[Federal Register Volume 60, Number 161 (Monday, August 21, 1995)]
[Notices]
[Pages 43437-43459]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-20551]
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DEPARTMENT OF ENERGY
Record of Decision; York County Energy Partners Cogeneration
Facility, York County, Pennsylvania
AGENCY: Department of Energy.
ACTION: Record of Decision; York County Energy Partners Cogeneration
Facility of the Clean Coal Technology Demonstration Program in North
Codorus Township, York County, Pennsylvania.
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SUMMARY: The Department of Energy (the Department) has prepared an
Environmental Impact Statement (DOE/EIS-0221) to assess the
environmental and human health impacts associated with construction and
operation of the York County Energy Partners, L.P. (YCEP) Cogeneration
Facility on a 38-acre (15.4-hectare) parcel in North Codorus Township,
York County, PA. After careful consideration of these impacts, along
with Clean Coal Technology Program goals and objectives, the Department
has decided to provide $75 million (approximately 17 percent of total
project cost) in federal funding support for the design, construction,
and operation of a nominal 250-megawatt coal-fired, cogeneration
facility demonstrating utility-scale atmospheric circulating fluidized
bed (ACFB) technology.
Concerns were expressed by the Pennsylvania Game Commission
regarding effects on wildlife habitats and by the Pennsylvania Bureau
for Historic Resources on adverse impacts to historic properties. The
Department met with the Pennsylvania Game Commission and received a
list of mitigation measures the Commission believes would be adequate
to mitigate the impacts to wildlife habitats on Game Commission lands.
The Department also negotiated a Memorandum of Agreement with the
Pennsylvania Bureau for Historic Resources that requires YCEP to
perform nontraditional mitigation measures. To resolve issues related
to volatile organic compound (VOC) emissions from the cooling tower,
the Pennsylvania Department of Environmental Resources (PADER)
incorporated mandatory monitoring requirements into the project's air
permit, which was issued on July 25, 1995. These requirements, and any
subsequent mitigation actions required through regulations, will be
enforced through the air permit.
The Department's decision to provide cost-shared federal funding
for the YCEP Cogeneration Facility is contingent on YCEP fulfilling its
obligations to complete the actions described in this Record of
Decision and in the Mitigation Action Plan prepared by the Department
for this YCEP project.
FOR FURTHER INFORMATION CONTACT:
For further information on the Department's activities related to this
project, please contact Dr. Suellen A. Van Ooteghem, Environmental
Project Manager, Morgantown Energy Technology Center, 3610 Collins
Ferry Road, Morgantown, WV 26507-0880 or call (304) 285-5443.
For further information on the Department's National Environmental
Policy Act process, please contact Carol M. Borgstrom, Director, Office
of NEPA Policy and Assistance (EH-42), U.S. Department of Energy, 1000
[[Page 43438]]
Independence Avenue, SW., Washington, DC 20585, or call either (202)
586-4600 or (800) 472-2756.
SUPPLEMENTARY INFORMATION: The Department has prepared this Record of
Decision pursuant to Council on Environmental Quality regulations for
implementing the provisions of the National Environmental Policy Act
(40 CFR Parts 1500-1508) and Department regulations (10 CFR Part 1021).
This Record of Decision is based on the Department of Energy's Final
Environmental Impact Statement for the YCEP Cogeneration Facility (DOE/
EIS-0221).
An overall National Environmental Policy Act compliance procedure
was developed for the Clean Coal Technology Demonstration Program that
includes consideration of both programmatic and project-specific
environmental impacts during and after the process of selecting a
project. The procedure is called ``tiering'' (40 CFR 1508.28), and
refers to the coverage of general matters in a broader Environmental
Impact Statement (e.g., the Programmatic Environmental Impact Statement
for the Clean Coal Technology Demonstration Program), with subsequent
narrower statements or environmental analyses incorporating by
reference those general discussions found in the broader programmatic
document. A project-specific document, therefore, concentrates solely
on the issues specific to the particular project being considered.
The Department procedure has three principal elements. The first
element involved preparation of a comprehensive Programmatic
Environmental Impact Statement for the Clean Coal Technology
Demonstration Program (DOE/EIS-0146, November 1989) to address the
potential environmental consequences of widespread commercialization of
up to 22 successfully demonstrated clean coal technologies by the year
2010. The Programmatic Environmental Impact Statement evaluated (1) a
no-action alternative that assumed the Clean Coal Technology
Demonstration Program was not continued and that conventional coal-
fired technologies with flue gas desulfurization controls would be used
for new plants or as replacements for existing plants that are retired
or refurbished, and (2) a proposed action that assumed that Clean Coal
Technology Demonstration Program projects would be selected for funding
and that successfully demonstrated technologies would undergo
widespread commercialization by 2010.
The second element involved preparation of a preselection
environmental review of project-specific environmental data and
analyses that the Clean Coal Technology Demonstration Program offerors
were required to supply to the Department as part of their Clean Coal
Technology Demonstration proposal or site change.
The third element consists of preparing site-specific National
Environmental Policy Act documents for each selected project. As part
of this overall strategy, the YCEP Cogeneration Facility's
Environmental Impact Statement draws upon the Programmatic
Environmental Impact Statement and preselection environmental reviews
that analyzed various alternatives and scenarios (e.g., alternative
technologies).
Project Description
YCEP (a wholly-owned project company of Air Products and
Chemicals, Inc.) plans to provide steam to the P.H. Glatfelter Company
paper mill and power to Metropolitan Edison Company (Met-Ed) through
the construction and operation of a nominal 250-megawatt coal-fired
cogeneration facility with one atmospheric circulating fluidized bed
(ACFB) boiler and a pollution control system consisting of a baghouse
to control emissions of particulates (PM10), selective non-
catalytic reduction for reducing emissions of oxides of nitrogen
(NOX), and limestone injection for reducing emissions of sulfur
dioxide (SO2) and acid aerosol emissions. Carbon monoxide (CO) and
volatile organic compound (VOC) emissions will be controlled through
utilization of an efficient combustion process. In addition, the
facility will be equipped with a continuous emissions monitoring (CEM)
system, which will continuously measure and record flue gas volumetric
flowrate and temperature; opacity; and sulfur dioxide (SO2),
oxides of nitrogen (NOX), and either carbon dioxide (CO2), or
oxygen (O2) concentrations. This project was selected under the
Department's Clean Coal Technology Demonstration Program to demonstrate
the commercial viability of using utility-scale ACFB technology in a
cogeneration facility to generate electric power and steam.
Construction of the facility will take 3 years; the demonstration
period will last 24 months.
The facility will be located on a 38-acre (15.4-hectare) site in
North Codorus Township in York County, PA across Codorus Creek from the
P. H. Glatfelter Company paper mill. It is designed to operate
continuously (24 hours a day, 365 days per year), with the exception of
outages for maintenance purposes. Output of the facility will range
from 114 to 227 megawatts (net) depending on Met-Ed's hourly power
requirements. Steam generated in the ACFB boiler will be used to drive
a steam turbine to produce electricity for sale to Met-Ed. Up to
400,000 pounds/hour of high pressure steam will be sold to the P. H.
Glatfelter Company.
There are currently many small, mostly industrial, ACFB units in
existence in the United States. The large (250-megawatt electric and
greater) single-boiler utility-scale ACFB, however, is not yet widely
accepted as commercial technology in the risk-averse utility market.
Thus, actions involving large capital expenditures would usually be
undertaken using only well established, proven, conventional
technologies.
One of the purposes of the Clean Coal Technology Demonstration
Program, however, is to accelerate technological demonstration of
developing technologies. The Department believes that the development
of the Foster Wheeler ACFB technology to be demonstrated by the YCEP
Cogeneration Facility project will accelerate the commercialization of
ACFB technology and further the deployment of ACFB clean coal
technology. The Department will fund this cogeneration project at
approximately 17 percent of total cost. This represents a relatively
low level of funding, compared to other Clean Coal Technology
demonstration projects, and indicates that the Department acknowledges
the approaching maturity of ACFB technology.
A unique feature of the YCEP Cogeneration Facility is the scale of
the fluidized-bed unit in terms of steam production. The unit will
produce 2.1 million pounds per hour (MMlb/hr) of steam, which is 25
percent larger than any other unit built, under construction, or being
planned with a single boiler. The scale at which this project is to be
demonstrated (i.e., utility-scale) is of importance, since another
chief goal of the Clean Coal Technology Demonstration Program is to see
that more efficient and environmentally responsive coal technologies
have been demonstrated at the utility-scale by the year 2000 and are
available for replacing the existing inventory of aging utility boilers
in the United States.
ACFB boilers have several unique operating characteristics which
differentiate them from more conventional boiler technologies. The
Foster Wheeler boiler design to be demonstrated by YCEP will utilize a
water-cooled full division wall to
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improve the predictability of hydrodynamic behavior, improve
temperature uniformity, and reduce unit height while still maintaining
a large heat transfer surface. The relatively low combustion
temperature within the boiler will limit formation of oxides of
nitrogen (NOX) and optimize sulfur capture. The use of an
INTREXTM heat exchanger also increases the heat transfer surface
area while not increasing the height of the boiler. The Foster Wheeler
boiler has also been designed for high limestone utilization efficiency
by advantageously placing the front and rear wall feeders to allow for
lower feed rates and longer residence times for feedstock (coal and
limestone). The boiler's design also accommodates a relatively short
mixing zone and air-swept coal distribution to allow for optimal solids
mixing. The boiler will use four cylinders in parallel to absorb heat
while recycling fine particles back to the boiler furnace. Because the
coal and limestone to be added will represent only a fraction of total
coal and limestone available in the combustor, the boiler will react
more slowly to variations in coal or limestone quality. Steam
characteristics and boiler temperatures will be more uniform. This is
expected to result in easier operation, fewer upset conditions and air
emission spikes, and more consistent (e.g., more uniform chemical
composition) solid waste by-products. As a consequence of bed
fluidization and the recycling back from the cyclone, good mixing will
be achieved at more uniform temperatures, and will allow for more
complete combustion and limestone utilization.
As a benefit of the YCEP Cogeneration Facility, the P. H.
Glatfelter Company will curtail operation of one of its existing coal-
fired boilers. Power Boiler No. 4, a 357 MMBtu/hr (32 MWe equivalent
output) pulverized coal boiler, will be curtailed to back-up status and
will be used during times when the YCEP unit is down for maintenance or
under other circumstances, such as the loss of steam production from a
P. H. Glatfelter Company boiler. Power Boiler No. 4 will be limited
through terms of a State-issued air quality permit to operate
simultaneously with the YCEP Cogeneration Facility for no more than the
operating equivalent of 720 hours of oxides of nitrogen (NOX)
emissions at full output per year.
Associated utility corridors and interconnects will be required and
include the following five main utility corridors and interconnection
with an electric substation:
A 6.1-kilometer (3.8-mile) single circuit 115-kilovolt
electrical interconnection from the cogeneration facility to an
existing substation in Bair, PA;
A 228.6-meter (750-foot) double circuit 115-kilovolt
electrical intraconnection between the cogeneration facility and an
existing Met-Ed line at the P. H. Glatfelter Company paper mill;
A 685.8-meter (2,250-foot) steam supply line/condensate
return line and electrical raceway extending from the cogeneration
facility to the P. H. Glatfelter Company facility;
A 762-meter (2,500-foot) potable water supply line from an
existing Spring Grove Water Company water line to the cogeneration
facility;
Approximately 2.4 kilometers (1.5 miles) of cooling water
supply lines and wastewater return lines from the cogeneration facility
to the P. H. Glatfelter Company wastewater treatment facility; and
Expansion of a switchyard at Bair that would cover an area
of approximately 1 acre (0.4 hectare).
Project Status
Project activities to date include applications for permits and
approvals necessary to construct and operate the YCEP Cogeneration
Facility in North Codorus Township; preparation of designs and
specifications necessary to apply for these permits and approvals;
preliminary engineering and design activities in accordance with the
cooperative agreement with the Department; and preparation,
publication, and distribution of the Draft and Final Environmental
Impact Statements.
In October 1991, YCEP notified the Pennsylvania Public Utility
Commission (PUC) of the potential for using Clean Coal Technology
Demonstration Program funds to design, construct, and operate the
proposed YCEP project that would supply Met-Ed with power. YCEP
requested that the PUC order Met-Ed to enter into a power supply
agreement, and the PUC concurred in an order issued in November 1991
(Docket No. P-910549). YCEP and Met-Ed executed a 227-megawatt, 25-year
power supply agreement in April 1992. Met-Ed subsequently appealed to
the Federal Energy Regulatory Commission (FERC), asking that this order
be rescinded (Docket No. EL95-41-000); this request was denied by FERC
on June 28, 1995. On August 4, 1995, Met-Ed filed a petition for re-
hearing with the FERC.
YCEP submitted its Prevention of Significant Deterioration (PSD)
``Plan Approval Authority to Construct'' permit application in January
1994 to the Pennsylvania Department of Environmental Resources (PADER).
PADER issued the air permit on July 25, 1995. In addition, an erosion
and sediment control plan/National Pollutant Discharge Elimination
System (NPDES) construction stormwater permit has been submitted to the
York County Conservation District and PADER for review and comment.
Approval for the NPDES construction stormwater permit was issued in
April 1995. YCEP applied for final Land Development and Subdivision
approval from North Codorus Township; approval was denied pending
completion of the Record of Decision and approval of the air permit by
PADER. YCEP has since refiled its request for approval, and
simultaneously appealed the township's decision to the Court of Common
Pleas. YCEP also petitioned the West Manchester Zoning Hearing Board
for a ``special exception use'' for public utilities, as set forth in
Sec. 150-15 of the West Manchester Township Zoning Code, to allow the
expansion of an electric switchyard adjacent to the existing Bair
substation. Hearings were held on March 28 and April 26, 1995, and the
Board denied YCEP's initial petition (Case No. 95-09). YCEP filed an
appeal (Number 95-SU-2193-08) of the West Manchester Township decision
with the Pennsylvania Court of Common Pleas on May 25, 1995.
Alternatives
Congress directed the Department to pursue the goals of the Clean
Coal Technology Demonstration Program by means of cooperative
agreements that provide partial funding for projects owned and
controlled by nonfederal-government sponsors. This statutory
requirement places the Department in a more limited role than if the
federal government were the owner and operator of the project. When the
Department signs a Cooperative Agreement with an industrial partner,
the scope of alternatives is necessarily more restricted because the
Department must focus on alternative ways that not only accomplish its
purpose but also reflect the industrial partner's needs and the
functions the industrial partner plays in the decision making process.
It is therefore, appropriate for the Department to give substantial
weight to the industrial partner's needs in establishing a project's
reasonable alternatives.
Based on the foregoing principles, the reasonable alternatives to
the preferred alternative are an alternative site location (West
Manchester Township) and the no-action alternative (including scenarios
reasonably foreseeable as a
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consequence of the no-action alternative). After reviewing all
potential environmental effects, the Department has determined that its
preferred alternative is to provide cost-shared financial assistance
for the YCEP Cogeneration Facility at the North Codorus Township site.
Preferred Alternative
The preferred alternative, implementation of the proposed action,
is the provision of approximately $75 million in cost-shared federal
funding support for the design, construction, and operation of a
single-boiler utility-scale cogeneration facility utilizing atmospheric
circulating fluidized bed (ACFB) technology at the 38-acre (15.4-
hectare) site in North Codorus Township in York County, PA.
Alternative Site Location
Construction and operation of the YCEP 227-megawatt (net)
Cogeneration Facility at an alternative site in West Manchester
Township would be similar to the preferred alternative. A continuously
operating conventional wet cooling unit system would be utilized for
process heat dissipation and condensation of steam to water in the
steam turbine condenser. Mechanical draft cooling units would be
utilized and the heat transfer medium would be fresh water. Cooling
unit blowdown would be minimized but some blowdown would be required to
prevent excessive buildup of dissolved solids that result in scale
formation and corrosion. The blowdown volume would vary, depending on
the number of cycles of concentration (projected to be 8 to 12 cycles).
The steam generated in the ACFB boiler would be used to drive a steam
turbine to produce electricity for purchase by Met-Ed, and a portion of
the high pressure steam exiting the steam turbine would be sold to the
J.E. Baker Company for use in their dolomite brick manufacturing
operations. During periods when steam would not be available from the
ACFB boiler within the cogeneration facility, YCEP would utilize back-
up natural gas boilers to provide steam.
No Action
Under the no-action alternative, the Department would not provide
cost-shared federal funding support for the YCEP cogeneration facility,
and the design, construction, and operation of a single-boiler utility-
scale ACFB technology applied to a cogeneration facility at the 38-acre
(15.4 hectare) site in North Codorus Township in York County, PA would
not take place. Because YCEP would be unable to satisfy the criteria
dictated by the agreement to deliver electricity to Met-Ed, the
cogeneration facility would not be constructed without financial
assistance from the Department. The Pennsylvania PUC order made Met-
Ed's obligation conditional on the Department's actual co-funding of
the project.
