### 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 ABBREVI ATIONS ........................................................................ ix

1. PURPOSE AND NEED FOR AGE NCY 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

iiiiv 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 RES OURCES....................................................................... 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 W ETLANDS........................................................... 3-10 3.5.1 Floodplains ......................................................................................... 3-10

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

3.6 ECOLOGICAL RES OURCES..................................................................... 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 TRANSPORTATI ON 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 CONS EQUENCES .............................................................. 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.............................................................................. 4-8v 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 THEvi NATIONAL HISTORIC PRESERVATION ACT .............................. B-1

APPENDIX C PUBLIC PA RTICIPATION LETTERS.............................................. C-1vii 

### 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 sy stem ...................................................................................................... 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........................................................................................... 4-22ix 

### ACRONYMS AND ABBREVIATIONS

ADT average daily traffic AES Applied Energy Services

Btu British thermal unit

CAA Clean Air Act

CaCO 3 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

CO 2 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

Ε F degrees Fahrenheit FGD flue gas desulfurization FONSI Finding of No Significant Impact

FR Federal Register

ft feet

ft 3 cubic feet

FWS U.S. Fish and Wildlife Service g the acceleration of gravity gpd gallons per day gpm gallons per minute

H 2 O water HCl hydrogen chloride HF hydrogen fluoride Hg mercury

in. inch lb pound

Φ g microgram

Φ m micrometer

m 3 cubic meter mg milligram mg/L milligrams per literx MGD million gallons per day MW megawatt NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act

NH 3 ammonia

NHPA National Historic Preservation Act of 1966 NIOSH National Institute for Occupational Safety and Health

NO 2 nitrogen dioxide

NO X oxides of nitrogen NPDES National Pollutant Discharge Elimination System NYSDEC New York State Department of Environmental Conservation

O 3 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 Φ m in aerodynamic diameter PM-2.5 particulate matter less than 2.5 Φ m 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

SO 2 sulfur dioxide

SO 3 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

V 2 O 5 vanadium pentoxide VOCs volatile organic compounds yd 3 cubic yardDOE/EA-1493; August 2004



### 1. PURPOSE AND NEED FOR AGENCY ACTION

1.1 INTRODUCTION
This environmental assessment (EA) ha s 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 ope rating 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 whethe r or not to provide cost-shared funding to design, construct, and demonstr ate 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 demonstrat ion project is expect ed 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 integra tion of technologies to reduce emissions of sulfur dioxide (SO 2 ), oxides of nitrogen (NO

x ), sulfur trioxide (SO 3 ), mercury (Hg), hydrogen chloride (HCl), and hydrogen fluor ide (HF) from smaller (<300 MW) coalfired boilers. The U.S. Congress established the PP II in Pub. L. 106-291, Department of the Interior and Related Agencies Appropri ations Act for Fiscal Year 2001. Congress directed DOE to provide up to $95 million in cost-shared funding to demonstrate commercial-scale technologies that impr ove the reliability and environmental performance of existing and new coal-fired power plants in the United States. Congress expected the selected technologi es to provide options by which coal plants could continue to generate low-cost electricity with improved performance and in compliance with stringent environm ental standards. The PPII Solicitation, issued in February 2001, required particip ants (i.e., the non-federal-government participant or participan ts) 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 environmen tal impacts, and/or increased costcompetitiveness. The projects were also requir ed to be applicable to a large portion of existing plants and and of co mmercial 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 pr oposed technology (40%), commer cial 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 proposa l; DOE budget constraints; environmental, health and safety implications; and program policy factors. Following selection, two of the projects were withdrawn by their particip ants in March 2002 a nd in October 2002. Each project participant is required to fina nce at least 50% of th e total cost of the project. After completion of a successful project demonstration, the participant would be obligated to repay the government’s financ ial contribution to ensure that taxpayers benefit from a successful projec t. The project par ticipant takes primary responsibility for

_____________________________________________________ ___________ 1-1Greenidge Multi-Polluta nt Control Project

designing, constructing, and demonstrating th e project. During project execution, the government oversees project activities, provi des 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 contro lled, 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 c ontribute nearly $61 m illion, exceeding the 50% private sector cost-sharing mandated by Congr ess. The host sites for the projects cover a large geographical cross-section of the Unite d 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 pr ovide cost-shared funding support for the design, construction, and demonstration of an in tegrated multi-pollutant control system at the existing 107-MW Unit 4 of AES’s coal-f ired 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 dem onstration would allow utilities to make decisions regarding the integrated emissions control system as a viable commercial option. CONSOL Energy Inc. and AES Greeni dge 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 involve ment constrains the ra nge 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, constructi on, and operation of the proposed combination of technologies to allow i ndustry to assess the project’s potential for commercial application. The proposed combination of tec hnologies is designed to reduce the capital and operating costs of envi ronmental controls for SO 2 , NO

x , SO 3 , HCl, HF, Hg, and

visible emissions. A demonstrat ion indicating that the perfor mance and cost targets are

achievable at the 100-MW scale would convince potential customers in the smaller boiler market that the integration of these syst ems 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 performa nce of existing and new coal-fired power plants in the United States. DOE’s cost-sha red funding would help reduce the financial risk to the project participant in demonstra ting the proposed combina tion of technologies:

________________________________________________________________________ 1

- 2DOE/EA-1493; August 2004

the single-bed selective catalytic reduction (S CR) 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 capaci ty 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 fu el or be retired in the future . If only the 190 boilers less than 110 MW are retired, the generating capaci ty would be reduced by up to 16,000 MW, which would exacerbate electricity and na tural gas supply and distribution problems throughout the United States. Therefore, a st rong incentive exists to commercialize technologies designed specifica lly to meet the environmen tal compliance needs of the smaller generating units. Because the SCR sy stem is a low-cost option for controlling

NO

x emissions from smaller generators and allo ws greater fuel flexibility, such as cofiring coal and biomass, it provides a feas ible alternative to retiring units as NO

x allocations are reduced and the NO

x 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 le tter and spirit of NEPA , which ensures that early consideration is given to environmenta l values and factors in federal planning and decision making. No action taken by DOE with regard to any propos al, including project selection or award, is considered a final decision prior to completion of the NEPA

process. For this proposed project, DOE has determ ined 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 Significan t 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 ma y significantly affect the quality of the human environment, then an EIS will be prepar ed 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 th e proposed project w ould 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 independe ntly assessing the issues and preparing the EA, ORNL has ut ilized information provided by DOE; other federal, state, and local agencies; the pr oject participant team; and others. DOE is responsible for the scope a nd 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 a nd evaluated in the EA include land use, aesthetics, atmospheric resources, water re sources, geological resources, floodplains,

_____________________________________________________ ___________ 1-3Greenidge Multi-Polluta nt Control Project

wetlands, ecological resources, waste manage ment, cultural resources, socioeconomic resources, transportation, noise, electromagne tic fields, and human health and safety. Related evaluations include impacts of co mmercial operation, cumulative effects, regulatory compliance and permit requirements, irreversible or irretrievable commitments of resources, and the relationship between s hort-term uses of the environment and longterm productivity. The scope of the assessm ent includes upgrades and alterations to Greenidge Station that are not considered part of the proposed project (i.e., replacing the secondary superheater s ection, installing low-NO

x 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, wh ich would be installed concurrently).

________________________________________________________________________ 1

- 4DOE/EA-1493; August 2004



### 2. THE PROPOSED ACTION AND ALTERNATIVES

This section discusses the proposed ac tion, the no-action al ternative (including four scenarios that would reasonably be exp ected to result as a consequence of the noaction alternative), and alternatives di smissed from further consideration.



### 2.1 PROPOSED ACTION
The proposed action is for DOE to pr ovide support through cost-shared funding for the design, construction, and demonstrati on 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 Yor k, along the western shore of Seneca Lake (Figure 2.1.1). The site is in a rural area of Torrey Townsh ip 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 Yate s County, is located about 5 miles to the west of Greenidge Station.

Greenidge

Station

Figure 2.1.1. Regional locati on map for the proposed project.

2-12-2 Greenidge Multi-Polluta nt 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 gene rate a total of approximately 161 MW (net) of electricity fo r the power grid. An additional 8 to 9 MW are produced to satisfy internal electrical n eeds at the station (the difference between gross MW and net MW). Figure 2.1.3 is a phot ograph 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 agricultu ral, 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 laydow n area and contractor parking lot adjacent to the existing powerhouse for Units 3 a nd 4 (Figure 2.1.4). The 3-acre site was previously excavated and graded in prepara tion for construction of a new unit, but those plans have since been abandoned. Units 1 and 2 of Greenidge Station we re constructed for the New York State Electric & Gas Corporation in 1937 and 1939, re spectively. 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 th e proposed project, began in December 1951, and the unit was placed in serv ice 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 pa rticular, the circulat ing dry scrubber (CDS)

would be taller than the insi de height of the powerhouse. Bo ilers 1 and 2 served the Unit 1 steam turbine, Boiler 3 served the Unit 2 st eam 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 pul verized coal. Conveyors with a capacity of 300 tons per hour transport crushed coal to the powerhouse for st orage in the bunkers prior to combustion in the 3 re maining 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 exhaus ted from the steam turbine generators. Water for cooling is drawn from Seneca Lake, a nd the heated water is returned to the lake via a discharge channel and Keuka Outlet. Tr ains 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 NO

x 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 overfire2-3gust 2004DOE/EA-1493; AuFigure 2.1.2. Site of GreenidgeStation and Lockwood Landfill.2-4 Greenidge Multi-Polluta nt Control Project

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

Figure 2.1.4. Photograph of the site for the propos ed project at Greenidge Station, as viewed toward the northwest.2-5 DOE/EA-1493; Au g ust 2004

air for NO

x 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 th e 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 NO

x control and a CDS for SO 2 , Hg, HCl, HF, and SO 3 control. By reducing SO 3 emissions, the CDS would also minimi ze visible emissions from the stack. This pollution control system is particular ly 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 NO

x control system consists of commercially available low-NO

x 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 (NH 3 ) storage and vaporization system, and an ammonia injection system. The CDS system consists of a hydrato r and hydrated lime feed system, the CDS vessel, an ESP or ba ghouse 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 ma tter into coarser material that would be collected in an ESP or baghouse. The in-duct SCR system is a mostly pa ssive technology with a minimal amount of moving parts, in which NO

x reduction occurs via a chemical reaction with ammonia in the presence of a catalyst. A mmonia supply to the flue gas stream relies on an ammonia pump, control valves, and a dilution air bl ower. Ammonia flow is controlled by two NO

x analyzers in the flue gas. Because the tec hnology is passive, negligible impact on station reliability is anticipated. The CDS system uses an absorption towe r 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, er osion, 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 SO 2 concentration in the inlet flue gas. The feed rate is adjusted by monitoring the SO 2 concentration at the exit of the particulate control device. The gas temp erature leaving the absorber controls the amount of flue gas cooling water injected th rough high-pressure flow nozzles into the absorber. Solids are discharged from the system at the same rate that hydrated lime, fly ash, and SO 2 enter the system.

1 In a gas reburn system, coal and combustion air to th e main burners are reduced and natural gas is injected to create a fuel-rich secondary combustion zone abov e the main burner zone, with final combustion air injected to create a fuel-lean burnout zone. The formation of NO

x is inhibited in the main burner zone due to the reduced combustion intensity, and NO

x is destroyed in the fuel-rich secondary combustion zone by conversion to molecular nitrogen.2-6Figure 2.1.5. A generalizeddiagram of the proposed multi-pollutant control system.BAGHOUSEORectGreenidge Multi-Pollutant Control ProjDOE / EA-1493; Au g ust 2004

The operating reliability of the CDS proce ss 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 ti me required to connect the system would be relatively short, which would minimize un it 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 demons tration include both improved costcompetitiveness with current technologies (particularly for SO 2 , NO

x , and Hg control on smaller coal-fired units) and greatly reduced Hg, SO 3 , and fine particulate emissions compared to conventional technologies. Th e following emissions targets have been established for the integrated technologies compared with uncontrolled emissions: a 95%

reduction in emissions of SO 2 , SO 3 , HCl, and HF, a 60% to 90% reduction in Hg emissions, NO

x emissions of less than 0.122 lb/MMB tu, and no visible emissions from

the stack.



### 2.1.3 Project Description The proposed project would integrate th e technologies described in Section 2.1.2 into the existing 107-MW Greenidge Unit 4. Becau se 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 Un it 4. The successful bidder providing the equipment would decide whether to inst all 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 c ontinue at AES’s nearby Lockwood Landfill, while commercial application of the materi al 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 w ould determine the effect of biomass firing on the performance of the integrated pollu tion control technologi es. In addition, the project would quantify the ma gnitude of cabon dioxide (CO 2) emissions reductions and

fuel cost reductions associated with using waste wood as feedstock.



