ENVIRONMENTAL ANALYSIS IN SUPPORT OF AN APPLICATION FOR CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER GENERATING STATION

Prepared For:

H. A. WAGNER LLC 1005 BRANDON SHORES ROAD, STE 100 BALTIMORE, MD 21226

Prepared By:

ZEPHYR ENVIRONMENTAL CORPORATION 10440 LITTLE PATUXENT PARKWAY, STE 750 COLUMBIA, MD 21044

JANUARY 8, 2014

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

CONTENTS

1.0 INTRODUCTION ...... 1

1.1 PROJECT OVERVIEW ...... 1 1.2 SUMMARY OF REQUIRED PERMITS AND APPROVALS ...... 2 2.0 DESCRIPTION OF THE SITE AND ADJACENT AREAS ...... 6

2.1 PROJECT SITE LOCATION AND DESCRIPTION ...... 6 2.2 BIOPHYSICAL ENVIRONMENT ...... 12 2.2.1 Meteorology and Ambient Air Quality ...... 12 2.2.2 Geohydrology ...... 21 2.2.3 Surficial Hydrology ...... 28 2.2.4 Ecology ...... 28 2.2.5 Existing Acoustical Environment ...... 33 2.3 ARCHAEOLOGICAL, ARCHITECTURAL, AND HISTORICAL SITES ...... 35 2.1 LAND USE ...... 37 2.1.1 Regional Setting ...... 37 2.1.2 Comprehensive Land Use ...... 37 2.1.3 Zoning ...... 39 2.1.4 Existing and Approved Land Uses ...... 39 2.1.5 Agricultural Resources ...... 44 2.1.6 Open Space Areas ...... 44 2.1.7 Chesapeake Bay Critical Area ...... 44 2.1.8 Visual Quality ...... 44 3.0 PROJECT DESCRIPTION ...... 48

3.1 GENERAL DESCRIPTION ...... 48 3.2 DSI SYSTEM: PROJECT DESIGN AND OPERATIONAL FEATURES ...... 49 3.2.1 Process Description ...... 49 3.2.2 Site Layout ...... 50 3.2.3 Air Emissions and Controls ...... 51 3.2.4 Water Use and Wastewater Effluents ...... 51 3.2.5 Onsite Drainage ...... 51 3.2.6 Solid and Hazardous Wastes ...... 52 3.3 SUBBITUMINOUS COAL USE: PROJECT DESIGN AND OPERATIONAL FEATURES ...... 52 3.3.1 Subbituminous Coal Characteristics ...... 53 3.3.2 Process Description ...... 54 3.3.3 Site Layout ...... 55 3.3.4 Air Emissions and Controls ...... 55 3.3.5 Water Use and Wastewater Effluents ...... 55 3.3.6 Onsite Drainage ...... 56 3.3.7 Solid and Hazardous Wastes ...... 56 3.4 PROJECT SCHEDULE ...... 57

ZEPHYR ENVIRONMENTAL CORPORATION I CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

3.5 RATIONALE FOR SITE SELECTION AND PROJECT CONCEPTUAL DESIGN ...... 57 3.6 IMPACT ON STATE ECONOMICS ...... 57 3.7 PROJECT EFFECT ON ELECTRIC SYSTEM STABILITY AND RELIABILITY ...... 57 3.8 FEATURES OF REQUIRED ELECTRIC SYSTEM UPGRADES ...... 58 4.0 EFFECTS OF SITE PREPARATION AND PROJECT CONSTRUCTION...... 60

4.1 IMPACTS ON AIR QUALITY ...... 60 4.2 IMPACTS ON GROUNDWATER ...... 61 4.3 IMPACTS ON SURFACE WATER ...... 61 4.4 ECOLOGICAL IMPACTS ...... 61 4.5 NOISE IMPACTS ...... 62 4.6 SOCIOECONOMIC AND LAND USE IMPACTS ...... 63 4.6.1 Socioeconomic Impacts ...... 63 4.6.2 Land Use Impacts ...... 64 4.6.3 Impacts on Public Services and Facilities ...... 64 4.6.4 Impacts on Cultural Resources ...... 65 4.6.5 Impacts on Chesapeake Bay Critical Area (CBCA) ...... 65 4.6.6 Visual Impacts ...... 65 5.0 EFFECTS OF PROJECT OPERATION ...... 67

5.1 IMPACTS ON AIR QUALITY ...... 67 5.1.1 Emissions Estimates for Subbituminous Coal Use ...... 67 5.1.2 Emission Estimates for DSI System ...... 73 5.1.3 Air Quality Regulatory Analysis ...... 75 5.2 IMPACTS ON GROUNDWATER ...... 79 5.3 IMPACTS ON SURFACE WATER ...... 80 5.3.1 Wastewater...... 80 5.3.2 Storm Water ...... 80 5.3.3 Sanitary Wastewater ...... 80 5.4 ECOLOGICAL IMPACTS ...... 80 5.5 NOISE IMPACTS ...... 81 5.6 IMPACTS ON SOLID WASTE DISPOSAL ...... 81 5.7 SOCIOECONOMIC AND LAND USE IMPACTS ...... 82 5.7.1 Transportation Impacts ...... 82 5.7.2 Socioeconomic Impacts ...... 83 5.7.3 Land Use Impacts ...... 83 5.7.4 Impacts on Public Services and Facilities ...... 83 5.7.5 Impacts on Cultural Resources ...... 84 5.7.6 Visual Impacts ...... 84

ZEPHYR ENVIRONMENTAL CORPORATION II CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

FIGURES

Figure 2-1 Site Locator Map Figure 2-2 Project Site and Surrounding Area Communities and Highways Figure 2-3 Project Site and Local Area Roads and Other Features Figure 2-4 Topographic Features of the Site and Vicinity Figure 2-5 Aerial Photograph of Site and Vicinity Figure 2-6 Wagner Generating Station Existing Layout Figure 2-7 Five-Year Annual Wind Rose for BWI (1995 to 1999) Figure 2-8 Five-Year Seasonal Wind Rose for BWI (1995 to 1999) Figure 2-9 Maryland Ozone (8-hr) Nonattainment Areas Figure 2-10 Maryland PM2.5 Nonattainment Areas Figure 2-11 Air Quality Index Chart for Anne Arundel County, 2010 Figure 2-12 Air Quality Index Chart for Anne Arundel County, 2011 Figure 2-13 Air Quality Index Chart for Anne Arundel County, 2012 Figure 2-14 The Coastal Plain of Maryland Figure 2-15 Hydrogeologic Section Figure 2-16 Location of Flood Plains in Site Vicinity Figure 2-17 DNR Wetlands in Site Vicinity Figure 2-18 NWI Wetlands in Site Vicinity Figure 2-19 Sensitive Species Review Areas in Site Vicinity Figure 2-20 Forest Interior-Dwelling Species (Potential Habitat) in Site Vicinity Figure 2-21 Presence of Cultural Resources Figure 2-22 Historic Resources in Northern Anne Arundel County Figure 2-23 General Development Plan Land Use Map Figure 2-24 Zoning Map for Site and Vicinity Figure 2-25 Land Use in Site Vicinity as of 2010 Figure 2-26 Land Use Plan in Site Vicinity as of 2009 Figure 2-27 Chesapeake Bay Critical Areas in Site Area Figure 2-28 Chesapeake Bay Critical Areas in Immediate Site Vicinity

TABLES

Table 1-1 Summary of State, Federal, and Local Permits and Approvals Possibly Required for the Proposed Projects at Wagner Table 2-1 National and Maryland Ambient Air Quality Standards Table 2-2 AQI Data for Anne Arundel County, 2010 – 2012 Table 2-3 General Geologic Units, Thickness, and Lithology of East Baltimore Area Table 2-4 Subjective Effect of Changes in Sound Pressure Levels Table 2-5 Typical Sound Levels Table 4-1 Maximum Allowable Noise Levels (dBA) for Various Land Use Categories Table 5-1 Comparison of Ash, Nitrogen, and Sulfur Contents on a lb/MMBtu basis for Bituminous and Subbituminous Coals Table 5-2 CO and VOC Emissions Comparison for Bituminous and Subbituminous Coals

ZEPHYR ENVIRONMENTAL CORPORATION III CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Table 5-3 Change in PM Emissions for Material Handling Operations Associated with the Use of Subbituminous Coal Table 5-4 PM Emissions Summary for Sources Associated with the DSI System for Wagner Units 2 and 3 Table 5-5 Emissions Change Summary for the Project at Wagner and NSR Applicability Assessment

APPENDICES

Appendix A MATERIAL SAFETY DATA SHEET FOR HYDRATED LIME Appendix B EQUIPMENT DIAGRAMS Appendix C SITE PLANS (WITH DSI EQUIPMENT LOCATION) Appendix D ANALYSIS OF COAL SAMPLE DATA Appendix E EMISSIONS CALCULATIONS Appendix F MDE PTC APPLICATION FORMS

ZEPHYR ENVIRONMENTAL CORPORATION IV CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

LIST OF ACRONYMS AND ABBREVIATIONS

°F degree Fahrenheit AAQS Ambient Air Quality Standards acfm actual cubic feet per minute AQI air quality index ASHRAE American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. BMP Best Management Practice Brandon Shores Brandon Shores Generating Station BTU British thermal unit BWI Baltimore-Washington International Thurgood Marshall Airport CAA Clean Air Act CBCA Chesapeake Bay Critical Area CFR Code of Federal Regulations CO2 carbon dioxide CO carbon monoxide COMAR Code of Maryland Regulations CPCN Certificate of Public Convenience and Necessity CPM condensable particulate matter Crane Charles P. Crane Generating Station dB decibel dBA A-weighted decibel DNR Maryland Department of Natural Resources DSI dry sorbent injection EPA U.S. Environmental Protection Agency ESP electrostatic precipitator FIDS forest interior-dwelling species FR Federal Register ft foot ft/sec feet per second GDP General Development Plan GHG greenhouse gas gpd gallons per day gr/scf grains per standard cubic foot HAA Maryland Healthy Air Act HCl hydrogen chloride HF hydrogen fluoride Hg mercury Hz hertz I-695 Interstate 695 ID induced draft IDA intense development area lb pound lb/hr pounds per hour lb/MMBtu pounds per million British thermal units LDA limited development area µg/m3 micrograms per cubic meter m meter

ZEPHYR ENVIRONMENTAL CORPORATION V CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

MATS Mercury and Air Toxics Standards MDE Maryland Department of Environment MD-173 Maryland Route 173 MERLIN Maryland’s Environmental Resources and Land Information Network MMBtu million British thermal units MMBtu/hr million British thermal units per hour MMBtu/yr million British thermal units per year mph miles per hour MW megawatt NAAQS National Ambient Air Quality Standards NNSR Nonattainment New Source Review NO2 nitrogen dioxide NOx nitrogen oxide NPDES National Pollutant Discharge Elimination System NSPS New Source Performance Standards NSR New Source Review NWI National Wetland Inventory NWS National Weather Service O3 ozone OS open space Pb lead PM particulate matter PM2.5 PM with a diameter of less than or equal to 2.5 micrometers PM10 PM with a diameter of less than or equal to 10 micrometers PM(TSP) Total suspended particulate matter PPRP Power Plant Research Program PRB Powder River Basin PSC Maryland Public Service Commission PSD Prevention of Significant Deterioration PUC Public Utilities Commission SAM sulfuric acid mist SCR selective catalytic reduction SNCR selective non-catalytic reduction SO2 sulfur dioxide SPCC spill prevention, control, and countermeasure SWM storm water management SWPPP Storm Water Pollution Prevention Plan tph tons per hour tpy tons per year USGS U.S. Geological Survey VOC volatile organic compound Wagner Herbert A. Wagner Generating Station WWTP wastewater treatment plant

ZEPHYR ENVIRONMENTAL CORPORATION VI CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

1.0 INTRODUCTION

H.A. Wagner LLC (the Applicant), a subsidiary of Raven Power Holdings LLC (Raven), is applying to the Maryland Public Service Commission (PSC) for a Certificate of Public Convenience and Necessity (CPCN) to modify the Herbert A. Wagner Generating Station (Wagner). This section of the CPCN application environmental analysis document provides an overview of the proposed modifications, summarizes the process for obtaining a CPCN under Maryland’s Power Plant Siting Act of 1971 (Chapter 31 of the Laws of Maryland for 1971 and subsequent amendments), and describes the various permits and approvals that are required.

1.1 PROJECT OVERVIEW

Wagner Station, owned by H. A. Wagner LLC, is located at 3000 Brandon Shores Road Baltimore, Maryland, and is located in northern Anne Arundel County. Wagner is operated by Raven Power Fort Smallwood LLC, located at 1005 Brandon Shores Road, Ste. 100, Baltimore, Maryland.

The main electrical generating units at Wagner and their current PJM capacity ratings are as follows: Unit 1, natural gas-fired (oil backup) unit, nominally rated at 126 megawatts (MW) net, which began operation in 1956; Unit 2, coal-fired unit, single wall-fired boiler type, nominally rated at 135 MW net, which began operations in 1959; Unit 3, coal-fired unit, opposed wall-fired dry-bottom boiler type, nominally rated at 305 MW net, which began operations in 1966; and Unit 4, oil-fired unit, nominally rated at 397 MW net, which began operations in 1972.

The focus of this CPCN application is on air emissions associated with coal firing in Units 2 and 3. Units 2 and 3 are each equipped with a cold-side electrostatic precipitator (ESP) for control of particulate matter (PM) emissions. Unit 2 is equipped with a selective non-catalytic reduction

(SNCR) system for control of nitrogen oxides (NOx) emissions, while Unit 3 is equipped with a selective catalytic reduction (SCR) system for control of NOx emissions. Each coal-fired boiler is equipped with an activated carbon injection system for control of mercury emissions and each boiler burns a refined coal, produced on site through the mixing of coal with two additives for emissions reduction.

Under the federal Mercury and Air Toxics Standards (MATS) rule, Wagner must comply with HCl standards for Units 2 and 3 by April 16, 2015. Wagner currently can achieve compliance with the particulate matter (PM) emission standard and the mercury emission standard. However, Wagner must either reduce HCl generated in the boiler and/or control HCl emissions in order to comply with the MATS HCl standard. [Additionally, since Wagner is on the same property as the Brandon Shores Generating Station (Brandon Shores) and under common control, Wagner may use averaging of HCl emissions with units at Brandon Shores in evaluating compliance.]

ZEPHYR ENVIRONMENTAL CORPORATION 1 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The Applicant is planning for two approaches to reduce HCl emissions to achieve compliance with the MATS. First, to reduce HCl generated in the boiler, the Applicant is proposing to burn in Unit 2 and/or Unit 3, subbituminous coals either solely or in blends with bituminous coals. Second, the Applicant is also proposing to use dry sorbent injection (DSI), a proven add-on control technology for reducing HCl emissions from Unit 2 and/or Unit 3. For this application, Wagner is proposing to use hydrated lime as the sorbent. The use of DSI will not adversely

alter boiler operations and will reduce emissions of certain pollutants, namely HCl and SO2.

There are ancillary emissions reductions benefits associated with both approaches. As Units 2

and 3 are also subject to SO2 emission limitations under the Maryland Healthy Air Act (HAA) (COMAR 26.11.27), the use of DSI and/or subbituminous coal (with its inherent lower sulfur content) will have the co-benefit of providing further flexibility for continued compliance with the HAA.

Testing of the DSI technology has been performed at Wagner to characterize the potential effectiveness, as well as associated environmental impacts that may result from construction and operation of the system. Based on those tests, specifications were developed and served as the basis for various designs and bids by vendors. A final vendor/design selection has yet to be made; therefore, the potential project impacts have been evaluated based on the highest potential emissions from the potential designs. The Application also assumes the most likely design, though the different designs are not materially different for the purposes of this Application and analysis.

The Applicant seeks to initiate final project engineering and construction for the DSI system in July 2014, with an in-service date of March 2015. This schedule is necessary in order to ensure construction and testing of the system in time to meet the MATS compliance deadline. Further, the Applicant intends to begin accepting delivery of subbituminous coal at Wagner by October 20141.

1.2 SUMMARY OF REQUIRED PERMITS AND APPROVALS

Prior to beginning final project engineering and construction of the DSI system and use of subbituminous coal at Wagner, the Applicant will need to obtain several licenses, permits, and approvals. The key approval for the project will be the CPCN from the PSC.

1 The Applicant believes that the use of subbituminous coal at Wagner Units 2 and 3 should not require a CPCN, as it is (1) arguably not a “physical alteration, replacement, change in the method of operation, or any other change . . .” or (2) even if a “change,” otherwise exempt from the CPCN requirement because it is a “[u]se of an alternative fuel or raw material . . . which: (a) [t]he source was capable of accommodating before January 6, 1975 . . . or (b) [t]he source is approved to use under a [CPCN] . . . .” See COMAR 20.79.01.06(C). Nevertheless, the Applicant is conservatively seeking a CPCN explicitly authorizing use of subbituminous coal.

ZEPHYR ENVIRONMENTAL CORPORATION 2 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

In addition to the CPCN, the Applicant will obtain other permits and approvals related to the proposed projects. Some of these permits and approvals will be required before construction of various project components can commence. Table 1-1 lists the other state and local permits and approvals required for the proposed projects.

The purpose of this environmental analysis document is to identify and assess potential environmental, ecological, socioeconomic and land use impacts associated with the construction and operation of the DSI system and use of subbituminous coal, consistent with the CPCN filing requirements of COMAR 20.79, listed in Table 1-1.

The DSI project involves the injection of sorbent into the boiler exhaust, which will reduce emissions of certain air pollutants from Wagner Units 2 and 3, while not adversely affecting boiler operations or emissions of other air pollutants. There will be a small increase in PM emissions from the DSI system (mainly from sorbent and ash handling), although these increases will not exceed New Source Review (NSR) significance thresholds (i.e., the proposed changes will not constitute a “major modification”).

In addition, while the construction and operation of the new equipment will have some other associated environmental impacts, these impacts can be characterized as minimal and do not trigger any federal permit requirements. For example, all construction activities are expected to occur within the previously impacted, active areas of the existing plant, and no construction is anticipated to occur within or close to any sensitive environmental or land use features (e.g., a wetland area or an area of special or sensitive habitat).

Subbituminous coal will be stockpiled on the existing coal pile. No modifications to the coal handling equipment are necessary to accommodate the use of subbituminous coal. Also, no modifications to the two boilers are necessary, and none will be made. (The boilers may have a small de-rate when subbituminous coal is burned, depending on the characteristics of the coal.)

Given (a) the DSI system and subbituminous coal pile locations at and within an existing power plant site, (b) the reductions in air pollution that will result from the implementation of the projects, and (c) the minimal potential to negatively impact most environmental resource areas to begin with as a result of the nature of the project and its layout and design, there are limited or no impacts associated with the various subjects of review in a CPCN application. Nonetheless, the Applicant has addressed each of the required subject areas in its application.

ZEPHYR ENVIRONMENTAL CORPORATION 3 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Table 1-1 Summary of Federal, State, and Local Permits and Approvals Possibly Required for the Proposed Projects at Wagner

Potentially Waiver or Required Applicable Status Variance for: to Project? (If Applicable) Requested ?

Filed

No No Yes Yes

be Herein

Operation Contained Permit/Approval to

Regulatory Responsible Application Application Construction val Obtained val Citation(s) Agency(ies) Permit/Appro Comments Federal Safe Efficient Use and 14 CFR 77 FAA Per §77.9(e), notice Preservation of the not required for any Navigable Airspace object that will be shielded by existing permanent and substantial structures. New sorbent storage silos will be shielded by the nearby taller boiler building. State Certificate of Public Maryland Convenience and COMAR 20.79 PSC, DNR, Necessity (CPCN)* † MDE CAA Title V Permit COMAR 26.11.03, MDE Application to be filed Modification 40 CFR Part 70 at later date in compliance with regulatory requirements.

State Discharge Permit COMAR 26.08.04, MDE (Storm water) CWA Section 401, 40 CFR 122 Local‡ See Comments Anne Arundel Anne Requirements under County Zoning Arundel local ordinances, Regulations County including building permit, grading permit (including E&S control), CBCA, and zoning and site plan approval to be addressed as applicable.

Note: CAA = Clean Air Act EPA = U.S. Environmental Protection DNR = Maryland Department of Natural CBCA = Chesapeake By Critical Area Agency Resources E&S = Erosion and Sediment MDE = Maryland Department of the PSC = Public Service Commission FAA = Federal Aviation Administration Environment *Per COMAR 26.11.02.09 and 10, “Electric generating stations that receive a certificate of public convenience and necessity (CPCN) under Public Utilities Article, §7-207 and 7-208, Annotated Code of Maryland” are not subject directly to air emission source “permits to construct and approvals.” Rather, under state law, specifically Section 7-208 of the PUC Article, the CPCN constitutes the permit to construct (PTC). Accordingly, PTC conditions are contained within and issued as part of the CPCN. †Under Section 7-208 of the PUC Article, the CPCN constitutes the state water appropriation permit. Accordingly, permit conditions stemming from water appropriation and use requirements are contained within and issued with the CPCN. ‡Local and county approvals may be preempted by state law.

ZEPHYR ENVIRONMENTAL CORPORATION 4 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

REFERENCES Code of Maryland Regulations (COMAR). 2013. www.dsd.state.md.us/comar

ZEPHYR ENVIRONMENTAL CORPORATION 5 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

2.0 DESCRIPTION OF THE SITE AND ADJACENT AREAS

This chapter describes the environmental features of the Wagner site and surrounding area and contains the following sections in compliance with the regulatory requirement that the environmental information include “[a] general description of the physical, biological, aesthetic, and cultural features and conditions of the site and adjacent areas” [COMAR 20.79.03.02.B.(1)(a)]: 2.1—Project Site Location and Description; 2.2—Biophysical Environment, including: Meteorology and ambient air quality; Geohydrology; Surficial hydrology; Ecology; Noise; 2.3—Cultural Resources; and 2.4—Land Use.

The information provided in this chapter was developed from information and data assembled from other recent applications associated with and studies conducted at Wagner and adjacent Brandon Shores, and literature and other publicly available sources. This chapter serves as the baseline from which the impacts of the proposed project are evaluated.

2.1 PROJECT SITE LOCATION AND DESCRIPTION

Wagner, which is collocated with the Brandon Shore power plant within Raven Power’s Fort Smallwood property, is located in northern Anne Arundel County. Figure 2-1 illustrates the general location of the site within the state of Maryland. Figures 2-2 and 2-3 show the site location superimposed on highway and street maps. Figure 2-4 shows the approximate Wagner site boundary within the Fort Smallwood property site superimposed on U.S. Geological Survey (USGS) topographical map. Figure 2-5 shows the site on an aerial photograph (dated 2005). The Wagner property and other selected features of the area have been highlighted on the various maps.

As shown, Wagner is located on the western shore of the Patapsco River and is also partially bounded on the south by Cox Creek. Brandon Shores occupies land immediately north and west of the Wagner site. The Stoney Beach and Orchard Beach neighborhoods are located south of the site on the opposite shore of Cox Creek. The Riviera Beach community is further to the south of the site.

ZEPHYR ENVIRONMENTAL CORPORATION 6 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-1 Site Locator Map

ZEPHYR ENVIRONMENTAL CORPORATION 7 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-2 Project Site and Surrounding Area Communities and Highways

ZEPHYR ENVIRONMENTAL CORPORATION 8 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-3 Project Site and Local Area Roads and Other Features

ZEPHYR ENVIRONMENTAL CORPORATION 9 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-4 Topographic Features of the Site and Vicinity

ZEPHYR ENVIRONMENTAL CORPORATION 10 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-5 Aerial Photograph of Site and Vicinity

Wagner is part of the Raven’s Fort Smallwood property that includes Brandon Shores, Wagner, and a warehouse; the aggregate Fort Smallwood property occupies a total of 455 acres. The topography of the plant property is flat, with elevations just a few feet above sea level. In addition, portions of the plant property are within the 500-year floodplain and the designated Chesapeake Bay Critical Area (CBCA). The matters of flood plain and CBCA are discussed later in this chapter.

Figure 2-6 shows the current plant layout and key features. As indicated previously, the main generating units at the plant are the four steam-electric units, including the two coal-fired units (Units 2 and 3). There is also a small (14-MW) No. 2 distillate fuel oil-fired combustion turbine generating unit at the plant. Other prominent features of the plant include barge coal unloading

ZEPHYR ENVIRONMENTAL CORPORATION 11 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

facilities, coal storage pile and handling equipment, and a coal additive mixing facility within the coal yard.

2.2 BIOPHYSICAL ENVIRONMENT

2.2.1 Meteorology and Ambient Air Quality

2.2.1.1 Climatology/Meteorology

The climate in north-central Maryland is classified as temperate with maritime influences from the Atlantic Ocean and Chesapeake Bay. Summers are warm and relatively humid, while winters are generally mild because of the warming influence of the Gulf Stream.

A summary of monthly mean and extreme temperatures based on National Weather Service (NWS) data collected at Baltimore-Washington International Thurgood Marshall Airport (BWI) can be used to describe the Wagner site’s basic climatic characteristics.

This NWS station is approximately 7 miles west of the plant site. Based on these data, January exhibits the lowest mean minimum temperature (approximately 24 degrees Fahrenheit [°F]) and the lowest normal mean monthly temperature (32°F). The highest mean daily maximum temperature (87°F) and the maximum mean monthly temperature (77°F) occur in July. The average annual temperature is 55°F.

Normal annual precipitation is approximately 42 inches. Summer rainfall is generally derived from local showers or thunderstorms. The highest normal monthly rainfall is 3.98 inches in September, while April is the driest month with an average of 3.00 inches of precipitation.

March has the highest mean monthly wind speed of 11 miles per hour (mph). The lowest mean monthly wind speed of 7.9 mph occurs in both July and August. The annual average wind speed is 9.3 mph. Figure 2-7 presents a 5-year annual wind rose (1995 to 1999) based on surface wind direction and wind speed observed at BWI. Figure 2-8 presents 5-year seasonal wind roses for the same station and period of record. The values presented in the figures represent

ZEPHYR ENVIRONMENTAL CORPORATION 12 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-6 Wagner Generating Station Existing Layout

ZEPHYR ENVIRONMENTAL CORPORATION 13 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-7 Five-Year Annual Wind Rose for BWI (1995 to 1999)

ZEPHYR ENVIRONMENTAL CORPORATION 14 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-8 Five-Year Seasonal Wind Rose for BWI (1995 to 1999)

ZEPHYR ENVIRONMENTAL CORPORATION 15 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

the percent of the time the wind blows from a particular direction at a given speed. The predominant wind directions during the 5-year period were from the west and west-northwest. The wind blew from the west approximately 15 percent of the time.

Thunderstorms are the most common severe weather in the area, occurring on an average of 28 days each year. Hurricanes and tornadoes are types of severe weather that may occur in the area. The possibility of a hurricane-strength tropical storm (winds greater than 73 mph) crossing the area is approximately 2 percent in any given year.

2.2.1.2 Ambient Air Quality

The Wagner site is located in an area that the Maryland Department of the Environment (MDE) has designated as attainment for most air pollutants and averaging times. This means the area meets most of the National Ambient Air Quality Standards (NAAQS) that are given in Table 2-1. (The NAAQS are incorporated into the Maryland air quality regulations through COMAR 26.11.04.02.) However, the area is designated nonattainment for the pollutants ozone and fine

particulate matter (PM with a diameter of less than or equal to 2.5 micrometers (PM2.5)), as shown in Figures 2-9 and 2-10, respectively. (Much of the northeastern United States is

classified as nonattainment for both ozone and PM2.5, and both are regional issues, as opposed to issues attributable to specific point sources of pollutants.) Although EPA has designated the

Baltimore Area, including Anne Arundel County, as a nonattainment area for PM2.5, the area has been classified by EPA as an unclassifiable/attainment area specifically for the 24-hr PM2.5 NAAQS (40 CFR 81.321).

In addition to the NAAQS, the MDE recognizes fluorides as a State AAQS (COMAR 26.11.04.01). MDE may assume unsatisfactory conditions exist if the ambient gaseous fluoride concentration exceeds 1.2 µg/m3 in any 24-hr sample or 0.4 µg/m3 in any 72-hr sample.