Under the no-action alternative, it is reasonable to assume that
some means to meet possible long-term needs for electrical power in the
region would be required. Future electricity demands could be met by
purchasing power from new non-utility generators, purchasing power from
the existing power pool, conducting purchase transactions outside the
pool with private entities, or constructing new gas- or coal-fired
facilities.
Thus, for the purposes of analyzing and making comparisons between
the preferred alternative and the reasonably foreseeable consequences
of the no-action alternative, construction and operation of the
cogeneration facility at the North Codorus site was compared to three
different options for meeting project capacity requirements under the
no-action alternative.
Construction and operation of a 227-megawatt natural gas-fired
combined-cycle facility was one of the no-action alternative options
analyzed. The primary fuel for this facility would be natural gas
supplied by a single pipeline to the facility. The pipeline would be
supplied through a series of gas transmission lines, most likely
originating from a supply source in the Gulf of Mexico area. The 227-
megawatt gas-fired combined-cycle facility would have an expected gas
consumption rate of 16 billion cubic feet per year. A back-up fuel
supply (typically fuel oil) would be required for times when natural
gas supply is interrupted. No associated steam host would be built.
The second no-action alternative option analyzed was construction
and operation of a 227-megawatt coal-fired twin-boiler exempt wholesale
generator facility consisting of two 114-megawatt ACFB units with no
associated steam host or related air emissions reductions.
The final option analyzed under the no-action alternative was
energy and capacity purchases from the Pennsylvania-New Jersey-Maryland
(PJM) Interconnection Power Pool. The PJM power pool consists of 538
generating units representing an installed capacity of 55,575
megawatts, connected to approximately 6,800 miles of high voltage
transmission lines throughout the PJM region. No construction would be
associated with this alternative, and future potential short-falls in
long-term power needs may still need to be addressed.
Alternative Site Analysis
The Department would not be the owner-operator of the YCEP
Cogeneration Facility. Therefore, the Department's evaluation of the
project's reasonable site alternatives focused on a review of the site
selection study and criteria prepared by the Industrial Participant.
Air Product's extensive site search extended over 1\1/2\ years, and
sites were evaluated based on the following criteria: location within
Met-Ed's service territory, in or near major electrical load centers,
near a large user of steam, and near areas where interconnection to the
utility's electrical grid would be practical; reasonable access to rail
lines for fuel delivery and other major infrastructure; unzoned, zoned
or reserved for industrial use; and environmental acceptability. During
the site search, Air Products evaluated potential sites in each of Met-
Ed's three service areas. The two sites selected for detailed analysis
in the Final Environmental Impact Statement, the P. H. Glatfelter
Company property in North Codorus Township and the J.E. Baker Company
site in West Manchester Township, appeared to meet all of the criteria.
Four alternative routes for the electrical interconnection were
originally considered by YCEP and reviewed by the Department. After
initial review, one alternative was eliminated and three variations of
another alternative were added for the more detailed investigation.
Four major factors were considered in selecting the utility corridor:
(1) Achieving Met-Ed's guidelines for placing new electrical lines; (2)
satisfying certain land use objectives; (3) minimizing environmental
effects; and (4) providing accessibility for construction and
maintenance. Evaluation criteria were identified for each of these four
factors. In addition to the YCEP evaluation, the Department made site
visits to view first-hand the various routes and to assess potential
impacts from the electrical interconnection. In addition, the
Pennsylvania Game Commission was consulted and a field review was
conducted to ensure that the final corridor selection was acceptable to
the Pennsylvania Game Commission.
Environmentally Preferred Alternative
The environmentally preferred alternative is the no-action
alternative, particularly if Met-Ed were to purchase its energy and
capacity from the existing Pennsylvania-New Jersey-Maryland (PJM) power
pool. Under this
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reasonably foreseeable result of the no-action alternative, no new
construction of utility lines, substations, or other electrical
interconnection infrastructure would be required. The potential for
development and commercialization of the proposed ACFB technology would
be less likely. Nominal increases in water supply requirements and
process wastewater could occur at PJM facilities. Other environmental
impacts, either positive or negative, would not be expected. Because
this option under the no-action alternative would not further the goals
of the Clean Coal Technology Program, this no-action alternative was
not identified as the Department's preferred alternative.
Major Environmental Impacts and Mitigation Measures
In compliance with the National Environmental Policy Act, the
Department analyzed the environmental impacts and mitigation measures
associated with the construction and operation of the YCEP Cogeneration
Facility at the North Codorus site (the preferred alternative);
construction and operation of the YCEP facility at the West Manchester
site; and three scenarios that could result as a consequence of the no-
action alternative.
Preferred Alternative
Setting: Substantial construction activities for the YCEP
Cogeneration Facility at the North Codorus site will be required.
Approximately 30 percent of the 38-acre (15.4-hectare) site (11 acres
or 4.6 hectares) will be developed. Short-term impacts (lasting the
duration of the construction period) are expected both at the project
site and along the utility corridor routes.
The power transmission line intraconnection (between the YCEP
facility and the P.H. Glatfelter Company facility) will be located
between two large industrial facilities thereby limiting visual
impacts. Much of the utility interconnection corridor, and especially
the water supply and wastewater return/cooling pipelines, will be
buried underground, resulting in primarily short-term impacts during
construction.
Some long-term impacts will be associated with construction of the
utility corridors. A number of deciduous trees will be removed,
particularly during construction of the electrical interconnection to
the Bair substation. The 6.1-kilometer (3.8-mile) electrical
interconnection between the YCEP Cogeneration Facility and the new
electric switchyard at the Met-Ed substation in Bair, PA will also
result in long-term visual impacts by altering existing land uses and
changing the viewshed near historically significant properties.
The facility will introduce industrial structures into a previously
rural open space containing some treelines and will have an adverse
visual impact on the residents on Colonial Valley Road west of the
facility. Buildings will be consistent with the industrial style
architecture of existing structures in the vicinity. Landscaping
features, to be incorporated into the final design of the facility,
will help blend the facility with its surroundings. Some existing
treelines will be preserved to visually buffer the facility from
adjacent properties and existing land uses surrounding the site. The
existing treeline between the Lions Club Pavilion area and the site
will be augmented with additional plantings to improve the visual
buffer.
Air Quality: On-site fugitive air emissions from earthmoving and
excavation activities will be mitigated during construction through the
application of proper construction practices, including periodic
wetting and mulching. Disturbed land will be stabilized to the greatest
extent practical. A permit (PAS-10-Y009-1) was obtained from the PADER
Water Management Division on April 3, 1995 for on-site earthmoving
activities.
Maximum permitted air emissions during operation of the YCEP
project include 2,891 tons/year of sulfur dioxide (SO2), 127 tons/
year of particulate matter (PM10), 1,437 tons/year of oxides of
nitrogen (NOX), 1,726 tons/year of carbon monoxide (CO), and 48
tons/year of volatile organic compounds (VOCs). The project is expected
to emit no more than 2,328,968 tons/year of carbon dioxide (CO2),
which will equate to approximately 0.05 percent of CO2 emissions
from U.S. fossil fuel combustion.
Modeling results indicate that pollutant levels will be in
compliance with National Ambient Air Quality Standards (NAAQS) after
the required offsets have been obtained. In addition, the increases in
ambient concentrations for total suspended particles (TSP), particulate
matter (PM10), nitrogen dioxide (NO2), and sulfur dioxide
(SO2) will not exceed the allowable Prevention of Significant
Deterioration (PSD) increment consumption. Both Class I and Class II
PSD increment analyses indicate no significant degradation of air
quality is expected to occur in either the Shenandoah National Park
(the closest Class I area), the Gettysburg National Military Park (a
nearby Class II area).
Because the project site exceeds the National Ambient Air Quality
Standard for ozone, offsets for oxides of nitrogen (NOX) must be
obtained. Emissions from the YCEP facility must be offset by a ratio of
1.15 to 1; emission reduction credits (ERCs) equivalent to 115 percent
of the potential oxides of nitrogen (NOX) emissions will be
obtained from the P.H. Glatfelter Company and the Transcontinental Gas
Pipe Line Corporation. Under the Phase II provision of the Clean Air
Act, Title IV, YCEP will also be obliged to purchase or obtain sulfur
dioxide (SO2) ``allowances'' to continue to emit sulfur dioxide
(SO2) into the ambient air after January 1, 2000.
After offsets and allowances, actual (or expected) air emissions
should result in a net reduction in sulfur dioxide (SO2--650 tons/
year), oxides of nitrogen (NOX--415 tons/year), and particulate
matter (PM10--7 tons/year). An increase is expected in carbon
monoxide (CO--1,350 tons/year), volatile organic compounds (VOCs--35
tons/year), and radionuclides (approximately 225 millicuries/year). Due
to the expected net decreases in sulfur dioxide (SO2) and oxides
of nitrogen (NOX), the contribution of the project to levels of
acid precipitation should be very low. The expected net reduction in
sulfur dioxide (SO2) emissions should minimize adverse impacts to
visibility from regional haze due to light scattering. The net
reduction in oxides of nitrogen (NOX) emissions could also help
reduce adverse visual impacts.
Cumulative cancer risk for all routes of exposure to facility
emissions will be approximately three in one million. Most of this risk
is attributable to radionuclide emissions. The YCEP project could
deliver a maximum effective radiation dose of up to 0.03 millirem/year,
which is not known to increase the incidence of disease, mutation, or
teratogenic effects. The cumulative hazard index for exposure to
noncarcinogenic emissions is less than 1, indicating no adverse effects
on human health is expected from facility operation.
A Good Engineering Practice (GEP) stack height analysis based on
EPA's Guideline for Determination of Good Engineering Practice Stack
Height was completed for the project using building design and facility
layout information. The maximum GEP height for the main stack was
determined to be 137.2 meters (450 feet). YCEP plans to build a stack
with a height of 120 meters (395 feet). Because the planned stack
height is less than the calculated GEP formula height,
[[Page 43442]]
additional air quality modeling analyses were conducted to determine if
excessive groundlevel concentrations will occur. For carbon monoxide
(CO) and particulate matter (PM10), the worst-case groundlevel
concentrations will be below EPA and PADER significance levels. For
sulfur dioxide (SO2) and oxides of nitrogen (NOX),
groundlevel impacts will be above significance levels (and thus
required PSD increment consumption analyses to be calculated). The
percentage of sulfur dioxide (SO2) and oxides of nitrogen
(NOX) PSD increments to be consumed will range from 10 to 27
percent. The cumulative PSD incremental consumption will range from 22
to 85 percent.
To avoid excess build-up of dissolved solids in the recirculating
cooling water and to replace water lost through evaporation, make-up
water from the secondary clarifiers of the P.H. Glatfelter Company
wastewater treatment plant will be added to the recirculating water.
This wastewater will contain measurable levels of dissolved solids,
salts, and chemical compounds that will be released from the cooling
tower in the form of drift and through volatilization. These drift/
volatiles would contain inorganic trace elements such as phosphate,
manganese, total cyanide, and selenium, and organic compounds such as
chloroform. Inorganic trace elements are expected to behave as solid
materials, travel with the cooling tower drift as water droplets, and
impact the ground as water deposition. One of the organic compounds,
chloroform, will be present in the make-up water at a concentration of
0.081 mg/L and its expected maximum groundlevel concentration (through
volatilization) is 3.05 x 10-3 g/m3. Residents
located in the surrounding area will be exposed to cooling tower
emissions.
Operation of the cooling tower is not expected to result in fog or
ice on railroads in the surrounding area. Cooling tower-induced fogging
and/or icing may occur for up to 5.2 hours/year within a 200-meter
(656-foot) radius of the cooling tower to the southeast and south-
southeast within site boundaries. Plume shadowing is expected to occur
entirely within YCEP's property fenceline. Adverse impacts associated
with fogging, icing, or plume shadowing are expected to be minimal.
It is not expected that the pH of local rainwater will be
measurably lowered in the region by projected facility emissions, and
no noticeable chemical alternation of regional soils will result from
sulfur dioxide (SO2) or oxides of nitrogen (NOX) emissions.
No meaningful reduction in crop production will be attributable to the
YCEP project. Except for mercury, maximum soil concentrations of trace
elements attributable to the facility will be approximately 100 times
lower than existing soil concentrations. Mercury concentrations will be
approximately equal to existing soil concentrations. One researcher
claims that mercury is phytotoxic at levels close to existing soil
concentrations, but other researchers believe mercury is not phytotoxic
until reaching concentrations that are approximately 10 times higher
than those expected to result from the project. Although it is not
possible to specifically assess all possible effects on crops and
trees, trace element emissions from the facility are not expected to
adversely impact plants used for food and feed.
Odor-producing compounds that could potentially be emitted from the
cooling tower are expected to be primarily released during primary and
secondary treatment of wastewater before that wastewater is used by the
facility. Therefore, use of process wastewater from the P. H.
Glatfelter Company is not expected to aggravate existing ambient odors.
Odor-producing compounds from the cooling tower are not expected to
cause additional odor problems in the local community.
Geology and Soils: Construction activities for the electrical
interconnection alignment will include pole placement, foundation
installation, and clearing of rights-of-way. Temporary roads will be
needed to provide access for construction equipment. For level terrain,
earth moving will not be required, but where steep slopes are present,
extensive earth moving activities will be required to provide a stable
base for these temporary roadways. To protect existing ground,
temporary roads will be created that have a stone fill on top of a
geotextile filter cloth. Following completion of construction,
temporary roads will be removed and the land will be restored to pre-
existing conditions. Excess soil remaining following completion of
construction activities will be available for reuse by local
contractors as fill.
Construction practices at the facility will be consistent with
approved guidelines for erosion and sedimentation control. An erosion
and sediment control plan has been submitted to the York County
Conservation District and PADER for review and comment. Erosion will be
minimized by beginning cleanup and revegetation operations immediately
following completion of construction activities. Facility structures
will be designed and constructed to resist the effects of earthquake
motion as specified in section 1612 of the BOCA National Building Code.
Other mitigative measures will include constructing perimeter silt
fencing, restricting heavy truck traffic to designated corridors during
very wet or dry periods; implementing dust-abatement practices as
needed; constructing sedimentation basins along runoff interception
and/or discharge channels; and stabilizing these channels.
An unimproved access way will be maintained along the interconnect
right-of-way to facilitate periodic maintenance and inspection.
Complete clearing within a right-of-way will be limited to a 12.2-meter
(40-foot) wide portion centered directly under the wire, called the
``wire zone.'' Selective clearing will occur in the ``edge zone,''
located on either side of the wire zone, allowing compatible tree and
brush species to be left in place. Tall deciduous trees that create a
safety hazard will be removed from the entire right-of-way area. The
methods commonly used to clear rights-of-way are expected to minimize
soil disturbance.
No operation is planned that will impact soil quality. If a spill
occurs, procedures contained in YCEP's Preparedness, Prevention, and
Contingency (PPC) plan and Spill Prevention Control and Countermeasure
(SPCC) plan will be followed.
Water Resources and Water Quality: During construction of the
cogeneration facility and associated utility corridors, impacts to
water resources and aquatic ecosystems may result from equipment and
vehicle access, earth disturbance, sedimentation, erosion from exposed
soils, damaged vegetation, and placement and compaction of fill to
support new rail lines [impacting an area approximately 7.6 meters (25
feet) wide and 426.7 meters (1,400 feet) long]. Appropriate measures to
control erosion and sedimentation will be implemented; however, minor
impacts may still occur during utility line installation. Stormwater
runoff will be minimized through facility design features, dust
control, and implementation of a facility-specific stormwater pollution
prevention plan. Stormwater runoff during construction will be
collected at the existing P. H. Glatfelter Company stormwater/sediment
pond. An existing stand of vegetation between the construction area and
the site perimeter will be maintained as a buffer for stormwater
runoff. The stormwater management collection system will be constructed
in accordance with York County Conservation District
[[Page 43443]]
requirements. Proper installation, maintenance, and monitoring of
structural stormwater controls will minimize potential impacts to
surface water from stormwater runoff.
Removal of streamside vegetation along the electrical corridor will
impact water resources by causing an increase in the stream
temperature. The stream's flowing water and narrow width within these
reaches should serve to minimize the effects of this temperature
increase.
Approximately 4 acres (1.6 hectares) of floodplain will be
disturbed during construction of facilities. Placement of utility poles
will occur on approximately 0.013 acres (0.005 hectares) of the 100-
year floodplain. An estimated 4 to 8 utility poles will be located on
land belonging to P. H. Glatfelter Company and 10 to 14 utility poles
will be located on land controlled by the Army Corps of Engineers.
Temporary routes will be developed to allow personnel and equipment
access for construction; some segments will occur within the 500-year
floodplain. Portions of the rail ladder tracks and a rail spur will
also be located on land within the 100-year floodplain. The steam and
condensate return pipeline to P. H. Glatfelter Company is expected to
require placing permanent pipe supports within the floodplain. The
electrical interconnection between the YCEP Cogeneration Facility and
the Met-Ed substation at Bair, PA, will also be located within the
floodplain for a portion of its length.