### 2.1.4 Construction Plans

Construction activities associated wi th the proposed project would include foundation laying, steel fabricat ion, piping installation, and el ectrical 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 th e equipment for the proposed project to the existing Unit 4, as well as tying in some ot her modifications. Upgrad es 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-NO

x

2-7Greenid g e Multi-Pollutant Control Pro j ect

burners, and potentially replacing the economi zer and primary superheater sections. The duration of the Unit 4 outage would be about 2 months. If constr uction 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 th e Unit 4 outage would correspond with periodic maintenance outages scheduled for the spring and fall to avoid the peak loadperiods 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 w ould be involved with excavation and laying foundations during the initial construction at the si te. Approximately 100 to 150 workers would be required duri ng 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 material s would include crushed stone, sand, and lumber for the proposed facilitie s and temporary structures such as enclosures, forms, and scaffolding. Components of the facilities would include structural st eel, 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 c onstruction periods (i.e., during concrete foundation pouring). Approximate ly one truck per week woul d haul away construction debris to a municipa l 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 w ithin the 4.5-year period of the cooperative agreement c overing September 2004 through February 2009. The actual performance testing and monito ring 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 demons tration. As with current practice, 4 plant workers would be on duty during each of f our 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 leve ls for the proposed project would be determined during the demonstration. Long-term staffi ng 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 sa me power level and percentage of time as under current conditi ons, 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 generate d by Greenidge Station. Because Units 3 and 4 are usually at their peak capacity when th ey’re operating, the loss of 1 MW to the electrical grid would likely be offset by ot her power plants within the grid. However, because the amount is very small compared w ith regional electrical capacity, the offset would barely be perceptible a nd is not evaluated further.

2-82-9 DOE / EA-1493; Au g ust 2004



### 2.1.6 Resource Requirements Table 2.1.1 displays the operating ch aracteristics, 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 distur bed site for the proposed project would be used temporarily during construction activities for equipm ent/material laydown, storage, assembly of site-fabri cated components, staging of ma terial, and facilities to be used by the construction workforce (i.e., offi ces and sanitary facilities). Other smaller vacant, cleared areas around the site would al so 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 th e 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 constructi on of the proposed project for various purposes, including personal consumption a nd 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 Ya n municipal water system, which provides water to Dresden, while service water woul d be drawn from the underground conduit that supplies Unit 3 cooling water and plantwide se rvice water (i.e., water used for auxiliary equipment cooling, equipment washing, and demineralization). Combined potable and service water use during cons truction would average about 1 gallon per minute (gpm). Drinking water also would be provided us ing bottled water. Portable toilets would minimize requirements for additional sanitary water. During demonstration of the proposed pr oject, Greenidge St ation cooling water

and service water would continue to be provided by Seneca Lake, while potable water would continue to be supplied by the Penn Ya n municipal water system. For part of its water needs, Greenidge Station is equipped with an 8-ft diam eter gravity-fed intake pipe that extends underwater appr oximately 700 ft beyond the s horeline to a lake-bottom

intake structure. Beneath th e 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 wate r is pumped for use as service water by the entire plant. The cooling wate r is returned to the lake af ter 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 separa te intake structure, intake pipeline, pump house, and discharge pipeline used exclusivel y 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 in take structure about 25 ft below the lakeGreenidge Multi-Pollutant Control ProjectTable 2.1.1. Typical operating characteristics for GreenidgeStation Unit 4 alone and combined with Unit 3Unit 4Units 3 and 4Operating characteristics2002 base yearIncluding theproposed project2002 base yearIncluding theproposed projectGeneratingcapacity(net),MW107106161160Capacity factor, %a80No change80No changeSize of power plant site, acres153No change153No changeSize of project site, acres33Size of nearby Lockwood Landfill, acres143No change143No changeBituminous coal consumption, tons/year290,000No change450,000No changeWood consumption, tons/year11,450No change11,450No changeNo. 2 fuel oil consumption, gallons/year49,000No change120,000No changeLime, tons/year018,940018,940Ammonia,tons/year01280128Activated carbon, tons/year043043Air emissions, tons/yearSulfur 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)13,3691,82063287415276330.0120900,000602660632874151420.0050.14900,000b19,4503,19095429218409500.01801,300,0006,6832,03095429218147190.0110.141,300,000b2-102-11DOE/EA-1493; August 2004Table 2.1.1. concluded.Unit 4Units 3 and 4Operating characteristics2002 base yearIncluding theproposed project2002 base yearIncluding theproposed projectWater use, gpmNoncontact cooling waterService waterPotable water68,00001.2No change93No change93,000500112No change593No changeEffluents, gpmNoncontact cooling waterTreated wastewater to Seneca Lake68,0000.7No changeNo change93,0001No changeNo changeSolid waste, tons/yearBottom ashFly ash5,80040,000No change70,0008,70059,000No change89,000aCapacity factor is the ratio of the energy output during a period of time to the energy that would have been produced if the equipment had operated at itsmaximum power during that period.bCO2emissions would probably not change substantially from the current level because the circulating dry scrubber (CDS) would be expected to decreaseCO2emissions but the decrease would probably be offset by thereduced boiler thermal efficiency resulting from the new low-NOxburners (not considered partof the proposed project).Greenid g e Multi-Pollutant Control Pro j ect

surface. The cooling water is returned to Se neca Lake from the units’ separate discharge pipelines via a common discharge channel nor th 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 actua l increase in cooling water temperature resulting from the heat transfer to condens e 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 pow er plant at full load would continue to average 93,000 gpm. Potable water needs for th e power plant would c ontinue 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 hydr ator 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 supp lies Unit 3 cooling water and plantwide service water. The water would be consumed during the propos ed processes rather than being returned

to the lake. This additiona l water would represent appr oximately 0.1% of Greenidge Station’s current water use supplied by th e lake and about 15% of the plant’s consumptive use.

2.1.6.3 Fuel and Sorbent Requirements The current fuel requirements of Gr eenidge Station would continue at approximately the same level during the dem onstration 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 mine s near Wana, West Virginia, in Monongalia County near the southwestern co rner 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 nor th of Dresden. The rail cars at the siding are switched with the rail cars at the power plant after the initia l 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 Fish er 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 pi le. The two coals are segregated within the storage pile and blended at the power plant to reduce the overall sulfur co ntent 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 suppl y lower-sulfur coal. Table 2.1.2 pr esents an analysis of the composition of the two types of coal. During demonstration of the proposed pr oject, the lower-sulfur coal would probably not be required for Unit 4 because the CDS would reduce SO 2 emissions from

2-122-13 DOE / EA-1493; Au g ust 2004

Figure 2.1.6. Water flow diagram that depicts water requirements and discharges at Greenidge Station.Greenid g e Multi-Pollutant Control Pro j ect

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 approxima tely 95%. Consequently, Unit 4 would require about the same amount of coal, but a bout 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 a bout 450 truck loads per year of lower-sulfur coal to blend with higher-sulfur coal at the power plant to reduce th e overall sulfur content.

Unit 4 also uses waste wood as feedst ock in the combustor. The waste wood currently provides up to 10% of the total heat input to the boiler, wh ich 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 Sta tion. One truck per day usually delivers the waste wood. The arrangement is mutually bene ficial 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 th e plant site by tanker

trucks. During demonstration of the proposed proj ect, annual consumption of lime for the CDS and ammonia for the SCR system w ould 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 sout h-southwest of Greenidge Station. About 1,000

loads would be delivered annua lly in 20-ton trucks. The lim e could possibly be shipped by rail rather than truck. Ammonia woul d 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 annua lly in 20-ton trucks. A supplie r of the carbon has not yet

been identified.



### 2.1.7 Outputs, Discharges, and Wastes

2-14DOE / EA-1493; Au g ust 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 woul d generally decrease or continue at the same level during the demonstrat ion of the proposed project. SO 2 emissions would decrease from 19,450 tons per year currently to 6,683 tons per year. NO

x emissions would decrease from 3,190 tons per year curre ntly to 2,030 tons per year. Because of the additional particulate loading re sulting 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 Comp any (Table 2.1.2). CO and volatile organic compound (VOC) emissions would also be expect ed to remain at the same level (i.e., 92 and 18 tons per year, respectively). Plantwid e 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 (NH 3 ) injection into the flue gas, NH 3 emissions would increase from ne ar zero to about 280 lb per year.

Plantwide HCl and HF emissions would decr ease to about 147 and 19 tons per year, respectively, compared with current emissions of 409 and 50 tons per year, respectively.

SO 3 emissions are expected to decrease by the same percentage as SO 2 emissions,

but current and future emissions are no t known. Trace emissions of other pollutants would include beryllium, sulfuric acid mist, benzene, arsenic, and various heavy metals.

CO 2 emissions would probably not change s ubstantially from the current level of 1,300,000 tons per year because the CDS would be expected to decrease CO 2 emissions but the decrease would probably be offset by an increase due to a change in combustion

characteristics associated with the new lo w-NOx burners (not part of the proposed project). Although CO 2 is not considered an air pollutant, CO 2 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 th e 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 completecombustion is attained by the high combustion temperatures and relatively long fuelresidence times. A formaldehyde emission an alysis was performed by stack sampling at another New York power plant that co-fir es coal with waste wood containing ureaformaldehyde (Lindsey 2004). As part of th e analysis, the study included blanks to measure the ambient levels of formaldehyde in reagent solutions pr ior 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-f iring operation were indistinguishable from the laboratory blank levels. Also, formaldehyde emissions from

2-15Greenid g e Multi-Pollutant Control Pro j ect

100% coal-fired operation were indistingui shable from emissions during co-firing operation, both of which were nearly undetectable (Lindsey 2004). During the demonstration of the proposed project, form aldehyde emissions would be expected to remain very low.

2.1.7.2 Liquid Discharges The proposed project would not affect liq uid effluent at Green idge Station. The discharge of once-through, noncont act cooling water with both units operating at full load would continue to average 93,000 gpm. The c ooling 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 backwa sh 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 collec tion sumps collect water potentially comingled with oil. Oil is cap tured by oil-adsorbent cloth on the surface of the sumps and the water is discharged to C Pond. The oil-ad sorbent cloth is repl aced periodically and transported from the site by a licensed wast e management contractor to authorized facilities for disposal. Stormwater runoff from the lined coal pi le storage area is collected in the surge basin, conveyed periodically to the wastewater plant for tr eatment, 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 samp led 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 combus tion 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 a nd transported for disposal at the Ontario County municipal landfill in Flint, New Yor k, about 15 miles to the north-northwest of Greenidge Station, or at the Seneca Meadow s municipal landfill in Seneca Falls, New York, about 20 miles to the north east 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 a bout 8,700 tons per year of bottom ash and 59,000 tons per year of fly ash (the latter am ount includes water used to wet the ash for transport). During the demonstr ation 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 ad dition of Unit 4’s new, more efficient ESP or new baghouse, which would capture additiona l fly ash resulting from the injection of lime and powdered activated carbon. Currently, all bottom ash is sold to m unicipalities 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

2-16DOE / EA-1493; Au g ust 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 th e marketplace, the commercial application would reduce the amount of fly ash requiring di sposal at the landfill to less than 89,000
tons per year. Fly ash transported to the landfill is c onditioned with water to control dust and allow compaction. Ash is transported to the la ndfill site in covered trucks. Most of the short haul road is on AES property. The work ing 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 re quires 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 acco rding to local fire codes and Occupational Safety and Health Administration (OSHA) re quirements. Chlorine is used for water filtration, while the solvents are used prim arily in maintenance activities. Hazardous wastes generated during operation are removed from the site at regular intervals by a licensed waste management contractor and tr ansported to authorized facilities for disposal. All toxic and hazardous materials ar e 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 tr eated as hazardous waste and disposed of in properly licensed faciliti es. The plant has a Spill Prevention, Control, and Countermeasures Plan (SPCCP) (40 CFR Part 112) that addresses th e 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 requirement s for or generation of toxic and hazardous materials. Proper precautions would be ta ken during ammonia stor age and handling to

minimize the risk of an accidental release of ammonia. The ammonia would be stored in a cylindrical tank with secondary containmen t 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 woul d comply with Emergency Planning and Community Right-to-Know Act (EPCRA) no tification 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 establis hed the PPII with a specific goal— to demonstrate commercial-scale technologi es that improve the reliability and environmental performance of existing and ne w 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-polluta nt control system in achieving the goal for the program. Reasonable a lternatives to this proposed action must be capable of meeting this purpose.