ZEPHYR ENVIRONMENTAL CORPORATION 16 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Table 2-1 National and Maryland Ambient Air Quality Standards Averaging Primary Secondary Pollutant Period NAAQS NAAQS 3) 3) 8-Hour (2008) a 150 (0.075 ppm) 150 (0.075 ppm)

a Ozone (O3) 8-Hour (1997) 157 (0.08 ppm) 157 (0.08 ppm) 1-Hour b,c 235 (0.12 ppm) 235 (0.12 ppm) 1-Hour d 40000 (35 ppm) - Carbon Monoxide (CO) 8-Hour d 10,000 (9 ppm) - 1-hour e 189 (100 ppb) - Nitrogen Dioxide (NO2) Annual f 100 (53 ppb) 100 (53 ppb) 24-Hour g 35 35 PM2.5 Annual h 12 15

i PM10 24-Hour 150 150

Lead (Pb) 3-Month j 0.15 0.15 1-Hour k 195 (75 ppb) - Sulfur Dioxide (SO2) 3-Hour d - 1300 (0.5 ppm) Notes: µg/m3 = micrograms per cubic meter a Annual fourth-highest daily maximum 8-hour concentration, averaged over 3 years. b Maximum 1-hour daily average concentration, not be exceeded more than one day per calendar year on average c EPA revoked this standard in all areas, but some areas have continuing obligations to it. The standard no longer applies in Maryland. d Not to be exceeded more than once per year. e The 98th percentile of daily maximum 1-hour average concentrations, averaged over 3 years. f Annual arithmetic mean. g The 98th percentile of 24-hour concentrations, averaged over 3 years. h Annual arithmetic mean, averaged over 3 years. i Not be exceeded more than once per year on average over 3 years. j Not to be ex c eeded. k The 99th percentile of daily maximum 1-hour concentrations, averaged over 3 years.

ZEPHYR ENVIRONMENTAL CORPORATION 17 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-9 Maryland Ozone (8-hr) Nonattainment Areas

ZEPHYR ENVIRONMENTAL CORPORATION 18 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-10

Maryland PM2.5 Nonattainment Areas

ZEPHYR ENVIRONMENTAL CORPORATION 19 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Local and regional ambient air quality monitoring data are available with which to generally characterize the existing air quality conditions in the vicinity of the site. Using the available data, the U.S. Environmental Protection Agency (EPA) has developed the Air Quality Index (AQI) for characterization of the air quality in a given county. Air quality is described over a range from good to hazardous based on a calculated numerical value, as follows:

Each category corresponds to a different level of health concern. The six levels of health concern are defined as follows: Good—The AQI value for the community is between 0 and 50. Air quality is considered satisfactory, and air pollution poses little or no risk. Moderate—The AQI for the community is between 51 and 100. Air quality is acceptable; however, for some pollutants there may be a moderate health concern for a small number of people. For example, people who are unusually sensitive to ozone may experience respiratory symptoms. Unhealthy for Sensitive Groups—When AQI values are between 101 and 150, members of sensitive groups may experience health effects. This means they are likely to be affected at lower levels than the general public. For example, people with lung disease are at greater risk from exposure to ozone, while people with either lung disease or heart disease are at greater risk from exposure to particle pollution. The general public is not likely to be affected when the AQI is in this range. Unhealthy—Everyone may begin to experience health effects when AQI values are between 151 and 200. Members of sensitive groups may experience more serious health effects. Very unhealthy—AQI values between 201 and 300 trigger a health alert, meaning everyone may experience more serious health effects. Hazardous—AQI values over 300 trigger health warnings of emergency conditions. The entire population is more likely to be affected.

An AQI value of 100 generally corresponds to the NAAQS for the pollutant, which is the level EPA has set to protect public health. AQI values below 100 are generally thought of as satisfactory. When AQI values exceed 100, air quality is considered to be unhealthy—at first for certain sensitive groups of people, then for everyone as AQI values get higher.

ZEPHYR ENVIRONMENTAL CORPORATION 20 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

AQI charts for Anne Arundel County for 2010 through 2012 (the most recent three years available on EPA’s AirData website) are shown in Figures 2-11 through 2-13. Details of the AQI data are summarized in Table 2-2.

Table 2-2 AQI Data for Anne Arundel County, 2010 – 2012 Number of Days by AQI Category Total Unhealthy for Days of Sensitive Very Year Data Good Moderate Groups Unhealthy Unhealthy 2010 360 208 140 9 3 0 2011 267 193 63 11 0 0 2012 264 197 54 11 2 0

Based on the AQI data, during the years 2010-2012 the air quality was classified as “good” or “moderate” 96 percent of the time. The air pollutants of primary concern affecting air quality in

Anne Arundel County are ozone and PM2.5. As shown in the AQI charts, days having the highest AQI values for those pollutants occur mostly in the spring and summer months.

2.2.2 Geohydrology

The site is located within the Coastal Plain Province, east of Baltimore (Figure 2-14). The surficial geology in the area (Table 2-3) includes Quaternary Alluvium (Map Designation Ql) and Cretaceous Age Potomac Group (Kp). The alluvium consists of gravel, sand, silt, and clay. The Potomac Group consists of the Patapsco Formation (gray, brown, and red variegated silts and clays; lenticular, cross-bedded, argillaceous, sub-rounded sands; minor gravels; thickness 0 to 400 feet [ft]), the Arundel clay (dark gray and maroon lignitic clays; abundant siderite concretions; present only in Baltimore-Washington area; thickness approximately 100 ft in the area), and the Patuxent Formation (white or light gray to orange-brown, moderately sorted, cross-bedded, argillaceous, angular sands and sub-rounded quartz gravels; silts and clays subordinate, predominately pale gray; thickness 0 to 250 ft) (Southwick and Owens, 1968). In the area of interest, the alluvium is a thin surficial layer (less than 100 ft), and the total thickness of the Potomac Group is approximately 625 ft (Achmad, 1991). Driller’s well logs in the area show sand, clay, and sandy gravel interlayered to approximately 650 ft below land surface (Chapelle, 1985, and Smigaj and Davis, 1987). Figure 2-15 depicts the subsurface in the area of the site.

ZEPHYR ENVIRONMENTAL CORPORATION 21 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-11 Air Quality Index Chart for Anne Arundel County, 2010

ZEPHYR ENVIRONMENTAL CORPORATION 22 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-12 Air Quality Index Chart for Anne Arundel County, 2011

ZEPHYR ENVIRONMENTAL CORPORATION 23 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-13 Air Quality Index Chart for Anne Arundel County, 2012

ZEPHYR ENVIRONMENTAL CORPORATION 24 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-14 The Coastal Plain of Maryland

ZEPHYR ENVIRONMENTAL CORPORATION 25 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Table 2-3 General Geologic Units, Thickness, and Lithology of East Baltimore Area Thickness Hydrogeologic Geologic Map Symbol System Group Unit (ft) Unit Description

Gravel, sand Lowland Surficial if silt and clay, Ql Quaternary 0 to 100 deposits present often reworked

Sand, fine to Raritan and medium, Patapsco Patapsco 300 interbedded Aquifer Formations with silt or clay Potomac Kp Cretaceous Clay, thick, Group Arundel 100 Confining Bed interbedded Formation with sand

Sand and Patuxent Patuxent 225 gravel with Formation Aquifer clay and silt

Baltimore Used for Igneous and Paleozoic and Gabbro groundwater Bgb Unknown metamorphic Precambrian Complex west of the fall rocks line only

Igneous and Baltimore West of fall line pCbg Precambrian Unknown metamorphic Gneiss only rocks Sources: Southwick and Owens, 1968. Achmad, 1991. Fleck and Vroblesky, 1996.

ZEPHYR ENVIRONMENTAL CORPORATION 26 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-15 Hydrogeologic Section

ZEPHYR ENVIRONMENTAL CORPORATION 27 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

2.2.3 Surficial Hydrology

There are 10 major aquifers in the Coastal Plain region of Maryland. These include (in descending order) the surficial (Columbia Group), upper and lower Chesapeake Formation, Piney Point, Aquia, Magothy, Patapsco, and Patuxent (Wheeler and Wilde, 1989). The Wagner site is located within the Patapsco River Area (Sub-Basin 02-13-09). As shown in Figures 2-3 and 2-4, the site is also bordered by Cox Creek, which drains into the Patapsco. According to COMAR 26.08.02.07 and -.08, Patapsco River, like all Maryland surface waters, is designated for Use I (water contact recreation and protection of aquatic life). Some of the Wagner site area is within the designated flood plain, as shown in Figure 2-16.

2.2.4 Ecology

As with geohydrology and surficial hydrology, the Project at Wagner will have minimal potential to negatively impact ecological resources. To the extent that there are impacts, those impacts

will be positive, in that emissions of HCl and SO2 from the Wagner coal-fired boilers will decrease. There is little potential for the proposed project to negatively impact either wetlands or terrestrial and aquatic resources; therefore, no baseline monitoring of ecological resources was conducted. Existing information was assembled from online sources (e.g., Maryland’s Environmental Resources and Land Information Network (MERLIN) Online). The key findings supported by MERLIN data were as follows: Both the Maryland Department of Natural Resources (DNR) and National Wetlands Inventory (NWI) maps indicated the presence of wetlands in the site area. No Wetlands of Special State Concern were shown to be present anywhere in the project vicinity. The presence of Sensitive Species Review Areas was indicated in the vicinity of the site.

Wagner is located within the Maryland Piedmont Plateau Province on lands near the shores of Patapsco River near its mouth to Chesapeake Bay. The landscape in the site region is characterized by rolling hills with incised stream valleys.

DNR and NWI wetland maps are available on DNR’s Geospatial Data Website. Figures 2-17 and 2-18 show these maps overlaying aerial photographs.

DNR’s MERLIN Online site was also used to obtain the more detailed information regarding Sensitive Species Review Areas as delineated by the Wildlife and Heritage Service. Figure 2-19 presents the resulting data. Highlighted areas indicate the presence or possible presence of listed species. The areas closest to the plant site are Group 2 areas, which relate to state-listed species. DNR’s MERLIN Online site also provided some information regarding potential habitat

ZEPHYR ENVIRONMENTAL CORPORATION 28 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-16 Location of Flood Plains in Site Vicinity (ECT, 2006)

ZEPHYR ENVIRONMENTAL CORPORATION 29 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Wagner Station

Figure 2-17 DNR Wetlands in Site Vicinity

ZEPHYR ENVIRONMENTAL CORPORATION 30 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Wagner Station

Figure 2-18 NWI Wetlands in Site Vicinity

ZEPHYR ENVIRONMENTAL CORPORATION 31 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Wagner

2

2

Figure 2-19 Sensitive Species Review Areas in Site Vicinity

Note: Numbered areas contain resources of concern to DNR; both areas are designated as Group 2, referring to State listed species. Source: Maryland Department of Natural Resources, MERLIN Online, 2011.

ZEPHYR ENVIRONMENTAL CORPORATION 32 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

for forest interior-dwelling species (FIDS). Figure 2-20 presents this information. There are no ecological resources or potential habitats for FIDS within or adjacent to the Wagner site boundaries.

2.2.5 Existing Acoustical Environment

Noise metrics are used to quantify sound pressure levels and describe a sound’s loudness, duration, and tonal character. A commonly used descriptor is the A-weighted decibel (dBA). The A-weighting scale approximates the human ear’s sensitivity to certain frequencies by emphasizing the middle frequencies and deemphasizing the lower and higher frequency sounds. The decibel is a logarithmic unit measure of sound. A 10-decibel change in the sound level means a 10-fold change in sound pressure, which roughly corresponds to a doubling or halving of perceived loudness. A 3-dBA change in the noise level is generally defined as being just perceptible to the human ear. Table 2-4 provides the subjective effect of different changes in sound levels.

Table 2-4 Subjective Effect of Changes in Sound Pressure Levels (ASHRAE 1989) Change in Sound Level Apparent Change in Loudness 3 dBA Just perceptible 5 dBA Noticeable 10 dBA Twice (or half) as loud

Sound level measurements sometimes include the analysis and breakdown of the sound spectrum into its various frequency components to determine tonal characteristics. The unit of frequency is the hertz (Hz), measuring the cycles per second of sound waves, and typically the audible frequency range from 16 to 16,000 Hz is divided into 11 (full octave) or 33 (half-octave) bands. A source is said to create a pure tone, also called a prominent discrete tone in the MDE noise regulations (which can be distinctly heard as a single pitch or a set of single pitches), if the one-third octave band sound pressure level in the band with the tone exceeds the arithmetic average of the sound pressure levels of the two contiguous one-third octave bands by 5 dB for center frequencies of 500 Hz and above, by 8 dB for center frequencies between 160 and 400 Hz, and by 15 dB for center frequencies less than or equal to 125 Hz (COMAR 26.02.03.01 B.(19)). Examples of pure tone sounds are a backup alarm on a large motor vehicle, siren on an emergency vehicle, or squeaky ventilation fan.

When pure tones are present in a noise spectrum, the dBA level is not adequate to predict human response because pure tones, especially at higher frequencies, are much more annoying than a broadband noise of the same level. Therefore, sound level measurements typically include the analysis and breakdown of the sound spectrum into its various frequency components to determine tonal characteristics.

ZEPHYR ENVIRONMENTAL CORPORATION 33 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-20 Forest Interior-Dwelling Species (Potential Habitat) in Site Vicinity (ECT, 2006)

ZEPHYR ENVIRONMENTAL CORPORATION 34 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The acoustic environment in an area such as the Wagner site area results from numerous sources in the vicinity of the site. The primary sources of noise in the area certainly include the existing operations at Wagner and Brandon Shores; automotive traffic, including that on Fort Smallwood Road, which carries a significant amount of heavy industrial traffic; aircraft over- flights (BWI is approximately 7 miles west of the area); and natural sounds. Table 2-5 presents typical peak sound levels associated with various activities and environments.

Table 2-5 Typical Sound Levels (ECT, 2006) Activity dBA Threshold of pain 130 Chipping on metal 120 Loud rock band 110 Jack hammer 100 Jet airliner 0.5 miles away 95 Threshold of hearing damage 90 Freeway traffic—downtown streets 80 Urban residential area 70 Normal conversation 60 Normal suburban area 50 Quiet suburban area 40 Rural area 30 Wilderness area 25 Threshold of audibility 0

Given: (a) the existing noise sources in the site area, and (b) the limited potential for the proposed Project to result in noise levels beyond those already present, no new measurements of background noise were undertaken.

2.3 ARCHAEOLOGICAL, ARCHITECTURAL, AND HISTORICAL SITES

Historical structures and archeological sites located in the vicinity of the Wagner site were identified using available Maryland Historical Trust data and other information. First, DNR geographic information system data were obtained to assess the potential presence or absence of such structures or sites. Figure 2-21 presents this information. The likely presence of

ZEPHYR ENVIRONMENTAL CORPORATION 35 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-21 Presence of Cultural Resources (ECT, 2006)

ZEPHYR ENVIRONMENTAL CORPORATION 36 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

culturally significant sites is indicated by the shaded grid squares that indicate a site is (or may be) present somewhere within the square. As can be seen, all such sites and resources are shown to be located at distances of 0.5 mile or more from the Wagner plant site.

Additional investigations of the possible presence of important cultural resources were done using published and/or online sources. The Pasadena/Marley Neck Small Area Plan (Anne Arundel County, 2004) for the relevant portion of Anne Arundel County was one such source (see Figure 2-22). As shown, the nearest sites are 1 mile or more away from the Wagner plant site.

2.1 LAND USE

Wagner is located entirely within lands previously impacted by manmade development and primarily within close proximity to heavily industrial areas. Land use features are evident in the aerial photograph of the site (see Figure 2-5).

2.1.1 Regional Setting

The site is located in a developed area of suburban Baltimore within lands previously impacted by manmade development and within close proximity to heavily industrial areas. The site area is characterized by mixed industrial, commercial, and residential development; and highways and roads.

2.1.2 Comprehensive Land Use

Article 66-B of the Annotated Code of Maryland requires all Maryland counties adopt a comprehensive plan that sets forth goals, objectives, and policies as the basis for future growth and development. Anne Arundel County’s land use plan is its General Development Plan (GDP), revised in 2009.

The development of the 2009 GDP was conducted in two phases. During the first phase a series of background reports were prepared on specific topics, summarizing existing conditions, programs, processes and other information relevant to each topic. They also identified current and anticipated needs to be addressed in the GDP. The second phase developed plan policies and recommendation to compile a Public Review Draft Plan, which was presented for review in January 2009. The 2009 GDO was approved by the County Council under Bill No. 64-09 on October 19, 2009.

ZEPHYR ENVIRONMENTAL CORPORATION 37 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-22 Historic Resources in Northern Anne Arundel County

ZEPHYR ENVIRONMENTAL CORPORATION 38 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The Anne Arundel County 2009 GDP contains a land use planning map, presented in Figure 2- 23. As this figure shows, Wagner occupies land primarily designated Industrial, with a small area adjacent to Patapsco River and Cox Creek designated Residential Low-Medium Density.

2.1.3 Zoning

The Wagner site and its immediate surroundings are designated as Industrial—Heavy (W3) on the county zoning map (see Figure 2-24). A small area in the southeastern corner of the property is designated as Open Space (OS). The closest areas zoned residential are found to the south of the site across Cox Creek.

2.1.4 Existing and Approved Land Uses

This brief section identifies existing land uses in the vicinity of the site. This analysis is used as an inventory of land uses and does not necessarily imply there will be impacts to these uses.

Much of the land in the site area is zoned for industrial uses. These include the adjacent Brandon Shores Generating Station and the Brandon Shores Energy Business Park across Fort Smallwood Road. The site area also includes residential, commercial, and forested lands. Fort Smallwood Road is also dotted with many commercial establishments. Figure 2-25 shows the 2010 land uses in the immediate vicinity, while Figure 2-26 shows 2009 land uses in the surrounding area as compiled by Anne Arundel County. A mix of land uses is indicated in both figures, ranging from industrial (power plant sites) to commercial to forest to residential.

Potentially sensitive land uses are some distance from the Wagner site. The schools nearest the site are Solley Elementary School (see Figure 2-3) and St. Jane Francis School (see Figure 2-4). Both are approximately 1.5 miles away from the power plant site. There are no hospitals anywhere in the vicinity of the project area.

The site area is intersected by or lies near numerous transportation-related facilities, including major highways, rail lines, port facilities, and airports. Interstate 695 (I-695), oriented generally northeast-southwest, is located to the north of the site area. Fort Smallwood Road is the other significant road in the immediate area (see Figures 2-3 and 2-4). The nearest airport is BWI, which is approximately 7 miles to the west.

ZEPHYR ENVIRONMENTAL CORPORATION 39 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-23 General Development Plan Land Use Map

ZEPHYR ENVIRONMENTAL CORPORATION 40 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-24 Zoning Map for Site and Vicinity

ZEPHYR ENVIRONMENTAL CORPORATION 41 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-25 Land Use in Site Vicinity as of 2010

ZEPHYR ENVIRONMENTAL CORPORATION 42 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Figure 2-26 Land Use Plan in Site Vicinity as of 2009

ZEPHYR ENVIRONMENTAL CORPORATION 43 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

2.1.5 Agricultural Resources

The Maryland Agricultural Land Preservation Program was created in 1977 to preserve productive agricultural lands and woodlands. According to information and maps provided on the Web site that is maintained by the Maryland Department of Planning, Wagner is not near any agricultural land preservation areas.

2.1.6 Open Space Areas

There are state and county parks and other open space areas located in the vicinity of the Wagner site. The public open space facilities closest to Wagner are Solley Park and Brandon Woods Park located to the west, across Fort Smallwood Road (see Figure 2-3). Other public open spaces located within 3 miles of Wagner include Fort Armistead Park (just south of I-695), Fort Smallwood Park, Harry and Jeanette Weinberg Park, Rock Creek Park, Sunset Park, Stoney Creek Park, Tick Neck Park, Highpoint Park, and Solleys Cove Park.

2.1.7 Chesapeake Bay Critical Area

In 1984, the Maryland General Assembly passed the CBCA Law. This law requires all jurisdictions abutting Chesapeake Bay to designate all lands within 1,000 ft of tidal waters as critical areas and require environmental protection and mitigation for the effects of development and redevelopment within these zones. The state CBCA Commission was created to formulate protective criteria for the use and development of this planning area and oversee the programs developed by local jurisdictions. The state law requires that local jurisdictions develop and adopt their own critical area programs based on the state CBCA Commission’s criteria.

The state criteria designated three categories of development within the critical area based on existing development and public services available as of December 1, 1985. The three designations are intense development area (IDA), limited development area (LDA), and resource conservation area (RCA).

Figure 2-27 shows the boundaries of the critical area in the project site area. As this figure and the more detailed Figure 2-28 show, a portion of the Wagner site is within area designated IDA. Properties that are developed within the critical area are subject to special regulations that are detailed in the Anne Arundel County Code.

2.1.8 Visual Quality

The visual quality of the site and surrounding area is consistent with the mix of land uses in the area. The area is heavily industrial, characterized by the existing Brandon Shores and Wagner power plants and support facilities, existing high-voltage transmission lines, and other heavy industrial plants on either side of Fort Smallwood Road between Kembo Road and Fort Armistead Road (to the north). Thus, the existing visual quality of the site area could readily be characterized as heavily impacted by manmade activities.

ZEPHYR ENVIRONMENTAL CORPORATION 44 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Wagner

Figure 2-27 Chesapeake Bay Critical Areas in Site Area

ZEPHYR ENVIRONMENTAL CORPORATION 45 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Wagner

Figure 2-28 Chesapeake Bay Critical Areas in Immediate Site Vicinity

ZEPHYR ENVIRONMENTAL CORPORATION 46 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

REFERENCES Achmad, G. 1991. Simulated Hydrologic Effects of the Development of the Patapsco Aquifer System in Glen Burnie, Anne Arundel County, Maryland. Maryland Geologic Survey, Report of Investigations No. 54.

American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE). 1989. Handbook, Fundamentals. Atlanta.

Annotated Code of Maryland. Article 66-B.

Chapelle, F.H. 1985. Hydrogeology, Digital Solute Transport Simulation, and Geochemistry of the Lower Cretaceous Aquifer System Near Baltimore, Maryland. Maryland Geologic Survey, Report of Investigations No. 43.

Code of Maryland Regulations (COMAR). 2013. www.dsd.state.md.us/comar

Environmental Consulting & Technology, Inc. (ECT). 2006. Wagner Generating Station Modification for Addition of Air Pollution Controls. Application for Certificate of Public Convenience and Necessity, Environmental Information. October 2006.

Fleck, W.B., and Vroblesky, D.A. 1996. Simulation of Ground Water Flow of the Coastal Plain Aquifers in Parts of Maryland, Delaware and the District of Columbia. USGS Professional Paper 1404-J.

Smigaj, M.J., and Davis, R.G. 1987. Ground Water Levels from the Maryland Observation Well Network, 1943-1986, Maryland Geological Survey, Basic Data Report No. 17.

Southwick, D.L., and Owens, J.P. 1968. Geologic Map of Maryland. Maryland Geological Survey.

Wheeler, J.C., and Wilde, F.D. 1989. Groundwater Use in the Coastal Plain of Maryland, 1900-1980, USGS Open File Report 87-540.

WEB SITES

Anne Arundel County, Maryland. http://www.aacounty.org/

Anne Arundel County Code. http://www.amlegal.com/library/md/annearundelco.shtml

Maryland Department of Planning. Local Planning. www.mdp.state.md.us/info/localplan/counties.html

Maryland Department of Natural Resources. Maryland’s Environmental Resources and Land Information Network (MERLIN). www.mdmerlin.net

U.S. Environmental Protective Agency (EPA). www.epa.gov/air/data/index.html

U.S. Fish & Wildlife Service. www.fws.gov/wetlands/data/mapper.html

ZEPHYR ENVIRONMENTAL CORPORATION 47 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

3.0 PROJECT DESCRIPTION

This chapter provides a description of the key components and systems of the proposed projects: installation of DSI systems and the use of subbituminous coal. The descriptions provide an estimate of the expected character, quality, and quantity of potential environmental effects associated with construction and operation of the projects, which have been evaluated in terms of highest possible emissions. Also described are proposed measures to limit impacts on the environment. In response to the requirements for project information listed in COMAR 20.79.03.01, Description of Generating Station, the specific sections in this chapter are: 3.1—General Description 3.2— DSI System: Project Design and Operational Features: Process Description Site Layout Air Emissions and Controls Water Use and Wastewater Effluents Onsite Drainage Solid and Hazardous Wastes 3.3— Subbituminous Coal use: Project Design and Operational Features: Subbituminous Coal Characteristics Process Description Site Layout Air Emissions and Controls Water Use and Wastewater Effluents Onsite Drainage Solid and Hazardous Wastes 3.4— Project Schedule 3.5—Rationale for Site Selection and Project Conceptual Design 3.6—Impact on State Economics 3.7—Project Effect on Electric System Stability and Reliability 3.8—Features of Required Electric System Upgrades

The facilities and equipment descriptions and project schedule presented in this chapter are based on the Applicant’s current plans, engineering and available design information (as of the submittal date of this application) for the projects.

3.1 GENERAL DESCRIPTION

Under the MATS Rule, the coal-fired boilers – Units 2 and 3 – at Wagner are subject to the emission limit for hydrogen chloride (HCl): 0.002 lb/MMBtu or 0.02 lb/MWh. Units 2 and 3 must be in compliance with this standard on April 16, 2015. These units have historically fired

ZEPHYR ENVIRONMENTAL CORPORATION 48

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

bituminous coals, which have associated HCl emissions that do not meet the MATS HCl limit. Wagner is co-located with Raven’s Brandon Shores Generating Station, which has a wet scrubber that removes HCl to levels well below the MATS limit. Under the MATS rule, Wagner’s HCl emissions can be averaged with Brandon Shores units to comply. However, even with averaging Wagner will require lower HCl emissions to comply with the MATS.

Testing of the DSI technology has been performed at Wagner to characterize the potential effectiveness, as well as associated environmental impacts that may result from construction and operation of the system. This testing was conducted in August 2011 and September 2012,

and has been deemed a technically feasible option for HCl (and SO2) emissions control. Based on those tests, specifications were developed and served as the basis for various designs and bids by vendors. A final vendor/design selection has yet to be made; therefore, the potential project impacts have been evaluated based on the highest potential emissions from the potential designs.

The use of subbituminous coal, including Indonesian Adaro coal, has also been evaluated at Wagner due to its lower chlorine content and associated lower HCl emissions. Testing of subbituminous coal firing in Wagner Units 2 and 3 was conducted in May 2007 and June 2009.

One benefit common to both DSI and subbituminous coal burning is the sulfur dioxide (SO2) emissions reduction. The Applicant seeks a CPCN to 1) install a DSI system for reducing acid gas emissions from Unit 2 and/or Unit 3, and 2) use subbituminous coal for up to 100% of the fuel needs (including blending with bituminous coals) for Unit 2 and/or Unit 3. Environmental impacts of each these projects have been evaluated and the impact from each project have been presented herein separately. However, another potential future operating scenario could involve the DSI system in operation concurrently with subbituminous coal burning. In this case Raven anticipates that the lower chlorine levels in that coal would result in lower sorbent injection levels resulting in lower PM emissions (associated with sorbent handling) than the DSI- bituminous coal project scenario. Therefore, the impacts described herein for the two separate projects are representative of worst-case impacts

3.2 DSI SYSTEM: PROJECT DESIGN AND OPERATIONAL FEATURES

3.2.1 Process Description

The sorbent under consideration for the DSI system, hydrated lime, also referenced as calcium

hydroxide [Ca(OH)2], is a common, non-hazardous, alkaline compound. An example Material Safety Data Sheet for the hydrated lime to be used at Wagner is included in Appendix A. It should be noted that Wagner, when owned by Constellation Power Source Generation, conducted tests of a DSI system using hydrated lime for Unit 2 in August 2011 and Unit 3 in September 2012.

Engineering diagrams for DSI equipment are provided in Appendix B. Note that these diagrams are representative of typical equipment expected to be installed at Wagner. A description of the sorbent handling and injection process is as follows:

ZEPHYR ENVIRONMENTAL CORPORATION 49

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

For each unit, hydrated lime will be delivered to Wagner by tank truck and transferred pneumatically from the truck to the storage silos via a truck-mounted blower. The Wagner DSI system will consist of two dedicated storage silos for each unit for a total of four silos. The maximum capacity of the silos for Unit 2 will be 150 tons and the maximum capacity of the silos for Unit 3 will be 300 tons.

From the silo, the hydrated lime will be gravity fed into a loss-of-weight hopper to measure flow.

From the hopper, the hydrated lime is pneumatically conveyed to the injection lances located in the air heater outlet duct on each unit.

The sorbent is distributed into the flue gases in the duct by the lances with a maximum injection rate of 4.6 tons/hr and 10 tons/hr for Unit 2 and 3, respectively. Based on projected operations and these injection rates, Wagner could use up to 70,000 tons of sorbent per year

If needed, Wagner will install an optional stationary mixing device in the duct to improve mixing and contact between the sorbent and the acid gases. This contact allows for the absorption of the acid gases into the sorbent particles.

