Final Scoping Document - Jamestown BPU Home · Final Scoping Document Jamestown Clean Coal Project...

PROJECT SPONSOR:Jamestown Board of Public UtilitiesJamestown, New York

LEAD AGENCY:Jamestown Board of Public UtilitiesJamestown, New York

FINAL SCOPING DOCUMENT

for the

JAMESTOWN CLEAN COAL PROJECTJamestown, Chautauqua County, New York

January 19, 2005CV04081a

Final Scoping Document Jamestown Clean Coal Project

i January 19, 2005

Table of Contents

1.0 INTRODUCTION..............................................................................................................................1-1

1.1 Project Overview ....................................................................................................................1-1

1.2 Project Sponsor and Involved Agencies ................................................................................1-1

1.3 Description of SEQR Process................................................................................................1-2 1.3.1 Environmental Assessment Form, Coordinated Review, and Determination of

Significance.................................................................................................................1-3 1.3.2 Scoping........................................................................................................................1-3 1.3.3 Draft Environmental Impact Statement .......................................................................1-4 1.3.4 Public Comment Period ..............................................................................................1-4 1.3.5 Final Environmental Impact Statement .......................................................................1-4

1.4 Permits and Approvals ...........................................................................................................1-4

2.0 PROJECT DESCRIPTION ..............................................................................................................2-1

2.1 Existing Carlson Plant ............................................................................................................2-1 2.1.1 Site Location................................................................................................................2-1 2.1.2 Combustion Units and Coal Handling System............................................................2-1 2.1.3 Electrical Generation ...................................................................................................2-3 2.1.4 District Heating System...............................................................................................2-3 2.1.5 Water Uses, Wastewater and Storm Water................................................................2-3

2.2 Proposed Clean Coal Project.................................................................................................2-4 2.2.1 Clean Coal Unit ...........................................................................................................2-4 2.2.2 Relocation of BPU Corporate Offices, Warehouses, and Garages..........................2-12 2.2.3 Construction of the Clean Coal Unit..........................................................................2-13

3.0 POTENTIALLY SIGNIFICANT ADVERSE ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ...........................................................................................................................................3-1

3.1 Air Resources.........................................................................................................................3-2 3.1.1 Construction ................................................................................................................3-2 3.1.2 Operation.....................................................................................................................3-3

3.2 Water Resources....................................................................................................................3-9


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3.3 Ecological Resources...........................................................................................................3-11

3.4 Cultural Resources...............................................................................................................3-12

3.5 Visual Resources .................................................................................................................3-14

3.6 Transportation and Traffic ....................................................................................................3-15

3.7 Noise ....................................................................................................................................3-18

3.8 Solid Waste ..........................................................................................................................3-19

3.9 Social and Economic Resources .........................................................................................3-20

4.0 ALTERNATIVES..............................................................................................................................4-1

APPENDIX A POSITIVE DECLARATION FOR JAMESTOWN CLEAN COAL PROJECT

APPENDIX B PRELIMINARY DRAFT EIS OUTLINE FOR JAMESTOWN CLEAN COAL PROJECT


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List of Tables

Table 1 Preliminary List of Permits and Approvals for Clean Coal Project ...........................................1-5


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List of Figures

Figure 1 Location of Samuel A. Carlson Generating Station, Jamestown, NY .....................................2-2

Figure 2 Site Plan for Clean Coal Unit ...................................................................................................2-5

Figure 3 Picture of a Typical Circulating Fluidized Bed Boiler ...............................................................2-6

Figure 4 Preliminary Rendering of Clean Coal Project ..........................................................................2-7


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List of Acronyms

AGC Annual Guideline Concentration

BACT Best Available Control Technology

BPU Jamestown Board of Public Utilities

BUD Beneficial Use Determination

CAA Clean Air Act

CFB Circulating Fluidized Bed

CFR Code of Federal Regulations

CO carbon monoxide

CO2 carbon dioxide

CTSCREEN Complex Terrain screening dispersion model

deg degrees

EAF Environmental Assessment Form

ECL Environmental Conservation Law

EIS Environmental Impact Statement

EJ Environmental Justice

ESP electrostatic precipitator

FAA Federal Aviation Administration

FBC Fluidized Bed Combustion

fps feet per second

ft msl feet above mean sea level

GEP Good Engineering Practice

gpm gallons per minute

HCl hydrogen chloride

HF hydrogen fluoride

HRSG Heat Recovery Steam Generator

ISCST Industrial Source Complex Short-Term dispersion model

ISO International Standards Organization

km kilometers

LOS Level of Service

MACT Maximum Available Control Technology

mgd million gallons per day

MMBtu million British thermal units


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List of Acronyms (cont’d)

NAAQS National Ambient Air Quality Standards

NGVD National Geodetic Vertical Datum

NO2 nitrogen dioxide

NOx oxides of nitrogen (includes NO2)

NSPS New Source Performance Standards

NYCRR New York Codes, Rules, and Regulations

NYSDEC New York State Department of Environmental Conservation

OPRHP Office of Parks, Recreation, and Historic Preservation

O3 ozone

Pb lead

PM10 particulate matter sized 10 microns and smaller (also called respirable particulate matter)

PM2.5 particulate matter sized 2.5 microns and smaller (also called fine particulate matter)

POTW Publicly Owned Treatment Works

PSD Prevention of Significant Deterioration

RACM Regulated Asbestos Containing Material

RUS railcar unloading station

SEQR State Environmental Quality Review Act

SGC Short-term Guideline Concentration

SIL Significant Impact Level

SIP State Implementation Plan

SNCR Selective Non-catalytic Reduction

SO2 sulfur dioxide

SPDES State Pollutant Discharge Elimination System

SWPPP Storm Water Pollution Prevention Plan

TDF tire derived fuel

tpy tons per year

USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

VOC volatile organic compounds


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1.0 INTRODUCTION

1.1 Project Overview

The Jamestown Board of Public Utilities (BPU) is a community-owned electric utility that has been providing low-cost and reliable electric generation and service to the City of Jamestown and surrounding area for more than a hundred years. The BPU’s energy portfolio includes a significant amount (over 80 percent) of renewable hydropower. The BPU also owns and operates the Samuel A. Carlson Generating Station (“Carlson Plant’) in Jamestown.

The Carlson Plant consists of four pulverized coal fired boilers and two steam turbines with a combined output of 49 megawatt (MW), a combined cycle gas turbine unit (LM6000) rated at 43 MW at International Standards Organization (ISO) conditions, and a small (23.3 million Btu per hour [MMBtu/hr]) gas fired boiler that is used to supplement district heating needs. On its own initiative, the BPU has also increased the Carlson Plant’s overall efficiency by installing an environmentally friendly district heating system, a form of cogeneration, and a district cooling system.

The Carlson Plant is an extension of the Steele Street Generating Station, which was built in the early 1920’s. While the existing plant has provided good service to the community, it is approaching the end of its useful life. Instead of continuing to spend increasing funds on maintaining the existing plant, the BPU is proposing to construct a new clean coal unit at the Station and to retire two of its existing coal-fired boilers when the new unit goes into commercial operation. The new unit will be a state-of-the-art circulating fluidized bed boiler (CFB) that will supply steam to a new 40 MW steam turbine generator. The CFB will be capable of burning coal and alternate fuels such as community wood waste, petroleum coke and chipped tires. The CFB is expected to be operational in 2010. Construction of the CFB will also involve upgrades of certain existing facilities, including storage facilities and railcar unloading facilities located north of the current plant site, and may result in increased water use.

The BPU will relocate its offices, warehouses and garages as part of the project. The BPU anticipates renovating and/or constructing a building in Jamestown and locating its electric, water and other utility staff in the building.

1.2 Project Sponsor and Involved Agencies

Project Sponsor Jamestown Board of Public Utilities Alternate Address: 92 Steele Street P.O. Box 700 Jamestown, New York 14071 Jamestown, New York 14702-0700


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Contact: Walter W. Haase, P.E., General Manager Phone: (716) 661-1670

State Environmental Quality Review Act (SEQR) Lead Agency

Jamestown Board of Public Utilities Alternate Address: 92 Steele Street P.O. Box 700 Jamestown, New York 14071 Jamestown, New York 14702-0700

Contact: Sue Jones, Communications Coordinator Phone: (716) 661-1666

Permitting Agencies

New York State Department of Environmental Conservation (NYSDEC) Region 9 – Division of Environmental Permits 270 Michigan Avenue Buffalo, New York 14203-2999

Contact: Steven Doleski, Regional Permit Administrator Phone: (716) 851-7165 United States Environmental Protection Agency (USEPA) Region 2 (Prevention of Significant Deterioration [PSD] Permit) 290 Broadway New York, New York 10007-1866

Contact: Steven Riva, Chief, Air Program Branch, Permitting Section Phone: (212) 637-4074

1.3 Description of SEQR Process

The State Environmental Quality Review Act (SEQR), as implemented by 6 NYCRR Part 617, requires the consideration of environmental, social and economic factors in the early stages of the planning, review, and decision-making process of New York agencies. SEQR is a formalized process that requires coordination and input among the BPU, other agencies that are involved and interested in the project, and the public, regarding the impacts of the project. The major steps in the SEQR process are described in more detail below.

An important aspect of SEQR is its public participation component. Opportunities for public participation are available and encouraged throughout the SEQR process and include public scoping


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and public input on the Draft Environmental Impact Statement (EIS). These opportunities allow the public and other agencies to contribute to the planning process. See generally NYSDEC’s SEQR Handbook (1982). Additionally, the BPU, as the SEQR Lead Agency, will be actively seeking public input in a variety of other forms.

The major steps in the SEQR process are described below.

1.3.1 Environmental Assessment Form, Coordinated Review, and Determination of Significance

The first step in the SEQR process is the completion of an Environmental Assessment Form (EAF), which provides information about the proposed action and describes, in a preliminary way, the potential environmental impacts of the proposed action. When an EAF is completed by the project sponsor, the agencies with authority over the project decide which agency will lead the environmental review. The BPU completed an EAF and circulated it to other involved and interested agencies on or about July 20, 2004. The EAF service list is included at the end of Appendix A to this document. The EAF is available at the BPU’s offices as well as the City of Jamestown Clerk’s office for review by the public. The BPU has obtained the concurrence of other involved and interested agencies that the BPU will lead the SEQR review of the project. Once the lead agency is selected, that agency determines whether an EIS will be prepared. A copy of the “Positive Declaration” issued by the Jamestown Board of Public Utilities (as Lead Agency for the project) indicating that a Draft EIS will be prepared for this project, is included in Appendix A.

1.3.2 Scoping

Once a lead agency has been agreed to (in this case, the BPU), the lead agency begins the formal process of getting public input on the project through scoping. While scoping is optional, the BPU has committed to scoping the project. The SEQR regulations allow for written comments or a scoping meeting; the BPU has done both. The purpose of scoping is to identify the important environmental impacts that are to be considered in the Draft EIS, identify studies needed to understand these impacts, and begin the process of identifying potential mitigation measures and alternatives. During the scoping process, the BPU has sought the input of the public and other involved and interested agencies regarding the project and its impacts. The BPU held two scoping meetings on November 18; the first from 2:00 PM to 5:00 PM at the Love School Gymnasium and the second from 7:00 PM to 9:00 PM at the Washington Middle School Auditorium. Substantive comments regarding the project that were received during the public scoping session, and during the written comment period, have been addressed in this final Scoping Document.