2-17Greenid g e Multi-Pollutant Control Pro j ect

Congress also directed DOE to pursue the goals of the legislation by providing partial funding for projects owned and cont rolled by nonfederal-govern ment participants. This statutory requirement places DOE in a much more limited role than if the federal government were the owner and operator of th e 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 applic ant, the scope of alternatives is necessarily more restricted. It is appropriate in such cases for DOE to give substantial weight to the need s of the proposer in establishi ng 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 alternativ e to the proposed action is the no-action alternative, including four scenarios reasona bly 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 combina tion of technologies would probably not be demonstrated elsewher e. Consequently, commercialization of the integrated multi-pollutant control system c ould be delayed or might not occur because

utilities and industries tend to use known and demonstrat ed technologies over new, unproven technologies. At the site of the propos ed project, four reasonably foreseeable

scenarios could result. None of these scen arios would contribute to the PPII goal of demonstrating technologies at the commercial scale that improve the reliability and environmental performance of existing and ne w coal-fired power plants in the United

States. First, AES could shut down Greenidge St ation. Because the plan t is expected to be subject to more stringen t emissions standards, mothba lling or dismantling the plant would be one option availabl e to the owners rather th an installing expensive, commercially available emissions control equi pment to comply with upcoming standards. Under this scenario, no cons truction 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 pow er plant workers would lose their jobs. Resource requiremen ts 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 Green idge Station. While the exact location or locations are uncertain, the sites are likely to be at ex isting 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 de mand, electric utilities typically dispatch electricity according to opera ting cost, starting with the l east costly. The under-utilized plants would also tend to be older and genera te greater quantities of air emissions, liquid discharges, and solid wastes. Therefore, wh ile current environmental impacts would be

2-18DOE / EA-1493; Au g ust 2004

reduced at the Greenidge site, impacts would li kely increase at the site(s) where electrical generation would increase to compensa te 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. Electric ity would be generated at approximately the same rate. Resource requirements and discha rges 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 in crease 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 pollu tion 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 environm ental conditions at the site and the impacts would remain very similar to existing conditions. Third, AES could switch to using natura l gas rather than coal at Greenidge Station, while maintaining most of the curren t equipment such as th e boilers, turbines, ductwork, and chimneys. The need for some of th e 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. B ecause a new 14-mile natural gas pipeline

would need to be constructed to deliver th e fuel, construction activities would probably be at a slightly greater level than those associated with th e proposed project. Because of pipeline construction, disturbance beyond the Gr eenidge 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 w ould be more efficient than the existing plant due to a new gas-fired delivery system and other upgrades. Air emissions, particularly

SO 2 emissions, would be considerably less because a new gas-fired delivery system would burn more efficiently and cleanly than an aging coal-fired pow er plant with limited emissions controls. Ash generation would be re duced or eliminated at the power plant, depending on whether Unit 4 alone or both uni ts were switched. Current environmental conditions and impacts at the site would be expected to improve. Finally, AES could purchase emissions allowances (e.g., SO 2 , NO

x ) as a compliance strategy for future emissions stan dards. By purchasing emissions allowances, AES would be compensating another utilit y or utilities for overcomplying with the standards while allowing the region as a w hole to meet the limits for those emissions. Under this scenario, the exis ting power plant would continue to operate without change.

No construction activities w ould be undertaken, and existi ng operations would remain essentially the same. Electricity would be generated at the same rate. Resource requirements and discharges and wastes woul d be the same. There would be negligible change in current environmenta l conditions at the site and th e impacts would remain very similar to existing impacts. This scenario would not provide employ ment for construction

workers in the area.



### 2.2.2 Alternatives Dismissed from Further Consideration The following sections discuss alternativ es that were initially identified and considered by the project participant. Becau se DOE’s role is limited to providing the

2-19Greenid g e Multi-Pollutant Control Pro j ect

cost-shared funding for the selected project, DOE is limited to either accepting or rejecting the project as proposed by the part icipant, including the proposed technology and site. As such, reasonable alternatives to the proposed project are narrowed and the following alternatives have been di smissed from further consideration.

2.2.2.1 Alternative Sites CONSOL Energy initially considered addi tional sites during th eir site selection process. Site selection was governed primarily by benefits that coul d be realized by the companies participating in the project. An ex isting 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 environm ental impacts likely would be much greater than at an existing facility. The site select ed for the project had to provide the maximum benefit to the companies by closely meeting th e project’s technical needs and integrating with existing infrastructure. No other site s 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 r easonable alternatives and are not evaluated

in this EA.

2.2.2.2 Alternative Technologies Other technologies have been dismisse d 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. Ot her PPII projects were selected to demonstrate other coalbased technologies. The preselection review s included environmen tal comparisons of proposals. The projects selected for demonstra tion are not considered alternatives to each

other. The use of other technologies and appro aches which are not a pplicable to coal (e.g., natural gas, wind power, solar energy, a nd conservation) woul d 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. De laying the project woul d not result in any change of environmental impacts once the pr oject were implemented but would adversely delay reductions in air emissions from the ex isting power plant and adversely affect the PPII goal of demonstrating technologies at th e commercial scale for potential customers in the smaller boiler market. The design size for the proposed combination of technologies was selected because it is consid ered 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 app lied 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 potentia l customers that the integra tion of these systems is not only feasible but economica lly attractive (Section 1.3).

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### 3. EXISTING ENVIRONMENT

3.1 SITE DESCRIPTION, L AND USE, AND AE STHETICS
The proposed project would be located at Greenidge Stati on in Yates County, New York, along the western shore of Sen eca Lake (Figure 2.1.1). The equipment and surrounding access space for the proposed projec t would occupy a tota l of about 3 acres of land, which currently serves as a pave d 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 a nd 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% an d 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 industria l area (Greenidge Station) that is surrounded primarily by agri cultural and rural resi dential 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 va riety of purposes, incl uding manufacturing at the Ferro Electronic Materials plant (which em ploys about 200 workers), but is primarily agricultural with rural residences interspers ed with vineyards and wineries. The areas west and north of the Greenidge Station propert y 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 St ation property is conspicuously marked with industrial facilities such as the po werhouse, ESP equipment, smokestacks, coal storage piles, ash storage silos, railroad f acilities, 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 con tinent, while winds from the south and southwest transport warm, humid air from the Gulf of Mexico a nd adjacent subtropical waters. These two air masses provide the dominant characteristics of th e 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 monitori ng station, which is located about 7 miles to the west of Greenidge Sta tion). In January, the daily ma ximum 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 averag e of 11 days per year with temperatures

3-1Greenid g e Multi-Pollutant Control Pro j ect

above 90°F. In July, the daily maximum temper ature is 83°F, on average, while the daily minimum is 61°F. Annual precipitation (e xcluding 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. dur ing the summer months . As depicted in Figure 3.2.1, prevailing winds at Penn Yan ar e dominantly from the southwest quadrant

with few winds from the easterl y 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 ce nter of the diagram. Wind speeds are denoted by bar widths and shading; the frequency of wind speed with in 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 o pp osite 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 (SO 2 ), nitrogen dioxide (NO 2 ), ozone (O 3 ), carbon monoxide (CO), l ead (Pb), and particulate matter less than or equal to 10 μm in aer odynamic 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 O 3 to replace the 1-hour O 3 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 gene ral public has access [40 CFR Part 501(e)]. Primary NAAQS define levels of air quality that EPA deems necessary, with an adequate

3-2DOE/EA-1493; Au g ust 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-hour a 9 ppm (10 mg/m 3 ) No secondary standard CO

1-hour a 35 ppm (40 mg/m 3 ) No secondary standard

Pb Maximum quarterly

average 1.5 μ g/m 3 Same as primary standard

NO 2 Annual arithmetic

mean 0.053 ppm
(100 μ g/m 3 ) Same as primary standard

Maximum daily 1- hour average b 0.12 ppm (235 μ g/m 3 ) O 3

4 th highest 8-hour daily maximum c 0.08 ppm (157 μ g/m 3 ) Same as primary standard

Same as primary standard

Annual arithmetic

mean d 50 μ g/m 3 Same as primary standard PM-10

24-hour d 150 μ g/m 3 Same as primary standard

Annual arithmetic

mean e 15 μ g/m 3 Same as primary standard PM-2.5

98 th percentile

24-hour e 65 μ g/m 3 Same as primary standard

Annual arithmetic

mean 80 μ g/m 3 (0.03 ppm) SO 2

24-hour a 365 μ g/m 3 (0.14 ppm) 3-hour a 1300 μ g/m 3
(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 determin ed according to Appendix H of the Ozone NAAQS.

c The 8-hour standard is met when the 3-year average of the annual 4 th highest daily maximum 8-hour

O 3 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/m 3 (3-year average); the 24-hour sta ndard is attained when the expe cted number of days above 150 μg/m 3
is less than or equal to 1 per year.

e The annual PM-2.5 standard is met when the annual averag e of the quarterly mean PM-2.5 concentrations is less than or equal to 15 μg/m 3 , when averaged over 3 years. If spatial av eraging is used, the annual averages from all monitors within the area may be averag ed in the calculation of the 3-year mean. The 24-hour standard is met when the

98 th percentile value, averaged over 3 years, is less than or equal to 65 μg/m 3

.

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margin of safety, to protect human health. Secondary NAAQS are similarly designated to protect human welfare by safeguarding envir onmental resources (such as soils, water, plants, and animals) and manufactured mate rials. States may modify NAAQS to make them more stringent, or set standards fo r additional pollutants. New York has added additional standards for criteria pollu tants [e.g., 99% of 3-hour and 24-hour SO 2 concentrations shall not exceed 0.25 ppm (650 μg/m 3 ) and 0.10 ppm (261 μg/m 3 ), respectively.] New York has also set ambi ent air quality standa rds for non-methane hydrocarbons, fluorides, beryllium, and hydroge n 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, w ith the exception of ammonia (NH 3 ) (Section 2.1.7.1). Yates County, as well as adjoining Seneca County, is in atta inment 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. SO 2 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 al so located in Rochester. A PM-10 monitoring station is located in Niagar a Falls, about 120 mile s west-northwest of Dresden, and an NO 2 monitoring station is located in Buffalo, about 100 miles westnorthwest of Dresden. O 3 monitoring stations are locat ed in Rochester, Elmira, and Williamson, about 45 miles north-northwest of Dresden. In addition to ambient air quality st andards, which represent an upper bound on allowable pollutant concentrations, national ai r 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 a llowable concentrations of pollutants, while PSD requirements provide maximum allo wable increases in concentrations of pollutants for areas already in compliance w ith the NAAQS. PSD standards are therefore expressed as allowable increments in th e atmospheric concentrations of specific pollutants. Allowable PSD increments cu rrently exist for three pollutants (NO 2 , SO 2 , and PM-10). One set of allowable increments exis ts for Class II areas, which cover most of the United States, and a much more stringent se t of allowable increments exists for Class I areas, which include many national parks a nd 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 pollu tants 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 tim e of each pollutant in the atmosphere. In the ambient air, many of these pollutant s are present only in extremely small concentrations, requiring expensive state- of-the-art equipment for detection and measurement. Measurements of existing ambi ent 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,

3-4DOE/EA-1493; Au g ust 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/m 3 )

Pollutant Averaging period Class I a Class II a

Sulfur dioxide (SO 2 ) 3-hour

24-hour

Annual 25

5

2 512

91

20

Nitrogen dioxide (NO 2 ) 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 Fi nger Lakes in the Oswego River Basin of Central New York. The Finger Lakes were form ed by about 20 cycles of glacial advances and retreats (Schuyler County 2003). Seneca La ke 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 rais e the level to a maximum of 450.2 ft. The lake rarely freezes over; since 1912 ice cover has apparently occurred onl y 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 La ke 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 th e 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).

3-5Greenid g e Multi-Pollutant Control Pro j ect



### 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 sta ndards 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 concentra tions (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 wa ter is moderately hard, with total hardness concentrations of 140 – 150 mg/L (ppm CaCO 3 ). Dissolved oxygen concentrations are at or near saturation throughout the water co lumn during the entire year (SLAP-5 1999). Biological parameters indicate that Seneca Lake is borderline oligotrophic/mesotrophic. Very low nutrien t concentrations, es pecially phosphate, prevent algal blooms and associated green co loration observed in smaller lakes of the region and prevent dissolved oxygen deplet ion in the hypolimnion during the late summer (SLAP-5 1999).