Water supply requirements during operation will average 4.2 million
gallons per day (mgd); 4.0 mgd will be utilized for cooling unit make-
up requirements. Internal recycle/reuse procedures will be employed to
minimize water demands. The P. H. Glatfelter Company's wastewater will
be used directly in the cooling tower, and no additional surface water
releases from Lake Marburg are expected. The project would affect water
quality in Codorus Creek directly by changing the effluent
characteristics of the P. H. Glatfelter Company's wastewater discharge,
and indirectly by reducing flow in Codorus Creek due to increases in
consumptive use.
During a low-flow year, concentrations of most constituents will
increase by an average of 9.5 percent near the outfall, and by 3.5
percent at the York gaging station. During lowest flow conditions [as
determined by Susquehanna River Basin Commission (SRBC) requirements],
an increase of approximately 20 percent is expected. When compared to
concentrations following expected improvements from Pulp Mill
modernization, potential concentrations of most constituents will
increase by 4.6 percent at the outfall and 1.6 percent at the York
gaging station. Overall, loadings (i.e., mass) of constituents will
generally remain the same after Pulp Mill modernization. A decrease in
effluent biochemical oxygen demand loadings (10 percent) and suspended
solids loadings (4 percent) are expected as a result of higher levels
of wastewater treatment resulting from the Pulp Mill modernization.
Evaporation of 2.8 mgd of wastewater effluent due to cooling tower
operation will reduce the discharge flow at the outfall from 12.5 mgd
to 9.7 mgd. The greatest effect from increased consumptive use will be
immediately downstream of the P. H. Glatfelter Company's discharge. It
is expected that the impact from this increase in consumption will be
attenuated further downstream, where flow will decrease 4.9 percent
[from 88 to 84 cubic feet per second (cfs)] during normal flow periods
and 9.6 percent (from 45 to 41 cfs) during low-flow years; minimum flow
will decrease to about 17 cfs (from 21 cfs). Consumptive wastewater
loss due to evaporation will reduce P. H. Glatfelter Company's
wastewater effluent volume by 25 percent. The cooling tower's
consumptive use will help reduce the amount of heated wastewater
discharged to Codorus Creek, and thereby will decrease creek
temperature. In-stream temperatures will decrease by 1 to 2 degrees in
the summer and 2 to 3 degrees in the winter. Decreased creek
temperature will tend to improve the dissolved oxygen concentration
downstream from the P. H. Glatfelter Company's outfall. Removal of
streamside vegetation for utility corridors could result in increases
in water temperature. Operation of the cogeneration facility will
degrade water color and cause a subsequent increase from Pulp Mill
modernization improvements to 165 color units.
To monitor potential adverse impacts to Codorus Creek due to
facility operation, YCEP will conduct periodic sampling and testing. On
a quarterly basis and during low-flow events for the duration of the
project's demonstration phase, YCEP will sample for temperature, color,
total dissolved solids, lead, copper, chloride, free cyanide,
phenolics, and chloroform both upstream and downstream of the P. H.
Glatfelter Company's discharge. The results will be provided to the
Department of Energy and made publicly available to the local public
reading rooms by YCEP.
Biological Resources and Biodiversity: Land disturbances resulting
from construction activities could have an adverse impact on the
biodiversity of terrestrial ecosystems. Habitat types potentially
impacted by construction of the cogeneration facility include
approximately 12 acres (4.8 hectares) of cultivated land, 2 acres (1.2
hectares) of maintained area (including a softball field), 0.3 acres
(0.12 hectares) of successional field, and small areas of hardwood
forest (less than 0.1 acre or 0.04 hectare).
Approximately 0.3 acres (0.08 hectares) of wetlands (within the
100-year floodplain) will be occupied by the new steam and condensate
return pipeline corridor facilities. Wetland values, such as floodplain
stabilization, ecological diversity, and water quality improvement, are
expected to be minimally impacted by the project. Fencing will be
installed around the perimeter of all off-site jurisdictional wetland
areas on P. H. Glatfelter Company property. Coordination, including on-
site review with the Army Corps of Engineers, will take place prior to
any wetland disturbing activities. The U.S. Army Corps of Engineers'
mitigation recommendations will be explicitly followed.
Construction of the power line will alter some wildlife habitat,
disturb some riparian and forest vegetation, and cause impacts to soil
and vegetative resources. Work in the electrical interconnection
corridor is planned for the dry season to minimize damage to vegetation
and soils, and to expedite construction. Vegetation removal along the
utility lines and electrical interconnections will result in the loss
of approximately 3.7 acres (1.5 hectare) of disturbed upland woody
vegetative and 0.8 acres (0.3 hectares) of wetland woody vegetation on
the P. H. Glatfelter Company property; 0.9 acres (0.4 hectares) of
wooded area along stream crossings and on Army Corps of Engineers Flood
Control Property will also be removed. Stream crossings will be
strategically placed to coincide with areas already impacted by roads
or rail. The stringing operation of tossing the pulling rope across the
creek and carrying it to the next pole will help minimize impacts to
riparian habitat.
It is expected that vegetation removal and clearing within the
Indian Rock Dam project will affect the area licensed to the
Pennsylvania Game Commission. Habitat modification in this area will
require coordination with both the Army Corps of Engineers and the
Pennsylvania Game Commission prior to construction. Vegetation
management strategies will be used to minimize forest fragmentation.
Low impact clearing methods planned for this
[[Page 43444]]
operation will avoid the use of heavy equipment, and all vegetation
removed will be left in the right-of-way. Logs and limbs will be
reduced to chip materials and left as mulch.
When conducting selective clearing or cutting within the right-of-
way, an effort will be made to prevent damage to ``compatible'' plants
that do not interfere with electrical transmission. Use of a chemical
herbicide will be required to control stumps of deciduous trees;
herbicides will be used in compliance with environmental protection
rules. Temporary access roadways will later be returned to their
original state.
The Pennsylvania Game Commission has stated that impacts to
wildlife habitats on U.S. Army Corps of Engineers land within the
utility corridor right-of-way can be addressed through proper
mitigation. As part of the Mitigation Action Plan for the project, YCEP
is required to comply with the following provisions:
Riparian areas along Codorus Creek cleared for
transmission lines are to be planted with various low growing shrub
species to replace lost wildlife habitat.
Construction of the transmission line through Pennsylvania
Game Commission property is to be coordinated with the agency to avoid
conflicts with hunting seasons, farming, and other management
activities.
To increase breeding habitats for waterfowl species, wood
duck nesting boxes and other water fowl nesting structures are to be
placed along Codorus Creek to replace nesting areas lost because large
trees are removed. Kestrel nesting boxes, bat boxes, and other wildlife
nesting/resting structures are to be placed on the single-shaft steel
or wooden poles supporting the transmission line.
Warm season grass species are to be planted to provide
both food and cover for wildlife at different times of the year.
To provide cover for wildlife, brush piles are to be
constructed with the vegetation cleared or trimmed during pole and
transmission line placement.
Evaluations of projected physio-chemical changes to Codorus Creek
suggest that biodiversity within the aquatic ecosystem could
potentially be adversely impacted. Although the Pulp Mill Modernization
Project should result in beneficial impacts to the creek because
reductions in effluent concentrations of inorganic dissolved solids
(especially chloride) and wood pulping products (e.g., tannins and
lignins) will reduce in-stream salinity, total organic carbon,
biochemical oxygen demand, chemical oxygen demand, and color, these
gains will be partially or totally offset by the project. Reductions in
concentrations of chloride will be partially offset, and total
dissolved solids and color units will increase slightly over
concentrations existing prior to modernization. Concentrations of most
inorganic constituents, although reduced by the Pulp Mill Modernization
Project, will increase above the concentrations observed before
modernization. For organic constituents, most concentrations will
remain below the concentrations observed before the Pulp Mill
Modernization Project.
Projected pollutant concentrations will increase, but they are not
expected to exceed EPA ambient water quality criteria at either mean-
flow or low-flow year conditions. For both low- and mean-flow
conditions, projected concentrations of manganese, selenium, and
chloroform will be less than the EPA ambient water quality criteria. A
comparison of projected low- and mean-flow concentrations of aluminum
and cyanide using recalculated acute and chronic water quality criteria
for warm water aquatic species indicate that these chemical
concentrations will be below levels likely to adversely impact aquatic
organisms in Codorus Creek. Available toxicity data for copper,
adjusted for the hardness values in P. H. Glatfelter Company's
discharge and in Codorus Creek, indicate that toxic impacts will not
occur.
During low-flow years, reduced flow could potentially affect
aquatic organisms immediately downstream from the P. H. Glatfelter
Company's outfall because mixing will be reduced and habitats may be
lost or segregated where the depth and cross-sectional areas of Codorus
Creek are reduced. Impacts on aquatic communities will be attenuated as
the drainage from sources below the P. H. Glatfelter outfall increase
the downstream volume.
Because rare or threatened plant or animal species have not been
reported on the site or along associated utility corridors, no impacts
to such species are expected as a result of the project.
Human Health and Safety, Including Waste Disposal: Construction-
and operation-related risks will be minimized by YCEP's adherence to
Occupational Safety and Health Administration (OSHA) and Air Products
and Chemicals, Inc. health and safety standards. Construction permits
and safety inspections will also be employed in an effort to minimize
the frequency of accidents and further ensure worker safety.
Implementing appropriate engineering controls will minimize potential
impacts. Operation equipment will be required to meet all applicable
safety design and inspection requirements, and personal protective
equipment will meet regulatory and consensus standards for adequacy.
YCEP will develop an internal Spill Prevention, Control,
Countermeasure, and Hazardous Waste Contingency Plan (SPCC) for the
prevention of accidents, which will include explicit procedures to be
followed in an emergency. The SPCC plan, required by the EPA, will also
outline engineering design measures incorporated into the facility to
minimize the potential for oil and chemical spills. Oil and grease
drums will be kept inside buildings to prevent exposure to rainfall.
All transport piping will be constructed of compatible material to
prevent corrosion or deterioration by the liquid being carried. Prior
to plant start-up and the first delivery of chemicals, the facility
will develop a Preparedness, Prevention, and Contingency (PPC) plan
that will include procedures for prompt handling and reporting of any
spill in accordance with regulatory requirements as well as a list of
measures to mitigate such a release. The facility will have a Plant
Safety Standard Practice Manual that will serve as a guide for
providing a safe and healthy work environment for employees, visitors,
contractors.
Employees will be trained in safety procedures prior to working in
the facility and refresher training will be provided. Employees who
potentially could be exposed to chemicals will be trained on their safe
handling.
Approximately 7,646 cubic meters (10,000 cubic yards) of waste will
be generated over the 3-year construction period, and approximately 3
tons/month of municipal waste will be generated during operation of the
YCEP Cogeneration Facility. Most of the municipal waste will consist of
paper and cardboard, which will be disposed through a private
contractor. The only solid waste potentially produced from construction
and operation of utility lines will be woody debris associated with
right-of-way clearings during periodic vegetative control activities.
Some woody debris will be left in place to promote habitat use by
upland game species.
During full operation, it is expected that up to 270,000 tons/year
of ash byproducts will be generated. YCEP will test the ash waste prior
to disposal to ensure its nonhazardous classification under the
Resource Conservation and Recovery Act (RCRA). The ash handling system,
located in the ash silo area, will include ash conditioning equipment
to dampen the ash with water, thus minimizing the potential for
fugitive dust emissions prior to loading into
[[Page 43445]]
totally enclosed 25-ton net capacity trucks. These trucks will be used
in accordance with applicable state regulations. YCEP proposes to
transport the ash byproduct to the Harriman Coal Corporation (Harriman)
in Schuylkill County, PA. The impact from disposal of the ash byproduct
will be positive and long-term because of its beneficial use in mine
reclamation.
It is expected that the facility will qualify as a small quantity
generator of hazardous waste (less than 1,000 kilograms per month) and
will meet all applicable state and federal requirements. Spent
degreasing solvents will be the only hazardous waste generated by the
facility.
YCEP proposes to use aqueous ammonia instead of anhydrous ammonia
in its selective non-catalytic reduction (SNCR) system because aqueous
ammonia is safer to handle and store. The ammonia storage tank will be
located within a fully contained and diked concrete area to provide
sufficient secondary containment. Although using chlorine dioxide
solution as the biocide in the cooling water recirculating system is
more expensive than chlorine gas, the use of chlorine dioxide was
determined to be the best alternative for this cooling water treatment
application because it avoids the need to store and use gaseous
chlorine material; tends to react with organics by oxidation (including
phenols) and does not appreciably produce chlorinated organics; and
does not tend to contribute to the formation of chloroform or
trihalomethanes.
YCEP will apply a general policy of ``prudent avoidance'' in
residential areas, near schools, churches, and other public gathering
places when locating utility lines, to reduce the potential for impacts
from electromagnetic fields (EMFs). YCEP has accepted, as a general
guideline, the Met-Ed policy of attempting to maintain a 100-meter
(328-foot) minimum setback. Magnetic field levels in the vicinity of
the line will be minimized through the use of a triangular conductor
layout. The maximum magnetic field predicted is 150 milligauss inside
the switchyard at Bair, which is less than the magnetic field expected
from a vacuum cleaner at a distance of 0.3 meters (1 foot). The field
intensity will fall off rapidly and the highest field expected beyond
the switchyard perimeter fence is 10 milligauss, equivalent to the
field from a vacuum cleaner at 1.2 meters (4 feet). The expected
magnetic field intensity at the closest residence is less than 1
milligauss, which equates to the magnetic field of a digital clock at a
distance of 1.2 meters (4 feet). YCEP has negotiated purchase options
on two residential properties near the switchyard in Bair, and will
assume ownership of these properties. For the proposed rail/trail along
the York-Hanover trolley route, the areas of maximum exposure would be
near the existing Bair Substation and directly beneath transmission
lines entering the switchyard. This is a distance of approximately 107
meters (350 feet), and trail users will potentially be exposed to
magnetic fields of 10 milligauss. Beyond this point, magnetic fields
will drop off drastically, and trail users will be exposed to fields
between 1 and 5 milligauss for approximately 0.8 kilometers (0.5
miles).
Noise: The projected increase in noise resulting from construction
activity at the site is expected to be 3 dBA or less (a barely
discernible increase) at all receptor locations and through all
construction phases. Construction of the electrical intraconnection,
wastewater discharge line, and steam and condensate return lines will
be of limited duration and will occur near the existing noise sources
at the P. H. Glatfelter Company paper mill.
There will be some noise associated with construction of the power
transmission line and expansion of the switchyard facility, which will
be located more than 122 meters (400 feet) from the nearest residence.
Noise levels affecting these and other residences in Bair, PA will be
comparable to those produced by similar standard construction
activities. Once constructed, the switchyard facility will be
landscaped with trees and shrubs around its outside perimeter fence to
help buffer noise from facility operations.
Construction activities will involve the purging of dirt and
construction debris from steam systems. Because purging could result in
very high noise levels, special mitigation measures will be utilized,
such as using silencers, minimizing the occurrence, scheduling purging
during less sensitive times of the day, and providing advance notice to
the potentially affected public.
Adverse impacts from increased noise levels are expected during
operation. Primary sources of project operation noise will come from
steam venting and rail car coupling. A vent silencer will be installed
to lessen the noise associated with the release of steam. Coupling
activities will be of short duration. In addition, low noise design
equipment will be used, as appropriate. When necessary to provide
further sound attenuation, equipment noise sources will be enclosed in
insulated buildings designed to absorb noise. Additional noise
mitigation features incorporated into the facility design include
extended fan housings on the cooling tower, thermal and acoustic
insulation around the induced stack draft fan, and discharge silencers
on the ventilation and forced draft fans. The spatial orientation of
major noise production structures are planned to block direct
propagation of noise to off-site receptors.
Transportation and Traffic: A peak employment of 974 persons during
construction will result in an additional 712 vehicles accessing the
project site, with an average increase in employee traffic of 178
vehicles per day. An increased accident risk of fewer than 4 accidents
per year could potentially occur during the construction period.
York Road and Colonial Valley Road will experience a degradation in
Levels of Service (LOS), from LOS D to LOS E during the a.m. peak hour.
During the p.m. peak hour, traffic on Colonial Valley Road at the
westbound approach of York Road will operate at LOS D compared to LOS C
without construction traffic. Northbound traffic turning west into the
project site at the York Road and Roundwood Facility Access Drive
intersection will operate at LOS E during the a.m. peak hour compared
to a LOS A without construction traffic; traffic exiting the facility
will operate at LOS F. During the p.m. peak hour, LOS F conditions will
exist for traffic exiting north and south onto York Road. Southbound
traffic on York Road at the Jefferson Road and Lehman Road intersection
will operate at LOS E during the p.m. peak hour compared to an LOS C
without construction traffic.
All material laydown and employee parking areas will be located on
site. In addition, to address the existing problem of occasional
disruption to traffic flow on York Road from an overflow of log truck
queues on the driveway, an additional truck parking area to accommodate
the queue will be provided. Facility security will enforce a ban on on-
street parking. Traffic conditions throughout the construction period
will be monitored. If congestion is noted, additional mitigation
measures, such as scheduling of shifts to further avoid peak periods or
the stationing of traffic control personnel at critical locations, will
be instituted.
