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3rr 5- P J

Office ofEnergy Projects

February 2003

Docket Nos. CPO2-379-000outhern LNG, Inc.CPO2-380-000

Elba IslandExpansion Project

Environmental Assessment

Washington, DC 20426

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FEDERAL ENERGY REGULA TORY COMMISSION

WASHINGTON, D. C. 20426

In Reply Refer To:O E P D E E W G a s1Southern LNG, Inc.Docket Nos. CPO2-379-000

and CPO2-380-000

TO THE PA RTY ADDRESSED:

The staff of the Federal Energy Regulatory Com mission (FERC or Com mission)has prepared an environmental assessment(EA) on the liquefied natural gas (LN G)facilities proposed by Southern LNG , Inc. (Southern LNG ) in the above-referen ceddocket.

The E A was prepared to satisfy the requirements of the National EnvironmentalPolicy Act. The staff concludes that approval of the proposed project, with appropriatemitigating measures, w ould not co nstitute a major Federal action significantly affectin gthe quality of the human environment.

The EA assesses the potential environmental effects of the proposed project whichincludes expansion of the existing Elba Island LN G import terminal in Chatham County,

Georgia. Southern LN G proposes to:

construct an L NG unloading slip cut into Elba Island withtwo shipunloading docks;constructa 1,000,000-barrel double walled L NG storage tank;construct two boil-off gas com pressors;construct two first-stage (booster) LNG pumps;construct a reco ndenser vessel;construct three secon d-stage LN G pum ps;construct three subm erged com bustion vaporizers; and

construct a motor control center.

Th e proposed facilities would expand the storage and sendout capacity of SouthernLN G's existing LN G import terminal in Chatham County, Georgia. The proposal would:1) expand the storage capacityof the terminal; and2 increase the su stainable dailysendout capability to806 million standard cubic feet per day (M Mscf/d) and its peakingcapacity to 1,2 15 MM scf/d. Southern LNG seeks import authorization in Docke t No.CPO2-379-000.

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The EA has been placedin the public files of the FERC. A limited number ofcopies of the EA are available for distribution and public inspection at:

Federal Energy Reg ulatory Com mission

Public Reference and Files Maintenance Branch888 First Street, N.E., Room 2A

Washington, DC 20426(202) 502-8371

Co pies of the EA have been m ailed to Federal, state and local agencies, publicinterest groups, interested individuals, new spap ers, and parties to this proceeding.

Any person wishing to comm ent on the EA may doso. To ensure considerationprior to a C omm ission decision on the proposal, it is important that we receive your

comm ents before the date specified below.Please carefully follow these instructions toensure that your co mm ents are received in time and prop erly recorded:

e Send an original andtwo copies of your com ments to:

SecretaryFederal Energy Regulatory Comm ission888 First St., N.E., Room 1AWashington, DC 20426;

Label one copyof the com ments for the attention of Ga s Branch 1, PJ11.1.

Refe rence Docket No. CPO2-380-000; and

Mail your comments so that they will be received in W ashington,DCon or before March 7,2003.

Please note that we are continuing to experience delays in mail deliveries from theU.S. Postal Service. As a result, we w ill include all comm ents that we receive within a

reasonable tim e f ram e in our environm ental analysis of this project.How ever, theCom mission stro ngly encourages electronic filing of any com ments or interventionsor protests to this proceeding. See 18 CF R 38 5.2001(a)(l)(iii) and the instructions onthe Com mission's web site ath t td /www.fe rc .gov under the e-Filing'' link and the link tothe User's Guide. Befo re you can file comm ents you will need to create a free accountwhich can be created by clicking on Login to File and then New User Account.

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http://httd/www.ferc.govhttp://httd/www.ferc.gov

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Commentswill be considered by the Com mission butwill not serve to make thecomm entor a party to the proceeding. Any person seeking to become a party to theproce eding must file a motion to intervene pursuant to Rule2 14 of the C omm ission'sRu les of Practice and Proced ures (18 CFR 385.214).

see k rehearing of the Com mission's decision.

On ly intervenors have the right to

Affected landow ners and parties with environmental concerns may be grantedintervenor status upon show ing good cause by stating that they have a clear and directinterest in this proceed ing which would not be adequately represented by any otherparties. You do not need intervenor status to have your comm ents considered.

Additional informa tion about the project is available from the Com mission'sOffice of External Affairs, at1-866-208-FERC or on the FER C Internet website(ww w.ferc .gov) using the FER RIS link. Click on the FERR IS link, enter the docket

num ber excluding the last three digits in the Docket Num ber field. Be sure you hav eselected an appropriate date range. For assistance with FER RIS, the FERR IS helplinecan be reached at 1-86 6-208-3676,TTY (202) 502-8659 or [email protected]. The FER RIS link on the FERC Internetwebsite also provides access to the texts of formal docum ents issued by the Co mm ission,such as orders, notices, and rulemakings.

Ma galie R. Salas

Secretary

'Interventions m ay also be filed electronically via the Internet in lieu of paper. Seethe previous discussion on filing com men ts electronically.

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mailto:[email protected]:[email protected]

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ELBA ISLAND EXPANSION PROJECTENVJRONMENTAL ASSESSMENT

TABLE OF CONTENTS

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . 1-1 1.1 PURPOSE ANDNEED. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 1.2 PUBLIC REVIEW ND COMMENT.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

2.0 DESCRIPTION OF THE PROPOSED ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.12.1 EXISTING FACILITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.2 PROPOSED FACILITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.3 NONJURISDICTIONAL FACILITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2.4 LANDREQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2.5 CONSTRUCTION. OPERATION.AND MAINTENANCE.................... 2-5 2.6 FUTUREPLANS AND ABANDONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8 2.7 PERMITS. APPROVALS. CONSULTATIONS.ND REGULATORY

REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

3.0 ENVIRONMENTAL ANALYSIS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.1.1 Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3.1.2 Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3

3.2 WATER RESOURCES, WETLANDS.AND FISHERIES ..................... 3-4 3.2.1 Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 3.2.2 Surface Water Resources. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6 3.2.3 Wetlands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8 3.2.4 Fisheries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9

3.3.1 Vegetation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12 3.3.2 Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-13

3.4.1 Federally-Listed Species. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-14 3.4.2 State-Listed Species. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-15

3.5.1 LandUse . . . . . . . . . . .. . . . . . . . . . . . .. . . . . . . . . . . .. . . . . . . . . . . .. . . . . 3-16 3.5.2 Existing Residences and Planned Residential Development. . . . . . . . . . . . . 3-17 3.5.3 Recreation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17 3.5.4 Coastal Zone Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18 3.5.5 Visual Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18

3.6.1 Population and Construction Schedule.............................. 3-19 3.6.2 Employment and Income. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19 3.6.3 Fiscal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20 3.6.4 Housing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

3.1 GEOLOGYAND SOILS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -1

3.3 VEGETATION AND WILDLIFE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12

3.4 ENDANGEREDAND THREATENED SPECIES........................... 3-14

3.5 LANDUSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16

3.6 SOCIOECONOMICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

3.6.5 Schools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-21

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LIST OF ACRONYMSAND ABBREVIATIONS(Continued)

MMscf/dmPhMSFCMA

MwNAAQSNFPANGANHPANMFSNOAANO1

NO,NPDESNRHPNSANWI

W R

N W SOEPOPSPeeplesPlanPMPM,o

PPmPPtProceduresPSDQuestRecommissioningProjectRNASBISecretarySHPOso2Southern LNGSPCC PlanSRWSWPPPt YTmlUSGSvocWPC

million standard cubic feet per daymiles per hourMagnuson-Stevens Fishery Conservation and Management Act

magnitudeNational Ambient Air Quality StandardsNational Fire Protection AssociationNatural Gas ActNational Historic Preservation ActNational Marine Fisheries ServiceNational Oceanic and Atmospheric AdministrationNotice of Intent to PreDare an Environmental Assessment for the ProDosed ElbaIsland Expansion Proiect. Reauest for Comments on Environmental Issues. andNotice of Public ScoDing Meeting Terminationnitrogen oxidesNational Pollutant Discharge Elimination SystemNational Register of Historic Placesnoise sensitive areaNational Wetland InventoryNational Wildlife RefugeNational Weather ServiceOffice of Energy ProjectsOffice of Pipeline SafetyPeeples Industries, Inc.Upland Erosion Control, Revegetation and Maintenance Planparticulate matterparticulate matter less than10 microns

parts per millionparts per trillionWetland and Waterbody Construction Proceduresprevention of significant deteriorationQuest Consultants, Inc.Elba Island Recommissioning Project

Regulated Navigation AreaSouthern Bulk IndustriesSecretaryof the CommissionGeorgia State Historic Preservation Officesulfur dioxideSouthern LNG, Inc.Spill Prevention, Containment, and Control PlanSavannah River WharfStormwater Pollution Prevention Plantons per yeartidal marsh, saltyU.S. Geological Surveyvolatile organic compoundWright Padgett Christopher Engineering& Construction Services

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1.0 INTRODUCTION

The staffof the Federal Energy Regulatory Comm ission (FERC or Commission) preparedthis Environmental Assessment (EA) to assess the environmental effects of a proposal bySouthern LNG, Inc. (Southern LNG) to expand the facilities at its existing liquefied natural gas(LNG ) terminal on Elba Island in Chatham County, Georgia. The proposed Elba IslandExpansion Project would: increase sustainable sendout from 446 to 806 m illion standard cubicfeet per day (MM scUd), and maximum sendoutfrom 675 to 1,2 15 MMscUd; increase storagecapacity by adding a 1,000,000 barrel LNG storage tank; and add a new m arine slip with twoberths.