3.3.2.2 Water Use Greenidge Station uses water for thr ee primary purposes: noncontact cooling, service water, and potable water. Units 3 and 4 use once-through cooling water for noncontact condensing of steam exhausted fr om the turbines. About 93,000 gpm of water are withdrawn for this purpose from Se neca Lake through two underwater intake structures, one for each unit (Section 2.1.6.2). Se rvice water for the entire plant (about 500 gpm) is also withdrawn from the inta ke 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 thr ough 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 discharg e to C pond (an unlined settling pond), which ultimately drains to Seneca Lake. C pond also re ceives 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 sedimenta tion pond where it is sampled and treated, if necessary. It is ultimately discharged thr ough an outfall point to the Keuka Lake Outlet. Discharge of these water sources through th eir outfall points is regulated under the facility’s State Pollutant Discharge Elimina tion 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 sma ller quantities than Greenidge Station (SLAP5 1999). These discharges are regulated through SPDES permits. Fifty-one SPDES permits allow large-scale discharge into su rface waters in the watershed; twenty-one allow discharge directly to Seneca Lake (S LAP-5 1999). The largest two users, Cargill

3-6DOE/EA-1493; Au g ust 2004

Salt Company and U.S. Salt Corporation (b oth 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 discharg es 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 temper ature 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 temper ature increase that month was 17°F. In November 2003 (a winter month) the maximu m 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 locate d in the glaciated Allegheny Plateau physiographic province. The station and th e 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 Pleist ocene Epoch had a major influence on regional topography. Glacial erosion deepened preglacial stream valleys into a semiparallel series of deep, narro w linear troughs that form the fi ord-like basins of the Finger Lakes. Upland bedrock surfaces are mantle d by varying thicknesses of glacial till (unsorted sediment deposited directly by glacier ice) and stratified glaci al 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 la rgest 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 a nd 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 t opographic relief, increase to th e south of the power station,

3-7Greenid g e Multi-Pollutant Control Pro j ect

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 s ite 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 pr oject 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 th e 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 be drock. This material is characterized as gravelly sandy clay silt to s ilty 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 (ex cavated from an adjoining area) on the ground surface to provide a minimum 5-ft thic kness of soil above the groundwater table. Glacial deposits are thicker on portions of th e 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 s ite of the proposed project. The local bedrock is not subject to dissolution or s ubsidence, and the glacial sediments on the power station and landfill prope rties 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 th e New York State Seismic Building Code proposed in 1993 by the New York State Earthquake Code Advisory Committee (Multidisciplinary Center fo r Earthquake Engineering Re search 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 accel eration of 0.09 g (that is, 9% of the acceleration of gravity) in a 50-year period. A more recent se t 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 natura l 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 ga s wells were in production in Yates County in 2001 and 2002. Production of natu ral gas in the stat e of New York has been declining since a peak year in the 1980s. Another economic use of geologic resources in the area is und erground storage of natural gas. One underground natural gas st orage 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. Howeve r, bedrock exposures are limited.

3-8DOE/EA-1493; Au g ust 2004



### 3.4.4 Groundwater Groundwater is an important resource in th e region. Over half of the population of Yates County relies on groundwater for drinki ng 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 a quifers in the area, but in many areas the only source of groundwater supp ly is the relatively low-permeability bedrock (Keuka Lake Foundation 1996), in which groundwater occurs and moves almost entirely in fractures (Merin 1992). Domes tic wells in the region typi cally 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 pr operty has not detected adve rse effects from station operations (Eileen Reynolds, AES, persona l communication to Ellen Smith, ORNL, May 25, 2004). Groundwater beneath the site discharges to Seneca Lake. Monitoring wells at the Lockwood La ndfill site allow observations of groundwater conditions, including water le vels and water quality, both up- and downgradient from the disposal area. Groundwater moves from southwest to northeast, mirroring the natural topography. Depth to gr oundwater in shallow wells is typically between 5 and 20 ft, with greater depths r ecorded on the downgrad ient 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 dispos al area and the Keuka Outlet stream (north and northwest of the site), where shallow groundwater moving north from the landfill area would discharge to th e surface water system. Groundwater quality at the Lockwood La ndfill is strongly influenced by the chemistry of the rock units in which wells are completed. The natural chemical characteristics of site groundwater, as obser ved in background mon itoring wells, typically include slightly alkaline pH (7.0 to 7.5) and very high hardness and alkalinity (both hardness and alkalinity are cons istently above 250 mg/L). Wate r with these attributes is generally suitable for use as drinking water, but its hardness and its characteristically high concentrations of iron (frequently exceedi ng 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 fo r 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 mon itoring of downgradient monitoring wells had not detected water quality changes attribut able to landfill contamination (Criss 2004). The clay-rich soil and bedrock at the landfill si te can be expected to have geochemical attributes that would help to retard th e transport of many dissolved contaminants.

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### 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 wetla nd area to the project site is about 1,200

ft to the northwest across the Keuka Lake Outle t. 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 occu rs 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 inla nd herbaceous wetland totaling about 1.5 acres

in size lies on the south bank of the ou tlet 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 woul d 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 comple te 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 ced ar. Isolated patches of forest occur in the area surrounding Greenidge Stati on, along with open fields, re sidential 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 severa l species of songbirds and shorebirds and mammals including white-tailed deer, beav er, groundhog, skunk, opossum, gray squirrel, Eastern coyote, red fox, muskrat, and cottont ail rabbit (SLAP-5 1999). Seneca Lake has a significant concentration of wi ntering waterfowl. Diving duc ks use the whole lake, and

mallard and American black ducks concen trate around Dresden station. Other species present include greater scaup, canvasbac k, redhead, common goldeneye, buffelhead, common merganser, and Canada goose. The closest wildlife mana gement area to the proposed project, the Willard Wildlife Manage ment Area, is located across Seneca Lake in the Town of Ovid, about 5 mile s east of Greenidge Station.

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### 3.6.2 Aquatic Ecology Seneca Lake supports a substantial fishery consisting predominantl y of lake trout, smallmouth bass, and yellow perch. Other spec ies such as rainbow trout, brown trout, landlocked-Atlantic salmon, northern pike, and largemouth bass add diversity to the fishery. In addition, alewives (sawbellies) a nd rainbow smelt provide a dependable forage base for trout and salmon (SLAP-5 1999). Th e 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 natura l reproduction. An important factor in a recent resurgence of the Seneca fishery is the Ne w York State Department of Environmental Conservation’s (NYSDEC’s) ongoing control of the invasive, parasitic sea lamprey. The control program involves appl ying a highly selective chemi cal 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 mu ssel, 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-wa ter habitat, filter-feeding on the plankton. Changes in lake water opacity, nutrient con centrations, and chlor ophyll-a concentrations from the early 1900s to 1998 suggest that zebra mussels have decreased the algal

concentrations in Seneca Lake and incr eased water clarity. Starting in 1998 and continuing through 1999 however, these trends reversed. The variab ility indicates the lack of complete understanding of the present extent and futu re impact of zebra mussels on the ecology of the lake a nd its fishery (SLAP-5 1999).



### 3.6.3 Threatened and Endangered Species
The FWS (FWS 2004b) lists 12 non-marine an imal and 6 plant species, which are either threatened or endangere d, that may occur in the state of New York. Of these only two species, Indiana bat (endangered) and Lee dy'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 know n to occur in the Seneca Lake watershed (SLAP-5 1999). Of the threatened and enda ngered 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 endange red, short-eared owl (Asio flammeus) could possibly occur in Yates County (NYSDEC 2003a; SLAP-5 1999). Because the proposed project site is alrea dy 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 with in an area of the United States that exhibits reasonably good biodiversity at the state and ecoregion scales. Numerous ecosystem types and plant, mammalian, and avia n species contribute significantly to the overall biodiversity. Based on (1 ) the variety of surviving ha bitats and (2) the number of species in the more visible classes of plan ts and animals observed in the environs, the area within a few miles of the proposed proj ect exhibits moderately high biodiversity. The proposed project site itself exhibits lit tle biodiversity because previous industrial

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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 reso urces 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 re sources 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 In gersoll 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 soci oeconomic resources most likely to be affected by the proposed project. Most of the data are for comm unities in Yates County, where the proposed project site is located, but some are fo r Ontario County and the city of Geneva because they would also experi ence socioeconomic impacts from the proposed project.



### 3.8.1 Population Table 3.8.1 contains populati on data for Yates County, Ontario County, and some of the local communities most likely to be a ffected by the proposed project. As indicated in Table 3.8.1, both Yates County and Ontari o County experienced moderate population growth (7.9% and 5.4%, respectively) be tween 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 wo rkers associated with construction of the proposed project would reside in the village of Penn Yan (popul ation 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 Count y, 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 Yate s County (6.4%) was higher than that in

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the United States (5.8%), but lower than that in the stat e 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), a nd 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 peopl e, the majority of whom reside in Penn Yan (85%) and Geneva (10%). Total em ployee payroll at Green idge 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%), pr obably due to the larg e number of tourist and vacation properties in the area. Pe nn 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 re ly on private wells for their water supply, residents of Penn Yan and Dresden re ceive their water from a water treatment facility located in Penn Yan. The Penn Yan wa ter treatment facility has a capacity of 1.77 MGD and currently operates at about 0.8 M GD (Steve Isaacs, Yates County Industrial Development Agency, personal communication to Bo Saulsbury, ORNL, February 11, 2004).

Penn Yan also has a wastewater treatme nt facility with a capacity of 1.8 MGD

and current use of about 1.0 MGD. For seve ral years, however, Penn Yan's wastewater treatment system has had a recurring problem with infiltration and/or infill, in which

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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

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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 thr ough 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 tr ying 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 per centages than the United States and the state of New York. Yates County's percentage be low 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 povert y level (16.0% and 15.2%, respectively) than

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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 Yate s County, between Seneca Lake and Penn Yan. The proposed project site at Gr eenidge 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 % Minority 1 % Below Poverty 2

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 leve l 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 pr oposed project (i.e., between State Highway 54 and County Route 36). This traffic volume represents a "V olume/Capacity Ratio" of 0.1 (i.e., the road segment is at 10% of capacity), and the leve l of service on Highway 14 near the proposed project site is "very good" (B ill Piatt, New York State De partment of Transportation Region 6, personal communication to Bo Sa ulsbury, ORNL, February 11, 2004). The New York State Department of Transportati on has no road construc tion activities planned for Highway 14 or for any other roads in Yates County (NYSDOT 2004). Access to the proposed project site fro m 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.

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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. Occas ionally, a train of 100 cars transports coal to the Dresden area, w ith 50 cars moved to Greenidge Station to remove the coal, while the remaining 50 cars ar e 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 backgr ound 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 va lues are normally adjust ed 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 ar ea on the west bank of Seneca Lake. The village of Dresden, where reside ntial dwellings line the shores of the lake, is located 1 mile northwest of the proposed project. There is no residential popula tion 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 harv esters) nearby passing trains, recreational activities, and other industrial activitie s. For example, sound levels may exceed 100 dB(A) within 50 ft of a train passing on one of the nearby railroa d tracks. Although the presence of Seneca Lake precludes stationa ry noise sources to the east of Greenidge Station, motorboats using the lake genera te 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-relate d complaints associated with Greenidge

Station have been identified. Past construction activities at Greenidge Station did not generate noise that triggered doc umented 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 (OSH A) (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 admi nister 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.

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### 4. ENVIRONMENTAL CONSEQUENCES

This section analyzes the potential impacts to human and environmental resources resulting from construction and demonstra tion 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 s ite, the proposed project woul d 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 i ndustrial 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 projectoperation 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 zoni ng. The in-migration of workers that would result from project construc tion would not be large enough to increase the amount of offsite land required for reside ntial 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 powerhous e, portions of the equipment would be visible from the west, includ ing 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 blen d into the existing industrial structures. From other viewpoints, including Seneca La ke, the proposed equipment would likely be obscured by the taller, existi ng power plant structures. Ex isting vegetation would also

contribute in some locations to the visual screening of the pr oposed equipment. In summary, because the visual landscape of th e Greenidge Station property is already conspicuously marked with industrial structur es (Section 3.1), the visual impacts of the facilities on the propert y 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.

