Environmental Review Document

8/11/2019 Environmental Review Document

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Morgantown Coal Barge Unloading Facility

Environmental Review Document

Application for Approval to Modify a Generating Station:

Mirant Mid Atlantic is seeking approval from the Maryland Public Service

Commission (PSC) to modify the existing Morgantown Generating Station by

adding a new coal barge unloading facility under the requirements of a non-

utility generator in Subtitle 79 of the Title 20 Code of the Maryland Regulations

(COMAR). The approval in this case would be based on recommendations from

interested local, state and federal agencies to ensure compliance with federally

delegated, state regional and local environmental laws and regulations. This

Environmental Review Document submitted with the modification application is

filed with the PSG, pursuant to the PSG Regulations found in COMAR 20.79.01

through 20.79.03. The application and environmental review document includes

a description of the site and existing power plant installations, all proposed

changes or alterations of the site and plant, the new or altered associated

facilities, the environmental and other impacts of the project, and the

environmental and other benefits to be realized from the project.

Facility Description:

The Morgantown Generation Station is 525 acre site on the Potomac River, just

south of Route 301 at the Potomac River Nice bridge near the town of Newburg,

Maryland. The facility consists two base loaded 620 MW coal and residual oil

fired boilers, six peaking #2 oil fired combustion turbines (2x20 MW Frame 5 and

4x65 MW Frame 7), two auxiliary boilers, associated fuel handling and storage

facilities and electric transmission facilities. Coal is delivered to the Morgantown

Station by CSXT unit train. The coal is unloaded using an enclosed rotary railcar

dumper and is either transferred by conveyor directly to the station bunkers or

placed into storage using a stacker reclaimer. Residual oil is delivered to the

Station by pipeline and No.2 oil is delivered barge.

Constructing the coal barge unloading facility at Morgantown will expand and

diversify the coal supply base for both the Chalk Point and Morgantown Stations.

These Stations were designed in the 1960-1970s to burn Northern Appalachian

coal (Pennsylvania, Western Maryland, and Northern West Virginia). The

Northern Appalachian coal region production has undergone significant changes

during the last 3-4 decades characterized by mine closures, reduced production

and the consolidated of producers. These changes have resulted in fewer mines

producing the quality of coal to meet both Morgantown and Chalk Point's coal

quality requirements. Additionally, Morgantown and Chalk Point are captive to a

single delivering railroad, CSX Transportation.


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The coal barge unloader will allow Mirant to diversify its coal supply base by

accessing the Central Appalachian Region (Central and Southern West Virginia,

Southern Virginia and Kentucky) and offshore coal supply from Columbia and

Venezuela. Central Appalachian coal will be transported by rail to the Tidewater

Piers in Virginia by either CSX Transportation or Norfolk Southern, loaded into

barges and shipped to Morgantown. Offshore coal will be off loaded from ocean

going vessels at a deepwater port (Tidewater Virginia or Baltimore) and then

transferred to barges for shipment to Morgantown. Both of these scenarios will

significantly expand Morgantown and Chalk Point's coal supply base and create

a transportation alternative resulting in optionality for both facilities.

The Morgantown Generating Station new coal barge unloading facility will consist

of a dock, unloader, a transfer and distribution system and a rail loading facility.

The coal barge unloading facility is sized to unload 5.0 million tons of coal per

year, the annual consumption rate of both Morgantown and Chalk Point. In

addition, Mirant will maintain the capability of the existing Morgantown railcar

unloading system for back up capability. An overall site plan of the barge

unloading facility is shown on drawing SP-1. The barge unloader's overall flow

schematic is shown in drawing FS-1.

The coal barge unloader's transfer and distribution system will be integrated into

Morgantown's existing coal handling system as much as possible. The coal

transfer system is designed to provide the capability to transfer coal from barges

directly to the plant, to on-site storage or to railcars for transport to Chalk Point.

The railcar loading capability allows the barge unloader to transfer coal directly to

railcars for transport to Chalk Point or reclaim coal from on-site storage for

transport to Chalk Point.