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1.3.3 Draft Environmental Impact Statement

Once scoping is complete, the Draft EIS is prepared. The Draft EIS identifies the relevant impacts of the proposed action, discusses measures to mitigate or lessen these impacts, and evaluates reasonable alternatives to the proposed action. A preliminary Draft EIS outline is included in Appendix B.

1.3.4 Public Comment Period

After the Draft EIS is accepted as adequate by the BPU, it will be provided to the NYSDEC, other involved agencies, and the public for their review and comment. There will be a public review and comment period and the BPU will likely hold a hearing on the Draft EIS.

1.3.5 Final Environmental Impact Statement

Upon completion of the public review period, the BPU will prepare a Final EIS which responds to public comment. The Final EIS includes the Draft EIS, the substantive comments received, responses to these comments and, as appropriate, revisions to the Draft EIS. The final product of the SEQR process is the findings statement, in which the BPU must determine that the proposed action minimizes or avoids environmental impacts to the maximum extent practicable and that the proposed action incorporates practicable mitigation procedures.

1.4 Permits and Approvals

The table on the following page is a preliminary identification of the permits and approvals that may be required for the proposed project. This is not a final list of all applicable permits and approvals; additional permits and approvals may be identified during the EIS/environmental permit process.


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Table 1 Preliminary List of Permits and Approvals for Clean Coal Project

Permit/Approval Agency FEDERAL Title 40 of the Code of Federal Regulations (CFR), Part 52, §52.21, Prevention of Significant Deterioration (PSD) Permit to Construct

USEPA Region 2

STATE Title 6 of the New York Code, Rules and Regulations (NYCRR) Part 201 et seq. – Permit to Construct/Title V Operating Permit Revision

NYSDEC

6 NYCRR Part 596 – Registration of Hazardous Substance Bulk Storage Tanks

NYSDEC

6 NYCRR Part 750 et seq. – Storm Water General Permits for Construction and Operation Activities (Notice of Intent)(1)

NYSDEC

New York State Parks, Recreation and Historic Preservation Law, Section 14.09 – No Impact Determination

New York State Office of Parks, Recreation and Historic Preservation (OPRHP)

LOCAL 6 NYCRR Part 617 (SEQR) – Draft and Final EIS BPU Site Plan Approval City of Jamestown Building Permits City of Jamestown (1) Includes modification of Carlson Plant’s Spill Prevention and Countermeasure Control Plan (SPCC)


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The Carlson Plant burned 112,455 tons of bituminous coal in 2004. Approximately one-half of this amount was delivered to the site by truck, with the balance provided by rail (on average about one rail shipment per week). Rail shipments of coal are unloaded at a rail siding located underneath the Third Street bridge (north of the Chadakoin River and west of the Carlson Plant) onto trucks which then

2.0 PROJECT DESCRIPTION

2.1 Existing Carlson Plant

2.1.1 Site Location

The Carlson Plant is located at 136 Steele Street in the City of Jamestown, Chautauqua County, New York. As shown on Figure 1, the Carlson Plant is bordered to the south by Steele Street, to the north by the Chadakoin River, to the west by Sprague Street, and to the east by the BPU office buildings, warehouses and garages. Access to the site is from Steele Street.

2.1.2 Combustion Units and Coal Handling System

The Carlson Plant operates four low-sulfur pulverized coal-fired boilers (Nos. 9, 10, 11, and 12), along with auxiliary coal and ash handling equipment, a natural gas-fired combustion turbine with a heat recovery steam generator (HRSG) with supplementary-fired duct burners, and a small natural gas-fired auxiliary boiler. Boiler No. 11 has not operated since 2001. The coal boilers and HRSG provide steam through a common header which can feed either one or both of the two steam turbine generators (Nos. 5 and 6), each rated at less than 25 MW. A portion of the steam from the No. 6 turbine generator is also used to heat hot water for the District Heating System (see section 2.1.4). The gas turbine can operate in either simple cycle mode (HRSG is bypassed and steam is not produced) or combined cycle mode (HRSG is used and steam is produced).

Particulate emissions from the four boilers are controlled by individual electrostatic precipitators (ESPs). Two of the boilers, Nos. 9 and 12 (rated at 190 and 297 million Btu per hour [MMBtu/hr]), are vented into a common stack, referred to as the North Stack. The other two boilers, Nos. 10 and 11 (each rated at 190 MMBtu/hr), are vented into the South Stack. The height of both stacks is 195 feet above grade.

The combustion turbine (General Electric LM6000) has a nominal capacity of 43 MW and a heat input rate of 410 MMBtu/hr at ISO conditions (ambient temperature of 59oF, 60 percent relative humidity, and a pressure of 14.7 pounds per square inch). The HRSG has a natural gas supplemental duct burner rated at 144 MMBtu/hr. During simple cycle operation, heat from the gas turbine exhaust is not recovered in the HRSG. During combined cycle operation, the turbine exhausts through the HRSG. Steam generated in the HRSG is sent to the existing steam turbines to generate additional electricity as needed.

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Steam generated by the boilers and the HRSG is condensed in a closed-loop system. In this system, water circulating through condenser tubes absorbs heat from the steam exhausted from the plant’s steam turbines. The circulating water, which does not come in contact with the steam, is heated in the process of condensing the steam. The circulating water is sent to mechanical-draft cooling towers where the heated circulating water is cooled by being brought into direct contact with cooler ambient air. In the process, some water is evaporated into the air that flows through the cooling tower, sometimes resulting in the formation of a visible vapor cloud over the tower. The circulating water that is evaporated into the air must be replaced with fresh water; the source of this make-up water is the

transport the coal to the site via Sprague and Steele Streets. Upon being dumped into a receiving hopper, the coal can be conveyed for immediate use into one of four bunkers with a total storage capacity of 1200 tons or be stored in a 4000 ton capacity silo. There is no open storage of coal. All coal transport within the plant is via totally enclosed conveyors.

2.1.3 Electrical Generation

The Electric Division of the BPU serves the City of Jamestown, the Villages of Celoron and Falconer, and portions of the Town of Ellicott. The winter peak electrical need in the BPU service area is approximately 100 MW. This need is met through a combination of purchased hydroelectric power (over 80 percent) from the New York Power Authority and power generated by the Carlson Plant. The electricity produced by the Carlson Plant travels out to eleven neighborhood distribution substations located throughout the service territory at 13.8 kilovolts (kV). When the Carlson Plant is producing more power than is needed by its customers, the excess power is sent to the New York power grid over Niagara Mohawk lines.

2.1.4 District Heating System

The Carlson Plant also provides the thermal energy for the City of Jamestown’s District Heating System. More than 60 customers representing a cross-section of businesses, industries, churches, schools, housing facilities, and not-for-profit agencies currently use approximately 16 MW thermal of district heating power. The system works as follows. A portion of the “live” steam generated by the coal boilers and the HRSG is extracted from the No. 6 turbine generator and is passed through a heat exchanger to thermally heat the water in the system. Steam from the main steam line to the steam turbine generators is used for an auxiliary topping heat exchanger that provides additional heat if required. In addition, a portion of the steam is extracted from the No. 6 turbine generator. During periods when the coal boilers and combustion turbine’s HRSG are not operating, the auxiliary boiler is operated to heat the water. The heated water is sent through more than 11 miles of pipelines to the customers who use their own heat exchangers to draw energy from the water to heat buildings, provide domestic hot water, and for industrial purposes. The water returns to the plant to repeat the cycle.

2.1.5 Water Uses, Wastewater and Storm Water


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Chadakoin River. Moreover, the constant evaporation of circulating water concentrates solids in the water that remains in the closed-loop system, creating the need for water to be released, or blown down, from the system and replaced with fresh water (again, from the river) to maintain concentrations at acceptable levels. Water cascades down through the cooling tower into a cooling basin that is located on the BPU site and separated from the Chadakoin River. Make-up water is added to the cooling basin as needed to maintain the water level. At the peak make-up rate (700 gallons per minute [gpm], or approximately one million gallons per day [mgd]], river water flows through the intake structure at less than 0.5 feet per second (fps).

The water that is heated to steam in the boilers and HRSG must also be blown down to remove impurities. The make-up for the boiler water (approximately 20,000 gallons/day), as well as minor amounts of potable water for sanitary uses, is obtained from the BPU’s Water Division. The water is obtained from seven artesian wells located just north of Falconer that draw water from the Cassadaga aquifer. The BPU also operates four artesian wells in Poland Center, drawing water from the Conewango aquifer. These two aquifers have watersheds of 140 and 290 square miles, respectively.

Operation of the Carlson Plant results in the generation of various wastewater streams, all of which are sent to BPU’s Publicly Owned Treatment Works (POTW); i.e., the plant does not discharge any wastewater to the Chadakoin River. The largest of these streams is the blowdown from the cooling tower (peak rate of approximately 0.2 mgd).

Storm water generated on the Carlson Plant site is directed to the plant’s cooling basin; i.e., it is not discharged to the Chadakoin River. Storm water generated at the existing railcar unloading area west of the Carlson Plant percolates into the surrounding ground (note that the coal is unloaded directly from the railcars to trucks for immediate transport to the Carlson Plant, i.e., there is no temporary placement of coal on the ground).

2.2 Proposed Clean Coal Project

The Clean Coal Project is comprised of the Clean Coal Unit and the relocation of the BPU’s offices, warehouses, and garages. A brief description of these components is provided below.

2.2.1 Clean Coal Unit

Overview

The Clean Coal Unit will be comprised of one CFB boiler, an advanced emissions control system, a fuel and ash handling system, a 40 MW steam turbine generator, supporting infrastructure, and connections to the district heating system. Figure 2 provides a preliminary site plan of the unit (Area C does not include the fueling station which is operated by the BPU Water Department). Figure 3 provides a picture of a typical CFB boiler. Figure 4 is a preliminary rendering of the clean coal project.

Figure 3 Picture of a Typical Circulating Fluidized Bed Boiler

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Figure 4

Preliminary Rendering of Clean Coal Project

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The CFB boiler and material storage area will be located east of the existing power plant buildings, in an area currently occupied by the BPU’s office, garage, and warehouse buildings and parking area. The BPU currently uses land owned by the BPU on the south side of Steele Street for equipment storage, coal truck weighing, and vehicle fueling. This area will be expanded as part of the Clean Coal Project

The BPU intends to operate the CFB boiler as its base unit for electricity and district heat. Additional electrical and hot water needs will be met by operating the existing units. Once the Project has completed its shakedown period and is fully operational, existing coal-fired boilers No. 10 and No. 11 will be permanently shut down.

There are significant advantages to locating the Clean Coal Unit on BPU property adjacent to the existing Carlson Plant. The use of this site will provide substantial additional efficiencies, in that it will enable the BPU to make use of existing infrastructure and staff. For example, existing coal handling facilities as well as the existing cooling towers and water systems can be reused for the CFB. In addition, the district heating and transmission and distribution infrastructures are already in place at the Carlson Plant and can be easily accessed to support the new plant. Because the area is primarily industrial and commercial, and a power plant is already located adjacent to the Clean Coal Unit site, the noise from the new plant will be consistent with existing conditions.