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### 4.1.2 Atmospheric Reso urces and Air Quality This section evaluates potential impacts to atmospheric resources that may result from construction or operation of the propos ed project. Section 4.1.2.1 discusses effects of construction, including fugitive dust a ssociated with earthwork and excavation. Section 4.1.2.2 discusses operational effects, pa rticularly 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 atmo spheric concentrations of NO

x , CO, SO 2 , VOCs, and particulate matter would result from exhaus t emissions of workers’ vehicles, heavy construction vehicles, diesel generators, a nd other machinery and tools. Construction vehicles and machinery would be equipped w ith standard pollution-control devices to

minimize emissions. These emissions would be very small compared to regulatory thresholds typically used to determine whet her further air quality impact analysis is necessary [40 CFR Part 93.153(b)]. Fugitive dust would result from excava tion and earthwork. The proposed project

would use a total of about 3 acr es of previously disturbed la nd, primarily for the new ESP or baghouse and surrounding access space. Limite d 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 th an 10 μm in aerodynamic diameter (PM-10)

would be localized because of the small c onstruction 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 wa ter 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 ge nerally be beneficial because, with the exception of ammonia (NH 3 ), plantwide air emissions would decrease or continue at the same level (Section 2.1.7.1). SO 2 emissions would decrease from 19,450 tons per year currently to 6,683 tons per year. NO

x 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, resp ectively (Section 2.1.7.1). CO and volatile organic compound (VOC) emissions woul d also be expected to remain at their current level (i.e., 92 and 18 tons per year, re spectively). Plantwide Hg emissions would decrease from about 36 lb per year currently to about 22 lb per year. NH 3 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, re spectively. As discussed in Section 2.1.7.1,

annual CO 2 emissions would probably not change s ubstantially from th e current level of 1,300,000 tons.

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The existing 250-ft stack that serves Un it 3 and 227-ft stack that serves Unit 4 would continue to be used (the stack tops ar e 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 st ack 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 existi ng 46 miles per hour to 31 miles per hour. Consequently, the decreased exit temperatur e and exit velocity during the demonstration would decrease the plume rise from the Un it 4 stack, which could result in increased downwind ground-level concentratio ns 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 mo re detailed models are recorded at Penn Yan, which is located about 7 miles to the west of Greenidge St ation (Section 3.2.1), and

because the SCREEN3 results are conserva tive (forming an upper bound) using a full range of potential meteorological conditions. Be cause the height of the Unit 4 stack is approximately 2.5 times the height of th e 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, locatio ns 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 applie d 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 adjusti ng the 2002 base year emissions (Table 2.1.1) by the 80% capacity f actor (i.e., dividing by 0.8), a reasonable assumption given that Unit 4 is usually at pe ak 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 con centrations were predicted to be 2 μg/m 3 for a 24-hour averaging period and 0.4 μg/m 3 for an annual averaging period. The maximum

increases in PM-2.5 concentratio ns were predicted to be 1 μg/m 3 for a 24-hour averaging period and 0.2 μg/m 3 for an annual averaging period. Th ese increases were predicted to

occur about 1.5 miles to the sout h of Greenidge Station in elev ated 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 so uth) is likely to be low, as indicated by the Penn Yan wind rose (Figure 3.2.1). The maximum increases in predic ted 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 signif icance of the increases. As i ndicated in Table 4.1.1, the sum

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Table 4.1.1. Ambient air quality standards impa ct analysis for the proposed project

Pollutant Averaging period NAAQS a (μg/m 3 ) Maximum

modeled

increase (μg/m 3 ) Ambient background

concentration b
(μg/m 3 ) Total impact c (μg/m 3 ) 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). Th e 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 De terioration (PSD) impact analysis for the proposed project

Pollutant Averaging period PSD Class II

increment a

(μg/m 3 ) Maximum

modeled

increase (μg/m 3 ) Percentage of

PSD Class II

increment

PM-10 b 24-hour

Annual 30

17 2

0.4 7

2

a PSD increments are standards established in accordan ce 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/m 3 ) added to the 24-hour background concentration of 42 μg/m 3 in 2003 at the nearest monitoring station in Niagara Falls (Secti on 3.2.2) yields a total of 44 μg/m 3 , which is 29% of the corresponding NAAQS of 150 μg/m 3 . The sum of the maximum increase in modeled annual PM-10 concentration (0.4 μg/m 3 ) added to the annual background concentration of

19 μg/m 3 at Niagara Falls yi elds a total of 19.4 μg/m 3 , which is 39% of the corresponding NAAQS of 50 μg/m 3 . Similarly for PM-2.5, the sum of the maximum increase in modeled 24-hour PM-2.5 concentration (1 μg/m 3 ) added to the 24-hour background concentration

of 36 μg/m 3 in 2003 at the nearest monitoring stati on in Rochester (Section 3.2.2) yields a

total of 37 μg/m 3 , which is 57% of the corresponding NAAQS of 65 μg/m 3 . Finally, the

sum of the maximum increase in mode led annual PM-2.5 co ncentration (0.2 μg/m 3 ) added to the annual background concentration of 11.8 μg/m 3 at Rochester yields a total of

12 μg/m 3 , which is 80% of th e corresponding NAAQS of 15 μg/m 3 . 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

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nearest air monitoring stati ons are distant from Greeni dge Station (Section 3.2.2) in locations likely to have higher ambient partic ulate 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 incr eases 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/m 3 ) is 7% of the corre sponding increment of

30 μg/m 3 . The maximum increase in modele d annual PM-10 concentration (0.4 μg/m 3 ) is 2% of the correspond ing increment of 17 μg/m 3 . No modeling was performed at Lye Brook Wilderness Area (the nearest PSD Class I area a bout 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 NH 3 concentration. Because NH 3 emissions would increase from near zero rather than remaining the same (as was assumed for part iculate 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 terra in at an elevation about 50 ft below the stack top elevation. The fre quency of winds from the nor th-northeast (which would transport emissions to the south-southwest) is likely to be lo w (Figure 3.2.1). The

maximum NH 3 concentration was predicted to be 0.02 μg/m 3 for a 1-hour averaging period. By comparison, t he National Institute for Occ upational Safety and Health ( NIOSH) Recommended Exposure Limit (REL) for ammonia is 25 ppm (17,400 μg/m 3 ). RELs are time-weighted average (TWA) con centrations for up to a 10-hour work day during a 40-hour work week. The maximum pr edicted concentration is a negligible

fraction of the REL. No air dispersion modeling was pe rformed for other pollutants. SO 2 and NO

x 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 th at the decreased plume height would increase downwind concentrations by a maxi mum factor of 2.5, emissions reductions of at least 60% (resulting in Un it 4 emissions during the demonstration of no more than 40% or original emissions) would result in no increase in con centrations at any downwind location (40% oof 2.5 equals 1). Conseque ntly, a net improvement in air quality

associated with SO 2 and NO

x concentrations would result. SO 3 emissions are expected to decrease by the same percentage as SO 2 emissions, with similar air quality improvement.

The 95% reduction in Unit 4 emissions of HC l 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 ma ximum 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 demonstr ation, these pollutants were not evaluated

further. Because CO 2 is stable in the atmosphere and essentially uniformly mixed throughout the troposphere and stratosphere, CO 2 impacts resulting from no change in emission levels at Greenidge Stat ion would also remain unchanged.

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At times in the past, concerns have been raised about fugitive dust blown offsite from the Lockwood Landfill. The proposed proj ect would not affect the frequency or severity of this type of occurrence, but pla nned 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. Da igler & Associates 2003).



### 4.1.3 Surface Water Resources

4.1.3.1 Construction Construction activities for the proposed pr oject 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. B ecause the area was previously graded and paved and currently serves as a parking lo t, it is ecologically highly disturbed. The construction area does not encomp ass any existing body of water. Construction of the proposed project woul d generate small amounts of both solid and liquid wastes including solvents, paints, coatings, adhesives, and empty containers. Existing facilities for containment and treatm ent 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, standa rd engineering practices for the prevention or minimization of runoff, erosion, and sediment ation from the construction site to offsite surface waters would be employed. The New Yo rk State Department of Environmental Conservation’s (NYSDEC’s) regulations and guidelines governing c onstruction activities would be followed. Prompt containment and clean-up of accidental spills of harmful

materials would be conducted in accordance wi th an appropriate spi ll prevention, control, and countermeasure plan and best management practices plan. Thus, project construction is not likely to have appreciable a dverse effects on area surface waters.

4.1.3.2 Operation The proposed project would not affect the qua lity 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 circulati ng dry scrubber rather than being returned to the lake. This additi onal water is slightly less than 20% of the plant’s current consumptive use, and represen ts only about 0.1% of Greenidge Station’s total water use (Section 2.1.6.2). Thus, advers e impacts on water qual ity 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 th e storage tank for the SCR system would be prevented from reaching surface water by sec ondary containment. Wastewater effluents

must be treated to meet the standards se t forth in the State Pollutant Discharge Elimination System (SPDES) permit before be ing 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.

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Due to a reduction in air em issions (Section 2.1.7.1) of SO 2 , NO

x , HCl, and HF (which are associated with acid deposition) and Hg (which adversely affects humans and biota), the proposed project would have a sli ght 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. On ly 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 mo dest due to the modest size of the new facilities. No agricu ltural 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 prev ious 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 C onstruction Activity (NYSDEC 2003c)

. The lime required for operation of the pr oposed 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, a nd the project also would not use groundwater as a water source for project constructi on 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 becau se the waste would be placed in an engineered landfill that is lined and equi pped 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 downgr adient 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 contam inant 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).

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4.1.4.3 Geological Hazards Because only minimal geologic hazards ar e associated with the proposed project site (Section 3.4.2), geologic conditions woul d 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. Ther efore, neither constr uction nor operation of the proposed project would have adverse im pacts 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 ad jacent 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 woul d 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 loca ted in an area that is highly disturbed and completely industrialized (p redominantly 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 NH 3 injection into flue gas to control NO

x emissions, NH 3 emissions

would increase from near zero to abou t 280 lb per year (Section 2.1.7.1). This NH 3 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 applica tion (Penn State 2002). Any fertilization effect from the NH 3 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 NH 3 fertilizer per acre we re applied once per year to the 10,414 acres of vineyards in the Finger Lakes Region (Uncork New York 2004),

then the NH 3 emissions from the proposed project would represent on ly about 0.14% of the total from vineyards, not consideri ng other agricultural uses in the area. Operation of the proposed project would re duce 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.

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4.1.6.2 Aquatic Ecology Because appropriate engineering practices for (1) preventing or minimizing runoff, erosion, and sedimentation from the pr oject 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 Ke uka 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 aff ected by the project’s NH 3 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 le vels in sediments and water.

4.1.6.3 Threatened and Endangered Species

Federal- and state-listed threatened an d 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 propos ed project on threatened and endangered species would likely be margina lly beneficial as a result of expected reductions in Hg,

NO

x , SO 2 , HCl, HF, and particulate emissions. In compliance with Section 7 of th e Endangered Species Act of 1973, as amended, DOE requested consultation with th e U.S. Fish and Wildlife Service (FWS) regarding potential impacts of the proposed project on threat ened and endangered species (Appendix A). The FWS response indicated that, except for occasional transient individuals, no federal-listed sp ecies or critical ha bitat for such species are known to exist in the project impact area, and that no fu rther Endangered Species Act coordination or consultation with FWS is required (Appendix A).

4.1.6.4 Biodiversity Given adequate collection and treatm ent of runoff during construction and operation of the proposed project, neither of these activities woul d adversely affect biodiversity of the surrounding ecosystems. Both local and fa r-field biologi cal diversity might realize a net beneficial, but probably im measurable, effect as a result of expected reductions in Hg, NO

x , SO 2 , HCl, HF, and particulate emissions.



### 4.1.7 Waste Management

4.1.7.1 Construction Construction of the proposed project w ould generate solid wastes in types and amounts typical of construction projects. Wast es would include pack aging from materials transported to the site, scrap materials, me tals 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 wast e would be sold as scrap. Some dismantled building material would probably be used on th e 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 landf illed waste would be very small in comparison with the capacity of the 387-acr e Ontario County landfill, which is permitted

4-9Greenid g e Multi-Pollutant Control Pro j ect

to accept 624,000 tons [approximately e quivalent to 624,000 cubic yards (yd 3 )] per year of municipal solid waste and has a pote ntial total capacity of over 21 million yd 3 (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 cu rrent 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 in crease would result almost entirely from (1) the use of lime in the CDS system and (2 ) the enhanced captur e of fine particles (including calcium sulfate and calcium sulfite formed from SO 2 reacting with the calcium in lime). The enhanced capture would occur be cause the CDS agglomerates fine particles

into coarser material that w ould be collected in a new E SP or baghouse. Minor increases

in volume would result from the activated ca rbon 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 operati on would have somewhat different characteristics than the fly ash currently ge nerated by Greenidge Sta tion. The facility's current fly ash is a mixture consisting prim arily of mineral ash and a small amount of unburned carbon that is captured with the fl y ash. Fly ash from the proposed project would include these same constituents, w ith 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 co nstituents of coal (such as Hg) incorporated in the ash and to verify that the material is not a ha zardous waste as defined under the Resource Conservation and Recovery Act (RCRA).

