serves as a paved laydown area and contractor parking lot 

adjacent to the existing powerhouse for Units 3 and 4. 

Yates County is primarily rural, with over 73% of its population classified as 

"rural" and 27% as "urban" in the 2000 U.S. Census (U.S. Census Bureau 2004a). 

Agriculture, particularly that associated with vineyards and wine-making, is becoming an 

increasingly important land use in the county. While the amount of land in farms and the 

number of full-time farms decreased by 3% and 8%, respectively, in the state of New 

York between 1992 and 1997, they increased by 3% and 8%, respectively, in Yates 

County during the same period (USDA 1997). 

The proposed project site is located within an existing industrial area (Greenidge 

Station) that is surrounded primarily by agricultural and rural residential land uses. The 

Greenidge Station property is bounded to the east by Seneca Lake. The area south of the 

Greenidge Station property is used for a variety of purposes, including manufacturing at 

the Ferro Electronic Materials plant (which employs about 200 workers), but is primarily 

agricultural with rural residences interspersed with vineyards and wineries. The areas 

west and north of the Greenidge Station property are also primarily agricultural, but with 

more residences (including the village of Dresden) and small commercial developments 

along State Highway 14. 

 The visual landscape of the Greenidge Station property is conspicuously marked 

with industrial facilities such as the powerhouse, ESP equipment, smokestacks, coal 

storage piles, ash storage silos, railroad facilities, and other associated infrastructure 

(Figure 2.1.3). The power plant is visible from the surrounding local area, including from 

nearby Seneca Lake. 

3.2 ATMOSPHERIC RESOURCES

3.2.1 Climate

 The regional climate, which is classified as humid continental, is influenced by 

the passage of multiple types of air masses. Cold, dry air frequently arrives from the 

northern interior of the continent, while winds from the south and southwest transport 

warm, humid air from the Gulf of Mexico and adjacent subtropical waters. These two air 

masses provide the dominant characteristics of the area’s climate. A third type of air mass 

occasionally flows inland from the Atlantic Ocean to produce cool, cloudy, and damp 

weather conditions. 

 Winters are generally long and cold, with an average of 137 days per year with 

temperatures below 32°F and an average of 5 days per year with temperatures below 0°F 

(as measured at Penn Yan, the nearest monitoring station, which is located about 7 miles 

to the west of Greenidge Station). In January, the daily maximum temperature is 33°F, on 

average, while the daily minimum is 17°F. Average annual snowfall is about 54 in. 

Summers are pleasantly warm, with an average of 11 days per year with temperatures 

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Greenidge Multi-Pollutant Control Project

above 90°F. In July, the daily maximum temperature is 83°F, on average, while the daily 

minimum is 61°F. Annual precipitation (excluding snow) averages about 31 in. The 

distribution of precipitation is fairly uniform during the year, ranging from around 2 in. 

during the winter months to around 3 in. during the summer months. As depicted in 

Figure 3.2.1, prevailing winds at Penn Yan are dominantly from the southwest quadrant 

with few winds from the easterly and northeasterly directions. 

Figure 3.2.1. Wind rose for Penn Yan, New York (1999-2003). The frequency of wind blowing from each 

direction is plotted as a bar that extends from the center of the diagram. Wind speeds are denoted by bar 

widths and shading; the frequency of wind speed within each wind direction is depicted according to the 

length of that section of the bar. Because the wind rose displays directions from which the wind blows, 

emissions would travel downwind in the opposite direction.

3.2.2 Air Quality

 Criteria pollutants are defined as those for which National Ambient Air Quality 

Standards (NAAQS) exist (Table 3.2.1). These pollutants are sulfur dioxide (SO2), 

nitrogen dioxide (NO2), ozone (O3), carbon monoxide (CO), lead (Pb), and particulate 

matter less than or equal to 10 μm in aerodynamic diameter, designated PM-10. The U.S. 

Environmental Protection Agency (EPA) has also promulgated NAAQS for particulate 

matter less than or equal to 2.5 μm in aerodynamic diameter (PM-2.5) (62 FR 38652), 

and a new 8-hour NAAQS for O3 to replace the 1-hour O3 standard (62 FR 38856). 

 The NAAQS are expressed as concentrations of pollutants in the ambient air; that 

is, in the outdoor air to which the general public has access [40 CFR Part 501(e)]. 

Primary NAAQS define levels of air quality that EPA deems necessary, with an adequate 

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DOE/EA-1493; August 2004

Table 3.2.1 National Ambient Air Quality Standards (NAAQS) for criteria pollutants 

Primary 

(Health related) 

Secondary 

(Welfare related) 

Pollutant Averaging period Concentration 

Averaging 

period Concentration 

8-houra 9 ppm (10 mg/m3 CO ) No secondary standard 

1-houra 35 ppm (40 mg/m3

) No secondary standard 

Pb Maximum quarterly 

average 

1.5 μg/m3

Same as primary standard 

NO2 Annual arithmetic 

mean 

0.053 ppm 

(100 μg/m3

) Same as primary standard 

Maximum daily 1-

hour averageb 0.12 ppm (235 μg/m3 O3 ) 

4th highest 8-hour 

daily maximumc 0.08 ppm (157 μg/m3

) 

Same as primary standard 

Same as primary standard 

Annual arithmetic 

meand

50 μg/m3

Same as primary standard PM-10 

24-hourd 150 μg/m3 Same as primary standard 

Annual arithmetic 

meane 15 μg/m3

Same as primary standard PM-2.5 

98th percentile 

24-houre 65 μg/m3

Same as primary standard 

Annual arithmetic 

mean 

80 μg/m3 SO2 (0.03 ppm) 

24-houra 365 μg/m3

 (0.14 ppm) 

3-houra 1300 μg/m3

(0.50 ppm) 

a

Not to be exceeded more than once per year. 

b

The standard is attained when the expected number of days per calendar year with maximum hourly average 

concentrations above 0.12 ppm is equal to or less than 1, as determined according to Appendix H of the Ozone 

NAAQS. c

The 8-hour standard is met when the 3-year average of the annual 4th highest daily maximum 8-hour 

O3 concentration is less than or equal to 0.08 ppm. d

The annual PM-10 standard is attained when the expected annual arithmetic mean concentration is less than or 

equal to 50 μ/m3

 (3-year average); the 24-hour standard is attained when the expected number of days above 150 μg/m3

is less than or equal to 1 per year. e

The annual PM-2.5 standard is met when the annual average of the quarterly mean PM-2.5 concentrations is less 

than or equal to 15 μg/m3

, when averaged over 3 years. If spatial averaging is used, the annual averages from all 

monitors within the area may be averaged in the calculation of the 3-year mean. The 24-hour standard is met when the 

98th percentile value, averaged over 3 years, is less than or equal to 65 μg/m3.

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Greenidge Multi-Pollutant Control Project

margin of safety, to protect human health. Secondary NAAQS are similarly designated to 

protect human welfare by safeguarding environmental resources (such as soils, water, 

plants, and animals) and manufactured materials. States may modify NAAQS to make 

them more stringent, or set standards for additional pollutants. New York has added 

additional standards for criteria pollutants [e.g., 99% of 3-hour and 24-hour SO2

concentrations shall not exceed 0.25 ppm (650 μg/m3) and 0.10 ppm (261 μg/m3), 

respectively.] New York has also set ambient air quality standards for non-methane 

hydrocarbons, fluorides, beryllium, and hydrogen sulfide. The New York standards are 

not quantified further or used in the analysis (Section 4.1.2.2) because Greenidge 

Station’s air emissions during demonstration of the proposed project would decrease or 

continue at the same level, with the exception of ammonia (NH3) (Section 2.1.7.1). 

 Yates County, as well as adjoining Seneca County, is in attainment with NAAQS 

and state ambient air quality standards for all pollutants (John Kent, New York State 

Department of Environmental Conservation, personal communication to Robert Miller, 

ORNL, March 11, 2004). Because the air quality falls within standards, no ambient air 

quality monitoring stations are located in these counties. SO2 monitoring stations are 

located in Rochester, about 50 miles northwest of Dresden, and in Elmira, about 45 miles 

south-southeast of Dresden. PM-2.5 monitoring stations are also located in Rochester. A 

PM-10 monitoring station is located in Niagara Falls, about 120 miles west-northwest of 

Dresden, and an NO2 monitoring station is located in Buffalo, about 100 miles westnorthwest of Dresden. O3 monitoring stations are located in Rochester, Elmira, and 

Williamson, about 45 miles north-northwest of Dresden. 

 In addition to ambient air quality standards, which represent an upper bound on 

allowable pollutant concentrations, national air quality standards exist for Prevention of 

Significant Deterioration (PSD) (40 CFR Part 51.166). The PSD standards differ from the 

NAAQS in that the NAAQS specify maximum allowable concentrations of pollutants, 

while PSD requirements provide maximum allowable increases in concentrations of 

pollutants for areas already in compliance with the NAAQS. PSD standards are therefore 

expressed as allowable increments in the atmospheric concentrations of specific 

pollutants. Allowable PSD increments currently exist for three pollutants (NO2, SO2, and 

PM-10). One set of allowable increments exists for Class II areas, which cover most of 

the United States, and a much more stringent set of allowable increments exists for Class 

I areas, which include many national parks and monuments, wilderness areas, and other 

areas as specified in 40 CFR Part 51.166(e). Allowable PSD increments for Class I and 

Class II areas are given in Table 3.2.2. The PSD Class I area nearest to Greenidge Station 

is Lye Brook Wilderness Area in Vermont, about 200 miles to the east-northeast. 

 Contaminants other than the criteria pollutants are present in the atmosphere in 

varying amounts that depend on the magnitude and characteristics of the sources, the 

distance from each source, and the residence time of each pollutant in the atmosphere. In 

the ambient air, many of these pollutants are present only in extremely small 

concentrations, requiring expensive state-of-the-art equipment for detection and 

measurement. Measurements of existing ambient air concentrations for many hazardous 

pollutants are, at best, sporadic. Regulation of these pollutants is attempted at the sources; 

emissions from specific source categories are regulated by the National Emissions 

Standards for Hazardous Air Pollutants (40 CFR Part 61; 40 CFR Part 63). However, 

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DOE/EA-1493; August 2004

electric utilities are not included among the specific source categories to which these 

regulations apply. 

Table 3.2.2. Allowable increments for Prevention of Significant 

Deterioration (PSD) of air quality 

Allowable increment 

(μg/m3

) 

Pollutant 

Averaging 

period Class Ia Class IIa

Sulfur dioxide (SO2) 3-hour 

24-hour 

Annual 

25 

5 

2 

512 

91 

20 

Nitrogen dioxide (NO2) Annual 2.5 25 

Particulate matter less 

than 10 μm in 

aerodynamic diameter 

24-hour 

Annual 8 

4 

30 

17 

a

Class I areas are specifically designated areas (e.g., national parks greater than 

6,000 acres in area) in which the degradation of air quality is to be severely restricted. 

Class II areas (which include most of the United States) have a less stringent set of 

allowable increments. 

3.3 SURFACE WATER RESOURCES

3.3.1 Hydrology 

Seneca Lake is the largest of the 11 Finger Lakes in the Oswego River Basin of 

Central New York. The Finger Lakes were formed by about 20 cycles of glacial advances 

and retreats (Schuyler County 2003). Seneca Lake holds about 50% of the volume of all 

of the Finger Lakes. It is 35 miles long and averages about 2 miles in width. The average 

depth is 290 ft; the maximum depth is 651 ft. The typical lake elevation is 446 ft; 

flooding has been known to raise the level to a maximum of 450.2 ft. The lake rarely 

freezes over; since 1912 ice cover has apparently occurred only in localized, near shoreareas (SLAP-5 1999). 

Greenidge Station lies to the south of the Keuka Lake Outlet which it flows into 

and joins Seneca Lake to the east. Keuka Lake Outlet drains the Keuka Lake watershed; 

the elevation of Keuka Lake is 715 ft (SLAP-5 1999). 

At the U.S. Geological Survey (USGS) gauging station closest to the proposed 

project location (approximately 0.25 mile to the west), streamflow in the Keuka Lake 

Outlet averaged 120 cubic ft per second (cfs) in 2001, with a range of annual mean flows 

of 85 to 395 cfs over the period from 1966 through 2001 (USGS 2004). The average 

daily mean flows have ranged from 6 cfs in March of 2002 to 1540 cfs in May of 1996 

(USGS 2004). 

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Greenidge Multi-Pollutant Control Project

3.3.2 Water Quality and Use 

3.3.2.1 Water Quality 

Seneca Lake rates high in the quality spectrum of large U.S. lakes (SLAP-5 

1999). Its water meets all drinking water standards established by the EPA under the Safe 

Drinking Water Act and provides Class “AA” drinking water to 70,000 residents within 

its watershed (SLAP-5 1999). 

General clarity is about 15 ft in summer to 30 ft in winter. The water is chloride 

rich (150 mg/L), but well below concentrations (greater than 250 mg/L) which pose a 

health risk (SLAP-5 1999). The pH of Seneca Lake is slightly alkaline, 8.0 to 9.0, and 

varies with season and depth. Seneca Lake water is moderately hard, with total hardness 

concentrations of 140 – 150 mg/L (ppm CaCO3). Dissolved oxygen concentrations are at 

or near saturation throughout the water column during the entire year (SLAP-5 1999). 

Biological parameters indicate that Seneca Lake is borderline 

oligotrophic/mesotrophic. Very low nutrient concentrations, especially phosphate, 

prevent algal blooms and associated green coloration observed in smaller lakes of the 

region and prevent dissolved oxygen depletion in the hypolimnion during the late 

summer (SLAP-5 1999). 

3.3.2.2 Water Use 

Greenidge Station uses water for three primary purposes: noncontact cooling, 

service water, and potable water. Units 3 and 4 use once-through cooling water for 

noncontact condensing of steam exhausted from the turbines. About 93,000 gpm of water 

are withdrawn for this purpose from Seneca Lake through two underwater intake 

structures, one for each unit (Section 2.1.6.2). Service water for the entire plant (about 

500 gpm) is also withdrawn from the intake serving Unit 3. Potable water (about 1.2 

gpm) is supplied by the Penn Yan municipal water system. 

3.3.3 Effluent Discharges 

Cooling water from the units exits through their discharge pipelines to Seneca 

Lake via the discharge channel that flows into Keuka Lake Outlet (Section 2.1.6.2). 

Service water is treated prior to discharge to C pond (an unlined settling pond), which 

ultimately drains to Seneca Lake. C pond also receives treated wastewater from plant site 

activities and treated stormwater runoff from the lined coal pile. Stormwater runoff is 

collected at the Lockwood Landfill which has an underground leachate collection system 

that conveys water to an existing sedimentation pond where it is sampled and treated, if 

necessary. It is ultimately discharged through an outfall point to the Keuka Lake Outlet. 

Discharge of these water sources through their outfall points is regulated under the 

facility’s State Pollutant Discharge Elimination System (SPDES) permit, which limits the 

discharge volume and specifies effluent limitations. 

Other industrial, municipal, and private water users withdraw from and discharge 

into the Seneca Lake watershed, but in smaller quantities than Greenidge Station (SLAP5 1999). These discharges are regulated through SPDES permits. Fifty-one SPDES 

permits allow large-scale discharge into surface waters in the watershed; twenty-one 

allow discharge directly to Seneca Lake (SLAP-5 1999). The largest two users, Cargill 

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DOE/EA-1493; August 2004

Salt Company and U.S. Salt Corporation (both of Watkins Glen, New York), each 

discharge about 10% of Greenidge Station’s discharge to Seneca Lake (9,200 and 6,700 

gpm, respectively). The next largest users are Marsh Creek Wastewater Treatment Plant 

in Ontario County, which discharges about 2,800 gpm to Seneca Lake, followed by Penn 

Yan Sewage in Yates County, which discharges about 1,260 gpm to Keuka Lake Outlet. 

Other users discharge much lower volumes (SLAP-5 1999). 

3.3.4 Thermal Discharge 

Discharge of condenser cooling water to Seneca Lake is regulated under the 

SPDES permit, which limits discharge to 190 million gallons per day (MGD). Actual 

discharges are well below this limit. The average and maximum daily discharges for 

August were both 145 MGD. In November the average discharge was 133 MGD, and the 

maximum was 135 MGD (AES Greenidge 2003a,b). 