On May 3 1,20 02 Southem LNG filedan application in Docket No. CPO2-380-0000seeking approval under Section 7(c) of the Natural Gas Act (NGA), and Parts 153 and 157 of theCom mission's regulation for a Certificate of Public Convenience and Necessity (Certificate) toconstruct and operate certain new facilities. Southern LNG also seeks authorization to provide

additional LNG tanker unloading se rvices under Part284

of the C omm ission's regulations.Inaddition, in DocketNo. CPO2-379-000, Southern LNG requests authorization under Section 3 ofthe NGA and Subpart Bof Part 153 of the C omm ission's regulations for the importation of LNG.This application is directly related to Southern LN Gs proposal described above in Docket No.CPO2-380-000.

The original application for the construction and operation of the existing terminal wasfiled in 1972 with the Federal Power Commission (FPC), predecessor to the FERC , in DocketNo. CP71-264. Southern LNG received authorization in 1972 and began construction in 1973.Southern LNG commenced operation in 1978 and received LNG shipm ents until 1980. From1980to 1982, Southern LNG provided peak shaving service with the remaining inventoryof

LNG. Between 1982 and 2000, the terminal operated on standby while Southern LNG searchedor new LN G supplies.

On July 13, 1999, Southem LNG filed an application with the Commission in DocketNo.CP99-580-000 to recomm ission the Elba Island Terminal. This project was referred toas heElba Island Terminal Recomm issioning Project (Recomm issioning Project) and involvedeturning the S outhern LNG's existing, certificated Elba Island Terminal to active service. FERCtaff preparedan EA for the Recom missioning Project. The EA was issued on January 10,20 00.

On March 16,200 0, the Com mission issued an Order Issuing Certificate. Section 3Authorization, and Denvinn Request for Rehearing. The March 16,200 0 Order authorizedSouthern LNGto recommission the Elba Island Terminal.

On A ugust 15,20 00, Southern LNG filed an application with the Commission in DocketNo. C P99-580-002 to amend the authorizations issued in the Comm ission's March 16,200 0Order. Southern LNG proposed limited modifications to the sendout system at the Elba IslandTerminal. This project, referred to as the Sendout Modification Project, involved increasing the

eak vaporization from 540 to 675 MMscUd. This would allow Southern LNG to increase the

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throughput capacity of the LNG Terminal without increasing the LNG storage capacity. FERCstaff prepared an EA for the Sendout Modifications Project. The EA w as issued on April 17,2001. On July 16 ,2001 , the Comm ission issued an Order Amending Certificate and AuthorizingAbandonm ent, allowing Southern LNG to increase its sendout capacity.

On D ecember 1,200 1, Southern LNG placed the Recomm issioning and SendoutModifications Projects in service.

1.1 PURPOSE AND NEED

Southern LNG proposes to expand its existing LNG terminal on Elba Island, Georgia tomeet growing demand for importation of LNG and delivery to domestic markets. By creatingaccess to new LNG imports, the project promotes the public interest in d iversifylng energysupplies, meeting unserved demand, and using clean-burning natural gas to generate electricity.

In 2002, Southern LNG received several shipments with the frequency of unloadingincreasing toward a base load of 65 ships by the end of the year, when long-term supplies fromthe Trinidad export expansion become available. On September 10,2001, Southern LNGannounced an open season to determine market interest in contracting for firm, long-termcapacity at its Elba Island LNG Terminal. Southern LNG awarded all the proposed capacity toShell NA LNG, Inc. for a 30-year term starting on the in-service date of the expansion.

This EA w ill analyze Southern LN G s facilities in Docket No. CPO2-380-000. OnNovember 20 ,2002 , the Commission issued a Preliminarv Determination on Non-EnvironmentalIssues which found Southern LN G s proposal to be in the public convenience and necessity.

1.2 PUBLIC REVIEW AND COMMENT

On September 12 ,2002 , the Comm ission issued a Notice of Intent to PreDare anEnvironmental Assessment for the Proposed E lba Island Expansion Proiect. Reauest forCom ments on Environmental Issues, and Notice of Public ScoDing Meeting(NOI). The mailinglist included approx imately 208 individuals and organizations consisting of Federal, state, andlocal agenc ies; state and local elected officials; local libraries; newspapers; and surroundinglandowners of the Elba Island LNG Terminal site or within one half mile of the site. The NO1was also published in the Federal Register.

In the NOI, the Commission requested written comments from interested parties onenvironm ental issues and concerns to be addressed in the EA and announced a public scopingmeetingto be held in Savannah , Georgia on October 1,2002. The public meeting was held toprovide interested parties an opportun ity to learn more about the proposed project and tocomm ent on environm ental issues to be addressed in the EA. Issues and concerns raised by the

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public in response to the notices for the project, presented during the scoping meeting, orindependently identified byus' are addressedin the EA.

One concern raised by Georgians for Clean Energy was related to what action FERC istaking to ensure that the Southeast region has sustainable energy supplies for the future-specifically energy efficiency and conservation (demand side measures) and renewable energytechnologies that are more water conserving anddo not increase air pollution. The comm entsrelated to this issue focused on electric generation in Georgia and its coastal areas. TheCom mission has long recognized that attaining the expected benefits from competitive wholesalemarke ts relies on the existence of some measure of demand response . Simply put, markets donot h c t i o n unless there is an elastic demand curve. While most of the necessary rate design andother issues necessary for effective demand response on the electric side lies within statejurisdiction, the Comm ission has m ade special efforts to accommodate demand response.How ever, more work needs to be done with the states and their jurisdiction to m ake demandresponse a reality.

1 We, us, and our refer to the environmental staff of the O fficeof Energy Projects(OEP),part of the Commission Staff.

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2.0 DESCRIPTION OF THE PROPOSED ACTION

2.1 EXISTING FACILITIES

The E lba Island LN G Term inal, site of the proposed project, is located in ChathamCounty, Georgia, approximately 7 m iles upstream of the rivers discharge into the Atlantic Oceanand approx imately 5 miles downstream of the City of Savannah, Georgia. The existing terminalencom passes approximately140 acres and is locatedon the south side of the shipping channelinto thePort of Savannah.

As discussed in section1 O the existing terminal was originally authorized in 1972 andcomm enced construction in 1973. The 140-acre existing site includes the following facilities:

an LNG ship unloading facility with four LNG unloadingarms and one vaporreturn line, mooring and breasting dolphins, fendering system, firewater pumps,

and support trestles;

three 400,000 barrel LNG storage tanks each approximately 166 feet in diameterand 168 feethigh surrounded by earthen bermed secondary containment dikescapable of containing in excess of 105 percent of the tanks contents;

LNG sendout facilities, including pumps and vaporizers with a maximum rate of675 MMscf7d;

boil-off com pressors and recondenser; and

firewater system sourcedfiom a fkesh water pond and river water.

The existing facilities are currently used to provide unloading and storage services. Theservices consist of LNG ship unloading, storage, and vaporization of LNG and the delivery ofnatural gas.

2.2 PROPOSED FACILITIES

Southern LNG proposes to expand the capabilities of its existing LNG terminal to receiveand process additional LNG. To achieve this expansion,a num ber of new facilities would beequired. A site plan dep icting the proposed expansion facilitiesis provided in figure2.2-1.

Specifically, the proposed expansion facilities would include:

LNG unloading slip withtwo berths, each of which would have un loadingarms.The S outh Dock with three liquidarms and one vaporarm and the North Dockwith two liquid arms and one vaporarm moo ring and breasting dolphins,fendering system, and support trestles;

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M

kBh

>3Y

f- -.-I-

ik-3NNWH3 Hll lOS

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relocation o f three of the existing unloading arms from the existing dock to on eofthe new berths (North Dock) for use astwo liquidarms and one vapor returnarmas described above;

one LNG storage tank with agross volume of1,000,000 barrels (1 60,000cubicmeters [m3]), the regasified equivalentof 3.5billion standard cubic feet (Bscf);

two first stage (booster) pumps, each sized for360 MMscf/d;

one recondenser, sized for20 MMscUd;

three second stage pumps, each sized for180MMscUd;

three submerged combustion vaporizers, each sized for180 MMscDd;

desuperheaters;

a motor control center;

two dock control buildings;

a compressor shelter; and

associated hazard detection, con trol, and prevention systems, cryogenic piping andinsulation, electrical and instrumen tation systems, and a road from the current siteto the new slip.

Naturalgas would be sen t out of the facility via thetwo existing 30-inch-diameterpipelines connecting the Elba Island LNG Terminal with the in terstate natural gas pipelinesystem. The proposed Elba Island Expansion Project would not necessitate expansion of thedownstream pipeline.