Fuel Delivery and Storage

In a CFB boiler, crushed coal and other fuels are mixed with limestone and fired in a process resembling a boiling fluid. The CFB boiler will have a maximum heat input rate of approximately 500 MMBtu/hr and will be capable of firing a mixture of fuels, including bituminous coal, petroleum coke, waste wood, and other opportunity fuels (including chipped tires). The CFB boiler will have the capacity on a heat input basis to burn these solid fuels in various proportional combinations, including up to 100 percent coal, up to 100 percent petroleum coke, not more than 25 percent processed wood, and not more than 20 percent chipped tires (referred to as tire derived fuel, or TDF). The nominal throughput values corresponding to these maximum proportional amounts for the above types of fuel are about 20 tons/hr for coal, 15 tons/hr for petroleum coke, 8 tons/hr for processed wood, and 3 tons/hr for TDF.

Delivery of the coal and coke fuels will be by truck and/or railcar. Truck delivery will utilize the existing scale, the existing coal receiving hoppers, and the existing belt conveyor system between the existing receiving hoppers and first transfer tower. The existing receiving hoppers are enclosed by a three-sided structure with a roof for weather protection and dust control. Railcar delivery will be at a new railcar unloading station (RUS) located along a rail siding on the north (opposite) side of the Chadakoin River across from the plant (shown in Figure 2, Area A). This new system will eliminate the need to transport the coal by truck from the current railcar unloading site to the Carlson Plant, thereby resulting in a significant reduction in noise impact associated with this activity. The new RUS will include an excavator with above grade hoppers for open-top railcar unloading. Stationary machinery and/or


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mobile equipment will be provided for moving and positioning railcars during unloading. Sufficient entry and exit track length will be provided at the RUS to manage block shipments of 1,000 tons (10 railcars at 100 tons each).

A new (enclosed) belt conveyor system will be installed to transport the fuel receipts above grade level from the new RUS on the north side of the river to the first transfer tower of the existing coal conveyor system on the south (plant) side of the river. Another new (enclosed) belt conveyor system will be installed to transport both truck and railcar delivered fuel (coal and petroleum coke) from that same existing transfer tower either to the new fuel (coal and petroleum coke) storage facilities, or directly to the boiler bunker in the new plant. The new coal/coke storage facilities will have a total fuel storage capacity of 5,000 tons, which includes one 1,000-ton silo and one 4,000-ton silo. The coal storage silo will have the capacity to feed the CFB at base load for approximately eight days. A new reclaim belt conveyor system will be provided to transport fuel from the two new silos to the bunker in the new plant. When burning a mixture of coal and petroleum coke, metering systems at each silo will be able to provide the desired ratio of coal and coke to the boiler bunker. A new crusher with bypass equipment will be installed in the new reclaim belt conveyor system to enable correct fuel sizing. All of the material handling components of the new fuel (coal and petroleum coke) handling systems will be designed for a conveying capacity of 250 tons/hr.

Delivery of processed wood fuel will be by truck. The truck unloading station for this fuel will be located inside a new processed fuel storage building. The processed wood will be delivered properly sized for burning in the CFB boiler. A front-end loader will be used inside the storage building to place truck dumped fuel into a new receiving hopper. From the receiving hopper, a new (enclosed) belt conveyor system will deliver the processed wood to a set of new live bottom metering bins located in the new plant. The metering bins will control the flow of fuel into the boiler. A new (enclosed) overage return belt conveyor system will be installed to return the overage of fuel that is not used by the metering bins back to the new fuel storage building. The processed wood fuel handling system will be designed for a conveying capacity of 10 tons/hr.

The TDF also will be delivered by truck to the new processed fuel storage building. The TDF (as delivered) will be properly sized for burning in the CFB. The same new equipment (i.e., front-end loader, receiving hopper and supply/return belt conveyor systems) used for handling processed wood fuel will be used for handling the TDF.

Limestone Delivery and Storage

The new circulating fluidized bed (CFB) boiler will use crushed limestone to reduce sulfur dioxide (SO2) and other acid gas emissions (including hydrogen chloride [HCl], sulfuric acid mist [H2SO4], and fluorides [as HF]). The limestone will be added to the CFB boiler above the dense phase bed section of the boiler. The nominal top size of the limestone sorbent is 1/8-inch. The CFB boiler will be furnished with an 800-ton limestone storage silo inside the boiler house. The silo will be equipped with


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feeders for metering limestone to a pneumatic conveyor system that transports the limestone to the boiler.

A new limestone handling system will be installed to receive delivery of (high calcium) limestone materials with two significantly different size gradations and different moisture contents. One of the materials (coarse limestone) will have a size gradation corresponding to coarse aggregate with a nominal top size of 2 inches and a moisture content of up to 10 percent. The other material (fine limestone) will have a nominal top size of 1/8-inch and a moisture content of not more than one percent. The new limestone handling system will be capable of receiving both types of material. The fine limestone will be unloaded and conveyed directly to the limestone storage silo in the boiler house; whereas, the coarse limestone will be unloaded and processed onsite to meet boiler feed size and moisture requirements before being conveyed to the limestone storage silo.

The fine limestone material will be delivered to the plant by tank trucks equipped for pneumatic unloading. A pneumatic conveyor system will be installed to transport the fine limestone from a new tank truck unloading station directly into the limestone storage silo. The trucks will connect to the pneumatic system intake pipe at grade level. The conveyor pipe run will extend from the truck unloading station to the conveyor discharge outlet at the top of the silo. The silo will be equipped with a bin vent filter for removing dust from the air that is used to convey the limestone to the top of the silo. The clean air from the bin vent filter will discharge to the atmosphere. The fine limestone handling system will be designed for a conveying capacity of 20 tons/hr.

Delivery of coarse limestone material will be by truck and/or railcar. Railcar shipments will be received at the new RUS to be located on the north (opposite) side of the Chadakoin River across from the plant. The coarse limestone will be unloaded from the railcars at the new RUS and transported across the river using the same belt conveyor system that will be used for unloading and transporting railcar shipments of fuel (coal and petroleum coke). The limestone will be conveyed across the river to the existing transfer tower on the plant (south) side of the river where a diverter gate and transfer chute will be installed to direct the coarse limestone to a new truck loading station adjacent the existing transfer tower. The new truck loading station will include a surge bin equipped with a gated chute for loading the coarse limestone directly into haul trucks. The trucks will transport and dump the coarse limestone either at a new 500-ton coarse limestone storage building, or at the receiving hopper of a new (enclosed) limestone preparation facility. At this facility the coarse limestone will be crushed and dried to a size gradation and moisture content corresponding to fine limestone material. The fine limestone will be transported from the preparation facility to the top of the limestone storage silo by a pneumatic conveyor system similar to the one installed to unload tank truck shipments of fine limestone directly into the limestone storage silo in the new boiler house.

If limestone deliveries are late, coarse limestone will be reclaimed from the stockpile in the new coarse limestone storage building and processed in the new limestone preparation facility at a nominal rate of 20 tons/hr. A front-end loader and trucks will be used to reclaim and transport the coarse limestone to the truck unloading station at the new limestone preparation facility.


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Ash Generation and Handling

When operating at full load, the CFB boiler will produce various ash residues at a combined rate of about 10 tons/hr. These ash residues will accumulate at three locations in the new plant, i.e., the fluid bed combustion chamber, the tubular air heater, and the baghouse. At the first location, discharge ports on the bottom of the dense phase fluid bed section of the boiler will enable hot ash to be removed from the bed of burning material. A water-cooled system will be used to reduce the temperature of this hot ash while transporting the ash from the boiler bed section to transfer bins. This combustion residue is referred to as bottom ash. At the second location, hoppers beneath the tubular air heater will collect ash that falls out of the flue gas stream as it passes through the heater. At the third location, hoppers located under the baghouse will collect ash that is removed from the flue gas as it passes through the baghouse. The ash residues collected in the air heater and baghouse hoppers are referred to as fly ash.

A new ash handling system will be installed to load, transport, store and unload the bottom ash and fly ash residues produced by the CFB boiler. The system will include two ash storage silos, pneumatic conveying equipment to transport the bottom ash and fly ash from the collecting bins and hoppers to the ash storage silos, air/ash separation equipment at the top of each silo, and an ash unloader at the bottom of the each silo. The pneumatic conveying equipment will include ash intake valves at each ash bin/hopper outlet connection to control the flow of solids to three ash pickup branch conduits serving the three bin/hopper locations. The ash pickup branch piping will connect to a main conveying conduit, which will transport the ash to the storage silo. A control system will be provided to automatically sequence the opening and closing of the ash intake valves so that the ash bins/hoppers do not overfill.

The ash conveying equipment will include conveyor piping from each ash intake valve to the ash separating equipment located on top of the ash storage silo. A motor driven blower installed at the silo unloader floor level will provide air flow for ash conveying. The blower will draw air through the ash transport piping circuits. When an ash valve is opened, the ash will flow from the hopper by gravity and become entrained in the air stream in the branch piping. The entrained ash is then conveyed pneumatically to the ash separating equipment at the top of the silo. The ash and conveying air will pass through a bag filter/separator where the ash is removed from the air stream, and discharged into the silo. The air that is drawn through the filter/separator will be monitored for dust, and the blower will be shut down if dust is detected in the air flow from the filter/separator. An outlet silencer will be installed on the discharge side of the blower to reduce noise. The exhaust air from the blower will discharge to the atmosphere.

Ash that is deposited in the storage silo will be removed through a gated outlet at the bottom of the silo, and then pass through a pugmill unloader. Ash will be conditioned with water in the unloader to reduce dusting before being discharged into trucks for offsite disposal.


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Air Pollution Control

As discussed previously, limestone will be injected in the CFB combustion zone to remove sulfur oxides and other acid gases. Oxides of nitrogen (NOx) will be controlled by the CFB combustion process and through a selective non-catalytic reduction system (SNCR). The combustion gases will then pass through a fabric filter baghouse for control of particulate matter before being vented to a new stack. The BPU expects the height of the CFB stack to be between 300 and 325 feet above grade and the diameter to be similar to the diameter of the existing North and South stacks (10 feet).

District Heating System

The new steam generator unit will provide a new source for heating the district hot water system. The steam turbine generator will have a controlled steam extraction port designed to provide 80 MMBtu to the district heating system. A heat exchanger will be used to transfer heat from controlled extraction steam to the hot water district heating system. New hot water piping will be constructed from the new heat exchanger to the main district heating system piping.

Water Uses, Wastewater and Storm Water

Steam generated by the CFB boiler will be condensed in the existing closed-loop system and cooling towers. The CFB unit, by itself, will require approximately 0.92 mgd of make-up water for the cooling tower from the Chadakoin River and up to an additional 20,000 gallons/day of potable water from the BPU’s Water Division. The BPU proposes to use the same intake screen system that is currently in use at the Carlson Plant (i.e., an outer 5/8-inch mesh screen and an inner 3/8-inch mesh screen). Wastewater from the clean coal unit, including approximately 0.2 mgd cooling tower blowdown, will be integrated with the wastewater streams from the existing Carlson Plant prior to discharge to the POTW.