The electrical interconnections will cross township roads used by
farmers and residents, but construction activity will be scheduled to
minimize disturbances to traffic on these roads. Construction will slow
traffic and measures will be taken to minimize this impact.
[[Page 43446]]
The projected increase in traffic resulting from operation of the
facility will be approximately 125 vehicles per day, for a total
projected access driveway volume of 325 vehicles per day. An increased
accident risk of approximately 2 accidents per year could occur during
the operation of the facility. Levels of Service (LOS) during both the
a.m. and p.m. peak hours will be degraded. An increase of 5 percent in
total intersection traffic at York Road and Colonial Valley Road is
expected during both the a.m. and the p.m. peak hours. At the
intersection of York Road and the Roundwood Facility Access Drive,
traffic could increase as much as 8 percent during the a.m. peak hour
and 8.5 percent during the p.m. peak hour. At the York Road, Jefferson
Road, and Lehman Road intersection, an increase of 5 percent in total
traffic during both the a.m. and the p.m. peak hours is expected during
operation. Installation of a traffic signal at the intersection has
been approved by the Pennsylvania Department of Transportation.
Land Use: The site of the facility in North Codorus Township will
be purchased by YCEP. Project approval must be obtained under the North
Codorus Township Land Development and Subdivision Ordinance. Non-
industrial land uses, primarily residences located south of the site,
will not be buffered from the facility by either distance or
intervening industrial structures. A vegetative screen will be provided
by landscaping to shield these residences from the YCEP facility. No
change in land use trends and controls will be required for
construction of the cogeneration facility or the utility pipeline.
Impacts to land use will occur during construction of some portions
of utility corridors as a result of temporary disturbances during pole
installation. Construction and placement of each pole will disturb
approximately 2.3 square meters (25 square feet) of surface and could
require access to the area for periodic maintenance. The electrical
interconnection will not prevent existing land uses of light industry,
agriculture, wildlife conservation, and flood control. In some
instances, the electrical interconnection will cross wooded or riparian
lands and will require removal of some woody vegetative cover. Within
the identified right-of-way, the alignment will permanently alter
industrial or wooded/riparian land uses. No permanent conversion of
prime agricultural land is expected to occur.
Before installation of the switchyard at the Bair substation, YCEP
must obtain approval from the West Manchester Township Zoning Hearing
Board for a ``special exception use'' for public utilities. YCEP must
prove that construction at the electric switchyard at the Bair
substation will not discourage use of adjacent land and buildings and
that the location, nature, and height of new buildings, walls, and
fences will not impair the value of adjacent land and buildings.
Specifically, YCEP must show that the public utility will not emit any
obnoxious noise, glare, dust, odor, vibration, electrical disturbance,
or have other objectionable impacts. Once the electric switchyard is
completed, the surrounding area will be landscaped to be compatible
with local scenery. YCEP is considering a design change for the
switchyard so it can be built entirely on existing Met-Ed property, and
thus not require a zoning exception.
Pollution Prevention: The YCEP Cogeneration Facility will implement
the pollution prevention programs that have been adopted by Air
Products. Air Products has adopted the voluntary Chemical Manufacturers
Association (CMA) Responsible Care Pollution Prevention Code of
Management Practices. The facility is expected to be in full compliance
with the code within 4 years after start-up.
The facility's material handling systems for coal, limestone, and
ash byproducts will be completely enclosed to minimize fugitive dust
emissions to the environment. Potential emission points in the material
handling systems will be equipped with dust control systems. Chemical
and storage areas will be equipped with secondary containment to avoid
discharge to the surrounding environment. In the event of a tank leak
or a system leak, spilled liquid will be retained within the concrete
containment area. Tanks will include a lock valve that will open to a
sump. To reduce the potential for equipment failures, a preventive
maintenance program will be implemented.
Other pollution prevention measures include the selection of water
treatment chemicals that do not adversely impact the environment (e.g.,
the cooling tower circulating water system will use a phosphate-based
rather than a heavy-metal based treatment program, and ash byproducts
will be used for mine land reclamation rather than landfill disposal.
General good housekeeping practices (e.g., neat and orderly storage
of chemicals, prompt cleanup of small spills, regular refuse removal,
maintenance of clean, dry floors, and proper storage of containers away
from walkways and roads) will be followed at the facility.
Cultural Resources: Three historical districts and eight individual
historical resources within the viewshed of the facility site, and one
district and three individual historical resources within the viewshed
of the electrical interconnection route were identified as eligible for
listing on the National Register of Historic Places. The Bureau for
Historic Preservation (the Bureau) originally determined that the
cogeneration facility would have an adverse visual effect on one
historical district and three historical individual resources but
decided, that for two of the resources, planned landscaping would
mitigate the adverse effects. Consequently, an unavoidable adverse
visual impact to one district and one individual resource will result.
For these, non-traditional mitigation measures are being negotiated
between the Department and the Bureau. A draft Memorandum of Agreement
has been written calling for YCEP to publish a history and self-guided
tour of the Dempwolf Architectural Firm and to assist the Bureau with
computer coding, mapping, and general organization of York County
historical survey records. The Bureau has indicated that through these
non-traditional methods, mitigation of the unavoidable visual effects
is possible. Construction and alignment of project pipelines will not
affect historic properties. No evidence of archeological resources has
been found. Therefore, no archeological impacts are expected from
construction of either the facility or associated utility corridors.
Socioeconomic Resources: Because of the skilled construction labor
force existing in the York County area, it is expected that much of the
construction workforce for the project will be hired regionally. This
will have a positive, but temporary, impact on regional unemployment
rates. During construction, supporting local retail establishments will
be positively impacted by increased revenues, and the regional economy
may benefit from an influx of wage dollars.
To the extent practical, the 70 person full-time workforce for the
operational facility will be derived from the local labor force. The
impact of these newly created positions, along with new positions in
related sectors, will be positive but not significant (i.e., less than
a 0.1 percent reduction in York County's unemployment rate). Increased
tax revenues may benefit local and state infrastructure and government
programs, including schools, roadway systems, and hospitals; this could
have a positive impact on local property
[[Page 43447]]
values. However, other factors, such as visual appearances, noise, and
traffic may have negative impacts on real estate values.
Because much of the labor force will be supplied locally, increased
demands on public and community services will be minimal. A fire water
system, designed in conformance with Uniform Fire Code and applicable
National Fire Protection Association standards, will minimize impacts
to community fire protection services from facility operation.
The Lions Club picnic pavilion and fishing area will receive a
long-term, direct negative impact from the introduction of additional
industrial structures into the viewshed. The electrical interconnection
corridor will cross a mix of land uses including light industrial,
agricultural, conservation, and flood control properties. Placement of
the electrical poles will entail a visual impact. Compared to baseline
conditions, water quality for the protection and propagation of fish
and wildlife and for recreation in or on the water should be minimally
impacted by the project.
The project should provide consumers with predictably priced
electricity. It is not possible to speculate what effect the project
will have on long-term electric rates because of uncertainties in
energy markets and the specific factors that contribute to long-term
analyses.
Environmental Justice: Neither construction nor operation of the
facility and associated utility corridors will have disproportionately
high and adverse human health or environmental effects on low-income or
minority communities. The minority community located in Jackson
Township is not expected to experience visual or noise-related impacts
due to its distance from the utility corridor and electric switchyard.
Proposed Project at the Alternative Site Location
Substantial construction activities would be required to build the
cogeneration facility at the West Manchester site. Approximately 20
percent of the 47-acre (19-hectare) site [9.4 acres (3.8 hectares)]
would be developed. The industrial function of the facility at the West
Manchester site would be consistent with existing structures located at
the J.E. Baker Company surface mining and brick manufacturing complex.
Air Quality: Projected air emission rates, without offsets or
allowances, would include 2,300 tons/year of sulfur dioxide (SO2),
107 tons/year of particulate matter (PM10), 1,212 tons/year of
oxides of nitrogen (NOX), 1,454 tons/year of carbon monoxide (CO),
and 39 tons/year of volatile organic compounds (VOCs). Emissions
generated by the main boiler would be controlled through selective non-
catalytic reduction (SNCR) for limiting oxides of nitrogen (NOX)
emissions to 0.125 lbs/MMBtu, a baghouse for limiting emissions of
particulate matter (PM10) to 0.011 lbs/MMBtu, and limestone
injection into a single train ACFB boiler to limit sulfur dioxide
(SO2) emissions to 0.25 lbs/MMBtu. The West Manchester site is
located in the Northeast Ozone Transport Region (NOTR) that exceeds
National Ambient Air Quality Standards for ozone. Therefore, oxides of
nitrogen (NOX) offsets would be required. With offsets, the
overall (net) NOX levels would be reduced by 182 tons/year.
A comparison of anticipated emissions of sulfur dioxide (SO2),
oxides of nitrogen (NOX), and particulate matter (PM10)
between the 227-megawatt coal-fired facility at the West Manchester
site facility and at the North Codorus site, indicates that these
emissions at the West Manchester site would exceed the levels of these
emissions at the North Codorus.
Modeling analysis indicates that operation of the cooling unit at
the West Manchester site would have minimal impacts on the roadways and
railroad surrounding the facility. Emigs Mill Road, east of the cooling
unit, would experience less than 30 minutes of fogging annually as a
result of operation of the West Manchester facility. No other roadways
surrounding the facility would be impacted. There would be no occasions
where the cooling unit would also induce icing on roadways adjacent to
the facility. The cooling unit plume would cause less than 15 minutes/
year of fogging and/or icing on adjacent Yorkrail tracks. Results of a
study conducted by Dr. Ducatman, Director of the West Virginia
University's Institute of Occupational and Environmental Health,
concluded that the groundlevel concentrations of emissions from the
facility at the West Manchester site would not expose the York County
community to a health risk.
Geology and Soils: Construction impacts to soil would include loss
of excavated soil from water and wind erosion, reduction of soil
quality from mixing topsoil with subsoil, and soil compaction from
activities of construction equipment. Construction involving site
grading, preparation, and placement of fill would alter the existing
topography, and excavation would be necessary. Non-organic soils found
on the site would be expected to be suitable for uses such as compacted
fill for loaded structures, pavements, and embankment construction, as
well as for landscaping and grading purposes. A total of 98,763 cubic
meters (129,169 cubic yards) of on-site excavated materials would be
used for site preparation and access roadway construction.
Water Resources and Water Quality: Water supply requirements for
construction of the facility at the West Manchester site would be
30,000 to 100,000 gallons per day (gpd), which would be supplied by the
York Water Company municipal distribution system; no adverse impact to
company service would be expected. In addition, handling, treatment, or
discharge of sanitary wastes during construction would not be expected
to impact existing sewage systems or surface water.
Dewatering would be required during construction activities if a
shallow water table were encountered, but water table levels would
return to their original contours following completion of dewatering
activities. No long-term impacts to groundwater would occur. No
construction would occur within the 100-year floodplain.
Water supply requirements during operation of the facility at the
West Manchester site would range between 2.8 and 3.0 mgd. Adequate
surface water resources would be available to meet water supply needs
during normal and excess rainfall periods. A net water savings of 80 to
180 gpm would be obtained through recycling and reuse. Consumptive use
for the facility at the West Manchester site would range from 2.5 to
2.6 mgd, which is greater than the Susquehanna River Basin Commission
(SRBC) regulatory threshold of 20,000 gpd. Consequently, the facility
in West Manchester would be subject to SRBC's consumptive use
compensation requirement.
All ambient water quality and thermal discharge criteria would be
met. Within the discharge's zone of initial dilution, the total
dissolved solids (TDS) concentration is expected to increase by
approximately 100 mg/L; following complete mixing, an increase of 30
mg/L is anticipated. In-stream TDS concentrations are expected to
remain below the 500 mg/L standard. The PADER thermal discharge
criterion would be met because of available in-stream dilution capacity
and the facility's use of a stormwater retention pond on the West
Manchester site for cooling. The facility at the West Manchester site
would also be capable of meeting the effluent limitations for
[[Page 43448]]
total suspended solids, oil and grease, pH, chlorine residual, zinc,
and polychlorinated biphenols defined by EPA's pretreatment standards
for new sources.
Biological Resources and Biodiversity: No construction of site
facilities would take place in a wetland; however, electric
transmission lines and non-contact discharge pipelines would cross
narrow wetlands. A permit to construct these utility corridors would
need to be obtained. The most probable electric transmission line route
would cross a narrow wetland associated with Honey Run. The crossing
would consist of an overhead span, and vegetation in the existing
meadow wetland would not require additional management for right-of-way
maintenance. No alterations to wetlands would be expected to occur. The
non-contact wastewater discharge pipeline would cross approximately 4.8
kilometers (3 miles) of wetlands between the West Manchester site and
its discharge to Codorus Creek. Short-term impacts to herbaceous
wetlands have occurred previously with placement of underground utility
pipelines. A limited, temporary impact to wetlands would also occur if
a natural gas pipeline were installed along a proposed alternative
route. The route would cross few wetlands and all construction would
take place in areas that were previously altered for roadway
construction and use. Construction in wetlands would occur during
periods of low flow and if necessary, flow would be diverted during
construction. Following completion of construction, affected areas
would be restored to their original contour, and altered areas would be
revegetated with appropriate species.
No threatened or endangered plant or animal species were reported
to occur on the West Manchester site or within the area of proposed
associated infrastructure routes.
Noise: Increased outdoor noise levels at four residences closest to
the project at the West Manchester site would be clearly perceptible.
Daytime noise levels at two residences to the north and east of the
site and at the golf course located to the west of the site would
increase by approximately 14 to 20 dBA. The noise increase at more
distant receptors to the south and southeast would range from 3 to 12
dBA.
The purging of steam systems of dirt and construction debris would
be scheduled for several brief periods; this process may result in
extremely high noise levels. To limit the impact from noise during this
process, special mitigation measures would be utilized, including
efforts to minimize the extent of the process, scheduling the process
during daylight hours, and providing advance notice to the potentially
affected public.
Transportation and Traffic: Traffic studies indicate that traffic
flow is already slow in many of the affected areas and would be
aggravated. Along the East Berlin Road, one intersection (East Berlin
Road/Emigs Mill Road) would experience a change in level of service
(LOS) during p.m. peak hours. A decline from LOS D to LOS E would be
expected at this intersection from construction traffic. Most Route 30
intersections, which are already operating at unsatisfactory levels of
service, would be expected to experience significant impacts during
construction. Once the facility is operational, only one intersection
(Route 30 and Emigs Mill Road) would experience a decline in level of
service. During the a.m. peak hour, facility traffic would cause
southbound traffic on Emigs Mill Road to decline from LOS C to LOS D.
Plans are underway, independent of this project, to improve highway
conditions.
Land Use: The West Manchester site would be located within the
General Industrial Zone, which is the most intensive level of
industrial zoning in the township. Even though the site is designated
to be used for industrial purposes, construction of the facility would
impact existing agricultural land use. Coordination would be conducted
with the appropriate zoning authority. Utility interconnection
corridors may require a Conditional Use Permit because the project is
not included as a specifically permitted use within the General
Industrial Zone. The West Manchester site is of adequate size to comply
with the minimum area requirements that apply to this General
Industrial Zone. Most of the proposed facility structures would be less
than the 30.5-meter (100-foot) maximum permitted height or could
accommodate required setback distances. Features exceeding the maximum
height (e.g., the facility stack) would require zoning approval.
Environmental Justice: Construction and operation of the facility
at the West Manchester site has the potential to impact both minority
and low-income communities. Although the site is located in an
industrialized area, three census tract block groups within a 5-
kilometer (3.1-mile) radius contain minority population concentrations
higher than the county average. In addition, a low-income community is
located in the same census tract block group as the West Manchester
site. Thus, there is a potential for greater environmental justice
impacts from the project at the West Manchester site compared to the
preferred alternative.
No-Action Alternative
Substantial construction activities would be required for the gas-
fired facility and the coal-fired facility options. The number of acres
developed for the coal-fired facility would be similar to that for the
preferred alternative [approximately 38 acres (15.4 hectares)].
Approximately 10 acres (4 hectares) would be developed for the gas-
fired facility. No construction would be required for the PJM
Interconnection Power Pool option.
Many impacts from construction, which apply only to the coal-fired
facility and gas-fired facility options, would be similar to impacts
identified for construction of the preferred alternative. Because
generic sites were analyzed, it is assumed that appropriate sites would
be used and thus no adverse land use, cultural resources, or
environmental justice impacts would occur. During construction of the
gas-fired facility, monthly employment would average approximately 180
persons compared to 350 for the preferred alternative; consequently,
less traffic impact would result. Employment during construction of the
coal fired facility would be similar to employment for the preferred
alternative and all related impacts would be comparable. Impacts
associated with operation of the three no-action alternative options
are as follows.