The barge unloader's 600-foot long dock will extend approximately 11OO-feet

channelward into the Potomac River parallel to Morgantown's existing oil barge

channel. No dredging will be required to deepen or expand the existing Potomac

River or Morgantown channels. The dock will be able to accommodate two

15,000 DWT hopper barges. The 600-foot long dock includes a 50 X 42 foot

main platform constructed on steel pipe piles, a concrete deck, a fender system

and four 48 diameter steel pipe monopile dolphins. The main dock platform

supports the unloader, acts as a fender structure and supports the receiving

conveyor gallery that transfers the coal to the transfer tower on shore. A 1,200

TPH pedestal-mounted vertical-screw mechanical unloader is installed on the

dock. During the unloading process the barge will shift along the fender line

using a continuous cable haul system. Barge unloading will be conducted as a

drop and swap operation. A tug will bring a loaded barge to the dock and take

the empty barge back to its supply point. Approximately 265 to 350 barges

deliveries per year will be needed to meet the two Station's coal supply.

The dock unloader will feed an approximate 860 foot long 1200 TPH enclosed

conveyor BC-1 which conveys the coal to the on shore transfer tower TT -1. An

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approximate 1850-foot enclosed and covered conveyor BC-2 (350-foot enclosed

and 1500-foot covered) will transfer the coal from transfer tower TT -1 to transfer

tower TT -2. An approximate 760-foot covered conveyor BC-3 will then transfer

the coal to the existing coal yard transfer tower at the breaker house where the

process will be integrated into the existing Morgantown coal handling system. At

that point coal can be transferred directly into the plant, placed in onsite storage

using Morgantown's existing stacker-reclaimer or transferred to railcars for

shipment to Chalk Point. The general arrangements of conveyors BC-1, BC-2

and BC-3 are shown in drawings GA-1 through 3.

There are two rail loading options being considered. Option 1 is directly

connected to the transfer station at the breaker house and allows for direct

transfer from barge to railcar. Option 2 is a satellite operation that does not allow

for direct barge to railcar transfer. Both railcar loading systems require two 1000

TPH approximately 600-foot (BC-4) and approximately 400-foot (BC-5) covered

conveyors that transfer coal to an elevated railcar loader.

Mirant is projecting to start construction in mid-2006 and commission the barge

unloader in the fourth quarter of 2007. A conceptual schedule for the permitting

and construction of the project is presented in Attachment A.

Air Emission Sources:

The barge unloader and its associated conveyor system and railcar loader will be

a source of fugitive particulate matter (PM) and particulate matter with a diameter

less then 10 um (PM-10) emissions. Fugitive PM and PM-10 emissions will

occur at several points of the barge's coal unloading, transfer and railcar loading

operations. The barge unloader will not be a source of any other pollutants.

The barge unloader has 7 activities that will be a source of fugitive PM and PM-

10 emissions. They are the conveyor's 4 transfer towers, the dock unloader, the

railcar transfer, and the railcar loader. These 7 emission points are projected to

emit a total of 3.33 tons/year of PM and 1.15 tons/year of PM-1O. These

emissions were determined using EPA AP-42 emission factors and a maximum

coal throughput of 5.0 million ton/year. The emissions by activity and back-up

emission calculations are presented in Attachment B.

The actual emission increases from the proposed project will be less than what is

reported above. With the barge unloader in operation, Morgantown's existing

railcar unloading operation and its associated emissions will be reduced or

eliminated all together. Because of Mirant's desire to maintain rail as a coal

delivery option, the Company will not propose netting emissions from the

reduced or discontinued rail operations.

To determine if the emission increases associated with barge unloader are

considered a significant modification to an existing major source and must under

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go Prevention of Significant Deterioration (PSD) [40 CFR 52.21 & COMAR

26.11.06.04] review, the emission increases are compared to PSD Significant

emission thresholds. Table 1 shows the barge unloaders emission increases

are well below the PSD emission thresholds 25 tons/yr for PM and 15 tons/yr for

PM-10. The barge unloader is considered a minor modification and will not have

to undergo PSD review.