The sorbent with the absorbed/reacted acid gases then arrive at the electrostatic precipitator (ESP) where the sorbent particles are removed along with the fly ash, and forwarded to the ash silos using the existing ash handling systems.

PM emissions will be generated as a result of the material handling of the incoming sorbent and the fly ash/reacted sorbent mixture. Sorbent handling-based PM emissions include that generated by the transfer of the sorbent from the truck to the storage silos. Each silo will be equipped with a bin vent filter for efficient control of emissions generated by the transfer operation. PM emissions from the handling of fly ash/reacted sorbent will be generated by the pneumatic transfer of the mixture from the ESPs to the ash silos and from the ash silos into the ash trucks. In general, fugitive particulate emissions from material handling systems will be minimized by equipment design, operating procedures, and existing controls.

The use of DSI will have no effect on the electrical generation capacity [megawatts (MW)] or the annual amount of electricity generated (MW-hr) at Wagner. This also correlates to the fact that the use of DSI will have no effect on the short-term heat input or the annual quantity of coal to be burned (and electrical generation) relative to what the units have been capable of achieving in the past

3.2.2 Site Layout

The DSI system equipment will be located completely within the station property boundaries on the west side of the main boiler building. A depiction of the equipment layout relative to existing structures and landmarks (e.g., plant roads) at Wagner is shown in Appendix C.

ZEPHYR ENVIRONMENTAL CORPORATION 50

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

3.2.3 Air Emissions and Controls

It has been demonstrated through testing that sorbents, such as hydrated lime, when injected into the flue gas stream, can effectively remove HCl from the flue gas. The removal efficiency will vary with the injection rate and the sorbent injected, but generally, it is anticipated that HCl removal efficiencies of 90 percent will occur.

With the possible exception of PM, emissions of regulated air pollutants from the boiler stacks should not increase because the sorbent will be injected downstream of the boilers (which does

not affect combustion). In fact, the DSI will help to reduce emissions of SO2 and acid gases in

general (e.g., H2SO4). The injection of sorbent will not result in an increase in carbon dioxide (CO2), as hydrated lime does not contain carbonates, which can break down to form CO2.

There will be a small increase in PM emissions at Wagner as a result of the handling of the sorbent. PM emissions from these material handling systems will be minimized by equipment design, operating procedures, and emission controls. Material transfers through the system will be conducted pneumatically, and the storage silos will be equipped with efficient dust collectors. The projected increase in PM emissions associated with sorbent handling and storage are below levels that trigger NSR (i.e., the DSI system does not constitute a “major modification” to Wagner). Section 5.1.2 provides more detail on the estimated emissions.

No PM emissions increase from the boiler stacks is expected. The Wagner ESPs are oversized with large specific collection areas for high efficiency PM removal. Also, with sorbent injection, condensable PM emissions from the boiler stack should decrease due to acid gas emission reductions. Finally, actual PM stack tests and opacity measurements performed in conjunction with testing of a DSI system with hydrated lime at Wagner in September 2012 showed no increase in PM emissions from the boiler stacks with sorbent injection.

3.2.4 Water Use and Wastewater Effluents

The storage, handling and use of sorbent will not involve water use or wastewater generation; therefore, no impact on Wagner’s wastewater effluent is expected.

3.2.5 Onsite Drainage

As required by the Wagner plant’s National Pollutant Discharge Elimination System (NPDES) permit, the plant currently employs best management practices (BMPs) to mitigate the release of pollutants in storm water. BMPs are defined in a storm water pollution prevention plan (SWPPP). In general, storm water from industrial areas of the plant is managed using inlet protection and diversion to control, prevent and/or reduce pollutant transport from industrial materials and activities to the storm water system. These areas include all areas where sorbent will be stored and handled. Other BMPs for specific tasks and areas that involve industrial materials and activities are detailed in the SWPPP.

ZEPHYR ENVIRONMENTAL CORPORATION 51

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The storage, handling and use of sorbent will not affect current storm water drainage and pollutant loadings. No revision of the plant’s SWPPP will be required for sorbent storage, handling and use. A minor revision of the plant’s SWPPP may be required to address sorbent storage and handling equipment that is not contained within a storm-resistant shelter.

3.2.6 Solid and Hazardous Wastes

The use of DSI at Wagner will add sorbent material to boiler ash, resulting, by itself, in somewhat increased ash generation. The most ash generation will occur under a scenario where only bituminous coal is fired and DSI is used concurrently on a full-time basis. Under this scenario, the volume of ash could increase by up to approximately 70,000 tpy.

Changes in boiler ash quality due to sorbent usage may affect disposition of the ash. Ash that is not beneficially used as a product will be placed in Raven’s Fort Armistead Road – Lot 15 landfill, which only receives material from Raven facilities. There is sufficient landfill capacity to accommodate any portion of the ash that could not be beneficially used.

The use of sorbent at the Wagner plant will not result in the generation of any hazardous waste.

3.3 SUBBITUMINOUS COAL USE: PROJECT DESIGN AND OPERATIONAL FEATURES

In addition to seeking approval for a DSI system, the Applicant also is seeking approval to be able to burn subbituminous coal in blends (with bituminous coal) ranging from 0 to 100 percent subbituminous in Wagner Units 2 and 3. These units currently burn bituminous coals, generally from the central Appalachian (CAPP) region, with sulfur contents of 1% or less. Subbituminous coals have lower ash, nitrogen, sulfur and chlorine contents than CAPP coals. It is expected that the subbituminous coals will be sourced from either western locations in the United States (e.g., Powder River Basin (PRB) coal), or foreign countries (e.g., Indonesian Adaro coal).

The use of subbituminous coal firing at Wagner is aimed at reducing HCl (and to a lesser degree SO2 emissions) as part of an overall program to achieve compliance with the MATS. Although the HCl emissions from the burning of subbituminous coal is lower than from bituminous coal, it will likely require averaging with the emissions from the collocated Brandon Shores facility to comply with MATS.

For subbituminous coal use, no modifications to the two boilers will be made. Although, due to the lower heat content of the subbituminous coal, there may be a slightly lower heat input to the boilers, for the purpose of the environmental assessments, this application has, to add a conservative degree of safety to the analysis, assumed that the boilers will not be de-rated as a result of this project. Modifications planned for the coal handling system are ancillary and intended only to address critical safety concerns associated with subbituminous coal (see coal characteristic section below). Such modifications include:

ZEPHYR ENVIRONMENTAL CORPORATION 52

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

Restoring/making improvements to existing water spray system and dust extraction system for dust suppression (for safety reasons); Restore coal mill inerting systems; Install carbon monoxide (CO) monitoring systems in reclaim tunnel and ash silo; Install fire protection in coal bunkers; and Upgrading electrical devices for use in wet (wash-down) areas.

3.3.1 Subbituminous Coal Characteristics

Wagner currently burns almost exclusively domestic medium-sulfur, low-fusion Central Appalachian bituminous coal. The average specifications of the coal now burned at the plant are approximately 12,168 Btu/lb, 12 percent ash, 0.8 percent sulfur, and 7 percent moisture (see Appendix D). A comparison of approximate characteristics of current bituminous coal and the subbituminous coals (PRB and Adaro) under consideration is as follows:

Coal Characteristic Central Appalachian Subbituminous Coals Bituminous Coal Total Moisture (%) 5.5 – 8.0 17 – 29 Sulfur Content (%) 0.6 – 1.0 0.05 – 0.5 Heat Content (Btu/lb) 11,800 – 12,700 8,600 – 10,600 Ash Content (%) 11.5 – 12.5 0.8 – 7.2

As shown in the comparison of coal specifications above, subbituminous coal typically has lower sulfur and ash content and heat content, while having a higher moisture content than bituminous

coal. The lower sulfur content for subbituminous coal results in lower SO2 emissions, compared to bituminous coal, when the coals are combusted. The lower ash content for subbituminous coal results in lower particulate matter generation (fly ash as well as bottom ash generation), compared to bituminous coal, when the coals are combusted. Furthermore, the lower sulfur content level for subbituminous coal also results in less sulfate compounds formed, i.e., less condensable particulate matter (CPM) emissions. Note that the higher moisture content of subbituminous coal means there could be an associated higher exhaust flow rate.

As described above, the lower heat content of subbituminous coal means a greater quantity of that coal must be burned to achieve the same power generation. The average heat content of bituminous coal currently burned at Wagner is approximately 27 percent higher than that for subbituminous Adaro coal (with an average heat content of 9,564 Btu/lb). Based on previous testing, Raven thinks there is only approximately 20% additional coal feed capacity that can be achieved with the sub-bituminous coal in both Unit 2 and Unit 3. Therefore, depending on the actual coal characteristics, these units might experience a minor derate.

The moisture content of the coal is an important parameter in the estimating PM emissions associated with fugitive dust generation from coal handling. The standard EPA emission factor typically used to estimate emissions for coal transfers is inversely proportional to the coal moisture content. For existing bituminous coals a value of 6 percent moisture coal was utilized in the EPA emission factor-based emissions calculation. Although subbituminous coals are

ZEPHYR ENVIRONMENTAL CORPORATION 53

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

listed with moisture content up to 29 percent, this is primarily bound moisture in the coal matrix that does not affect dust generated from handling. A conservative unbound moisture content of 4 percent, based on information provided in EPA’s AP-42 Table 13.2.4-1 (coal-fired power plant, as-received coal) was utilized to develop the PM emission factors for subbituminous coal handling. This level of moisture content is consistent with coal moisture contents shown in AP- 42 Section 11.9 – Western Surface Coal Mining. This lower moisture content for subbituminous coal yields a higher PM emission factor for estimating PM emissions from coal handling, compared to that for bituminous coal handling. While there may be greater dust generation for the subbituminous coals, the use of previously installed dust suppression sprays and dust extraction systems at certain transfer points should result in PM emissions comparable to that for bituminous coal.

3.3.2 Process Description

Due to subbituminous coals having a lower heat content and higher bound moisture content, a higher quantity of subbituminous coal (tons/hr) compared to CAPP bituminous coal must be fed to the boiler to maintain the same heat input (MMBtu/hr), and a higher exhaust flow rate (lbs/hr or scfm) will be generated. During past test burns of subbituminous coals at Wagner, the coal feeders and induced draft (ID) fans demonstrated that they have additional margin to allow greater throughput.

The coal feeders, which for bituminous coal typically run with short-term feed rates around 60 tons/hr in Unit 2 and 120 tons/hr in Unit 3, are capable of accommodating approximately 20 percent higher short-term boiler feed rates without any changes. For subbituminous coals, the boilers are anticipated to burn approximately 72 and 144 tons/hr maximums for Units 2 and 3, respectively, which is within the capacity of the coal feeders.

The annual total heat input “baseline” for Units 2 and 3 has been established as 20,746,586 MMBtu/hr based on the bituminous coal use for the 2009-2010 period (see Section 5.1.1.1). Because the use of subbituminous coal does not fundamentally increase the projected short- term or annual electricity generation from these units, projected annual total subbituminous coal usage in this evaluation for Units 2 and 3 has been set to be equivalent to the baseline heat input when using bituminous coal.

As described earlier, subbituminous coal has a greater moisture content than bituminous coal. Bound water in coal acts as an inert gas in the boiler and adds mass to the combustion gases in the boiler exhaust. Similar to the coal feeders, the ID fans on Units 2 and 3 have available margin in their design air flows, which will allow the unit to carry additional flue gas, as compared to bituminous coal burning. Similar to the coal feeding limitations, the flue gas exhaust system may ultimately limit total heat input and electrical generation to slightly below current capacity. But, for the purposes of this evaluation, it has conservatively assumed the heat input will be the same as for bituminous coals.

ZEPHYR ENVIRONMENTAL CORPORATION 54

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

As mentioned above, the dust suppressant spray systems previously installed at certain coal transfer points will be placed in use when sub-bituminous coal is handled. The specific locations of these improvements are as follows: At the Belt 1 to Belt 2 transfer (barge unloader system); At the Belt 2 to Belt 3 transfer in Transfer Building 1; At the transfer from the vibratory feeders to MC Belt (coal reclaim system); and At the Belt D to Belt F transfer in Transfer Tower 1.

Additionally, the two Engart dust extraction systems previously installed on each of the Unit 2 and Unit 3 bunker rooms will also be used for all sub-bituminous coal handling. The need for the spray systems and Engart systems is dictated by safety reasons, i.e., to minimize dust generation inside areas with a potential for explosions/fires.

3.3.3 Site Layout

An overall facility layout, including the existing coal pile area and coal handling equipment (e.g., conveyors) is provided in Appendix C.

3.3.4 Air Emissions and Controls

Combustion of subbituminous coal is expected to reduce emissions of HCl, SO2, NOx, and PM (and subsequently CPM) from the Unit 2 and 3 boilers as part of an overall program to achieve compliance with the MATS, while providing further flexibility for maintaining compliance with the

HAA. The boilers’ emissions of CO, VOC, and CO2 are projected to increase, but not to levels that trigger NSR (i.e., the Project is not a “major modification”). Section 5.1.1 provides more detail on the estimated emissions.

There will be no increase in PM emissions at Wagner as a result of the handling and storage of subbituminous coal. PM emissions from these material handling systems will be reduced by equipment design, operating procedures, and dust suppressant spray controls. All coal transfer points are (and will continue to be) at least partially enclosed. The existing water spray systems on certain coal conveyor transfer points will be used for safety reasons when subbituminous coal is being conveyed. Fugitive dust emissions from wind erosion of the subbituminous coal pile will be minimized via good coal pile management and by periodic application of a latex polymer-based dust suppressant/sealant. Section 5.1.1 provides more detail on the estimated emissions.

3.3.5 Water Use and Wastewater Effluents

Subbituminous coal storage piles will be sprayed with a latex polymer dust suppressant emulsion to minimize exposure of coal to precipitation. The as-received emulsion may be diluted with water during application. The quantity of any water used to dilute the emulsion is expected to be insignificant [less than 1,000 gallons per day (gpd) on average]. No additional wastewater will be generated.

ZEPHYR ENVIRONMENTAL CORPORATION 55

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

A water spray system will be employed at certain enclosed coal conveyor transfer points. The use of water sprays when handling subbituminous coal could increase water use by up to approximately 23,400 gpd. The water spray applied to coal in the enclosed transfer areas will remain on the coal, and no additional wastewater will be generated.

The use of subbituminous coal will require periodic equipment wash-downs at an estimated rate of approximately 15,000 gpd. The associated additional wastewater generation will be directed to and handled by the existing WWTP.

3.3.6 Onsite Drainage

As required by the Wagner plant’s National Pollutant Discharge Elimination System (NPDES) permit, the plant currently employs best management practices (BMPs) to mitigate the release of pollutants in storm water. BMPs are defined in a storm water pollution prevention plan (SWPPP). In general, storm water from industrial areas of the plant is managed using inlet protection and diversion to control, prevent and/or reduce pollutant transport from industrial materials and activities to the storm water system. These areas include any areas where subbituminous coal will be stored and handled. Other BMPs for specific tasks and areas that involve industrial materials and activities are detailed in the SWPPP.

The storage, handling and use of subbituminous coal will not affect current storm water drainage and pollutant loadings. No revision of the plant’s SWPPP will be required for subbituminous coal storage, handling and use because these activities are already adequately addressed in the current SWPPP. Wagner will assess and comply with any requirements related to dust suppressant spraying of the subbituminous coal pile (e.g., NPDES permit conditions).

3.3.7 Solid and Hazardous Wastes

The use of subbituminous coal will cause a reduction in generation of boiler ash because subbituminous coal contains less ash per unit of heat input than bituminous coal. Ash disposition will depend on the characteristics of the ash from the particular subbituminous coal burned. Wagner desires to beneficially use as much ash as possible. However, if the ash does not meet required specifications, it will be placed in Raven’s Fort Armistead Road – Lot 15 landfill, which receives material from Raven facilities only. The use of subbituminous coal will not result in the generation of any hazardous waste.

Although not currently planned, sorbent could be injected, when burning subbituminous coals, too. As described in Section 3.2.6, the use of dry sorbent injection will cause an increase in generation of boiler ash because injected sorbent material will exit the system in boiler ash. Net change in boiler ash generation volume will depend on subbituminous coal usage and dry sorbent injection rates. Under such an operating scenario, it is not anticipated that boiler ash generation volume will change significantly from current ash generation volume.

ZEPHYR ENVIRONMENTAL CORPORATION 56

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

3.4 PROJECT SCHEDULE

Project construction and final engineering for the DSI system is planned to begin around July 2014, with the construction activities requiring approximately 8 months to complete. Based on this schedule, the DSI system would initiate operations by the April 2015 MATS compliance date.

If the use of subbituminous coal is selected as the initial MATS compliance option, Raven plans to start on-site storage of Adaro coal in approximately October 2014, with subsequent graduated use of subbituminous coal (as needed for compliance with the MATS).

3.5 RATIONALE FOR SITE SELECTION AND PROJECT CONCEPTUAL DESIGN

The coal-fired units at Wagner are mandated to maintain emissions of certain air pollutants, HCl in particular, within specified limits in accordance with the MATS. The proposed projects will facilitate compliance.

3.6 IMPACT ON STATE ECONOMICS

The DSI system installation will involve a capital investment of approximately $22 million at Wagner, providing a small, positive economic impact to the area during construction. There will also be a small additional positive economic impact from the purchase and transportation of the dry sorbent to Wagner.

The use of subbituminous coal at Wagner, as described in this application, will have minimal capital requirement.

To the extent the Projects can be assumed to have an impact on the PJM market price of electricity or on the retail price of electricity paid by consumers, it will be a beneficial impact because, in the absence of the Projects, it is expected that the operation of the units would be curtailed or the units would be retired. (As discussed earlier, the Project is needed for MATS compliance.)

3.7 PROJECT EFFECT ON ELECTRIC SYSTEM STABILITY AND RELIABILITY

The DSI and subbituminous coal use at Wagner, as described in this application, will facilitate the impacted units’ compliance with environmental requirements, enabling their continued operation. For this reason, the Projects have a positive impact on the stability and reliability of the electric system, by maintaining a higher level of overall capacity and available supply in the region.

ZEPHYR ENVIRONMENTAL CORPORATION 57

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

3.8 FEATURES OF REQUIRED ELECTRIC SYSTEM UPGRADES

The DSI and subbituminous coal use at Wagner, as described in this application, will require no electric system upgrades.

ZEPHYR ENVIRONMENTAL CORPORATION 58

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

REFERENCES Code of Maryland Regulations (COMAR). 2013. www.dsd.state.md.us/comar

ZEPHYR ENVIRONMENTAL CORPORATION 59

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

4.0 EFFECTS OF SITE PREPARATION AND PROJECT CONSTRUCTION

4.1 IMPACTS ON AIR QUALITY

Construction-related activities will temporarily generate air emissions off and on during construction of the DSI system, which will span a period of approximately 8 months. The quantity of any emissions released during the construction process will generally be low, but will vary due to weather conditions and on an hourly and daily basis as construction progresses. As described above, the DSI system mainly involves the installation of four new silos, weigh hoppers, four pneumatic blowers, piping to the injection lances, electrical control systems and associated shelter. Construction equipment needed for this installation is typical of this small- scale project and will include items such as: backhoes, concrete delivery trucks, dump trucks, equipment delivery vehicles and cranes. The use of subbituminous coal will not involve construction of new equipment.

Site preparation and vehicle movement will generate fugitive dust emissions. Fugitive dust emissions are typically greater during the site preparation phase of a project, although, in this case, given that the construction activities will occur within an existing, developed power plant site, little site preparation should be required. The area around the new silo, hopper and blowers is all paved. The only disturbance of soils will be when foundations and slabs are installed into/over the existing pavement. Fugitive dust emissions will also be greater during the more active construction periods as a result of increased vehicle traffic on the site. Of course, all construction-related fugitive dust emissions will be temporary and will stop once construction is completed.

There will be a small increase in emissions from internal combustion engines temporarily during site preparation and project construction for the DSI system (and almost no change for the subbituminous coal project). Internal combustion engines will release NOx, VOC, CO, and other combustion products. The increase will be small because the scope of construction is small.

Finally, construction worker travel to the site will result in vehicular emissions. While not readily quantifiable, the temporary net changes in vehicle-miles traveled in the greater Baltimore area would be insignificant, as would any temporary net changes in regional vehicular emissions.

The air quality impacts caused by construction activity will vary as a function of the level of activity, the specific nature of the activity, and the weather conditions while the activity is occurring. However, the air quality impacts caused by construction emissions are expected to be small, temporary, and limited to the immediate area of the site under construction. For these reasons, any potential emissions are not anticipated to have a significant adverse impact on regional air quality.

ZEPHYR ENVIRONMENTAL CORPORATION 60

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

4.2 IMPACTS ON GROUNDWATER

Impacts to groundwater during project construction will be limited to percolation of storm water and possible dewatering of excavations for foundations. There will be no direct discharges to groundwater as part of construction activities. A limited amount of dewatering may temporarily be required during the excavation of some foundations. Any impacts to groundwater are expected to be insignificant.

Construction materials, fuels, waste and debris will be stored and handled in a manner that will not create an environmental or safety hazard, and will prevent the release of untreated chemical constituents to site soil, surface water and groundwater. Any such handling and storage will comply with applicable environmental regulations, such as spill prevention, control and countermeasures (SPCC) procedures and storm water pollution prevention plan (SWPPP) procedures.

4.3 IMPACTS ON SURFACE WATER

Plant areas that will be impacted by construction will be minimal. Surface runoff and drainage from project construction and lay-down areas will be controlled using existing systems supplemented, if needed, by approved SWM systems (e.g., straw bales, silt fencing, portable sediment tanks, sandbags) designed and permitted in accordance with applicable soil conservation regulations. Storm water and excavation de-watering discharges to surface water will comply with applicable requirements in environmental permits and regulations.

As noted in Section 4.2, construction materials, fuels, waste and debris will be handled and stored in a manner that complies with applicable environmental regulations and prevents the release of untreated chemical constituents to soil, surface water and groundwater.

If required, detailed erosion and sediment control plans will be prepared in accordance with Anne Arundel County storm water and sediment control requirements. These plans will form the basis for ensuring adequate protection of surface waters during construction.

Some construction activity could take place within the 100-year floodplain (see Figure 2-16). If applicable, these activities will comply with local ordinances.

Given plans to properly handle excavated soils and any water from excavation de-watering, and utilize established storm water quantity and quality controls as well as SPCC procedures, no significant impacts on surface waters resulting from project construction will occur.

4.4 ECOLOGICAL IMPACTS

The Project will involve the construction and installation of several new structures, including a building, piping, pneumatic blowers and storage silos. All of the proposed construction activities are expected to take place within developed or previously impacted areas of Wagner property,

ZEPHYR ENVIRONMENTAL CORPORATION 61

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

specifically within the paved area west of the boiler house. Construction laydown and parking areas are also expected to be located on previously developed areas. Raven does not anticipate or plan any tree removal or any vegetation clearing or alteration for the construction of the Project. Thus, there are no construction-related impacts expected to onsite natural vegetation communities. No state or federally listed plants are present onsite, nor anticipated to occur, due to lack of suitable habitat.

Potential secondary impacts resulting from sediment erosion and storm water runoff will be managed by the Wagner plant’s BMPs, which are detailed in the SWPPP. The planned new equipment associated with the Project will be constructed within the existing paved area west of the boiler house. This area’s drainage is already addressed in the SWPPP; storm water is collected and sent through wastewater treatment for sediment control. The SWPPP and BMPs will be revised as necessary for the new equipment and associated materials.

Because all project construction activities will be within the existing paved and developed areas of the plant, there will be no impact on local wildlife resources. There are no listed or sensitive species within or adjacent to the Wagner site boundaries (see Figure 2-19). Similarly, there is no FIDS habitat present on or in the vicinity of the site (see Figure 2-20), thus no impacts to FIDS species are anticipated from project construction.

Project construction will not directly impact any aquatic habitats. No construction activity will take place within or near Cox Creek or the Patapsco River. No direct impacts to these water bodies will result from construction of the project equipment and facilities. As discussed above potential secondary impacts such as sedimentation and storm water runoff will be controlled to the extent possible using revised BMPs which will be incorporated into the Wagner plant SWPPP.

In summary, the construction of the Project will take place on a developed parcel of land that has housed an operational power plant since the 1950s. No natural communities will be cleared for the Project, and, therefore, no direct impacts to natural communities will result. There could be temporary impacts to wildlife species inhabiting adjacent areas during the construction process due to human presence and noise. These disturbances will exist only for the duration of construction and should have no long-term effect on the wildlife community.

4.5 NOISE IMPACTS

MDE has established a state noise regulation (COMAR 26.02.03.02) that sets maximum allowable sound levels (with a few exceptions as discussed in this section). Table 4-1 summarizes these limits.

Table 4-1. Maximum Allowable Noise Levels (dBA) for Various Land Use Categories Day/Night Industrial Commercial Residential Day 75 67 65 Night 75 62 55 COMAR 26.02.03.02B, Table 1

ZEPHYR ENVIRONMENTAL CORPORATION 62

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The regulation also prohibits the creation of prominent discrete tones. These limits do not apply to motor vehicle traffic on public roads, or to pile-driving activity during the daytime hours of 8 a.m. to 5 p.m. Noise from construction activities cannot exceed 90 dBA during daytime hours (i.e., 7 a.m. and 10 p.m.). Noise from construction activities during nighttime hours (i.e., 10 p.m. to 7 a.m.) cannot exceed the levels in Table 4-1.

The sound levels resulting from construction activities vary greatly depending on such factors as the operations being performed and the type of equipment being employed. Variations in the noise levels during operation of the construction equipment and changes in construction phases and equipment mix make the prediction of potential noise impacts even more challenging. Most of the time, noise generated by project construction activities will be screened by existing plant structures, surrounding property trees and vegetation, and/or masked by noise from other manmade activities, including ongoing power plant operations. Noise from project construction activities from 7 a.m. to 10 p.m. will comply with the state noise regulation daytime limit of 90 dBA for construction activities. Construction activities are not expected to be scheduled during nighttime hours. At locations more distant from the project construction activities, the noticeable sound will be less since sound levels decrease with distance from the source.

4.6 SOCIOECONOMIC AND LAND USE IMPACTS

This section summarizes the impacts to the local economy, land use, public services and facilities, and cultural resources associated with site preparation, construction, and operation of the Project. In addition, this section describes visual impacts to surrounding uses.

Overall, the construction of the Project is expected to have positive—albeit small— socioeconomic impacts, particularly from the creation of temporary local construction jobs. The entire project will be on an existing industrial site and, therefore, will not displace any residential property.

4.6.1 Socioeconomic Impacts

The Project is expected to have a small, but positive impact on local businesses and the local economy as a whole during construction. Local businesses will likely benefit by servicing Raven’s needs and those of its contractors during construction. Purchases of a wide variety of services and supplies such as concrete, aggregate, conduit, building supplies, and tools are likely to be obtained locally, whenever available.

Project construction will also generate a small amount of tax revenue for the state from retail sales tax on expenditures by workers. Local government tax revenues during construction will primarily accrue from permitting and impact fees.

As further described in Section 4.6.3, no significant impacts on any public services and facilities are expected to be required as a result of or to support construction. Further, it is currently

ZEPHYR ENVIRONMENTAL CORPORATION 63

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION expected that no state or local expenditures will be required to pay for any infrastructure improvements to support project construction.

4.6.2 Land Use Impacts

The Project should have almost no impact on land use since: (1) the plant site has been in use for electrical generation for many years, and (2) as described in Section 2.4, the site and its surroundings are either already mostly developed or are limited from much further development. Some minor short-term impacts due to typical construction activities, such as temporary increases in noise levels and/or traffic volumes, could be expected. These impacts would be consistent with any proposed construction effort.

4.6.3 Impacts on Public Services and Facilities

No significant impacts to public services and facilities are expected to occur during construction of the Project. The peak construction workforce is expected to reach approximately 25-30 employees from in and around the metropolitan area. Given the relatively small workforce, impacts to local public services and facilities are expected to be minimal during the brief construction period. The selected contractor(s) will coordinate any special needs with local and other regional agencies and facilities as needed.

The anticipated construction-related traffic will constitute an insignificant addition to the existing volumes on the metro and local roadway network. The Wagner plant is located in relatively close proximity to major roadways, including Fort Smallwood Road and I-695. The modest increase in traffic on Fort Smallwood Road, which is a divided four-lane road, should not be noticeable during construction. And any construction-related traffic impacts will be modest and temporary.

Project construction is expected to generate relatively small amounts of construction debris and solid waste. As the volume of solid wastes generated during construction is expected to be insignificant in comparison to this available regional disposal capacity, no significant impacts are expected to result to existing solid waste facilities as a result of project construction.