Setting: It is assumed that the additional structures for the gas-
fired and coal-fired facilities would not alter visual quality. The
tallest structures for the coal-fired facility would be similar in
height to those of the preferred alternative. The gas-fired facility's
exhaust stack would be between 45.7 and 61 meters (150 and 200 feet)
tall [compared to the 120.4-meter (395-foot) stack associated with the
preferred alternative]. Building height would be approximately 30.5 to
45.7 meters (100 to 150 feet) tall [compared to 57.9 meters (180 feet)
for the preferred alternative]. There would be no new structures to
alter visual quality for the PJM Interconnection Power Pool option.
Air Quality: Anticipated air emission rates during operation of a
gas-fired facility would include 26 tons/year of sulfur dioxide
(SO2), 23 tons/year of particulate matter (PM10), 240 tons/
year of oxides of nitrogen (NOX), 144 tons/year of carbon monoxide
(CO), and 35 tons/year of volatile organic compounds (VOCs).
Anticipated air emission rates
[[Page 43449]]
during operation of a coal-fired facility would include 2,456 tons/year
of sulfur dioxide (SO2), 108 tons/year of particulate matter
(PM10), 1,226 tons/year of oxides of nitrogen (NOX), 1,474
tons/year of carbon monoxide (CO), and 41 tons/year of volatile organic
compounds (VOCs). Compared to the preferred alternative, the coal-fired
facility emissions would be approximately 15 percent less because it
would burn less coal and produce less energy, since it would not supply
steam to an adjacent host. Radionuclide emissions would be much lower
from a gas-fired facility when compared to any of the coal-fired
options.
If either the gas-fired or the coal-fired facility were to be
located in the NOTR, oxides of nitrogen (NOX) offsets would be
required. Under the gas-fired facility option, the overall (net) oxides
of nitrogen (NOX) reduction would be 36 tons/year and under the
coal-fired facility option, the overall (net) reduction would be 184
tons/year. Secondary emissions associated with the gas-fired facility
would be less than for the preferred alternative because fewer workers
would be required and the need for rail delivery of coal and shipments
of limestone-ash byproduct would be eliminated.
Under the PJM Interconnection Power Pool option, 0.4 percent of the
existing total capacity of the facilities would be utilized by Met-Ed.
No increases in air emissions at existing PJM facilities would occur.
Water Resources and Water Quality: No increases in water supply
requirements or wastewater discharges would occur from the purchase of
existing electrical capacity from the PJM pool. One mgd of freshwater
would be required for cooling under the gas-fired facility option; 2.5
mgd would be required under the coal-fired facility option. The gas-
fired facility would be expected to use 200,000 gpd for boiler make-up
and to discharge approximately the same amount. The coal-fired facility
would be expected to use 340,000 gpd for boiler make-up. For the gas-
fired facility option, non-cooling water consumption would decrease 40
percent compared to the preferred alternative; for the coal-fired
facility option, the decrease would be 15 percent. Discharges from both
the gas-fired and coal-fired facilities would be expected to raise
water temperature in the receiving surface water bodies.
Biological Resources and Biodiversity: It is possible that because
of reduced spatial requirements for the gas-fired facility, less
disturbance to wildlife habitats would take place. No other impacts to
biological resources or biodiversity would be expected from any of the
no-action alternative options.
Human Health and Safety: Impacts from the coal-fired facility
option would be similar to those for the preferred alternative; however
approximately 10 to 15 percent less ash byproduct would be generated
because less fuel would be consumed. There would be no coal handling
requirements or related mitigation measures needed for the gas-fired
facility option. Instead, special procedures for natural gas (e.g.,
leak detection) would be implemented. Less municipal waste, compared to
the preferred alternative would be generated and no ash byproduct would
be produced. Current facility health and safety procedures would not be
affected with the PJM Interconnection Power Pool option. No impacts to
the health and safety of employees or the local population would occur
with any of the no-action alternative options.
Noise: It is expected that noise levels for the coal-fired facility
option would be equivalent to those of the preferred alternative. For
the gas-fired option, noise attributed to coal handling and processing
equipment would be eliminated. Because there would be no increase in
operating activity at existing facilities with the PJM Interconnection
Power Pool option, there would be no impact on existing noise levels.
Transportation and Traffic: Impacts to transportation and traffic
would be similar between the preferred alternative and the coal-fired
facility option. No additional impacts to traffic or transportation
would occur with the PJM Interconnection Power Pool. It is assumed that
for the gas-fired facility option, operation impacts to transportation
and traffic would be less than those for the preferred alternative
because of reduced employment levels. In addition, impacts from rail
traffic for coal delivery and truck traffic for limestone delivery and
ash removal would be avoided. If the gas supply is interrupted,
however, continuing supplies would need to be delivered by tandem
trucks, thus impacting the transportation infrastructure.
Socioeconomic Resources: $75 million in federal funds would not be
expended for any of the no-action alternative options. Socioeconomic
resources would benefit from the sale of excess capacity with the PJM
power pool option; but because the sale of 227 megawatts represents
only 0.4 percent of the total capacity available for sale, the increase
would not be significant. Socioeconomic impacts (e.g., employment,
property tax revenue, electricity cost) for the coal-fired facility
option would be similar to those of the preferred alternative.
The payment of property tax, under the gas-fired facility option,
would be approximately 40 to 60 percent less than for the preferred
alternative. Employment would be 25 to 30 workers compared to 70
employees for the preferred alternative. Because the source of fuel
would most likely originate in the Gulf of Mexico, additional revenues
associated with the sale of Pennsylvania coal would not be realized for
the gas-fired facility option.
Comments Received
The Department received comments on the YCEP Final Environmental
Impact Statement from 14 commenters/groups.
Nina Huizinga from the Pennsylvania Department of Environmental
Resources' Office of Policy and Communication stated that PADER had no
comments. Steven Hill congratulated the Department on its ``timely
completion and absolute thoroughness'' of the Final Environmental
Impact Statement. Barry G. Hoffman, District Engineer for the
Pennsylvania Department of Transportation's Engineering District 8-0,
informed the Department that Air Products had submitted an application
for the required traffic signal and the District had no substantive
comments [note: approval for the signal (permit no. 84-55) was made to
North Codorus Township on March 6, 1995]. Roland Bergner commented that
the Pennsylvania Game Commission concurred with the selection of the
Flood Control Property alternative as the preferred electric
interconnect corridor route. Mr. Bergner reiterated the U.S. Army Corps
of Engineers (USACE) requirement that during the final design phase,
both agencies must approve YCEP's mitigation measures for alleviating
impacts to wildlife associated with construction across USACE property.
The Department is aware of this stipulation and is including this
requirement in its Mitigation Action Plan.
Ronald Davis, Chief, Engineering Services of the Air Quality
Program, Pennsylvania Department of Environmental Resources (PADER),
submitted four substantive comments with supporting documentation. His
comments were related to analyses of secondary effluent (process
wastewater) samples that were recently collected by PADER and YCEP from
the P.H. Glatfelter Company's Outfall 001. The PADER analyses indicated
the presence of several compounds [specifically, residual agricultural
pesticides (Aldrin,
[[Page 43450]]
BHC, and propachlor) and herbicides (MCPA and dalapon) and three
additional volatile organics (1,4-dioxane, 1,1,2,2-tetrachloroethane,
and formaldehyde)] that were not identified in the Final Environmental
Impact Statement. The YCEP cooling tower is designed to utilize the
process wastewater for cooling tower make-up water, and would evaporate
an estimated maximum 2.8 million gallons per day during the cooling
process.
The first comment stated that several of the compounds
detected in wastewater are classified by the U.S. EPA as carcinogens.
Most of the other detected compounds have non-carcinogenic toxicity.
Except for chloroform, none of these contaminants had been previously
identified by YCEP or reviewed by PADER.
The Department reviewed the analytical data submitted by both PADER
(1 sampling event--analyses conducted by PADER Bureau of Laboratories)
and YCEP (4 sampling events--analyses conducted by Lancaster
Laboratories), and found that results of the analyses differed between
sampling events, between the laboratories conducting the analyses,
between the analytical technique used, and, when tested, between the
varying ``hold times'' (time between sample collection and analysis).
Some compounds were believed to be present in one sample, but were not
found in other samples. In addition, some compounds were thought to be
present by one laboratory and not the other, and some compounds were
thought to be present by both laboratories, but at very different
concentration. Thus, one needs to understand the limitations of the
results presented, since there seems to be some inherent uncertainty
with respect to the accuracy and/or precision of the analytical data
generated. These limitations and uncertainties are explored below.
Most of the organic components indicated as present in PADER's
wastewater analyses were tentatively identified compounds (TICs). TICs
are compounds analyzed through screening techniques (gas
chromatographic/mass spectrometric analyses), where the spectra
obtained from components in the sample are matched with a computerized
spectral database of possible compounds. The TICs were not generally
quantified in the PADER laboratory report, as denoted by the letter
``J'' behind the values for some of the analyses. [The ``J''
designation is a laboratory data qualifier used in the EPA's Contract
Laboratory Program to indicate that a reported value is estimated.]
Although several organic compounds were tentatively identified by
PADER's analyses, further component-specific analytical validation
methods did not indicate the presence of many of these compounds. To
verify TIC results, a pure sample (of the compound indicated by the TIC
result) should be rerun on the same equipment to determine if retention
times match those of the TIC and to determine if actual spectral
results obtained with the mass spectrometer match those indicated by
the computerized library. If both of these match then can one state
with reasonable certainty that a TIC represents a compound that is
truly present. In summary, only compounds identified and quantified
according to EPA methodology (in the manner indicated above) are
detected. TIC's are not present until confirmed; they are only presumed
present.
The EPA has provided specific guidelines for evaluating the
usability of laboratory data in quantitative risk assessments. As a
general rule, only positively identified compounds that are listed
within a methods list of compounds to be identified (i.e., the
instrument response factor has been derived based on a multipoint
standards curve for each of these chemicals) can be used in risk
assessment calculations, and then only if they are present above the
method quantification limit once corrected for field and laboratory
blanks. EPA guidance allows substantial leeway on use of TICs, but one
cannot identify ``method list'' chemicals (e.g., bromodichloromethane)
as TICs (please note that nearly all of the compounds presumed to be
present are compounds having methods list), automatically printout the
first chemical on a computer hitlist as being the TIC, or use
quantification levels derived from TICs for anything but estimating
relative importance of the compound.
As a conservative measure for health effects analysis, DOE acted on
the premise that all analysis results were valid until proven
otherwise, and conducted a risk screening of DOE's targeted 21
potentially hazardous compounds at the highest concentrations
``detected'' in any of the analyses.
Concurrent with risk screening conducted by DOE, YCEP submitted a
``Human Health Risk Assessment for the YCEP Cooling Tower Drift,'' to
PADER on July 12, 1995, and its Addendum on July 20, 1995. A copy of
this health risk assessment was received and reviewed by DOE. Both
YCEP's health risk assessment and DOE's risk screening concluded that
the recently detected compounds in P.H. Glatfelter Company wastewater
posed no increased human health risks. Both YCEP's human health risk
assessment and DOE's screening assessment are in the public reading
rooms.
DOE determined that although potential emissions of most compounds
detected in the recent sampling events were not assessed in the Final
Environmental Impact Statement, the addition of these compounds (at the
highest detected concentrations) to emissions from the proposed cooling
tower are expected to pose no additional human health risks. Therefore,
the general human health risk conclusions reached in the Final
Environmental Impact Statement are not measurably altered. It should
also be noted that the health risk analyses conducted in the Final
Environmental Impact Statement were based on measurements made using a
simulated cooling tower, which arguably would generate more accurate
release data than that based on pure extrapolation of analytical
measurements made on wastewater samples.
PADER's laboratory analyzed the wastewater outfall for one sampling
campaign (4/17/95), and Lancaster Laboratories, an EPA-accredited
facility, analyzed wastewater samples taken during four sampling
campaigns (3/13/95, 4/17/95, 5/18/95, and 6/21/95). DOE reviewed and
evaluated all of these available data in identifying components in the
wastewater and in assessing potential health effects from cooling tower
operation. As stated before, many of the organic compounds identified
by PADER's laboratory were only tentatively identified during screening
analyses, but were not confirmed in their validation analyses, which
support the general findings of Lancaster Laboratories.
The second comment stated that five (5) of the detected
compounds are hazardous air pollutants (HAPs), as defined in the 1990
Clean Air Act Amendments. The compound detected at the highest level
was formaldehyde at 0.3 mg/L. Based on this level, the potential
emissions of formaldehyde from the YCEP cooling tower would be over one
ton/year. PADER's sampling results indicated that potential HAP
emissions from the cooling tower have not been fully investigated, and
that there is a need to determine the amount of hazardous air
pollutants (HAPs) that will be emitted from the process.
The volatile and semi-volatile (methods lists) analyses conducted
by the PADER and YCEP laboratories included scans for over 120
different compounds. Additional analyses for pesticides, herbicides,
and base neutral
[[Page 43451]]
components bring the total quantity of compounds analyzed in excess of
160, with 55 of these components being on the Clean Air Act Amendments
list of HAPs.
The Department's review of the sampling analysis data submitted by
PADER determined that five of the compounds presumed to be present
(chloroform, formaldehyde, 1,4-dioxane, 1,1,2,2-tetrachloroethane, and
1,2,3,4,5,6-hexachlorocyclohexane), were HAPs. The Department then
estimated the amounts of these five compounds that would be emitted
from the cooling tower. Four of the HAPs are volatile organic compounds
(VOCs), except 1,2,3,4,5,6-hexachlorocyclohexane). These four volatile
compounds were assumed to be released from the cooling tower in vapor
(100 percent evaporation) form. The 1,2,3,4,5,6-hexachlorocyclohexane
was assumed to be released primarily in the form of drift (0.005
percent of the water recirculation rate).
Based on the maximum potential concentrations of tentatively
identified HAPs in the make-up water, the proposed YCEP cooling tower
operation would be expected to release an additional 2.8 tons/year of
HAPs beyond the amount (0.57 tons/year) assessed in the Final
Environmental Impact Statement. It should be noted that, based on
confirming analyses for volatile and non-volatile components that would
be used for regulatory purposes, only chloroform was detected in the
samples with any degree of confidence. PADER's formaldehyde analyses
which yielded a concentration of 0.3 mg/L may be invalid due to the
presence of a pale yellow color in the sample as well as the exceedance
of maximum holding time prior to analysis. Subsequent analyses by
Lancaster Laboratories indicate the formaldehyde levels are less than
57 g/L. However, the method (water) blank had a background
level of 48.5 g/L, which generated a corrected analytical
result below the detection limit. If one extrapolates based on the
validated analytical information obtained during the recent sampling
campaigns, the total emissions for VOCs (including HAPs) from the
cooling tower would be approximately 0.11 tons/year, which is less than
that reported in the Final Environmental Impact Statement (0.57 tons/
year).
The Department determined that although potential increased
emissions (2.8 tons/year) of HAPs presumed to be present in the recent
sampling events were not assessed in the Final Environmental Impact
Statement, the incremental health risks associated with these expected
additional emissions from the proposed cooling tower would pose no
additional environmental or human health risks, and that the human
health risk conclusions reached in the Final Environmental Impact
Statement are not measurably altered. Analytical results suggest that
the health risk could be lower than that reported in the Final
Environmental Impact Statement due to the lower chloroform emissions
from the cooling tower.
A monitoring stipulation has been included in the Prevention of
Significant Deterioration (PSD) Air Permit to resolve issues related to
the actual amount of volatile organic compound and HAPs emissions from
the YCEP facility. This stipulation reads as follows: Within 60 days of
issuance of this plan approval, the applicant shall submit a cooling
water sampling protocol to the Regional Air Quality Program Manager for
approval. The protocol shall address the following analyses: a.
Volatile organic compounds; b. semi-volatile organic compounds; c.
chloroform; d. formaldehyde; e. dimethylsulfide; f. chlorinated
herbicides; and g. organochloride pesticides. The sampling of the
Glatfelter effluent/YCEP cooling tower evaporant stream shall be
conducted on a monthly basis. Sampling results in accordance with this
condition shall be submitted to the Department [PADER] within 30 days
of completion of the laboratory analysis. Sampling results shall be
used to verify compliance with the 50 tons/year VOC emission limit and
to verify that HAP concentrations in the cooling water are consistent
with the sampling values known to the Department [PADER] prior to
issuance of this plan approval. Sampling shall be conducted for at
least 1 year (12 consecutive months) or until the maximum production
rate of the source is achieved, as deemed appropriate by the Department
[PADER] based upon review of the information collected. At the
conclusion of the monthly sampling program, the Department [PADER]
shall specify sampling frequency which shall continue for the life of
the project. The applicant may recommend a sampling frequency and other
changes to the protocol at that time. The long term sampling program
may include correlation with the NPDES monitoring results at the P.H.