Table 1: Emission Increase Summary

Additional minor sources have also been permitted at Morgantown in the recent

years. They include the new auxiliary boiler and the Snyfuel Process. These two

sources are permitted to emit a total of 5.05 tons/yr of PM and 4.71 tons/year of

PM-10. The permitted emissions from these sources are presented in Table 2.

These sources were minor sources or minor source modifications and were

permitted as such.

Table 2 : Previous Permitted Emission Increase

Source

PM (tn/yr)

I

PM 10 (tn/yr)

Aux. I

Boiler

I

snyfuel

lrocess

4.410 4.410

0.640

0.300

ITotal

5.050 4.710

Applicable Air Emission Standards:

Because the barge unloader is a minor modification under the PSD rules there

are no Federal permitting or PSD related emission control requirements. Further

there are no applicable Federal new source performance standards (NSPS) or

hazardous air pollutants (HAPs) standards for this facility.

The barge unloader will be subject to the following Maryland Department of The

Environments Air Quality Regulations.

Visible Emission Limit [COMAR 26.11.06.02C (1)] - Requires opacity to

be less than 20 percent.

.

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Visible Emission Limit [COMAR 26.11 .O6.02C (3)] - Requires no visible

emission across property line from material handling actives.

.

Particulate Matter from Material Handling and Construction [COMAR

26.11.06.030 (1 -(6)] - Requires reasonable precautions to prevent

particulate matter from becoming airborne from material handling

actives.

.

.

Toxic Air Pollutants [COMAR 26.11.15.04 & .07] - Requires new

sources to quantify toxic emissions and demonstrate compliance with

toxic air pollutants screening levels.

The Morgantown barge unloader is to incorporate the best engineering design

and operational practices to minimize fugitive dust at all the unloading, loading,

and conveyor transfer stations. The barge unloader will incorporate in its design

the following fugitive dust suppression technology: (a) enclosed and covered

conveyors, (b) enclosed transfer stations, (c) telescoping loader, and (e) a

partially enclosed railcar loader. The control efficiencies for these designs are

found in the following table.

Table 3: Design Control Efficiencies

Design

Control Efficiency

Enclosed Transfer Stations

-

90%

75%

75%

Telescooina Loader

Partially Enclosed Railcar Loadout /Loader

The MDE Permit to Construction Form (Form 5) for the Barge Unloader is

presented in Attachment C.

The barge unloader's fugitives hazardous air pollutants emission rates were

calculated and were compared to their appropriate toxic screening level emission

rates. The hazardous air pollutant emissions rates are all well below the toxic

screening levels. The MDE Toxic Emission Forms (Form 5A & 58) and back up

calculations are presented in Attachment D.

Water and Terrestrial Related Impacts:

Station Location

The Morgantown Station is located in Charles County Maryland on the northeast

bank of the Potomac River. The Station is 41.5 nautical miles upstream from the

confluence of the Potomac River with the Chesapeake Bay and 53.5 nautical

miles downstream from Washington, D.C. Several small marinas are located


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directly above and below the Station. The U.S. Naval Test Center at Dahlgren,

VA lies directly across the river from Morgantown.

Geomorphology and Flows and Obstructions

In the vicinity of the plant, the Potomac River is approximately 1O,OOO-ftwide. A

navigation channel, located closer to the Maryland bank, is maintained by the

U.S. Army Corps of Engineers. Water depths vary from about 82-ft at mid-

channel to 10-ft at the channel lines. The mean annual freshwater discharge is

approximately 13,400 cfs. The spring tidal flow is approximately 220,000 cfs

downstream during the ebb stage and upstream during the flood stage.

At the Station, a dredged channel, 200 to 260 feet wide and perpendicular to the

intake structure, is maintained out to a distance of approximately 1200 feet. The

channel was originally dredged to 50-ft. Siltation over the years has reduced the

depth at centerline to about 40-ft.

The plant property extends for approximately 1/4-mi long the main stem of the

Potomac River. Fifty percent of this length is hardened with riprap or concrete

structures associate with the facility's intake and outfall. Dolphins are located off

shore where the current barge docking area is, along the intake channel. \

Sheet ice, in general, does not form in the Potomac River near the Station. .