The majority of construction employees are expected to be from the metro area, and construction will require 6 - 8 months. Therefore, there will be little to no increase in the number of people permanently living or working in the vicinity of the Wagner plant that will occur as a result of the construction of the Project. With no direct project services required except as previously described, and minimal to no increase in local population expected during construction, negligible impacts on police, education, fire, medical, social, and/or community services are expected.

ZEPHYR ENVIRONMENTAL CORPORATION 64

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

4.6.4 Impacts on Cultural Resources

As discussed in Section 2.3, no historical structures or archaeological sites exist on or in the immediate vicinity of the plant site. Because the Project will be constructed and located within the Wagner plant boundaries, no impact on cultural resources would be expected as a result of construction activities.

4.6.5 Impacts on Chesapeake Bay Critical Area (CBCA)

The proposed DSI project location will be at the existing paved area on the west side of the boiler house the Wagner Generation Station, which is within the CBCA IDA. As discussed in Section 2.4, criteria set forth in the CBCA Law require that any development or redevelopment within an IDA be accompanied by practices to reduce water quality impacts associated with storm water runoff. Furthermore, these practices must be capable of reducing storm water pollutant loadings from a development site to a level at least 10 percent below the load generated by the same site prior to development. Because the proposed project will be located within a previously disturbed and currently active area of the site, the direct land impact from project construction is expected to be minimal. The Applicant will consult and coordinate with Anne Arundel County officials (e.g., Anne Arundel County Office of Planning and Zoning) as to their expectations for compliance with the CBCA Law.

4.6.6 Visual Impacts

During construction, construction equipment, including cranes, will be operating onsite. Views into the project site from the west and south are obstructed to a great degree from most locations by existing structures and vegetation. From other vantage points (e.g., from the water), existing power plant structures (including those at adjacent Brandon Shores) create a visual character that is primarily industrial in nature, with its multiple boiler houses, exhaust stacks, and coal handling and storage facilities.

This construction equipment and the structures being constructed will, nonetheless, be visible from some limited vantage points around the area. All visual impacts anticipated during construction will be temporary and are considered consistent with industrial development and not incompatible with the surrounding uses. Overall, given the screening of the site by vegetation and existing structures, construction activities will have little to no discernible visual impacts, particularly on existing residences.

ZEPHYR ENVIRONMENTAL CORPORATION 65

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

REFERENCES Code of Maryland Regulations (COMAR). 2013. www.dsd.state.md.us/comar

ZEPHYR ENVIRONMENTAL CORPORATION 66

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

5.0 EFFECTS OF PROJECT OPERATION

5.1 IMPACTS ON AIR QUALITY

This section presents air emissions estimates for the Project and the analyses of the emissions potentially subject to air quality regulations. The Project’s purpose is to benefit air quality consistent with regulatory requirements, and the Project will have no substantial adverse impacts on air quality. The primary air quality effects of the Project are decreases in boiler emissions of certain air pollutants, HCl and SO2 in particular. The Project is divided into two parts: the use of DSI with bituminous coal and the use of subbituminous coal. The impacts associated with operation of each part of the Project are described in separate sections below, as some of these impacts are greatest for one or the other part alone. As shown in Section 5.1.3, a regulatory assessment was conducted for each part of the Project individually, as applicable, as well as the combined operation of both parts.

The MDE requires that a PTC application be submitted for a modification to an existing facility (that does not meet MDE’s permit exemption criteria). Completed MDE PTC application forms for the Project are provided in Appendix F. As described in this application, the Project will be constructed and operated in accordance with all applicable federal and state air quality regulations and laws.

5.1.1 Emissions Estimates for Subbituminous Coal Use

5.1.1.1 Boiler Combustion Emissions

Raven does not project any change in the short-term or annual electricity generation from Units 2 and 3 as a result of the combustion of subbituminous coal, whether by itself or in blends with bituminous coal. The annual generation (and capacity factor) for these units is predominantly determined by the market demand, and the addition of DSI and/or use of subbituminous coal will not increase the units’ generating potential or the market demand. If anything, additional costs borne by the units under either scenario have the potential to decrease annual generation. But, for this analysis, Raven assumed the projected generation to be the same as the representative generation using bituminous coal (i.e., “baseline”).

An analysis was conducted of recent Wagner operations on bituminous coal to determine a representative annual heat input total for Units 2 and 3 for future operations under full-time firing of subbituminous coal. A review of annual coal throughputs for the 2009 through 2013 period for Units 2 and 3 combined shows that the highest average 2-year period throughput occurred in the 2009-2010 period. The average annual bituminous coal throughput total for Units 2 and 3 for that period was 852,527 tpy. Based on an assumed heat content of 12,168 Btu/lb for bituminous coal used at Wagner, the calculated annual heat input for the 2009-2010 period was 20,746,586 MMBtu/yr. [The actual analysis includes only the data for the 2009 through 2012 period, as a complete year of data for 2013 is not yet available; however, based on available coal throughput data for 2013 (January through November), total coal throughput for Units 2 and

ZEPHYR ENVIRONMENTAL CORPORATION 67

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

3 will be no higher than the total coal throughput for 2011 (and the total coal throughput for 2011 was lower than the totals for 2009 and 2010).]

The projected annual future subbituminous coal use (and associated emissions) for Units 2 and 3 is based on the maximum annual heat input discussed in the previous paragraph. Due to variability of fuel characteristics, an assumed low heat content for subbituminous coal of 8,750 Btu/lb (that of PRB) has been applied to estimate a conservatively high subbituminous coal throughput. The use of this low heat content and the assumed future maximum annual heat input yields an annual coal throughput of 1,185,465 tpy.

5.1.1.1.1 PM, NOx, and SO2 Emissions

Based on an evaluation of coal sample laboratory analysis data for bituminous coal used at Wagner and subbituminous coals – PRB and Adaro – under consideration, subbituminous coal

burning in Units 2 and 3 will result in a reduction in emissions of PM, NOx, and SO2 compared with that for bituminous coal burning. A review of the data shown in Table 5-1 shows that for

the same boiler heat input, emissions of PM (based on ash content analysis), NOx (based on nitrogen content analysis), and SO2 (based on sulfur content analysis) will decrease with subbituminous coal burning. And, the burning of Adaro coal results in the greatest emissions decreases for these pollutants. The supporting analysis of coal sample data for each coal type is provided in Appendix D.

Table 5-1. Comparison of Ash, Nitrogen, and Sulfur Contents on a lb/MMBtu basis for Bituminous and Subbituminous Coals Coal Type Mass Content (lb/MMBtu) Ash Nitrogen Sulfur Bituminous 9.746 0.986 0.657 Subbituminous-PRB 5.572 0.800 0.240 Subbituminous-Adaro 2.136 0.764 0.126 Comparison Ratios PRB:Bituminous 0.572 0.811 0.365 Adaro:Bituminous 0.219 0.774 0.192

The NOx emission rate for coal combustion is a function of fuel (coal) nitrogen content and thermal NOx from the oxidation of nitrogen in the air. As noted by EPA in AP-42 (Section

1.1.3.3), fuel nitrogen can account for up to 80 percent of total NOx from coal combustion; i.e.,

NOx emissions from the boilers are primarily a function of fuel nitrogen content. Therefore, Raven assumes that the significant decrease in fuel nitrogen content associated with a use of

subbituminous coal burning is the primary factor in concluding that NOx emissions also will decrease.

Based on the annual average emission rates for the 2009-2010 period (from the 2009 and 2010 Emission Certification Reports for Wagner), the annual average heat input for the same period (20,746,586 MMBtu/yr), and the PRB:bituminous ratios shown in Table 5-1, the estimated changes (reductions) in the annual PM(TSP), PM10, PM2.5, NO2 and SO2 emissions associated

ZEPHYR ENVIRONMENTAL CORPORATION 68

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

with the use of subbituminous coal in Units 2 and 3 are -46, -31, -14, -290, and -7,658 tpy, respectively. These PM emission changes address filterable PM changes only, and do not account for changes in CPM emissions. However, CPM emissions also would be expected to decrease with the use of subbituminous coal, especially given the significant decrease in associated sulfur compound emissions, including sulfates (which make up the majority of CPM emissions from coal-fired boilers).

5.1.1.1.2 CO and VOC Emissions

An assessment of potential changes in emissions for CO and VOC was conducted based on the bituminous and subbituminous coal throughputs associated with the future maximum annual heat input of 20,746,586 MMBtu/yr and AP-42 emission factors. AP-42 emission factors for CO and VOC are given in the form of lb of pollutant per ton of coal burned, and the same emission factor applies for both bituminous and subbituminous coals. Although these factors are an over- simplification of CO emission rates, since boiler configuration and air:fuel ratios really drive CO and VOC formation, these factors have been used to provide a measure of conservatism for this evaluation.

A summary of the emission changes associated with the use of subbituminous coal is shown in Table 5-2. Supporting calculations for the CO and VOC emissions changes are provided in Appendix E, Table E-1. Note that the calculated emissions increases are less than significant emissions increase thresholds for NSR (100 tpy for CO and 25 tpy for VOC).

Table 5-2. CO and VOC Emissions Comparison for Bituminous and Subbituminous Coals Pollutant Annual Emissions by Coal Type (tpy) Change in Bituminous Subbituminous Emissions (tpy) COa 213 296 +83 VOCb 26 36 +10 a Based on an emission factor of 0.5 lb CO/ton coal (AP-42, Table 1.1-3) b Based on an emission factor of 0.06 lb TNMOC/ton coal (AP-42, Table 1.1-19); TNMOC = Total non- methane organic compounds

5.1.1.1.3 CO2 Emissions

An assessment of the potential change in CO2 emissions was conducted based on lb/MMBtu emission factors developed for bituminous and subbituminous coal burning. The lb/MMBtu emission factor for subbituminous (PRB) coal burning was developed using mean heat input and CO2 emissions data for 2011 and 2012 from the EPA GHG Summary Reports for Raven’s C.P. Crane facility, which burns PRB. The lb/MMBtu emission factor for bituminous coal burning was developed using mean heat input and CO2 emissions data for 2011 and 2012 from the EPA GHG Summary Reports for Wagner. Both of those reports use actual emissions of CO2 measured by CEMS and actual heat inputs to the units.

ZEPHYR ENVIRONMENTAL CORPORATION 69

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The resulting analysis showed that the CO2 emission factor for subbituminous coal burning – 210.9 lb/MMBtu – is 2.25 percent higher than the average emission factor for bituminous coal burning – 206.2 lb/MMBtu. The 2.25 percent increase in the lb/MMBtu emission factor yields an increase in CO2 emissions, based on the maximum annual heat input of 20,746,586 MMBtu/yr, of 48,101 tpy for subbituminous coal burning. Supporting calculations for the CO2 emissions change are provided in Appendix E, Table E-2. Note that this calculated emissions increase is less than the significant emissions increase threshold of 75,000 tpy for NSR.

5.1.1.1.4 Acid Gases

Emissions, specifically emission factors, of the acid gases, HCl and hydrogen fluoride (HF), are based on the chloride and fluoride content and heat content of representative coal fuels. Emissions factors are calculated assuming that the ESP provides minimal control of the acid gases.

The chloride contents representative of the existing bituminous coal are based on Wagner coal sample data (see Appendix D). Because of the lack of fluoride measurements in the Wagner coal samples, the fluoride contents representative of the existing bituminous coal (Central Appalachian coal) are the average contents for bituminous coals in West Virginia and Kentucky given in Table 3-5 of EPA’s EPCRA Section 313 Industry Guidance – Electricity Generating Facilities (EPA 2000). The calculated emission factors for the existing bituminous coal (typical heat content of 12,168 Btu/lb) are 0.1234 lb/MMBtu and 0.0062 lb/MMBtu for HCl and HF, respectively.

The chloride and fluoride contents representative of the possible subbituminous coals (PRB and Adaro coals) were based on available, limited Wagner coal sample data and the contents for subbituminous coals in Wyoming, given in Table 3-5 of EPA’s EPCRA Section 313 Industry Guidance – Electricity Generating Facilities (EPA 2000), and for the subbituminous Adaro coal, Wagner coal sample data (from previous Adaro testing) and data provided by Adaro (i.e., typical specifications for Adaro Envirocoal). Emission factors are calculated for the PRB coal (typical heat content of 8,750 Btu/lb) and the Adaro coal (typical heat content of 9,564 Btu/lb), with the average factors being representative of possible subbituminous coals; namely, 0.0135 lb/MMBtu and 0.0040 lb/MMBtu for HCl and HF, respectively.

Emissions of acid gases are expected to decrease with the use of subbituminous coals. Assuming that the future annual total heat input rate to Wagner Units 2 and 3 is equivalent to the average heat input rate for 2009-2010, specifically 20,746,586 MMBtu/yr, the changes in annual HCl and HF emissions from the coal boilers are expected to be -1,140 tpy for HCl and - 23.6 tpy for HF. Moreover, if the proposed DSI system is used when burning subbituminous coal, the reductions in the acid gas emissions would be greater. The supporting calculations for the HCl and HF emissions changes are provided in Appendix E, Table E-3.

ZEPHYR ENVIRONMENTAL CORPORATION 70

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

5.1.1.1.5 Sulfuric Acid Mist

Emissions of the sulfuric acid mist (SAM) are based on the estimation methodologies presented in the 2012 Electric Power Research Institute (EPRI) Technical Update report entitled Estimating Total Sulfuric Acid Emissions from Stationary Power Plants (EPRI 2012). In general, the SAM emissions depend on the type and amount of coal burned, the sulfur content of the

coal, and the type of NOx and particulate control system. The released emissions account for the amount of SAM produced during combustion and, for Wagner Unit 3, the amount produced

from the use of the SCR (due to catalytic conversion of SO2 to SO3). Also, the released emissions account for the amount of SAM captured by residual ammonia from the use of the SCR and SNCR control systems. In addition, the released emissions account for the reduction in SAM due to the downstream air heater and ESP.

Emissions of SAM are expected to decrease with the use of subbituminous coals. Assuming that the future annual total heat input rate to Wagner Units 2 and 3 is equivalent to the average heat input rate for 2009-2010, specifically 20,746,586 MMBtu/yr, the change in annual SAM emissions from the coal boilers is expected to be -38.5 tpy. Moreover, when the proposed DSI system is active the reductions in the SAM emissions will be greater. The supporting calculations for the SAM emissions change are provided in Appendix E, Table E-4.

5.1.1.1.6 Lead

Emissions of lead (Pb) are expected to decrease with the use of subbituminous coals. Assuming that the future annual total heat input rate to Wagner Units 2 and 3 is equivalent to the average heat input rate for 2009-2010, specifically 20,746,586 MMBtu/yr, the changes in annual Pb emissions from the coal boilers is expected to be -0.01 tpy. The supporting calculations for the Pb emissions change are provided in Appendix E, Table E-5.

5.1.1.2 Material Handling Emissions

The use of subbituminous coal will affect the generation of PM emissions associated with material handling operations at Wagner. Raven assessed and quantified the effects on the following source groups related to material handling: 1) coal transfers; 2) coal breaker; 3) coal pile wind erosion; and 4) coal pile maintenance. As discussed earlier in this report, the use of subbituminous coal will not require the construction of any new equipment at Wagner.

Emission factors for the various material handling operations involving coal were estimated in accordance with current EPA techniques as presented in AP-42 (EPA 1995), EPA’s fugitive dust background document (EPA 1992), historical EPA emission factors when no current factors are applicable, and equipment design information.

For batch drop operations such as conveyor transfer points, the total suspended particulate

matter [PM(TSP)], PM10 and PM2.5 emission factors for batch drop operations are defined in Section 13.2.4 of AP-42 by the equation:

ZEPHYR ENVIRONMENTAL CORPORATION 71

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

E = k(0.0032) (u/5)1.3/(m/2)1.4

where: E = emission factor (lb/ton) k = particle size multiplier u = mean wind speed (mph) m = material moisture content (percent)

The particle size multiplier, k, was based on the recommended multipliers of 0.74, 0.35 and

0.053 in developing the PM(TSP), PM10, and PM2.5 emission estimates, respectively. The mean wind speed – 8.9 mph – was obtained from the Local Climatological Data (2001) for BWI.

Emission factors given in Section 11.19.2 of AP-42 were used to estimate emissions from coal

crushing. Specifically, the emission factors representing tertiary crushing for PM(TSP), PM10, and PM2.5 are 0.0054, 0.0024, and 0.000378 lb/ton, respectively. Note that there is no emission factor in AP-42 specifically for coal crushing. The crushed material output from tertiary crushers, though, is in the 3/16 to 1 inch size range, which is typical for coal crushers.

A control efficiency for each source was based on EPA's fugitive dust background document (EPA 1992) and information about the source. In the past, EPA emission estimation methodologies tended to account for other factors potentially affecting emissions, such as drop height. For example, an earlier form of the current EPA emission factor included a drop height factor in the equation such that a source that had a 10 foot drop would have 10 times more emissions than a source that had a 1 foot drop. While this factor is no longer used in the current EPA emission estimation methodologies, the height of the drop can influence the amount of potential fugitive emissions, as was recognized by EPA in its fugitive dust background document (EPA 1992). In addition, the consideration of control efficiencies for the various techniques is somewhat subjective based on the configuration of the source and combination of controls (e.g., extent of enclosure and water spray application). Such factors were considered in assigning control efficiencies.

Material handling emissions associated with bituminous coal use and projected future subbituminous coal use, which assumes all of the safety systems described in Section 3.3 for subbituminous coal use are operational, are provided in the Appendix E, Tables E-6 through E- 12. Differences of note between the emission factor calculations for each coal type relate to the coal moisture content and annual throughput. The moisture content has been reduced from 6.5 (for bituminous coal) to 4.5 percent (for subbituminous coal) to better characterize the dustier nature of subbituminous coal (even though chemically bound moisture is significantly higher for subbituminous coals).

Based on the maximum annual heat input for full-time subbituminous coal use (that is no higher than the heat input associated with baseline bituminous coal throughput), the annual throughput of coal was changed from 852,527 (for bituminous coal) to approximately 1.185 MMtons/yr (for subbituminous coal). Note that for the subbituminous coal, the heat input is conservatively based on the full-time use of PRB coal (at 8,750 Btu/lb), which has lower heat content than Adaro coal (at 9,564 Btu/lb).

ZEPHYR ENVIRONMENTAL CORPORATION 72

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The calculated change in annual emissions for material handling operations associated with the use of subbituminous coal are shown in Table 5-3. The use of dust suppressant spray controls and dust extraction systems for subbituminous coal handling are responsible for the overall decrease in material handling emissions. In addition, the existing coal breaker, which is equipped with a by-pass system, will be by-passed for subbituminous coal use; i.e., there will be no subbituminous coal breaking/crushing-related emissions.

Table 5-3. Change in PM Emissions for Material Handling Operations Associated with the Use of Subbituminous Coal Pollutant Change in Annual Emissions (tpy) Coal Wind Total Transfers Breaker Erosion Bulldozer Change PM 0.517 -0.691 -0.025 -1.616 -1.815

PM10 0.244 -0.307 -0.012 -0.170 -0.244

PM2.5 0.037 -0.048 -0.002 -0.026 -0.039

5.1.1.3 Emissions Summary

The analysis comparing the emissions associated with bituminous coal burning in Units 2 and 3 at a total heat input of 20,746,586 MMBtu/yr with the emissions associated with future subbituminous coal burning at that same heat input shows potential emissions increases for

CO, VOC, and CO2. This analysis also shows that NOx, SO2, SAM, acid gases (HCl and HF), lead, and PM emissions from the boilers (Units 2 and 3) and material handling operations should decrease with subbituminous coal use at Wagner.

5.1.2 Emission Estimates for DSI System

5.1.2.1 Boiler Stack Emissions

Sorbents, such as hydrated lime, when injected into the flue gas stream, can remove HCl from the flue gas, and the existing PM control device (i.e., ESP) then removes the sorbent containing the HCl. The removal efficiency will vary with the injection rate and the sorbent injected, but generally, it is anticipated that HCl removal efficiencies of approximately 90 percent will be achieved.

With the possible exception of PM, emissions of regulated air pollutants from the boiler stacks should not increase because the sorbent will be injected downstream of the boilers (which does not affect combustion). In fact, the DSI will help to reduce emissions of SO2 and H2SO4 and other acid gases. The injection of sorbent will not result in an increase in CO2, as hydrated lime does not contain carbonates.

In terms of PM emissions from the boiler stacks, typically, the output from Unit 2 and Unit 3 ESPs will not be affected by minor changes in inlet particulate loading, especially given that the ESPs are oversized with large specific collection areas for high efficiency PM removal. In fact,

ZEPHYR ENVIRONMENTAL CORPORATION 73

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

actual PM stack sampling and opacity measurements performed in conjunction with previous testing of a DSI system at H.A. Wagner Station in September 2012 showed no increase in PM emissions from the boiler stacks with sorbent injection2. An additional factor to consider is that condensable particulate matter (CPM) emissions from the boiler stack should decrease due to acid gas emission reductions; such a decrease conservatively is not accounted for in the PM calculations to support this application.

The use of DSI will have no effect on the electrical generation capacity (MW) or the annual amount of electricity generated (MW-hr) for the Wagner boilers. This also correlates to the fact that the use of DSI will have no effect on the short-term heat input (MMBtu/hr) or the annual quantity of coal to be burned (tons/yr).

5.1.2.2 Material Handling Emissions

The operation of the DSI system at Wagner will result in the generation of PM emissions from the 1) fugitive dust generated by additional truck traffic; and 2) handling/storage of sorbent. As described previously, the sorbent will be delivered to Wagner via tank truck. The travel over on- site roads by these additional tank trucks will generate fugitive PM emissions. Also, additional truck traffic will be associated with increased fly ash generation/haul-out. These fugitive emissions will be controlled through the existing dust control practice (watering and/or sweeping) at Wagner. The sorbent storage silos will be equipped with efficient dust collectors to minimize PM emissions. Each of the four storage silos will be equipped with a bin vent filter, with the PM emissions from the each emission point based on design specifications for outlet grain loading (0.005 gr/scf) and exhaust flow (800 acfm).

The projected total annual PM, PM10, and PM2.5 emissions associated with the DSI system, accounting for the above-described emission sources, are summarized in Table 5-4. The

material handling emissions calculation methodologies for PM, PM10, and PM2.5 emissions, based on project specifications and EPA AP-42 emission factors, are detailed in Appendix E, Tables E-13 through E-16.

Table 5-4. PM Emissions Summary for Sources Associated with the DSI System for Wagner Units 2 and 3 Annual Emissions (tpy) Pollutants Sorbent and Ash Sorbent Ash Truck Traffic Handling/Storage Handling/Storage TOTAL PM 0.472 0.104 1.615 +2.191 PM10 0.047 0.017 1.082 +1.146 PM2.5 0.012 0.006 0.468 +0.486

2 Stack sampling conducted as part of the DSI system testing in 2012 showed an average emission rate of 0.006 lb/MMBtu for each unit while injecting hydrated lime, compared to an emission rate of 0.008 lb/MMBtu for Unit 3 prior to hydrated lime injection. Also, measured opacity was an average of approximately 3 percent during hydrated lime injection, compared to an average of approximately 4 percent prior to hydrated lime injection (UCC 2012).

ZEPHYR ENVIRONMENTAL CORPORATION 74

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

5.1.3 Air Quality Regulatory Analysis

The Project will be constructed and operated in compliance with all applicable state and federal regulations and laws. 5.1.3.1 New Source Review

New major stationary sources of air pollutants and major modifications to major stationary sources are required by the CAA to obtain a permit before commencing construction and operation. This NSR process is required whether the major source or major modification is to be constructed in an area where the NAAQS are exceeded (nonattainment area), where nonattainment NSR (NNSR) applies, or in an area where air quality meets NAAQS (attainment or unclassifiable area), where Prevention of Significant Deterioration (PSD) review applies.

5.1.3.1.1 PSD Review

PSD review is used to determine whether significant air quality deterioration will result from a new or modified facility located in an attainment area. Under federal PSD review requirements, all new major stationary sources or major modifications to major stationary sources must be reviewed and approved by EPA or by the state agency if PSD review authority has been delegated. Federal PSD requirements are contained in 40 CFR 52.21, Prevention of Significant Deterioration of Air Quality. EPA has approved Maryland's State Implementation Plan, including authority to implement the PSD program (per COMAR 26.11.02.12 and 26.11.06.14). PSD permit approval authority for electric generating facilities in Maryland has been granted to the PSC.

A major stationary source is defined as any one of 28 named source categories that has the potential to emit 100 tons per year (tpy) or more, or any other stationary source that has the potential to emit 250 tpy or more, of any regulated NSR pollutant. Potential to emit means the capability at maximum design capacity to emit a pollutant after accounting for physical or operational limitations on the capacity (including control equipment) that are federally enforceable. A major modification is defined as any physical change in or change in the method of operation of a major stationary source that would result in a significant emissions increase of a regulated NSR pollutant, and a significant net emissions increase of that pollutant from the major source. Significant is defined as any increase in emissions in excess of the designated threshold levels.

5.1.3.1.2 NNSR

NNSR is a Federally-mandated pre-construction permitting program for major stationary sources or major modifications to major stationary sources located within a nonattainment area. Anne Arundel County, the location of the Project, has been designated as an attainment or

unclassifiable area for all criteria pollutants except ozone and PM2.5 (40 CFR §81.321). The Maryland NNSR rules are codified under COMAR 26.11.17.

ZEPHYR ENVIRONMENTAL CORPORATION 75

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

VOC and NOx are precursor emissions for ozone; while, NOx and SO2 are precursor emissions for PM2.5. Therefore, emissions of VOC, NOx, SO2 and PM2.5 should be evaluated to assess the applicability of NNSR requirements for ozone and PM2.5.

5.1.3.1.3 NSR Applicability Assessment

Wagner constitutes a major source under the PSD program since it falls into one of the named source categories (fossil fuel-fired steam electric plant of more than 250 MMBtu/hr heat input) and has the potential to emit 100 tpy or more of at least one regulated NSR pollutant. Table 5-5 summarizes each project’s proposed changes in annual emissions and compares the worst- case (i.e., highest) emissions change to the significant emission rate thresholds for PSD and NNSR. Note that if sub-bituminous coal was burned and DSI was used the impacts would be no worse than the higher of the two projects by themselves. As shown in Table 5-5, the projected emissions changes associated with the Projects are below significant emission rate thresholds for all pollutants; thus the Project is not subject to PSD review and NNSR requirements.

Table 5-5. Emissions Change Summary for the Project at Wagner and NSR Applicability Assessment DSI Subbituminous Coal Use System Worst- Annual Annual Case Emission Emission Annual Annual PSD NNSR Rate Change Rate Change Emission Emission Significant Significant Project for Units 2 for Material Rate Rate Emission Emission Subject to Pollutant and 3 Handling Change Change Level Level PSD/NNSR? (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) PM(TSP)a -46 -1.8 +2.2 +2.2 25 NA No/NA a PM10 -31 -0.2 +1.2 +1.2 15 NA No/NA a PM2.5 -14 -0.04 +0.5 +0.5 NA 10 NA/No

SO2 -7,658 NA NC NC 40 40 No/No b NOx -290 NA NC NC 25 25 No/No VOC +10 NA NC +10 NA 25 NA/No CO +83 NA NC +83 100 NA No/NA SAM -39 NA NC NC 7 NA No/NA Lead -0.01 NA NC NC 0.6 NA No/NA Fluoride -24 NA NC NC 3 NA No/NA

CO2 +48,101 NA NC +48,101 75,000 NA No/NA Note: NA = Not applicable; NC = No change a PM emission rate change is based on the change in the filterable PM component only; CPM component is assumed to be the same for each coal, although CPM emissions would be expected to decrease for subbituminous coals and with the use of a DSI system b Emission change shown represents NO2 emissions; other NOx compounds from coal combustion are also assumed to decrease but are not quantified for this analysis

ZEPHYR ENVIRONMENTAL CORPORATION 76

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

5.1.3.2 New Source Performance Standards

5.1.3.2.1 NSPS Subpart Da – Electric Utility Steam Generating Units

Subpart Da is applicable to affected electric utility steam generating units capable of combusting more than 250 MMBtu/hr of fossil fuel. Units 2 and 3 at Wagner include electric utility steam generating units of this size. Standards under Subpart Da are applicable to affected facilities that commenced construction, reconstruction or modification after certain dates as defined in the Subpart Da regulations.

This planned project does not include any construction, reconstruction or modification of any electric utility steam generating unit at Wagner, and would not be subject to Subpart Da.