Permitted effluent temperature limits are 108°F in summer months and 86°F in 

winter months. The maximum allowable temperature increase under the permit is 31°F in 

the winter and 26°F in the summer. Actual temperatures and temperature increases are 

well below these limits. The highest effluent temperature in 2003 was 99°F, recorded in 

August (a summer month). The maximum temperature increase that month was 17°F. In 

November 2003 (a winter month) the maximum temperature increase was also 17°F and 

the maximum effluent temperature was 74°F. 

3.4 GEOLOGICAL RESOURCES 

3.4.1 Geology and Topography 

The Greenidge Station site is located in the glaciated Allegheny Plateau 

physiographic province. The station and the surrounding area are underlain by a thick 

sequence of sedimentary rock of middle to late Devonian age (approximately 360 to 375 

million years old), consisting predominantly of shale and siltstone, but also including 

sandstone and several distinct calcareous (limestone) layers. The strata have a slight dip 

toward the south. 

Continental glaciation during the Pleistocene Epoch had a major influence on 

regional topography. Glacial erosion deepened preglacial stream valleys into a semiparallel series of deep, narrow linear troughs that form the fiord-like basins of the Finger 

Lakes. Upland bedrock surfaces are mantled by varying thicknesses of glacial till 

(unsorted sediment deposited directly by glacier ice) and stratified glacial drift (sediments 

deposited by glacial meltwater). Thick sequences of glacial sediment also fill the deeper 

portions of the basins of the Finger Lakes. 

Greenidge Station is on the western shore of Seneca Lake, south of the mouth of 

the Keuka Outlet stream. Seneca Lake is the largest of the Finger Lakes at 35 miles long, 

about 1.9 miles wide on average, and as much as 650 ft deep. Its bedrock valley extends 

down to about 1,000 ft below sea level (Callinan 2001). The lake basin is oriented nearly 

due north-south. North of the power station and west of the lake, upland surfaces slope 

gently eastward toward the lake. The Keuka Outlet stream, which carries outflow from 

Keuka Lake to Seneca Lake, occupies a deep valley, with local relief of more 150 ft. 

Upland elevations, and thus topographic relief, increase to the south of the power station, 

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Greenidge Multi-Pollutant Control Project

where the short streams draining the uplands are more deeply incised than are similar 

streams north of the power station. 

Surficial materials at the power station site include glacial sediments and fly ash 

(in former waste disposal areas). Past site development activities in the area where new 

structures would be built for the proposed project included removal of surficial materials, 

exposing the bedrock surface. 

Lockwood Landfill occupies a 143-acre site about 1/4 mile west of Greenidge 

Station. In its natural state the site had a northward slope, from an elevation of about 660 

ft at the southwest corner of the property to less than 550 ft in the north end of the tract, 

near the Keuka Outlet stream. Silt-clay glacial till, ranging from 1 to 11 ft thick with an 

average thickness of about 4.5 ft, mantles the bedrock. This material is characterized as 

gravelly sandy clay silt to silty sand with clayey gravel, reflecting its unsorted character. 

Permeability of the till is very low; hydraulic conductivity values measured in the field 

ranged from 4.2 x 10-5 to 1.1 x 10-7 cm/sec. Site preparation for some portions of the 

landfill included placement of borrow soil (excavated from an adjoining area) on the 

ground surface to provide a minimum 5-ft thickness of soil above the groundwater table. 

Glacial deposits are thicker on portions of the AES property north of the waste disposal 

area, ranging from 25 to 80 ft thick (Criss 2004). 

3.4.2 Geological Hazards 

Geologic hazards are minimal at the site of the proposed project. The local 

bedrock is not subject to dissolution or subsidence, and the glacial sediments on the 

power station and landfill properties are naturally compacted mineral materials that are 

not subject to settlement or subsidence. Underground mining has not been conducted in 

the area. In the Seismic Zoning Map for the New York State Seismic Building Code 

proposed in 1993 by the New York State Earthquake Code Advisory Committee 

(Multidisciplinary Center for Earthquake Engineering Research 2004.), Yates County is 

included in Seismic Zone A. This is the lowest seismic risk classification in the state and 

the only mapped seismic zone characterized as “low risk.” In this zone there is less than a 

10% chance of a peak ground acceleration of 0.09 g (that is, 9% of the acceleration of 

gravity) in a 50-year period. A more recent set of estimates by the US Geological Survey 

indicates that the peak ground acceleration with a 10% chance of occurring in a 50-year 

period in the Dresden area is just 0.03 g (USGS 2002). 

3.4.3 Geological Resources 

Mineral resources of economic value in the area surrounding Greenidge Station 

include sand and gravel, clay and glacial till, and natural gas (Division of Mineral 

Resources 2004). In 2001 twelve active sand and gravel pits and one operation for mining 

of clay and glacial till were active in Yates County. Five gas wells were in production in 

Yates County in 2001 and 2002. Production of natural gas in the state of New York has 

been declining since a peak year in the 1980s. 

Another economic use of geologic resources in the area is underground storage of 

natural gas. One underground natural gas storage facility exists in Yates County 

(Division of Mineral Resources 2004). Another potential use of these resources is the 

study and collection of invertebrate fossils, which are abundant in some of the Devonian 

rock strata of the region. However, bedrock exposures are limited. 

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DOE/EA-1493; August 2004

3.4.4 Groundwater 

Groundwater is an important resource in the region. Over half of the population of 

Yates County relies on groundwater for drinking water supply, primarily in rural areas 

away from the lake shores (Winkley 2001). Permeable sands and gravels deposited by 

glacial meltwater form the most productive aquifers in the area, but in many areas the 

only source of groundwater supply is the relatively low-permeability bedrock (Keuka 

Lake Foundation 1996), in which groundwater occurs and moves almost entirely in 

fractures (Merin 1992). Domestic wells in the region typically yield less than 5 gpm 

(USDA Forest Service 2001). 

No groundwater is used on the Greenidge Station site. Some seepage from C 

pond (the unlined settling pond described in Section 3.3.3) enters the shallow 

groundwater system. Quarterly sampling of a network of about 30 onsite monitoring 

wells distributedaround the property has not detected adverse effects from station 

operations (Eileen Reynolds, AES, personal communication to Ellen Smith, ORNL, May 

25, 2004). Groundwater beneath the site discharges to Seneca Lake. 

Monitoring wells at the Lockwood Landfill site allow observations of 

groundwater conditions, including water levels and water quality, both up- and 

downgradient from the disposal area. Groundwater moves from southwest to northeast, 

mirroring the natural topography. Depth to groundwater in shallow wells is typically 

between 5 and 20 ft, with greater depths recorded on the downgradient side of the 

landfill. Observations in pairs of shallow and deep wells indicate a strong downward 

gradient from the till into the underlying bedrock. Most groundwater movement is 

believed to occur in the upper portion of the bedrock (Criss 2004). No water supply wells 

exist north of the landfill between the disposal area and the Keuka Outlet stream (north 

and northwest of the site), where shallow groundwater moving north from the landfill 

area would discharge to the surface water system. 

Groundwater quality at the Lockwood Landfill is strongly influenced by the 

chemistry of the rock units in which wells are completed. The natural chemical 

characteristics of site groundwater, as observed in background monitoring wells, typically 

include slightly alkaline pH (7.0 to 7.5) and very high hardness and alkalinity (both 

hardness and alkalinity are consistently above 250 mg/L). Water with these attributes is 

generally suitable for use as drinking water, but its hardness and its characteristically high 

concentrations of iron (frequently exceeding 0.3 mg/L in unfiltered samples) and total 

dissolved solids (450-570 mg/L) may be objectionable for some users and some types of 

domestic uses. Additionally, some unfiltered water samples from background wells have 

exceeded drinking water quality criteria for specific metals, including antimony and 

cadmium (Criss 2004). 

Leachate collection systems within the Lockwood Landfill and groundwater 

underdrains beneath unlined portions of the landfill collect water that has percolated 

through disposed waste. This water exhibits substantially elevated levels of many 

constituents, but as of the end of 2002 monitoring of downgradient monitoring wells had 

not detected water quality changes attributable to landfill contamination (Criss 2004). 

The clay-rich soil and bedrock at the landfill site can be expected to have geochemical 

attributes that would help to retard the transport of many dissolved contaminants. 

3-9 
Greenidge Multi-Pollutant Control Project

3.5 FLOODPLAINS AND WETLANDS 

3.5.1 Floodplains 

The entire proposed project site would be located outside the Federal Emergency 

Management Agency’s delineated 500-year floodplain for Keuka Lake Outlet and Seneca 

Lake (FEMA 1987). 

3.5.2 Wetlands 

The proposed project would be located in an existing, developed industrial site 

containing no wetlands. The closest actual wetland area to the project site is about 1,200 

ft to the northwest across the Keuka Lake Outlet. This wetland is about five acres in size 

and is classified by the U.S. Fish and Wildlife Service (FWS) as an inland forested 

wetland (FWS 2004a). Another wetland occurs about 1,400 ft to the north of the 

proposed project site along the confluence of Keuka Lake Outlet with Seneca Lake. Here, 

a long narrow strip of FWS-classified inland herbaceous wetland totaling about 1.5 acres 

in size lies on the south bank of the outlet and extends into the lake (FWS 2004a). 

3.6 ECOLOGICAL RESOURCES 

3.6.1 Terrestrial Ecology 

The proposed project would be located in the Laurentian Mixed Forest Province 

(Ecological Subregion) of the United States (Bailey 1995). This province is transitional 

between the boreal forest and the broadleaf deciduous zones. In the Seneca Lake 

watershed more than 90% of the remaining forests are mixed northern hardwood and oak 

(SLAP-5 1999). The proposed project would occupy about 3 acres of developed 

industrial property in the midst of the 153-acre Greenidge Station. The proposed project 

site is characterized by an almost complete lack of natural ecological resources. 

Vegetation occurs in the project area only on isolated unpaved areas (e.g., road shoulders 

and cut slopes) and includes a mixture of grasses, herbaceous species (e.g., mullen), and 

brush consisting of sumac, ailanthus, and red cedar. Isolated patches of forest occur in the 

area surrounding Greenidge Station, along with open fields, residential development, and 

other industrial sites. 

Wildlife is abundant and varied due to the variety of land uses in the Seneca Lake 

basin. Among the most prominent are several species of songbirds and shorebirds and 

mammals including white-tailed deer, beaver, groundhog, skunk, opossum, gray squirrel, 

Eastern coyote, red fox, muskrat, and cottontail rabbit (SLAP-5 1999). Seneca Lake has a 

significant concentration of wintering waterfowl. Diving ducks use the whole lake, and 

mallard and American black ducks concentrate around Dresden station. Other species 

present include greater scaup, canvasback, redhead, common goldeneye, buffelhead, 

common merganser, and Canada goose. The closest wildlife management area to the 

proposed project, the Willard Wildlife Management Area, is located across Seneca Lake 

in the Town of Ovid, about 5 miles east of Greenidge Station. 

3-10 
DOE/EA-1493; August 2004

3.6.2 Aquatic Ecology 

Seneca Lake supports a substantial fishery consisting predominantly of lake trout, 

smallmouth bass, and yellow perch. Other species such as rainbow trout, brown trout, 

landlocked-Atlantic salmon, northern pike, and largemouth bass add diversity to the 

fishery. In addition, alewives (sawbellies) and rainbow smelt provide a dependable forage 

base for trout and salmon (SLAP-5 1999). The fishery has benefited from steady annual 

stockings of 60,000 lake trout, 65,000 brown trout, and 24,000 Atlantic salmon. All other 

fish species are sustained entirely by natural reproduction. An important factor in a recent 

resurgence of the Seneca fishery is the New York State Department of Environmental 

Conservation’s (NYSDEC’s) ongoing control of the invasive, parasitic sea lamprey. The 

control program involves applying a highly selective chemical lampricide to known sea 

lamprey nursery areas in Catherine Creek and Keuka Lake Outlet at three-year intervals 

(SLAP-5 1999). 

Another invasive species, the zebra mussel, has more recently invaded Seneca 

Lake and was first observed late in the summer of 1992. Today zebra mussels have 

colonized almost every suitable shallow-water habitat, filter-feeding on the plankton. 

Changes in lake water opacity, nutrient concentrations, and chlorophyll-a concentrations 

from the early 1900s to 1998 suggest that zebra mussels have decreased the algal 

concentrations in Seneca Lake and increased water clarity. Starting in 1998 and 

continuing through 1999 however, these trends reversed. The variability indicates the 

lack of complete understanding of the present extent and future impact of zebra mussels 

on the ecology of the lake and its fishery (SLAP-5 1999). 

3.6.3 Threatened and Endangered Species 

The FWS (FWS 2004b) lists 12 non-marine animal and 6 plant species, which are 

either threatened or endangered, that may occur in the state of New York. Of these only 

two species, Indiana bat (endangered) and Leedy's roseroot (threatened), are known to be 

found in Yates County (EPA 2004). The state of New York lists many species of animals 

(NYSDEC 2003a) and plants (NYSDEC 2003b) as either threatened or endangered. 

Some of these state-listed species are known to occur in the Seneca Lake watershed 

(SLAP-5 1999). Of the threatened and endangered species in the watershed, only one 

plant, Leedy's roseroot (state endangered, also federally threatened), has been confirmed 

to be in Yates County (NYSDEC 2003b). The state-listed endangered, short-eared owl 

(Asio flammeus) could possibly occur in Yates County (NYSDEC 2003a; SLAP-5 1999). 

Because the proposed project site is already highly disturbed and offers virtually no 

suitable habitat for any of these species, they are unlikely to occur at the site. 

3.6.4 Biodiversity 

The proposed project site is located within an area of the United States that 

exhibits reasonably good biodiversity at the state and ecoregion scales. Numerous 

ecosystem types and plant, mammalian, and avian species contribute significantly to the 

overall biodiversity. Based on (1) the variety of surviving habitats and (2) the number of 

species in the more visible classes of plants and animals observed in the environs, the 

area within a few miles of the proposed project exhibits moderately high biodiversity. 

The proposed project site itself exhibits little biodiversity because previous industrial 

3-11 
Greenidge Multi-Pollutant Control Project

development has almost completely destroyed the native habitats that were once present, 

as well as the wildlife communities they supported. 

3.7 CULTURAL RESOURCES

Although no record exists of a cultural resources survey of the Greenidge Station 

property, the proposed project site has been disturbed by power plant construction and 

operations since the 1950s, and no cultural resources have been reported or found on or 

near the site (CONSOL 2002). In Yates County, 61 properties are listed on the National 

Register of Historic Places (NPS 2004). The two National Register properties closest to 

the proposed project site are the Robert Ingersoll Birthplace and the Christopher Willis 

House, both located in the town of Dresden about 0.5 mile northwest of the project site. 

3.8 SOCIOECONOMICS

This section contains data on the socioeconomic resources most likely to be 

affected by the proposed project. Most of the data are for communities in Yates County, 

where the proposed project site is located, but some are for Ontario County and the city 

of Geneva because they would also experience socioeconomic impacts from the proposed 

project. 

3.8.1 Population

Table 3.8.1 contains population data for Yates County, Ontario County, and some 

of the local communities most likely to be affected by the proposed project. As indicated 

in Table 3.8.1, both Yates County and Ontario County experienced moderate population 

growth (7.9% and 5.4%, respectively) between 1990 and 2000. Dresden, the community 

closest to the proposed project site, is a small village with around 300 residents. It is 

anticipated that most of the additional workers associated with construction of the 

proposed project would reside in the village of Penn Yan (population 5,219) or the city of 

Geneva (population 13,617), each of which experienced population declines between 

1990 and 2000. 