However, sheet ice which has formed in the freshwater portion of the river

upstream of the site near Washington, D.C. does accumulate along the shoreline

at Morgantown.

Siltation is a problem in the Potomac River. In the vicinity of the Morgantown

Station, extensive shoaling has occurred. The siltation can be attributed to a

decrease in river velocity as the estuary widens, allowing suspended particles to

settle.

Vegetated Habitat

A littoral marsh area is located just south of the plant. The emergent species

found there include: Spartina a Itern iflora. S. cynosuroides, S. patens, Atriplex

patula, Eleocharis parvula, Typha angustifolia, Lilaeopsis chinensis, Iva

frutescens, Scirpus american us, S. pungens, S. robustus, Acnida cannabina,

Pluchea purpurescens, Kosteletzkya virginica and Rumexverticillatus.

A Submerged Aquatic Vegetation (SAV) study was performed in the Spring (May

25) and Summer (September 1) of 2004. A kayak was used to paddle transects

of the shoreline from the discharge canal to the mouth of Pasquahanza Creek,

out to a depth of about 6 feet. The only grass beds noted were concentrated at

the mouth of Pasquahanza Creek. The beds continued north along the shoreline

(to 30' offshore in places) for approximately 300 feet from the creek mouth. The

most abundant species in the creek and along the shoreline was Myriophyllum

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spicatum (Eurasian watermilfoil). To a lesser degree, Vallisneria americana (wild

celery) was found mixed in with the milfoil in the creek and along the shoreline.

Floating pieces of Ruppia maritima (widgeon grass) was found tangled in mats of

other debris being pulled towards the Station's intake structure, but no beds of

widgeon grass were noted during the survey.

The project will take place well north of the SAV bed locations and should have

no impact on the vegetation.

Wildlife (fish/shellfish, birds, mammals)

The Potomac River estuary at Morgantown Station falls into both the oligohaline

and mesohaline salinity regimes, depending on the time of the year and flows. A

number of fish and shellfish species are concentrated around the Station. Finfish

are present either as generally permanent residents such as white perch and

gizzard shad, seasonal residents like bay anchovy or juveniles of species

seeking the protection of the estuary like menhaden, or as adults during

spawning runs like striped bass or shad. Blue crab, American oyster and

brackish water clam are the main shellfish found in the area. Fish and shellfish

should not be impacted by this project. The biggest concern for a project such as

this one would be oyster bed disturbances. This area is on the cusp of being too

fresh for oyster production. The closest oyster beds (Pascahana bar) are located

just south of the proposed structure.

Waterfowl are abundant on the Potomac River during the winter months. The

river around the project site is considered by DNR to be a waterfowl staging area.

This project however, shouldn't have any impacts on the present waterfowl use

of the area directly in front of the facility. There are already barges using the site

and any additional lighting, structures in the river and traffic will be concentrated

in these industrial use areas.

There are probably no aquatic or semi-aquatic mammals using the present intake

area where this work is proposed. Beaver, otter and muskrat activities are more

likely concentrated further inland on the site or in the tidal wetlands found in

PasquahanzaCreek.

Recreational Uses (fishing, hunting, boating)

The recreational uses of the Potomac River in the area surrounding the site are

primarily fishing, hunting and boating. There is a good deal of fishing that takes

place in the warm water plume of the facility's discharge. This area is located to

the north of the proposed project and shouldn't be impacted by the proposed

project. Neither will the new construction preclude small craft from being able to

follow the shoreline along Mirant's waterfront.

Hunting for waterfowl is allowed in the Potomac River. There are two blinds

licensed near the facility, both around Pasquahanza Creek. In the past, the

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company purchased the blind rights, but in recent years Mirant has stopped that

practice. The proposed construction and associated extra barge traffic shouldn't

have any impact on this activity.

Recreational boat traffic in this part of the Potomac River is generally not

concentrated. The activities at Dahlgren tend to keep people moving through the

area and there are no attractions such as waterfront restaurants or sandy

beaches that tend to draw boaters, other than the marina at Aqualand, which is

located north of the 301 Nice Bridge. An increase in barges to the facility should

not impede the flow of boat traffic in the area nor will the proposed pier and

conveyor act as a barricade to small craft from hugging the shoreline along

Mirant's waterfront in the case of inclement weather.