Glatfelter Company. [See DOE's mitigation commitment concerning the
cooling tower sampling results below under Mitigation Action Plan]
A third comment made by PADER stated that a number of the
newly identified pollutants are volatile organic compounds (VOCs), and
that the total potential emissions (from the cooling tower) could be
greater than two tons/year. When these emissions are added to the 49
tons/year identified from other sources in YCEP's air permit
application, the total project emissions exceed 50 tons/year;
therefore, New Source Review might now apply to VOC emissions from the
project. PADER also detected 76.2 mg/L of total organic carbon in the
wastewater, and questioned if the cooling tower might release this
organic carbon to the air as VOCs.
The Department's review of data submitted by PADER determined that
up to an additional 4.2 tons/year of identified VOCs could be emitted
from the proposed YCEP cooling tower, if VOCs are confirmed to be
present in the make-up water at the maximum detected concentrations
using appropriate protocols. If these emissions (4.2 tons/year) are
accurate and when combined with the circulating fluidized bed boiler
emissions exceed the New Source Review (NSR) threshold for VOCs of 50
tons/year, an additional regulatory review would be required. However,
as a condition for providing cost-shared funding for the YCEP project,
net VOC emissions for the YCEP facility will not exceed 50 tons/year as
prescribed by law.
Chloroform levels measured for samples collected during recent
sampling events indicate an almost 10-fold reduction (when compared to
concentrations analyzed in the Final Environmental Impact Statement).
This reduction is probably due to the effects of the P. H. Glatfelter
Company's Modernization Project, which went online in the fall of 1994,
since similar reductions in many of the surrogate parameters have been
observed (e.g., color, specific conductance, chemical oxygen demand,
total organic carbon). The highest formaldehyde concentration (0.3 mg/
L) that was used in the estimation of maximum VOC emissions by the
Department could be in question due to analytical interferences noted
by the laboratory that conducted the analyses. More recent formaldehyde
analyses indicate that its presence is non-detectable. Thus, there is a
possibility that further analyses of current and future data will
indicate that the total VOC emissions will be less than 50 tons/year,
and that the component contributed by the cooling tower could be less
than 0.57 tons/year (as previously reported in the Final Environmental
Impact Statement). In light of the discrepancies and non-validation
found in the analytical analyses between samples and
[[Page 43452]]
laboratories, additional sampling would be required to more accurately
establish the overall amount of VOC emissions that would be emitted.
More recent analyses conducted suggest that VOC emissions from the
cooling tower could be approximately 0.11 tons/year.
To address this issue as part of the Prevention of Significant
Deterioration (PSD) Permit for the YCEP Project, PADER's Ronald Davis
has stated that the following language has been included in the PSD
permit (which was issued on July 25, 1995): ``Annual actual volatile
organic carbon emissions from all activities at the YCEP facility shall
not exceed 50 tons for any consecutive twelve month period. This limit
is based upon the VOC applicability threshold contained in Chapter 127
Subchapter E of the New Source Review of the Department's rules and
regulations.''
Another stipulation of the permit (as outlined in the previous
response) will require YCEP to conduct sampling to determine, in part,
VOC emissions. If total VOC emissions on an annualized basis exceed 50
tons/year, YCEP would be required under law to mitigate the effects by
demonstrating lowest achievable emission rates (LAER) for VOC
emissions. If initial operational data indicate a potential VOC
exceedance, YCEP could pursue a number of options (including
operational or engineering controls at the combustor) to reduce the
VOCs on an annualized basis for the entire facility to less than 50
tons/year. As a condition for providing cost-shared funding for the
this project, net VOC emissions for the YCEP facility will not exceed
50 tons/year as prescribed by law.
The need for a New Source Review is a regulatory issue which will
be determined by PADER based on operational data. As noted earlier,
PADER has not determined the need for a New Source Review at this time,
but will require YCEP to monitor the P.H. Glatfelter Company wastewater
for volatile organic compounds, semi-volatile organic compounds,
chloroform, formaldehyde, dimethyl disulfide, chlorinated herbicides,
and organochloride pesticides. Data from this monitoring will provide
the basis for the determination of whether additional mitigative
measures would be required. PADER, in its capacity as the regulatory
agency would determine the need for a New Source Review, and (if
required) the conditions would be outlined and enforced by PADER's
permit. Previously unaccounted VOC emissions from the proposed cooling
tower are not expected to alter conclusions in the Final Environmental
Impact Statement regarding health risks or environmental impacts.
The issue of whether the 76.2 mg/L of total organic carbon in the
wastewater contains volatile constituents has been addressed through
the EPA standardized volatile organic compound analyses of the
wastewater samples conducted by the various laboratories. It is not
unusual to find that the carbon associated with volatile constituents
does not total the organic carbon in the entire wastewater sample due
to the presence of color-containing non-volatile components. These
color-containing components are derivatives of wood structure such as
lignin, a non-volatile, complex sugar derived from wood. In addition,
total organic carbon analyses involve air stripping methodology to
remove inorganic constituents, such as carbon dioxide, bicarbonates,
and carbonates. Therefore, the measurement of total organic carbon may
represent the non-volatile organic carbon fraction and may not
contribute to additional VOC emissions.
PADER's fourth comment stated that compounds possessing
very low odor thresholds were present in the wastewater and that
release of these compounds in the air, both as a vapor and in water
mist, may result in odors being generated in the area.
The Department reviewed PADER's analysis results and identified
dimethyl disulfide as the presumptively present compound having the
most significant odor-causing potential. Assuming dimethyl disulfide is
present in the make-up water at the maximum reported concentration, 130
micrograms/liter (g/L), a worst case ambient air concentration
was calculated. The results of these calculations estimated an ambient
air concentration (6.0 x 10plus-minus6 g/m3) which
is five orders of magnitude less than the lowest reported odor
detection threshold for dimethyl disulfide (3.0 g/m3) (K.
Verschueren, Handbook of Environmental Data on Organic Chemicals, New
York, Van Nostrand Reinhold, 1983). Therefore, the Department
determined that the addition of these emissions (at the highest
detected concentrations) would pose no additional odor impacts. Thus,
the conclusions reached in the Final Environmental Impact Statement
regarding odor are not measurably altered.
Since receipt of the comments from Mr. Davis, Pennsylvania has
issued the air permit for the YCEP facility. In its press release
announcing issuance of the air permit, Michael Steiner, acting director
of the Department of Environmental Protection's (DEP's) southcentral
region office noted that DEP required YCEP to conduct a health risk
assessment showing that the project will not result in significant
human health risk. The health assessment requested by PADER is
available in the public reading rooms.
Mr. John R. Pomponio, Acting Director, Environmental Services
Division, EPA Region 3, submitted two major comments for consideration.
The first comment was related to the human health risks
associated with the constituents identified in the wastewater analyses
conducted by PADER. This wastewater is to be used for cooling tower
purposes. The EPA requested that a human health risk assessment be
prepared for the compounds identified in the PADER laboratory analyses:
oil and grease, total organic carbon, chemical oxygen demand, methylene
blue active substances (MBAs), formaldehyde, ammonia, nitrobenzene,
toluene, bromide, bromofluorobenzene, bromodichloromethane, 2,4,6-
tribromophenol, phenols, 2-fluorophenol, terphenyl, 2-fluorophenyl
(sic), 1,1,2,2-tetrachloroethane, 1,2-dichloroethane, carbon disulfide,
dimethyl sulfide, dimethyl sulfone, 1,4-dioxane, propachlor, aldrin,
hexachlorocyclohexane (all congeries), cyanide, sulfide, sulfate,
fluoride, nitrates, nitrites, and metals (sodium, calcium, potassium,
magnesium, iron, aluminum, strontium, manganese, molybdenum, vanadium,
zinc, lithium, titanium, mercury, barium, boron, chromium [+6] and
chromium [total]). The human health risk assessment should address all
potential exposure pathways resulting from both the air cooling towers
and the wastewater discharge. In addition, possible remediation of the
wastewater from the P.H. Glatfelter Company should be examined.
Please see above the responses to comments received from Ronald
Davis, Chief, Engineering Services of the Air Quality Program,
Pennsylvania Department of Environmental Resources (PADER), which
outline the utility of analytical data generated by PADER and Lancaster
Laboratories.
The Department and YCEP conducted concurrent health risk
assessments to address EPA's concerns. These studies were screening
studies (i.e., assessing maximum exposure pathways under maximum
exposure scenarios) in order to assess whether more refined analyses
were appropriate.
In terms of performing risk analyses on the components identified
by EPA, those items which are surrogate or compound non-specific
parameters (i.e.,
[[Page 43453]]
oil and grease, total organic carbon, chemical oxygen demand, and MBAs)
do not lend themselves to risk assessment methodology, since the
cornerstone of health effects analyses is to assign risk to specific
compound exposure or an aggregation of specific compound exposures. As
such, the information provided in these surrogate parameters is
inappropriate for conducting quantitative risk assessments and for
these basic reasons were not included in the health risk analyses
conducted.
Eight compounds listed by EPA for investigation were internal
standards used by PADER's analytical laboratory in conducting its
analyses. These compounds included bromofluorobenzene, 2-fluorophenol,
2-fluorobiphenyl, 2,4,6-tribromophenol, 1,2-dichloroethane-(d4),
toluene-(d8), nitrobenzene-(d5), phenol-(d6), and terphenyl-(d14). An
indication that some of these were internal standards was the notation
that these compounds contained deuterium (as noted by the suffix
``d''), an isotope of hydrogen. The fact that these compounds were
internal standards introduced into the sample by the analytical
laboratory obviates the need for their inclusion in the health risk
analyses.
Many of the constituents analyzed by PADER's laboratory which were
listed by EPA for further health effects investigation were below
detection limits. These constituents included sulfide, fluoride, boron,
hexavalent chromium, total chromium, total mercury, molybdenum,
lithium, titanium, free cyanide, oil and grease, and MBAs. Since these
components were not above the limits of detection, these were not
included in the health risk assessment.
Many of the constituents on EPA's list are essential human
nutrients, considered by toxicological experts to be largely non-toxic
at ``environmental exposure'' conditions, as evidenced by their lack of
inclusion in two of the most common risk assessment data bases
(Integrated Risk Information System [IRIS] and Health Effects
Assessment Summary Tables [HEAST]). These common constituents include
components such as sodium, sulfates, calcium, potassium, magnesium, and
iron. EPA guidance suggests that chemicals that are essential human
nutrients, present at low concentrations (i.e., only slightly elevated
above naturally occurring levels), and toxic only at very high doses
need not be considered further in quantitative risk assessments.
Examples of these chemicals include iron, magnesium, calcium,
potassium, and sodium. Some of the components on EPA's target list were
detected in the wastewater at concentrations less than Primary or
Secondary National Interim Drinking Water Standards for Inorganics
(Federal Register, Feb. 1978, No. 266). These levels are established to
protect the public against both ``nuisance'' and health effects
(assuming consumption of approximately 2 liters of water each day). For
instance, barium was detected at 429 g/L; the primary drinking
water standard is 1,000 g/L. Manganese was detected at 40
g/L; the secondary drinking water standard is 50 g/L.
Sulfate was detected at 190 mg/L; the secondary drinking water standard
is 250 mg/L. Zinc was detected at 28 g/L; the secondary
drinking water standard is 5,000 g/L. Another method for
estimating the effects of these essential human nutrients is to compare
the effective dose with recommended daily dietary allowances. Even if
one unrealistically assumes that an average male ingests 2 liters of
the cooling tower wastewater daily [note: the maximum expected drift
exposure of cooling tower water for a person would be 9 x 10-7
liters/day], many of the components consumed would be less than the
daily dietary allowances. For example, calcium consumption would be
approximately 31 percent of the recommended daily dietary allowances
for a 23-50 year old male; sodium consumption would be about 50
percent; potassium consumption would be about 4 percent; iron
consumption would be approximately 15 percent; magnesium consumption
would be 7 percent; zinc consumption would be 0.4 percent; and
manganese consumption would be about 3 percent of the recommended daily
dietary allowances.
To address EPA's concerns, additional human health risk analyses
were conducted by Environmental Resources Management, Inc. (ERM) (Human
Health Risk Assessment for the YCEP Cooling Tower Drift, 11 July 1995,
and Addendum to Human Health Risk Assessment for the YCEP Cooling Tower
Drift, 20 July 1995). As a response to the EPA letter submitted to the
Department on July 14, 1995, the Addendum assessed human health risks
to additional chemicals not in the first report.
A step-wise approach was used in the ERM analysis. The first step
was to determine the chemicals of concern and their concentrations in
the wastewater, based on analyses conducted on the wastewater streams.
The compounds which were incorporated into the analyses based on this
analytical screening protocol in the initial July 11, 1995 ERM Report
were the following: pesticides (congeners of hexachlorocyclohexane
[alpha BHC, beta BHC, delta BHC], aldrin, heptachlor epoxide,
propachlor); herbicides (dalapon, MCPP, MCPA, 2,4-D, 2,4-DB), and other
compounds (formaldehyde and chloroform). The Addendum analyzed or
reanalyzed the following constituents: organics (dimethyl disulfide,
dimethyl sulfone, formaldehyde, chloroform, phenol, carbon disulfide,
aldrin, beta BHC); metals (aluminum, strontium, manganese, vanadium,
zinc, barium, boron, and lithium), and inorganics (ammonia, cyanide,
fluoride, nitrate, nitrite, and bromide). Aldrin and B-BHC were
reanalyzed in the Addendum at concentrations higher than in the
original report. Formaldehyde and chloroform were reanalyzed in the
Addendum using a more conservative transport mechanism (i.e., 100
percent volatilization from cooling tower; dispersion based on droplet
behavior in order to maximize groundlevel concentration). Although
dimethyl disulfide, dimethyl sulfone, and bromide have no risk-based
concentrations available from EPA Region 3 (which suggest that these
pose negligible risk to human health at the trace concentrations
present in the cooling tower), they were included in the Addendum to
demonstrate that groundlevel concentrations will be negligible.
Estimates of steady-state concentrations of the chemicals following
three cycles within the cooling tower were derived based on the
expected volatility behavior of the compounds in the tower. Estimates
of airborne concentrations and deposition rates for each of the
chemical constituents were derived. In addition, in the July 11, 1995
Report, soil concentrations that would occur if chemicals were
deposited over the facility lifetime of 30 years were estimated. Human
health risks associated with the emissions from the cooling tower based
on inhalation and potential residential exposures to soils affected by
deposition were then determined by comparison with EPA Region III Risk-
Based Concentrations (RBC's) which are acceptable levels for inhalation
and residential use of soil. These RBC's are reported to prevent (1)
carcinogenic effects at a target lifetime cancer risk of 1x10-6
for known and potential carcinogenic chemicals; and (2) non-
carcinogenic effects for systemic toxicants at a target hazard quotient
of 1.0.
The results in the July 11, 1995 Report indicate that in every case
for which an RBC was known, the predicted airborne
[[Page 43454]]
concentration of components analyzed in this risk assessment was at
least four orders of magnitude smaller than the RBC; for some
compounds, the predicted concentration is more than eight orders of
magnitude smaller. This means that there is essentially no chance of
airborne concentration of constituents being great enough to cause
adverse health effects to the surrounding population. The risk
assessment results for the soil ingestion pathway are similar to the
air pathway. None of the compounds are predicted to accumulate to
levels approaching their RBC for soil ingestion. The calculated soil
concentration for each constituent with a known RBC is at least two
orders of magnitude smaller than the RBC; for most of the compounds, it
is at least five orders of magnitude smaller.
The results in the July 20, 1995 Addendum indicate that for non-
volatile chemicals, the predicted airborne concentration is at least
four orders of magnitude smaller than the RBC; for some compounds, the
predicted concentration is nearly eight orders of magnitude smaller.
These results seem to suggest that there is essentially no chance of
airborne concentrations of non-volatile drift constituents being great
enough to cause adverse health effects to the surrounding population.
For volatile constituents, such as chloroform and formaldehyde, the
predicted airborne concentrations are nearly two orders of magnitude
smaller than the RBCs. The predicted airborne concentrations for the
VOCs are extremely conservative given that the dispersion modeled for
the water droplets in the drift was used to estimate VOC dispersion. In
actuality, the VOC vapors, which are lighter than water droplets, would
disperse over a greater area, resulting in much lower groundlevel
concentrations.
Another risk assessment was conducted by the Department to validate
the general conclusions reached in the RBC-based health effects
analysis presented above. The assessment considered risks from
inhalation as well as risks from both oral ingestion and dermal
absorption, and made conservative assumptions for exposure and dose
which would tend to overstate risks to human health. It was determined
by the Department that the human exposure route via contact with P. H.
Glatfelter Company wastewater was not a primary route due to the fact
that the Codorus Creek is not used as a drinking water source in the
area, and therefore there are no viable exposure points for ingestion
of the wastewater. In addition, if the wastewater exposure route was a
primary exposure pathway, it would be difficult, if not impossible, to
discern or isolate any unique or toxicological effects due to the
project, since the wastewater is currently being discharged to Codorus
Creek.