Table 3.8.1. Population data for Yates County, Ontario County, and selected communities 

Location 1990 Population 2000 Population 

Percent change 

1990-2000 

Yates County 22,810 24,621 7.9 

Penn Yan 5,248 5,219 (0.6) 

Dresden NA 307 NA 

Ontario County 95,101 100,224 5.4 

Geneva 14,143 13,617 (3.7) 

NA=Not available 

Sources: U.S. Census Bureau 1994; U.S. Census Bureau 2004a; U.S. Census Bureau 2004b 

3.8.2 Employment and Income

Table 3.8.2 contains employment and income data for Yates County and Ontario 

County in 2000. The unemployment rate in Yates County (6.4%) was higher than that in 

3-12 
DOE/EA-1493; August 2004

the United States (5.8%), but lower than that in the state of New York (7.1%). The 

unemployment rate in Ontario County (4.5%) was lower than both the state and national 

rates. Both counties had per capita incomes in 2000 lower than those of the state of New 

York ($23,289) and the United States ($21,587) (U.S. Census Bureau 2004b). 

Table 3.8.2. Employment and income data for Yates County and Ontario County in 2000

Location Labor 

force 

Number 

Employed 

Number 

Unemployed 

Unemployment 

rate (%) 

Per capita 

income ($) 

Yates County 11,959 11,191 768 6.4 16,781 

Ontario County 53,200 50,822 2,378 4.5 21,533 

Source: U.S. Census Bureau 2004b 

Table 3.8.3 contains data on employment by industry or economic sector in Yates 

County and Ontario County in 2000. Employment patterns are similar in both counties, 

with the largest sector being educational, health, and social services, followed by 

manufacturing and retail trade. 

The largest employer in Yates County is the Penn Yan Central School District 

with 400 employees. Other large employers in Yates County include the Soldiers and 

Sailors Memorial Hospital in Penn Yan (342 full-time and 181 part-time employees), 

Yates County government (310 employees), and the Yates County Chapter of the New 

York State Association for Retarded Citizens, Inc. (190 full-time and 125 client 

employees) (YCIDA 2003). 

Greenidge Station currently employs 44 people, the majority of whom reside in 

Penn Yan (85%) and Geneva (10%). Total employee payroll at Greenidge Station in 2003 

was over $6.4 million (AES Greenidge 2004). 

3.8.3 Housing

Table 3.8.4 contains housing data for Yates County, Ontario County, and some of 

the local communities most likely to be affected by the proposed project. Yates County 

has a relatively high vacancy rate (25.2%), probably due to the large number of tourist 

and vacation properties in the area. Penn Yan (6.4%) and Geneva (10.1%), the 

communities in which most current Greenidge Station employees reside, have much 

lower vacancy rates than Yates County. The housing stock in Penn Yan and Geneva is 

relatively old, with 56.2% and 65.3% of the housing units, respectively, built before 1940 

(Table 3.8.4). 

3.8.4 Water and Wastewater Services 

Although many residents of Yates County rely on private wells for their water 

supply, residents of Penn Yan and Dresden receive their water from a water treatment 

facility located in Penn Yan. The Penn Yan water treatment facility has a capacity of 1.77 

MGD and currently operates at about 0.8 MGD (Steve Isaacs, Yates County Industrial 

Development Agency, personal communication to Bo Saulsbury, ORNL, February 11, 

2004). 

Penn Yan also has a wastewater treatment facility with a capacity of 1.8 MGD 

and current use of about 1.0 MGD. For several years, however, Penn Yan's wastewater 

treatment system has had a recurring problem with infiltration and/or infill, in which

3-13 
Greenidge Multi-Pollutant Control Project

Table 3.8.3. Employment by industry or economic sector 

in Yates County and Ontario County in 2000

Yates County Ontario County 

Industry Number Percent Number Percent 

Educational, health, and 

social services 

3,096 27.7 12,891 25.4 

Manufacturing 1,713 15.3 9,557 18.8 

Retail trade 1,251 11.2 6,378 12.5 

Arts, entertainment, 

recreation, 

accommodation, and 

food services 

801 7.2 3,889 7.7 

Construction 839 7.5 3,327 6.5 

Professional, scientific, 

management, 

administrative, and 

waste management 

services 

512 4.6 3,485 6.9 

Wholesale trade 306 2.7 1,440 2.8 

Agriculture, forestry, 

fishing and hunting, and 

mining 

731 6.5 952 1.9 

Other services (except 

public administration) 

484 4.3 2,248 4.4 

Finance, insurance, real 

estate, and rental and 

leasing 

420 3.7 2,095 4.1 

Public administration 423 3.8 1,732 3.4 

Transportation and 

warehousing, and 

utilities 

438 3.9 1,685 3.3 

Information 177 1.6 1,143 2.3 

Total 11,191 100 50,822 100 

Source: U.S. Census Bureau 2004b 

3-14 
DOE/EA-1493; August 2004

Table 3.8.4. Housing data for Yates County, Ontario County, and selected communities in 

2000

Yates 

County Penn Yan Dresden 

Ontario 

County Geneva 

Total housing 

units 

12,064 2,281 149 42,647 5,573 

Occupied units 9,029 2,135 128 38,370 5,009 

Vacant units 3,035 146 21 4,277 564 

Vacancy rate (%) 25.2 6.4 14.1 10.0 10.1 

Median value, 

owner-occupied 

($) 

75,600 70,400 63,200 94,100 69,300 

Median rent, 

renter-occupied 

($) 

467 453 605 564 474 

Units built before 

1940 (%) 

39.3 56.2 78.5 34.4 65.3 

Source: U.S. Census Bureau 2004b 

groundwater gets into the sewer system through leaks in the pipes, joints, and other 

structures. During periods of high groundwater flow, this additional water in the sewer 

system causes added demand (and cost) to the operation of the treatment system (Penn 

Yan 1999). The town of Penn Yan is currently trying to resolve this wastewater treatment 

issue. Residents of the village of Dresden rely on septic systems for wastewater disposal. 

3.8.5 Local Government Revenues

The 2004 budget for Yates County is projecting over $32.6 million in total 

revenues, with $10.2 million coming from local property and school taxes (YCIDA 

2004). In 2003, Greenidge Station paid Yates County $784,862 in property taxes and 

$888,877 in school taxes (AES Greenidge 2004). 

3.8.6 Environmental Justice 

Table 3.8.5 contains the percentages of the total population that are classified as 

"minority" and "below poverty" for the United States, the state of New York, Yates 

County, and the five Census Tracts within Yates County. Yates County and its five 

Census Tracts have much lower minority percentages than the United States and the state 

of New York. Yates County's percentage below the poverty level (13.1%) is slightly 

lower than that of the state of New York (14.6%), but is slightly higher than that of the 

United States (12.4%). 

Within Yates County, Census Tract 9905 and Census Tract 9901 each have 

slightly higher percentages below the poverty level (16.0% and 15.2%, respectively) than 

3-15 
Greenidge Multi-Pollutant Control Project

Yates County, the state of New York, and the United States. Both Census Tract 9905 and 

Census Tract 9901 are located in the eastern part of Yates County, between Seneca Lake 

and Penn Yan. The proposed project site at Greenidge Station is located within Census 

Tract 9901. 

Table 3.8.5. Environmental justice data for the United States, the state of New York, 

Yates County, and the five Census Tracts within Yates County 

Place % Minority1 % Below Poverty2

United States 30.9 12.4 

State of New York 38.0 14.6 

Yates County 3.2 13.1 

Census Tracts within Yates County 

CT 9901 4.4 15.2 

CT 9902 3.0 13.2 

CT 9903 2.5 9.5 

CT 9904 2.4 11.6 

CT 9905 3.5 16.0 

1

Includes all persons who identified themselves as not “White alone,” plus those who identified 

themselves as both “White alone” and “Hispanic or Latino.” 

2

Represents individuals below the poverty level as defined by the U.S. Census Bureau. 

Sources: U.S. Census Bureau. 2004a; U.S. Census Bureau 2004b 

3.9 TRANSPORTATION AND NOISE

3.9.1 Transportation

3.9.1.1 Roads

Road access to the proposed project site is from State Highway 14, a two-lane 

north/south highway that parallels Seneca Lake through eastern Yates County (Figure 

2.1.1). In 2003, annual average daily traffic (ADT) was 2,595 vehicles on the segment of 

Highway 14 closest to the proposed project (i.e., between State Highway 54 and County 

Route 36). This traffic volume represents a "Volume/Capacity Ratio" of 0.1 (i.e., the road 

segment is at 10% of capacity), and the level of service on Highway 14 near the proposed 

project site is "very good" (Bill Piatt, New York State Department of Transportation 

Region 6, personal communication to Bo Saulsbury, ORNL, February 11, 2004). The 

New York State Department of Transportation has no road construction activities planned 

for Highway 14 or for any other roads in Yates County (NYSDOT 2004). 

Access to the proposed project site from Highway 14 is via Lampman Road, a 

short, two-lane gravel road currently used by employee vehicles and delivery trucks 

coming to and from Greenidge Station. 

3-16 
DOE/EA-1493; August 2004

3.9.1.2 Rail

Rail access to the proposed project site is from a CSX trunk rail line that is 

currently used to transport coal to Greenidge Station. Under current operations, a train of 

50 rail cars delivers coal to the station about twice per week. Occasionally, a train of 100 

cars transports coal to the Dresden area, with 50 cars moved to Greenidge Station to 

remove the coal, while the remaining 50 cars are parked at a railroad siding immediately 

north of Dresden until they can be switched with the empty 50-car section at Greenidge 

Station. 

3.9.2 Noise

Noise can be defined as unwanted sound. Noise becomes annoying when it is loud 

enough to be heard above the usual background sounds to which people have become 

accustomed. Background levels, in turn, vary with location and time of day. Sound levels 

are measured in decibels (dB); measured values are normally adjusted to account for the 

response of the human ear, in which case they are expressed as decibels as measured on 

the A-weighted scale [dB(A)]. 

Greenidge Station sits in a rural area on the west bank of Seneca Lake. The 

village of Dresden, where residential dwellings line the shores of the lake, is located 1 

mile northwest of the proposed project. There is no residential population within a quarter 

mile of the proposed project (Radder 2002). According to a survey by Goodfriend and 

Associates (1971), sound levels at Greenidge Station are similar to those at other 

industrial plants. The relatively steady noise resulting from Greenidge Station is 

augmented by the presence of other sound sources in the area, including vehicular traffic, 

farming traffic (i.e., tractors, grape harvesters) nearby passing trains, recreational 

activities, and other industrial activities. For example, sound levels may exceed 100 

dB(A) within 50 ft of a train passing on one of the nearby railroad tracks. Although the 

presence of Seneca Lake precludes stationary noise sources to the east of Greenidge 

Station, motorboats using the lake generate noise. Residential areas are minimally 

affected by Greenidge Station. 

Neither Torrey Township nor the City of Dresden Codes contain ordnances 

regarding noise. No documented, noise-related complaints associated with Greenidge 

Station have been identified. Past construction activities at Greenidge Station did not 

generate noise that triggered documented noise-related complaints. 

In addition to the guideline level of 55 dB(A) given by the Environmental 

Protection Agency (EPA 1974), a level of 90 dB(A) is specified by the Occupational 

Safety and Health Administration (OSHA) (29 CFR Part 1910.95) as the maximum 

occupational exposure during an 8-hour period for protection against hearing loss. When 

worker noise exposure levels equal or exceed an 8-hour time weighted average (TWA) of 

85 dB(A), the employer is required to administer a continuing effective hearing 

conservation program. This 85 dB(A) represents an action level. Greenidge Station has a 

hearing conservation program in place for all workers. 

3-17 
DOE/EA-1493; August 2004

4. ENVIRONMENTAL CONSEQUENCES

This section analyzes the potential impacts to human and environmental resources 

resulting from construction and demonstration of the proposed multi-pollutant control 

system and for four reasonably foreseeable scenarios of no action. Potentially affected 

physical, biological, social, and economic resources are included. 

4.1 ENVIRONMENTAL IMPACTS OF THE PROPOSED PROJECT 

4.1.1 Land Use and Aesthetics 

4.1.1.1 Land Use 

 On the Greenidge Station site, the proposed project would require about 3 acres of 

land adjacent to the existing powerhouse for construction of new facilities (Section 

2.1.6.1). This land currently is dedicated to industrial uses and is mostly paved. Because 

construction would displace an existing parking area, a nearby vacant land area of similar 

size would probably be developed for parking. The land that would be occupied by a new 

parking lot is cleared and is dedicated to industrial use, but has not previously been 

developed. 

 Disposal of fly ash generated by project operation would be in the nearby AESowned, double-lined Lockwood Landfill, which is a state-permitted landfill on a site that 

is already dedicated to waste disposal. 

 The proposed project would not affect offsite land use because it would be 

confined to an existing industrial area within the Greenidge Station and Lockwood 

Landfill property. As with Greenidge Station, the proposed project would be consistent 

with existing land use plans and local zoning. The in-migration of workers that would 

result from project construction would not be large enough to increase the amount of 

offsite land required for residential purposes (Section 4.1.9.3). 

4.1.1.2 Aesthetics

 Greenidge Station is visible from the surrounding local area (Figure 2.1.3), 

including from nearby Seneca Lake. Because the proposed project’s equipment would be 

installed adjacent to the west side of the existing powerhouse, portions of the equipment 

would be visible from the west, including along nearby State Highway 14. However, 

because of the similarity of the architecture and colors associated with the existing and 

new equipment, any visible portions would blend into the existing industrial structures. 

From other viewpoints, including Seneca Lake, the proposed equipment would likely be 

obscured by the taller, existing power plant structures. Existing vegetation would also 

contribute in some locations to the visual screening of the proposed equipment. In 

summary, because the visual landscape of the Greenidge Station property is already 

conspicuously marked with industrial structures (Section 3.1), the visual impacts of the 

facilities on the property after installation of the proposed project’s equipment would be 

indistinguishable from the existing visual impacts. 

With regard to Lockwood Landfill, the proposed project would not affect the 

visual appearance of the landfill. 

4-1 
Greenidge Multi-Pollutant Control Project

4.1.2 Atmospheric Resources and Air Quality

 This section evaluates potential impacts to atmospheric resources that may result 

from construction or operation of the proposed project. Section 4.1.2.1 discusses effects 

of construction, including fugitive dust associated with earthwork and excavation. 

Section 4.1.2.2 discusses operational effects, particularly with regard to changes from 

existing operations. 

4.1.2.1 Construction

 During construction of the integrated multi-pollutant control system, temporary 

and localized increases in atmospheric concentrations of NOx, CO, SO2, VOCs, and 

particulate matter would result from exhaust emissions of workers’ vehicles, heavy 

construction vehicles, diesel generators, and other machinery and tools. Construction 

vehicles and machinery would be equipped with standard pollution-control devices to 

minimize emissions. These emissions would be very small compared to regulatory 

thresholds typically used to determine whether further air quality impact analysis is 

necessary [40 CFR Part 93.153(b)]. 

 Fugitive dust would result from excavation and earthwork. The proposed project 

would use a total of about 3 acres of previously disturbed land, primarily for the new ESP 

or baghouse and surrounding access space. Limited site clearing and grading would be 

required because the land currently serves as a paved laydown area and contractor 

parking lot adjacent to the existing powerhouse for Units 3 and 4. A new paved parking 

lot would likely be built on vacant, cleared land near the powerhouse to compensate for 

the loss of the existing lot. The temporary impacts of fugitive dust on offsite ambient air 

concentrations of particulate matter less than 10 μm in aerodynamic diameter (PM-10) 

would be localized because of the small construction area, the limited amount of clearing 

and grading, and the relatively rapid settling of fugitive dust due to its relatively large 

size. Sprinkling of exposed soils with water would be conducted as necessary to 

minimize fugitive dust emissions. 

4.1.2.2 Operation

 Potential air quality impacts resulting from changes at Greenidge Station during 

demonstration of the proposed project would generally be beneficial because, with the 

exception of ammonia (NH3), plantwide air emissions would decrease or continue at the 

same level (Section 2.1.7.1). SO2 emissions would decrease from 19,450 tons per year 

currently to 6,683 tons per year. NOx emissions would decrease from 3,190 tons per year 

currently to 2,030 tons per year. PM-10 and PM-2.5 emissions are assumed to continue at 

their existing level of 95 and 42 tons per year, respectively (Section 2.1.7.1). CO and 

volatile organic compound (VOC) emissions would also be expected to remain at their 

current level (i.e., 92 and 18 tons per year, respectively). Plantwide Hg emissions would 

decrease from about 36 lb per year currently to about 22 lb per year. NH3 emissions 

would increase from near zero to about 280 lb per year. Plantwide HCl and HF emissions 

would decrease to about 147 and 19 tons per year, respectively, compared with current 

emissions of 409 and 50 tons per year, respectively. As discussed in Section 2.1.7.1, 

annual CO2 emissions would probably not change substantially from the current level of 

1,300,000 tons.