In order to burn subbituminous coal in Wagner Units 2 and 3, there are no physical changes planned. The existing units, as constructed, accommodate subbituminous coal. Subbituminous coal firing in the units is not projected to increase either the electrical generation capacity (MW) or the amount of electricity generated (MW-hr) at Wagner. In addition, there will not be any increase in the short-term or annual heat input to the units over the baseline level (firing bituminous coal). Under 40 CFR 60.14 (e), the following operational changes shall not be considered a modification:

“(2) An increase in production rate of an existing facility, if that increase can be accomplished without a capital expenditure on that facility;

(3) An increase in the hours of operation;

(4) Use of an alternative fuel if, prior to the date any standard under this part becomes applicable to that source type, , the existing facility was designed to accommodate that alternative use. A facility shall be considered to be designed to accommodate an alternative fuel if that use could be accomplished under the facility’s construction specifications as amended prior to the change.”

Therefore, the planned project would not be considered a modification to existing electric utility steam generating Units 2 and 3 at Wagner.

Moreover, even if an operational change were presumed to occur, there will not be an increase in emissions of air pollutants regulated under Subpart Da from the electric utility steam generating units. Without a resulting increase in emissions, the change would not be a modification under 40 CFR 60.2 and 40 CFR 60.14 (a) and (h).

5.1.3.2.2 NSPS Subpart Y – Coal Preparation Plants

Subpart Y is applicable to new, modified or reconstructed affected facilities of a coal preparation and processing plant which prepares coal by a process such as breaking and crushing and

ZEPHYR ENVIRONMENTAL CORPORATION 77

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION processes more than 200 ton of coal per day. The coal breaker at Wagner would be considered a coal preparation and processing plant of this size; however, Wagner plans to bypass the existing breaker for subbituminous coal use, i.e., there will be no crushing or breaking of this coal. Standards under Subpart Y are applicable to certain affected facilities that commenced construction, reconstruction or modification after certain dates as defined in the regulations (40 CFR 60.250). The potential affected facilities at Wagner include the coal pile, the coal breaker and conveying equipment, and the coal storage system (i.e., the coal bunkers).

This planned project does not include any construction, reconstruction or modification of any potential affected facilities within the coal preparation and processing plant at Wagner, and would not be subject to Subpart Y. As previously mentioned, the coal breaker will be by-passed (without the need for any modifications to the existing equipment) for subbituminous coal use. The size of the coal pile will not change with the use of subbituminous coal. Lastly, there will not be any physical change to the coal storage system, including the bunkers that store the coal, or the conveyors filling those bunkers.

Although more tons of coal would need to be conveyed to the bunkers in a year, in order to produce the same heat input as bituminous coal, Wagner will accomplish this simply through increasing the hours of operation of the equipment and conveyor belt speeds (within current capabilities). To address the safety/explosive concerns associated with the subbituminous coal, Wagner will simply be adding dust control measures at certain points of the process. NSPS does not consider these types of changes to be modifications. Under 40 CFR 60.14 (e), the following operational changes shall not be considered a modification:

“(2) An increase in production rate of an existing facility, if that increase can be accomplished without a capital expenditure on that facility.

(3) An increase in the hours of operation.”

Also, under 40 CFR 60.14 (e), the following physical change shall not be considered a modification:

“(5) The addition or use of any system or device whose primary function is the reduction of air pollutants, ”

Therefore, the planned project would not be considered a modification to any existing affected facility at the coal preparation and processing plant at Wagner.

Moreover, even if a physical or operational change were presumed to occur, because of the dust suppression systems employed during subbituminous coal use, there will not be an increase in particulate emissions from affected facilities at the existing coal preparation and processing plant. Without an increase in emissions the change would not be a modification under 40 CFR 60.2 and 40 CFR 60.14 (a).

ZEPHYR ENVIRONMENTAL CORPORATION 78

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

5.1.3.3 State-Specific Regulations

The Project will comply with all applicable Maryland air quality regulations, including:

COMAR 26.11.06.02.C.(2) – Prohibition of emissions from any building or installation which are visible to human observers; COMAR 26.11.06.03.B.(2)(a) – Prohibition of PM emissions from any confined installation in excess of 0.03 gr/scfd; COMAR 26.11.06.03.C.(1) – Reasonable precautions must be taken to prevent PM from becoming airborne from unconfined sources; COMAR 26.11.06.03.D – Reasonable precautions must be taken to prevent PM from becoming airborne from material handling and construction operations; and COMAR 26.11.06.08 and 26.11.06.09 - Prohibition of emissions beyond the property line that cause a nuisance or air pollution; and COMAR 26.11.15 and 26.11.16 – Toxic air pollutants (TAPs) and procedures related to requirements for TAPs.

With regard to TAPs, calcium hydroxide, which has an MDE TAP Screening Level of 50 µg/m3 (8-hr averaging period), will be emitted from the hydrated lime storage silos associated with the DSI system. A screening analysis conducted per COMAR 26.11.16.02 A.(4) shows that the projected total emission rate for the silos will be below the applicable emission rate threshold (0.10 lb/hr), indicating that the DSI system emissions will not unreasonably endanger human health. (See Attachment E, Table E-14 for the projected PM/calcium hydroxide emission rates for the silos.) Trace metal TAP emissions from coal handling operations may vary between bituminous and subbituminous coals, given the varying trace metal contents of each coal. However, as shown in Section 5-3, use of subbituminous coal will result in reduction of emissions from coal handling operations; therefore, TAPs emissions for coal handling operations should either decrease or remain essentially unchanged.

5.2 IMPACTS ON GROUNDWATER

The storage, handling and use of subbituminous coal and dry sorbent will not result in any direct discharges to groundwater other than percolation of storm water. Percolation of storm water from coal storage and handling areas will be unchanged by storage and handling of subbituminous coal. Storage and handling of dry sorbent will occur in closed containers and equipment, with minimal exposure to storm water.

As discussed in Section 3.2.6, storm water will be managed in accordance with applicable regulations. An onsite storm water management system, BMPs, and implementation of a SWPPP designed in accordance with applicable standards will help to maintain predevelopment runoff characteristics of storm water. Percolation of storm water during normal plant operations will not adversely affect groundwater quality.

ZEPHYR ENVIRONMENTAL CORPORATION 79

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

5.3 IMPACTS ON SURFACE WATER

5.3.1 Wastewater

The storage, handling and use of dry sorbent will not cause any new or increased generation of a continuous or intermittent wastewater stream. The quantity and quality of wastewater generated at the plant will not be adversely affected.

The storage, handling and use of subbituminous coal will increase the generation of an intermittent wastewater stream. One of the means for reducing the build-up of explosive subbituminous coal dust is to wash it down with water. The plan is to wash down the insides of certain coal handling enclosures and transfer that water to the plant’s industrial WWTP. It is estimated that an additional 15,000 gpd of water could be used in wash-downs and the same amount would be conveyed for wastewater treatment. The existing WWTP has additional capacity for this water and is designed to remove coal fines from wastewater (as it does now from coal yard stormwater runoff). Wagner will assess and comply with any requirements related to additional wash-downs of equipment (e.g., NPDES permit conditions).

To control subbituminous coal dust build-up in areas over the water, such as at barge unloading, Wagner will institute a mobile vacuum system to remove the dust without the use of water. This will prevent wash-down water from getting to the River. 5.3.2 Storm Water

Storm water runoff from subbituminous coal and dry sorbent storage and handling areas will be managed in accordance with applicable regulations as described in Section 3.2.6. The quantity and quality of storm water runoff from these areas is not expected to change due to change in coal type and the installation of dry sorbent storage and handling equipment. The continued implementation of existing storm water management procedures, BMPs and SWPPP procedures will ensure that there are no significant impacts to any surrounding surface waters as a result of storage, handling and use of subbituminous coal and dry sorbent.

A new latex polymer dust suppressant emulsion will be sprayed on the subbituminous coal pile in order to “seal” the surface, which prevents dust generation and excessive water infiltration. The chemical is non-hazardous and designed for environmentally-safe exposure to storm water. Wagner will assess and comply with any requirements related to dust suppressant spraying of the subbituminous coal pile (e.g., NPDES permit conditions). 5.3.3 Sanitary Wastewater

The Project will not increase the number of permanent employees at the facility; therefore, there will be no change in the generation of sanitary wastewater.

5.4 ECOLOGICAL IMPACTS

Potential minor effects of operation of the Project on the project area ecological resources could potentially arise from stack and fugitive emissions, operational noise, human presence, and

ZEPHYR ENVIRONMENTAL CORPORATION 80

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

storm water runoff. Effects of air emissions to the onsite ecological resources are expected to

be positive, in that the main purpose of the Project is the reduction of HCl and SO2 emissions, with either reductions or insignificant increases in other air pollutants. PM emissions generated by the handling of sorbent will be minimized through equipment design, operating procedures, and efficient dust collectors. Dust suppressant sprays applied for subbituminous coal handling and storage will reduce the generation of fugitive PM.

The presence of humans and noise are indirect effects of facility operation that could potentially affect surrounding wildlife. The Project will not noticeably alter the situation relative to on-going operations. The Project will not increase the number of permanent employees at the facility. The wildlife species onsite and in the vicinity are adapted to human presence and noise and are anticipated to continue to coexist with the plant. Thus, it can be concluded that the impacts on area ecological resources from the presence of humans and noise will be unchanged.

The quality and quantity of storm water from the power plant site will continue to be managed to minimize impacts to the ecology of adjacent waters. The storm water from the Project will be contained within the coal yard drainage, and will be collected and treated for sediment removal. Thus, aquatic ecological resources should not be affected by the operation of the Project.

In summary, given (1) the previous site disturbances and current—and on-going—operation of the existing Wagner Generating Station; (2) the absence of unique or sensitive ecological communities or species including rare, threatened, or endangered plant or wildlife species; and (3) the implementation of project systems and operating procedures designed to minimize impacts to the site and surrounding ecology, no significant negative ecological impacts are anticipated to occur due to the operation of the Project.

5.5 NOISE IMPACTS

The operation of the Project equipment will contribute insignificantly to overall plant noise emissions. The Project will involve additional truck traffic associated with the delivery of sorbent and haul-out of additional ash, and the use of small motors (for blower fans for the DSI system). Each blower will be mounted in a sound enclosure with inlet and outlet silencers. The noise generated by these activities will be masked by noise generated by existing operations. As such, overall noise levels at plant boundaries are not expected to increase from levels that result from ongoing plant operations.

5.6 IMPACTS ON SOLID WASTE DISPOSAL

The use of subbituminous coal will cause a reduction in generation of boiler ash because subbituminous coal contains less ash per unit of heat input than bituminous coal. Ash disposition will depend on the characteristics of the ash from the particular subbituminous coal burned. Wagner desires to beneficially use as much ash as possible. However, if the ash does not meet required specifications, it will be placed in Raven’s Fort Armistead Road – Lot 15 landfill. The use of subbituminous coal will not result in the generation of any hazardous waste.

ZEPHYR ENVIRONMENTAL CORPORATION 81

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The use of DSI at Wagner will add sorbent material to boiler ash, resulting, by itself, in somewhat increased ash generation. The most ash generation will occur under a scenario where only bituminous coal is fired and DSI is used concurrently on a full-time basis. Under this scenario, the volume of ash could increase by up to approximately 70,000 tpy. Changes in boiler ash quality due to sorbent usage may affect disposition of the ash. Ash that is not beneficially used as a product will be placed in Raven’s Fort Armistead Road – Lot 15 landfill. There is sufficient landfill capacity to accommodate any portion of the ash that could not be beneficially used. The injection of dry sorbent will not result in the generation of any hazardous waste.

Although not currently planned, sorbent could be injected, when burning subbituminous coals, too. The net change in boiler ash generation volume will depend on subbituminous coal usage and dry sorbent injection rates. Under such an operating scenario, it is not anticipated that boiler ash generation volume will change significantly from current ash generation volume. Subbituminous coal and dry sorbent usage may affect ash quality; any changes will be evaluated to determine the effect on disposition of the ash. No other solid waste impacts are expected due to change in coal type or injection of dry sorbent.

5.7 SOCIOECONOMIC AND LAND USE IMPACTS

This section summarizes the impacts to transportation, the local economy, land use, public services and facilities, and cultural resources associated with the operation of the Project. In addition, this section describes visual impacts to surrounding uses.

5.7.1 Transportation Impacts

The primary access road to Wagner is Fort Smallwood Road/Maryland Route 173 (MD-173), which is a four-lane highway with 12-ft lanes, curbed median, and adequate shoulders. MD-173 provides routing to Interstate 695 (I-695) via Hawkins Point Road (also part of MD-173) and Quarantine Road about 2.5 miles northwest of Wagner, and provides direct access to the Greater Baltimore Metropolitan Area. In the vicinity of its intersection with Brandon Shores Drive, MD-173 is classified as an urban “Other Principal Arterial.”

Raven anticipates that no additional workers will be employed as a direct result of the Project. Therefore, Project operations will not affect the Level of Service on local roadways. Maintenance activities, which may involve additional workers on a temporary basis, will be mostly short term in duration and be similar to maintenance activities currently performed on existing equipment at the site.

The additional trucks associated with DSI system operation, which would be needed for sorbent delivery and fly ash haul-out, would increase truck traffic on MD-173 and I-695. Raven estimates a daily increase of no more than an average of 17 round-trip truck trips associated with the Project. The local road system, including key intersections and road segments, will

ZEPHYR ENVIRONMENTAL CORPORATION 82

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION continue to operate at satisfactory levels of service with this small increase in truck traffic. As a point of comparison, for the Brandon Shores 2007 air pollution control project, the projected increase in traffic of approximately 1,080 round-trip truck trips per day destined for or originating from Brandon Shores (located adjacent to Wagner) was determined to not adversely impact the levels of service during morning and afternoon peak hours at nearby intersections (PPRP 2007).

5.7.2 Socioeconomic Impacts

There is expected to be no increase in permanent workers needed for operation of the Project. Despite this aspect of the Project, some indirect revenues may still result from its operation (e.g., purchase of maintenance materials).

There will be only nominal increases in direct tax revenue to the state as a result of the installation and operation of the DSI equipment associated with the Project. The DSI equipment is considered a “coal pollution control facility”, which, once certified, will qualify for a partial exemption from property tax, per COMAR 18.10.03.02A.

5.7.3 Land Use Impacts

The Project should have no impacts on land use since: a) the site has been in use for electrical generation for many years, and b) the plant site and its surroundings are either already mostly developed or are limited from much further development by zoning and land use designations. The new equipment associated with the Project will be located and operated entirely on the existing Wagner site, and therefore, will not displace any residential property.

Given the existing and designated land uses in and around the project site, it is anticipated that neither operation of the new equipment nor the continued presence of the Wagner plant will cause any significant impact to the surrounding land uses.

5.7.4 Impacts on Public Services and Facilities

No significant impacts to public services and facilities are expected to occur during operation of the Project, as further described in the following paragraphs.

No upgrades to any water or sewer production or treatment facilities are expected to be required to incorporate the needs of the Project.

The Project will not impact the local police and medical services, as there will be no new permanent staff required for normal operation. Regular transportation of materials into and out of Wagner resulting from the Project (based on full-time use of DSI) will involve approximately 17 additional trucks per day to the plant site in addition to the trucks currently supporting Wagner operations. Given the adequacy of the road system to the site and the existing traffic, this number of truck trips over the course of a work-day will have insignificant impacts on the area.

ZEPHYR ENVIRONMENTAL CORPORATION 83

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

The Project equipment is expected to generate small amounts of solid waste during operations. As the volumes of wastes generated during operation are expected to be insignificant in comparison to available regional disposal capacity, no significant impacts are expected to result to existing waste disposal facilities during operation.

5.7.5 Impacts on Cultural Resources

As previously described, the closest historical structures or archaeological sites to Wagner are a mile or more away from the site. The plant has been operating in proximity to these resources for many years. It is not anticipated that plant operations including the operation of the Project will have any different direct or indirect impacts to these resources.

5.7.6 Visual Impacts

The existing visual character of the site and immediate area is primarily industrial in nature, due to the presence of the existing Wagner structures and equipment, along with the adjacent Brandon Shores structures and equipment. Wagner has been in operation since 1956. Among the existing plant features impacting the visual character are the Units 1 through 4 generator housing structures, the multiple tall stacks, coal handling equipment and storage piles, substation structures, and existing transmission towers conveying electricity off the site.

The visual impacts of the Project will not be significant given the location and relatively insignificant profile of even the largest components of the new equipment. The tallest equipment associated with the DSI system will be the four sorbent storage silos, which will be no taller than the existing boiler building at Wagner. The proposed new equipment and structures will be adjacent to the existing boiler building at Wagner and will not present any additional impact to surrounding developed uses.

ZEPHYR ENVIRONMENTAL CORPORATION 84

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

REFERENCES Code of Maryland Regulations (COMAR). 2013. www.dsd.state.md.us/comar

Electric Power Research Institute (EPRI). 2012. Estimating Total Sulfuric Acid Emissions from Stationary Power Plants. Electric Power Research Institute, Palo Alto, California. March 2012. 1023790.

Power Plant Research Program (PPRP). 2007. Environmental Review of Proposed Air Pollution Control Project at Brandon Shores (Draft). Power Plant Research Program, Maryland Department of Natural Resources, Annapolis, Maryland. February 5, 2007.

United Conveyor Corporation (UCC). 2012. H.A. Wagner Station Unit 3 Test Report – DSI Demonstration for HCl Removal. United Conveyor Corporation, Waukegan, Illinois. September 2012.

U. S. Environmental Protection Agency (EPA). 1992. Fugitive Dust Background Document and Technical Information Document for Best Available Control Measures. Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. September 1992. EPA- 450/2-92-004.

U. S. Environmental Protection Agency (EPA). 1995 (as updated). AP-42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources. Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. January 1995.

U. S. Environmental Protection Agency (EPA). 2000. EPCRA Section 313 Industry Guidance – Electricity Generating Facilities. Office of Pollution Prevention and Toxics, Washington, DC. February 2000. EPA 745-B-00-004.

ZEPHYR ENVIRONMENTAL CORPORATION 85

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

APPENDIX A MATERIAL SAFETY DATA SHEET FOR HYDRATED LIME

ZEPHYR ENVIRONMENTAL CORPORATION

Carmeuse Lime & Stone Date of Origin: 06/05/2002 11 Stanwix Street, 21st Floor Date of Revision: 05/15/2012 Pittsburgh, PA 15222

Phone: 412-995-5500 Revision No 12 Fax: 412-995-5594

Material Safety Data Sheet

Product Name: HYDRATED LIME

INFOTRAC: 800-535-5053 [In case of an emergency call this number 24 HOURS a day 7 DAYS a week.]

1. IDENTIFICATION OF THE SUBSTANCE AND COMPANY 1.1. Identification of the substance:

Chemical name: Calcium hydroxide Product name(s): Hydrated Lime, Industrial Hydrate Formula: Ca(OH)2 CAS #: 1305-62-0 Molecular Weight: 74.08 Material Uses: Water treatment, steel flux, caustic agent, pH adjustment, acid gas absorption, construction 1.2. Company:

Main Office: st 11 Stanwix Street, 21 Floor Telephone: 412-995-5500 Pittsburgh, PA 15222 Fax: 412-995-5594

Canadian Office: P.O. Box 190 Telephone: 519-423-6283 Ingersoll, Ontario N5C 3K5 Fax: 519-423-6545

2. COMPOSITION / INFORMATION ON INGREDIENTS Ingredient % by Weight CAS # Exposure Limits

OSHA PEL: 15 mg/m3 (total), 5 mg/m3 (resp) ACGIH TLV: 5 mg/m3 Calcium hydroxide >85 1305-62-0 O. Reg. 833 TWAEV: 5 mg/m3 LD50 oral (rat) 7340 mg/kg

OSHA PEL*: 10 mg/m3 (total dust); 3.3 mg/m3 (respirable) Silica - crystalline quartz <1 14808-60-7 ACGIH TLV: 0.025 mg/m3 (respirable) O. Reg. 845: 0.1 mg/m3

*PEL (total dust) = (30 mg/m3) / (% silica + 2) ; PEL (respirable) = (10 mg/m3) / (% silica + 2)

- 1 - Product Name: HYDRATED LIME (continued) 3. HAZARDS IDENTIFICATION AND CLASSIFICATION

Overview: Hydrated lime is an odorless white or grayish-white granular powder. Contact can cause irritation to eyes, skin, respiratory system, and gastrointestinal tract. Contact may aggravate disorders of eyes, skin, gastrointestinal tract, and respiratory system. Eyes: Can cause severe irritation or burning of eyes, including permanent damage. Skin: Can cause severe irritation or burning of skin, especially in the presence of moisture. Ingestion: Can cause severe irritation or burning of gastrointestinal tract if swallowed. Inhalation: Can cause severe irritation of the respiratory system. Long-term exposure may cause permanent damage. Hydrated lime is not listed by MSHA, OSHA, or IARC as a carcinogen, but this product may contain crystalline quartz silica, which has been classified by IARC as (Group I) carcinogenic to humans when inhaled. Inhalation of silica can also cause a chronic lung disorder, silicosis. Irritant: Eyes, mucous membranes, moist skin, respiratory tract. Flammability: This product is not flammable or combustible Explosive: This product is not explosive in dust form Reactivity: May react violently with strong acids producing heat and possible steam explosion in confined space Symbols: WHMIS Symbol: “E” Corrosive Material; “D2A” Materials causing other toxic effects

4. HEALTH EFFECTS AND TREATMENTS

Health Effects: Spacer Inhalation: Acute: irritation, sore throat, cough, sneezing. Chronic: persistent coughing and breathing problems. Long-term exposure to silica can cause a chronic lung disorder, silicosis. Eyes: Acute: severe irritation, intense tearing, burns. Chronic: possible blindness when exposure is prolonged. Skin: Acute: removes natural skin oils, blotches, itching and superficial burns in case of sweating. Chronic: no known effects. Ingestion: Acute: sore throat, stomach aches, cramps, diarrhea, vomiting. Chronic: no known effects.

Treatments: Spacer: Inhalation: Move victim to fresh air. Seek medical attention if necessary. If breathing has stopped, give artificial respiration. Eyes: Immediately flush eyes with large amounts of water for at least 15 minutes. Pull back the eyelid to make sure all the lime dust has been washed out. Seek medical attention immediately. Do not rub eyes. Skin: Flush exposed area with large amounts of water. Seek medical attention immediately. Ingestion: Give large quantities of water or fruit juice. Do not induce vomiting. Seed medical attention immediately. Never give anything by mouth if victim is rapidly losing consciousness or is unconscious or convulsing.

- 2 -

Product Name: HYDRATED LIME (continued) 5. FIRE FIGHTING MEASURES Flash point: Non-flammable

Autoignition temperature: Non-flammable

Inflammability limits: None

Explosion risk: None by itself, but heat produced by reaction with strong acids can generate steam and pressure

Hazardous combustion products: Decomposes to produce calcium oxide (CaO), which can react with water to produce steam and pressure

Extinguishing media: Use dry chemical fire extinguisher. Do not use water or halogenated compounds, except that large amounts of water may be used to deluge small quantities of hydrated lime. Use appropriate extinguishing media for surrounding fire conditions.

Fire fighting instructions: Keep personnel away from and upwind of fire. Wear full fire-fighting turn-out gear (full Bunker gear), and respiratory protection (self- contained breathing apparatus). 6. ACCIDENT PREVENTION MEASURES Individual and collective precautions: Avoid creating conditions which release dust – use mechanical ventilation to remove dust from work spaces

Avoid inhalation of dust: Wear respiratory protection - minimum NIOSH N-95 Dust Mask

Cleaning methods for spills: Use personal protective equipment (eyes, skin and inhalation, see Section 8). Use dry methods (vacuuming, sweeping) to collect spilled materials. Avoid generating dust. For large spills, evacuate area downwind of clean-up area operations to minimize dust exposure. For small spills, store spilled materials in dry, sealed plastic or metal containers. Dust residue on surfaces may be washed with water.

Precautions for the protection of May not be released into surface waters without controls (increases pH) the environment:

Waste Disposal: Dispose according to federal, provincial/state and local environmental regulations 7. HANDLING AND STORAGE Handling: In open air or in ventilated places, avoid skin and eye contact, avoid creating airborne dust

Storage: Store in dry places sheltered from humidity. Keep away from acids and incompatible substances Keep out of reach of children

- 3 -

Product Name: HYDRATED LIME (continued) 8. EXPOSURE CONTROL / PERSONAL PROTECTION Exposure Limits: Calcium hydroxide: 15 mg/m3 (OSHA-total); 5 mg/m3 (OSHA – resp); 5 mg/m3 (ACGIH, O. Reg. 833) Silica (crystalline quartz): 10 mg/m3 (total dust); 3.3 mg/m3 (respirable) (OSHA); 0.05 mg/m3 (respirable - ACGIH); 0.1 mg/m3 (O. Reg. 845)

Use ventilation and dust collection to control exposure to below applicable limits. Engineering Controls: Wear NIOSH N-95 Dust Mask. Respiratory Protection:

Eye Protection: Eye protection (chemical goggles, safety glasses and/or face shield) should be worn where there is a risk of hydrated lime exposure. Contact lenses should not be worn when working with lime products

Hand Protection: Use clean dry gloves

Skin Protection: Cover body with suitable clothes.

Refer to Ontario Regulation 845: Designated Substance – Silica.

9. PHYSICAL AND CHEMICAL PROPERTIES

Physical State: Solid Odor & Appearance: Odorless, white powder pH: 12.4 in saturated water solution at 25oC Melting point: 580°C Boiling point: 2850°C Vapor pressure: Non volatile Vapor density: Non volatile Specific Gravity: 2.24 Solubility: Slightly soluble in water: 0.2% @ 0 C Soluble in acids, glycerin and sugar solutions 10. STABILITY AND REACTIVITY

Stability: Stable products, not very soluble. Decomposition temperature: 580oC, forms calcium oxide (CaO) and water Reactivity: Reacts with acids to form calcium salts while generating heat. Reacts with carbon dioxide in air to form calcium carbonate. Conditions to avoid: Vicinity of incompatible materials

Incompatible materials: Acids; reactive fluoridated, brominated or phosphorous compounds; aluminum (may form hydrogen gas), reactive powdered metals; organic acid anhydrides; nitro-organic compounds; interhalogenated compounds

Hazardous decomposition products: Calcium oxide (CaO)

- 4 -

Product Name: HYDRATED LIME (continued) 11. TOXICOLOGICAL INFORMATION

Toxicity: LD50 oral (rat) for calcium hydroxide is 7340 mg/kg. This product is not listed by MSHA, OSHA, or IARC as a carcinogen, but this product may contain crystalline silica, which has been classified by IARC as (Group I) carcinogenic to humans when inhaled in the form of quartz or cristobalite. No reported Carcinogenicity, Reproductive Effects, Teratogenicity or Mutagenicity.

Exposure Limits: Refer to section 8.

Irritancy: Can cause severe irritation of eyes, skin, respiratory tract and gastrointestinal tract.

Chronic Exposure: Inhalation of silica can cause a chronic lung disorder, silicosis.

12. ECOLOGICAL INFORMATION

Alkaline substance that increases pH to a maximum of 12.4 in a saturated water solution at 25oC Calcium hydroxide gradually reacts with CO2 in air to form calcium carbonate (CaCO3) Calcium carbonate is ecologically neutral Uncontrolled spillage in surface waters should be avoided since the increase pH could be detrimental to fish Harmful to aquatic life in high concentration

13. DISPOSAL CONSIDERATIONS

Dispose according to federal, provincial/state and local environmental regulations.

14. TRANSPORTATION INFORMATION

Classification: TDG Not listed for ground transportation HMR Not listed for ground transportation

TDG: Transportation of Dangerous Goods Regulation (CAN) HMR: Hazardous Materials Regulation (USA)

- 5 -

Product Name: HYDRATED LIME (continued) 15. REGULATORY INFORMATION Symbol: WHMIS RATING D2A, E NFPA RATING HEALTH – 3 SPECIFIC HAZARD - ALK FLASH POINTS – 0 REACTIVITY – 1 HMIS RATING HEALTH –3 SPECIFIC HAZARD - ALK FLASH POINTS – 0 REACTIVITY – 1

Risk Phrases: Risk of serious damage to the eyes Keep out of reach of children

Safety Phrases: Keep storage container away from humidity Avoid contact with skin and eyes. In case of contact with eyes, rinse immediately with water for at least 15 minutes

CPR (Canada): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulation (CPR) of Canada and this MSDS contains all information required by the CPR.

16. MISCELLANEOUS OTHER INFORMATION Hydrated lime can be removed from objects (such as vehicles) using rags dampened with dilute vinegar. After applying dilute vinegar, vehicles (especially chrome surfaces) must be washed with water.

The information contained herein is believed to be accurate and reliable as of the date hereof. However, Carmeuse makes no representation, warranty or guarantee as to results or as to the information’s accuracy, reliability or completeness. Carmeuse has no liability for any loss or damage that may result from use of the information. Each user is responsible to review this information, satisfy itself as to the information’s suitability and completeness, and circulate the information to its employees, customers and other appropriate third parties.