2.3 NONJURISDICTIONAL FACILITIES

There are no non-jurisd ictional facilities associated with the proposed project.

2.4 LANDREQUIREMENTS

Elba Island, where the proposed Project would occur,is owned by Sou thern LNG andconsistsof dredge material disposed from the main tenance of the navigation channel from the1800s to mid 1900s. The con structionof the proposed LNG tank, vaporizers, pumps,compressor, and associated facilities would occur en tirely within previously disturbed andcurrently main tained portions of the existing LNG terminal site. Construction of the proposed

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Elba Island Expansion Project would affect a totalof 87.7acres of w hich37.3 would bepermanently changed with new structures or open water(table 2.4-1). Construction of the LNGtank, vaporizers, pumps, and associated facilities (including temporary laydown, o ffice trailers,and worker pa rking) would affect a total of 35.5 acres of the existing terminal site.

Vaporizers 0.5 0.2

Compressor Area 0.4 0.1

31.2 acres would lie belowmean low water

2.2 35.3NG Unloading Slip and AssociatedFacilities

TABLE 2.4-1I

3.5onstruction Offices and Construction

Worker Parkina

Summary of Land Requi rementsfor the Elba Island Expansion Project

Entire area retumed to pre-construction condition

.0

Facility

Total 87.7

LandTemporarily

Affected DuringConstruction of

ExpansionFacilities (acres)

37.3

LandPermanentlyAffected by

Construction ofExpansion

Facilities (acres)