Storm water from industrial areas of the Clean Coal Unit site will be directed to the cooling basin, consistent with the manner in which the existing plant manages storm water. Storm water from the railcar unloading area currently either percolates into the ground or flows over land into the Chadakoin River. In the future with the project, storm water will be managed in a manner consistent with NYSDEC storm water management guidelines. One design under consideration is to collect the storm water from the new railcar unloading area and pump it across the river to the cooling basin.

2.2.2 Relocation of BPU Corporate Offices, Warehouses, and Garages

The BPU anticipates either renovating an existing building or constructing a new building in Jamestown and relocating its support services to the new space. The BPU has begun searching for this space in proximity to its present location. The site must be large enough to accommodate BPU corporate offices, warehouses, and garages and equipment, sewer maintenance garages and equipment, and to


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add water department employees and garages, while providing for ease of access. The addition of the water department to the BPU corporate headquarters has long been a goal of the utility. This move will allow the BPU to consolidate the water division with the existing services and provide enhanced workforce management efficiencies.

The BPU will prepare a separate scoping document and hold a separate scoping meeting to address the relocation of its support services. The potential impacts associated with the relocation will be addressed in either the Draft EIS or in a supplement thereto.

2.2.3 Construction of the Clean Coal Unit

Following the relocation of personnel, offices and equipment to the new location, the existing corporate office building, warehouses and garages will be demolished. After the demolition and debris removal work is complete, there will be minimal additional site preparation work required for the Clean Coal Unit. The site is currently flat and reasonably level, varying by approximately 2 feet in elevation from the east end of the site to the west end, a distance of approximately 1000 feet. However, the site is bounded on the south by Steele Street, which is approximately 10 feet higher in elevation than the site. To maximize the usable area at the site, a new retaining wall could be constructed along the south edge of the site, just north of Steele Street.

Excavation will be required for building and equipment foundations, utilities, circulating water lines, cooling tower basin expansion, etc. However, there will not be any large, deep excavations because there will be no basements in any of the new buildings. It is anticipated that the foundations for the buildings, silos, stack, baghouse, and transfer towers will all be supported on driven steel piles or caissons. The BPU does not anticipate the need for any rock excavation or blasting during the demolition or excavation work.

There will be three areas designated for construction laydown, staging and parking. These areas include the construction site itself, the BPU owned area south of the site across Steele Street where the existing BPU truck scales and BPU Water Department’s fueling station are located, and other off site locations including the following:

Anticipated Activity Off Site Location

Parking Long Term Staging

Long Term Laydown

City owned parking ramp and surface lots X Harrison Street Substation X X X BPU Solid Waste Division – River Street Location X

Clinton Street Storage Area (NW corner of Clinton Street and Isabella Avenue) X X


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Note that the truck scales and fueling station across Steele Street from the site will continue to remain in service during the construction period.

City owned parking garages and surface lots include five surface lots and one parking ramp totaling 465 spaces. The City also has an additional 209 on street metered spaces located primarily downtown.

All contractor trailers will be located either in the designated areas south of Steele Street or at the east end of the construction site. There will be minimal on-site parking, and that will be available only at the contractor trailer areas. The areas listed in the above table should adequately accommodate the vehicles for the anticipated number of construction workers (average of 300 during the two-year construction period, with a peak work force of 600). Contractors will provide transportation for the construction workers between the various parking areas and the construction site.

Long-term storage and staging of materials and equipment will be at the designated area in the above table. Short-term storage, laydown, and staging of materials and equipment will be in limited areas designated on the site and in the area across Steele Street south of the site.


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3.0 POTENTIALLY SIGNIFICANT ADVERSE ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

During review of this project, the Lead Agency identified the following potentially significant environmental impacts associated with the project.

1. The BPU anticipates that aggregate air emissions rates (per unit of energy produced) from the new unit will be approximately one-tenth the emissions from the existing coal-fired units. The BPU will also permanently shut down coal boiler Nos. 10 and 11 once the Clean Coal Project has completed its shakedown period and is fully operational, thereby eliminating emissions from these existing units once the new unit is built. Assuming the CFB unit operates at full load for 95 percent of the year (95 percent annual capacity factor) and existing coal boilers Nos. 9 and 12 operate at a 30 percent annual capacity factor, there will be a reduction in total facility SO2 and NOx emissions compared to 2002-2003 levels. The BPU anticipates that pollutants emitted by the proposed project will include trace elements contained in fuels, such as heavy metals, and various organic compounds. The emissions of these compounds will be quantified. The Draft EIS will demonstrate that the impact of these emissions on air quality will be below established health- and welfare-based guidelines and standards.

2. The BPU will continue not to discharge water into the Chadakoin River after implementation of the proposed project. Although there is the potential for increased water withdrawal from the Chadakoin River for cooling tower purposes, the intake velocity will remain below 0.5 feet per second (fps) (the intake velocity to meet the impingement performance standard set out in USEPA’s Section 316(b) rule).

3. The project structures will be consistent with surrounding land uses. However, the proposed stack height will be taller than the existing stacks.

4. The type of traffic and noise impacts from the new plant will be consistent with existing site use. Nonetheless, traffic and noise impacts associated with the Carlson Plant under current and projected operating conditions will be evaluated as part of the EIS.

The Draft EIS for the proposed project is intended to be the primary source of information for the public and involved and interested agencies regarding the potential environmental effects of the project. The BPU will utilize existing plant data and supplement it with project-specific studies, to fully assess the potential impacts of the Clean Coal Project. The BPU will also identify how impacts are to be avoided, minimized, or mitigated in each of the impact categories analyzed.

Provided below is an identification of the issues to be analyzed in the Draft EIS, the approaches used to evaluate their impact, and potential mitigation measures. The scope of the Draft EIS reflects public


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and regulatory comments received during the scoping process and may be expanded further if additional issues are identified as the Draft EIS is prepared.

3.1 Air Resources

Construction and operation of the proposed project will result in emissions of various compounds into the air. An analysis will be conducted to quantify the expected emissions and to demonstrate that the predicted air quality impacts are below established health and welfare-based ambient standards and guidelines.

3.1.1 Construction

Construction of the Clean Coal Project is expected to result in the emissions of fugitive dust caused by construction activities. In addition, the construction activities will generate small quantities of engine exhaust emissions. The main sources of fugitive dust during the construction of the project will include the following:

• Earthwork, including excavation, bulldozing, landscaping, grading, and other activities performed by heavy equipment;

• Demolition and removal of the existing office buildings, warehouses, and garages at the Carlson Plant site;

• Vehicles traveling on unpaved (and to a lesser extent on paved) surfaces (re-entrained road dust); and

• Wind erosion of exposed soils.

Emissions will be considered and quantified where practicable using readily available emission factors (such as from USEPA’s Compilation of Air Pollutant Emission Factors, AP-42) and expected construction activities. Methods to minimize construction-related emissions will be evaluated, including:

• Covering or containerizing loads on all vehicles transporting loose aggregate and material to/from the site to minimize spillage and fugitive dust generation.

• Applying gravel cover to all regularly traveled, unpaved areas on site; regularly maintain through re-grading and re-application as needed until roadways are paved.


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• Applying water to on-site roads at regular intervals during the construction phase through use of a water truck. During dry and windy weather conditions, the application of water will occur more frequently.

• Providing daily monitoring of the site access road entrance at Steele St. for spillage or carry-out of loose dirt, mud, etc. Clean up all materials deposited on public roadways from construction-related activities as soon as practical.

• Controlling fugitive dust generation from stockpiled soil due to wind erosion, etc. through measures such as covering the piles with a tarp or regular watering.

The BPU does not expect that demolition activities will require the removal of regulated asbestos-containing material (RACM) (BPU records indicate that there is no RACM in the existing offices, warehouses, and garages on the plant site.) Nevertheless, should it be determined that demolition activities will require the removal of RACM, the potential for emissions of asbestos will be minimized to the extent practicable in strict accordance with regulations under 6 NYCRR Part 56 and 40 CFR Sections 61.145 and 61.150. In addition, disposal of the RACM would be conducted in accordance with 6 NYCRR 360-2.17(p) requirements.

3.1.2 Operation

Regulatory Requirements

The impact of the facility on air quality will be considered in depth. The Draft EIS will analyze CFB stack emissions and fugitive particulate emissions associated with fuel, limestone and ash storage and handling operations and assess their impacts on ambient air quality and the environment. This analysis will also address the regulatory requirements for the facility.

Regulatory programs for which impacts will be reviewed include:

• Federal Prevention of Significant Deterioration (PSD) permit regulations for impacts in areas that meet the applicable National Ambient Air Quality Standards (NAAQS), referred to as “attainment areas” (40 CFR 50.21);

• Federal New Source Performance Standards (NSPS) for electric utility steam generating units (40 CFR Part 60, Subpart Da) and for coal handling systems (Subpart Y);

• Federal Acid Rain program requirements for SO2 and NOx (Title IV of the Clean Air Act);

• Maximum Achievable Control Technology (MACT) requirements (40 CFR Part 63, Section 112(g));


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• New York State air pollution control regulations requiring a permit to construct and the Title V operating permit program (6 NYCRR Part 201);

• New York State air pollution control regulations for new source review in areas that do not meet applicable NAAQS, referred to as “nonattainment areas” (6 NYCRR Part 231);

• New York State Implementation Plan (SIP) for sulfur dioxide (SO2) (6 NYCRR Part 225) and particulate matter (PM), opacity, and nitrogen oxides (NOx) (6 NYCRR Part 227);

• New York State Acid Deposition Reduction requirements (6 NYCRR Parts 204 and 237 for NOx and Part 238 for SO2); and

• New York State Clean Air Initiative – in April 2003, New York proposed an initiative focused on the reduction of carbon dioxide (CO2) emissions from power plants in the Northeast. This initiative called for the development of a market-based emissions trading system to require power plants to reduce emissions of this greenhouse gas. The goal of this initiative is to reach an agreement by April 2005 on a market-based cap-and-trade program that will initially focus on power plants.

The regulatory programs identified above impose substantial analytical requirements on the development of this project. The methodology to be used in performing the air quality analyses for the proposed project will be reviewed and approved by the NYSDEC and USEPA Region 2 (for those pollutants subject to PSD review).

Pollutants for Analysis

The federal Clean Air Act (CAA) requires that NAAQS be set for “criteria” pollutants, defined as air contaminants that have been demonstrated to have the potential for widespread adverse impacts on human health. In response to this mandate, the USEPA has named six criteria pollutants and established maximum allowable ambient concentrations to aid in controlling them. These pollutants are: SO2, nitrogen dioxide (NO2), particulate matter sized 10 microns in diameter and less (PM10), carbon monoxide (CO), ozone (O3) and lead (Pb). In addition, the USEPA promulgated a new NAAQS for particulate matter sized 2.5 microns and smaller (PM2.5) on July 17, 1997. Compliance with the PM2.5 standard at the federal level is not yet required (the USEPA policy is to use compliance with PM10 as a surrogate). However, the NYSDEC has developed a policy for addressing PM2.5 impacts (CP-33). The NAAQS are designed to protect the public health and welfare with an adequate margin of safety. The project area has been classified by the USEPA as an attainment area for all of the criteria pollutants with the exception of O3 (the entire State is part of the ozone transport region and, as such, is treated as a nonattainment area for O3). The NYSDEC has established New York Ambient Air Quality Standards for the criteria pollutants and for the following additional pollutants: total suspended particulates, beryllium, fluorides, and hydrogen sulfide.