- 6 - CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

APPENDIX B EQUIPMENT DIAGRAMS

ZEPHYR ENVIRONMENTAL CORPORATION Typical Dry Sorbent Injection System Drawings

Dust Collectors (Emissions Points)

Typical Dry Sorbent Injection System Drawings

Typical Dry Sorbent Injection System Drawings

CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

APPENDIX C SITE PLANS (WITH DSI EQUIPMENT LOCATION)

ZEPHYR ENVIRONMENTAL CORPORATION

NORTH SIDE

MOUNT CLARE PROPERTIES C/O CSX TAX DEPT. J910 500 WATER STREET JACKSONVILLE, FL 32202

SOUTH SIDE

ANNE ARUNDEL COUNTY DEPARTMENT OF PUBLIC WORKS 1 HARRY S. TRUMAN PARKWAY ANNAPOLIS, MARYLAND 21401

NOTES:

1. ALL ELEVATIONS ARE IN FEET AND ARE BASED ON U.S.G.S. AND N.G.V.D. 2. MEAN HIGH WATER ELEVATION 0.8 FT 3. MEAN LOW WATER ELEVATION 0.0 FT 4. LATITUDE: 39° 10’ 44.6” LONGITUDE: -76° 31’ 37.1”

See Next Sheet for Detail

H. A. WAGNER POWER PLANT 3000 BRANDON SHORES ROAD BALTIMORE, MARYLAND 21226 ANNE ARUNDEL COUNTY, MARYLAND H. A. WAGNER LLC

DECEMBER 2013 H. A. Wagner Proposed Dry Sorbent Injection Equipment Locations

N

Proposed Location of DSI Silos (2 per Unit)

Proposed Location of DSI Blower Building

H. A. WAGNER POWER PLANT 3000 BRANDON SHORES ROAD BALTIMORE, MARYLAND 21226

SOUTHWEST SIDE OF PATAPSCO RIVER APPROX. ½ MILE EAST OF FORT SMALLWOOD ROAD (MD 173)

SCALE: 1” = 200’ - 0” CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

APPENDIX D ANALYSIS OF COAL SAMPLE DATA

ZEPHYR ENVIRONMENTAL CORPORATION Comparison Coal Constituents By Coal Type (As Received Basis)

Mass Content

Coal Type Energy Ash Nitrogen Sulfur (Btu/lb) (lb/MMBtu) (lb/MMBtu) (lb/MMBtu)

Bituminous 12,167.7 9.746 0.986 0.657 Subbituminous-PRB 8,750.4 5.572 0.800 0.240 Subbituminous-Adaro 9,564.3 2.136 0.764 0.126

Ratios

PRB:Bituminous 0.719 0.572 0.811 0.365 Adaro:Bituminous 0.786 0.219 0.774 0.192 Coal Analysis Data - As Received Basis

Proximate Analysis Ultimate Analysis Shipment Sample Report Volatile Fixed Type Mine Transport Cargo # Date Date Date Report # Sample # Moisture Ash Matter Carbon Energy Carbon Hydrogen Nitrogen Oxygen Sulfur Cl F (%) (%) (%) (%) (Btu/lb) (%) (%) (%) (%) (%) (ppm) (ppm)

Bituminous Barge 1015 2/27/2013 7.68 12.17 30.59 49.56 11,955 0.65 1,100 Bituminous Barge 1016 3/16/2013 3/16/2013 3/18/2013 7.62 11.77 32.59 48.02 11,914 0.76 1,300 Bituminous Barge 1017 3/18/2013 3/18/2013 3/20/2013 8.09 12.13 32.08 47.70 11,844 0.73 1,400 Bituminous Barge 1018 3/21/2013 3/21/2013 3/21/2013 7.55 11.83 31.65 48.97 12,032 0.69 1,500 Bituminous Brooks Run Rail 5946 2/27/2013 B 253 4.98 11.75 31.91 51.36 12,650 70.00 5.26 1.09 10.91 0.99 Bituminous Brooks Run Rail 5947 3/6/2013 B 374 5.58 11.5 32.13 50.79 12,611 70.07 5.15 1.31 10.99 0.98 2,000 Avg 6.92 11.86 31.83 49.40 12,168 70.04 5.21 1.20 10.95 0.80 1,460.00

Subbituminous Antelope Rochelle Rail 6/14/2013 6/15/2013 13839453NH 27.09 5.23 31.82 35.86 8,764 0.20 Subbituminous Antelope Rochelle Rail 8/4/2013 8/6/2013 13852320NH 27.47 4.78 31.45 36.30 8,766 0.18 Subbituminous Antelope Rochelle Rail 8/25/2013 8/27/2013 13857585NH 26.96 4.64 31.64 36.76 8,870 0.22 Subbituminous Antelope Rochelle Rail 9/13/2013 9/14/2013 13762619NG 27.12 4.91 31.7 36.27 8,739 0.20 Subbituminous Antelope Rochelle Rail 7/8/2013 7/15/2013 28.79 4.82 46.74 19.65 8,613 49.73 6.65 0.70 37.85 0.25 100 Avg 27.49 4.88 34.67 32.97 8,750 49.73 6.65 0.70 37.85 0.21 100.00

Adaro (Typical) 26 1.3 37.5 35.50 9,180 53.65 6.45 0.65 37.87 0.07 100 40 Adaro Oct-09 24 1.06 38.68 36.26 9,489 56.87 6.69 0.76 34.51 0.11 Adaro 5/29/2007 6/14/2007 86-12072-39 22.03 2.07 38.3 37.60 9,773 56.82 6.58 0.72 33.66 0.15 130 20 Adaro 5/29/2007 6/14/2007 86-12072-40 21.85 2.08 38.85 37.22 9,870 56.86 6.61 0.69 33.62 0.14 Adaro 5/29/2007 6/14/2007 86-12072-37 21.44 2.29 38.09 38.18 9,844 57.52 6.52 0.75 32.74 0.18 200 24 Adaro 5/29/2007 6/14/2007 86-12072-38 21.01 2.05 39.22 37.72 9,957 57.76 6.56 0.72 32.78 0.13 Adaro 5/24/2007 6/12/2007 86-12043-97 23.84 2.28 38.13 35.75 9,419 56.91 6.42 0.77 33.51 0.11 100 20 Adaro 5/24/2007 6/5/2007 86-12043-98 21.66 1.97 39.8 36.57 9,699 58.21 6.33 0.78 32.61 0.10 Adaro 5/23/2007 6/5/2007 86-12043-100 23.52 2.15 38.26 36.07 9,441 57.33 6.33 0.77 33.33 0.09 Adaro 5/23/2007 6/12/2007 86-12043-101 24.3 2.15 38.5 35.05 9,310 55.86 6.58 0.74 34.59 0.08 46 20 Adaro 5/16/2007 6/5/2007 86-12043-51 24.3 2.71 36.61 36.38 9,423 54.62 6.44 0.69 35.40 0.14 130 24 Adaro 5/16/2007 6/5/2007 86-12043-52 25.24 1.97 36.68 36.11 9,296 53.75 6.60 0.66 36.91 0.11 Adaro 5/8/2007 6/5/2007 86-12043-22 22.87 2.48 37.42 37.23 9,635 56.42 6.78 0.79 33.37 0.16 220 20 Avg 23.24 2.04 38.16 36.59 9,564 56.35 6.53 0.73 34.22 0.12 132.29 24.00

Note:

Ash N S Bit 9.746 0.986 0.657 lb/MMBtu Subbit 5.572 0.800 0.240 lb/MMBtu Adaro 2.136 0.764 0.126 lb/MMBtu

Subbit:Bituminous 0.572 0.811 0.365 Adaro:Bituminous 0.219 0.774 0.192 BITUMINOUS COAL SAMPLE ANALYSES (WAGNER STATION)

SUBBITUMINOUS-PRB COAL SAMPLE ANALYSES (CRANE STATION)

SUBBITUMINOUS-ADARO COAL SAMPLE ANALYSES (WAGNER STATION)

2009 Adaro – Drummond Testing Report October, 2009 H. A. Wagner Units 2 and 3 monitoring, safety-oriented walk downs of coal and ash systems and general support of the test burn.

Coal Quality was determined by proximate and ultimate analyses. Results are as follows:

As Received Coal Analysis Proximate Analysis, Wt % Adaro Drummond (El Descanso) Moisture 24.00 16.70 Volatile Matter 38.68 38.27 Fixed Carbon 36.26 42.11 Ash 1.06 2.92 Ultimate Analysis, Wt % Hydrogen 6.69 6.15 Carbon 56.87 64.37 Nitrogen 0.76 1.20 Sulfur 0.11 0.57 Oxygen 34.51 24.79 Ash 1.06 2.92 Hydrogen Excl. Moisture, Wt 4.03 4.29 % Oxygen Excl. Moisture, Wt % 13.22 9.93 Heating Value, Btu/lb 9,489 10,776

Mercury (Hg) reduction was achieved by the injection of lignite or bituminous coal based powdered activated carbons (PACs) directly into the flue gas stream. These products are specially produced for the removal of mercury from flue gas. They are finely ground to increase surface area and chemically treated to promote adsorption. Once in the gas stream the carbon adsorbs mercury and is then removed by the existing Electrostatic Precipitators.

Based on results from previous sorbent injection testing, and owing to time constraints for testing, three PACs were selected for testing: Babcock HOK-BR (Units 2 & 3), Norit Darco Hg-LH (Unit 3 only) and Calgon SOx Tolerant R&D A (Unit 3 only).

Injection location was limited to the Air Preheater Outlets on both Units 2 and 3 to replicate the locations of the permanent Activated Carbon Injection System.

SO2 reduction was achieved solely by the blending of lower sulfur coals. No supplemental sorbent (Trona, Sodium Bicarbonate, etc.) injection was conducted during this testing. SO2 levels were measured by the plant Continuous Emissions Monitors.

Sorbent injection equipment was provided by Industrial Accessories Company (IAC). IAC provided the sorbent delivery system and installed the hoses and lances into the flue gas ducts. PAC injection was performed using two dedicated, self-contained injection systems mounted on

2

PT. ADARO INDONESIA

ENVIROCOAL

ENVIROCOAL SPECIFICATIONS

Envirocoal Specifications 1

TYPICAL SPECIFICATIONS

Proximate Analysis % Moisture a.r. 26.0 Moisture a.d.b. 14.5 Ash a.r. 1.3 Ash a.d.b 1.5 Volatile Matter a.r 37.5 Volatile Matter a.d.b 43.0 Fixed Carbon a.r. 35.5 Fixed Carbon a.d.b. 41.0 Calorific Value (kcal/kg) g.a.r. 5,100 Calorific Value (kcal/kg) a.d.b. 5,900 Total Sulphur 0.1 Hardgrove Grindability Index 50

Ultimate Analysis % Carbon d.a.f 73.8 Hydrogen d.a.f 4.9 Nitrogen d.a.f 0.9 Oxygen d.a.f 20.3 Sulphur d.a.f 0.1

Ash Fusion Temperature C Deformation 1,200 (Reducing Atmosphere) Hemisphere 1,260 Flow 1,340

Other Properties % Chlorine a.d.b. 0.01 Fluorine a.d.b. 0.006 Mercury ppm 0.04 Boron ppm 10

Envirocoal Specifications 2

TYPICAL SPECIFICATIONS

Typical Ash Composition % Silicon SiO3 d.b. 35.0 Aluminium Al2O3 d.b. 20.0 Iron FE2O3 d.b. 20.0 Calcium CaO d.b. 11.0 Magnesium MgO d.b. 3.0 Sodium Na2o3 d.b. 0.3 Potassium K2O5 d.b. 0.7 Phosphorus P2O5 d.b. 0.3 Titanium TiO2 d.b. 1.0 Sulphur SO3 d.b. 9.0

Typical Sizing - mm Size range Typical Range + 50.00 2% 1-3% 50.00 - 31.50 11% 8-13% 31.50 - 22.40 9% 6-12% 22.40 - 11.20 19% 17-20% 11.20 - 4.75 23% 21-25% 4.75 - 2.00 14% 12-15% 2.00 - 1.00 9% 7-10% 1.00 - 0.50 6% 5-7% - 0.50 9% 7-10%

Envirocoal Specifications 3

TYPICAL SPECIFICATIONS

Trace Elements Antimony a.r. 0.06 (Concentration mg/kg) Arsenic a.r. 0.37 Barium a.r. 12.5 Beryllium a.r. 0.31 Boron a.r. - 10 Bromine a.r. 12 Cadmium a.r. 0.01 Chlorine a.r. 0.01% Chromium a.r. 1.99 Cobalt a.r. 1.3 Copper a.r. 1.32 Fluorine a.r. 40 Lead a.r. 1 Lithium a.r. 0.58 Manganese a.r. 8.83 Mercury a.r. 0.04 Molybdenum a.r. - 0.01 Nickel a.r. 2.7 Selenium a.r. .2 Silver a.r. - 0.01 Strontium a.r. 2.7 Thallium a.r. 0.16 Tin a.r. - 1 Uranium a.r. 0.07 Vanadium a.r. 4.53 Zinc a.r. 6.18 Zirconium a.r. 3.9

Envirocoal Specifications 4 CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

APPENDIX E EMISSIONS CALCULATIONS

ZEPHYR ENVIRONMENTAL CORPORATION TABLE E-1 CO AND VOC EMISSIONS FOR BITUMINOUS AND SUBBITUMINOUS

CO Emissions Analysis

Emission Factors

Bituminous Coal: 0.5 lb CO/sT coal Note: sT = short Ton Subbituminous Coal: 0.5 lb CO/sT coal Source: U.S. EPA, AP-42, Table 1.1-3

Emissions Analysis - Future Use of Subbituminous Coal

Bituminous Coal Firing Total (Baseline) for Units 2 and 3: 852,527 sT per year CO Emissions for Bituminous Coal Firing Total (Baseline) for Units 2 and 3: 213 TPY

Projected Future Total Subbit Coal Firing for Units 2 and 3: 1,185,465 sT per year Projected Future CO Emissions for Subbit Coal Firing Total for Units 2 and 3: 296 TPY

Change in CO Emissions Associated with Full-Time Subbit Use at Wagner: + 83 TPY

VOC Emissions Analysis

Emission Factors

Bituminous Coal: 0.06 lb TNMOC/sT coal Sub-bituminous Coal: 0.06 lb TNMOC/sT coal Source: U.S. EPA, AP-42, Table 1.1-19

Emissions Analysis - Future Use of Subbituminous Coal

Bituminous Coal Firing Total (Baseline) for Units 2 and 3: 852,527 sT per year VOC Emissions for Bituminous Coal Firing Total (Baseline) for Units 2 and 3: 26 TPY

Projected Future Total Subbit Coal Firing for Units 2 and 3: 1,185,465 sT per year Projected Future VOC Emissions for Subbit Coal Firing Total for Units 2 and 3: 36 TPY

Change in VOC Emissions Associated with Full-Time Subbit Use at Wagner: + 10 TPY TABLE E-2

CO2 EMISSIONS FOR BITUMINOUS AND SUBBITUMINOUS COALS

CO2 Emission Factor for Bituminous Coal (Wagner Units 2 and 3)*

Unit 2 Year: 2011 Annual CO2 Emissions: 529,958 TPY Annual Heat Input: 5,165,299 MMBtu

Emission Factor: 205.2 lb/MMBtu

Year: 2012 Annual CO2 Emissions: 455,414 TPY Annual Heat Input: 4,394,357 MMBtu

Emission Factor: 207.3 lb/MMBtu

Unit 2 - 2-Year Avg. Emission Factor: 206.2 lb/MMBtu

Unit 3 Year: 2011 Annual CO2 Emissions: 1,172,257 TPY Annual Heat Input: 11,425,504 MMBtu

Emission Factor: 205.2 lb/MMBtu

Year: 2012 Annual CO2 Emissions: 848,692 TPY Annual Heat Input: 8,189,152 MMBtu

Emission Factor: 207.3 lb/MMBtu

Unit 3 - 2-Year Avg. Emission Factor: 206.2 lb/MMBtu

2-Year Average Emission Factor for Bituminous Coal Firing in Wagner 2 & 3: 206.2 lb/MMBtu

CO2 Emission Factor for Subbituminous Coal (based on subbituminous coal firing at Crane)*

Unit 1 Year: 2011 Annual CO2 Emissions: 579,769 TPY Annual Heat Input: 5,527,961 MMBtu

Emission Factor: 209.8 lb/MMBtu

Year: 2012 Annual CO2 Emissions: 484,125 TPY Annual Heat Input: 4,565,200 MMBtu

Emission Factor: 212.1 lb/MMBtu

Unit 1 - 2-Year Avg. Emission Factor: 210.9 lb/MMBtu

Unit 2 Year: 2011 Annual CO2 Emissions: 662,673 TPY Annual Heat Input: 6,318,382 MMBtu

Emission Factor: 209.8 lb/MMBtu

Year: 2012 Annual CO2 Emissions: 459,938 TPY Annual Heat Input: 4,341,512 MMBtu

Emission Factor: 211.9 lb/MMBtu

Unit 2 - 2-Year Avg. Emission Factor: 210.8 lb/MMBtu

2-Year Average Emission Factor for Subbituminous Coal Firing in Crane 1 & 2: 210.9 lb/MMBtu

Change in CO2 Emissions Associated with Full-Time Use of Subbituminous Coal: + 2.25%

Bituminous Coal Heat Content: 12,168 Btu/lb, as received (based on 2012 data for Units 2 and 3)

Bituminous Coal Usage (Average Annual Total for 2009-2010): 852,527 TPY Annual Bituminous Coal Heat Input (based on 2009-2010 period): 20,746,586 MMBtu/yr Annual CO2 Emission Rate for Bituminous Coal (2009-2010): 2,139,346 TPY CO2 Emissions Increase, Full-Time Subbit Use Instead of Bituminous: 48,101 TPY

* Annual coal usage and heat input data are taken from EPA GHG Summary Reports for 2011 and 2012 TABLEE3 HClANDHFEMISSIONSFORBITUMINOUSANDSUBBITUMINOUSCOALS

ChlorideandFluorideContentsofCAPPBituminousandPRBSubbituminousCoals

ClContent FContent (ppmw) (ppmw) Notes BituminousCoal WestVirginia 58 BasedonEPA745B00004,Table35 Kentucky 86 BasedonEPA745B00004,Table35 Average 72

SubbituminousPRBCoal Wyoming 118 44 BasedonEPA745B00004,Table35

AcidGasEmissionFactors

HCl HF HeatContent ClContent EF FContent EF CoaltType (Btu/lb) (ppmw) (lb/MMBtu) (ppmw) (lb/MMBtu) Notes

ClcontentbasedonaverageofWagnercoalsamples(seeAppendix Bituminous 12,168 1,460 0.1234 72 0.0062 D);FcontentisaveragevaluefromEPA(seeabove) ClcontentbasedontheaverageofoneavailableWagnercoal sample(seeAppendixD)andtheaveragevaluefromEPA(see SubbituminousPRB 8,750 109.2 0.0128 43.7 0.0053 above);FcontentisaveragevaluefromEPA(seeabove) ClandFcontentsbasedonaverageofWagnercoalsamplesand SubbituminousAdaro 9,564 132.3 0.0142 24 0.0026 typicalAdarocoal(seeAppendixD)

AcidGasAnnualEmissions

TotalAnnualHeatInput= 20,746,586 MMBtu/yr

Bituminous Subbituminous* Change (tpy) (tpy) (tpy) HCl 1,280.22 140.35 1,139.87 HF 64.61 40.97 23.64

*BasedontheaverageemissionfactorforPRBandAdarocoals TABLEE4 SULFURICACIDMIST(SAM)EMISSIONSFORBITUMINOUSANDSUBBITUMINOUSCOALS

TotalAnnualHeatInput= 20,746,586 MMBtu/yr WagnerUnit2HeatInput= 6,920,334 MMBtu/yr WagnerUnit3HeatInput= 13,826,251 MMBtu/yr

Unit WagnerUnit2 WagnerUnit3 WagnerUnit2 WagnerUnit3 WagnerUnit2 WagnerUnit3 NOxControl SNCR SCR SNCR SCR SNCR SCR CoalType Bituminous Bituminous SubbitPRB SubbitPRB SubbitAdaro SubbitAdaro SulfurContent %,w 0.8 0.8 0.21 0.21 0.12 0.12 HeatContent Btu/lb 12168 12168 8750.4 8750.4 9564.3 9564.3 Coal tpy 284366 568140 395430 790035 361779 722805 SO2 tpy 4322.4 8635.7 1453.2 2903.4 759.7 1517.9 BasedonEq43ofEPRIdocument;SulfurconversiontoSO2fromEPRIdocument,pg43(bit=0.95;subbit=0.875) SO2 ppmv 657.70 657.70 BasedonEq45ofEPRIdocument

SAMmanufacturedfromcombustion EMcomb=KXF1XSO2 BasedonEq41ofEPRIdocument

K lb/ton 3063 3063 3063 3063 3063 3063 F1 0.0072 0.0072 0.0019 0.0019 0.0019 0.0019 BasedonTable41ofEPRIdocument SO2 tpy 4322.4 8635.7 1453.2 2903.4 759.7 1517.9 EMcomb lb/yr 95613.5 191027.8 8457.2 16896.8 4421.4 8833.7

SAMmanufacturedfromSCR EMscr=KXS2XfsopsXSO2XF3scr BasedonEq46ofEPRIdocument

K lb/ton 3063 3063 3063 S2 0.009 0.03 0.03 BasedonSO2toSO3conversiondiscussionsonpgs33and47ofEPRIdocument fsops 1 1 1 SO2 tpy 8635.7 2903.4 1517.9 F3scr 1 1 1 EMscr lb/yr 238061.0 266791.6 139479.0

AmmoniaslipfromSCR/SNCR NH3scr.sncr=KsXCoalXfsreagentXSNH3 BasedonEq412ofEPRIdocument

Ks lb/(Tbtuppmv) 3799 3799 3799 3799 3799 3799 Coal tpy 284366 568140 395430 790035 361779 722805 Coal Tbtu/yr 6.920 13.826 6.920 13.826 6.920 13.826 fsreagent 111111 SNH3 ppmv 5 0.75 5 0.75 5 0.75 Basedonvaluesgivenonpg413ofEPRIdocument(SCR=0.75ppmv;SNCR=5ppmv) NH3scr.sncr lb/yr 131451.8 39394.4 131451.8 39394.4 131451.8 39394.4

SAMbeforedownstreamequipment SAMi=EMcomb+EMscrNH3scr.sncr

SAMi lb/yr 0.0 389694.4 0.0 244293.9 0.0 108918.2 ZeroreleasewhenammoniaslipisgreaterthanSAMmanufacture

SAMrelease SAM=SAMiXF2aphXF2esp BasedonEq32ofEPRIdocument

F2aph 0.5 0.5 0.36 0.36 0.36 0.36 BasedonTable43ofEPRIdocument F2esp 0.63 0.63 0.72 0.72 0.72 0.72 BasedonTable44ofEPRIdocument SAM lb/yr 0 122753.7 0 63321.0 0 28231.6

SAMAnnualEmissions tpy 0 61.4 0 31.7 0 14.1

ChangeinAnnualEmissions tpy 0 29.7 0 47.3 or 38.5 tpyaverageforPRBandAdarocoals

**PrimaryReferenceis:EstimatingTotalSulfuricAcidEmissionsfromStationaryPowerPlants . EPRI, Palo Alto, CA: 2012. 1023790.

TABLEE5 LEADEMISSIONSFORBITUMINOUSANDSUBBITUMINOUSCOALS

LeadContentsofCAPPBituminousandPRBSubbituminousCoals

PbContent (ppmw) Notes BituminousCoal WestVirginia 7.2 BasedonEPA745B00004,Table35 Kentucky 10.6 BasedonEPA745B00004,Table35 Average 9

SubbituminousPRBCoal Wyoming 2.1 BasedonEPA745B00004,Table35

LeadEmissionFactors (BasedonEPAAP42,Table1.116)

AshContent PbContent EFPM EFPb CoalType (%,wt) (ppmw) (lb/MMBtu) (lb/1012Btu) Bituminous 11.86 9 0.01032 2.7712 SubbituminousPRB 4.88 2.1 0.00590 1.1230 SubbituminousAdaro 2.04 5 0.00226 2.1196

LeadAnnualEmissions

TotalAnnualHeatInput= 20,746,586 MMBtu/yr

Bituminous Subbit Change Pollutant (tpy) (tpy) (tpy) Pb 0.03 0.02 0.01 TABLE E-6 ANNUAL PARTICULATE MATTER EMISSIONS (TPY) CHANGE ASSOCIATED WITH THE USE OF SUBBITUMINOUS COAL

CAPP Coal Sub-Bit Coal

Coal Wind Coal Wind Total Change in Air Pollutant Transfers Breaker Erosion Bulldozer Total Transfers Breaker Erosion Bulldozer Total Emissions PM 0.757 0.691 1.083 4.290 6.821 1.273 0 1.058 2.674 5.006 -1.815

PM10 0.358 0.307 0.541 0.936 2.142 0.602 0 0.529 0.766 1.897 -0.244

PM2.5 0.054 0.048 0.081 0.143 0.327 0.091 0 0.079 0.117 0.288 -0.039

Change in Annual Emissions (tpy)

Coal Wind Total Air Pollutant Transfers Breaker Erosion Bulldozer Change PM 0.517 -0.691 -0.025 -1.616 -1.815

PM10 0.244 -0.307 -0.012 -0.170 -0.244

PM2.5 0.037 -0.048 -0.002 -0.026 -0.039 TABLE E-7 ESTIMATION OF PM EMISSION FACTORS AND RATES FOR THE COAL HANDLING SYSTEM FROM BATCH/CONTINUOUS DROP OPERATIONS AT TRANSFER POINTS - BITUMINOUS COAL H. A. Wagner Power Plant

Barge Unloading Coal Additive Process Area

Transfer from Transfer from Conveyor D to Transfer from Transfer from Pug Mill Bucket scoop Pug Mill Feed Pug Mill Feed Pug Mill to Pug Product from coal in Transfer from Transfer from Transfer from Belt 2 to Belt Transfer from Belt No. 3 to Transfer from under-pile Transfer from MC Belt to Transfer from Bradford Conveyor (or F Conveyor to Mill Product Conveyor to Transfer from F Belt to G Transfer from M Belt to Transfer from N Belt to O Transfer from G Belt to Transfer from N Belt to Transfer from O Belt to Parameters barge scoop onto Belt 1 Belt 1 to Belt 2 3 (Transfer Bldg. 1) MB Belt MB Belt to Pile Syntron to MC Belt Bradford Breaker Breaker to D Belt Belt) Pug Mill Conveyor Conveyor F Belt or M Belt N Belt Belt Unit 2 Bunker Unit 3 Bunker Unit 3 Bunker Emission Point/Area Barge Unloader Barge Unloader Barge Unloader

Operational Data Activity, hours Daily 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 days Annual 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365

Material Handling Data Material type CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal CAPP Coal + Additive CAPP Coal + Additive CAPP Coal + Additive CAPP Coal + Additive CAPP Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Material throughput, ton/hr (design) Hourly 175 175 175 175 175 175 360 360 360 360 360 362 362 362 362 362 362 362 362 ton/day Daily 2336 2336 2336 2336 2336 2336 2336 2336 2336 2336 2336 2347 2347 2347 1731 1731 616 866 866 ton/yr Annual 852,527 852,527 852,527 852,527 852,527 852,527 852,527 852,527 852,527 852,527 852,527 856,790 856,790 856,790 631,950 631,950 224,840 315,975 315,975 Moisture content (M), % (nominal) 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 6.5 Number of transfers 1 1 1 1 1 1 1 1 1 1111111111

General/ Site Characteristics Mean wind speed, mph Daily 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 Annual 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9

Particle size multiplier, PM (k) 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 Particle size multiplier, PM10 (k) 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 Particle size multiplier, PM2.5 (k) 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053

Emission Control Data Emission control method

Enclosed Partially Enclosed Transfer in Enclosed Transfer with Low Drop Partially Enclosed Building with Partial Enclosure with Telescoping Chute with Low Underground Enclosed Enclosed Transfer into Closed Enclosed Transfer with Low- Enclosed Transfer to Sealed Mill in Enclosed Transfer Enclosed Transfer Enclosed Transfer in Partially Enclosed Transfer Partially Enclosed Transfer Partially Enclosed Transfer Partially Enclosed Transfer Partially Enclosed Transfer (from Scoop) Transfer Filter Enclosed Transfer in Building Windwalls and Roof Drop Transfer and Low-Dust Chutes Breaker Dust Seals and Skirts in Building Building in Building in Building Building in Building in Building in Building in Building in Building Emission control removal efficiency, % 70 70 95 95 90 50 95 90 90 95 99 99 95 95 95 95 95 95 95

Emission Factor (EF) Equations Uncontrolled EF (UEF) Equation UEF (lb/ton) = k x (0.0032) x (U / 5)1.3)/[(M / 2)1.4] Controlled EF (CEF) Equation CEF (lb/ton) = UEF (lb/ton) x [100% - Removal efficiency (%)]

Calculated PM Emission Factor (EF) Uncontrolled EF, lb/ton Short term 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 0.00237 Annual 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 0.00096 Controlled EF, lb/ton Short term 0.000711 0.000711 0.000118 0.000118 0.000237 0.001185 0.000118 0.000237 0.000237 0.000118 0.000024 0.000024 0.000118 0.000118 0.000118 0.000118 0.000118 0.000118 0.000118 Annual 0.000289 0.000289 0.000048 0.000048 0.000096 0.000481 0.000048 0.000096 0.000096 0.000048 0.000010 0.000010 0.000048 0.000048 0.000048 0.000048 0.000048 0.000048 0.000048

Calculated PM10 Emission Factor (EF) Uncontrolled EF, lb/ton Short term 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 0.00112 Annual 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 0.00046 Controlled EF, lb/ton Short term 0.000336 0.000336 0.000056 0.000056 0.000112 0.000560 0.000056 0.000112 0.000112 0.000056 0.000011 0.000011 0.000056 0.000056 0.000056 0.000056 0.000056 0.000056 0.000056 Annual 0.000137 0.000137 0.000023 0.000023 0.000046 0.000228 0.000023 0.000046 0.000046 0.000023 0.000005 0.000005 0.000023 0.000023 0.000023 0.000023 0.000023 0.000023 0.000023

Estimated Emission Rate (ER) TOTAL EMISSIONS PM ER lb/hr (daily basis) 0.069 0.069 0.012 0.012 0.023 0.115 0.012 0.023 0.023 0.0115 0.0023 0.0023 0.0116 0.012 0.009 0.009 0.003 0.004 0.004 0.425 lb PM/hr TPY 0.123 0.123 0.021 0.021 0.041 0.205 0.021 0.041 0.041 0.0205 0.0041 0.0041 0.0206 0.021 0.015 0.015 0.005 0.008 0.008 0.757 TPY PM PM10 ER lb/hr (daily basis) 0.033 0.033 0.005 0.005 0.011 0.055 0.005 0.011 0.011 0.0055 0.0011 0.0011 0.0055 0.005 0.004 0.004 0.001 0.002 0.002 0.201 lb PM10/hr TPY 0.058 0.058 0.010 0.010 0.019 0.097 0.010 0.019 0.019 0.0097 0.0019 0.0019 0.0097 0.010 0.007 0.007 0.003 0.004 0.004 0.358 TPY PM10 PM2.5 ER lb/hr (daily basis) 0.005 0.005 0.001 0.001 0.002 0.008 0.001 0.002 0.002 0.0008 0.0002 0.0002 0.0008 0.001 0.001 0.001 0.000 0.000 0.000 0.030 lb PM2.5/hr TPY 0.009 0.009 0.001 0.001 0.003 0.015 0.001 0.003 0.003 0.0015 0.0003 0.0003 0.0015 0.001 0.001 0.001 0.000 0.001 0.001 0.054 TPY PM2.5

Source: USEPA, 2006; AP-42, Section 13.2.4 for Aggregate Handling and Storage Piles.