Beneficial reuse of some or all of th e 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 Stat ion 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 mixi ng it with treated sewa ge 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 pu rpose. 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 as h would be commingled with fly ash from Unit 3 and other solid wastes generated in minor quantities at Gr eenidge Station. The

143-acre Lockwood Landfill site has been used fo r disposal of Greenidge Station fly ash and related wastes since 1979. In 2003, the si te was calculated to have a potential

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remaining waste disposal capacity of 3.3 million yd 3 (J.A. Daigler & Associates 2003). This calculation forms an upper bound for rema ining 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 el evation), NYSDEC approval of fu ture disposal designs, and continued renewal of the facility's 5-year pe rmits. By using this calculation with current waste generation rates and assuming a waste density of one ton per yd 3 , an estimate is

derived that the site could accommodate Green idge Station wastes through 2057. If all of the waste from the proposed project were landf illed, 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 as h from the proposed project until well beyond the 12-month demonstration period of performa nce testing and monito ring (see Section 5 regarding landfill sufficiency over the period of commercial operation). Landfill disposal of ash has the potentia l 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 syst em within lined portions of the landfill and to groundwater underdrains below unlined por tions. These drains discharge by gravity flow to the adjacent sedimentation pond, whic h 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 contam inants (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 as certained that the water quality meets the requirements of the SPDES discharge permit. If permit requirements were not met, water

could be treated before bei ng discharged. Monitoring data from a discharge event in 2003 (Table 4.1.3) show that the quality of the wa ter in the pond easily met all of the permit requirements. Changes in the composition of the Unit 4 fly as h due to the proposed project could affect the chemistry of Lockwood Landfill leachate a nd thus of discharges to Keuka Lake Outlet. Monitoring of Lockwood Landfill le achate done as part of the landfill groundwater monitoring program found elevated levels of several c onstituents (Table 4.1.4). Total dissolved solids in the leachat e were much higher than in background groundwater (Section 3.4.4). The principal dissolv ed ions in the leachate were calcium, magnesium, and sulfate. Other dissolved substa nces 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 samp les were similar to the groundwater with neutral to slightly alkaline pH, but one sa mple 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 concen trations of calcium

and sulfate. These substances are not likel y to settle out in th e 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 dissipate d by dilution in the stream and in Seneca Lake. Increased removal of Hg in plant em issions would lead to increased Hg concentrations in Greenidge Station fly as h. Research on leaching of Hg from fly ash indicates that there should be negligible effects on Hg levels in Lockwood Landfill

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Table 4.1.3. State Pollutant Discharge Eliminat ion 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

event b

F low (gallons/day) 250,000 c 178,571

A luminum (total; mg/L) 2.4 <0.05

C admium (total; mg/L) 0.11 <0.005

C opper (total; mg/L) 1.0 <0.01

I ron (total; mg/L) 4.0 0.1

Z inc (total; mg/L) 2.0 <0.01

M ercury (total; mg/L) 0.0008 d <0.0002

M anganese (total; mg/L) 3.0 0.02

T otal suspended solids (mg/L) 50 <4

A rsenic (total; mg/L) 0.1 <0.02

S elenium (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) Discha rge Permit Number NY-1007069, AES Gree nidge, L.L.C.: Lockwood Disposal Facility, Modification Date June 7, 1999.
b AES Greenidge, “AES Eastern Energy NPDES/SPDES Discharge Monitoring Repor ts,” Eileen Reynolds, December 16, 2003. Total volume of discharge, which occurr ed 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 meas ured in Keuka Lake Outlet at

Dresden is less than 27 ft 3 /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 th ree 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 ge nerated with the Toxicity Characteristic Leaching Procedure (TCLP), which is pres cribed 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 (S GLP), which is more representative of conditions in most coal ash landfills, ra nged from undetectable (less than 0.00001 mg/L) up to 0.00005 mg/L. All reported Hg concentr ations were well below potentially applicable criteria, including the primary drinking water standard of 0.002 mg/L, water quality criteria for protection of aquatic lif e (0.0014 mg/L for acute exposure and 0.00077

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Table 4.1.4. Selected data from monitoring of leachate collection drains at

Lockwood Landfill during 2002

Parameter Highest level reported during 2002 a

T otal dissolved solids (mg/L) 3330

A lkalinity (mg/L) 493

H ardness (mg/L) 1687

A luminum (total; mg/L) 7.1

B oron (total; mg/L) 20.5

C alcium (total; mg/L) 519

I ron (total; mg/L) 79

M anganese (total; mg/L) 2.2

M agnesium (total; mg/L) 105

S elenium (total; mg/L) 0.2

S ulfate (mg/L) 2280

pH (pH units) 5.9 to 8.3 b

a Data included in Criss 2004.

b Range of values reported.

mg/L for chronic exposure; EPA 2002), and the threshold for identify ing a material as a hazardous waste (0.200 mg/L). Only one ash so urce in the study produced extracts with detectable Hg concentrations. That ash had total Hg concentrati ons 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 ex tract concentrations

indicate release of somewhere between one-f ive-hundredth and one-four teenth of the Hg in the ash. If treated effluents containing si milar 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 sli ghtly alkaline pH of

natural waters at the Lockwood La ndfill 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 e xpected to include final covering of old unlined waste areas, thus reducing potential fu ture 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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Operation of the proposed project’s SCR system could result in generation of a hazardous waste. Catalysts used in the SCR pr ocess lose their reactivity over time and would need to be replaced or regenerated afte r about 3 years. No catalyst replacement or regeneration is expected during the 12-month demonstr ation 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 proce dures would be employed for the proposed project (Section 2.1.7.4).



### 4.1.8 Cultural Resources In compliance with Section 106 of the Na tional Historic Pres ervation Act of 1966, as amended, DOE requested a consultation with New York's State Hi storic Preservation Officer (SHPO) regarding a determination of the potential for impacts associated with the proposed project on any historic resources that may be liste d 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 disturbe d 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 propos ed project would be most noticeable during the 12-month construction period, especi ally when the peak construction work force (100 to 150 workers) would be on th e 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 jo bs 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 proj ect participants and constr uction 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 i ndirect 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 th e 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 indir ect 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 pr oject area (100 to 150 direct jobs plus 100 to 150 indirect jobs). The following subsect ions discuss the pote ntial socioeconomic impacts of the proposed project, particularly t hose associated with this direct and indirect employment.

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4.1.9.1 Population

The construction work force would be expected to come from outside the immediate project area and would either comm ute 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 temporaril y in hotels or motels. Although it is not likely that many

of the construction workers w ould 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 mo re reasonable to exp ect that none of the workers staying temporarily in hotels or motels would be accompanied by family, and that only 40% of the work ers relocating permanently (4 to 6 workers) would be accompanied by family. Assuming that 4 to 6 workers would reloca te 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 specia lized than the direct construc tion 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 reloca te to the project area during the construction period. Combining the population growth that woul d 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 worker s 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 discus sed 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 pe riod would represent less than

2.5% of the total labor for ce in Yates County in 2000. Alt hough the direct jobs would go to workers from outside the immediate project ar ea, 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 Stat ion during demonstration of the proposed project, no new employment would be associ ated 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 empl oyment would likely be lost following completion of project construction.

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Because the construction work force w ould come from outside the immediate project area, construction wages would not have a larg e effect on total or per capita income in Yates County. However, the wage s paid to existing area residents through indirect jobs created during the constructi on 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 hous eholds (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 s eason could be a larger issue than that of housing the construction worker s 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, restaura nts, and other local bu sinesses that rely on tourism could be adversely affected if touris ts 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 im pact 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 projec t area temporarily in hotels and motels or permanently as new residents, there would be additional de mand for water and wastewater services. As discussed in Section 3.8.4, the Penn Yan wate r treatment facility has excess capacity of 0.97 MGD. This excess capacity would be mo re than enough to meet the additional

demand for water associated with th e peak construction work force.

The Penn Yan wastewater treatment f acility has excess capacity of 0.8 MGD (Section 3.8.4), which also would be more th an enough to meet the additional wastewater needs associated with the peak construction work force. However, the need to provide

additional wastewater services for the cons truction workers could slightly exacerbate existing problems with the Penn Yan wastewat er 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 proj ect would not add to the as sessed 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 sa les tax rate of 4.25%, Yates County and Ontario County have local sales tax ra tes of 4.0% and 3.0%, respectively (NYSDTF 2004). Therefore, local purchases of mate rials for project construction and local purchases of goods and services by constructi on 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 wo rkers during the peak construction period), and limited pe riod of construction (Section 2.1.4).

4.1.9.6 Environmental Justice As discussed in Section 3.8.6, the percentage s of residents classi fied as "minority" in Yates County (3.2%) and Census Tract 9901 (4.4%) are much lower than the minority percentages of the United Stat es (30.9%) and the state of New York (38.0%). Therefore, the impacts of constructing and operating the proposed project woul d 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 pe rcentage 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 C ounty, 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 ove rall 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 Lampma n Road from State Highway 14. For this assessment, most of the construction worker s 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 worker s (CONSOL 2004b). Thus, as an upper bound, about 150 additional vehicles trips (75 roundt rips to and from the site) would be generated each day by th e 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 th at would result from construction workers driving to and from the projec t site each day would repres ent 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 tr affic on Highway 14 and with delivery trucks using Highway 14 and Lampman Road to acces s 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

4-17Greenid g e Multi-Pollutant Control Pro j ect

traffic congestion. Traffic flow and safety on Highway 14 a nd Lampman Road could also be affected by additional truck trips to and from the proj ect site during constr uction. 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 ti mes) would be appropria te 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 mu ch 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 propos ed 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 privat e roads, the increase would not affect local highway users.

Rail Rail shipments to Greenidge Station would not increase during project construction because all construction equipm ent and materials would be delivered by truck (CONSOL 2004a). As discussed in S ection 2.1.6.3, rail shipments during project demonstration would increase annually by abou t 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 thres hold 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 thre shold 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

4-18DOE/EA-1493; Au g ust 2004

areas. Day-night average sound le vel is defined as the 24 hour average sound level, in dB(A), obtained after the addi tion of 10 dB(A) to sound levels in the night from 10 p.m. to 7 a.m. Maintaining relatively continuous noi se below this level also protects against hearing loss, although less stri ngent requirements are typicall y 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., vehicu lar traffic, lawn mowers, work activities, and recrea tional activities); consequen tly, noise at around 50 dB(A) becomes more noticeable and can be annoyi ng. Therefore, 45 dB(A) is the level for potential activity interference and annoyan ce during the nighttime hours specified above. During construction of the proposed project, the principal sources of noise would be from construction equipment and mate rial handling. The amount and type of construction equipment would vary dependi ng on the specific construction activity occurring at that time. Construction activity would primarily occur w ithin 3 acres of the 153 acres occupied by Greenidge Station. The pr oposed project area is currently confined by the power plant building, th e ramp from the upper parkin g lot, the short railroad bridge connecting the upper pa rking lot and the power plant building and the access road to the upper parking lot. The upper parking lo t, 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 re located and the buildi ng 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 E SP 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 ca rbon storage silo, ammonia (NH 3 ) storage tank system], and ancillary equipment would be er ected on this land. The main construction, staging and fabrication areas w ould be expected to be locate d between existing structures and not located in proximity to sensitive noise receptors. During construction, employees and cont ractors would be responsible for ensuring that exhaust mufflers and engine en closures are in place and in good working order for all industrial trucks and other pie ces of construction-re lated equipment. An

exhaust muffler is a device that deadens th e noise of escaping ga ses or vapors through which the exhaust gases of an internal -combustion engine are passed. An engine enclosure silences low frequency noise radiat ed from the engine. Exhaust mufflers and engine enclosures are commonly used, a nd are commercially available from many different manufacturers. All construction eq uipment 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 car bon storage and injection system, and the electrostatic precipitator. Specifically, sound sources would include a water pump, hydrator feed system, air blowers, mechanical electrostatic precipita tor rappers, two large booster fans, and various control valves. Th ese sound sources would be enclosed and acoustically insulated. Noise sources within the buildings would be fitted with soundattenuating enclosures or other noise dampen ing measures that would meet all state and federal regulations and AES’ noise standard s. 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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There is no residential popul ation within a quarter mile of the proposed project (Section 3.9.2). Due to planned noise attenuation measures, na tural and man-made terrain features, and distance to the nearest residences , no perceptible change in noise associated with the proposed project would be expecte d. Therefore, the propos ed 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 member s of the scientific community and the public have expressed concer n regarding human health effects from electromagnetic fields (EMF) during the transmission of el ectrical current from power plants. Despite efforts by the scientific community and re search 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 us es electricity and is exposed to EMFs; therefore, a continued emphasis on educat ing 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 pe rceptible changes to existing EMF levels would occur. Consequently, EMF-related health effects, if presen t, 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 Constructi on Industry Standards (29 CFR Part 1926). During construction and operation of the propos ed 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 establis h practices, chemical and physical exposure limits, and equipment specifications to preserve employee health and safety. Construction activities would comp ly with OSHA Construction Industry Standards (29 CFR Part 1926). Construction pe rmits and safety inspections would be employed in an effort to minimize the freque ncy of accidents and further ensure worker safety. Construction equipment would be required to meet all applicable safety design and inspection requirements, and personal pr otective equipment would meet regulatory

and consensus standards. Potential health impacts to workers du ring construction of the proposed project

would be limited to normal hazards asso ciated with construction (i.e., no unusual situations would be anticipated that woul d make the proposed c onstruction activities more hazardous than normal for a major industr ial construction project). Most accidents in the construction industry result from overe xertion, falls, or being struck by equipment