The methodology used was slightly more rigorous than the
aforementioned study, since hazard quotients and risk values were
specifically calculated for the compounds investigated. The two major
exposure pathways examined were inhalation and ingestion under maximum
effective dose scenarios. This maximization of effective oral dose
obviates the need to calculate oral doses from indirect ingestion
(e.g., soil ingestion, beef, fish, milk, and water consumption). The
following compounds were analyzed: aldrin, ammonia, alpha-BHC, beta-
BHC, delta-BHC, bromodichloromethane, 2-(2-butoxyethoxy) ethanol,
carbon disulfide, chloroform, cyanide, dalapon, dimethyl sulfide,
dimethyl trisulfide, dimethyl sulfone, 1,4-dioxane, formaldehyde, 1-
hexadecene, heptachlor epoxide, MCPA, MCPP, phenol, propachlor,
1,1,2,2-tetrachloroethane, 1-(2-thienyl)-1-propanone, strontium, and
vanadium. Although delta-BHC, dimethyl disulfide, dimethyl sulfone, 1-
hexadecene, and 1-(2-thienyl)-1-propanone have no risk-based
concentrations available from EPA Region 3 (which suggest that these
pose negligible risk to human health at the trace concentrations
present in the cooling tower), they were included in the Addendum to
demonstrate that groundlevel concentrations will be negligible. Based
on the assumptions and methodology used in this screening assessment,
the results indicate that the compounds investigated would not pose a
measurable and adverse risk to human health. For non-carcinogenic
substances, hazard quotients are all less than 1, indicating that these
substance would not adversely affect human health. For carcinogenic
substances, risk factors are less than 1 in 1 million, which is below
the EPA's presumptively safe range (1 x 10-4 to 1 x 10-
6), except for 1,1,2,2-tetrachloroethane in a combined ``worst-case''
inhalation and dermal absorption dose, when the risk is approximately 4
in 1 million. Further assessment does not appear to be warranted, since
PADER identified 1,1,2,2-tetrachloroethane as a ``tentatively
identified compound'' (TIC) during its analysis of P.H. Glatfelter
Company wastewater. Although EPA guidance (EPA, Risk Assessment
Guidance for Superfund Volume 1 Human Health Evaluation Manual (Part
A), EPA/540/1-89/002, p. 5-19, 1989) allows for the use of TICs for
human health risk assessments, caution is recommended - particularly if
inclusion of the TIC at the detected concentrations would dominate the
risk assessment. In the case of 1,1,2,2-tetrachloroethane, other
analyses, including a split sample, do not confirm the presence of the
compound, and PADER's own volatile organics analysis for which 1,1,2,2-
tetrachloroethane was a ``Target Compound'' did not detect a
concentration 65 times lower than the concentration used for this
screening assessment.
Based on the health risk assessments conducted for the Final
Environmental Impact Statement and two conducted for this document, the
acceptable health risk levels associated with evaporative and drift
emissions from the cooling tower do not currently support the need for
further wastewater treatment. In addition, in the unlikely event that
emissions from the cooling tower contribute to regulatory or health
risk exceedances during operation (i.e., for HAPs and VOCs), there are
a number of options that YCEP could pursue to remedy the situation.
EPA's second comment dealt with regulatory concerns
related to major source thresholds of hazardous air pollutants (HAPs)
(10 tons/year of individual HAP; 25 tons/year of aggregate HAP) and
toxic release inventory requirements.
These issues are related to regulatory concerns that would need to
be coordinated with PADER for resolution. However, under the
requirements of the CAA Amendments of 1990, the YCEP facility is not
currently required to address hazardous air pollutants listed in
Section 112(b) of the CAA. According to Section 112(n), Other
Provisions, (1) Electric Utility Steam Generating Units, the EPA must
perform a study before deciding if Section 112(b) is applicable to
electric utility steam generating units. A draft study was issued in
June 1995. As a general requirement of the Clean Coal program, the
Environmental Monitoring Plan for the proposed project will contain a
requirement for reporting monitoring results from project operation for
some selected air toxics (as outlined in Table 4.4-1 of the Final
Environmental Impact Statement).
DOE has received a letter from Robert Kramer, Acting Chief,
Environmental Assessment Branch, EPA Region III, which states that the
EPA's initial review of the human health risk assessments for the
cooling tower indicates that the EPA's concerns have been addressed.
EPA will conduct a more in-depth analysis over the coming weeks, and
will advise DOE of any changes to their initial concurrence.
[[Page 43455]]
Willie R. Taylor, Director, Office of Environmental Policy and
Compliance of the Office of the Secretary, United States Department of
Interior (DOI), submitted four comments relative to the Final
Environmental Impact Statement for this project. These same comments
were made earlier (letter received on December 22, 1994; Volume IV,
Written-94, Final Environmental Impact Statement) relative to the
Prevention of Significant Deterioration (PSD) permit application for
the York County Energy Partners (YCEP) project.
The first comment suggested that air quality could be
expected to improve because reductions in nitrogen oxide and sulfur
oxide, (sic., dioxide) emissions from the P. H. Glatfelter Company
would be made federally enforceable concurrent with this permit.
Section 4.1.2.3 (Volume I, pg. 4-21) of the Final Environmental
Impact Statement states that an enforceable restriction would apply to
P. H. Glatfelter's Power Boiler No. 4, so that this boiler could
operate for an equivalent of 720 hours per year at full (100 percent)
load. An accompanying reduction of sulfur dioxide (SO2) would
result from restriction of operation of Power Boiler No. 4.
Furthermore, Section 3.1.2 (Volume I pg. 3-2) and 4.1.2.1 (Volume I,
pg. 4-10) of the Final Environmental Impact Statement also discuss the
regulatory requirements applicable to this project.
A second comment indicates that (for future reference) the
DOI wishes the permitting authority to notify the Federal Land Manager
of all major sources on a case-by-case basis and model for those
sources even if the distance from a Class I area is greater than
required by current regulations (100 km), when there is a potential to
affect air quality in such a Class I area.
Comment is noted for future projects. The Department is responsible
for developing NEPA documentation to assess the effects of potential
actions on health and the human environment, regardless of distance
from the proposed action if there is the possibility of potential,
measurable effects. DOE has made extensive contact with the DOI on this
project, as evidenced by the correspondence contained in Volume IV of
the Final Environmental Impact Statement. These letters are dated March
16, 1992; March 3, 1993; July 21, 1993; September 22, 1993; September
23, 1993; May 27, 1994; and December 22, 1994.
A third comment from DOI agreed that nitrogen oxide
emissions should be determined during compliance testing, and requested
that the BACT emission levels for other pollutants should also be
determined and set at lower levels than the levels proposed, if testing
indicates lower levels can be achieved on a continuous basis.
This same comment was made earlier by DOI and responded to by the
Department during the comment period for the Draft Environmental Impact
Statement (W-BJG-12/22a, Volume IV, pg. Written-96). The Department
believes this matter has been adequately addressed in the comment
response. In addition, a discussion of BACT and air pollution control
equipment for this project is found in Section 4.1.2.2 of the Final
Environmental Impact Statement (Volume I, pg. 4-17.)
A final comment by Mr. Taylor indicated that the DOI
wanted to see both nitrogen oxide and sulfur dioxide emissions to be
made federally enforceable and permanent.
This issue was also presented earlier by DOI and the Department
considers its response to DOI's concerns to be complete (see response
W-BJG-12/22b, Volume IV, pg. Written-96).
Alan J. Barak, the attorney for Mr. Richard and Mrs. Joan Clark and
Stop Targeting Our People (STOP) submitted a ``Request/Demand for
Supplement or New EIS'' with three specific comments and supporting
documentation.
The first comment asserted that the Department failed to
include the ruling by the West Manchester Township Zoning Hearing Board
that construction of the Bair switchyard is contrary to the Township's
zoning laws and that a construction permit had been denied.
The Department described the West Manchester Zoning Ordinance in
Section 3.2.9.2 (page 3-144) and further discussed it in Sections
4.1.14.9 (page 4-192) and Section 9.7 (page 9-19) of the Final
Environmental Impact Statement. In addition, the issue, including the
then forthcoming hearing, was covered in the responses to several
comments, such as D-50/17 (Volume II, page DEC-109), D-51/16 (Volume
II, page DEC-113), and D-53/8 (Volume II, page DEC-117). Thus, the
Final Environmental Impact Statement included information that was as
current as possible. This Record of Decision provides more recent
information in the Project Status discussion. Since final resolution of
this issue is still pending due to YCEP's appeal of the West Manchester
Township Board's decision, it is not currently ripe for the Department
to address. Furthermore, in addition to appealing the West Manchester
Township decision, YCEP has prepared preliminary designs for a mini-
substation arrangement which could be constructed entirely on existing
Met-Ed property, thus negating the zoning issue. Therefore, the
Department concludes that building the proposed switchyard at the Bair
substation (which is the environmentally preferred utility corridor
route) remains viable. Met-Ed has indicated to YCEP that it preferred a
conventional interconnection requiring the adjacent lot and Specific
Exemption, and only in the event that YCEP was unsuccessful in
receiving approval for this conventional interconnection would Met-Ed
consider other interconnection alternatives, including the mini-
substation design.
The second comment stated that the Department did not
address EPA's determination that alternative plant designs could lower
the plant's polluting emissions by 70 percent. This point raises the
question of YCEP's Best Available Control Technology (BACT) analysis.
The Department publicly responded to EPA-suggested design changes
in its response to Comment W-PHK-1/31a (Volume IV, page WRITTEN-229).
Additional responses to EPA issues were provided in the following
agency correspondence which are reproduced in Appendix E (Volume IV) of
the Final Environmental Impact Statement: June 9, 1994, letter to Diana
Esher (EPA) from Jan Wachter (METC); January 17, 1995, letter to
William G. Browne (EPA) from Gary Kinsey (YCEP); February 15, 1995,
letter to Peter Kostmayer (EPA) from Gary Kinsey (YCEP); February 22,
1995, letter to Peter Kostmayer (EPA) from Gary Kinsey (YCEP); March 1,
1995, letter to Ronald Davis (PADER) from Bradley Hahn (YCEP); March 2,
1995, letter to Ronald Davis (PADER) from Gary Kinsey (YCEP); March 21,
1995, letter to Peter H. Kostmayer (EPA) from Thomas Bechtel (METC);
and April 4, 1995, letter to William Browne (EPA) from Gary Kinsey
(YCEP). Based on its own analysis and information provided by the
boiler manufacturer, the Department has concluded that incorporating
the design changes suggested by EPA is neither technically nor
economically feasible and would not satisfy the Department's purpose
and need as set forth in Section 1.3.1 (page 1-8) and Section 1.3.2
(page 1-11) of the Final Environmental Impact Statement because the
recommended design changes cannot be incorporated without abandoning
the proposed technology. Ultimately, the final determination of the
adequacy of YCEP's BACT analysis is a matter for the regulatory agency
(PADER). PADER issued the Prevention of Significant Deterioration (PSD)
permit on July 25, 1995 thus accepting YCEP's BACT analysis based on
the atmospheric
[[Page 43456]]
circulating fluidized bed (ACFB) technology to be employed.
The final comment stated that the Final Environmental
Impact Statement did not address the fact that Met-Ed has undertaken a
``study showing that the power from the facility will cost its
customers $900 million more than readily available alternative power''
and has ``filed an action at the Federal Energy Regulatory Commission *
* * to void the power purchase contract.''
The commenter cited two sources as references to the Met-Ed study.
Both of these sources are provided in the Final Environmental Impact
Statement. The March 14, 1995, letter from A.M. Seltzer is reproduced
in Appendix E and the January 27, 1995, letter from A. M. Seltzer is
provided as Comment W-AMS-1/27 with the Department's response beginning
on page WRITTEN-153, both in Volume IV of the Final Environmental
Impact Statement. The Department also updated the Final Environmental
Impact Statement from the Draft using relevant information provided by
Met-Ed. A new alternative was described (Volume I, Section 2.2.4.3,
page 2-85) and associated impacts analyzed (Volume I, Section 4.3.3,
page 4-249), and the subsection on Utilities under Section 4.1.12.3
(Volume I, page 4-169) was revised to incorporate the relevant
information on potential impacts to utility rates. In addition,
responses to several comments present the results of the Met-Ed study
[e.g., D-119/11 (Volume II, page DEC-249), D-137/17 (Volume II, page
DEC-285), and J-152/5 (Volume III, page JAN-305)]. The Project Status
section of this document presents the latest information the Department
has on the action taken by Met-Ed to void the power purchase contract.
In summary, the Department agrees that if YCEP is unable to build
the switchyard at the Bair substation or if Met-Ed should win an appeal
and the power purchase contract is void, then additional analyses,
which could include the development of a Supplemental Final
Environmental Impact Statement, may be necessary. The Department's NEPA
process (10 CFR 1021.314) provides for supplement analysis to address
substantial changes or significant new information relevant to
environmental concerns. The results of supplement analysis, if
required, cannot be predetermined. Moreover, the parties have not
exhausted all possible remedies. Therefore, the issues are not ripe for
Departmental consideration at this time. NEPA does not require that all
permits be issued or that all compliance questions be resolved before
an agency's decision on a proposed action can be made.
John and Margaret Klunk submitted three comments with supporting
documentation.
The first comment pertained to U.S. Geological Survey
(USGS) provisional data on organochlorine and trace elements.
These data are from bed sediment and fish tissue collected in 1992
from 18 sites in the lower Susquehanna River Basin, including one site
in Codorus Creek, downstream from both the YCEP facility and the city
of York. The provisional data indicate the occurrence of contaminants
and are not intended to determine impacts on human health or aquatic
life. Also, according to the USGS, because of the small data set used,
differences in contaminant concentrations among species or even within
species are not easily explained and site comparisons between unlike
species are not valid and are only generally comparable using like
species. The Pennsylvania Interagency Workgroup reviewed the data and
determined that no public health advisories were warranted. The
Department does not believe these data significantly change the
description of Codorus Creek water quality as presented in Chapter 3,
Affected Environment, of the Final Environmental Impact Statement and
thus, do not alter the environmental impact analysis presented.
The second comment pertained to the U.S. Environmental
Protection Agency's 1993 Toxics Release Inventory, which became
available in March 1995. As a result of its total releases of 1,818,951
pounds, the P. H. Glatfelter Company was listed first among
Pennsylvania facilities for total toxic releases.
In the Department's discussion of the affected environment, more
current Toxics Release Inventory data were used. As indicated in
Section 3.1.2 (page 3-14) of the Final Environmental Impact Statement,
the Department based its assessment on 1994 air emissions reported to
the EPA on Form R.
Mr. and Mrs. Klunk's final comment pertained to
correspondence from the P. H. Glatfelter Company to PADER's Regional
Water Quality Manager regarding National Pollutant Discharge
Elimination System (NPDES) permit issues.
These issues are currently subject to negotiation between the P. H.
Glatfelter Company and the state agency. It would be inappropriate for
the Department to project possible outcomes from these discussions.
However, obtaining an NPDES permit and complying with its provisions
are required for the facility to operate in the Commonwealth. A
discussion on how NPDES permits are enforced is presented in the
Department's response to Comment D-82/24 (Volume II, page DEC-175) in
the Final Environmental Impact Statement.
Carl Vallow believed that the Final Environmental Impact
Statement's discussion on the effects from the YCEP facility on
recreation and Lake Marburg was insufficient. He stated that adequate
assurances still need to be provided that the ``massive'' increase in
water usage will not be detrimental to the recreational activities and
advantages of Lake Marburg. The Department believes that the
discussions presented in Sections 4.1.4.2.8 (page 4-114) and 4.1.12.3
(page 4-168) on impacts to Lake Marburg and recreational facilities,
including Codorus State Park, support the conclusions that recreational
activities on Lake Marburg will not be adversely impacted by the
project. In addition, the Department provided responses to comments
related to Mr. Vallow's concerns. Please see the responses to Comments
D-270/2 (Volume II, page DEC-547), J-32/25 (Volume III, pages JAN-65),
J-179/19 (Volume III, page JAN-359), and W-JK-1/28mm (Volume IV, page
WRITTEN-195) of the Final Environmental Impact Statement.
Ms. Genevieve Ketterman submitted five comments.
She expressed her belief that there would be effects of
the project, especially due to evaporative losses, on water supplies,
water quality, and ``the atmosphere.'' The Department believes that the
Final Environmental Impact Statement addresses water resource issues in
depth in Section 4.1.4 (page 4-98) and Section 4.1.14.4 (page 4-177).
The effects of evaporation on air quality and atmospheric conditions
are discussed in Section 4.1.2.9 (page 4-44).
Ms. Ketterman's second comment questioned the need for
power in the local area. The Final Environmental Impact Statement
discusses the need for power in the Met-Ed service area, including York
County, in Section 1.3.4 (page 1-14), in the response to Comment D-83/5
(Volume II, page DEC-177), and also in Appendix K (Volume IV).
Ms. Ketterman also mentioned that the proposed facility
would ``place a burden on Met-Ed,'' and thus would negatively impact
consumers. This issue is addressed in great length in Section 4.1.12.3
(page 4-169) and in the responses to Comment D-119/11 (Volume II, page
DEC-249) and Comment J-152/5 (Volume III, page JAN-305).