Consecutive 2-Yr 2-Year Avg. Unit 2 Unit 3 Actual Wagner Coal Firing: Year TPY Total (TPY) (TPY) (TPY) (TPY) 2009 993,422 2010 711,632 1,705,054 852,527 223,721 628,806 2011 665,704 1,377,336 688,668 2012 498,034 1,163,738 581,869

Wagner Bituminous Coal Heat Content: 12,167.7 Btu/lb TABLE E-8 PARTICULATE MATTER EMISSIONS FROM BITUMINOUS COAL CRUSHING

Wagner Existing Bradford Breaker

E = EF x W PM PM10 PM2.5 EF = Emission Factor 0.0054 0.0024 0.000378 AP-42, Section 11.19.2, Table 11.19.2-2, Tertiary Crushing; PM2.5 (73 FR 22906) W (average weight) 852,527 852,527 852,527 CAPP coal throughput for Boilers No. 2 and 3 combined Emissions (tons/year) 2.302 1.023 0.161

Control Efficiency 70.0% 70.0% 70.0% Partial enclosure Emissions (tons/year) 0.691 0.307 0.048 Emissions (lb/hr) 0.648 0.288 0.045 400 tons/hr 2,131.3 hrs/yr TABLE E-9 ESTIMATION OF PM EMISSION FACTORS AND RATES FOR THE COAL HANDLING SYSTEM FROM BATCH/CONTINUOUS DROP OPERATIONS AT TRANSFER POINTS - SUBBITUMINOUS COAL H. A. Wagner Power Plant

Barge Unloading Coal Additive Process Area

Transfer from Transfer from Conveyor D to Transfer from Transfer from Pug Mill Bucket scoop Pug Mill Feed Pug Mill Feed Pug Mill to Pug Product from coal in Transfer from scoop Transfer from Transfer from Belt 2 to Belt Transfer from Belt No. 3 to Transfer from under-pile Transfer from MC Belt to Transfer/bypass around Conveyor (or F Conveyor to Mill Product Conveyor to Transfer from F Belt to G Transfer from M Belt to N Transfer from N Belt to O Transfer from G Belt to Transfer from N Belt to Transfer from O Belt to Parameters barge onto Belt 1 Belt 1 to Belt 2 3 (Transfer Bldg. 1) MB Belt MB Belt to Pile Syntron to MC Belt Bradford Breaker Bradford Breaker to D Belt Belt) Pug Mill Conveyor Conveyor F Belt or M Belt Belt Belt Unit 2 Bunker Unit 3 Bunker Unit 3 Bunker Emission Point/Area Barge Unloader Barge Unloader Barge Unloader

Operational Data Activity, hours Daily 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 days Annual 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365 365

Material Handling Data Material type Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Adaro Coal + Additive Material throughput, ton/hr (design) Hourly 175 175 175 175 175 175 360 360 360 360 360 362 362 362 362 362 362 362 362 ton/day Daily 3248 3248 3248 3248 3248 3248 3248 3248 3248 3248 3248 3264 3264 3264 2408 2408 857 1204 1204 ton/yr Annual 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,185,465 1,191,392 1,191,392 1,191,392 878,746 878,746 312,646 439,373 439,373 Moisture content (M), % (nominal) 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 Number of transfers 1 1 1 1 1 1 1 0 1 1111111111

General/ Site Characteristics Mean wind speed, mph Daily 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 17.8 Annual 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9 8.9

Particle size multiplier, PM (k) 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 Particle size multiplier, PM10 (k) 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 Particle size multiplier, PM2.5 (k) 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053 0.053

Emission Control Data Emission control method Enclosed Enclosed Transfer in Transfer in Enclosed Transfer Building and Enclosed Enclosed Building and Partially Enclosed in Building and Partial Enclosure with Underground Enclosed Transfer, Enclosed Transfer with Low- Dust Transfer to Transfer in Dust Enclosed Transfer in Partially Enclosed Transfer Partially Enclosed Transfer Partially Enclosed Transfer with Low Drop Partially Enclosed Dust Suppressant Enclosed Transfer in Building Windwalls and Roof and Dust Low-Dust Chutes and Dust Enclosed Transfer into Closed Dust Seals and Skirts and Dust Suppressant Sealed Mill in Building with wet Suppressant Building and Dust Partially Enclosed Transfer Partially Enclosed Transfer in Building and Engart Dust in Building and Engart Dust in Building and Engart Dust (from scoop) Transfer Spraying and Dust Suppressant Spraying Suppressant Telescoping Chute with Low Drop Suppressant Spraying Breaker and Dust Suppressant Suppressant Spraying Building additive Spraying Suppressant in Building in Building Extraction Control Extraction Control Extraction Control Emission control removal efficiency, % 70 70 99 99 95 50 99 99 98 99 99 99 99 99 95 95 99 99 99

Emission Factor (EF) Equations Uncontrolled EF (UEF) Equation UEF (lb/ton) = k x (0.0032) x (U / 5)1.3)/[(M / 2)1.4] Controlled EF (CEF) Equation CEF (lb/ton) = UEF (lb/ton) x [100% - Removal efficiency (%)]

Calculated PM Emission Factor (EF) Uncontrolled EF, lb/ton Short term 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 0.00396 Annual 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 0.00161 Controlled EF, lb/ton Short term 0.001189 0.001189 0.000040 0.000040 0.000198 0.001982 0.000040 0.000040 0.000079 0.000040 0.000040 0.000040 0.000040 0.000040 0.000198 0.000198 0.000040 0.000040 0.000040 Annual 0.000483 0.000483 0.000016 0.000016 0.000081 0.000805 0.000016 0.000016 0.000032 0.000016 0.000016 0.000016 0.000016 0.000016 0.000081 0.000081 0.000016 0.000016 0.000016

Calculated PM10 Emission Factor (EF) Uncontrolled EF, lb/ton Short term 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 0.00188 Annual 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 0.00076 Controlled EF, lb/ton Short term 0.000563 0.000563 0.000019 0.000019 0.000094 0.000938 0.000019 0.000019 0.000038 0.000019 0.000019 0.000019 0.000019 0.000019 0.000094 0.000094 0.000019 0.000019 0.000019 Annual 0.000228 0.000228 0.000008 0.000008 0.000038 0.000381 0.000008 0.000008 0.000015 0.000008 0.000008 0.000008 0.000008 0.000008 0.000038 0.000038 0.000008 0.000008 0.000008

Estimated Emission Rate (ER) TOTAL EMISSIONS PM ER lb/hr (daily basis) 0.161 0.161 0.005 0.005 0.027 0.268 0.005 0.000 0.011 0.0054 0.0054 0.0054 0.0054 0.005 0.020 0.020 0.001 0.002 0.002 0.716 lb PM/hr TPY 0.286 0.286 0.010 0.010 0.048 0.477 0.010 0.000 0.019 0.0095 0.0095 0.0096 0.0096 0.010 0.035 0.035 0.003 0.004 0.004 1.273 TPY PM PM10 ER lb/hr (daily basis) 0.076 0.076 0.003 0.003 0.013 0.127 0.003 0.000 0.005 0.0025 0.0025 0.0026 0.0026 0.003 0.009 0.009 0.001 0.001 0.001 0.339 lb PM10/hr TPY 0.135 0.135 0.005 0.005 0.023 0.226 0.005 0.000 0.009 0.0045 0.0045 0.0045 0.0045 0.005 0.017 0.017 0.001 0.002 0.002 0.602 TPY PM10 PM2.5 ER lb/hr (daily basis) 0.012 0.012 0.000 0.000 0.002 0.019 0.000 0.000 0.001 0.0004 0.0004 0.0004 0.0004 0.000 0.001 0.001 0.000 0.000 0.000 0.051 lb PM2.5/hr TPY 0.021 0.021 0.001 0.001 0.003 0.034 0.001 0.000 0.001 0.0007 0.0007 0.0007 0.0007 0.001 0.003 0.003 0.000 0.000 0.000 0.091 TPY PM2.5

Source: USEPA, 2006; AP-42, Section 13.2.4 for Aggregate Handling and Storage Piles.

Projected Future Subbit-Adaro Coal Use:

- Maximum projected future annual heat input is equal to the highest 2-year average total heat input for Units 2 and 3 over the 2009-2012 period:

20,746,586 MMBtu/yr

- Subbit coal use based on heat content of 8,750.4 Btu/lb (from composite of coal sample analyses)

1,185,465 TPY

- Subbit coal use by unit based on relative bituminous coal use by unit for 2009-2010 period: Unit 2: 311,091 TPY Unit 3: 874,374 TPY TABLE E-10 FUTURE PARTICULATE MATTER EMISSIONS FROM SUBBITUMINOUS COAL CRUSHING

Wagner Existing Bradford Breaker

E = EF x W PM PM10 PM2.5 EF = Emission Factor 0.0054 0.0024 0.000378 AP-42, Section 11.19.2, Table 11.19.2-2, Tertiary Crushing; PM2.5 (73 FR 22906) W (average weight) 0 0 0 Sub-bit coal throughput for Boilers No. 2 and 3 combined* Emissions (tons/year) 0 0 0

*Breaker will be by-passed for subbituminous coal use TABLE E-11 ESTIMATION OF PM EMISSION FACTORS AND RATES FOR WIND EROSION FROM ACTIVE STORAGE PILES

Wind Erosion Emissions

Existing/Bituminous Subbituminous Active Coal Parameters Berthed Barges Pile Berthed Barges Active Coal Pile

Active Coal Active Coal Emission Point/Area Barge Stockout Pile Barge Stockout Pile

Storage Pile Data

Pile Description (shape) Rectangular Rectangular Rectangular Rectangular Average Height (ft) 12.0 a 40 b 12.0 a 40 b Average Length (ft) 200.0 a 350 b 200.0 a 350 b Average Width (ft) 35.0 a 300 b 35.0 a 300 b Average No. of Barges Berthed at One Time 1.00 1.00 Size, ft2 7,000 105,000 7,000 105,000 Size, acres 0.16 2.41 0.16 2.41

General/ Site Characteristics

Days of precipitation greater than or Short term 0 0 0 0 equal to 0.01 inch (p) Annual 112 112 112 112

Time (%) that unobstructed wind speed Short term 20 20 20 20 exceeds 5.4 m/s at mean pile height (f) Annual 20 20 20 20

Silt content (s), % 2.2 c 2.2 c 8.6 d 8.6 d

Particle size multiplier, PM (k) 1.00 1.00 1.00 1.00 Particle size multiplier, PM10 (k) 0.50 0.50 0.50 0.50 Particle size multiplier, PM2.5 (k) 0.075 0.075 0.075 0.075

Emission Control Data: Emission control method None None None Dust Suppressant e Emission control removal efficiency, % 0 0 0 80

Emission Factor (EF) Equation Uncontrolled EF (UEF) Equation = k x 1.7 x (s/1.5) x ((365 - p)/365) x (f/15) Controlled (Final) EF (CEF) Equation F (lb/day/acre) x (100 - Removal efficiency (%)

Calculated PM Emission Factor (EF) Uncontrolled EF, lb/day/acre Short term 3.32 3.32 13.00 13.00 Uncontrolled EF, lb/day/acre Annual 2.30 2.30 9.01 9.01 Controlled EF, lb/day/acre Short term 3.32 3.32 13.00 2.60 Controlled EF, lb/day/acre Annual 2.30 2.30 9.01 1.80

Calculated PM10 Emission Factor (EF) Uncontrolled EF, lb/day/acre Short term 1.66 1.66 6.50 6.50 Uncontrolled EF, lb/day/acre Annual 1.15 1.15 4.50 4.50 Controlled EF, lb/day/acre Short term 1.66 1.66 6.50 1.30 Controlled EF, lb/day/acre Annual 1.15 1.15 4.50 0.90

Calculated PM2.5 Emission Factor (EF) Uncontrolled EF, lb/day/acre Short term 0.25 0.25 0.97 0.97 Uncontrolled EF, lb/day/acre Annual 0.17 0.17 0.68 0.68 Controlled EF, lb/day/acre Short term 0.25 0.25 0.97 0.19 Controlled EF, lb/day/acre Annual 0.17 0.17 0.68 0.14 TOTAL EMISSIONS Estimated Emission Rate Existing Subbit PM lb/hr 0.02 0.33 0.09 0.26 0.36 0.35 TPY 0.07 1.02 0.26 0.79 1.08 1.06 PM10 lb/hr 0.01 0.17 0.04 0.13 0.18 0.17 TPY 0.03 0.51 0.13 0.40 0.54 0.53 PM2.5 lb/hr 0.00 0.03 0.01 0.02 0.03 0.03 TPY 0.01 0.08 0.02 0.06 0.08 0.08

a Typical dimensions for a coal barge b Based on amount of coal stored and density of 52 lb/cuft c Table 13.2.4-1; average coal silt content for coal fired power plant d Table 11.9-3; average coal silt content for Western Surface Coal Mining Source: USEPA, 1992 (Fugitive Dust Background and Technical Information Document for Best Available Control Measures, Section 2.3.1.3.3, Wind Emissions from Continuously Active Piles) e Latex polymer-based dust suppressant applied to coal storage piles TABLE E-12 RECLAIM EMISSIONS FROM COAL PILE USING BULLDOZER/TRACTOR

Existing/Bituminous Subbituminous Data Data Units/Comments

PM

E=k x (s/12)a x (w/3)b; where a = 0.7 and b= 0.45, k = 4.9 for TSP 6.167 16.014 lb/VMT PM(TSP) s = 2.2 from AP-42 Table 13.2.4-1 (Coal); 8.6 from AP-42 Table 11.9-3 (PRB) 5.5 6.60 milesa w = 70 tons 12379.70 38578.42 lb 6.19 19.29 tons uncontrolled without rainfall Emission control method None Dust Suppressantb Emission control removal efficiency, %c 0 80 %

Accounting for rainfall using (365-P)/365 and Contol 4.29 2.67 tons controlled with rainfall

PM10

a b E=k x (s/12) x (w/3) ; where a = 0.9 and b= 0.45, k = 1.5 for PM10 1.345 4.586 lb/VMT PM10 s = 2.2 from AP-42 Table 13.2.4-1 (Coal); 8.6 from AP-42 Table 11.9-3 (PRB) 5.5 6.60 milesa w = 70 tons 2699.32 11048.49 lb 1.35 5.52 tons uncontrolled without rainfall Emission control method None Dust Suppressantb Emission control removal efficiency, %c 0 80 %

Accounting for rainfall using (365-P)/365 and Contol 0.94 0.77 tons controlled with rainfall

PM2.5

a b E=k x (s/12) x (w/3) ; where a = 0.9 and b= 0.45, k = 0.23 for PM10 0.206 0.703 lb/VMT PM2.5 s = 2.2 from AP-42 Table 13.2.4-1 (Coal); 8.6 from AP-42 Table 11.9-3 (PRB) 5.5 6.60 milesa w = 70 tons 413.90 1694.10 lb 0.21 0.85 tons uncontrolled without rainfall Emission control method None Dust Suppressantb Emission control removal efficiency, %c 0 80 %

Accounting for rainfall using (365-P)/365 and Contol 0.14 0.12 tons controlled with rainfall

a Subbit VMT adjusted due to higher material throughput: Coal handling system current total for bituminous coal: 120 tons/hr Subbituminous coal: 144 tons/hr VMT scaling ratio: 1.2 b Latex polymer based dust suppressant applied to coal pile c Based on AP-42 Figure 13.2.2-2, assumed concervative moisture ratio of 1.5. Source: USEPA, 2003; AP-42, Section 13.2.2 for Unpaved Roads. Industrial road factors used. TABLE E-13 ANNUAL PARTICULATE MATTER EMISSIONS (TPY) ASSOCIATED WITH SORBENT DELIVERY, HANDLING, AND STORAGE AND RESULTING ADDITIONAL ASH HANDLING, STORAGE, AND HAULING

Sorbent & Ash Sorbent Ash Air Pollutant Truck Traffic Handling/Storage Handling/Storage Total PM 0.472 0.104 1.615 2.191

PM10 0.047 0.017 1.082 1.146

PM2.5 0.012 0.006 0.468 0.486 TABLE E-14a PM EMISSIONS ASSOCIATED WITH THE HANDLING/STORAGE OF SORBENT AT H.A. WAGNER GENERATING STATION

DSI Process Information

Potential annual sorbent use, Unit 2: 17,152 tons (total for Units 2, based on ratio of max. hourly sorbent use - 4.6 ton/hr - to coal throughput - 60 ton/hr and projected future total annual coal usage for Units 2: 223,721 TPY) Potential annual sorbent use, Unit 3: 52,401 tons (total for Units 3, based on ratio of max. hourly sorbent use - 10.0 ton/hr - to coal throughput - 120 ton/hr and projected future total annual coal usage for Units 3: 628,806 TPY)

Sorbent truck carrying capacity: 23 tons

Number of truck trips annually, Unit 2: 746 trucks/yr or 2 trucks/day Number of truck trips annually, Unit 3: 2,278 trucks/yr or 6 trucks/day

Unloading time for each truck: 120 min/truck

Total unloading time annually, Unit 2: 1,491 hr/yr Total unloading time annually, Unit 3: 4,557 hr/yr

PM Emission Rates for Dust Collectors

Controlled PM PM10 PM2.5 2 2 Exhaust PM Emissions Emission Rate Emission Rate Emission Rate Hydrated Lime Storage Silo ID Flow (acfm)1 (grain/scf) lb/hr lb/day TPY lb/hr lb/day TPY lb/hr lb/day TPY DSI Silo 2A 800 0.005 0.0343 0.1401 0.0128 0.0055 0.0226 0.0021 0.0021 0.0085 0.0008 DSI Silo 2B 800 0.005 0.0343 0.1401 0.0128 0.0055 0.0226 0.0021 0.0021 0.0085 0.0008 DSI Silo 3A 800 0.005 0.0343 0.4280 0.0391 0.0055 0.0692 0.0063 0.0021 0.0259 0.0024 DSI Silo 3B 800 0.005 0.0343 0.4280 0.0391 0.0055 0.0692 0.0063 0.0021 0.0259 0.0024 TOTAL: 0.1371 1.1362 0.1037 0.0222 0.1836 0.0168 0.0083 0.0689 0.0063

1Flow rate at ambient conditions (assumed the same as standard conditions) 2 PM10 and PM2.5 emission rates calculated using ratios of emission factors (each fraction to total PM) from AP-42 Table 11.19.2-4: Emission Factors for Pulverized Mineral Processing Operations - Product Storage with Fabric Filter Control:

PM10: 0.162 , based on the ratio of PM 10 emission factor, 0.0016 lb/ton, to the total PM emission factor, 0.0099 lb/ton

PM2.5: 0.061 , based on the ratio of PM 2.5 emission factor, 0.0006 lb/ton, to the total PM emission factor, 0.0099 lb/ton

Note: DSI = Dry Sorbent Injection TABLE E-14b CALCIUM HYDROXIDE EMISSIONS ASSOCIATED WITH THE HANDLING/STORAGE OF SORBENT AT H.A. WAGNER GENERATING STATION

Calcium Hydroxide - Ca(OH)2 - Emission Rates for TAPs Screening Analysis for Dust Collectors: 8-hr Averaging Period Basis

Ca(OH)2 Emission Rate Hydrated Lime Storage Silo ID (lb/hr)1 DSI Silo 2A 0.0086 DSI Silo 2B 0.0086 DSI Silo 3A 0.0086 DSI Silo 3B 0.0086 TOTAL: 0.0343

Applicable TAP Emission Rate Threshold: 0.10 lb/hr, based on screening analysis table provided in COMAR 26.11.16.02 A.(4)

Because the silos total lb/hr emission rate is less than the TAP emission rate threshold given in COMAR, calcium hydroxide emissions will not unreasonably endanger human health

1Short-term (lb/hr) emission rate assumes that no more than one delivery of hydrated lime will be made to each silo in any 8-hr period. Therefore, for each silo, the maximum lb/hr emission rate for PM is multiplied by a factor of 0.25 (2 hrs/8 hrs) yielding an appropriate 8-hr emission rate. For any 8-hr period, the total maximum short-term emission rate is based on the assumption that each of the four silos will be filled, at 2 hrs per silo, nor more than once in that period. TABLE E-15 PM EMISSIONS ASSOCIATED WITH THE HANDLING/STORAGE OF ASH AT H.A. WAGNER GENERATING STATION

Ash Handling Information

Assumption: Ash handling system is operating during all hours of boiler operation

Projected annual bituminous coal use: 852,527 tpy total for Units 2 and 3 Coal use by unit: Unit 2: 223,721 tpy Unit 3: 628,806 tpy Hours of Operation by unit: Unit 2: 3,729 hr/yr Unit 3: 5,240 hr/yr

Potential annual sorbent use, Unit 2: 17,152 tons (total for Unit 2, based on ratio of max. hourly sorbent use - 4.6 ton/hr - to coal throughput - 60 ton/hr and projected future total annual coal usage for Unit 2: 223,721 TPY) Increased operating time of ash handling system to process extra ash generated by added sorbent for Unit 21: 1,460 hrs (assuming, for baseline puposes, that the ash handling system operates the same number of hours as the boiler)

Potential annual sorbent use, Unit 3: 52,401 tons (total for Unit 3, based on ratio of max. hourly sorbent use - 10.0 ton/hr - to coal throughput - 120 ton/hr and projected future total annual coal usage for Unit 3: 628,806 TPY) hrs required to handle ash directly associated with sorbent injection1 Increased operating time of ash handling system to process extra ash generated by added sorbent for Unit 31: 2,157 hrs (assuming, for baseline puposes, that the ash handling system operates the same number of hours as the boiler)

PM Emission Rates for Dust Collectors

Exhaust Controlled PM PM10 PM2.5 2 2 Ash Handling Equipment Flow PM Emissions Emission Rate Emission Rate Emission Rate Description Source ID (dscfm) (grain/dscf) lb/hr lb/day3 TPY lb/hr lb/day3 TPY lb/hr lb/day3 TPY Unit 2 Silo Bin Vent4 5.11 0.02 0.0009 0.0210 0.0006 0.0006 0.0141 0.0004 0.00025 0.0061 0.0002 Unit 2 Filter/Separator 1,879 0.02 0.3221 7.7307 0.2352 0.2158 5.1796 0.1576 0.0934 2.2419 0.0682 Unit 3 Silo Bin Vent4 11.11 0.02 0.0019 0.0457 0.0021 0.0013 0.0306 0.0014 0.00055 0.0133 0.0006 Unit 3 Filter/Separator 4,100 0.02 0.7029 16.8686 0.7581 0.4709 11.3019 0.5079 0.2038 4.8919 0.2198 Dry Spout Baghouse 3,349 0.02 0.5741 13.7787 0.6192 0.3847 9.2318 0.4149 0.1665 3.9958 0.1796 TOTAL: 1.602 38.445 1.615 1.073 25.758 1.082 0.465 11.149 0.468

1Hours based on coal ash content of 11.91 % for bituminous coal used at Wagner 2 PM10 and PM2.5 emission rates calculated using the PM10 and PM2.5 percentages of total PM for dry bottom boilers with ESP controls given in AP-42, Table 1.1-6: PM10: 67%

PM2.5: 29% 3Assumes ash handling system could be operating 24 hours in any day 4Flow rate for bin vent filter based on air displacement of 1 cubic foot of air for each cubic foot of sorbent, and a bulk density for flyash of 30 lb/ft3 or 0.015 ton/ft3 TABLE E-16 FUGITIVE PM EMISSIONS ASSOCIATED WITH SORBENT DELIVERY AND ASH REMOVAL TRUCK TRAFFIC ON PAVED ROADS AT H.A. WAGNER GENERATING STATION

E = k x (sL)a x (W)b , where a = 0.91 and b = 1.02

- E = Particulate matter emission factor (lb/VMT) - k = Particle size multiplier (lb/VMT) - sL (silt loading) = 1, based on Golder 2001 Port Transportation Study - W (average of unloaded and loaded weights of each truck, in tons) = 28.5 - Number of Days >0.01 in rain, P = 112 - Round trip distance per truck in miles (estimated) = 1.26 - Number of sorbent truck trips per year = 3,024 Total truck trips: 6,048 - Number of additional ash truck trips per year = 3,024 - Controlled emission rate accounts for spraying with water or sweeping for 60 % control - Emission rate accounts for dust suppression effects from rainfall [1-P/(4x365)]

PM Fraction Data Units & Comments

PM(TSP) (k = 0.011 lb/VMT) Emission Factor: 0.335 lb/VMT (average of empty & full truck)

2554.6 lb/year uncontrolled, without rainfall 1.2773 tpy uncontrolled, without rainfall Annual: 0.4717 tpy controlled with spraying; rainfall accounted for Daily: 2.5848 lb/day controlled with spraying; rainfall accounted for Hourly: 0.1077 lb/hr controlled with spraying; rainfall accounted for

PM10 (k = 0.0022 lb/VMT) Emission Factor: 0.067 lb/VMT (average of empty & full truck)

255.46 lb/year uncontrolled, without rainfall 0.1277 tpy uncontrolled, without rainfall Annual: 0.0472 tpy controlled with spraying; rainfall accounted for Daily: 0.2585 lb/day controlled with spraying; rainfall accounted for Hourly: 0.0108 lb/hr controlled with spraying; rainfall accounted for

PM2.5 (k = 0.00054 lb/VMT) Emission Factor: 0.016 lb/VMT (average of empty & full truck)

62.70 lb/year uncontrolled, without rainfall 0.0314 tpy uncontrolled, without rainfall Annual: 0.0116 tpy controlled with spraying; rainfall accounted for Daily: 0.0634 lb/day controlled with spraying; rainfall accounted for Hourly: 0.0026 lb/hr controlled with spraying; rainfall accounted for

Source: AP-42, Section 13.2.1 - Paved Roads, USEPA, January 2011. HIERARCHY OF CONTROL METHODS FOR MATERIAL HANDLING OPERATIONS

(1) Control Method Used Control Efficiency Description and Rationale Enclosed with bag-type filter. Source underground in an enclosed space with low Underground enclosed building, or equivalent 99% drops. See (2) Enclosed Structure or Area 95% Source enclosed with minimum openings for fugitive dust to escape Water Sprays and enclosed on three sides 90% 60% for water spray and 75% for wind reduction. See (2) Water Sprays with Low Drops, or equivalent 90% Low drop resulting in lower PM emissions coupled with water sprays Telescoping chute with water sprays, or equivalent 75% Moderate drop coupled with water sprays Partial Enclosure with no control 70% Low to moderate drop with some openings on at least two sides. See (2) Open Enclosure with water sprays, or equivalent 60% Water sprays (Based on 42% to 75% from EPA, 1992) No control 0% No control provided

Source: EPA, 1992; Golder, 2005. (1) Based on proposed preliminary design for the barge and the land-based system.