4-20DOE/EA-1493; Au g ust 2004

(NSC 2003). Construction-related illnesses would also be possible (e.g., exposure to chemical substances from spills). Following construction of the proposed proj ect, the total number of permanent employees needed to operate the faciliti es would not change (Section 2.1.4). To maximize worker safety, operations would be managed from a control room. All

instruments and controls woul d be designed to ensure safe start-up, operation, and shut down. The control system would also mon itor operating parameters and perform reporting functions. Control stations would be placed at remote locations at which operator attention would be required. Therefore, the overa ll 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 ma intain occupational safety at Greenidge Station. No substantial differences with resp ect to occupational safety or industrial hygiene would be expected between current ope rations and those of the proposed project. Thus, the occupational safety and health experi ence 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, vis itors, and the community. These procedures would include job procedures describing prope r and safe manners of working within the facilities, appropriate personal protective equipment (PPE) and hearing conservation protection devices (e.g., handling/storage of NH 3 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 i nvestigation 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, supplementa l provisions would be added to the plant’s Contingency Plan for Hazardous Waste, Spil l Prevention Control and Countermeasures Plan, Hazard Substances Response Procedur es, and Air Pollution Emergency Episode

Plan. Potential health impacts to the public from the proposed project would include fugitive dust emissions typical of constr uction sites (Section 4.1.2.1) and operational combustion emissions from the proposed pr oject (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 atta inment of air quality sta ndards 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 m easures 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 emissi ons. Specifically, the project would integrate a si ngle-bed selective catalytic reduction (SCR) system for NO

x control and a circulating dry scrubber (CDS) for SO 2 , Hg, HCl, HF, and SO 3 control.

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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 constr uction 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, o il and grease, and hazardous substances in accordance with an appropriate spill, pr evention, control, and countermeasure plan and best management practices plan.

Waste disposal Investigate opportunities to reduce wast e 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 degr adation of SCR catalyst, thus reducing the frequency of replacement or regeneration.

Noise Ensure that all construction equipm ent (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 w ith 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 imp acts for most resource areas would be less than for the proposed project. Resource requi rements and discharges and wastes would

cease. Because current environmental conditions at the site would tend to revert back to conditions prior to plant opera tion, existing impacts would be reduced. However, adverse socioeconomic impacts would be experienced because no construc tion activities would be undertaken, no employment would be provided for construction workers in the area (except for some limited activity associated with mothballing or di smantling the plant), and power plant workers would lose their jobs . In addition, at othe r power plants where electrical generation would increase to comp ensate 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 quantitie s 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 app lied, consistent with NYSDEC permitting requirements. The multilayer final cover would consist of a low-permeability synthetic membrane layer overlain by a permeable geosyn thetic drainage layer and a protective soil layer at least 2 ft thick. Vegetation would be established over the c over. Site maintenance and monitoring would continue during a 30- year post-closure period. Landfill runoff and

leachate would continue to be collected and di scharged periodically to Keuka Outlet, as discussed in Section 4.1.7.2, until NYSDEC dete rmined that the leachate no longer posed

a threat to human health or the environmen t (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-ac tion alternative, in which AES would install commercially available pollution contro ls to comply with current and future emissions standards, operations would remain essentially the same as for the existing plant. Resource requirements a nd discharges and wastes woul d generally be the same as under current conditions, except that air emi ssions 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 s cenario would be similar in scale to those of the proposed project. With the exception of improving ai r quality, there would be minimal change in current environmental c onditions 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 c onstruction associated with a new 14-mile natural gas pipeline to deliver the fuel. Be neficial socioeconomic effects would likely result because construction activities would pr obably be at a slightly greater level than those associated with the pr oposed project. However, th e potential cumulative impacts associated with the proposed project (i.e ., availability and cost of tourist lodging facilities, effectiveness of wast ewater 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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because of the type of fuel and because the converted facility would be more efficient than the existing plant due to a new gas-fire d delivery system and other upgrades. Air emissions, particularly SO 2 emissions, would be consider ably less than under current conditions because a new gas-fired delivery system would burn more efficiently and cleanly than an aging coal-fired power pl ant with limited emissions controls. As a beneficial impact, ash generation would be re duced or eliminated at the power plant, depending on whether Unit 4 alone or both uni ts 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., SO 2 , NO

x ), the existing power plant woul d continue operating under current conditions. Resource requirements and discha rges and wastes would be the same. Negligible change in current environmental conditions would be expe rienced 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., availa bility and cost of tourist lodging facilities, effectiveness of wastewater treatment services, and flow and safety of traffic on State Hi ghway 14) would not be experi enced. The proposed project’s potential benefits of reducing SO 2 , NO

x , HCl, HF, SO 3 , and Hg air emissions would not be realized. Consequently, th e potential benefits of redu ced air emissions to surface waters, wetlands, and ecological re sources would not be realized.

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### 5. IMPACTS OF COMMERCIAL OPERATION

At the end of the 12-month demonstrat ion period of performance testing and monitoring, two scenarios are reasonably fo reseeable: (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 car bon injection, or the SCR system. Under the first scenario, the level of short-term impacts during commercial operation would not change from those desc ribed for the demonstr ation in Section 4 because the proposed project would continue as a baseload power plant operating 24 hours per day with the same operating characte ristics. For long-term effects, the level of impacts would be nearly identical to thos e 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 th at the landfill could accommodate Greenidge Station wastes (including all of the wast e from the proposed project) through 2040. Even with less optimistic assumptions about landfill ca pacity, 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 commercia l operation of the proposed project, it may be possible to regenerate the sp ent catalyst in situ, or it coul d 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 (V 2 O 5 ), is classified as an acutely hazardous waste when discarded and is restricted from land disposal under both NYSDEC and federal regulations. Any spent cata lyst discarded as a waste would need to be physically stabilized with cement or a sim ilar material prior to disposal in a licensed hazardous waste landfill (40 CFR 268).

Hazardous waste landfills ar e 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 facilit y 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. Ho wever, licensed landfills in other parts of the country are estimated to have sufficien t capacity for the volum e of waste currently being landfilled at the Niagara County site (NYSDEC 2003d). Re sidues from catalyst regeneration might need to be managed as hazardous waste, bu t quantities would be

smaller than if the entire cat alyst volume were disposed. Impacts associated with operations unde r the second scenario (an unsuccessful demonstration followed by operation of Unit 4 at the same power level using the ESP or

______________________________________________________________________________________ 5-1Greenidge Multi-Pollutant Control Project

baghouse without the CDS, lime or carbon in jection, 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 s econd scenario would revert back to the characteristics of the fly ash currently ge nerated by Greenidge Station. Air emissions would revert back to approach those unde r 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.

______________________________________________________________________________________ 5-2DOE/EA-1493; August 2004



### 6. CUMULATIVE EFFECTS

This section discusses pote ntial impacts resulting from other facilities, operations, and activities that in combination with poten tial impacts from the proposed project may contribute to cumulative impacts. Cumulativ e impacts are impacts on the environment that result from the incremental impact of th e proposed project when added to other past, present, and reasonably foreseea ble future actions regardless of the agency (federal or non-federal) or person that undertakes su ch other actions (40 CFR Part 1508.7). An inherent part of the cumulative effects analys is is the uncertainty surrounding actions that have not yet been fully developed. The Council on Environmental Quality (CEQ) regulations provide for the in clusion 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 anal ysis cannot be performed if the information is lacking. Consequently, the analysis contai ned in this section includes what could be reasonably anticipated to occur given the unc ertainty created by the lack of detailed investigations to support all cau se and effect linkages that may result from the proposed project, and the indirect e ffects 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 ag gregating all of the actions occurring in and around the proposed facility and attempting to form some conclusions regarding the eff ects of the many unrelated actions. Narrowing the scope of the analysis to resources that would be exp ected 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 extrane ous background data; and to emphasize real

environmental issues and alte rnatives” [40 CFR Part 1500.2(b)]. Each resource analyzed has its own spatial (geogra phic) boundary, although the te mporal boundaries (time frame) can generally be assumed to equal the lif e expectancy of the proposed project. The proposed project would reduce SO 2 , NO

x , HCl, HF, SO 3 , 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 SO 2 , NO

x , HCl, HF, and SO 3 , (which are associated with acid deposition) and Hg (which adversely affects humans and biota), the proposed pr oject 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 ha ve slight socioeconomic impacts, and could contribute to cumulative impacts on th e area's socioeconomic resources. The most noticeable of these cumulative impacts woul d 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. Ho wever, 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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Because negligible or no impacts from the proposed project would be experienced by remaining resources, no cumulative impact s 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 Green idge Station in the same time frame as the proposed project. The New York State Depa rtment of Transportation has no ongoing or planned road construction activ ities for State Highway 14 or for any other roads in Yates County (Bill Piatt, New York State Depart ment of Transportation Region 6, personal communication to Bo Saulsbury, ORNL, February 11, 2004). The only ongoing or potential project known to the Yates Count y Industrial Development Agency is the possibility of an additional tourist lodging f acility (Steve Isaacs, Yates County Industrial Development Agency, personal communica tion to Bo Saulsbury, ORNL, March 10, 2004).

______________________________________________________________________________________ 6-2DOE/EA-1493; Au g ust 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 Sp ecies 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 existe nce 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 Hist oric 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 Qua lity 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 C ontrol. 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 r ecord keeping requirements, and compliance plans for emission sources. Th is Title requires th at 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 c onditions, including monitoring and analysis, inspections, cer tification, 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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Section 316—Thermal Discharg es. 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 (Nati onal Standards of Performance) can demonstrate that an effluent limitation is “. . . more stringent than necessary to assure the protection and propagation of a balanced, indigenous populat ion 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 perm itting of water in take structures and requires that “Any standard esta blished pursuant to Section 301 or Section 306 of this Act and applicable to a point source sha ll require that the location, design, construction, and capacity of cooling water intake structures reflect best technology av ailable for minimizing adverse environmental impact.”

— Title IV—Permits and Licenses Section 402, National Pollutant Discharge Elimination System (NPDES). This section regulates th e discharge of pollutants to surface waters. Regulations implementing the NPDES program are found in 40 CFR

Part 122. Section 404, Permits for Dredge d or Fill Material . This section regulates the discharge of dredged or fill material in the jurisdictional

wetlands and waters of the United Stat es. 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 Preven tion. This regulation requires the preparation of a Spill Prevention, Co ntrol, 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 Manageme nt, directs federal agencies to establish procedures to ensure that they c onsider potential effect s of flood hazards and floodplain management for any action undertak en. 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 CF R Part 1022 establishes procedures for compliance with these Executive Orders. Wh ere no practical alte rnatives exist to development in floodplain and wetlands, DOE is required to prepare a floodplain and wetlands assessment discussing the eff ects on the floodplain and wetlands, and consideration of alternatives. In addition, these regulations require DOE to design or modify its actions to minimize potential dama ge 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).

7-2DOE/EA-1493; Au g ust 2004

The floodplain and wetlands effects anticip ated 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—E xisting Environment), Section 4.1.5.1 (Floodplains— Environmental Conseque nces), 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 samp les 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 Coopera tion,” requires any federal agency authorizing, funding, or carry ing out any action to ensu re that the action is not likely to jeopardize th e continued existence of any endangered species or threatened species or result in the de struction or adverse modification of critical habitat of such species. Cons equently, the U.S. Fish and Wildlife

Service will conduct a consu ltation, 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 lis ted by the Service and any critical habitat of such species in th e vicinity of the project.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION • OSHA General Industry St andards (29 CFR Part 1910) • Authority: Secs. 4, 6, 8, Occupational Safe ty and Health Act of 1970 (29 U.S.C. 653, 655, 657); Secretary of Labor's Or der 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 Yo rk State Department of

Environmental Conservation

7-3Greeni dg e Multi-Pollutant Control Pro j ect

• State Pollutant Discharge Elimin ation System Permit 8-5736-00004/00001, New York State Department of Environmental Conservation

• Facilities used for disposal of solid wa ste must be licensed by the New York State Department of Environmental Conserva tion. 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.