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The USEPA and the NYSDEC also regulate, on a case-by-case basis, pollutants for which no ambient air quality standards have been established. These are called “non-criteria” pollutants. The NYSDEC has developed short-term and annual guideline concentrations (SGCs and AGCs) for non-criteria pollutants as part of their Air Guide-1 policy. Non-criteria pollutants that are expected to be emitted by the proposed project include trace elements contained in the fuels, including heavy metals, and various organic compounds.

The air quality evaluation will also address the greenhouse gas CO2.

Baseline Data

Baseline emission rates for the Carlson Plant will be obtained from the annual emissions statements provided to the NYSDEC. Emission rates for pollutants not covered by the emission statements will be estimated based on stack test data, fuel firing records and readily available emission factors (e.g., US EPA’s AP-42 emission factor database).

The NYSDEC operates ambient air quality monitoring sites at numerous locations throughout the state. The nearest NYSDEC ambient air quality monitoring sites relative to the Carlson Plant, as well as the pollutants monitored at those sites, are summarized below.

Location Relative to Carlson Plant Monitoring Site Distance (km) Direction (deg)

Pollutant(s) Monitored

Jamestown (0602-07) 1.3 104 SO2(1)

Westfield (0675-01) 35.8 311 SO2, PM10, PM2.5, O3

Dunkirk (0601-04) 41.3 350 SO2, O3

Buffalo (1401-18) 94.2 25 CO, NO2

Niagara Falls (3102-25) 111.6 13 PM10

(1) Sampling discontinued on July 12, 2001

The NYSDEC also conducted PM10 sampling at the Jamestown monitoring site (0602-07); however, this sampling was permanently discontinued at the end of 1998 because of continually low measured concentrations. Air quality concentrations measured at Dunkirk, Buffalo, and Niagara Falls are expected to be the same or higher than in the vicinity of the Carlson Plant because of the presence of similar or greater concentration of industrial sources in these areas. The NYSDEC monitoring data will therefore provide a conservative estimate of baseline air quality conditions in the proposed project’s impact area.

A description of climatology and meteorology of the Jamestown area will be provided based on meteorological data measured at the County Airport in Jamestown and other readily available data sources (e.g., Climate of the States).


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Source Data for the Clean Coal Project Sources

Emission rates and flue gas characteristics (flow rate, temperature) for the CFB boiler will be estimated for a range of potential operating conditions based on a combination of the performance of the proposed air pollution control system, design characteristics of the fuels, performance specifications for the boilers, and other relevant engineering data. Data will be developed for two fuel firing scenarios: 100 percent coal firing and a worst-case mixture of coal, petroleum coke, wood, and other opportunity fuels such as chipped tires. Estimates of particulate emission rates associated with the controlled material handling and storage operations (e.g., loadout into the coal and petroleum coke storage silos, material conveyor transfer points) will be made based on design particulate matter control device outlet grain loadings and flow rates and frequencies of operation. Estimates of particulate matter emission rates for uncontrolled material handling and storage operations (e.g., limestone storage) will be made based on published emission factors (USEPA AP-42 and others), where available, engineering judgment, and frequencies of operation. Expected future emission rates at the Carlson Plant (after implementation of the project) will be compared to existing emission rates, both in terms of pounds per megawatt and total mass emissions (tons/yr).

Air Pollution Control Technology Evaluation

The existing Carlson Plant is classified as a major stationary source as defined by the federal PSD regulations. The significantly cleaner and more efficient CFB boiler will enable the BPU to operate the Carlson Plant so that there is projected to be a reduction in the facility’s annual emissions relative to current levels (determined from the average emission rates during the two-year baseline period [e.g., 2003 and 2004]), with the exception of CO and volatile organic compounds (VOC) and possibly PM10. Based on this approach, the BPU expects that the Clean Coal Project will be subject to the federal PSD permitting requirements for only CO and possibly PM10. As required by the PSD regulations, BPU will conduct a Best Available Control Technology (BACT) evaluation to determine the best level of control for that pollutant, taking into account its environmental, economic and energy consumption impacts.

The proposed project will be subject to Part 231 nonattainment new source review if the project’s potential emissions of VOC or NOx are greater than 40 tons/yr and if the net change in emissions of VOC or NOx are above the significant emission thresholds (40 tons/yr for each pollutant). (Nonattainment review applies to VOC and NOx emissions because these pollutants are precursors to the formation of O3, which is the nonattaining pollutant.) Based on preliminary estimated emission rates and the future shutdown of coal boiler Nos. 10 and 11, the BPU expects that the Clean Coal Project will not be subject to nonattainment new source review for either VOC or NOx.

Regardless of PSD or nonattainment new source review applicability, SEQR requires the applicant to mitigate environmental impacts to the maximum extent practicable. Based on this requirement, the BPU will evaluate alternative pollution control techniques for the CFB boiler (e.g., selective catalytic reduction [SCR] for the control of NOx, polishing scrubber for additional control of acid gases) In


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addition, the BPU will evaluate alternative means of controlling particulate emissions from the material handling sources, including coal dust from coal cars.

Air Quality Impact Analysis

Computer models approved by the USEPA and the NYSDEC, including the conservative complex terrain screening model CTSCREEN and the more refined Industrial Source Complex Short-Term (ISCST3) dispersion models, will be used to assess air quality impacts associated with emissions from the proposed project (CFB boiler and material handling and storage emissions). The computer models will be set up to be representative of the Jamestown area and to best describe the potential air quality impacts in the vicinity of the site. The specific modeling approach will be described in detail in a dispersion modeling protocol that will be submitted to the NYSDEC and USEPA for review and approval as part of the air permitting process.

The ISCST3 dispersion model will predict pollutant concentrations at an array of locations, called receptors, placed within the proposed project’s expected impact area. It is expected that the receptor array will extend outward from the Carlson Plant to a maximum distance of 20 kilometers (km). Five years of hourly surface meteorological data (wind speed, wind direction, temperature, cloud cover) from the Chautauqua County Airport located approximately 7 miles north of the Carlson Plant will be used in conjunction with concurrent upper air data from Buffalo International Airport (the nearest site with representative data). The CTSCREEN model uses an array of hypothetical meteorological conditions to estimate air quality concentrations at receptors where the terrain elevations are above the height of the stack (called complex terrain receptors).

If a modeled concentration exceeds a very low level (called the significant impact level, or SIL), it will be necessary to model the emissions of other major background sources to determine whether the proposed project, in conjunction with the contribution of other major sources and regional background concentrations, will exceed the applicable NAAQS. USEPA and NYSDEC modeling guidelines require consideration of sources that are located within a radius equal to the farthest distance to the proposed project’s impact above the SIL plus an additional 50 km. Model input data for these background sources will initially be obtained from NYSDEC and Pennsylvania. Screening modeling will then be conducted to limit the number of background sources to only those that will contribute significantly to the total modeled concentrations. Once the list of background sources has been finalized, BPU will verify the source data in accordance with NYSDEC's Air Guide-36. The final inventory will be provided to the NYSDEC for approval.

Maximum short-term and annual modeled concentrations will be compared to NYSDEC’s Air Guide-1 guideline concentrations.

The NYSDEC is requiring an analysis of PM2.5 emissions pursuant to their CP-33 policy. (This policy applies only to those projects that are subject to review under SEQR.) The PM2.5 analysis will be conducted with PM10 emission rates as recommended by NYSDEC. In accordance with the policy,


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NYSDEC will review modeling results to make a determination if the project PM2.5 emissions could potentially have an adverse impact on the public. Because the proposed project’s annual potential PM10 emissions will likely be greater than 15 tons (even though there will not be an increase in PM10 emissions at the facility), the potential consequences of secondary formation of PM2.5 will be analyzed in accordance with the policy.

The State of New York enacted the State Acid Deposition Control Act (Environmental Conservation Law [ECL] Article 19, Title 9, enacted in 1984) in response to concerns over acid rain impacts in sensitive areas. In accordance with this act, the BPU will quantify the proposed project's contribution to the deposition of sulfates and nitrates at sensitive receptors located in New York and nearby States in accordance with NYSDEC guidelines and compare these deposition rates to those associated with the existing Carlson Plant.

The use of Selective Non-catalytic Reduction (SNCR) to control NOx emissions from the CFB boiler will require the storage and use of aqueous ammonia at the site. (BPU expects to store aqueous ammonia at a concentration of less than 20 percent.) The tank containing aqueous ammonia will be registered in accordance with 6 NYCRR Part 596 regulations. The tank will be located within a fully contained and diked concrete storage area, and the holding capacity of the containment area will be 110 percent of the capacity of the tank. In the unlikely event of a significant release of ammonia solution from the tank, spilled liquid will be retained within the concrete containment area. A worst-case dispersion modeling analysis will be conducted to estimate airborne ammonia concentrations at the fence-line and the nearest actual or potential residence to evaluate this hypothetical scenario.

In addition, a discussion of the potential impact of CO2 emissions from the CFB boiler on global warming in relation to regional and global CO2 emissions will be provided.

Proposed Mitigation Measures

Based on a preliminary evaluation, the BPU is proposing the following pollution control system:

For the CFB boiler

• in-bed limestone injection for the control of acid gases (SO2, sulfur acid mist, hydrogen fluoride, hydrogen chloride);

• selective non-catalytic reduction (SNCR) for the control of NOx; and

• fabric filter baghouse for the control of particulate matter (including trace metals).


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For the Material Handling and Storage System

• storage of coal, petroleum coke, and ash within silos equipped with fabric filters to control particulate emissions during loading;

• storage of wood, other fuels and limestone within three-sided and roofed buildings; and

• transport of fuel and limestone from storage to the CFB boiler in enclosed conveyors equipped with fabric filters at strategic locations.

3.2 Water Resources

Baseline Data

BPU will review available literature, studies, and readily available water resources data, including documentation prepared for the LM-6000 project relative to water resources (groundwater, surface water, and storm water) and data available from the State of New York. Available data on the flow and water quality characteristics of the Chadakoin River will be collected, reviewed, and summarized, as well as compared to estimates of existing and proposed water usage for the facility. BPU will develop estimates of historical water withdrawal from the Chadakoin River, since actual data are not available. BPU will summarize the current storm water management system based on available data and will calculate storm water run-off rates for the existing facility (including the current and proposed railcar unloading areas and the area south of Steele Street).

A brief summary of some of the information available on the Chadakoin River and other water resources potentially affected by the project is provided below.

• The Chadakoin River drains Lake Chautauqua, flowing into the Cassadaga Creek and then into the Conewango, Allegheny, and Ohio Rivers to the Mississippi.

• The NYSDEC has classified the Chadakoin River as a Class C water body. According to the NYSDEC, the best usage of Class C waters is fishing. This classification means that the river is also suitable for primary and secondary contact recreation.

• The BPU controls the level of the Chadakoin River in the vicinity of the Carlson Plant through its operation of the Warner Dam (located approximately one-quarter mile downriver) in accordance with NYSDEC and U.S. Army Corps of Engineers requirements.