4-2 
DOE/EA-1493; August 2004

 The existing 250-ft stack that serves Unit 3 and 227-ft stack that serves Unit 4 

would continue to be used (the stack tops are at the same elevation, but the base elevation 

of the Unit 4 stack is 23 ft above the Unit 3 stack base elevation). While the Unit 3 stack 

parameters would not change and the Unit 4 stack height and flue diameter would remain 

the same during the demonstration, the Unit 4 exit temperature and exit velocity would 

decrease. The exit temperature would decrease from the current 235°F to 153°F, and the 

exit velocity would drop from the existing 46 miles per hour to 31 miles per hour. 

Consequently, the decreased exit temperature and exit velocity during the demonstration 

would decrease the plume rise from the Unit 4 stack, which could result in increased 

downwind ground-level concentrations of those air pollutants experiencing little or no 

decrease in stack emissions. 

 An analysis of the magnitude of the changes in ground-level pollutant 

concentrations resulting from changes in Unit 4 stack parameters was conducted using 

the EPA-approved SCREEN3 air dispersion model (EPA 1995). SCREEN3 was used 

because the nearest wind data required by more detailed models are recorded at Penn 

Yan, which is located about 7 miles to the west of Greenidge Station (Section 3.2.1), and 

because the SCREEN3 results are conservative (forming an upper bound) using a full 

range of potential meteorological conditions. Because the height of the Unit 4 stack is 

approximately 2.5 times the height of the adjacent powerhouse (i.e., Good Engineering 

Practice stack height), wake effects from building downwash were not considered. 

Because increased ground-level concentrations resulting from a lower plume height 

would be maximized in elevated terrain, locations representing the steepest rise in terrain 

within 4 miles of the power plant were selected for use in the model. 

 The results from the model were applied to particulate emissions from Unit 4, 

conservatively assuming that no reduction in emissions resulting from the proposed 

project would occur. Hourly emissions were calculated by adjusting the 2002 base year 

emissions (Table 2.1.1) by the 80% capacity factor (i.e., dividing by 0.8), a reasonable 

assumption given that Unit 4 is usually at peak capacity when it’s operating. Conversion 

factors were used to adjust the maximum 1-hour concentrations predicted by SCREEN3 

to 24-hour and annual averages (EPA 1992), as required for comparison with applicable 

particulate standards. 

 The maximum increases in PM-10 concentrations were predicted to be 2 μg/m3 for 

a 24-hour averaging period and 0.4 μg/m3

 for an annual averaging period. The maximum 

increases in PM-2.5 concentrations were predicted to be 1 μg/m3 for a 24-hour averaging 

period and 0.2 μg/m3 for an annual averaging period. These increases were predicted to 

occur about 1.5 miles to the south of Greenidge Station in elevated terrain at an elevation 

about 50 ft above the stack top elevation. In actuality, the frequency of winds from the 

north (which would transport emissions to the south) is likely to be low, as indicated by 

the Penn Yan wind rose (Figure 3.2.1). 

The maximum increases in predicted PM-10 and PM-2.5 ground-level 

concentrations resulting from the decrease in Unit 4 plume rise were compared with the 

applicable NAAQS (Table 4.1.1) and the PSD Class II increments (Table 4.1.2). These 

comparisons are not regulatory requirements but are used as metrics in this analysis to 

evaluate the potential significance of the increases. As indicated in Table 4.1.1, the sum 

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Greenidge Multi-Pollutant Control Project

Table 4.1.1. Ambient air quality standards impact analysis for the proposed project 

Pollutant 

Averaging 

period 

NAAQSa 

(μg/m3) 

Maximum 

modeled 

increase 

(μg/m3) 

Ambient 

background 

concentration b

(μg/m3) 

Total 

impact c

(μg/m3) 

Total impact 

as a 

percentage 

of NAAQS 

PM-10 d 24-hour 

Annual 

150 

50 

2 

0.4 

42 

19 

44 

19.4 

29 

39 

PM-2.5 e 24-hour 

Annual 

65 

15 

1 

0.2 

36 

11.8 

37 

12 

57 

80 

a National Ambient Air Quality Standards (NAAQS). The NAAQS are established in accordance with the 

Clean Air Act to protect public health and welfare with an adequate margin of safety. b At nearest monitoring station. 

c The sum of the maximum modeled increase and the ambient background concentration. 

d PM-10 = particulate matter less than 10 μm in aerodynamic diameter. 

e PM-2.5 = particulate matter less than 2.5 μm in aerodynamic diameter.

Table 4.1.2. Prevention of Significant Deterioration (PSD) impact analysis 

for the proposed project 

Pollutant 

Averaging 

period 

PSD Class II 

incrementa

(μg/m3) 

Maximum 

modeled 

increase 

(μg/m3) 

Percentage of 

PSD Class II 

increment 

PM-10b 24-hour 

Annual 

30 

17 

2 

0.4 

7 

2 a

PSD increments are standards established in accordance with the Clean Air Act provisions to limit the 

degradation of ambient air quality in areas in attainment of the National Ambient Air Quality Standards. b

PM-10 = particulate matter less than 10 μm in aerodynamic diameter.

of the maximum increase in modeled 24-hour PM-10 concentration (2 μg/m3) added to 

the 24-hour background concentration of 42 μg/m3

 in 2003 at the nearest monitoring 

station in Niagara Falls (Section 3.2.2) yields a total of 44 μg/m3

, which is 29% of the 

corresponding NAAQS of 150 μg/m3. The sum of the maximum increase in modeled 

annual PM-10 concentration (0.4 μg/m3

) added to the annual background concentration of 

19 μg/m3

 at Niagara Falls yields a total of 19.4 μg/m3, which is 39% of the corresponding 

NAAQS of 50 μg/m3. Similarly for PM-2.5, the sum of the maximum increase in modeled 

24-hour PM-2.5 concentration (1 μg/m3

) added to the 24-hour background concentration 

of 36 μg/m3 in 2003 at the nearest monitoring station in Rochester (Section 3.2.2) yields a 

total of 37 μg/m3

, which is 57% of the corresponding NAAQS of 65 μg/m3. Finally, the 

sum of the maximum increase in modeled annual PM-2.5 concentration (0.2 μg/m3) added 

to the annual background concentration of 11.8 μg/m3 at Rochester yields a total of 

12 μg/m3, which is 80% of the corresponding NAAQS of 15 μg/m3. In each of the above 

cases, the background concentrations contribute much more to the respective totals than 

the maximum predicted increases associated with the proposed project. Because the 

4-4 
DOE/EA-1493; August 2004

nearest air monitoring stations are distant from Greenidge Station (Section 3.2.2) in 

locations likely to have higher ambient particulate concentrations, the above estimates are 

likely to form an upper bound of actual expected concentrations and percentages of the 

standards. 

 As an additional analysis, maximum increases in modeled concentrations were 

compared directly with the PSD Class II increments for PM-10 (there currently are no 

PSD increments for PM-2.5). As indicated in Table 4.1.2, the maximum increase in 

modeled 24-hour PM-10 concentration (2 μg/m3) is 7% of the corresponding increment of 

30 μg/m3

. The maximum increase in modeled annual PM-10 concentration (0.4 μg/m3) is 

2% of the corresponding increment of 17 μg/m3

. No modeling was performed at Lye 

Brook Wilderness Area (the nearest PSD Class I area about 200 miles to the eastnortheast) where the change in Unit 4 plume height would have a negligible effect. 

The SCREEN3 model was also used to predict the maximum downwind NH3

concentration. Because NH3 emissions would increase from near zero rather than 

remaining the same (as was assumed for particulate emissions), the location of maximum 

concentration was predicted to occur at a slightly different location, about 0.6 mile to the 

south-southwest of Greenidge Station in terrain at an elevation about 50 ft below the 

stack top elevation. The frequency of winds from the north-northeast (which would 

transport emissions to the south-southwest) is likely to be low (Figure 3.2.1). The 

maximum NH3 concentration was predicted to be 0.02 μg/m3

 for a 1-hour averaging 

period. By comparison, the National Institute for Occupational Safety and Health 

(NIOSH) Recommended Exposure Limit (REL) for ammonia is 25 ppm (17,400 μg/m3). 

RELs are time-weighted average (TWA) concentrations for up to a 10-hour work day 

during a 40-hour work week. The maximum predicted concentration is a negligible 

fraction of the REL. 

 No air dispersion modeling was performed for other pollutants. SO2 and NOx

emissions from Unit 4 would decrease during the demonstration by about 95% and 65%, 

respectively (Table 2.1.1). These reductions are greater than the maximum increase in 

downwind concentrations predicted as a consequence of the decreased plume height (as 

obtained from the modeling of particulate emissions using SCREEN3). Specifically, 

because the SCREEN3 modeling indicated that the decreased plume height would 

increase downwind concentrations by a maximum factor of 2.5, emissions reductions of 

at least 60% (resulting in Unit 4 emissions during the demonstration of no more than 40% 

or original emissions) would result in no increase in concentrations at any downwind 

location (40% oof 2.5 equals 1). Consequently, a net improvement in air quality 

associated with SO2 and NOx concentrations would result. SO3 emissions are expected to 

decrease by the same percentage as SO2 emissions, with similar air quality improvement. 

The 95% reduction in Unit 4 emissions of HCl and HF would more than offset the 

increase associated with a lower plume height, and the reduction in Hg emissions of at 

least 60% would approximately offset the maximum increase. Because power plants are 

not large emitters of CO and VOCs (Table 2.1.1) and because there would be no change 

in emissions associated with the demonstration, these pollutants were not evaluated 

further. Because CO2 is stable in the atmosphere and essentially uniformly mixed 

throughout the troposphere and stratosphere, CO2 impacts resulting from no change in 

emission levels at Greenidge Station would also remain unchanged. 

4-5 
Greenidge Multi-Pollutant Control Project

 At times in the past, concerns have been raised about fugitive dust blown offsite 

from the Lockwood Landfill. The proposed project would not affect the frequency or 

severity of this type of occurrence, but planned increases in landfill height could increase 

the incidence of problems with fugitive dust. To reduce the generation of fugitive dust, 

the landfill operators have increased the wetting and compaction of fly ash and are 

implementing a new landfill operations plan designed to reduce wind exposure of active 

disposal areas (J.A. Daigler & Associates 2003). 

4.1.3 Surface Water Resources 

4.1.3.1 Construction 

Construction activities for the proposed project would be limited to 3 acres of 

developed industrial property in the midst of the 153-acre Greenidge Station and adjacent 

to the existing powerhouse for Units 3 and 4. Because the area was previously graded and 

paved and currently serves as a parking lot, it is ecologically highly disturbed. The 

construction area does not encompass any existing body of water. 

Construction of the proposed project would generate small amounts of both solid 

and liquid wastes including solvents, paints, coatings, adhesives, and empty containers. 

Existing facilities for containment and treatment of runoff and spills on the power plant 

site would be engaged to help prevent adverse effects on offsite surface waters. In 

addition, as necessary and appropriate, standard engineering practices for the prevention 

or minimization of runoff, erosion, and sedimentation from the construction site to offsite 

surface waters would be employed. The New York State Department of Environmental 

Conservation’s (NYSDEC’s) regulations and guidelines governing construction activities 

would be followed. Prompt containment and clean-up of accidental spills of harmful 

materials would be conducted in accordance with an appropriate spill prevention, control, 

and countermeasure plan and best management practices plan. Thus, project construction 

is not likely to have appreciable adverse effects on area surface waters. 

4.1.3.2 Operation 

The proposed project would not affect the quality or quantity of the liquid effluent 

from Greenidge Station, but somewhat more water would be withdrawn from Seneca 

Lake. The proposed project would require an additional 93 gpm of service water that 

would be consumed by operation of the lime hydrator and circulating dry scrubber rather 

than being returned to the lake. This additional water is slightly less than 20% of the 

plant’s current consumptive use, and represents only about 0.1% of Greenidge Station’s 

total water use (Section 2.1.6.2). Thus, adverse impacts on water quality and quantity in 

Seneca Lake would be negligible. 

No additional wastewater would be generated from the proposed project. 

Accidental spills, if any, of ammonia from the storage tank for the SCR system would be 

prevented from reaching surface water by secondary containment. Wastewater effluents 

must be treated to meet the standards set forth in the State Pollutant Discharge 

Elimination System (SPDES) permit before being discharged to Seneca Lake. Hazardous 

wastes are removed from the site by a waste management contractor for disposal at an 

authorized facility. No measurable effects on the water quality of Seneca Lake would be 

expected. 

4-6 
DOE/EA-1493; August 2004

Due to a reduction in air emissions (Section 2.1.7.1) of SO2, NOx, HCl, and HF 

(which are associated with acid deposition) and Hg (which adversely affects humans and 

biota), the proposed project would have a slight beneficial effect on area surface waters. 

4.1.4 Geological Resources 

4.1.4.1 Rock, Soils, and Mineral Resources

 Construction for the proposed project would not affect the availability or 

accessibility of rock or mineral resources. Only limited excavation is expected, and any 

excavated material probably would be used within the project as fill. Sand and crushed 

stone that would be used in construction are readily available in the region, and 

requirements for these materials would be modest due to the modest size of the new 

facilities. No agricultural soils would be removed from potential production. Construction 

of new facilities would not preclude future access to any undiscovered natural gas that 

might be present deep underground. 

Due to low topographic relief and the previous excavation of the project site 

(Section 3.4.1), little soil erosion would be expected during construction. Erosion of 

exposed surfaces and soil stockpiles would be limited through standard management 

practices, consistent with requirements of the NYSDEC SPDES General Permit for 

Stormwater Discharges from Construction Activity (NYSDEC 2003c).

 The lime required for operation of the proposed project, which would be acquired 

commercially, would be produced from limestone, which is an abundant resource in the 

surrounding region. Glacial till soil for construction and capping of the Lockwood 

Landfill also is abundant in the area and can be obtained from land adjacent to the 

landfill. 

4.1.4.2 Groundwater 

The proposed project would not affect any uses or users of groundwater. No uses 

of groundwater occur in the site vicinity, and the project also would not use groundwater 

as a water source for project construction or operation. Temporary dewatering of 

excavations during construction activities might collect some groundwater in addition to 

stormwater runoff, but because permeability is low the amounts would be small and any 

changes in the water table would be very localized. 

 Disposal of waste generated by the proposed project (Section 4.1.7.2) would be 

unlikely to affect groundwater quality because the waste would be placed in an 

engineered landfill that is lined and equipped with a leachate collection system. If 

leachate were to reach groundwater (e.g., due to a leak in a landfill liner), periodic 

sampling of groundwater monitoring wells downgradient from the landfill should detect 

it. Contaminant migration would be slow, so any needed remedial measures could be 

implemented in time to prevent contaminants from migrating to surface water or sites 

where water is used. Past waste disposal has affected the quality of groundwater collected 

in underdrains beneath older portions of the Lockwood Landfill that are not lined, but this 

water does not remain in the ground, and contaminant migration has not been detected in 

downgradient monitoring wells (Section 3.4.4). Eventual landfill closure would extend 

hydrological controls to older portions of the landfill, thus reducing the potential for old 

waste disposal to affect groundwater over the long term (Section 4.1.7.2). 

4-7 
Greenidge Multi-Pollutant Control Project

4.1.4.3 Geological Hazards 

 Because only minimal geologic hazards are associated with the proposed project 

site (Section 3.4.2), geologic conditions would be unlikely to contribute to adverse 

impacts from or to the proposed project. 

4.1.5 Floodplains and Wetlands

4.1.5.1 Floodplains 

The entire proposed project site would be located outside the 500-year floodplain 

of Keuka Lake Outlet and Seneca Lake. Therefore, neither construction nor operation of 

the proposed project would have adverse impacts on the Keuka Lake Outlet and Seneca 

Lake floodplain. 