7-4DOE/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, th e resources would be neither renewable nor

recoverable for future use. Resources that would be irreversib ly or irretrievably committed by construction and demonstration of the proposed project include

construction materials that could not be r ecovered 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, gaso line, and iron ore used to produce steel. Resources used during the demonstration w ould 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 commit ment of human and financial resources that could threaten or jeopardize the use of these resources for al ternative projects or federal activities. However, the commitment is consistent with the purpose and need for the proposed project (Section 1).

8-1DOE/EA-1493; August 2004



### 9. THE RELATIONSHIP BETWEE N 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 th e fly ash were sold). Except for NH 3 emissions, air

emissions would be unaffected or reduced. The long-term benefit of the proposed project would be to demonstrate environmentally sound and innovati ve technologies for the utilization of coal. The project would integrate a single-bed selective catalytic reduction (S CR) system for NO

x control and a circulating dry scrubber (CDS) for SO 2 , Hg, HCl, HF, and SO 3 control. By reducing SO 3 emissions, the CDS would also minimi ze visible emissions from the stack. This pollution control system is particular ly 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 demons tration include both improved costcompetitiveness with current technologies (particularly for SO 2 , NO

x , and Hg control on smaller coal-fired units) and greatly reduced Hg, SO 3 , and fine particulate emissions compared to conventional technologies. Th e following emissions targets have been established for the integrated technologies compared with uncontrolled emissions: a 95%

reduction in emissions of SO 2 , SO 3 , HCl, and HF, a 60% to 90% reduction in Hg emissions, NO

x emissions of less than 0.122 lb/MMB tu, and no visible emissions from

the stack. The design size for the proposed project was selected to es tablish performance

results at a scale that would convince uti lities that the integr ated technologies, once demonstrated at this scale, could be comm ercialized using similar sized or larger applications without further scale-up to ve rify operational or economic performance. Therefore, although the propos ed project would consume resources and generate effluents and solid wastes, the project woul d demonstrate integrat ed 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 2003b. AES Eastern Energy NPDES/ SPDES Discharge Monitoring Reports , Eileen M. Reynolds, December 16.

AES Greenidge. 2004. Payroll and tax payment information provided to members of the

Environmental Assessment team duri ng the project site visit. January.

Bailey, R.G. 1995. Description of the Ecoregions of the United States. Accompanying 1:7,500,000 Map: Ecoregions of the United States (1994). U.S. Dept. Agriculture, U.S. Forest Service. Misc. Pub. No. 1391. Washington, D.C.

Callinan, Clifford W. 2001. Water Quality St udy of the Finger Lakes. New York State Department of Environmental Cons ervation, Division of Water, July.

Casella Waste Systems, Inc. 2003. “Casella Waste Systems, Inc. Announces Fiscal 2004 Second Quarter Results.” Casella Waste Sy stems, Inc., Rutland, VT. December 3. http://www.forrelease.com/D20031203/new032.P1.12032003162129.27425.html

CONSOL. 2002. Environmental Information Volume for Greenidge Multi-Pollutant Control Project . Prepared for the U.S. Department of Energy National Energy Technology Laboratory by Shiaw Tseng, CONSOL Energy, Inc. Research & Development Department. June.

CONSOL. 2004a. Response to Request for Additional Information . Letter from Roy Scandrol, CONSOL Energy, to Robert L. Miller, Oak Ridge National Laboratory. February 17.

CONSOL. 2004b. Carpooling at the CONSOL Project. E-mail from Bill Rady, CONSOL Energy, to Robert L. Miller, Oak Ridge National Laboratory. March 12.

Criss, Stan. 2004. Report from Fagan Engineer s for the Lockwood Ash Disposal Landfill, Town of Torrey, New York. February 9.

DARME (Cornell University Department of Agricultural, Resource, and Managerial Economics). 1996. Policy Issues In Rural Land Use--Economic Multipliers and the New York State Economy . Volume 9, Number 2. December.

Division of Mineral Resources, New York State Department of Environmental Conservation, 2004. http://www.dec.stat e.ny.us/website/dmn/oilgas.html and http://www.dec.state.ny.us/website/dmn /geograph.htm. Accessed February 20.

10-1Greenid g e Multi-Pollutant Control Pro j ect

EPA (U.S. Environmental Protection Agency) 1974. Information on Levels of Environmental Noise Requisite to Prot ect Public Health and Welfare with an Adequate Margin of Safety, EPA-550/9-74-004, Washington, D.C.

EPA (U.S. Environmental Protection Agency) 1992. Screening Procedures for Estimating the Air Quality Impact of Stationary Sources, Revised

, EPA_454/R_92_019, Office of Air and Radia tion, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., October.

EPA (U.S. Environmental Protection Agency) 1995. SCREEN3 Model User's Guide

, EPA_454/B_95_004, Research Triangle Park, N.C.

EPA (Environmental Protection Agency) 2002. National Recommended Water Quality

Criteria: 2002 , United States Office of Water, EPA-822-R-02-047.

EPA (US Environmental Protection Agency) 2004 . Website of Office of Water, Office of Wastewater Management, URL: http://cfpub.epa.gov/npdes/sto rmwater/endangerprint.cfm

EPA (Environmental Protection Agency). U ndated. National Bienni al RCRA Hazardous Waste Report: Based on 2001 Data. http://www.epa.gov/epaoswer/hazw aste/data/brs01/national.pdf

FEMA (Federal Emergency Management Ag ency) 1987. Flood Insurance Rate Map for Town of Torry, New York, Map Number 3609660005B, Effective Date December 3, 1987. (Obtained from website http://store.msc.fema.gov/webapp/wcs/stor es/servlet/CategoryDisplay?storeId=10 001&catalogId=10001&langId =1&categoryId=12001&parent_category_rn=1200 1&type=CAT_MAPPANEL&stateId= 13039&countyId=14880&communityId=3 50916&stateName=NEW+YORK&countyN ame=YATES+COUNTY&communit yName=TORRY%2CTOWN+OF&dfirm_kit_id=&dfirmCatId=12009&isCounty

Selected=&isCommSelected=&userT ype=G&urlName=&HashKey=&MemberK ey=&mandatoryKey=&cat_state=13039& cat_county=14880&cat_community=35

0916 )

FWS (US Fish & Wild life Service) 2004a. U.S. Fish & Wildlife Service National Wetlands Inventory , Latitude 42 degrees 40 minutes 49 seconds, Longitude 76 degrees 57 minutes 16 degrees, URL: http://wetlands2.nwi.fws.gov/sites/nwi/viewer.htm?Title

FWS (US Fish & Wild life Service) 2004b. U.S. Fish & Wildlife Se rvice Threatened and Endangered Species System (TESS), Lis tings by State and Territory as of

02/20/2004 , New York, URL: http://ecos.fws.gov/tess_public/ TESSWebpageUsaLists?state=NY

10-2DOE/EA-1493; Au g ust 2004

Goodfriend, L.S. and Associates 1971. Noise From Industrial Plants, U.S. Environmental Protection Agency, Office of Noise Abatement and Control, NTID300.2, Washington, D.C.

J.A. Daigler & Associates. 2003. Lockwood As h Landfill Fill Progression Plan, prepared for AES Greenidge, L.L.C. Seneca Falls, NY. October.

Keuka Lake Foundation, Inc., Watershed Pr oject Committee. 1996. Keuka Lake Looking Ahead: A Community Listens to the La ke. Keuka Lake Association, Penn Yan, New York, September 1996. http://www.keukalakeassoc.org/pdf/

Lindsey, Christopher. 2004. "Dunkirk Steam St ation: Co-firing Emission Test," In Proceedings, Electric Power 2004 , AP Session 5-4 - Advanced Technologies Applied to Conventional Systems, Baltimore, Maryland. April.

Maier, Herwig, and Spokoyny, Felix. 2000. “S uccessful Experience with In-situ Regeneration of SCR Catalyst in Coal Fired Applications.” In: Proceedings: 2000 Conference on Selective Catalytic - Sele ctive Non-Catalytic Reduction for NOx Control. Pittsburgh, PA, May 17-18, 2000. National Energy Technology Laboratory. http://www.netl.doe.gov/publications/proceedings/00/scr00/SPOKOYNY.PDF

Merin, Ira S. 1992. Conceptual Model of Gr ound Water Flow in Fractured Siltstone Based on Analysis of Rock Cores, Bo rehole Geophysics, and Thin Sections. Groundwater Monitoring Review, 12:4, 118-125.

Multidisciplinary Center for Earthquake Engineering Research. 2004. Seismic Zoning Map for New York State Seismic Building Code. Buffalo, New York. http://mceer.buffalo.edu/infoService/faqs/nysszmap.asp

NIEHS (National Institute of E nvironmental Health Sciences) 1999. NIEHS Report on Health Effects from Exposure to Powe r-Line Frequency Electric and Magnetic Fields, National Institutes of Health, NI H Publication No. 99-4493, Research Triangle Park, N.C.

NPS (National Park Service). 2004. National Register Informati on System: Index by State and County . Accessed at http://www.nr.nps.gov.

NRC (Nuclear Regulat ory Commission). 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants . May.

NRC (National Research Council) 1997. Possible Health Effects of Exposure to Residential Electric and Magnetic Fields, National Academy Press, Washington, D.C.

NSC (National Safety Council) 2003. Injury Facts, 2003 Edition, Itasca, Ill.

10-3Greenid g e Multi-Pollutant Control Pro j ect

NYSDEC (New York State Department of Environmental Conservation) 2003a. List of Endangered, Threatened and Special Concer n Fish & Wildlife Species of New

York State , last modified October 10, URL: http://www.dec.state.ny.us/website/d fwmr/wildlife/endspec/etsclist.html

NYSDEC (New York State Department of Environmental Conservation) 2003b. Botany Program , last modified July 23, URL: http://www.dec.state.ny.us/website/dfwmr/heritage/plants.htm

NYSDEC (New York State Department of Environmental Conservation). 2003c. State Pollutant Discharge Elimination System (SPDES) General Permit for Stormwater Discharges from Construction Activity. Albany, NY. January 8. http://www.dec.state.ny.us /website/dow/gen_constr.pdf

NYSDEC (New York State Department of Environmental Conservation). 2003d. Draft Hazardous Waste Facility Siting Plan. http://www.dec.state.ny.us/websi te/dshm/hzwstman/hazsiteplan.htm

NYSDOT. 2004. Planned Road Construction Activities--By County . Accessed at http://www.dot.state.ny. us/roads/rc6.html.

NYSDTF (New York State Department of Taxation and Finance). 2004. New York State Sales and Use Tax Rates by Jurisdiction . Publication 718, effective March 1,

2004. Accessed at http://www.tax.state.ny.us/pdf /publications/Sales/pub718_304.pdf.

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10-4DOE/EA-1493; Au g ust 2004

Senior, C., C. J. Bustard, K. Baldrey, T. Starns, and M. Durham 2003. “Characterization of Fly Ash from Full-Scale Demonstrati on of Sorbent Injection for Mercury Control on Coal-Fired Power Plants,” presented at the 28 th International

Technical Conference on Coal Utilizati on and Fuel Systems, Clearwater, Fla.,

March 10–13.

SLAP-5 (Seneca Lake Area Partners in Five Counties) 1999. Setting a Course for Seneca Lake, the State of the Se neca Lake Watershed – 1999, URL: http://www.gflrpc.org/Seneca%20Lake/Watershed%20Report/WatershedState.htm

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Winkley, Steven. 2001. Using a GIS to Identify Areas at Risk of Nitrate Ground Water Contamination. Aquafacts Magazine, Spring 2001. New York Rural Water Association, Claverack, New York. Accessed at http://www.nyruralwater.org/aquafacts/spring2001/3.shtml

YCIDA (Yates County Industrial Development Agency). 2003. Yates County Major Employers Listing . October.

YCIDA. 2004. Summary of Budget--All Funds . Provided by Steve Isa acs, Director, Yates County Industrial Development Agency. January.

10-5DOE/EA-1493; August 2004



### 11. LIST OF AGENCIES A ND INDIVIDUAL S 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