• Based on USGS stream flow data at a stream gage in the Chadakoin River in Falconer (a mile or two downstream of the Carlson Plant), the annual mean flow in the river for 1935 through 2001 was 360 cubic feet per second or 232 mgd.


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• A review of the boundaries of the most recent (December 1977) Flood Insurance Study conducted for the City of Jamestown shows that the 100-year base flood water surface elevation in the vicinity of the Carlson Plant ranges from 1,306.1 feet above mean sea level (ft msl) at the project’s eastern site boundary (based on 1929 National Geodetic Vertical Datum, NGVD) to 1,307.5 ft msl at the Sprague Street bridge (western boundary of the Carlson Plant). A review of the site topography provided by the BPU shows that, with the exception of a narrow strip of land along the south bank of the Chadakoin River, the lowest portion of the project site is at an elevation above 1,308 ft msl. Based on this information, and the preliminary site layout, it appears that project construction will not occur within the 100-year floodplain.

• Available information indicates that the depth to groundwater is approximately three feet.

Environmental Impacts

Impacts to groundwater are expected to occur only during construction-related excavation activities. The BPU expects that these impacts can be evaluated based on available data. Fuel and limestone for the project will be stored within enclosed structures and on paved ground. As such, this component of the project is not expected to result in groundwater impacts.

The evaluation of impacts on surface water (i.e., the Chadakoin River) will be limited to water withdrawal-related impacts, since there will continue to be no direct discharge to the river from process sources or from storm water (other than sheet flow from non-industrial areas). A comparison of the following water withdrawal-related impacts for the existing and proposed facility configurations will be provided:

• Peak, daily average, and annual average water withdrawal amounts; and

• Impact, if any, on NYSDEC classification of Chadakoin River.

To evaluate impacts from storm water, BPU will calculate storm water run-off rates based on the projected site layout and will compare these results to baseline conditions. This information will be used as input to the conceptual storm water management plans for construction of the proposed project and operation of the facility after project implementation.

Proposed Mitigation Measures

There will be a slight increase in the amount of impervious area resulting from the construction of the Clean Coal Project, thereby increasing overland flows of rainfall runoff. However, the rate of runoff will be controlled by the existing storm water drainage system as modified for the project. There will continue to be no discharge of storm water from industrial areas to the Chadakoin River.


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A storm water pollution prevention plan (SWPPP) will be developed in accordance with the terms and conditions contained in the General Permit for Construction Activities. The SWPPP will address all areas affected by the project and will include mitigation measures to minimize potential adverse surface water impacts resulting from construction- and operation-related storm water runoff.

Water from construction dewatering activities, if encountered, will be managed such that there will be no discharge of sediment-laden water to the Chadakoin River. A State Pollutant Discharge Elimination System (SPDES) dewatering permit will be obtained from the NYSDEC if necessary.

The current withdrawal volume from the Chadakoin River results in an intake velocity of less than 0.5 fps. Implementation of the Clean Coal Project is not expected to result in intake velocities that exceed this level.

3.3 Ecological Resources

Baseline Conditions

Existing aquatic data for the Chadakoin River will be obtained from available sources (e.g., NYSDEC, National Oceanic and Atmospheric Administration, National Marine Fisheries Service, U.S Fish and Wildlife Service [USFWS]). To supplement this information, the BPU has conducted an ichthyoplankton entrainment assessment of the Chadakoin River in spring/summer 2004. This ichthyoplankton assessment was completed via two mobilizations to the Chadakoin River in early and late June 2004. The objective of the sampling program was to collect and analyze the type and abundance of ichthyoplankton in the vicinity of the Carlson Plant water intake potentially impacted by operation of the facility after CFB project implementation. The program entailed ichthyoplankton collection via a net tow, with four tows being completed during each mobilization to account for temporal variability, and analysis of the sample collected by a qualified laboratory. Approximately 80,000 gallons of water were analyzed for sub-500 micron fish larvae and eggs. The results of that program indicated a moderate abundance of ichthyoplankton, represented by four primary common species: common carp (Cyprinus carpio), pumpkinseed (Lepomis gibbosus), emerald shiner (Notropis athernoides), and to a lesser extent, white bass (Morone chrysops). In addition, six other species were observed in lesser abundance, including crappie (Pomoxis spp.) and several species of sunfish (Lepomis spp.). The overall averaged density of ichthyoplanktojn collectd was 0.113 fish per cubic meter, or 425.8 per million gallons of water. The low average (Sample 3) included 47.3 fish per million gallons, and the high average (Sample 7) averaged 946.2 fish per million gallons of water. No rare or unusual species were observed, nor were any sport species observed in abundance. This analysis was completed by Ichthyological Associates, Inc. of Lansing, New York.

Existing data on wetlands and terrestrial and aquatic ecology will be obtained from available sources and from in-field investigation. Such information will include current mapping and data on wetlands and rare species from the NYSDEC, U.S. Geological Survey (USGS), U.S. Army Corps of Engineers, and USFWS, as well as available data on any local sensitive plant or animal communities (including


January 19, 2005 3-12

migratory birds) or other ecological resources of special significance. Correspondence with NYSDEC and USFWS indicates that there are no protected species on or in the vicinity of the Carlson Plant (including in the Chadakoin River) that could potentially be affected by the proposed project. Furthermore, no wetland resources or significant terrestrial ecological resources, including those that could support threatened or endangered species, were found present on the Carlson Plant site based on a site walk by a Professional Wetland Scientist.

Wildlife

Significant wildlife habitat is not known to occur on or adjacent to the urbanized landscape surrounding the Carlson Generating Station. Common suburban mammals, including the woodchuck (Marmota monax), grey squirrel (Sciurus carolinensis), and chipmunk (Tamias striatus) were observed in several areas. No unique or unusual habitat features were otherwise observed within the Study Area. Correspondence with NYSDEC and USFWS does not indicate the presence of any unusual or protected terrestrial species in the vicinity of the Carlson Plant.

Environmental Impacts

An evaluation of the impact on aquatic resources (ichthyoplankton and other biological organisms) resulting from the change in water withdrawal from the Chadakoin River and from the change in air emissions and deposition will be conducted. Based on the final site layout, the Draft EIS will describe the nature, extent, and duration of impacts to the on-site terrestrial ecology. In addition, a screening level analysis will be conducted to evaluate the impact of air emissions and deposition on the terrestrial ecology in the vicinity of the facility. This evaluation will be an extension of the soils and vegetation analysis conducted in support of the air permit application.

Potential Mitigation Measures

The BPU expects that maintaining low intake velocities associated with Chadakoin River water withdrawal will have a minimal impact on aquatic resources in the river. Furthermore, continuing to not discharge storm water or wastewater to the Chadakoin River will have a positive impact on aquatic resources.

3.4 Cultural Resources

Jamestown and the surrounding area are rich in history. Per both federal and state requirements the project will need to demonstrate that it will not adversely affect resources that are of either known and listed historic importance as well as those than have been nominated for protection or are candidates for projection.


January 19, 2005 3-13

The first step in this process was the completion of a prescribed Phase IA study which includes a data search and visit with the State Historic Preservation Office to identify structures and sites that are listed or have been determined eligible for listing on the State or National Register of Historic Places. The State Historic Preservation Office has confirmed that it has no concerns regarding the buildings, structures and districts within BPU’s 92 Steele Street site. The area of interest consists of a three-mile radius of the project site and includes such facilities as the train station located across from the Carlson Plant. Specific steps included:

1. Examination of the archeological site files of the New York State Museum and the New York State Office of Parks, Recreation and Historic Preservation (OPRHP) for reported sites within three miles of the project area;

2. Examination of the OPRHP computer inventory for properties that are listed on or have been determined eligible for listing on the State/National Register located in the immediate vicinity;

3. Examination of pertinent historic maps that document the development of the area;

4. Review of local histories and previous cultural resources reports prepared for other studies in the vicinity of the project area; and

5. A site visit to assess and photograph existing conditions and identify areas of previous ground disturbance and archeological sensitivity, if any.

The information gathered during the Phase IA literature review will be combined with environmental information to provide an archeological sensitivity assessment for the project area.

A Phase IA report will be prepared in accordance with The Standards for Cultural Resource Investigations and the Curation of Archaeological Collections in New York State and included as an Appendix in the Draft EIS. It will summarize the results of the literature review and site visit and will provide brief pre-contact and historic contexts for the area, an inventory of known cultural resources within the vicinity of the project area, an archeological sensitivity assessment and recommendations. A condensed version of these materials will be presented in the body of the Draft EIS.

Analysis will determine the potential for construction and operation of the proposed project to affect the cultural resources identified in the Phase IA survey. Based on the developed nature of the site it is expected that no sensitive cultural resources will be affected by facility development. Impacts to off-site cultural resources such as the railroad station identified from the Phase IA survey are expected to be limited to visual impacts. The results of this analysis, along with the Phase IA report, will be submitted to the OPRHP for review. The expected outcome of this process will be a Determination of No Impact from the OPRHP. Based on this expected outcome, it is unlikely that mitigation measures will be required.


January 19, 2005 3-14

The BPU will relocate its offices, warehouses and garages as part of the project. The BPU anticipates renovating and/or constructing a building in Jamestown and locating its electric, water and other utility staff in the building. Once a building and/or site is selected, the BPU, in coordination with OPRHP, will determine the historic and cultural significance of the site and proceed with the appropriate review. Further, the analysis described above will be extended to encompass the site of the relocated office building.

3.5 Visual Resources

The site of the Clean Coal Project is dominated by the structures that comprise the Carlson Plant. The site is essentially flat and open, characteristic of an industrially developed site. The immediate area is primarily industrial and commercial. The Clean Coal Project structures will be consistent in size and type with the existing structures at the Carlson Plant as previously shown in Figure 4, with the exception that the height of the proposed new CFB stack will be taller than the height of the existing stacks. It is the NYSDEC’s Division of Air Resources policy (Air Guide-26) for new stacks to be constructed at a height that meets Good Engineering Practice (GEP). The preliminary GEP stack height for the proposed project is 325 feet above grade. (For comparison, the tallest structures at the Carlson Plant are the existing stacks at a height of approximately 200 feet above grade) The NYSDEC Air Guide-26 policy allows for stack heights less than the GEP height, provided a lower height can be justified. Such justification includes aesthetics, Federal Aviation Administration (FAA) limitations, and engineering or local zoning restrictions. A taller stack will result in lower air quality impacts, but it will increase the project’s visual impact. Conversely, a shorter stack will result in a lesser visual impact, but it will increase the project’s air quality impact. BPU will strive to attain the appropriate balance between these two competing resources in selecting the appropriate stack height. The diameter of the new CFB boiler stack will be similar to the diameter of the existing stacks.

The overall approach to the visual resources assessment is an evaluation of the change in the landscape caused by the project at a number of selected viewpoints. The viewpoints will be selected after an extensive search of points within a three mile radius of the project site that are important locally or are sites and structures that are listed or have been determined eligible for listing on the State or National Register of Historic Places. Using USGS digital topographic data for the project site and surrounding area, a preliminary base map was developed and used to determine the potential visibility of the completed facility from the viewpoints within the three-mile study area. A field program verified the accuracy of the viewshed map and documents through photographs the views towards the project site from the selected viewpoints. Since there are no existing structures at the height of the proposed stack, additional field work involved floating two helium-filled balloons at or near the proposed stack height in order to obtain appropriate scale reference points.