4.1.5.2 Wetlands 

Construction and operation of the proposed project would have no adverse effects 

on wetlands because none are present on or adjacent to the project location. Runoff and 

spills from the site would not reach wetlands due to use of measures discussed in 

Sections 4.1.3.1, and 4.1.3.2. 

Because operation of the proposed project would reduce Hg emissions, a slight 

benefit to area wetlands would be provided by reducing Hg deposition and potential 

build-up of Hg levels in wetlands and the ecological communities they support. 

4.1.6 Ecological Resources 

4.1.6.1 Terrestrial Ecology 

Because the proposed project would be located in an area that is highly disturbed 

and completely industrialized (predominantly a parking lot), and that supports almost no 

native plant or animal communities, neither construction nor operation of the proposed 

facility would adversely affect terrestrial ecological resources. 

Due to NH3 injection into flue gas to control NOx emissions, NH3 emissions 

would increase from near zero to about 280 lb per year (Section 2.1.7.1). This NH3 would 

be widely dispersed and ultimately deposited to terrestrial and aquatic ecosystems 

through dry and wet deposition. Wineries, such as those in the local area, typically use 

nitrogen-based fertilizer at about 10 to 40 lbs per acre per application (Penn State 2002). 

Any fertilization effect from the NH3 emissions due to the proposed project would be 

miniscule due to the constant slow rate of emission (less than 1 lb per day) and large 

dispersal area. For example, if 20 lb of NH3 fertilizer per acre were applied once per year 

to the 10,414 acres of vineyards in the Finger Lakes Region (Uncork New York 2004), 

then the NH3 emissions from the proposed project would represent only about 0.14% of 

the total from vineyards, not considering other agricultural uses in the area. 

Operation of the proposed project would reduce Hg emissions and provide a slight 

benefit to terrestrial ecosystems in the area by reducing Hg deposition and potential 

build-up of Hg levels in soils, water, and biota. 

4-8 
DOE/EA-1493; August 2004

4.1.6.2 Aquatic Ecology 

Because appropriate engineering practices for (1) preventing or minimizing 

runoff, erosion, and sedimentation from the project site to offsite surface waters, and (2) 

the prompt containment and clean-up of accidental spills would be implemented, 

construction of the proposed project would have negligible impacts on the fish, birds, and 

wildlife of Seneca Lake and Keuka Lake Outlet (Section 4.1.3) 

During operation of the proposed project, Seneca Lake’s biota would be 

negligibly affected by the potential 93-gpm reduction of return water. Similarly, the biota 

would be negligibly affected by the project’s NH3 emissions (Section 4.1.6.1). 

Because operation of the proposed project would reduce Hg emissions, a slight 

benefit to aquatic ecosystems in the area would be provided by reducing Hg deposition 

and potential build-up of Hg levels in sediments and water. 

4.1.6.3 Threatened and Endangered Species 

Federal- and state-listed threatened and endangered species (Section 3.6.3) are not 

known to occur, and are unlikely to occur, on the proposed project site due to its highly 

disturbed nature. Any effects of the proposed project on threatened and endangered 

species would likely be marginally beneficial as a result of expected reductions in Hg, 

NOx, SO2, HCl, HF, and particulate emissions. 

In compliance with Section 7 of the Endangered Species Act of 1973, as 

amended, DOE requested consultation with the U.S. Fish and Wildlife Service (FWS) 

regarding potential impacts of the proposed project on threatened and endangered species 

(Appendix A). The FWS response indicated that, except for occasional transient 

individuals, no federal-listed species or critical habitat for such species are known to exist 

in the project impact area, and that no further Endangered Species Act coordination or 

consultation with FWS is required (Appendix A). 

4.1.6.4 Biodiversity 

Given adequate collection and treatment of runoff during construction and 

operation of the proposed project, neither of these activities would adversely affect 

biodiversity of the surrounding ecosystems. Both local and far-field biological diversity 

might realize a net beneficial, but probably immeasurable, effect as a result of expected 

reductions in Hg, NOx, SO2, HCl, HF, and particulate emissions. 

4.1.7 Waste Management 

4.1.7.1 Construction 

 Construction of the proposed project would generate solid wastes in types and 

amounts typical of construction projects. Wastes would include packaging from materials 

transported to the site, scrap materials, metals and other materials from dismantling the 

existing Unit 4 ESP, and demolition debris from removal of the existing waste oil storage 

shed and the parking lot surface. Metal waste would be sold as scrap. Some dismantled 

building material would probably be used on the site as fill material. The remaining solid 

wastes would be transported for disposal in one of the municipal landfills serving the 

region (Section 2.1.7.3). The volume of landfilled waste would be very small in 

comparison with the capacity of the 387-acre Ontario County landfill, which is permitted 

4-9 
Greenidge Multi-Pollutant Control Project

to accept 624,000 tons [approximately equivalent to 624,000 cubic yards (yd3)] per year 

of municipal solid waste and has a potential total capacity of over 21 million yd3

 (Casella 

Waste Systems, Inc. 2003). The disposal of project construction waste would not 

measurably affect that landfill’s potential operating life. 

4.1.7.2 Operation 

 The proposed project would increase the quantity of fly ash generated by 

Greenidge Station by about 50%, from the current 59,000 tons per year to an estimated 

89,000 tons per year (Table 2.1.1). Fly ash generation from Unit 4 would increase 

annually from 40,000 tons to 70,000 tons. This increase would result almost entirely from 

(1) the use of lime in the CDS system and (2) the enhanced capture of fine particles 

(including calcium sulfate and calcium sulfite formed from SO2 reacting with the calcium 

in lime). The enhanced capture would occur because the CDS agglomerates fine particles 

into coarser material that would be collected in a new ESP or baghouse. Minor increases 

in volume would result from the activated carbon used in the CDS system. The proposed 

project would not affect Greenidge Station’s generation of bottom ash or the subsequent 

use of this material (Section 2.1.7.3). 

 Fly ash generated in project operation would have somewhat different 

characteristics than the fly ash currently generated by Greenidge Station. The facility's 

current fly ash is a mixture consisting primarily of mineral ash and a small amount of 

unburned carbon that is captured with the fly ash. Fly ash from the proposed project 

would include these same constituents, with the addition of lime and other calcium 

compounds formed from the lime, powdered activated carbon, and increased amounts of 

sulfate compounds and other materials removed from air emissions. Project participants 

would characterize this material physically and chemically, and would investigate 

possible opportunities for beneficial reuse. Leaching tests would be done, in part to 

evaluate the stability of trace constituents of coal (such as Hg) incorporated in the ash and 

to verify that the material is not a hazardous waste as defined under the Resource 

Conservation and Recovery Act (RCRA). 

Beneficial reuse of some or all of the fly ash from the proposed project would 

reduce the need for landfill disposal and could reduce demands for other materials that 

the fly ash replaces. Although fly ash is commonly used as a cementitious material in 

concrete, this is not likely to be an option for fly ash from the proposed project. The fly 

ash currently generated at Greenidge Station contains too much unburned carbon to be 

suitable for this purpose, and ash waste from the proposed project can be expected to 

have similar limitations. However, because it would contain substantial amounts of lime 

and other calcium compounds, the fly ash from the proposed project might be suitable for 

use as a soil amendment, probably after mixing it with treated sewage sludge. Project 

participants have identified a potential customer for this material and estimate that up to 

20,000 tons per year could be used for this purpose. Other potential uses also would be 

explored. 

If not beneficially reused, fly ash from the proposed project would be transported 

to the Lockwood Landfill for disposal. The ash would be commingled with fly ash from 

Unit 3 and other solid wastes generated in minor quantities at Greenidge Station. The 

143-acre Lockwood Landfill site has been used for disposal of Greenidge Station fly ash 

and related wastes since 1979. In 2003, the site was calculated to have a potential 

4-10 
DOE/EA-1493; August 2004

remaining waste disposal capacity of 3.3 million yd3 (J.A. Daigler & Associates 2003). 

This calculation forms an upper bound for remaining capacity because it assumes full site 

utilization, a final maximum elevation of 785 ft above mean sea level (approximately 85 

ft above the current peak elevation), NYSDEC approval of future disposal designs, and 

continued renewal of the facility's 5-year permits. By using this calculation with current 

waste generation rates and assuming a waste density of one ton per yd3, an estimate is 

derived that the site could accommodate Greenidge Station wastes through 2057. If all of 

the waste from the proposed project were landfilled, resulting in a 50% increase in waste 

volume beginning in 2006, the landfill would reach capacity about 17 years sooner (in 

2040). Even with less optimistic assumptions about landfill capacity, it is apparent that 

the landfill site could accommodate fly ash from the proposed project until well beyond 

the 12-month demonstration period of performance testing and monitoring (see Section 5 

regarding landfill sufficiency over the period of commercial operation). 

 Landfill disposal of ash has the potential to affect groundwater and surface water 

as a result of leaching of landfilled fly ash. Leachate generated within the Lockwood 

Landfill drains to the leachate collection system within lined portions of the landfill and 

to groundwater underdrains below unlined portions. These drains discharge by gravity 

flow to the adjacent sedimentation pond, which also receives surface water runoff from 

the landfill area. No active water treatment processes are employed in this pond, but 

suspended material and some dissolved contaminants (such as iron and manganese) settle 

out of the water. A few times each year, water from the pond is pumped to Keuka Lake 

Outlet after sampling and analysis have ascertained that the water quality meets the 

requirements of the SPDES discharge permit. If permit requirements were not met, water 

could be treated before being discharged. Monitoring data from a discharge event in 2003 

(Table 4.1.3) show that the quality of the water in the pond easily met all of the permit 

requirements. 

Changes in the composition of the Unit 4 fly ash due to the proposed project could affect 

the chemistry of Lockwood Landfill leachate and thus of discharges to Keuka Lake 

Outlet. Monitoring of Lockwood Landfill leachate done as part of the landfill 

groundwater monitoring program found elevated levels of several constituents (Table 

4.1.4). Total dissolved solids in the leachate were much higher than in background 

groundwater (Section 3.4.4). The principal dissolved ions in the leachate were calcium, 

magnesium, and sulfate. Other dissolved substances found in elevated concentrations are 

commonly found in coal or pyrite, which is one of the minor waste streams codisposed 

with ash in the Lockwood Landfill. Most samples were similar to the groundwater with 

neutral to slightly alkaline pH, but one sample had a slightly acidic pH of 5.9. Because 

the ash from the proposed project would be similar to the ash currently generated, but 

with higher levels of calcium and sulfate compounds, the overall chemical character of 

the leachate would not be changed, but there could be higher concentrations of calcium 

and sulfate. These substances are not likely to settle out in the sedimentation pond, so 

they probably would be discharged to Keuka Lake Outlet. Calcium and sulfate are not 

toxic and there are no permit limits for these substances in pond discharges. Any effects 

on water quality would be dissipated by dilution in the stream and in Seneca Lake. 

 Increased removal of Hg in plant emissions would lead to increased Hg 

concentrations in Greenidge Station fly ash. Research on leaching of Hg from fly ash 

indicates that there should be negligible effects on Hg levels in Lockwood Landfill 

4-11 
Greenidge Multi-Pollutant Control Project

Table 4.1.3. State Pollutant Discharge Elimination System (SPDES) permit limits and 

reported values for discharge from the Lockwood Landfill 

sedimentation/neutralization basin

Effluent parameter Discharge limit 

(daily maximum value)a

Value measured in 

November 2003 discharge 

eventb

Flow (gallons/day) 250,000c 178,571 

Aluminum (total; mg/L) 2.4 <0.05 

Cadmium (total; mg/L) 0.11 <0.005 

Copper (total; mg/L) 1.0 <0.01 

Iron (total; mg/L) 4.0 0.1 

Zinc (total; mg/L) 2.0 <0.01 

Mercury (total; mg/L) 0.0008d <0.0002 

Manganese (total; mg/L) 3.0 0.02 

Total suspended solids (mg/L) 50 <4 

Arsenic (total; mg/L) 0.1 <0.02 

Selenium (total; mg/L) 0.07 0.01 

pH (pH units) range: 6.0 to 9.0 8.1 a

New York State Department of Environment and Conservation (NYSDEC) State Pollutant Discharge 

Elimination System (SPDES) Discharge Permit Number NY-1007069, AES Greenidge, L.L.C.: Lockwood Disposal 

Facility, Modification Date June 7, 1999.

b

AES Greenidge, “AES Eastern Energy NPDES/SPDES Discharge Monitoring Reports,” Eileen Reynolds, 

December 16, 2003. Total volume of discharge, which occurred over a period of several days, was about 1.5 million 

gallons. c

Maximum flow shall not exceed 140,000 gallons/day if stream flow measured in Keuka Lake Outlet at 

Dresden is less than 27 ft3

/sec. 

d Modified from 0.002 mg/L to 0.0008 mg/L, in accordance with NYSDEC letter of July 22, 2004. See 

Appendix C.

leachate. Leachability testing of ash from three projects that demonstrated the use of 

activated carbon injection for Hg control found low rates of Hg release (Senior et al. 

2003). Hg concentrations in waste extracts generated with the Toxicity Characteristic 

Leaching Procedure (TCLP), which is prescribed in regulations under RCRA and is 

designed to mimic leaching conditions in a municipal solid waste landfill, ranged from 

undetectable (less than 0.00001 mg/L) up to 0.00007 mg/L. Values obtained with the 

Synthetic Groundwater Leaching Procedure (SGLP), which is more representative of 

conditions in most coal ash landfills, ranged from undetectable (less than 0.00001 mg/L) 

up to 0.00005 mg/L. All reported Hg concentrations were well below potentially 

applicable criteria, including the primary drinking water standard of 0.002 mg/L, water 

quality criteria for protection of aquatic life (0.0014 mg/L for acute exposure and 0.00077 

4-12 
DOE/EA-1493; August 2004

Table 4.1.4. Selected data from monitoring of leachate collection drains at 

Lockwood Landfill during 2002

Parameter Highest level reported 

during 2002a

Total dissolved solids (mg/L) 3330 

Alkalinity (mg/L) 493 

Hardness (mg/L) 1687 

Aluminum (total; mg/L) 7.1 

Boron (total; mg/L) 20.5 

Calcium (total; mg/L) 519 

Iron (total; mg/L) 79 

Manganese (total; mg/L) 2.2 

Magnesium (total; mg/L) 105 

Selenium (total; mg/L) 0.2 

Sulfate (mg/L) 2280 

pH (pH units) 5.9 to 8.3b

a

Data included in Criss 2004. 

b

Range of values reported.

mg/L for chronic exposure; EPA 2002), and the threshold for identifying a material as a 

hazardous waste (0.200 mg/L). Only one ash source in the study produced extracts with 

detectable Hg concentrations. That ash had total Hg concentrations ranging from 0.2 to 

more than 0.5 μg/g (200 to more than 500 ppb). Given these values and the 20-fold 

dilutions used in the leachability tests, the highest measured extract concentrations 

indicate release of somewhere between one-five-hundredth and one-fourteenth of the Hg 

in the ash. If treated effluents containing similar leachates were discharged to Keuka 

Lake Outlet, no violation of water quality standards would result. Other research has 

found that leaching of Hg from fly ash is dependent on pH, with greater releases 

occurring at lower (acidic) pH (Schroeder et al. 2003). Thus, the slightly alkaline pH of 

natural waters at the Lockwood Landfill site could limit Hg release. 

 The proposed project would not change the requirements and eventual process for 

closure and post-closure care of the landfill. Final cover would be placed over the entire 

facility to limit infiltration and thus reduce future leaching of the waste. The multilayer 

final cover would consist of a low-permeability synthetic membrane layer overlain by a 

permeable geosynthetic drainage layer and a protective soil layer at least 2 ft thick. 

Closure of the Lockwood Landfill would be expected to include final covering of old 

unlined waste areas, thus reducing potential future impacts from the entire facility. Postclosure care would be provided for a 30-year period, as mandated under NYSDEC 

permitting requirements for landfills. 