Comments

I 1.3 I11.9 acres re tumed to grass~~~~ ~~~ ~~

LNG Storage Tank and Containment Dike I 13.2I 4.9 0.2 14.7 acres retumed to grass

~~~~ ~~

ITank Dike Area and LaydownISecondary Pump Area ~~ I 0.3 I 0 2 I

Laydown AreaEntire area retumed to pre-construction condition

6.7 0.0 I

Constructio n Trailers an d LaydownEntire area retumed to pre-construction condition6.0 0.0

Following construc tion, all but 2.0 acres would either be restored to their pre-constructionstatus, grassed or covered with gravel for roads. No clearing of vegetation, other than areascurrently maintainedas grass, would be required for the LNG tank, vaporizers, pumps,com pressor, and associated facilities.

The construction of the slip and docks would require the disturbanceof approximately52.2 acres of land above mean low water (MLW). The characteristics of the land to be disturbed

are as follows:13.4 acres of land covered by grass; 35.4 acres of wooded areas;2.6acres ofmarsh; and0.8 acres of mud flats. At the com pletionof the slip and dock construction,approximately31.2 acres would lie beneath MLW , 3.2 acres of land would be covered with slopeprotection,0.6 acres' would be covered by pervious surfaces (gravel roadways), 0.3 acres wouldbe covered by imperv ious surfaces (concrete containm ent areas), and 16.9 acres would begrassed.

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The temporary construction parking area is a previously cleared, grassed area that hasserved a similar function for previous construction projects at the terminal. Likewise, thetemporary laydown area is a previously cleared, grassed site that has served as a laydown area forprevious construction projects at the terminal. Both of these areas would be returned to their pre-existing conditions after the construction of the terminal expansion facilities.

2.5 CONSTRUCTION, OPERATION, AND MAINTENANCE

Under the provisionsof the Natural Gas Pipeline Safety Act of 1968, as amended,Southern LNG w ould construct, operate, and maintain the facilities in accordance with theU.S.Departmentof Transportation (DOT) Federal Safety Standards for Liquefied Natural GasFacilities, Title 49 Code of Federal Regulations (CFR) Part 193. The facilities would also meetthe National Fire Protection Association(NFPA) Standards for the Production, Storage, andHandling of LNG( NFPA 59A). The marine cargo transfer system and any appurtenances foundbetween the LN G ships and the last valve immediately before the LNG storage tanks wouldcomply with applicable sectionsof the U. S Coast Guards (Coast Guard) regulations forLiquefied Natural Gas W aterfront Facilities, 33 CFR Part 127 and Executive Order 10173.

Construction

Southern LNG proposes to b egin procurement and construction activities in early2003.Constructionof the new LNG tank would take approximately 24 months. Construction of theLNG ship unload ing facility would take approx imately 16 mon ths and the other facilitiesapprox imately 18 months. Southern LNG proposes to have the facilities in service by September30,2005.

Installationof the new tank would beg in with the grading of the tank area. Appropriatemeasu res to control sedimentation and erosion would be installed at this same time. Once thegrading work was complete, foundation construction would begin with the installationof pilesand the pile cap. Tank ancho r straps and bolts would be embedded in the slab. The outer tankwou ld be erected and then the inner tank constructed within the outer tank. Following the raisingof the tank roof, bottom insulation and the tank bottom would be installed. A diagramof theproposed LNG storage tank is presented infigure2.5-1.

Tank internal accessories would be installed, then platforms, walkways, and piping.Upo n placem ent of the construction steel door, the tank would be ready for hydrotesting.Follow ing hydrotesting, exterior insulation between the inner and ou ter tanks would b e installed.

Process piping from tank top to grade would then be installed, and the tank would be ready forpurge and cooldown.

Once tank co nstruction is underway, construction of terminal buildings, installation ofmajor mechanical equipment, installation of process and utility piping, and electricalinstrumentation would occur.

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/CARBON STEELOUTER TANK

9% NICKELINNER TANK

FIBERGLASS BLANKET

- TANK

HANGERS

I I I I

FOAHGLAS INSULATIONrTE INSULATION

TANK S E C T I O N

Figure 2.5-1

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2.6 FUTURE PLANS AND ABANDONMENT

There are no facilities to be abandoned as part of the proposed project.In addition, thereare no plans for future expansion of facilities that would affect additional land requirem ents orcom patibility of plans w ith the currently proposed project.

2.7 PERMITS, APPROVALS, CO NSULTATIONS, AND REGULATO RYREQUIREMENTS

Table 2.7-1 lists Federal, state, and local permitsor approvals that would be required toconstruct the proposed project. However, any such permits for the proposed project must beconsistent with the conditionsof the FERC Certificate. The Com mission encourages cooperationbetween applicantse.g., Southern LNG) and local authorities. However,this does not mean thatstate and local agencies,through application of state or local laws, may prohibit o r unreasonablydelay the constructionof facilities approved by the Commission.

See u chneidewind vANR Pipeline Co., 485U.S. 293 (1988); National Fuel GasSupply v. Public Service Com mission, 894 F.2d 571 (2d C ir. 1990); and Iroquois GasTransm ission System, O.P.,@ a., 2 FERC 61,091 (1 990) and 59 FERC51,094 (1992 .

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TABLE 2.7-1Permits, Approvals, Consultations and Regulatory Requirements

for the Elba Island Expansion Project

t Aaencv I PermitlADproval I Anticipated Filing Date I Status I

Federal Energy RegulatoryCommission (FERC)

FEDERALISection 7 (c) of the Natural

Gas ActMay 31.2002

Prior to construction

Prior to operation

May 29 2002

Preliminary Determinationissued November 20,2002

Application underpreparation

Pending state Coastal ZoneManagement Act review

U S . Coast Guard (Coast Guard)

U.S. Fish and Wildlife ServiceW S )

National Marine FisheriesService (NMFS)

STATE OF GEORGIA

Department of NaturalResources, EnvironmentalProtection Division

Department of NaturalResources, EnvironmentalProtection Division

U.S. Environmental ProtectionAgency (EPA)

U.S. Department ofthe ArmyCorps of Engineers (COE)

I Letter of intent must be filed33 CFR Part 127)

Spill Prevention, Containmentand Control Plan (CleanWater Act, 33 USC.1321 j))Section 404 (Clean Water

Harbors Act)Act)/Section 10 Rivers and

May 7,2002

Coastal Resources Division

Letter of recommendationissued May 30,2002

Section 7 of EndangeredSpecies Act Consultatiqn

April 15,2002 Concurrence receivedMay 13,2002

Section 7 of EndangeredSpecies Act Consultation

April 15,2002

Prevention of SignificantDeterioration (PSD) Permit

NPDES General Pennit forStormwater DischargesAssociated with Constructionand Operating Activiy

Water Quality Certification

Concurrence receivedMay 9,2002

Consistency Determinationunder Coastal ZoneManagement Act

Land Disturbing ActivityPermitepartment of Engineering

IHistoric Preservation Division

Application underpreparationeptember 30.2002

~~

ICHATHAM COUNTY

Department of Health

Section 106 of the NationalHistoric Preservation Act

Application underpreparationeptic System Permit September 30.2002

April 12.2002

Notice of termination duewhen constructioncomplete

May 31,2002

April 30,2002

April 15,2002

IDraft permit issuedNovember 4.2002

Not applicable

Received November 6,2002

Coastal MarshlandsProtection Committeemeeting held December 20,2002 Concurrence pending

Clearance issuedMav 29.2002.

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3.0 ENVIRONMENTALANALYSIS

3.1 GEOLOGY AND SOILS

3.1.1 Geology

The E lba Island LNG Terminal, site of the proposed Elba Island Expansion Project, islocated in the Atlantic Coastal Plain Physiographic Province (Hunt, 1974). Coastal Plain strataconsistof unconsolidated to sem i-consolidated layers of sand and clay and semi-consolidatedlayers of limestone and dolom ite. Sediments range in age from late Cretaceous to Holocene andunconformably overlie igneous intrusive rocks and low-grade metamorphic rocks of PaleozoicAge (Clarke, 1990). These sediments were depositedas a wedgeof sediment dipping towardsthe coast from the erosion of igneous and metamorphic rocks in the Piedmont and Blue RidgeProvinces.

Elevations on Elba Island range from0 to 10 feet above sea level. The island topographyhas been influenced by deposition of dredged materialas a result ofU.S.Army Corps ofEngineers (COE) maintenance of the Savannah harbor channel. Dredge spoil is composedprimarily of sand, silt, and clays. Beneath the dredge material the islandis composedof mediumo fine silt to clayey sands andsoft to firm clay to approx imately120 feet below the surface ofhe dredge spoil. Bedrock beneath the sediments is composed of limestone and dolom ite.

Soil test borings were used to i den ti9 subsurface conditions in both the areas of theproposed LNG tank and the slip. Seven layers were identified in the LNG tank area (WrightPadgett Christopher Engineering& Construction Services [W PC],2002) and consisted of theollowing: a surficial layer of hydraulic fill placed m ore than30 years ago fiom the maintenance

dredging in the Savannah Rive r and man-made fill fiom previous construction; asoft lay layeromprised of recent alluvial deposits typically found in the marshes along the Savannah River; aand layer; a marl form ation layer below the sand layer; a very dense clayey sand layer; and aimestone layer below 1 53 feet MLW at the project site.

Mineral Resources

The primary mineral resources in the coastal Georgia and South Carolina region are sand,ravel, and phosphorus(U.S.Geological Survey [USGS],2002). These resources are abundantn the area. The proposed Elba Island Expansion Project would not interfere with current orbture uses of these resources. Southern LNG conducted a reviewof aerial photographs and

opographic maps and a field survey of the proposed project area. No mining of mineralesources occurs near the proposed Elba Island Expansion Project area. Noknown uture minesre planned for the proposed E lba Island Expansion Project area.

Construction of the proposed E lba Island Expansion Project would not affect anyknownmineral resources nor hinder mine reclamation or expansion efforts.

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Bedrock Blasting

No blasting would be required during any phase of construction of the proposed ElbaIsland Expansion Pro ject, as the entire site is made up of Pleistocene alluvial deposits.

Geologic Hazards

Potential geologic hazards include, surface fau lts, earthquakes, soil liquefaction, andground subsidence.

There a re no recognized fau lts in the Coastal Plain o f Georgia that are associated withseismicity. No faults were observed at the site of the proposed Elba Island Expansion Projectduring field explorations conducted at the site. However, faults are recognized in other areas ofthe Atlantic Coas tal Plain in South Carolina.

A discussion of significant historical earthquakes focuses on the Charleston1886earthquake as it was th e cause of the greatest earthquake damage in the Savannah area.According to h istorical records, the shak ing was severe in the Savannah area to the extent thatseveral buildings and the Tybee Light Station were damaged and people had difficulty standing.Ano ther earthquake of a Modified Mercalli Intensity VI occurred on January 23, 1903. Centerednear Tybee Island, it was felt over an area of 10,000 square miles. Another shock was felt onJune 20, 1912, at Savannah with an intensity of V. The exact epicenters of the 1903 and 1912earthquakes have been postulatedto be near Bluffion, South Carolina. There have beenrelatively few earthquakes with a magnitude (M,) greater than or equal to5 on the Richter Scalewithin 100 kilometers(km) f the proposed site of the E lba Island Expansion Project.