From this data base and input from the scoping meetings, four viewpoints will be selected for the visual simulation that will be the basis for determining the change in landscape following project completion. A three dimensional computer model of the site and the reference elements will be developed to verify


January 19, 2005 3-15

the alignment of each viewpoint to be simulated. Simulations of the proposed project will be developed based on the model of the proposed project. Each photographic viewpoint will be aligned with the model and the model then superimposed on the photograph. Each simulation will show a photograph of the existing view and a second photograph of the view as it would be following project completion.

Project impacts on visual resources will be evaluated in accordance with the NYSDEC’s Visual Impacts Policy (DEP-00-2) and consider changes in line, form, color and scale, and importance and intensity of use of the viewpoint. The analysis will consider all project related structures, including the stack, powerhouse, silos, railcar unloading station, and the material handling conveyor system (both on site and across the Chadakoin River).

Possible mitigation measures for other aspects of the project include exterior building color, exterior building treatment, building elevation, landscape design, and general outdoor lighting.

Warning lights will be installed on the new CFB stack if required by the FAA. For example, the FAA may require that the BPU install a dual lighting system consisting of red lights (L-864) for nighttime and medium intensity flashing white lights (L-865) for daytime and twilight use approximately five feet below the top of the stack. Use of this lighting system would minimize the visual impact to residents during the nighttime.

As is true for the Carlson Plant, outdoor lighting will be installed on the new structures to ensure a safe and secure working environment. The lighting system will be consistent with best management practices in that it will:

• provide adequate light for the intended task without over-lighting;

• use “fully-shielded” lighting fixtures that control the light output in order to keep the light in the intended area;

• position the lights to maximize their effectiveness on the targeted areas and minimize their adverse impact beyond the property borders; and

• use fixtures with high-efficiency lamps, while still considering the color and quality as essential design criteria.

3.6 Transportation and Traffic

The Carlson Plant currently experiences traffic from the following sources:

• coal delivery trucks (both directly to the site from the mine as well as from the railcar unloading site across the river) (on average, about 22 trucks/day);


January 19, 2005 3-16

• ash disposal trucks (on average, about 3-4 trucks/day);

• railcar delivery of coal to the off-site unloading site across the river (on average, about 1 delivery/week of 10 railcars);

• plant workers (on average, about 34 vehicles/day over three shifts); and

• maintenance vehicles, office workers, and customers associated with the existing office buildings, garages and warehouse (on average, about 290 vehicles/day).

The Clean Coal Project will result in approximately 300 temporary jobs, on average, during the approximately two-year construction period, with a peak construction force of approximately 600 over a two-month period. The BPU expects that there will be six additional permanent jobs associated with the Clean Coal Project. In addition, the BPU estimates that at most approximately 50-60 trucks/day will access the site during operation of the Carlson Plant after implementation of the project. This number is based on the assumption that coal, coke and limestone will be delivered to the site by truck rather than by rail as is expected. Therefore, both construction- and operational-related traffic will be addressed in the Draft EIS.

Current traffic conditions in the project area will be determined largely from existing data routinely collected by state and local transportation authorities. Certain information regarding the proposed plant expansion will be developed as necessary for the traffic analysis and evaluation. This will include:

1. Site layout for the plant’s existing and proposed entrances, exits, staging areas, and parking lots;

2. Hourly traffic count data for the roads surrounding the plant site, maintained by the New York State Department of Transportation;

3. The location of designated truck routes in the City of Jamestown;

4. Information on truck origins/destinations for coal suppliers fuel deliveries and ash disposal facilities;

5. Information on seasonal differences in plant operations (i.e., greater coal shipments in winter rather than summer);

6. Information on the staging of development for the proposed plant expansion, to develop assumptions for a construction phase traffic analysis; and


January 19, 2005 3-17

7. Road weight limits.

This information will be supplemented with in-field traffic counts at selected intersections. One set of peak-hour morning (7:30 AM – 9:30 AM) and afternoon (4:30 PM – 6:30 PM) turning movement counts will be conducted at the three local street intersections closest to the plant and railroad loading. The three intersections proposed to be evaluated are:

• the un-signalized intersection of Steele St., Barrett Ave., and Harrison St.;

• the signalized intersection of Steele St. and Sprague St.; and

• the un-signalized entrance to the Carlson Plant.

Additional intersections will be added if necessary to evaluate the impact of construction worker parking and staging areas. Traffic counts will be obtained over a 2 day week day period. On the afternoon of the initial day, roadway geometry will be recorded, followed by undertaking PM traffic counts, with AM traffic counts conducted on the following morning.

Data and information gathered as part of the baseline evaluation will be used to perform a level of service (LOS) analysis for the three key intersections. An analysis of the site and nearby roadway network will be done to identify and quantify the existing baseline operating conditions. To determine the traffic flow implications of the project, an analysis of the roadway network will be performed using the SYNCRO traffic simulation and analysis program. SYNCRO is a micro-simulation traffic analysis model that allows for comprehensive analysis of traffic flow patterns and intersection operations on a roadway network using a series of traffic measures of effectiveness. The software also allows for conventional LOS analysis using the procedures in the Institute of Transportation Engineer’s Highway Capacity Manual. Six scenarios will be assessed in the simulation:

• Morning and afternoon peak hour for the no-build condition;

• Typical morning and afternoon peak hour during the construction period; and

• Morning and afternoon peak hour after full build-out (i.e., plant expansion in operation).

The SYNCRO analysis will be able to account for traffic origins and destinations and vehicle mix within the roadway network and will allow for analysis of different roadway directional patterns in relation to traffic circulation needs. The program also has the ability to graphically simulate traffic flow throughout the roadway network, which can assist in the visual identification of traffic flow constraints and areas operating at/or over capacity.


January 19, 2005 3-18

Sound data for significant facility sound sources, including fuel delivery and handling, and stationary power plant sources will be compiled from existing data and from data provided by prospective equipment suppliers. Using this data, a computer model will be developed of facility sound emissions. Adjustments for source directivity, atmospheric absorption, natural/man-made barriers and mitigation methods will be incorporated in the modeling. The results of the modeling will be expressed as A-weighted, and octave band sound levels at receptor points of interest. A map of the surrounding community with contours of A-weighted sound levels will be produced. The modeling will be conducted for one operating scenario.

Based on the results of the above analysis, measures to mitigate adverse transportation impacts will be identified. These can include such measures as the use of traffic control offices, staging of work hours during construction and realignment of key intersections.

3.7 Noise

The Carlson Plant is located adjacent to commercial, institutional, and residential land uses with varying sensitivity to environmental noise. Because the proposed operations at the facility and the off-site coal handling/storage areas may differ from current operations, there is a potential for changes to the intensity and tonal characteristics of sound generated at the power plant as a result of construction and operation of the Clean Coal Project.

Existing noise conditions in the project area will be determined through a field monitoring program. A combination of hand-held and continuous monitoring will be conducted at up to five measurement locations at the property boundary and nearby sensitive receptors. Hand-held monitoring will involve gathering representative samples (typically 20-minute intervals) for both daytime and nighttime periods. Data from the program will include A-weighted sound level descriptors (Lmin, Lmax, Leq, L99, L90, L50, L10, and L01), octave band analyses, and A-weighted time histories. A single environmental sound monitor will collect and process A-weighted sound level data (hourly intervals) on a continuous basis for a 24-hour period. The monitor will be installed on or near the project property at a location that is representative of the nearest residential receptors.

Near-field sound level measurements of existing environmental sound sources will be performed to characterize these sources and to provide adjustments for baseline environmental sound level data. Calculations and computer modeling will be performed to adjust background sound data for the operation of existing sound sources.

Evaluation of potential noise impacts will be done for the period of construction and subsequent operation. Using the Power Plant Construction Noise Guide, data from USEPA publications, and actual equipment specifications if they are available, construction sound levels at selected community locations will be determined and expressed as A-weighted Leq sound levels. The significance of the resulting sound levels will be evaluated by comparison to existing background sound levels and existing noise regulations.


January 19, 2005 3-19

Based on the results of the noise impact analysis, measures to mitigate potentially adverse noise impacts during construction and operation of the project will be identified. These will include the following:

• avoid pile driving (if needed to support foundations) during evening and early morning hours;

• use a blow-down tank outfitted with a steam discharge silencer able to provide a 30-dBA reduction in steam noise for pipe cleaning prior to system start-up;

• consideration of equipment alignment;

• use of sound attenuation materials; and

• minimize to the extent practicable the alarm noise associated with backing up of trucks.

3.8 Solid Waste

The Carlson Plant currently disposes approximately 25,200 tons/yr of fly ash and bottom ash from the coal boilers by either sending it back to the originating coal mine in Pennsylvania or to the Chautauqua County Landfill. Other types of solid waste (such as office waste) generated at the Carlson Plant are disposed of in the Chautauqua County Landfill.

The project will generate in the range of 42,000 – 54,000 tons/yr of ash associated with the combustion of fuels in the CFB, the composition of which will vary depending on the fuel used. When the CFB boiler is burning only coal, the resulting ash, if agreed to by the originating mine, will be returned to the mine for disposal and therefore will have no impact on local landfills. When the CFB boiler is burning a combination of fuels, or when the originating mine will not accept the ash, the resulting fly ash and bottom ash will be disposed of in the nearby Chautauqua County Landfill. The analysis, which will include the quantity and quality of the solid waste to be disposed of, will demonstrate that this is an acceptable waste and show the potential impact on the life of the landfill. The analysis will identify alternative ash disposal locations that can be used in the event the Chautauqua County Landfill cannot take the ash from the Carlson Plant.

The Draft EIS will also evaluate the potential beneficial use of CFB ash as an alternative to landfill disposal. A considerable amount of research has been performed by others regarding the beneficial use of CFB ash. Four (4) general categories have been identified as having potential:

• Agriculture − Lime source for croplands, orchards and pastures − Mulching Agent


January 19, 2005 3-20

• Reclamation − Low strength fill material − Liming agent

• Construction − Structural fill − Flowable fill − Production of Type IP pozzolanic cement

• Waste Stabilization

The NYDEC Division of Solid and Hazardous Materials has granted two beneficial use determinations (BUD) for fluid bed combustion (FBC) ash. Both of the BUDs involved waste from the Fort Drum Cogeneration Facility. In one application the FBC ash was used in the reconstruction of an unpaved road while in the other application it was used for the construction of barnyard pads.

3.9 Social and Economic Resources

Social and economic resources in the project area can be described of in terms of employment, area population and demographics, land uses, recreational resources and supporting infrastructure, including solid waste disposal facilities. Existing conditions for all of these aspects will be documented through the use of existing secondary information.