4.1.7.3 Hazardous Waste 

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Greenidge Multi-Pollutant Control Project

Operation of the proposed project’s SCR system could result in generation of a 

hazardous waste. Catalysts used in the SCR process lose their reactivity over time and 

would need to be replaced or regenerated after about 3 years. No catalyst replacement or 

regeneration is expected during the 12-month demonstration period (see Section 5 

regarding catalyst replacement over the period of commercial operation). 

Construction and operation of the proposed project would not be expected to 

introduce any other new hazardous wastes that are not already generated by operation of 

Greenidge Station. However, the amounts of paint, solvents, and lubricants used, 

recycled, or transported for disposal could increase slightly. Existing Greenidge Station 

hazardous waste handling and disposal procedures would be employed for the proposed 

project (Section 2.1.7.4). 

4.1.8 Cultural Resources 

In compliance with Section 106 of the National Historic Preservation Act of 1966, 

as amended, DOE requested a consultation with New York's State Historic Preservation 

Officer (SHPO) regarding a determination of the potential for impacts associated with the 

proposed project on any historic resources that may be listed in or eligible for the 

National Register of Historic Places or that may have local importance (Appendix B). 

Impacts from construction and operation of the proposed project are not likely, 

however, because the project site has been disturbed since the 1950s, no cultural 

resources have been reported or found on or near the project site, and the two National 

Register properties closest to the project site are about 0.5 mile to the northwest. 

4.1.9 Socioeconomic Resources

The socioeconomic impacts of the proposed project would be most noticeable 

during the 12-month construction period, especially when the peak construction work 

force (100 to 150 workers) would be on the site. Because existing personnel would 

continue to operate Greenidge Station during demonstration of the proposed project, no 

additional influx of additional workers during project operations would result. 

In addition to the 100 to 150 direct jobs that would be created by project 

construction, a number of indirect jobs could be created as a result of the purchases of 

goods and services by the project participants and construction workers. Employment 

multipliers developed for the state of New York indicate that each direct construction job 

leads, on average, to the creation of 1.57 indirect jobs (DARME 1996). However, this 

employment multiplier is likely to be too high for the proposed project because of the 

short construction period (12 months) and the probability that few construction workers 

would relocate to the area permanently. So, this analysis assumes a lower employment 

multiplier of 1.00 (i.e., 1 indirect job for every 1 direct job). Given this assumption, 

roughly 100 to 150 indirect jobs could be created during the peak construction period, for 

a total of roughly 200 to 300 new jobs in the project area (100 to 150 direct jobs plus 100 

to 150 indirect jobs). The following subsections discuss the potential socioeconomic 

impacts of the proposed project, particularly those associated with this direct and indirect 

employment. 

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DOE/EA-1493; August 2004

4.1.9.1 Population 

The construction work force would be expected to come from outside the 

immediate project area and would either commute from their homes to the project site 

daily or stay temporarily in area hotels and motels (CONSOL 2002). To account for these 

two types of workers, this analysis assumes that 50% of the peak construction work force 

(50 to 75 workers) would commute from home daily, while another 40% (40 to 60 

workers) would stay temporarily in hotels or motels. Although it is not likely that many 

of the construction workers would relocate to the project area permanently (i.e., for 

longer than the 12-month construction period), this analysis assumes as a conservative 

estimate that 10% of the peak work force (10 to 15 workers) would relocate permanently. 

Past experience with large, multi-year power plant construction and refurbishment 

projects indicates that approximately 60% of the in-migrating work force is accompanied 

by family, while the remaining 40% is not (NRC 1996). However, for this relatively 

small, 12-month construction project, it is more reasonable to expect that none of the 

workers staying temporarily in hotels or motels would be accompanied by family, and 

that only 40% of the workers relocating permanently (4 to 6 workers) would be 

accompanied by family. 

Assuming that 4 to 6 workers would relocate permanently with their families, and 

assuming the average household size of 2.61 persons for the state of New York (U.S. 

Census Bureau 2004b), the permanent population in the project area would increase by 

roughly 10 to 16 residents as a result of direct employment. The indirect jobs that could 

be created would be less specialized than the direct construction jobs, and would be even 

more likely to be filled by existing area residents. Accordingly, this analysis assumes that 

none of the indirect work force would relocate to the project area during the construction 

period. 

Combining the population growth that would occur due to workers staying in the 

area temporarily without families (40 to 60 workers), workers relocating permanently 

without families (6 to 9 workers), and workers relocating permanently with families (4 to 

6 workers, with 6 to 9 family members), the peak construction period would result in 

roughly 56 to 84 additional residents in the project area. This population growth would 

represent roughly 0.2% to 0.3% of Yates County's population of 24,621. The potential 

impacts of this population growth are discussed below in Sections 4.1.9.3 (Housing) and 

4.1.9.4 (Water and Wastewater Services). 

4.1.9.2 Employment and Income 

The 200 to 300 total new jobs (100 to 150 direct jobs plus 100 to 150 indirect 

jobs) that could be created during the peak construction period would represent less than 

2.5% of the total labor force in Yates County in 2000. Although the direct jobs would go 

to workers from outside the immediate project area, most (if not all) of the indirect jobs 

would go to existing residents in Yates and Ontario counties. Because existing personnel 

would continue to operate Greenidge Station during demonstration of the proposed 

project, no new employment would be associated with project operations. Accordingly, 

construction of the proposed project would have a temporary positive effect on local 

employment by creating indirect jobs, but gains in local employment would likely be lost 

following completion of project construction. 

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Greenidge Multi-Pollutant Control Project

Because the construction work force would come from outside the immediate 

project area, construction wages would not have a large effect on total or per capita 

income in Yates County. However, the wages paid to existing area residents through 

indirect jobs created during the construction period would have a small positive effect on 

total and per capita income. 

4.1.9.3 Housing 

The 10 to 15 new construction-related households (i.e., the households of workers 

relocating permanently with and without families) assumed as an upper bound in this 

analysis would represent less than 0.5% of the 3,035 vacant housing units in Yates 

County in 2000. This level of increased demand is not likely to have an adverse effect on 

the availability or cost of housing in Yates County. 

Because many of the construction workers would stay in area hotels and motels, 

the availability and cost of tourist lodging in the summer season could be a larger issue 

than that of housing the construction workers who relocate permanently. The hotels and 

motels themselves are not likely to lose business, as they could rent rooms to the 

construction workers, but the wineries, restaurants, and other local businesses that rely on 

tourism could be adversely affected if tourists are not able to find lodging in the area. 

However, given the large number of tourist lodging facilities in the area, the short 

duration of the construction period, and the fact that some of the construction work would 

occur outside the tourist season, this economic impact is expected to be relatively minor. 

4.1.9.4 Water and Wastewater Services 

Because many of the 100 to 150 workers expected during the peak construction 

period would stay in the project area temporarily in hotels and motels or permanently as 

new residents, there would be additional demand for water and wastewater services. As 

discussed in Section 3.8.4, the Penn Yan water treatment facility has excess capacity of 

0.97 MGD. This excess capacity would be more than enough to meet the additional 

demand for water associated with the peak construction work force. 

The Penn Yan wastewater treatment facility has excess capacity of 0.8 MGD 

(Section 3.8.4), which also would be more than enough to meet the additional wastewater 

needs associated with the peak construction work force. However, the need to provide 

additional wastewater services for the construction workers could slightly exacerbate 

existing problems with the Penn Yan wastewater treatment system during periods of high 

groundwater flow (Section 3.8.4). 

4.1.9.5 Local Government Revenues 

Because pollution control equipment is exempt from property taxation in the state 

of New York, the proposed project would not add to the assessed value of the existing 

Greenidge Station for property tax purposes and would not result in additional property 

tax revenues for Yates County. 

In addition to the New York state sales tax rate of 4.25%, Yates County and 

Ontario County have local sales tax rates of 4.0% and 3.0%, respectively (NYSDTF 

2004). Therefore, local purchases of materials for project construction and local 

purchases of goods and services by construction workers would result in some additional 

sales tax receipts for the counties. However, the overall effect of these revenue increases 

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for local governments would be relatively minor because of the limited local purchases of 

materials, moderate number of construction workers (100 to 150 workers during the peak 

construction period), and limited period of construction (Section 2.1.4). 

4.1.9.6 Environmental Justice 

As discussed in Section 3.8.6, the percentages of residents classified as "minority" 

in Yates County (3.2%) and Census Tract 9901 (4.4%) are much lower than the minority 

percentages of the United States (30.9%) and the state of New York (38.0%). Therefore, 

the impacts of constructing and operating the proposed project would not be distributed 

disproportionately to a minority population. 

The percentage of residents classified as "below poverty" in Yates County 

(13.1%) is also lower than that of the state of New York (14.6%), but slightly higher than 

that of the United States (12.4%). Also, the percentage of residents classified as below 

poverty in Census Tract 9901 (15.2%) is higher than that of Yates County, the state of 

New York, and the United States (Section 3.8.6). However, because the percentages 

below poverty for Census Tract 9901, Yates County, and the state of New York are all 

within 2.1 points, it does not appear that Census Tract 9901 constitutes a "poverty" 

population that would be disproportionately affected by the proposed project. Further, 

many of the potential impacts associated with the proposed project would be beneficial 

rather than adverse (e.g., an overall improvement in air quality). 

4.1.10 Transportation and Noise 

4.1.10.1 Transportation 

Roads

The 100 to 150 direct workers expected during the peak construction period 

would access the project site using Lampman Road from State Highway 14. For this 

assessment, most of the construction workers were assumed to carpool to and from the 

project site each day (either from their homes or from hotels and motels), and the average 

vehicle was assumed to carry two workers (CONSOL 2004b). Thus, as an upper bound, 

about 150 additional vehicles trips (75 roundtrips to and from the site) would be 

generated each day by the construction workers. 

As discussed in Section 3.9.1.1, ADT on the segment of Highway 14 near 

Greenidge Station was 2,595 vehicles in 2003, or about 10% of the highway's capacity. 

The estimated 150 additional vehicle trips that would result from construction workers 

driving to and from the project site each day would represent about a 5.8% increase over 

existing traffic. By itself, this small increase is not expected to create an appreciable 

impact on the overall level of service on Highway 14. 

However, because the additional trips would occur at approximately the same 

time each morning and evening, there could be slight impacts to traffic flow and safety on 

Highway 14 and Lampman Road during peak drive times, which could be exacerbated if 

they would coincide with summer tourist traffic on Highway 14 and with delivery trucks 

using Highway 14 and Lampman Road to access Greenidge Station. Traffic flow would 

be monitored during the construction period to determine if actions (e.g., scheduling the 

arrival and departure times of workers in 15-minute shifts) would be appropriate to avoid 

4-17 
Greenidge Multi-Pollutant Control Project

traffic congestion. 

Traffic flow and safety on Highway 14 and Lampman Road could also be affected 

by additional truck trips to and from the project site during construction. Currently, about 

20 trucks access Greenidge Station per week. During the peak construction period, 

especially during concrete foundation pouring, up to 15 additional trucks would enter the 

project site per day (CONSOL 2004a). Traffic flow would be monitored during the 

construction period to determine if actions (e.g., scheduling truck deliveries to avoid 

construction workers' arrival and departure times) would be appropriate to avoid traffic 

congestion. 

During demonstration of the proposed project, approximately three fewer 

truckloads of coal would be delivered to Greenidge Station each day (Section 2.1.6.3). 

This decrease in truck traffic would be offset by new truck traffic: three truckloads of 

lime that would be delivered each day and much less frequent deliveries of ammonia and 

powdered activated carbon (CONSOL 2004a). These new deliveries would have a 

negligible impact on traffic flow and safety on Highway 14 and Lampman Road. 

Disposal of fly ash generated by the proposed project would increase the number 

of daily truck trips between Greenidge Station and the landfill from the current 6 trips to 

9 trips. Because all travel would be on private roads, the increase would not affect local 

highway users. 

Rail

Rail shipments to Greenidge Station would not increase during project 

construction because all construction equipment and materials would be delivered by 

truck (CONSOL 2004a). As discussed in Section 2.1.6.3, rail shipments during project 

demonstration would increase annually by about 2 trains of 100 rail cars each to offset 

about 850 loads of coal no longer delivered by truck (CONSOL 2004a). The impact of 

the increased train traffic would be negligible.

4.1.10.2 Noise

Noise levels are related to the magnitude of air pressure fluctuations that cause the 

eardrum to oscillate, thereby stimulating the auditory system. The magnitude of these 

pressure fluctuations is typically expressed as the Sound Pressure Level (SPL), which is 

measured in dB. By definition, the threshold of human hearing is 0 dB. Background 

levels at a recording studio are as low as 15 dB, conversational speech at the location of 

the listener is around 60–65 dB, and a jet takeoff is in the range of 120 dB at a distance of 

about 100 ft from the runway. The human threshold of pain, where the brain receives a 

signal to reduce the SPL or risk damage to the auditory system, begins at around 130 dB 

for most individuals. SPL is reduced by about 6 dB for each doubling of distance from an 

individual source. 

Sound typically occurs over a wide spectrum of frequencies. For most 

applications, dB levels are determined by weighting the frequencies (i.e., some 

frequencies count more than others). The so-called “A weighting,” which was developed 

to approximate the way in which the human ear responds to the various frequencies, is 

typically expressed as dB(A). 

EPA (1974) recommends a day-night level of 55 dB(A) or less to protect the 

public from activity interference and annoyance in typically quiet outdoor and residential 

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DOE/EA-1493; August 2004

areas. Day-night average sound level is defined as the 24 hour average sound level, in 

dB(A), obtained after the addition of 10 dB(A) to sound levels in the night from 10 p.m. 

to 7 a.m. Maintaining relatively continuous noise below this level also protects against 

hearing loss, although less stringent requirements are typically set for that purpose. From 

about 10:00 p.m. to 7:00 a.m., background noise is typically reduced due to the absence 

of the usual noise sources during daytime hours (e.g., vehicular traffic, lawn mowers, 

work activities, and recreational activities); consequently, noise at around 50 dB(A) 

becomes more noticeable and can be annoying. Therefore, 45 dB(A) is the level for 

potential activity interference and annoyance during the nighttime hours specified above. 

During construction of the proposed project, the principal sources of noise would 

be from construction equipment and material handling. The amount and type of 

construction equipment would vary depending on the specific construction activity 

occurring at that time. Construction activity would primarily occur within 3 acres of the 

153 acres occupied by Greenidge Station. The proposed project area is currently confined 

by the power plant building, the ramp from the upper parking lot, the short railroad 

bridge connecting the upper parking lot and the power plant building and the access road 

to the upper parking lot. The upper parking lot, which is about 30 ft above the main 

construction site, would be utilized as an equipment laydown area. An existing waste oil 

storage shed on this property would be relocated and the building torn down to make 

room for new equipment. The existing booster fan at the base of Unit 4 stack would be 

replaced by two larger units. The existing ESP would be replaced, and the new buildings 

[i.e., circulating dry scrubber (CDS) vessel, two ash recycling bins, lime storage silo, 

lime hydrator, powder activated carbon storage silo, ammonia (NH3 ) storage tank 

system], and ancillary equipment would be erected on this land. The main construction, 

staging and fabrication areas would be expected to be located between existing structures 

and not located in proximity to sensitive noise receptors. 

During construction, employees and contractors would be responsible for 

ensuring that exhaust mufflers and engine enclosures are in place and in good working 

order for all industrial trucks and other pieces of construction-related equipment. An 

exhaust muffler is a device that deadens the noise of escaping gases or vapors through 

which the exhaust gases of an internal-combustion engine are passed. An engine 

enclosure silences low frequency noise radiated from the engine. Exhaust mufflers and 

engine enclosures are commonly used, and are commercially available from many 

different manufacturers. All construction equipment would be properly maintained. 

During operation of the proposed project, the principal interior sound sources 

would be the in-duct Selective Catalytic Reduction (SCR) unit, the hydrator, the 

circulating dry scrubber vessel, the carbon storage and injection system, and the 

electrostatic precipitator. Specifically, sound sources would include a water pump, 

hydrator feed system, air blowers, mechanical electrostatic precipitator rappers, two large 

booster fans, and various control valves. These sound sources would be enclosed and 

acoustically insulated. Noise sources within the buildings would be fitted with soundattenuating enclosures or other noise dampening measures that would meet all state and 

federal regulations and AES’ noise standards. New equipment would operate at noise 

levels less than 85dB(A) at 3 ft from the base of the equipment (Scandrol 2004). During 

maintenance/repair events, workers would be required to wear hearing protection 

equipment. 