Liquefaction is a phenomenon in w hich soils experience a dramatic decrease in strengthand stifhes sas a result o f earthquake shaking or other rapid loading. Liquefaction occurs insaturated, granular soils when excess pore pressure generated by earthquake shaking reaches orexceeds the e ffective stress. The clays and silts in the layers beneath the proposed s ite are notliquefiable as their c lay contents are generally higher than 15 percent and the liquid limits arehigher than 35 percent,two criteria of so ils not prone to liquefaction. Post earthquake fieldinvestigations have indicated that liquefac tion has historically been confined to a zone within acertain distance from the earthquake. Liquefaction has not been found beyond an epicenterdistance of 100 km for a M,=7 earthquake, nor beyond a epicenter distanceof 200 km for aM,=7.5 earthquake. These relationships are consistent with research of liquefaction findings

from the 1886 Charleston earthquake, in which evidence of liquefaction was found in HiltonHead but not in Savannah , a distanceof approximately 150km from Charleston (WPC, 2002).

In summary, ased on the analysis conducted on the proposed site and the fact that noevidence of liquefaction was found in Savannah from the 1886 Charleston earthquake, it wasconcluded that the risk of liquefaction for a M,=7.3 earthquake is very small ( W C , 2002). Thecharacteristics of the sand deposit makes it less susceptible to liquefaction.

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Som e subsidence has occurred since the terminal was constructed on dredge spoilmaterial. However, SouthernLNG constructed the terminal by placing all facility structures onpiles, which also reduces the threat of soil liquefaction effects as well as damage to the terminalfiom subsidence. The proposed expansion facilities would be constructed in a similar manner.

Impac ts to topography would be limited primarily to the construction phaseof theproposed expansion facilities, when the topographic features at specific locations on the 140-acreexisting terminal site and the proposed slip excavation site would be altered permanently. Aftercompletion of construction, however, topographic and drainage conditions would be restoredasclose to pre-construction conditions as possible.

3.1.2 Soils

The Natural Resources Conservation Service has identified soils of the proposed ElbaIsland Expansion Project siteas made land (M ae) and tidal marsh, salty (Tm l)( U . S .Departmento f Agriculture, 1974). Made land soils consist of areas where dredged materials have beendum ped. Dredged materials are a by-product of dredging activities in the Savannah Rivershipping channel and harbor. Most areas where made land soils occur were formerly marshland.Made land soils consist of course sands to c lays, sometimes with stratified layers of varyinghickness. Tm l land types are tidally influenced and occupied by salt-tolerant vegetation.

Surface layers of this land type contain many pithy, fibrous roots with a high organic mattercontent. Soil series associated with this land type are Capers, Kershaw and O sier soils. Soilseries are highly variable, but the Capers series most likely represents the soils within the tidalmarsh area of Elba Island.

Approx imately 48.8 acresof Mae soil type and 3.4 acresof Tml soil type would be

permanently impactedas a result of the proposed Elba Island Expansion Project. The highlydisturbed nature o f the made land so ils affected by the proposed Elba Island Expansion Projectacilities indicates that while permanent im pacts would occur, there would not be an overalleduction in quality of soils on the island d ue to the proposed Elba Island Expansion Project.

The erosion potential of soils within the proposed Elba Island Expansion Project facilityonstruction area would be minimal due to the level nature of the site and the erosion andedimentation control practices to be implemented during construction.No effects on primearmlands or hydric soils would occuras no prime farmlands or hydric soils occur at the siteofhe proposed facilities. There would be noloss of cropland or residential areas since they do notxist due to the existing industrial facilityon the proposed site. Southem LNG would adoptour

Plan to ensure that potential effects on soils due to construction related effects are minimal. ToW h e r minimize the construction impacts, Southem LNG would develop and implement a site-pecific Soil Erosion and Sediment Control Plan (E&SC Plan) to be approved by Chatham

County and the Georgia Department of Natural ResourcesGADNR). outhern LNG has notubmitted this site-specific plan. Therefore,we recommendthat:

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Prior to construction, Southern LNG should file with the Secre tary, its site-specificSoil Erosion and Sedim ent Control Plan and the county and state approvals.

We believe that the use of our Plan and Southem LN Gs site-specific E&SC Plan wouldminimize erosion and sedimentation.

3.2 WATER RESOURCES, WETLANDS, AND FISHERIES

3.2.1 Groundwater

There are three designated sole source aquifers located within U S . EnvironmentalProtection Agency (EPA) RegionIV, one of which are located in Georgia or South Carolina(EPA, 2000). Therefore, the proposed Elba Island Expansion Project would not affect any solesource aquifers.

The Floridan aquifer system (Tertiary limestone aquifer) consists of a thick sequence ofcarbonate rock (limestone and dolomite) of Tertiary age. This system is the most productiveaquifer in the region and ex tends under southem A labama, southeastem Georgia, southern SouthCarolina, and all of Florida. Typically the Floridan Aquifer becomes thicker near the coastlines,being thinnest near its northern limits. Within the proposed Elba Island Expansion Project area,the Floridan Aquifer is thought to be approximately700 feet thick and is at a depth of153 feetbelow MLW. The Floridan Aquifer is usedas a public water sourcein many areas and supportsseveral large mun icipalities, including Savannah, Georgia (USGS,1990).

The proposed E lba Island Expansion Project area is underlain by the follow ing aquifers insequence: Pearl River, Chattahoochee River, and Black Warrior. The Pearl River Aquifer is

predominatelya thick sequence of sand w ith minor sandstone, gravel, and limestone bedsexkrlding over coastal Alabama, Georgia, and South Carolina. The Chattahoochee RiverAqULifms isolated from the Pearl R iver Aquifer by the Chattahoochee River confining unit andconsists of m ostly sand beds with clay lenses and local deposits of glauconitic sand andlimes tone ranging in age from Later Cretaceous to Late Paleocene. The Black Warrior RiverAqu ifer is isolated from the Chattahoochee River Aquifer by the Black Warrior River confiningunit and consists of Upper C retaceous sands and clay that extend fiom North Carolina tosou thwestem Alabama. The Black Warrior River Aquifer is absent in a wide band adjacent tothe inner C oastal Plain margin of South Carolina and eastem G eorgia, including portions of theproposed Elba Island Expansion Project area.

The surficial aquifer system of the Coastal Plain of Georgia consists primarily of beds ofunconso lidated sand, shelly sand, and shell (coquina) materials less than100 feet thick ofcontinental an do r marine deposits fiom the Cretaceous to H olocene ages. Complex layering offine a n d o r coarse sand, sandy shell, shell, and clay are typical of the systemas continental andmarine influences fluctuated over time.

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Groundwater inthis aquifer is typically unconfined, but confined or semi-confinedconditions may occur locally due to the presence of impermeable or semipermeable clay beds orlenses. Water quality and yield within the shallow aquifer are extremely variable. Water entersthe surficial aquifer as precipitation, quickly moving along short flowpaths, and is oftendischarged quickly as baseflow to surface waterbodies.In addition, a large percentage of thewater is lost through evapotranspiration from the forests that occupy large portions of theGeorg ia Coastal Plain. The water that is not lost to evapotranspiration or discharged to surfacewaterbod ies infiltrates to the F loridan Aquifer in areas where the hydraulic head within theFloridan Aquifer is less than that in the surficial aquifer. The opposite is true in areas where thehydraulic head in the Floridan Aquifer is greater than that in the surficial aquifer.

Because recharge to the shallow aquifer is via local precipitation, water levels tend toluctua te seasonally. Despite fluctuations in water level, water quality, and yield, this aquiferepresents a valuable resource in many areas providing for dom estic and other small-demandupplies. Local yields, occurring within highly permeable deposits, may exceed500 gallons per

minute (gpm) allqwing support of higher demand uses.

Several comm entors mentioned the importance of the Floridan aquiferas a source ofotable w ater for Savannah and had concem s that construction may lead to salt water intrusionnto the aquifer,as the Savannah River at the Elba Island site is brackish. Previous constructiont the Elba Island site has not lead toany known degradation of the aquifer to date. Additionalhee t piling would be placedas previously done for the existing tanks into the formations above

he aquifer. Dredging would occur to a depth of42 feet below MLW over a34 acre area for theerthing slip. The present depthof dredgmg in the river shipp ing channel by the COE has beeno a depth of46 feet near the slip. The river dredging has not lead to anyknown alt waterntrusion into the aquifer. The CO E in its January23,2003Case Document and Environmental

Assessm ent concluded that dredging the berthing slip to42 feet below MLW would not impacthe Floridan aquifer.

No significant impacts are expected to occur to groundwater resources from constructionnd operation of the proposed Elba Island Expansion Project. Potential impacts to groundwateresources would be avoidedor minim ized by the use of both standard and specializedonstruction techniques.No groundw ater withdrawals would be required for the construction,peration, or maintenance of the p roposed Elba Island Expansion Project facilities, and therefore,he proposed Elba Island Expansion Project would not result in the lowering of the localroundw ater table.

During construction, accidental spills, leaks, or other releases of hazardous substancesave the potential to affect groundwater resources. However, subsurface conditions areharacterized by alluvial deposits consisting mostly of stiff, to very stiff clays, and any smallccidental spills or leaks or other releases would not present an immediate threat to significantquifers in the area if recovered in a timely manner. SouthernLNGhas developed a generalnshore Spill Prevention, Containm ent, and Control Plan (SPCC Plan), that, when followed

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During construction or operation of the proposed Elba Island Expansion Project, spills,leaks, or other releases of hazardous materials could adversely impact water quality. Hazardousmaterials entering nearby waterbodiesas a result of spilled materials being flushed intowaterbodies with stormwater runoff or entering the Savannah River directly fkom leaks or spills.along the unloading pier could have an adverse impact on water quality and aquatic organisms.To minimize the potential for accidental releases of hazardous m aterials and to establish properprotocol concerning minimization, containment, remediation, and reporting of any releases whichoccur, Sou thern LNG has developed a general onshore SPCC Plan.

Construction of the proposed expansion facilities would increase the amount ofmpervious surfaces at the LNG terminal, which would increase stormwater runoff volumes. The

existing stormwater system would be modified, as necessary, to accommodate the additionalunoff from the proposed expansion facilities. Southem LNG is required to subm it its

Stormw ater Pollution Prevention Plan (SWPPP) to the GADNR, which would addressrunoffvolumes and the storm water drainage system.

During normal operationof the proposed Elba Island Expansion Project, surface waterdischarges would include storm water runoff and condensate from the vaporizers. Thesedischarges would be directed to drainage ditches that would interconnect to the existing drainageystem. All discharges fkom the proposed Elba Island Expansion Project would be via existing

outfalls authorized by National Pollutant Discharge Elimination System (NPDES) permits forndustrial wastewater. The existing permit would be modified to include the proposed Elbasland Expansion Project.