Project impacts will be evaluated based principally on the changes that the project will induce in the area during construction and operation. It is anticipated that the project will have significant positive socio-economic benefits to the community, including continued availability of reliable low-cost power, support for local industry, support for the local tax base, and increased number of jobs. Because employment for the construction and operational phases of the project is expected to be drawn from the local area and not result in a large immigration that will stress existing public service systems, the project’s impacts, with the exception of positive local fiscal impacts are expected to be minimal. The project’s potential importance in terms of jobs during construction and new jobs during operation and increase in local revenues will be demonstrated with reference to current conditions.

The impact of the construction and operation of the project on recreation will be evaluated. Specific issues to be addressed include the impact of the project on accessibility to Panzarella Point, the River Walk proposed by the City of Jamestown, and boating and fishing activities on the Chadakoin River. Regarding the River Walk, the BPU will create parking spaces to be used for the River Walk and will provide a walking bridge for access across the Chadakoin River.


January 19, 2005 3-21

The Clean Coal Project, by virtue of being subject to PSD review, will be required by the USEPA Region 2 to conduct an environmental justice (EJ) evaluation. USEPA Region 2 developed an “Interim Environmental Justice Policy” (December 2000) that defines the approach and methodology that Region 2 will use to evaluate and assess EJ communities and their concerns. The project is also subject to the NYSDEC’s Environmental Justice and Permitting Policy (CP-29) because it will be a major modification to the existing facility under the air permitting regulations (Article 19, implemented by 6 NYCRR Part 201 et seq.).

The first step in the federal and New York EJ process will be to determine whether any minority or low-income populations are located near the Carlson Generating Plant. The USEPA Region 2 and the NYSDEC have defined thresholds for low-income and minority communities in cities as follows:

• Low-income community means a census block group, or contiguous area with multiple census block groups, having a low-income population equal to or greater than 24.8% (USEPA Region 2) and 23.59% (NYSDEC) of the total population (based on 2000 Census data).

• Minority community means a census block group, or contiguous area with multiple census block groups, having a minority population equal to or greater than 48.5% (USEPA Region 2) and 51.1% (NYSDEC) in an urban area of the total population (based on 2000 Census data).

Based on a review of the 2000 Census data, there are several census blocks located in the Jamestown area that exceeded both the USEPA Region 2 and NYSDEC low income community thresholds. None of the census block groups exceeded either of the minority community thresholds. Based on this evaluation, therefore, an EJ analysis will be conducted in accordance with USEPA Region 2 and NYSDEC policies.

An important component of the NYSDEC EJ policy is the preparation and execution of public participation program. The BPU has initiated community outreach to all parts of the Jamestown area, including the EJ Communities. Outreach activities have included written materials in the monthly newsletter that goes to all electric customers with their district bills and daily weekday informational announcements on a local Jamestown radio station. The outreach materials have included basic information about the proposed project, the SEQR process, scoping and public input in the process. SEQR documents have been, and will continue to be, forwarded to a broad list of involved and/or interested agencies, state and federal representatives, and local civic groups. Additional outreach efforts have included presentations to local civic groups, including the Rotary Club and the Jamestown Manufacturers Association.

The BPU anticipates that future efforts will include:

1. identification of any additional stakeholders through contacts with public officials and community leaders in the Jamestown area;


January 19, 2005 3-22

2. additional public information meetings;

3. additional document repositories in or near EJ Communities;

4. community feedback; and

5. development of an EJ Public Participation Plan and submittal of the Plan to NYSDEC and the USEPA

Once the plan is approved, it will be implemented and certified by the BPU.


January 19, 2005 4-1

4.0 ALTERNATIVES

As shown in the EIS outline provided in Appendix B, the evaluation of alternatives is an important component of the Draft EIS. The following alternatives to the proposed action will be considered:

1. No Action Alternative – The No Action Alternative of continuing to operate the Carlson Plant as it currently exists and not relocating the office buildings, warehouses, and garages will be considered and will serve as a baseline with which to compare the proposed action.

2. Alternative Design and Technologies – The following alternative designs and technologies will be considered:

• Alternative site layout • Alternative combustion technologies • Alternative fuels, including availabilities of those fuels • Alternative sources of electricity, including purchase of wind power and additional

hydrological power

3. Alternative Sites – The process leading to the selection of the proposed location for the CFB unit and the supporting equipment and structures will be discussed. Included in the discussion will be the initial sites considered and the rationale for selecting the proposed locations.

4. Alternative Size – The rationale for selecting the proposed project size of 40 MW vs. an alternative project size of 80 MW will be discussed.

5. Alternative Timing – Alternative timings for shutting down the existing coal-fired boilers

This section of the Draft EIS will also include a discussion of alternatives considered but eliminated and the supporting reasons.


January 19, 2005

Appendix A

Positive Declaration for Jamestown Clean Coal Project


January 19, 2005

STATE ENVIRONMENTAL QUALITY REVIEW

POSITIVE DECLARATION NOTICE OF INTENT TO

PREPARE A DRAFT EIS AND DETERMINATION OF SIGNIFICANCE

This notice is issued pursuant to Part 617 of the implementing regulations pertaining to Article 8 (State Environmental Quality Review Act) of the Environmental Conservation Law.

The Jamestown Board of Public Utilities (BPU), as lead agency, has determined that the proposed action described below may have a significant impact on the environment and that a Draft Environmental Impact Statement will be prepared.

TITLE OF ACTION:

Jamestown Clean Coal Project

SEQR STATUS: Type 1 Action

Relevant thresholds include over 5 acres of land altered for a purpose other than constructing residential structures and expansion of existing non-residential activities that may exceed 100,000 square feet of gross floor area.

PERMIT JURISDICTION:

NYS Department of Environmental Conservation permits include Article 19 (Air Pollution Control). U.S. Environmental Protection Agency will issue a federal Prevention of Significant Deterioration (PSD) permit. City of Jamestown Planning Board approvals include site plan approval. Depending on the buildings selected for the BPU’s future offices and warehouses, and the level of renovation, approval may be required from the State Historic Preservation Office.

LOCATION: 92 Steele Street, Jamestown, New York

DESCRIPTION OF ACTION:

The Jamestown Board of Public Utilities is proposing to construct a new clean coal unit at its existing plant site and to retire two of its existing coal-fired boilers when the new unit goes into commercial operation. The new unit will be a 40 megawatt (MW) circulating fluidized bed boiler (CFB) that will be capable of burning coal and alternate fuels, such as community wood waste, petroleum coke and chipped tires. The CFB is expected to be operational by 2010. Construction of the CFB will also


January 19, 2005

involve upgrades of certain existing facilities, including storage facilities and rail car unloading facilities located north of the current plant site, and may result in increased water use.

The BPU will relocate its office, warehouses and garages as part of the project. The BPU anticipates renovating and/or constructing a building in Jamestown and locating its electric, water and other utility staff in the building.

SCOPING:

Scoping will be conducted. A Draft Scoping document will be made available at the Board of Public Utilities’ offices at 92 Steele Street, Jamestown, New York and on the BPU’s web site at www.jamestownbpu.com. Public Scoping meetings will be held on November 18th, 2004 from 2-5 pm at the Love School Gymnasium and on November 18th, 2004 from 7-9 pm at the Washington Middle School Auditorium. Written comments will be accepted until November 30, 2004.

REASONS SUPPORTING THIS DETERMINATION:

During review of this project, the BPU identified the following potentially significant adverse environmental impacts associated with the project:

1. The BPU anticipates that aggregate air emissions rates (per unit of energy produced) from the new

unit will be significantly lower than emissions from the existing coal-fired units. The BPU will also permanently shut down coal boiler Nos. 10 and 11 once the Clean Coal Project has completed its shakedown period and is fully operational, thereby eliminating emissions from these existing units once the new unit is operational. There is the potential for a minor increase in total annual facility air emissions (new and old units combined), including emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx), relative to current levels. The BPU anticipates that non-criteria pollutants emitted by the proposed project will include trace elements contained in fuels, such as heavy metals, and various organic compounds. The emissions of these compounds will be quantified; the impact of these emissions on air quality will be compared to established health- and welfare-based guidelines and standards.

2. The BPU will continue not to discharge water into the Chadakoin River after implementation of the

proposed project. Although there is the potential for increased water withdrawal from the Chadakoin River for cooling tower purposes, the intake velocity will remain below 0.5 feet per second (fps) (the intake velocity to meet the impingement performance standard set out in USEPA’s Section 316(b) rule).

3. The project structures will be consistent with surrounding land uses. However, the proposed stack

height will be taller than the existing stacks.

http://www.jamestownbpu.com/


January 19, 2005

4. The type of traffic and noise impacts from the new plant will be consistent with existing site use. Nonetheless, traffic and noise impacts associated with the new plant will be evaluated as part of the EIS.

The BPU therefore concludes that the project may have a significant impact on the environment and a Draft Environmental Impact Statement (EIS) will be prepared. As part of the Draft EIS, these impacts will be evaluated to determine mitigation options.

For further information contact:

Sue Jones Communications Coordinator Jamestown Board of Public Utilities P.O. Box 700, 92 Steele Street Jamestown, NY 14702-0700

Date: _________________________

Signature: ________________________________

cc: Steven Doleski, NYS Department of Environmental Conservation Jeffrey Dietz, NYS Department of Environmental Conservation Joe Sciascia, NYS Department of Environmental Conservation Environmental Notice Bulletin Service List


1 January 19, 2005

Appendix B

Preliminary Draft EIS Outline for Jamestown Clean Coal Project

1. Introduction 1.1 Project Overview 1.2 Public Purpose and Need 1.3 Benefits of Proposed Project 1.4 Statement of Consistency with Energy Policy

2. Description of the Proposed Action

3. Environmental Setting 3.1 Air Quality 3.2 Water Resources 3.3 Aquatic Ecology 3.4 Terrestrial Ecology 3.5 Earth Resources 3.6 Solid and Hazardous Waste 3.7 Community Resources 3.8 Land Use and Zoning 3.9 Noise 3.10 Transportation 3.11 Visual Resources 3.12 Cultural Resources 3.13 Socioeconomics and Environmental Justice 3.14 Recreation

4. Environmental Impacts and Mitigation 4.1 Air Quality 4.1.1 Guidelines and Regulations 4.1.2 Construction Related Impacts 4.1.3 Operational Impacts 4.1.4 Mitigation Measures 4.1.5 Unavoidable Adverse Impacts 4.2 Water Resources 4.3 Aquatic Ecology 4.4 Terrestrial Ecology 4.5 Earth Resources 4.6 Solid and Hazardous Waste 4.7 Community Resources


2 January 19, 2005

4.8 Land Use and Zoning 4.9 Noise 4.10 Transportation 4.11 Visual Resources 4.12 Cultural Resources 4.13 Socioeconomics and Environmental Justice 4.14 Recreation

5. Description and Evaluation of Reasonable Alternatives 5.1 Overview of Alternatives Considered 5.2 No-action Alternative 5.3 Alternative Sites for CFB Boiler and Office Buildings 5.4 Alternative Technologies 5.5 Alternative Project Size 5.6 Alternative Project Schedule

6. Irreversible and Irretrievable Commitment of Resources 6.1 Natural Resources 6.2 Air Resources 6.3 Water Resources 6.4 Earth and Ecological Resources 6.5 Community Resources 6.6 Material Resources 6.7 Construction Materials 6.8 Fuels

7. Growth Inducing Aspects

8. Impacts on the Use and Conservation of Energy

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