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Greenidge Multi-Pollutant Control Project

There is no residential population within a quarter mile of the proposed project 

(Section 3.9.2). Due to planned noise attenuation measures, natural and man-made terrain 

features, and distance to the nearest residences, no perceptible change in noise associated 

with the proposed project would be expected. Therefore, the proposed project would be 

unlikely to increase noise levels perceptibly at the nearest residences or other offsite 

locations. 

4.1.11 Electromagnetic Fields

Over the past two decades, some members of the scientific community and the 

public have expressed concern regarding human health effects from electromagnetic 

fields (EMF) during the transmission of electrical current from power plants. Despite 

efforts by the scientific community and research funding from governmental agencies 

and private organizations, the issue is still clouded with much uncertainty. The scientific 

evidence suggesting that EMF exposures pose any health risk is weak. The strongest 

evidence for health effects comes from associations observed in human populations with 

two forms of cancer, childhood leukemia and chronic lymphocytic leukemia in 

occupationally exposed adults (NIEHS 1999). EMF exposure cannot be recognized as 

entirely safe because of this evidence, even though the evidence does not clearly 

demonstrate a cause and effect relationship between EMFs and human health effects. 

Virtually everyone in the United States uses electricity and is exposed to EMFs; 

therefore, a continued emphasis on educating both the public and the regulated 

community on means aimed at reducing exposures is prudent. 

For the proposed project, no additional sources of EMF such as new transmission 

lines would be required and, as a result, no perceptible changes to existing EMF levels 

would occur. Consequently, EMF-related health effects, if present, would be unchanged 

and small (NRC 1997). 

4.1.12 Human Health and Safety

The proposed project would be subject to the OSHA General Industry Standards 

(29 CFR Part 1910) and the OSHA Construction Industry Standards (29 CFR Part 1926). 

During construction and operation of the proposed project, risks would be minimized by 

Greenidge Station’s adherence to procedures and policies required by OSHA, the state of 

New York, and AES. These standards establish practices, chemical and physical exposure 

limits, and equipment specifications to preserve employee health and safety. 

Construction activities would comply with OSHA Construction Industry 

Standards (29 CFR Part 1926). Construction permits and safety inspections would be 

employed in an effort to minimize the frequency of accidents and further ensure worker 

safety. Construction equipment would be required to meet all applicable safety design 

and inspection requirements, and personal protective equipment would meet regulatory 

and consensus standards. 

Potential health impacts to workers during construction of the proposed project 

would be limited to normal hazards associated with construction (i.e., no unusual 

situations would be anticipated that would make the proposed construction activities 

more hazardous than normal for a major industrial construction project). Most accidents 

in the construction industry result from overexertion, falls, or being struck by equipment 

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(NSC 2003). Construction-related illnesses would also be possible (e.g., exposure to 

chemical substances from spills). 

Following construction of the proposed project, the total number of permanent 

employees needed to operate the facilities would not change (Section 2.1.4). To 

maximize worker safety, operations would be managed from a control room. All 

instruments and controls would be designed to ensure safe start-up, operation, and shut 

down. The control system would also monitor operating parameters and perform 

reporting functions. Control stations would be placed at remote locations at which 

operator attention would be required. Therefore, the overall design, layout, and operation 

of the facilities would minimize human hazards. Compliance with the Federal 

Occupational Safety and Health Standards, as well as safety standards specified by the 

state of New York and AES, would help maintain occupational safety at Greenidge 

Station. No substantial differences with respect to occupational safety or industrial 

hygiene would be expected between current operations and those of the proposed project. 

Thus, the occupational safety and health experience would not be expected to change as a 

result of the proposed operations. 

Greenidge Station and AES would develop supplemental detailed procedures for 

inclusion in the plant’s Occupational Safety and Health Program to assure compliance 

with OSHA and EPA regulations and serve as a guide for providing a safe and healthy 

environment for employees, contractors, visitors, and the community. These procedures 

would include job procedures describing proper and safe manners of working within the 

facilities, appropriate personal protective equipment (PPE) and hearing conservation 

protection devices (e.g., handling/storage of NH3 would comply with CFR 1910.111 

Hazardous Materials, Storage and handling of anhydrous ammonia; PPE would comply 

with CFR 1910.132, etc.). The manual would be used as a reference and training source 

and would include accident reporting and investigation procedures, emergency response 

procedures, gas rescue plan procedures, hazard communication program provisions, 

material safety data sheets, medical program requirements, and initial and refresher 

training requirements. In addition, supplemental provisions would be added to the plant’s 

Contingency Plan for Hazardous Waste, Spill Prevention Control and Countermeasures 

Plan, Hazard Substances Response Procedures, and Air Pollution Emergency Episode 

Plan. 

Potential health impacts to the public from the proposed project would include 

fugitive dust emissions typical of construction sites (Section 4.1.2.1) and operational 

combustion emissions from the proposed project (Section 4.1.2.2). Because ambient air 

quality standards are designed to protect public health with an adequate margin of safety 

(Section 3.2.2), continued attainment of air quality standards during construction and 

operation of the proposed project (Section 4.1.2) indicates that impacts to public health 

would be minimal. 

4.2 POLLUTION PREVENTION MEASURES 

 Table 4.2.1 lists the pollution prevention measures that the project participants 

would provide during construction and operation of the proposed project. In addition, the 

project itself would demonstrate technologies to reduce air emissions. Specifically, the 

project would integrate a single-bed selective catalytic reduction (SCR) system for NOx

control and a circulating dry scrubber (CDS) for SO2, Hg, HCl, HF, and SO3 control. 

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Greenidge Multi-Pollutant Control Project

Table 4.2.1. Pollution prevention measures developed for the proposed project 

at Greenidge Station 

Environmental 

Issue Pollution prevention measure

Water quality Follow standard engineering practices to prevent or minimize runoff, erosion, 

and sedimentation on and near the construction site (e.g., silt fences, berms, 

liners and cover materials as necessary). 

Ensure prompt containment and clean-up of accidental spills of construction 

materials such as solvents, paints, oil and grease, and hazardous substances in 

accordance with an appropriate spill, prevention, control, and countermeasure 

plan and best management practices plan.

Waste disposal Investigate opportunities to reduce waste disposal requirements by finding 

beneficial uses for fly ash generated by the proposed project. 

Conduct leach testing of the fly ash prior to disposal to provide opportunities to 

modify the waste form to limit the potential release of contained Hg. 

Regenerate or recycle spent catalyst from the selective catalytic reduction 

(SCR) system, rather than transporting this material for disposal. 

Investigate the impact of process parameters on SCR catalyst life and 

adjust these parameters to minimize degradation of SCR catalyst, thus reducing 

the frequency of replacement or regeneration. 

Noise Ensure that all construction equipment (e.g., exhaust mufflers, engine 

enclosures, etc.) is in good working order, properly maintained, and lubricated. 

Use air inlet silencers on the project’s small blower units. 

Fit the ash handling system exhauster with an exhaust silencer (i.e., muffler) 

and operate the system intermittently. 

Equip delivery trucks with properly maintained mufflers. 

Acoustically insulate the structure enclosing the proposed ESP or baghouse and 

its associated equipment, as well as all doors, windows, and vent louvers.

Fugitive dust Sprinkle exposed soils at the proposed project site with water during 

construction. Erosion of exposed surfaces and soil stockpiles would be limited 

through standard management practices. 

Lockwood Landfill operators have increased the wetting and compaction of fly 

ash and are implementing a new landfill operations plan designed to reduce 

wind exposure of active disposal areas. 

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4.3 ENVIRONMENTAL IMPACTS OF NO ACTION 

 Under the first scenario of the no-action alternative, in which AES would shut 

down Greenidge Station, environmental impacts for most resource areas would be less 

than for the proposed project. Resource requirements and discharges and wastes would 

cease. Because current environmental conditions at the site would tend to revert back to 

conditions prior to plant operation, existing impacts would be reduced. However, adverse 

socioeconomic impacts would be experienced because no construction activities would 

be undertaken, no employment would be provided for construction workers in the area 

(except for some limited activity associated with mothballing or dismantling the plant), 

and power plant workers would lose their jobs. In addition, at other power plants where 

electrical generation would increase to compensate for shutting down Greenidge Station 

(Section 2.2.1), impacts would tend to increase because the plants would tend to be older 

and generate greater quantities of air emissions, liquid discharges, and solid wastes. 

 Under this first scenario, disposal activity at the Lockwood Landfill probably 

would cease. Final cover would be applied, consistent with NYSDEC permitting 

requirements. The multilayer final cover would consist of a low-permeability synthetic 

membrane layer overlain by a permeable geosynthetic drainage layer and a protective soil 

layer at least 2 ft thick. Vegetation would be established over the cover. Site maintenance 

and monitoring would continue during a 30-year post-closure period. Landfill runoff and 

leachate would continue to be collected and discharged periodically to Keuka Outlet, as 

discussed in Section 4.1.7.2, until NYSDEC determined that the leachate no longer posed 

a threat to human health or the environment (Title 6, Official Compilation of Codes, 

Rules and Regulations of the State of New York, Subpart 360-2, Landfills). 

 Under the second scenario of the no-action alternative, in which AES would 

install commercially available pollution controls to comply with current and future 

emissions standards, operations would remain essentially the same as for the existing 

plant. Resource requirements and discharges and wastes would generally be the same as 

under current conditions, except that air emissions would be reduced because of the 

enhanced pollution controls and solid wastes would likely increase due to the captured air 

emissions. Additional solid wastes would likely be recycled or sold as a usable product. 

Construction activities associated with this scenario would be similar in scale to those of 

the proposed project. With the exception of improving air quality, there would be 

minimal change in current environmental conditions at the site and the impacts would 

remain very similar to existing conditions. 

 Under the third scenario, in which AES would switch to using natural gas rather 

than coal at Greenidge Station, disturbance beyond the Greenidge site would be greater 

than for the proposed project because of construction associated with a new 14-mile 

natural gas pipeline to deliver the fuel. Beneficial socioeconomic effects would likely 

result because construction activities would probably be at a slightly greater level than 

those associated with the proposed project. However, the potential cumulative impacts 

associated with the proposed project (i.e., availability and cost of tourist lodging 

facilities, effectiveness of wastewater treatment services, and flow and safety of traffic on 

State Highway 14) could be more substantial under this scenario. Resource requirements 

and discharges and wastes would generally be smaller than for the proposed project 

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Greenidge Multi-Pollutant Control Project

because of the type of fuel and because the converted facility would be more efficient 

than the existing plant due to a new gas-fired delivery system and other upgrades. Air 

emissions, particularly SO2 emissions, would be considerably less than under current 

conditions because a new gas-fired delivery system would burn more efficiently and 

cleanly than an aging coal-fired power plant with limited emissions controls. As a 

beneficial impact, ash generation would be reduced or eliminated at the power plant, 

depending on whether Unit 4 alone or both units were switched. Current environmental 

conditions and impacts at the site would be expected to improve. 

 Under the fourth scenario, in which AES would purchase emissions allowances 

(e.g., SO2, NOx), the existing power plant would continue operating under current 

conditions. Resource requirements and discharges and wastes would be the same. 

Negligible change in current environmental conditions would be experienced at the site 

and the impacts would remain very similar to existing impacts. This scenario would not 

provide employment for construction workers in the area. The consumption of additional 

water from Seneca Lake by the proposed project would not occur. The potential 

cumulative impacts associated with the proposed project (i.e., availability and cost of 

tourist lodging facilities, effectiveness of wastewater treatment services, and flow and 

safety of traffic on State Highway 14) would not be experienced. The proposed project’s 

potential benefits of reducing SO2, NOx, HCl, HF, SO3, and Hg air emissions would not 

be realized. Consequently, the potential benefits of reduced air emissions to surface 

waters, wetlands, and ecological resources would not be realized. 

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5. IMPACTS OF COMMERCIAL OPERATION

 At the end of the 12-month demonstration period of performance testing and 

monitoring, two scenarios are reasonably foreseeable: (1) a successful demonstration 

followed immediately by commercial operation of the project at the same power level 

using all of the new equipment from the demonstration; and (2) an unsuccessful 

demonstration followed by operation of Unit 4 at the same power level using the ESP or 

baghouse without the CDS, lime or carbon injection, or the SCR system. 

 Under the first scenario, the level of short-term impacts during commercial 

operation would not change from those described for the demonstration in Section 4 

because the proposed project would continue as a baseload power plant operating 

24 hours per day with the same operating characteristics. For long-term effects, the level 

of impacts would be nearly identical to those discussed in Section 4, except for impacts 

that accumulate with time (i.e., fly ash disposal). 

If not beneficially reused, fly ash from the proposed project would be transported 

to the Lockwood Landfill for disposal (Section 4.1.7.2). By using the calculation in 

Section 4.1.7.2, an estimate is derived that the landfill could accommodate Greenidge 

Station wastes (including all of the waste from the proposed project) through 2040. Even 

with less optimistic assumptions about landfill capacity, it is apparent that the landfill site 

could accommodate fly ash from the proposed project until well beyond its 20-year 

commercial lifetime. 

Catalysts used in the SCR process lose their reactivity over time and would need 

to be replaced or regenerated after about 3 years (Section 4.1.7.3). During the 3-year 

intervals, which would occur during commercial operation of the proposed project, it may 

be possible to regenerate the spent catalyst in situ, or it could be removed and returned to 

the manufacturer for treatment by one of several methods (Maier and Spokovny 2000). In 

the unlikely event that spent catalyst were discarded, it could become a hazardous waste 

because the active agent in the catalyst, vanadium pentoxide (V2O5), is classified as an 

acutely hazardous waste when discarded and is restricted from land disposal under both 

NYSDEC and federal regulations. Any spent catalyst discarded as a waste would need to 

be physically stabilized with cement or a similar material prior to disposal in a licensed 

hazardous waste landfill (40 CFR 268). 

 Hazardous waste landfills are available commercially to manage this waste. In 

2001, a total of 32 licensed hazardous waste landfills or surface impoundments around 

the United States received waste from offsite sources (EPA undated). The one 

commercial hazardous waste land disposal facility in the state of New York is a landfill 

in Niagara County that handled 132,000 tons of waste in 2001. This landfill is projected 

to reach its licensed capacity by 2005 (NYSDEC 2003d). The NYSDEC expects that, if 

this facility closes, additional hazardous waste landfill capacity would be developed 

somewhere in the northeastern United States. However, licensed landfills in other parts of 

the country are estimated to have sufficient capacity for the volume of waste currently 

being landfilled at the Niagara County site (NYSDEC 2003d). Residues from catalyst 

regeneration might need to be managed as hazardous waste, but quantities would be 

smaller than if the entire catalyst volume were disposed. 

 Impacts associated with operations under the second scenario (an unsuccessful 

demonstration followed by operation of Unit 4 at the same power level using the ESP or 

______________________________________________________________________________________ 

5-1 
Greenidge Multi-Pollutant Control Project 

baghouse without the CDS, lime or carbon injection, or the SCR system) would be 

similar to those during existing operations. Less fly ash would be captured by the ESP or 

baghouse than during the demonstration, due to the absence of lime and carbon injection. 

The amount of captured fly ash would probably be the same or slightly greater than under 

existing operations because the efficiency of the new ESP or baghouse would probably 

be slightly greater than the efficiency of the existing ESP serving Unit 4. Also, the 

characteristics of the fly ash under the second scenario would revert back to the 

characteristics of the fly ash currently generated by Greenidge Station. Air emissions 

would revert back to approach those under existing operations. The slightly more 

efficient ESP or baghouse might capture more particulate emissions. The small additional 

amount of water required during the demonstration would no longer be needed. 