LNG ship activity at the slip may result in m inor resuspension of bottom sediments intohe w ater column resulting in a temporary increase in turbidity within the slip. Resuspension of

ottom sedim ents and resulting increases in turbidity are considered temporary, short-termmpacts. Use o f shallow draft tugs to assist LNG ships throughout the mooring and departureperations may result in some resuspension of bottom sediments and increase turbidity over thehort-term until sedim ents become stabilized. Turb idity caused by ship traffic presently occurs in

his area of the S avannah River from other ship traffic.

Prior to being placed into service, the proposed LNG storage tank would beydrostatically tested to ensure its integrity. Southem LNG estimates that25.3 million gallons of

water w ould be required to hydrostatically test the new tank. Hydrostatic test water would beumped fkom the Savannah River using the existing firewater pumps. Pump intakes would beppropriately screened to prevent the entrainmentof debris during hydrostatic test w ater

withdrawal and pum ping rates would be m inimized to prevent the impingement/entrainment ofish species on the screens.

Following the completion of the hydrostatic test, test water would be discharged directlyack to the dredge material containment area on Elba Island and ultimately to the Savannah

River through existing permitted discharge points.No chem icals would be added to the

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hydrostatic test water before o r after testing, and all test waters would be analyzed for chemicalcomposition prior to discharge. The hydrostatic test water withdrawal and discharge would beconducted in accordance with all federal rules and regulations.An addition of one milliongallons of freshwater would be required to wash the interior surfaces of the LNG tank as part ofthe hydrostatic testing procedure. This water would also be discharged to the dredge materialcontainm ent area.

The GADNR Environmental Protection Division (GEPD) issued a section 401 permitwith conditions on November6,2002in which it determined that the project would not violatestate water quality standards.

We be lieve the use of our Plan and Procedures, and Southern LNG's E&SC Plan, SWPPPand SPCC Plan, and its compliance with NPD ES perm its would m inimize adverse impacts towater quality.

3.2.3 WetlandsWetlands are areas that are inundated or saturated by surface water or groundwater at a

frequency and duration sufficient to support, and under certain circumstances do support, aprevalence of wetland vegetation typically adapted for life in saturated soil conditions (COE,1987 ). Southern LNG used the 1987 COE Wetland Delineation Manual to identi@ and delineatewetlands that would be affected by the proposed Elba Island Expansion Project. About2.63acres of emergent saltmarsh and0.8 acre of mud flat would be affected during construction andoperation of the proposed project. Typical species found in the saltmarshes include sea myrtle(Baccharis ha limijiolia),big leaf sumpweed( h a mtescens) ,wax myrtle(Myrica cer ifea ),saltmarsh cordgrass(Spartina altemiflora),and big cordgrass(Spartina cynosuroides).

U.S. Fish and Wildlife National Wetlands Inventory maps were also used todetermine the po tential occurrence of wetlands within the proposed Elba Island ExpansionProject site, and the resu lts were com pared with results of the field surveys. Based on theinformation presented on theNWI maps, the proposed expansion of the E lba Island LNGTerm inal site has two distinct wetland types: Estuarine (Intertidal, Emergent, Persistent,Irregularly Flooded ) and Palustrine (Forested Broad-Leaved, EvergreenBroad-Leaved,Deciduous, Temporarily Flooded ). However, based on actual field delineations, no palustrineforested wetlands occur on the site.

The impact of construction of the proposed Elba Island LNG Terminal expansion wouldbe the permanent loss of2.6 acres of coastal marsh.This loss would be mitigated by the creationof an emergent saltmarsh wetland on the southern tip of Elba Island. The area proposed formitigation is about11 acres. The area would be cleared of native and exotic upland vegetation,notably Chinese tallow(Sapium sebiferum),except for a strip adjacent to the Savannah River andthe A tlantic Intracoastal Waterway that would serveas erosion protection fo r the new marsh.The new saltmarsh would be planted with salt marsh cordgrass in the zone above the unvegetated

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Spills

A fuel spill in o r near the construction area of the proposed slip could releasecontaminants, which could affect fish directly or indirectly through changes in food sources orcontam ination of water resources. Adherence to the SPCC Plan would reduce the probability ofa spill occurring and the potential effects from a spill and would increase the response time forcontrol and cleanup of a spill, should one occur. Therefore, the probability of a sp illofhazardous materials is small and any impact to fisheries negligible.

In the unlikely event that LNGis spilled at the m arine terminal, the cryogenic liquidwould vaporize rapidly upon contact with wann water or a ir, leaving no liquid phase o r residualto mix with the river water. Therefore, the spilled LNG would not significantly affect fish andaquatic organism s around the slip.

3.3 VEGETATION AND WILDLIFE

3.3.1 Vegetation

The proposed project would be constructed on previously disturbed areasof Elba Island,an island within the Savannah River that has been utilizedas a dredged material disposal area fordredging activities conducted on the Savannah River. Due to the historic use of the islandas adredged material disposal site , it is considered to be h ighly disturbed, and comprisedof exoticspecies that are not productive as agricultural land, grazing land, or wildlife habitat. Currently,the north end o f the island is usedas a dredge material containm ent area. Adjacent to the dredgematerial containm ent area is the current Elba Island LNG Terminal site. The vegetationcomm unity typesof the terminal site can be characterizedas maintained grass areas. The

vegetation comm unities in areas to the southof the terminal include a mixtureof low qualityhardwood stands, maintained grass, and stripsof emergent marsh.

Areas o f the ex isting LNG terminal site that are not developed are covered by asphalt,crushed rock, or maintained grass. The maintained grassed areas identified on the existingterminal site are dominated by Bermudag r s s (Cynodondactylon).

Habitats that would be impacted by the constructionof the proposed slip includeemergent marsh, low quality hardwood stands, and maintained grass areas. Emergent marshcom mun ities identified within the area of the proposed slip are com prised of sea myrtle(Buccharishalimifoliu),bigleaf sumpweed Iva mtescens),saltmarsh cordgrass(Spartinauhemzflora),and big cordgrass(Spartinucynosuroides).Low quality hardwood communitiesidentified within the proposed slip area are typical of a high ly disturbed coastal upland area witha m ixture of Chinese tallow(Sapium sebifem m),yaupon hoIly Ilex vomitoria), Chinese privetLigustrumsinense),and wax myrtle(Myrica cerifera). Maintained grass areas within the area of

the proposed slip site are dominated by Bermudagrass.

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Construction of the proposed Elba Island Expansion Project would affect about87.7 acresof land. Emergent marsh comprises2.6 acres or three percent of the total land affected by theproposed project. Low qua lity hardwood forest com prises35.4 cres or40 percent of the totalland affected. Maintained grass comprises46.2 acres or53 percent of the total land affected.

Impacts to the emergent marsh areas would result in their permanent removal fromproductivity. SouthemLNGproposes to mitigate the loss of these wetlands by creating an areaof em ergent marsh on the southem tip of Elba Island,as previously described in section3.2.3,Wetlands.

Low quality hardwood habitat impacted by the proposed project would be perm anentlyremoved. Removal of this hab itat is not expected to significantly diminish the qua lity of habitaton the island due to the highly disturbed nature of the land and its high exotic speciescomposition.

Som e maintained grass areas would be permanently removed. The loss o f this vegetations not seenas significant due to the non-native spec ies composition.

3.3.2 Wildlife

The proposed p roject site has three areas that contain wildlife habitat: the existingerminal, the dredge material containment area, and the proposed slip area. Wildlife habitat onhe existing terminal site has been degraded due to prev ious construction activities. The terminalite habitat is that of a homogenized ecosystem managed in a grassed state, which occupiesortions o f the site thatare not occupied by terminal facilities or paved areas. Wildlife speciesotentially utilizing the site are limited to various sm all rodents, lizards, insects, and possibly

om e passerine species. Grassed areas outside the fenced portion of the terminal facilities aresed as grazing areas by deer.

Wildlife habitat on the dredged material disposal area is low quality hardwoods that areomprised primarily of exotic opportunistic species. The continued disturbance and alteration ofhis area m akes it poor quality wildlife habitat.

Wildlife habitat on the proposed slip area is com prisedof three separate habitat types:mergent marsh, low quality hardwood forest, and maintained grass areas. Emergent marsherves as valuable foraging habitat for many species of wildlife. This habitatis important to

migratory waterfowlas wintering grounds and stopover habitat during seasonal migrationeriods. The low quality hardwood forest area provides cover and foraging habitat for suchpecies as white-tailed deerOdocoileus virginiunus),eastem gray squirrel(Sciurusurohensus), feral pigs Sus scrofu), raccoon(ProcyonZotor), mourning dove(Denuidu

mucrouru), and yellow rumped warbler(Dendroicucoronutu). Maintained grass areas providewildlife habitat to on ly limited disturbance tolerant species, such as rodents and insects. These

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areas also provide foraging habitat to edge spec ies like white-tailed deer and certain passerinespecies.

Construction of the proposed project would have little impact on wildlife due to the lackof wildlife habitat existing on the site. The maintainedgrass areas do not provide sufficienthabitat to support diverse wildlife populations. Some species suchas small rodents, lizards, andinsects may be affected by the construction due to alteration in habitat and direct contact withconstruction equipment.

Construction on the proposed slip area would permanently impact52.2acres of wildlifehabitat:2.6 acres of emergent marsh,0.8 acre of mud flats,35.4acres of low quality hardwoodforest, and13.4acres of m aintainedgrass. Smaller less mobile wildlife species, suchas rodents,reptiles, amphibians, and insects may experience direct mortality due to excavation activities.Larger, more m obile species, such as white-tailed deer, feral pigs, raccoon, and waterfowl wouldbe perm anently displaced to other portions of the island. This displacement could cause these

species to u tilize lower quality habitats resulting in lowered reproductive success and decreasedsurvival rates. To mitigate theloss of em ergentmarsh,as discussed in Section3.2.3,SouthemLNG proposes to create new marsh on the southern tip o f Elba Island. The creation of this marshis expected to crea te wildlife habitat o f equal quality to the marsh lost to the proposed Elba IslandExpansion Project.

3.4 ENDANGER ED AND THREATENED SPECIES

The COE,as ead federal agency for consu ltations with section7 of the EndangeredSpecies Act, initiated informal consultation with theU.S. ish and Wildlife ServiceFWS) andNMFS regarding the p resence of federally-listed or proposed listing of species and their criticalhabitat within the proposed Elba Island Expansion Project area. The COE initiated consultationwhen it issued its Joint Public Notice on June12,2002,with the state of Georgia.In addition,Southern LNG, as the Commission's non-Federal representative, consulted with the FWS,NMFS, and the GADNR to determine the presence of federal and state-listed endangered,threatened, and species of concem that could be affected by the proposed project.

Sou them LN G also conducted a field survey at the Elba Island site in January2002,forterrestrial federally listed species,as well as other species of concern identified by the agencies.