Commercial Uses (fisheries, barge traffic)

According to the Potomac River Fisheries Commission (PRFC), the official body

in charge of fisheries on the main stem of the Potomac River, no pound nets are

typically located in the immediate vicinity of the proposed work. There are gill

netters that set up near the facility during the season for that fishery (generally

November through March), although it appears the fishing is more concentrated

around the plant's discharge, north of the proposed work site. Crabbing is

another commercial fishery in the river. Commercial crabbers in the Potomac

River typically use pots and trot lines. Both can be run anywhere outside of the

federally designated channel. The season generally runs from April through

November. It is probable that crabbers work the shallow offshore areas in front

of the Station during the commercial season, although the work proposed should

have little impact on such uses. Commercial oyster harvesting in that part of the

river is nonexistent at this time, according to the PRFC.

Required Permits

The construction of the Barge Unloader requires the submittal of a Joint

Federal/State Application for the alteration of any floodplain, waterway, tidal or

nontidal wetland in Maryland [40 CFR 233 and COMAR 26.23]. The application

is presented in Attachment E. Both Federal and State agencies will review the

permit. On the State level, this permit will be reviewed by MDE. Neither tidal nor

nontidal wetlands will be impacted for this project, but the Department of Natural

Resources will have input on time of year restrictions for the in-stream work to

take place, as well as input on any species of concern that may be in the area. It

is anticipated that the process should be fairly routine.

The Army Corps of Engineers is the Federal reviewing agency and the lead

agency for work in waterways. It is anticipated from conversations with the

Corps that they will make the determination that the work meets the terms and

conditions of the Maryland State Programmatic General Permit (MDSPGP-2).

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The Barge Unloader's onshore construction will take place within the Intense

Development Overlay (100) portion of Morgantown's Chesapeake Bay Critical

Area Plan. The barge unloader's construction and operation conform to activities

allowed in the 100 area. The Morgantown Station has a Critical Area

Conservation Plan in place and a bank of credit for permanent disturbances

within the 100 of the Critical Area. Mirant will update the Critical Area Plan to

include the additional impervious surface created by the Barge Unloader's

construction.

Summary of Additional Impacts-Effects:

Aesthetic Impacts

The Barge Unloader's construction footprint is within an existing developed

industrial zone. There will be minimum additional environmental impacts from

either the construction or operation of the barge unloader. No areas of

previously undisturbed land will be required for the construction of the Barge

Unloader. The bulk of the onshore project development will take place in

Morgantown's existing coal and rail yard. The project will require no increased

water use on the site, or create any new waste products or discharges.

This portion of the Potomac River is developed on both sides. Dahlgren U.S.

Naval Test Center, the Harry Nice Bridge, US Route 301 and multiple marinas all

add to an overall industrial feel to the area surrounding the Morgantown

Generating Station. The addition of the Barge Unloader will have only minimal

impacts on the River's existing view shed and noise levels.

Increased Barge Traffic Impacts

The project will increase commercial river traffic by approximately one barge

round trip per day. This portion of the Potomac River has only limited

commercial water borne traffic. The additional impact on existing commercial or

recreational river traffic in the Potomac River Channel will be minimal.

Construction Impacts

The Barge Unloader will be constructed over an 18-month period. All

construction impacts will be temporary in nature. Construction materials will be

brought to the site by truck, rail or barge. Morgantown's existing transportation

facilities are all capable of accommodating this temporary increase in road, rail or

barge traffic.

There will be increases in storm water runoff from the new facility. The storm

water runoff will be routed to the existing storm water collection system. The

Storm Water Pollution Prevention Plan will be updated to include and identify the

increased potential runoff from the project.

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Economic Impacts

Mirant expects that there will be no increase in employment at the Station for

operating the Barge Unloader. With the Barge Unloader in operation, rail traffic

into the Morgantown Station will decrease. There will no additional road traffic

associated with the operation of the new facility.

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Environmental Review Document