______________________________________________________________________________________ 

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DOE/EA-1493; August 2004 

6. CUMULATIVE EFFECTS

 This section discusses potential impacts resulting from other facilities, operations, 

and activities that in combination with potential impacts from the proposed project may 

contribute to cumulative impacts. Cumulative impacts are impacts on the environment 

that result from the incremental impact of the proposed project when added to other past, 

present, and reasonably foreseeable future actions regardless of the agency (federal or 

non-federal) or person that undertakes such other actions (40 CFR Part 1508.7). An 

inherent part of the cumulative effects analysis is the uncertainty surrounding actions that 

have not yet been fully developed. The Council on Environmental Quality (CEQ) 

regulations provide for the inclusion of uncertainties in the analysis, and state that 

“(w)hen an agency is evaluating reasonably foreseeable significant adverse effects on the 

human environment in an EIS and there is incomplete or unavailable information, the 

agency shall always make clear that such information is lacking” (40 CFR Part 1502.22). 

The CEQ regulations do not say that the analysis cannot be performed if the information 

is lacking. Consequently, the analysis contained in this section includes what could be 

reasonably anticipated to occur given the uncertainty created by the lack of detailed 

investigations to support all cause and effect linkages that may result from the proposed 

project, and the indirect effects related to construction and long-term operation of the 

facility. 

 Because cumulative impacts accrue to resources, the analysis of impacts must 

focus on specific resources or impact areas as opposed to merely aggregating all of the 

actions occurring in and around the proposed facility and attempting to form some 

conclusions regarding the effects of the many unrelated actions. Narrowing the scope of 

the analysis to resources that would be expected to experience a reasonable likelihood of 

accrued foreseeable impacts supports the intent of the NEPA process, which is “to reduce 

paperwork and the accumulation of extraneous background data; and to emphasize real 

environmental issues and alternatives” [40 CFR Part 1500.2(b)]. Each resource analyzed 

has its own spatial (geographic) boundary, although the temporal boundaries (time frame) 

can generally be assumed to equal the life expectancy of the proposed project. 

 The proposed project would reduce SO2, NOx, HCl, HF, SO3, and Hg air 

emissions, which would improve overall air quality and slightly decrease existing 

cumulative impacts in the region. Due to the reduction in emissions of SO2, NOx, HCl, 

HF, and SO3, (which are associated with acid deposition) and Hg (which adversely 

affects humans and biota), the proposed project would slightly decrease existing 

cumulative impacts to surface waters, wetlands, and ecological resources at the local and, 

quite possibly, regional scales. 

Project construction and operation would have slight socioeconomic impacts, and 

could contribute to cumulative impacts on the area's socioeconomic resources. The most 

noticeable of these cumulative impacts would likely result if the timing of the peak 

construction work force would coincide with the region's summer tourist season. These 

activities could conceivably combine to adversely affect the availability and cost of 

tourist lodging facilities, the effectiveness of wastewater treatment services, and the flow 

and safety of traffic on State Highway 14. However, such cumulative impacts, if they 

occur, would more likely be imperceptible and would be temporary, occurring during 

only a small portion of the 12-month construction period. 

______________________________________________________________________________________ 

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Greenidge Multi-Pollutant Control Project 

 Because negligible or no impacts from the proposed project would be experienced 

by remaining resources, no cumulative impacts would be expected to these resources. 

Further, few new facilities, operations, or activities that could result in cumulative 

impacts are anticipated for the vicinity of Greenidge Station in the same time frame as the 

proposed project. The New York State Department of Transportation has no ongoing or 

planned road construction activities for State Highway 14 or for any other roads in Yates 

County (Bill Piatt, New York State Department of Transportation Region 6, personal 

communication to Bo Saulsbury, ORNL, February 11, 2004). The only ongoing or 

potential project known to the Yates County Industrial Development Agency is the 

possibility of an additional tourist lodging facility (Steve Isaacs, Yates County Industrial 

Development Agency, personal communication to Bo Saulsbury, ORNL, March 10, 

2004). 

______________________________________________________________________________________ 

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DOE/EA-1493; August 2004

7. REGULATORY COMPLIANCE AND PERMIT REQUIREMENTS

 This section lists federal, state, and local regulatory compliance and permit 

requirements for the proposed project. 

 Under Section 7 of the Endangered Species Act of 1973 (Public Law 93-205, as 

amended), DOE must consult with the U.S. Fish and Wildlife Service to ensure that 

proposed actions are not likely to jeopardize the continued existence of any endangered 

species or threatened species or result in the destruction or adverse modification of the 

critical habitat of such species (Appendix A). 

 Under Section 106 of the National Historic Preservation Act (Public Law 89-665, 

as amended), DOE must consult with New York’s State Historic Preservation Officer to 

ensure compliance with the act (Appendix B). 

7.1 FEDERAL REQUIREMENTS 

CLEAN AIR ACT (CAA)

• Enacted by Public Law 90-148, Air Quality Act of 1967 (42 USC 7401 et seq.) 

• Amended by Public Law 101-549, Clean Air Act Amendments of 1990 

• Comprised of Titles I through VI 

• Applicable titles 

 — Title I—Air Pollution Prevention and Control. This Title is the basis for 

air quality and emission limitations, PSD permitting program, State 

Implementation Plans, New Source Performance Standards, and National 

Emissions Standards for Hazardous Air Pollutants. The PSD permitting 

program serves as the basis for PSD Construction Permits which are required 

by this Title of the Act. 

 — Title IV—Acid Deposition Control. This Title establishes limitations on 

sulfur dioxide and nitrogen oxide emissions, permitting requirements, 

monitoring programs, reporting and record keeping requirements, and 

compliance plans for emission sources. This Title requires that emissions of 

sulfur dioxide from utility sources be limited to the amounts of allowances 

held by the sources. 

 — Title V—Permitting. This Title provides the basis for the Operating Permit 

Program and establishes permit conditions, including monitoring and 

analysis, inspections, certification, and reporting. 

• Regulations implementing the CAA are found in 40 CFR Parts 50–95. 

FEDERAL WATER POLLUTION CONTROL ACT

• Enacted by Public Law 92-500 (33 USC 1251 et seq.) 

• Amended by Public Law 95-217, Clean Water Act of 1977 (CWA) and Public 

Law 100-4, Water Quality Act of 1987 

• Comprised of Titles I through IV 

• Applicable titles 

 — Title III—Standards and Enforcement 

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Greenidge Multi-Pollutant Control Project

 Section 316—Thermal Discharges. Section 316 (a) addresses the 

permitting of thermal discharges that can allow alternative thermal effluent 

limitations that are less stringent than the limitations under Section 402(a) of 

the CWA. This section states that, if an owner of a discharge subject to 

Section 301 (Effluent Limitations) or Section 306 (National Standards of 

Performance) can demonstrate that an effluent limitation is “. . . more 

stringent than necessary to assure the protection and propagation of a 

balanced, indigenous population of shellfish, fish, and wildlife in and on the 

body of water into which the discharge is to be made. . .”, then another 

effluent limitation may be imposed “. . .with respect to the thermal 

component of such discharge. . .” 

 Section 316 (b) addresses the permitting of water intake structures 

and requires that “Any standard established pursuant to Section 301 or 

Section 306 of this Act and applicable to a point source shall require that the 

location, design, construction, and capacity of cooling water intake structures 

reflect best technology available for minimizing adverse environmental 

impact.” 

 — Title IV—Permits and Licenses 

 Section 402, National Pollutant Discharge Elimination System 

(NPDES). This section regulates the discharge of pollutants to surface 

waters. Regulations implementing the NPDES program are found in 40 CFR 

Part 122. 

 Section 404, Permits for Dredged or Fill Material. This section 

regulates the discharge of dredged or fill material in the jurisdictional 

wetlands and waters of the United States. The COE has been delegated the 

responsibility for authorizing these actions. 

• Regulations implementing the CWA are found in 40 CFR Parts 104–140. 

Regulations which affect the permitting of this project include 

 — 40 CFR Part 112—Oil Pollution Prevention. This regulation requires the 

preparation of a Spill Prevention, Control, and Countermeasure Plan. 

 — 40 CFR Part 122—NPDES. This regulation requires the permitting and 

monitoring of any discharges to waters of the United States. 

EXECUTIVE ORDERS 11988 AND 11990

 Executive Order 11988, Floodplain Management, directs federal agencies to 

establish procedures to ensure that they consider potential effects of flood hazards and 

floodplain management for any action undertaken. Agencies are to avoid impacts to 

floodplains to the extent practical. Executive Order 11990, Protection of Wetlands, 

requires federal agencies to avoid short- and long-term impacts to wetlands if a practical 

alternative exists. DOE regulation 10 CFR Part 1022 establishes procedures for 

compliance with these Executive Orders. Where no practical alternatives exist to 

development in floodplain and wetlands, DOE is required to prepare a floodplain and 

wetlands assessment discussing the effects on the floodplain and wetlands, and 

consideration of alternatives. In addition, these regulations require DOE to design or 

modify its actions to minimize potential damage in floodplains or harm to wetlands. DOE 

is also required to provide opportunity for public review of any plans or proposals for 

actions in floodplains (and new construction in wetlands). 

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DOE/EA-1493; August 2004

 The floodplain and wetlands effects anticipated from this proposed project are 

provided in the following sections of the EA: Section 3.5.1 (Floodplains—Existing 

Environment), Section 3.5.2 (Wetlands—Existing Environment), Section 4.1.5.1 

(Floodplains— Environmental Consequences), and Section 4.1.5.2 (Wetlands—

Environmental Consequences). 

RESOURCE CONSERVATION AND RECOVERY ACT OF 1976

• Enacted by Public Law 94-580 (42 USC 6901 et seq.) 

• Amended by Public Law 98-616, Hazardous and Solid Waste Amendments of 

1984 and Public Law 99-499, Superfund Amendments and Reauthorization Act of 

1986 

• Applicable title 

 —Title II—Solid Waste Disposal (known as the Solid Waste Disposal Act) 

regulates the disposal of solid wastes. Under Title II, Subtitle D—State or 

Regional Solid Waste Plans, allows each state to develop a comprehensive 

plan for managing and permitting the disposal of solid wastes. 

• Project participants would be required to identify any residues that require 

management as hazardous waste under RCRA (40 CFR Part 261). For some waste 

streams, this includes testing waste samples using the TCLP or other procedures 

that measure hazardous waste characteristics. 

ENDANGERED SPECIES ACT OF 1973

• Enacted by Public Law 93-205 (16 USC 1531 et seq.) 

 — Section 7, “Interagency Cooperation,” requires any federal agency 

authorizing, funding, or carrying out any action to ensure that the action is 

not likely to jeopardize the continued existence of any endangered species or 

threatened species or result in the destruction or adverse modification of 

critical habitat of such species. Consequently, the U.S. Fish and Wildlife 

Service will conduct a consultation, in compliance with Subsection (a)(2) of 

Section 7 of the Act, with regard to the impacts of the proposed project on 

threatened and endangered species listed by the Service and any critical 

habitat of such species in the vicinity of the project. 

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

• OSHA General Industry Standards (29 CFR Part 1910) 

• Authority: Secs. 4, 6, 8, Occupational Safety and Health Act of 1970 (29 U.S.C. 

653, 655, 657); Secretary of Labor's Order Numbers 12-71 (36 FR 8754), 8-76 

(41 FR 25059), 9-83 (48 FR 35736), 1-90 (55 FR 9033), or 6-96 (62 FR 111), as 

applicable. 

• OSHA Construction Industry Standards (29 CFR Part 1926) 

• Authority: 44 FR 8577, Feb. 9, 1979; 44 FR 20940, Apr. 6, 1979 

7.2 STATE REQUIREMENTS 

• Title V Facility Permit and Modified Title IV Facility Permit 8-5736-

00004/00013 and 8-5736-00004/00014, New York State Department of 

Environmental Conservation 

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Greenidge Multi-Pollutant Control Project

• State Pollutant Discharge Elimination System Permit 8-5736-00004/00001, New 

York State Department of Environmental Conservation 

• Facilities used for disposal of solid waste must be licensed by the New York State 

Department of Environmental Conservation. Construction and operation of these 

facilities must conform with requirements established as a condition of licensing. 

Disposal of fly ash would be in Lockwood Landfill. 

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DOE/EA-1493; August 2004 

8. IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS 

OF RESOURCES

 For the proposed project, some of the resource commitments would be 

irreversible and irretrievable; that is, the resources would be neither renewable nor 

recoverable for future use. Resources that would be irreversibly or irretrievably 

committed by construction and demonstration of the proposed project include 

construction materials that could not be recovered or recycled and fuel and sorbent 

consumed or reduced to unrecoverable forms of waste. 

 Resources used during construction of the proposed project would include 

crushed stone, sand, water, diesel fuel, gasoline, and iron ore used to produce steel. 

Resources used during the demonstration would include coal, No. 2 fuel oil, lime, 

ammonia, powdered activated carbon, and water. None of these resources is in short 

supply relative to the size and location of the proposed project. 

 The proposed project requires a commitment of human and financial resources 

that could threaten or jeopardize the use of these resources for alternative projects or 

federal activities. However, the commitment is consistent with the purpose and need for 

the proposed project (Section 1).

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DOE/EA-1493; August 2004 

9. THE RELATIONSHIP BETWEEN SHORT-TERM USES OF THE 

ENVIRONMENT AND LONG-TERM PRODUCTIVITY

 The proposed project would occupy about 3 acres of the Greenidge Station site 

and consume resources (either individually or as part of the power plant) including coal, 

No. 2 fuel oil, lime, ammonia, powdered activated carbon, and water. The proposed 

project (either individually or as part of the power plant) would generate liquid effluents 

and solid wastes (unless all of the fly ash were sold). Except for NH3 emissions, air 

emissions would be unaffected or reduced. 

 The long-term benefit of the proposed project would be to demonstrate 

environmentally sound and innovative technologies for the utilization of coal. The project 

would integrate a single-bed selective catalytic reduction (SCR) system for NOx control 

and a circulating dry scrubber (CDS) for SO2, Hg, HCl, HF, and SO3 control. By 

reducing SO3 emissions, the CDS would also minimize visible emissions from the stack. 

This pollution control system is particularly suited for retrofitting smaller (<300 MW) 

coal-fired boilers that could be vulnerable to retirement or fuel switching under current 

environmental regulations. 

 The goals of the proposed demonstration include both improved costcompetitiveness with current technologies (particularly for SO2, NOx, and Hg control on 

smaller coal-fired units) and greatly reduced Hg, SO3, and fine particulate emissions 

compared to conventional technologies. The following emissions targets have been 

established for the integrated technologies compared with uncontrolled emissions: a 95% 

reduction in emissions of SO2, SO3, HCl, and HF, a 60% to 90% reduction in Hg 

emissions, NOx emissions of less than 0.122 lb/MMBtu, and no visible emissions from 

the stack. 

 The design size for the proposed project was selected to establish performance 

results at a scale that would convince utilities that the integrated technologies, once 

demonstrated at this scale, could be commercialized using similar sized or larger 

applications without further scale-up to verify operational or economic performance. 

Therefore, although the proposed project would consume resources and generate 

effluents and solid wastes, the project would demonstrate integrated technologies that, 

once commercialized, would generally reduce air emissions both domestically and abroad 

compared with conventional coal technologies. 

9-1
10. REFERENCES

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AES Greenidge. 2004. Payroll and tax payment information provided to members of the 

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CONSOL. 2002. Environmental Information Volume for Greenidge Multi-Pollutant 

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CONSOL. 2004a. Response to Request for Additional Information. Letter from Roy 

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Greenidge Multi-Pollutant Control Project

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DOE/EA-1493; August 2004

Goodfriend, L.S. and Associates 1971. Noise From Industrial Plants, U.S. Environmental 

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J.A. Daigler & Associates. 2003. Lockwood Ash Landfill Fill Progression Plan, prepared 

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Greenidge Multi-Pollutant Control Project

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10-4 
DOE/EA-1493; August 2004

Senior, C., C. J. Bustard, K. Baldrey, T. Starns, and M. Durham 2003. “Characterization 

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County Industrial Development Agency. January. 

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11. LIST OF AGENCIES AND INDIVIDUALS CONTACTED

John Kent, New York State Department of Environmental Conservation, Air Resources 

Division, Albany, New York 

Bill Piatt, New York State Department of Transportation Region 6, Hornell, New York 

Steve Isaacs, Yates County Industrial Development Agency, Penn Yan, New York

11-1