3.4.1 Federa lly-Listed Species

The COE identified1 1 federally-listed species that may occur in the project area: WestIndian manatee, Northern Right Whale, shortnose sturgeon, loggerhead sea turtle, Kemp's ridleysea turtle, eastem cougar, wood stork, bald eagle, peregrine falcon, piping plover, red-cockadedwoodpecker, and eastem indigo snake.

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Due to the lack of habitat, and additional information provided by Southern LNG, theCOE determined that the project would have no effect on the eastem cougar , wood stork, baldeagle, peregrine falcon, piping plover, red-cockaded woodpecker, and the eas tem indigo snake.In addition, Sou them LNG's field surveys found no habitat exists for the red-cockadedwoodpecker, piping plover, bald eagle, wood stork, and eastem indigo snake. Since no habitatsexist for these federally listed species, we concur with the COE's determination that the proposedproject would not affect these species.A copy of this EA will be sent to the FW S for theirreview.

A commentor questioned whether the new berths, piers, and docks would be designed toprevent in jury to manatees and right whalesas a result of increased ship calls. We note that theCOE would require the use of the Savannah District 1992 Standard Manatee Conditions toreduce the likelihood for the project to adversely affect the manatee. Based on theimplem entation of these conditions, the COE determined that the project is not likely toadversely affect the West Indian manatee. We concur.

The COE determined that the project is located above River Mile 6 in Savannah Harbor,therefore there is no potential for the Northern Right W haleto be found at or near the project site.Also, we understand that there has never been a docum ented occurrenceof this species at theLNG facility site. Therefore, we concur with the COE and believe that the project is not likely toadversely affect the Northem Right W hale.

The shortnose sturgeon is likely to be rare in the vicinity of the LNG facility site, howeverhe FW S i s concem ed that dredging activities and obstruction by construction equipment could

potentially limit and hinder their migration. TheCOE indicates that the shortnose sturgeonadults and juven iles) are almost all found in the Savannah Harbor near the f?esh/salt water

nterface (salt wedge), which is located above River M ile 16, about8 miles upstream of theproject site. Therefore, itis unlikely that adultsor juveniles would be found in the vicinity of theproject site. Hence, there is no potential for these fish to be entrapped by a hydraulic cutter headdredge. We believe that the project is not likely to adversely affect the shortnose sturgeon.

The C OE indicated that hydraulic cutterhead dredging, in the past, has not been found tohave adverse impacts on the loggerhead sea turtle or the Kemp's ridley sea turtle. Also, nodocum ented occurrences of these species of turtles have been identified at River Mile7proposed project site on the Savannah River). Therefore, we determine that the project is notikely to adversely affect the loggerhead sea turtle and the Kemp's ridley sea turtle.

.4.2 State-Listed Species

Consultations with state agencies have found no occurrences of any state-listed specieswithin the Elba Island Expansion Project siteGADNR, 2002). During field surveys conductedn January2002, no state-listed species of concem was observed on o r near the proposed E lba

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Island Expansion site(ATM, 2002). Assuch, we believe no adverse impacts would occuronstate-listed animal or plan t species.

3.5 LANDUSE

3.5.1 Land Use

Existing land uses surrounding the proposed Elba Island Expansion Project include amixture of industrial, residential-agriculture, and coastal marsh lands. The s ite and immediatesurrounding areas are zoned I-H, heavy industrial. Within atwo mile radius o f the site, land usesinclude forested wetlands, industrial, nonforested wetlands, streams and canals, and transitionalareas (areas unable to be identified by ex isting designations).

The construction of the proposed LNG tank, vaporizers, and pumps would occur entirelywith in previously disturbed portions of the existing LNG term inal site, and no clearing of

vegetation, other than areas maintainedas grass, would be required. The construction of theLNG unloading slip and ship berths would require approximately52.2 acres, of which35.4 cresare existing wooded vegetation,13.4 cres are m aintainedas grass, and3.4 acres are wetlandsbordering the shoreline of the island. The Elba Island Expansion Project would affect a total of87.7acres of the ex isting terminal property, of which35.4 acres are wooded,3.4 acres arewetlands,45.9 cres are grassed,2.7 acres covered in asphalt, concrete, or gravel. Constructionof the proposed Elba Island Expansion Project facilities would not affect existing and future landuses at the terminal site or in the vicinity of the proposed Elba Island Expansion Project site. Theproposed Elba Island Expansion Project facilities would be consistent with o ther existing andfbture on-site and site vicinity land uses.

Following construction,48.5 acres of the87.7acres disturbed by construction will ber rmed to grassed area. The number of ac res of asphalt, concrete or gravel covered area wouldincrease from2.7 cres to 8.0acres following construction. The number of acres lying beneathMLW would be3 1.2 acres. Of the3.4 cres of w etlands affected by construction, none wouldremain a fter construction. This loss would be mitigated in an area on the sou them end of theisland (see Section3.2.3). The area where the LNG storage tank would be constructed is apreviously cleared, grassed area. Areas fo r construction of the vaporizers, secondary pumps,compressor are also previously cleared, graveled areas.

The temporary construction parking area is a previously cleared grassed 3.5-acre area that

has served a sim ilar function for previous construction projects at the terminal. Likewise, thetemporary laydown areas and construction trailer locations are previously cleared, grassed,graveled, or paved areas of the existing LNG terminal site that has servedas a laydown area forprev ious construction projects. All of these areas would be returned to their pre-constructionconditions af ter the construction of the proposed Elba Island Expansion Project facilities iscomplete. A summ ary of these land areas is provided in table2.4-1.

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Operation of the proposed Elba Island Expansion Project would haveno effect on otherland uses because project-related land use would be consistent with existing and future land usesat the proposed Elba Island Expansion Project site and within the general vicinity.

3.5.2 Existing Residences and Planned Residential Development

Chatham C ounty has experiencedan ncrease in new housing construction in the last 10years. The closest residential subdivision to the terminal is located along Riverview Roadapproximately 12,000 feet from the terminal. Another residential subdivision occurs to thesouthw est about 12,300 feet from the terminal. All residential subdivisions occur as extensionsof the City of Savannah and co-exist with the existing industrial area bordering portions of theSavannah River and are not encroaching on the industrial area of the terminal. Because the siteis buffered from adjacent areas by existing industrial areas, marsh land and tidal creeks and theproposed construction would not disturb any land outside of the ex isting property boundary, theproposed expansion project w ould not have impacts on any existing or planned residences orresidential development.

3.5.3 Recreation

No parks, conservation easements, or recreation areas are located within2 miles of theproposed Elba Island Expansion Project site, except for properties that comprise the Fort PulaskiNational Monument. Fort Pulaski National Monument (Fort Pulaski) is located approximately15 miles east of Savannah onUS. 0. Fort Pulaski was established in 1924 and contains5,365acres . The park includes scenic marsh and uplands that support a variety of animal lifecharacteristic of southem barrier islands. Recreation activ ities at the park include biking, birdwatching, boating, fishing, hiking, kayaking, nature walks, and wildlife viewing. There were

over 400,000 visitors to the park in 2001.No adverse effects on recreational resources in the vic inity of the proposed Elba Island

Expansion Project site are anticipated during construction. The construction work force wouldargely commute to the project site. There are sufficient recreational resources in the vicinity ofhe proposed Elba Island Expansion Project to accommodate the additional users fiom theonstruction work force, should they choose to remain in the ChathamCounty area forecreational purposes.

No adverse effects on recreational resources in the vicinity of the proposed Elba IslandExpansion Project site are expected during operation. Southem LNG anticipates adding

pproximately ten permanent staff to handle project operations. This small increase in theermanent population would have little or no impact on the demand for recreational resources.

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3.5.4 Coastal Zone Management

The proposed E lba Island Expansion Project is located within Georgia's CoastalManagem ent Zone. It is the mission of the Georgia Coas tal Management Program to balanceeconom ic development in Georgia's coastal zone with preservation of natural, environmental,historic, archaeological, and recreational resources for the benefit of Georgia's present and futuregenerations'' (Georgia Coastal Management Program, 2002). Based on review of the coastalzone consistency guidelines and the fact that the proposed project involves expansion of anexisting terminal, which in part is responsive to requirements of the Coast Guard, the proposedElba Island Expansion Project is designed to be in com pliance with coas tal zone consistency

\ guidelines. A letter requesting coastal zone consistency confirmation was sent to the GADNRCoastal Resources Division on April 30,2002. To date, Southern LNG has not received aconsistency determination. Therefore,we recommend that:

Prior to construction, Southern LNG should file evidence from the GADNR that the

project is consistent with the Georgia Coastal Zone M anagement Plan.

3.5.5 Visual Resources

Visually, the site vicinity is a contrast between natural (water, undeveloped land area) andindustrial features. The three existing400,000 barrel LNG storage tanks are the dominant visualelements in the site vicinity. Each of the three existing storage tanks stands 168 feet high and166 feet in diameter.

The site of the proposed Elba Island Expansion Project is Southem LNG's ex isting LNGterminal site. The proposed facilities would be constructed in unused portions of the existingterminal site. The proposed LNG tank would be 183 feet high and 258 feet in diameter andwould be part o f the cluster of tanks currently on Elba Island. The new LNG tank would bepainted in the same coloras the existing tanks and would blend in with the existing tanks.

Aesthetic impacts associated with the constructionof the proposed Elba Island ExpansionProject facilities would include minor noise and dust,as well as the presence of constructionequipment. These effects would be temporary andas such would not be significant.

The proposed Elba Island Expansion Project facilities would be constructed at the

existing LNG terminal site and at a location that is surrounded primarily by industry. It isunlikely that there wou ld be any adverse impacts to the visual environmentof the site vicinitydue to operation of the project. The new LN G tank would be larger in diameter (92 feet) andtaller in height (15 feet) than those already in existence. However, it would be visua lly consistentwith the surrounding tanks and would be consistent with the current visual environment in thevicinity of the proposed expansion project site. It is unlikely that there would be any adverse

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effects to the visual environment of the site vicinity due to operationof the proposed Elba IslandExpansion Project.

3.6 SOCIOECONOMICS