EPA, 1992. Fugitive Dust Background Document and Technical Information Document for Best Available Control Measures. OAQPS, EPA-450/2-92-004

(2) Reduction Based on Reducing Wind Speed

1.3 Wind Speed (U) (U/5) Reduction Comment

(mph) from 8.9 mph

8.9 2.116 Used for open source 8.5 1.993 5.80% 81.84212.94% 7.5 1.694 19.95% 71.54926.82% 6.5 1.406 33.54% 61.26740.11% 5.5 1.132 46.51% 51.00052.74% 4.5 0.872 58.79% 40.74864.64% 3.5 0.629 70.28% Used for partially enclosed source 30.51575.68%Used for enclosed (3-sided) source 2.5 0.406 80.81% 20.30485.64% 1.5 0.209 90.12% 10.12394.17% 0.5 0.050 97.63% 0.25 0.020 99.04% Used for totally enclosed source CPCN ENVIRONMENTAL ANALYSIS FOR DRY SORBENT INJECTION AND SUBBITUMINOUS COAL USE PROJECTS AT HERBERT A. WAGNER STATION

APPENDIX F MDE PTC APPLICATION FORMS

ZEPHYR ENVIRONMENTAL CORPORATION

7. Person Installing this Equipment (if different from Number 1 on Page 1)

Name N/A Title

Company

Mailing Address/Street

City/Town State Telephone

8. Major Activity, Product or Service of Company at this Location

Electric power generation

9. Control Devices Associated with this Equipment

None

24-0

Simple/Multiple Spray/Adsorb Venturi Carbon Electrostatic Baghouse Thermal/Catalytic Dry Cyclone Tower Scrubber Adsorber Precipitator Afterburner Scrubber

24-1 24-2 24-3 24-4 24-5 24-6 24-7 24-8

Other

X Describe Bin vent filters (one on each storage silo) 24-9

10. Annual Fuel Consumption for this Equipment N/A

OIL - 1000 GALLONS SULFUR % GRADE NATURAL GAS - 1000 FT3 LP GAS - 100 GALLONS GRADE

26-31 32-33 34 35-41 42-45

COAL - TONS SULFUR % ASH % WOOD - TONS MOISTURE %

46-52 53-55 56-58 59-63 64-65

OTHER FUELS ANNUAL AMOUNT CONSUMED OTHER FUEL ANNUAL AMOUNT CONSUMED

(Specify Type) 66-1 (Specify Units of Measure) (Specify Type) 66-2 (Specify Units of Measure)

1 = Coke 2 = COG 3 = BFG 4 = Other

11. Operating Schedule (for this Equipment) Continuous Operation Batch Process Hours per Batch Batch per Week Hours per Day Days per Week Days per Year X 2 4 7 3 6 5 67-1 67-2 68-69 70-71 72 73-75 Seasonal Variation in Operation No Variation Winter Percent Spring Percent Summer Percent Fall Percent (Total Seasons =100%) X 76 77-78 79-80 81-82 83-84

Form Number: 5 Rev. 9/27/2002 Page 2 of 4 TTY User 1-800-735-2258 Recycled Paper 12. Equivalent Stack Information - is Exhaust through Doors, Windows, etc. Only? (Y/N) N 85 If not, then Height Above Ground (FT) Inside Diameter at Top Exit Temperature (°F) Exit Velocity (FT/SEC) For each of four bin vents: 1 0 6 86-88 86-88 92-95 96-98

NOTE: Attach a block diagram of process/process line, indicating new equipment as reported on this form and all existing equipment, including control devices and emission points

13. Input Materials (for this equipment only) Is any of this data to be considered confidential? N (Y or N) INPUT RATE NAME CAS NO. (IF APPLICABLE) PER HOUR UNITS PER YEAR UNITS 1. Hydrated Lime (Unit 2) N/A 9,200 lb/hr 40,296 ton/yr 2. Hydrated Lime (Unit 3) N/A 20,000 lb/hr 87,600 ton/yr 3. 4. 5. 6. 7. 8. 9. TOTAL

14. Output Materials (for this equipment only) Process/Product Stream OUTPUT RATE NAME CAS NO. (IF APPLICABLE) PER HOUR UNITS PER YEAR UNITS 1. 2. 3. 4. 5. 6. 7. 8. 9. TOTAL

15. Waste Streams - Solid and Liquid OUTPUT RATE NAME CAS NO. (IF APPLICABLE) PER HOUR UNITS PER YEAR UNITS 1. Flyash (Unit 2) N/A 9,200 lb/hr 40,296 ton/yr 2. Flyash (Unit 3) N/A 20,000 lb/hr 87,600 ton/yr 3. 4. 5. 6. 7. 8. 9. TOTAL Form Number: 5 Rev. 9/27/2002 Page 3 of 4 TTY User 1-800-735-2258 Recycled Paper 12. Process Flow Diagram

Electrostatic Precipitator Bin Vent Filter (existing) (one per silo)

Hopper Truck-mounted Silo (one per Pnuematic Truck (2) Gravity feed silo)

Unit 2 or Unit 3 (existing)

New Equipment 16. Total Stack Emissions (for this equipment only) in Pounds Per Operating Day

Particulate Matter Oxides of Sulfur Oxides of Nitrogen 1 . 1 4 99-104 105-110 111-116

Carbon Monoxide Volatile Organic Compounds PM-10 0 . 1 8 117-122 123-128 129-134

17. Total Fugitive Emissions (for this equipment only) in Pounds Per Operating Day

Particulate Matter Oxides of Sulfur Oxides of Nitrogen

99-104 105-110 111-116

Carbon Monoxide Volatile Organic Compounds PM-10

117-122 123-128 129-134

Method Used to Determine Emissions (1= ESTIMATE 2= EMISSION FACTOR 3= STACK TEST 4= OTHER)

TSP SOX NOX CO VOC PM10 4 4 165 166 167 168 169 170

AIR AND RADIATION MANAGEMENT ADMINISTRATION USE ONLY

18. Date Rec'd. Local Date Rec'd. State Return to Local Jurisdiction

Date By

Reviewed by Local Jurisdiction Reviewed by State

Date By Date By

19. Inventory Date Month/Year Equipment Code SCC Code

171-174 175-177 178-185

20. Annual Maximum Design Permit to Operate Transaction Date Operating Rate Hourly Rate Month (MM/DD/YR)

186-192 193-199 200-201 202-207

Staff Code VOC Code SIP Code Regulation Code Confidentiality

208-210 211 212 213 214 215-218 219

Point Description Action A: Add C: Change 220-238 239

Form Number: 5 Rev. 9/27/2002 Page 4 of 4 TTY User 1-800-735-2258 Recycled Paper MARYLAND DEPARTMENT OF THE ENVIRONMENT

SUMMARY OF DEMONSTRATIONS FOR MEETING THE AMBIENT IMPACT REQUIREMENT (26.11.15.05) AND THE T-BACT REQUIREMENT (26.11.15.06)

DO NOT WRITE IN THIS SPACE

H.A. Wagner LLC Company Name

1. Summary of T-BACT Demonstration: List all emission reduction options considered in determining T-BACT starting with the option that reduces emissions the most. Supporting documentation must be attached.

COSTS Emission Reduction Option % Emission Reduction Capital Annual Operating

1. Bin vent filters on all sorbent silos is 99+% the best option for T-BACT

2.

3.

4.

5.

2. Identify the emission reduction option selected as T-BACT and briefly explain why this is the best selection. Supporting documentation must be attached. Bin vent filters on all sorbent silos is the best option for T-BACT given the control efficiency of 99+%.

Form Number: 5A Revision Date 9/27/2002 Page 1 of 2 TTY User 1-800-735-2258 Recycled Paper 3. List screening levels and highest estimated off-site concentrations (ug/m3) resulting from premises-wide allowable emissions (1) of each Toxic Air Pollutant that is covered by the regulations and discharged from the installation or source applying for the permit. See the General Instructions for more detail. Supporting documentation must be attached.

OFF-SITE SCREENING LEVEL(S) CONCENTRATIONS Toxic Air Pollutant CAS Number 1-HR 8-HR ANNUAL 1-HR 8-HR ANNUAL

1 Calcium hydroxide 1305620 50 *

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16 *The Project's total calcium hydroxide lb/hr emission rate, 8-hr basis, is less than the most stringent applicable emission rate (0.10 lb/hr) shown in COMAR 26.11.16.02 A.(4).

If unable to use a Screening Analysis, check the box, and attach the Second Tier Analysis or Special Permit request to this form.

(1) Premises is defined as: "all the installation or other sources that are located on contiguous or adjacent properties and that are under the control of one person or under common control of a group of persons" (COMAR 26.11.15.01B (12)).

Allowable Emissions are defined as: "the maximum emissions a source or installation is capable of discharging after consideration of any physical or operational limitations required by this subtitle or by enforceable conditions included in an applicable air quality permit to construct, permit to operate, secretarial order, plan for compliance, consent agreement, or court order" (COMAR 26.11.15.01B (2)).

Form Number: 5A Revision Date 9/27/2002 Page 2 of 2 TTY User 1-800-735-2258 Recycled Paper MARYLAND DEPARTMENT OF THE ENVIRONMENT

EMISSIONS DATA

DO NOT WRITE IN THIS SPACE Fill out one Form 5B for each stack or other emission point subject to the regulations (see the General Instructions for more details)

Company Name H.A. Wagner LLC

1. Number Identifying This Emission Point On Required Plot Plan Silo 2A (If applicable, list company's internal I.D. )

2. Brief description of Emission Point, Associated Equipment and Control Devices

Bin vent filter on sorbent storage silo

3. Emissions Schedule (for this stack or emission point)

Continuous Intermittent Minutes Hours Days Weeks X per hour per day 24 per week 7 per year 52

Seasonal None X Winter Spring Summer Fall Variation: percent percent percent percent

4. Stack Information Height above ground (ft) Inside diameter at top of round stack (ft) Exit Temperature (°F) 106 Ambient Height above structures (ft) Dimensions at top of rectangular stack (ft) Exit Velocity (ft/min)

Distance to Nearest Property Line (ft) Gas Volume (acfm) 800

Dimensions of Building Stack is on (ft): Height Length Width

5. Control Devices Associated With This Stack or Emission Point

Control Device Number Control Device Number 0. None 7. Elec. Precipitator 1. Simple cyclone 8. Baghouse 2. Multiple cyclone 9. Thermal afterburner 3. Spray tower 10. Catalytic afterburner 4. Absorption tower 11. Other (specify) X 5. Venturi scrubber Bin vent filter 6. Carbon adsorber

Form Number: 5B Revision Date 9/27/2002 Page 1 of 2 TTY User 1-800-735-2258 Recycled Paper 6. Criteria Pollutant Emissions (attach supporting documentation)

Estimated Emissions Criteria Pollutants Design Capacity Projected Operations (1) (lb/hr) (lb/hr) (ton/yr) Particulate Matter 0.0343 0.0343 0.0128 PM10 0.0055 0.0055 0.0021 Oxides of Sulfur

Oxides of Nitrogen

Carbon Monoxide

VOC (Total)

Lead

7. Toxic Air Pollutant Emissions (attach supporting documentation)

Estimated Emissions Design Projected Used for Form 5A Capacity Operations (1) Part 3 (2) Toxic Air Pollutant (list all) CAS Number (lb/hr) (lb/hour) (ton/year) (lb/hour) (ton/year) 1. Calcium hydroxide 1305620 0.0343 0.0343 0.0128 0.0086 (3) N/A 2.

3.

4.

5.

6.

7.

8.

9.

(1) Based on the emission schedule reported in Block three of this form. (2) This column must be filled in with the emission estimates used to demonstrate compliance with the regulations. If continuous emissions at design capacity allow you to demonstrate compliance with all air pollution regulations, then these emissions should be listed here. If the air toxics regulations or any other regulations require you to discharge less than continuously at design capacity, then these emissions should be listed here. (3) Based on assumption of no more than one silo filling (at 2 hours per filling) for any 8-hour period

Form Number: 5B Revision Date 9/27/2002 Page 2 of 2 TTY User 1-800-735-2258 Recycled Paper MARYLAND DEPARTMENT OF THE ENVIRONMENT

EMISSIONS DATA

DO NOT WRITE IN THIS SPACE Fill out one Form 5B for each stack or other emission point subject to the regulations (see the General Instructions for more details)

Company Name H.A. Wagner LLC

1. Number Identifying This Emission Point On Required Plot Plan Silo 2B (If applicable, list company's internal I.D. )

2. Brief description of Emission Point, Associated Equipment and Control Devices

Bin vent filter on sorbent storage silo

3. Emissions Schedule (for this stack or emission point)

Continuous Intermittent Minutes Hours Days Weeks X per hour per day 24 per week 7 per year 52

Seasonal None X Winter Spring Summer Fall Variation: percent percent percent percent

4. Stack Information Height above ground (ft) Inside diameter at top of round stack (ft) Exit Temperature (°F) 106 Ambient Height above structures (ft) Dimensions at top of rectangular stack (ft) Exit Velocity (ft/min)

Distance to Nearest Property Line (ft) Gas Volume (acfm) 800

Dimensions of Building Stack is on (ft): Height Length Width

5. Control Devices Associated With This Stack or Emission Point

Control Device Number Control Device Number 0. None 7. Elec. Precipitator 1. Simple cyclone 8. Baghouse 2. Multiple cyclone 9. Thermal afterburner 3. Spray tower 10. Catalytic afterburner 4. Absorption tower 11. Other (specify) X 5. Venturi scrubber Bin vent filter 6. Carbon adsorber

Form Number: 5B Revision Date 9/27/2002 Page 1 of 2 TTY User 1-800-735-2258 Recycled Paper 6. Criteria Pollutant Emissions (attach supporting documentation)

Estimated Emissions Criteria Pollutants Design Capacity Projected Operations (1) (lb/hr) (lb/hr) (ton/yr) Particulate Matter 0.0343 0.0343 0.0128 PM10 0.0055 0.0055 0.0021 Oxides of Sulfur

Oxides of Nitrogen

Carbon Monoxide

VOC (Total)

Lead

7. Toxic Air Pollutant Emissions (attach supporting documentation)

Estimated Emissions Design Projected Used for Form 5A Capacity Operations (1) Part 3 (2) Toxic Air Pollutant (list all) CAS Number (lb/hr) (lb/hour) (ton/year) (lb/hour) (ton/year) 1. Calcium hydroxide 1305620 0.0343 0.0343 0.0128 0.0086 (3) N/A 2.

3.

4.

5.

6.

7.

8.

9.

(1) Based on the emission schedule reported in Block three of this form. (2) This column must be filled in with the emission estimates used to demonstrate compliance with the regulations. If continuous emissions at design capacity allow you to demonstrate compliance with all air pollution regulations, then these emissions should be listed here. If the air toxics regulations or any other regulations require you to discharge less than continuously at design capacity, then these emissions should be listed here. (3) Based on assumption of no more than one silo filling (at 2 hours per filling) for any 8-hour period

Form Number: 5B Revision Date 9/27/2002 Page 2 of 2 TTY User 1-800-735-2258 Recycled Paper MARYLAND DEPARTMENT OF THE ENVIRONMENT

EMISSIONS DATA

DO NOT WRITE IN THIS SPACE Fill out one Form 5B for each stack or other emission point subject to the regulations (see the General Instructions for more details)

Company Name H.A. Wagner LLC

1. Number Identifying This Emission Point On Required Plot Plan Silo 3A (If applicable, list company's internal I.D. )

2. Brief description of Emission Point, Associated Equipment and Control Devices

Bin vent filter on sorbent storage silo

3. Emissions Schedule (for this stack or emission point)

Continuous Intermittent Minutes Hours Days Weeks X per hour per day 24 per week 7 per year 52

Seasonal None X Winter Spring Summer Fall Variation: percent percent percent percent

4. Stack Information Height above ground (ft) Inside diameter at top of round stack (ft) Exit Temperature (°F) 106 Ambient Height above structures (ft) Dimensions at top of rectangular stack (ft) Exit Velocity (ft/min)

Distance to Nearest Property Line (ft) Gas Volume (acfm) 800

Dimensions of Building Stack is on (ft): Height Length Width

5. Control Devices Associated With This Stack or Emission Point

Control Device Number Control Device Number 0. None 7. Elec. Precipitator 1. Simple cyclone 8. Baghouse 2. Multiple cyclone 9. Thermal afterburner 3. Spray tower 10. Catalytic afterburner 4. Absorption tower 11. Other (specify) X 5. Venturi scrubber Bin vent filter 6. Carbon adsorber

Form Number: 5B Revision Date 9/27/2002 Page 1 of 2 TTY User 1-800-735-2258 Recycled Paper 6. Criteria Pollutant Emissions (attach supporting documentation)

Estimated Emissions Criteria Pollutants Design Capacity Projected Operations (1) (lb/hr) (lb/hr) (ton/yr) Particulate Matter 0.0343 0.0343 0.0391 PM10 0.0055 0.0055 0.0063 Oxides of Sulfur

Oxides of Nitrogen

Carbon Monoxide

VOC (Total)

Lead

7. Toxic Air Pollutant Emissions (attach supporting documentation)

Estimated Emissions Design Projected Used for Form 5A Capacity Operations (1) Part 3 (2) Toxic Air Pollutant (list all) CAS Number (lb/hr) (lb/hour) (ton/year) (lb/hour) (ton/year) 1. Calcium hydroxide 1305620 0.0343 0.0343 0.0391 0.0086 (3) N/A 2.

3.

4.

5.

6.

7.

8.

9.

(1) Based on the emission schedule reported in Block three of this form. (2) This column must be filled in with the emission estimates used to demonstrate compliance with the regulations. If continuous emissions at design capacity allow you to demonstrate compliance with all air pollution regulations, then these emissions should be listed here. If the air toxics regulations or any other regulations require you to discharge less than continuously at design capacity, then these emissions should be listed here. (3) Based on assumption of no more than one silo filling (at 2 hours per filling) for any 8-hour period

Form Number: 5B Revision Date 9/27/2002 Page 2 of 2 TTY User 1-800-735-2258 Recycled Paper MARYLAND DEPARTMENT OF THE ENVIRONMENT

EMISSIONS DATA

DO NOT WRITE IN THIS SPACE Fill out one Form 5B for each stack or other emission point subject to the regulations (see the General Instructions for more details)

Company Name H.A. Wagner LLC

1. Number Identifying This Emission Point On Required Plot Plan Silo 3B (If applicable, list company's internal I.D. )

2. Brief description of Emission Point, Associated Equipment and Control Devices

Bin vent filter on sorbent storage silo

3. Emissions Schedule (for this stack or emission point)

Continuous Intermittent Minutes Hours Days Weeks X per hour per day 24 per week 7 per year 52

Seasonal None X Winter Spring Summer Fall Variation: percent percent percent percent

4. Stack Information Height above ground (ft) Inside diameter at top of round stack (ft) Exit Temperature (°F) 106 Ambient Height above structures (ft) Dimensions at top of rectangular stack (ft) Exit Velocity (ft/min)

Distance to Nearest Property Line (ft) Gas Volume (acfm) 800

Dimensions of Building Stack is on (ft): Height Length Width

5. Control Devices Associated With This Stack or Emission Point

Control Device Number Control Device Number 0. None 7. Elec. Precipitator 1. Simple cyclone 8. Baghouse 2. Multiple cyclone 9. Thermal afterburner 3. Spray tower 10. Catalytic afterburner 4. Absorption tower 11. Other (specify) X 5. Venturi scrubber Bin vent filter 6. Carbon adsorber

Form Number: 5B Revision Date 9/27/2002 Page 1 of 2 TTY User 1-800-735-2258 Recycled Paper 6. Criteria Pollutant Emissions (attach supporting documentation)

Estimated Emissions Criteria Pollutants Design Capacity Projected Operations (1) (lb/hr) (lb/hr) (ton/yr) Particulate Matter 0.0343 0.0343 0.0391 PM10 0.0055 0.0055 0.0063 Oxides of Sulfur

Oxides of Nitrogen

Carbon Monoxide

VOC (Total)

Lead

7. Toxic Air Pollutant Emissions (attach supporting documentation)

Estimated Emissions Design Projected Used for Form 5A Capacity Operations (1) Part 3 (2) Toxic Air Pollutant (list all) CAS Number (lb/hr) (lb/hour) (ton/year) (lb/hour) (ton/year) 1. Calcium hydroxide 1305620 0.0343 0.0343 0.0391 0.0086 (3) N/A 2.

3.

4.

5.

6.

7.

8.

9.

(1) Based on the emission schedule reported in Block three of this form. (2) This column must be filled in with the emission estimates used to demonstrate compliance with the regulations. If continuous emissions at design capacity allow you to demonstrate compliance with all air pollution regulations, then these emissions should be listed here. If the air toxics regulations or any other regulations require you to discharge less than continuously at design capacity, then these emissions should be listed here. (3) Based on assumption of no more than one silo filling (at 2 hours per filling) for any 8-hour period

Form Number: 5B Revision Date 9/27/2002 Page 2 of 2 TTY User 1-800-735-2258 Recycled Paper

- 2 -

12. THE FOLLOWING SHALL BE DESIGN CRITERIA (FOR EACH BIN VENT)

INLET OUTLET

GAS FLOW RATE ACFM* 800 ACFM*

GAS TEMPERATURE °F Ambient °F

GAS PRESSURE INCHES W.G. INCHES W.G.

PRESSURE DROP

DUST LOADING GRAINS/ACFD** 0.005 GRAINS/ACFD**

MOISTURE CONTENT % %

WET BULB TEMP. °F °F

LIQUID FLOW RATE GALLONS PER MINUTE (WHEN SCRUBBER LIQUID OTHER THAN WATER INDICATE (WET SCRUBBER) COMPOSITION OF SCRUBBING MEDIUM IN WEIGHT %)

* = ACTUAL CUBIC FEET PER MINUTE ** = ACTUAL CUBIC FEET DRY

WHEN APPLICATION INVOLVES THE REDUCTION OF GASEOUS POLLUTANTS, PROVIDE THE CONCENTRATION OF EACH POLLUTANT IN THE GAS STREAM IN VOLUME PERCENT. INCLUDE THE COMPOSITION OF THE GASES ENTERING THE CLEANING DEVICE AND THE COMPOSITION OF EXHAUSTED GASES BEING DISCHARGED INTO THE ATMOSPHERE. USE AVAILABLE SPACE IN ITEM 15 ON PAGE 3.

13. PARTICLE SIZE ANALYSIS

SIZE OF DUST PARTICLES ENTERING CLEANING UNIT % OF TOTAL DUST % TO BE COLLECTED

0 TO 10 MICRONS

10 TO 44 MICRONS

LARGER THAN 44 MICRONS

14. FOR AFTERBURNER CONSTRUCTION ONLY: N/A

VOLUME OF CONTAMINATED AIR CFM (DO NOT INCLUDE COMBUSTION AIR)

GAS INLET TEMPERATURE °F

CAPACITY OF AFTERBURNER BTU/HR

DIAMETER (OR AREA) OF AFTERBURNER THROAT

COMBUSTION CHAMBER OPERATING TEMP. AT AFTERBURNER °F (DIAMETER) (LENGTH)

RETENTION TIME OF GASES - 3 -

15. SHOW LOCATION OF DUST CLEANING EQUIPMENT IN THE SYSTEM, DRAW OR SKETCH FLOW DIAGRAM SHOWING EMISSION PATH FROM SOURCE TO EXHAUST POINT TO ATMOSPHERE.

ElectrostaticP recipitator Bin Vent Filter (existing) (one per silo)

Hopper Truck-mounted Silo (one per Pnuematic Truck blower (2) Gravity feed silo)

Unit 2 or Unit 3 (existing) New Equipment - 4 -

DATE RECEIVED: LOCAL STATE:

ACKNOWLEDGEMENT DATE: BY:

REVIEWED BY: LOCAL STATE:

RETURNED TO LOCAL: DATE BY:

APPLICATION RETURNED TO APPLICANT: DATE BY:

REGISTRATION NUMBER OF ASSOCIATED EQUIPMENT:

PREMISES NUMBER:

EMISSION CALCULATIONS REVISED BY DATE

11-2

10. Annual Fuel Consumption for this Equipment Only OIL - 1000 GALLONS SULFUR % GRADE NATURAL GAS - 1000 FT3 LP GAS - 100 GALLONS GRADE

26-31 32-33 34 35-41 42-45 COAL - TONS SULFUR % ASH % WOOD - TONS MOISTURE % See Appendix E, Table E-9 of CPCN Environmental Assessment * * * 46-52 53-55 56-58 59-63 64-65 *See Appendix D of the CPCN Environmental Assessment OTHER FUELS OTHER FUEL ANNUAL AMOUNT CONSUMED Nat. Gas (start-up) Variable (Specify Type) 66-1 (Specify Units of Measure) (Specify Type) 66-2 (Specify Units of Measure) 1 = Coke 2 = COG 3 = BFG 4 = Other 11. Operating Schedule (for this equipment) 1=Pressure Gun 1=Cyclone Coal Burner Comfort/Space Process Percent Oil Burner 2=Air Atomizer Type 2=Stoker Heating Only Heat Only Process Heat Type 3=Steam Atomizer 3 3=Pulverized 67-1 67-2 68-69 70 4=Rotary Cup 71 4=Hand Fired SEASONAL VARIATION IN OPERATION (PERCENT) Days Per Days Per None Winter Spring Summer Fall Week 7 Year 3 6 5 X 72 73-75 76 77-78 79-80 81-82 83-84 12. Exhaust Stack Information (See attached Table 1) Height Above Ground (ft) Inside Diameter at Top (inches) Exit Temperature (°F) Exit Velocity (ft/sec)

86-88 89-91 92-95 96-98 13. Total Stack Emissions (for this equipment only) in Pounds Per Operating Day Particulate * Oxides of * Oxides of * Matter Sulfur Nitrogen 99-104 105-110 111-116

Carbon Volatile Organic PM-10 * Monoxide * Compounds * 117-122 122-128 129-134 *See CPCN Environmental Assessment 14. Method Used to Determine Emissions (1=Estimate, 2=AP-42, 3=Stack Test, 4=Other Emission Factor)

TSP SOx NOx CO VOC PM10 * * * * * * *See CPCN Environmental Assessment 165 166 167 168 169 170 15. What is the Maximum Rated Heat Input of this Unit (Million Btu/hr)? Air and Radiation Management Administration Use Only 16. Date Rec'd Local Date Rec'd State

Return to Local Jurisdiction Date By

Rev'd by Local Jurisdiction Date By Rev'd by State Date By

Acknowledgement Sent by State Date By

17. Inventory Date (MM/YY) SCC Code 18. Annual Operating Rate Maximum Design Hourly Rate

171-174 178-185 186-192 193-199 Permit to Operate Month Transaction Date Staff Code VOC SIP Code

200-201 202-207 208-210 211 212 213 214

Regulation code Confidentiality 215-218 219

Point Description Action A: Add 220-238 239 C: Change Form Number: 11 Rev. 9/27/2002 Page 2 of 2 TTY User 1-800-735-2258 Recycled Paper Table 1. Exhaust Stack Information (MDE-ARMA Form 11, No. 12)

Stack Exit Exit Stack Diameter Unit ID Heighta Temperature Velocity (ft) (in) (ºF) (ft/s) 2 300 235 286 35 3 360 235 286 35 a Height above ground