[[Page 43457]]
Fourth, Ms. Ketterman stated that despite the offsets, the
facility ``still means more emissions and pollution.'' Section 4.1.2.3
(page 4-21) discusses the net reductions in emissions of many criteria
pollutants and the expected increases of some pollutants. However,
detailed analyses determined that emissions of all pollutants are
expected to be within established limits. Section 4.1.2.11 (page 4-63)
describes the health effects of these emissions and shows that no
adverse impact is expected.
Finally, Ms. Ketterman questioned the worthiness of this
project for DOE funding. The Department uses established procedures on
the selection of a project as described in Section 1.4 (page 1-16) of
the Final Environmental Impact Statement, and diligently follows each
step. This Record of Decision presents the Department's concise
articulation of its decision to fund the YCEP project under the Clean
Coal Technology Demonstration Program.
Robin Sigworth submitted seven substantive comments.
M. Sigworth first claimed that the Department uses the
assertion that ``the area is already heavily polluted... to justify...
further pollution and environmental degradation.'' In the NEPA process,
the Department must consider the baseline conditions of the affected
area when assessing the impacts of a proposed project. Consequently,
the Final Environmental Impact Statement does, in fact, recognize that
the York County area, as a historically industrialized region, has
higher ambient levels of some pollutants. For instance, Section 3.1.4.1
(page 3-27) presents the baseline conditions of Codorus Creek water
quality, noting that the creek has been degraded in the past, due in
large part to municipal and industrial discharges and agricultural
runoff. The Department recognizes that the assessed impact from
increasing emissions or concentrations of pollutants in a previously
degraded area may not be as significant as for a pristine area. In
degraded areas, even a small incremental increase could result in a
negative impact. The analysis of impacts associated with the YCEP
facility, relative to the baseline conditions, indicated that few
adverse impacts are expected. Mitigation measures, outlined in the
Department's Mitigation Action Plan, will be implemented to alleviate
those adverse impacts that cannot be avoided (e.g., habitat loss on
U.S. Army Corps of Engineers land).
Second, M. Sigworth believed that the Final Environmental
Impact Statement deceives readers by misrepresenting Met-Ed's opinion
of the project, the need for power, and the effect of the project on
electric rates. The Department included all correspondence from Met-Ed
in Appendix E (Volume IV) and provided responses to Comment W-AMS-1/27
beginning on page WRITTEN-153 in Volume IV. Information presented in
the body of the Final Environmental Impact Statement represents the
Department's assessment of the situation, incorporating the opinions of
and the information provided by a vast number of sources, including
Met-Ed. The need for power is evaluated in Section 1.3.4 (page 1-14),
in the response to Comment D-83/5 (Volume II, page DEC-177), and also
in Appendix K (Volume IV). An adequate discussion of projected utility
rates can be found in Section 4.1.12.3 (page 4-169) and in the
responses to Comment D-119/11 (Volume II, page DEC-249), Comment D-137/
17 (Volume II, page DEC-285), and Comment J-152/5 (Volume III, page
JAN-305).
Third, M. Sigworth suggested that the Department did not
``fully address the impacts on the human community.'' The Department
believes that the local community and its various resources (e.g.,
cultural and socioeconomic) are accurately described throughout Chapter
3 and included in the corresponding assessments of environmental
consequences in Chapter 4. For instance, the Department has included
specific local residences as noise and visual receptors [Section 4.1.7
(page 4-144) and Section 4.1.1 (page 4-3), respectively], and included
all York County area residents, regardless of age, race, sex, or
religion, etc. in the health risk analysis [Section 4.1.2.11 (page 4-
63)].
Fourth, M. Sigworth questioned the `` `pollution reduction
figures' based on shutting down (emphasis Sigworth's) an unmodified [P.
H. Glatfelter Company] Power Boiler No. 4.'' As Section 4.1.2.3 (page
4-23) describes in substantial detail, all estimated emission rates are
based on the enforceable curtailment of Power Boiler No. 4 to 720 hours
of operation per year. M. Sigworth also notes that ``this same boiler
was due for an environmental overhaul regardless of [DOE's decision].''
This is true and reflected in the oxides of nitrogen (NOX) values
used in analyses presented in the Final Environmental Impact Statement.
As discussed in Section 4.1.2.3 (page 4-23), the Clean Air Act (CAA)
Amendments of 1990 required the P. H. Glatfelter Company to install
Reasonably Available Control Technology (RACT) on Power Boiler No. 4,
which was completed in July 1994. Furthermore, as discussed in Section
4.1.2.1 (page 4-16), the CAA Amendments of 1990 require that RACT
emissions levels be used as the existing baseline source in calculating
Emission Reduction Credits (ERCs).
Fifth, to the suggestion that the Final Environmental
Impact Statement has ``poorly 'reasoned away' the documented fog
problems,'' the Department disagrees and believes a thorough evaluation
was performed and presented in the discussion of current fog conditions
in Section 3.1.2 (page 3-15) and in the response to Comment D-62/8
(Volume II, page DEC-135).
Sixth, M. Sigworth surmises that the Department has
``failed to discuss contingency enforcement fine levels for
offenders.'' The Department's role in this proposed project is not that
of a regulatory agency. Fines are established by legislation and
enforced by regulatory bodies such as the Environmental Protection
Agency and PADER. Consequently, this is not a deficiency in the Final
Environmental Impact Statement.
Finally, M. Sigworth concludes that ``significant impact
studies on property values'' are not presented in the Final
Environmental Impact Statement. The Department believes the analysis of
impacts to real estate provided in Section 4.1.12.2 (page 4-166) and
Section 4.1.14.12 (page 4-197) to be sufficient.
Mr. Pat Brown submitted a reproduction of a page from the Final
Environmental Impact Statement (Volume IV, page WRITTEN-123) containing
the responses to two comments he had previously submitted. He was of
the opinion that the Department's replies were not written from the
perspective of someone whose life would be directly affected by the
project.
Mr. Brown noted that the response to W-PB-01/16a did not
clearly state whether or not the proposed facility would adversely
affect the quality of life in the community and did not address the
issue of health effects on children. He also noted that money cannot
replace anyone's health.
The Department included reference to the economic benefits that
could result from construction and operation of the YCEP facility
because financial security is reasonably included in a definition of
``quality of life.'' Mr. Brown is correct that the response does not
specifically address health effects to children; however, because of
the concerns regarding children, prior to issuance of the Draft
Environmental Impact Statement, the Department reassessed health risks
(particularly to children) for
[[Page 43458]]
boiler stack and cooling tower emissions. This information is presented
in Section 4.1.2.11 (page 4-65) of the Final Environmental Impact
Statement. The Department's analysis indicated that the project should
not adversely affect the health of children. Throughout the Final
Environmental Impact Statement, the Department presents its evaluation
of environmental consequences in terms of the likelihood of occurrence;
consequently, unequivocal claims are not made.
The second comment referred to the size of the YCEP
facility. Mr. Brown indicated that the Department's statement ``[t]he
plant size * * * is necessary to fulfill the needs of DOE's Clean Coal
Technology Program,'' in the response to Comment W-PB-01/16b, could be
translated to ``first on the list is to qualify for grant money.''
The scale of the single-boiler fluidized-bed unit [which will be
25% larger than any other unit built, under construction, or being
planned] was a factor in the Department's decision to select the
proposed project for demonstration under the Clean Coal Technology
Program. As noted earlier in this Record of Decision, the Department
believes that development of ACFB technology at the scale which will be
used in the YCEP Cogeneration Facility will accelerate the
commercialization of this maturing clean coal technology. If the ACFB
technology had been proposed at a smaller scale, it is probable that
the Department would not have viewed it as a technology requiring
demonstration, and thus, would not have considered funding it under the
Clean Coal Technology Demonstration Program.
Dr. Richard Dabb submitted a comment where he reiterated his
personal opposition to the project and asserted that his concerns
regarding adverse impacts to human health were not adequately reviewed.
The Department disagrees. The Department analyzed every report
previously submitted by the York County medical and osteopathic
communities, provided summaries in the Final Environmental Impact
Statement (page 4-69), and incorporated information from the reports in
an expanded health risk assessment discussion in Section 4.1.2.11 (page
4-63). In addition, responses to specific health effects issues were
provided for more that 30 comments, including: D-85/3; D-241/17; D-242/
11; D-243/2; D-255/11; D-256/1; D-257/4; J-85/21; J-111/3; J-112/3; J-
121/7; J-124/13; J-131/13; W-ACP-12/15a; W-HES-1/04a; W-LFL-12/14; W-
MK-1/28; W-PNK-1/3; W-PNP-12/94d; W-RS-1/27d; and W-YCMS-1/30.
Decision
DOE will implement the proposed action of providing approximately
$75 million in cost-shared federal funding support to YCEP for the
construction and operation of the ACFB technology as described in the
FEIS and summarized earlier in this Record of Decision. The YCEP
project will demonstrate ACFB technology in a cogeneration setting at a
single-boiler utility-scale which is approximately 25 percent larger
than any ACFB planned or in current operation. The project is expected
to generate sufficient data from the design, construction, and
operation to allow private industry to more accurately assess the
commercial potential of utility-scale (250-400 MWe) ACFB technology to
new or existing units. While it is possible that selecting no-action
would be environmentally preferable to the proposed action, it would
not produce the data needed to further the Congressionally-mandated
goals and objectives of demonstrating clean coal technologies. The
Department has evaluated the projected environmental impacts and
weighed the costs and benefits of proceeding with the proposed action,
and has determined that the benefits of early commercialization of the
technology described in the FEIS outweigh the limited environmental
impacts, which will be largely mitigated by the actions described in
this Record of Decision.
Mitigation Action Plan
Section 1021.331(a) of the Department of Energy regulations
implementing the National Environmental Policy Act (10 CFR Part 1021)
states that the Department shall prepare a Mitigation Action Plan that
addresses mitigation commitments expressed in the Record of Decision.
As a condition of providing federal funds under the Clean Coal
Technology Demonstration Program, the Department will require that
those mitigative measures, to which it has committed in the Final
Environmental Impact Statement and more specifically outlined and
discussed in the Mitigation Action Plan, will be implemented during the
construction and demonstration periods of the YCEP project.
In the course of making its decision, the Department analyzed the
information presented such as environmental and human health impacts
and associated mitigation measures, and determined that some of the
mitigation measures have been incorporated into the design of the
cogeneration facility, which include sound engineering and proper
construction practices, and that some of the mitigation measures are
part of existing YCEP/Air Products operating procedures. These
measures, which are considered part of the project, prevent or reduce
the likelihood of an adverse impact from occurring. However, the
Department also concluded that some adverse impacts are unavoidable
and, therefore, is requiring YCEP to complete additional mitigation or
monitoring measures that will lessen the severity of adverse
environmental impacts. All practicable means to avoid or minimize
environmental harm from the proposed action have been adopted. As part
of its agreement with the Department, YCEP is required to prepare an
Environmental Monitoring Plan and submit associated reports. The
Department will require YCEP to incorporate the following mitigation
measures into its Environmental Monitoring Plan and to document related
activities in quarterly reports.
Codorus Creek Monitoring
For the duration of the demonstration phase, YCEP will collect
samples from Codorus Creek both upstream and downstream of the P. H.
Glatfelter Company discharge. Samples of temperature, color, total
dissolved solids, lead, copper, chloride, free cyanide, phenolics, and
chloroform will be analyzed each quarter and during low-flow events.
Sampling of P.H. Glatfelter Company Effluent/Cooling Tower Evaporant
Stream
YCEP will conduct monthly sampling of P.H. Glatfelter Company
effluent/YCEP cooling tower evaporant stream as required by its PSD
permit, and will analyze the following components: volatile organic
compounds, semi-volatile organic compounds, chloroform, formaldehyde,
dimethylsulfide, chlorinated herbicides, and organochloride pesticides.
These sampling/analysis results will be submitted both to the PADER and
the Department within 30 days of completion of the laboratory analysis.
As a condition of this Record of Decision, these sampling results will
be made public by YCEP. YCEP will announce the availability of these
sampling results in the local reading rooms through notice in the local
newspapers.
Sampling results will be used to verify compliance with the 50
tons/year VOC emission limit and to verify that hazardous air pollutant
concentrations in the cooling water are consistent with the sampling
values known to PADER and the Department prior to issuance of
[[Page 43459]]
both the PSD Air Permit and this Record of Decision. Net VOC emissions
from the YCEP facility will not exceed 50 tons/year on an annualized
basis as prescribed by law.
Use of Geotextile Fabric for Temporary Roads
To protect existing ground, YCEP will create temporary roads that
have a stone fill on top of geotextile filter cloth. This measure will
be taken, as needed, throughout the construction period. After
construction, the stone fill and textile cloth will be removed.
Shrub Planting of Riparian Areas
YCEP will plant low growing shrub species in riparian areas along
Codorus Creek that have been cleared for transmission lines. Plantings
will take place as soon as possible following clearing, and under
favorable planting/establishment conditions.
Providing Nesting Structures
YCEP will place wood duck nesting boxes and other water fowl
nesting structures along Codorus Creek wherever large trees are
removed. YCEP will also place kestrel nesting boxes, bat boxes, and
other wildlife nesting/resting structures on the single-shaft steel or
wooden poles supporting the transmission line. The number, type, and
placement of nesting boxes will be mutually agreed upon by YCEP and the
Pennsylvania Game Commission.
Planting Warm Season Grasses
YCEP will plant warm season grass species. This measure will be
performed, as needed, throughout the construction phase, during
favorable planting conditions for seedling establishment. Unsuccessful
seedings will be reseeded the following spring.
Brush Pile Construction
YCEP will construct brush piles with vegetation cleared or trimmed
for pole and transmission line placement. This measure will be
performed, as needed, throughout the construction phase. The number and
placement of brush piles will be mutually agreed upon by YCEP and the
Pennsylvania Game Commission.
Reducing Logs and Limbs to Mulch
YCEP will reduce logs and limbs from cleared areas to chip
materials and leave them as mulch. This measure will be performed, as
needed, throughout the construction phase.
Steam Purge Notification
At the end of the construction phase, YCEP will take steps to
minimize the impact to local residents from the loud noise associated
with purging dirt and debris from the steam systems. These measures may
include providing advanced notice, minimizing the occurrence,
scheduling activities during less sensitive hours, and/or using vent
silencers.
Purchase of Residences
Although the expected magnetic field intensities at the residences
closest to Bair substation is less than 1 milligauss, YCEP will
negotiate purchase options for two properties near the Bair substation,
so it can assume ownership.
On-Street Parking Ban
During construction, YCEP facility security will enforce a ban of
on-street parking at the North Codorus site by posting signs,
patrolling the area, and arranging for vehicles to be towed if
necessary.
Traffic Monitoring
YCEP facility security will monitor traffic conditions throughout
the construction period. If congestion is noted, additional mitigation
measures will be implemented. These measures may include scheduling of
shifts or stationing traffic control personnel at critical locations.
Traffic Signal Installation
YCEP will communicate with the Pennsylvania Department of
Transportation and take whatever actions are necessary to ensure that a
traffic signal is installed at the York Road/Jefferson Road/Lehman Road
intersection before construction begins.
History/Tour of Dempwolf Architectural Firm
In accordance with a Memorandum of Agreement between the Department
and the Pennsylvania Bureau for Historic Preservation, YCEP will
publish a history and self-guided tour of the Dempwolf architectural
firm for distribution to the public. An outline, draft, and final draft
of the Dempwolf self-guided tour materials will be prepared and
reviewed by the Bureau for Historic Preservation. YCEP will provide 500
copies of the publication for distribution and a reproducible copy for
Historic York, Inc. The publication will be completed within 1\1/2\
years after the Memorandum of Agreement becomes effective.
Assist Bureau for Historic Preservation with Computer Coding
In accordance with a Memorandum of Agreement between the Department
and the Pennsylvania Bureau for Historic Preservation, YCEP will
provide the Bureau for Historic Preservation with a qualified
consultant, having a working knowledge of the Pennsylvania Historic
Resource Survey Form and York County resources. This individual will
work for a total of 15 days for 7\1/2\ hours each day and will assist
the Bureau with computer coding, mapping, and general organization of
York county historical survey records. Work will be completed within 6
months after the Memorandum of Agreement becomes effective.
Procedures currently are in place for Department oversight of
project activities. A Mitigation Action Plan for the YCEP Cogeneration
Facility has been developed that identifies how the Department will
ensure that YCEP implements all mitigation commitments and provides a
schedule for completion. This plan describes all of the mitigation
measures, including those incorporated into the project that prevent or
reduce the likelihood of an adverse impact occurring. Copies of the
Mitigation Action Plan may be obtained from Dr. Suellen A. Van
Ooteghem, Environmental Project Manager, Morgantown Energy Technology
Center, 3610 Collins Ferry Road, Morgantown, WV 26507-0880. Telephone
(304) 285-5443.
Issued in Washington, DC, on August 10, 1995.
Patricia Fry Godley,
Assistant Secretary for Fossil Energy.
[FR Doc. 95-20551 Filed 8-18-95; 8:45 am]
BILLING CODE 6450-01-P