In accordance with Executive Order 12989 on Environmental Justice, we considered theeffec ts of the proposed project to ensure that it would not discrim inate against minorities and lowincom e comm unities, or Native American programs. The proposed Elba Island ExpansionProject is located on an existing LNG terminal site and would not cause adverse environmentalimpac ts. Therefore, we have not identified any disproportionately high or adverse environmentaland hum an health im pacts to low-income and minority populations.

3.6.1 Population and Construction Schedule

The existing Southern LNG Elba Island LNG Terminal, site of the proposed Elba IslandExpansion Project, is located on Elba Island, Chatham County, Georgia. Chatham County has aland area o f 438 square miles, a 2000 population of 232,048 persons, and an average populationdensity of about 530 persons per square mile. Chatham County comprises less than1 percent ofhe total land area o f Georgia (57,906 square miles) and about 3 percent of its population

(8,186,453).

The workforce for the duration of the proposed 30-month construction period wouldaverage 65 personne l. The peak work force of 208 personnel occurs in month 18 and continueshrough month 20. When available, local workers would be used for construction. Additionalconstruction personnel hired fi-om outside the proposed Elba Island Expansion Project areawould be highly skilled mechanical, electrical, and instrumentation and control tradesmen.

Assum ing a worst-case scenario, that all 208 workers would relocate to the proposed Elbasland Expansion Project area, and using the 2000 census data for Chatham C ounty, Georgia

which indicate that a typical household consists of 2.49 peop le, 518 additional people wouldmo ve to the area. This estimated number of people who would relocate to the area temporarilyduring construction would not constitute a major impact on population.

.6.2 Employment and Income

Services, followed by retail trade, com prise the largest employment sectors in ChathamCounty. The2000 unemployment rate for Chatham County, Georgia was 3.8 percent, comparedwith 3.7 percent for the State of Georgia. The 1999 per capita income for Chatham County,Georg ia was $27,910 compared with $27,324 for Georgia.

Local expenditures in the proposed Elba Island Expansion Project area are expected toqual approximately $16 m illion for goods and services over the estimated 30-monthonstruction period. Total wages during that period a re expected to equal approximately

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miles southwest of the proposed Elba Island Expansion Project site. Because the proposed ElbaIsland Expansion Project is being constructed at an existing LNG facility that is imm ediatelysurrounded by and zoned for industrial use, it is unlikely that there would be any adverse effectson adjacent property values.

3.6.5 Schools

There are 53 primary and secondary public schools in Chatham County, Georgia, with anenrollment o f more than 36,000 students and 22 private schools with8,141 students. If all 208construction workers would relocate with school age children, the 102 children would be a0.3percent increase in the public school population and a1 O percent increase in the private schoolpopulation. Both of these are imperceptible increases that would not affect Chatham C ountyschools.

3.6.6 Hosp itals, Police, and Fire

There a re six hospitals located in Chatham County, Georgia, with a combined totalof1,642 beds that provide a full range o f health care services.

Police protection for Elba Islandis provided through cooperationof the Cityof Savannah,Chatham County Police Department and a contract security force. Both the Cityof Savannahnd Chatham County Police Departm ents and the private security force have sufficient numberoffficers to support the Elba Island LNG Terminal without adversely affecting the level ofrotection to the Cityas well as the County. Fire protection for the Elba Island LNG Terminal isrovided by the City of Savannah Fire Department along with some S outhern LNG siteesources.

Construction of the proposed Elba Island Expansion Project would result in little or nohort-term impact on the availabilityof local community facilities and services such as police,ire, and medical because the non-local workforce would be very sm all relative to the currentopulation. The local comm unities have adequate infrastructure and comm unity services to meethe needsof the few out-of-area workers that would b e required for construction and thenperation of the proposed Elba Island Expansion Project.

.6.7 Transportation

Access for transporting equipment, materials and personnel to the proposed Elba Islandxpansion Project would be provided by local roads. The local roads consist of a four-laneivided highway with a50 mile per hour (mph) speed limit, standard 12-foot lanes, andorresponding 12-foot left turning lanes at roads leading to the terminal. The local roads provideccess for vehicles traveling from the C ity of Savannah and the imm ediate vicinity of Chathamounty east of the city. The land use along local roads includes residential, comm ercial and light

ndustrial.

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The access road to the terminal is a two-lane paved road w ith a 25 mph speed limit,standard 12-foot travel lanes and 2-foot paved shoulders and becomes a private drive forSouthem LNGs Elba Island Terminal approximately500 feet beyondthe ntersection with localroads. The land use along this road is commercial and industrial.

According to the T ra fi c Impact Analysis for Elba Island Liquefied Natural GasTerminal Addition conducted by G resham, Smith and Partners (GS& P, 2002), the local roadspresently accomm odate approximately 18,600 vehicles per day.To obtain a more accuratepicture o f predicted traffic volumes during construction, current volumes were factored at acumulativegrowth rate of2 percent per year with a2005 predicted vo lume of 19,740 vehicles.

Site access patterns for trucks w ere established in the Elba Island TerminalRecom missioning Project: Environmental Assessment (FERC,2000). In order to avoid trucktr af ic in the downtown area of Savannah , terminal generated truck traffic would access the siteby traveling interstates and other su rface roads. Conversely, all exiting truck traffic would follow

this route in reverse. After consulting with the Chatham County Engineering Department, it wasassumed that 60 percent of the automobile traffic would access the site from the west and40percent will access the site from the east.

Construction and operations worker parking and equ ipment storage would be provided onthe existing Southem LNG E lba Island Terminal site. Material deliveries to the site would occurthroughout the majority of the construction phase, peaking in thefifth, sixth and seventh mon thsat approximately170 vehicles per month. On average,80 to 100 material deliveries per monthwould be anticipatedthrough all but the final three months of the construction period. The trafficimpact analyses were conducted under the conservative assumption that all deliveries wouldoccur during the peak traffic periods. If possible, Southem LNG would schedule the arrival of

material deliveries to occur during the non-peak traffic periods.

An average of approxim ately 65 workers would be employed over the 30-m onthconstruction period. In accordance with industry nom s, a conservative occupancy rate of 1.3persons per vehicle translates into about50 cars per day transporting workers to and from the sitetwice per day. At the peak of construction, approximately208 workers would travel to and fromthe site. This figure translates into approximately 160 trips to and from the site twice per day.

As in the case of material deliveries, the conservative assumption was used that allconstruction workforce arrivals and departures would occu r during the peak morning and eveningtraffic periods. The study was made even more conservative by the assumption that theconstruction workforce would make trips in singularly occupied vehicles. With theseconservative assumptions made, the traffic impact analysis concludes that while certainimprovements could be made to enhance traffic flow in the area, no new intersection trafficcontrol improvem ents are necessary due to m inimum increased intersection approach delays andan acceptable range of level of service for the intersection during current, future projected,construction and operational phases.

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3.7 AIR QUALITYAND NOISE

3.7.1 Air Quality

The proposed project would generate air emissions through both short-term constructionactivities and long-term operation of the stationary emission units at the terminal. Emissionsrom all phases of construction and from the operation of the emission units must comply with

applicable state and Federal regulations.

Construction impac ts would be short-term and would consist of a temporary increase inugitive dust and m obile source em issions from construction equipment operating on graveload s and the construction areas within the terminal site fenced boundary. However, such

emissions are not expected to have an adverse effect on the local ambient air quality.

During operations the proposed Elba Island Expansion Project would result in increasedir em issions due to the installation of the LNG vaporizers. The proposed Elba Island Expansion

Project would, therefore, be subject to Federal and state air quality regulations. Potential impactso air quality would be minim ized by strict adherence to app licable Federal and state regulations.

The Clean Air Act (CA A) of 197 0,42 United S tates Code 7401et seq. amended in 1977nd 1990, is the basic federal statute goveming air pollution. The provisions of the CAAotentially relevant tothis proposed E lba Island Expansion Project are listed below and areiscussed in the following sections:

e Air Quality Control Regions;

e

National Ambient Air Q uality Standards(NAAQS);e Prevention of Significant Deterioration (PSD );

e National Emission Standards for Hazardous Air Pollutants; and

e Title V Operating P ermits.

Additionally, the proposed E lba Island Expansion Project would b e subject to applicabletate regulations, which may be more stringent than federal regulations. Georgia has existingtate construction permit programs as well a s delegation fkom the Federal govemm ent for PSDnd TitleV permit programs. The GEPD would require Southern LNG to secure constructionerm its prior to the installation of equipment associated with the proposed E lba Island Expansionroject. Southern LNG prepared a PSD construction air permit application and subm itted it to

GEPD in April 2002, for their review. Southem LN G would obtain an air construction permitrior to any construction or installation of the proposed Elba Island Expansion Project. Other

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applicable state requirements that may differ from Federal requirements would be addressedthrough the state permitting process.

SouthernLNGs Elba Island Terminal currently operates under a Title V operating permit.The existing permitted air emission sources are:

five 135 MMscf7d submerged combustion vaporizers, each rated at 88.1 millionBritish thermal units per hour (MMBtu/hr);

a two reciprocating engine generators, each rated at 3,900 horsepower (hp);

a two gas urbine generators, each rated at3,800 hp;

two fuel gas heaters, each rated at 1.25 M M B t h ,

m

a heated vent gas heater rated at 11.74 MMBtu/hr,an air compressor rated at15 hp;

a a firewater pump engine rated at 2 15 hp; and

three oil storage tanks of 2,000,10,000, and 270 gallons.

The new emission sources as part of the proposed Elba Island Expansion Project thatwould b e subject to the p reviously mentioned state and Federal regulations are three 180MMscf7d submerged com bustion vaporizers, each rated at 121.4 MM Btu/hr.

Fugitive dust generation may result from construction activities suchas land clearing,grading, excavation, and concrete work, along with vehicular traffic on paved and unpaved roads.The magnitude of hg iti ve dust generation would be primarily a function of the area ofconstruction, silt and moisture contents of the soil, wind speed, frequency of precipitation,amount of veh icle traffic, vehicle types and paved roadway characteristics. Fugitive dust may beproduced during all phases o f construction. However, dust suppression techniques, suchaswa

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