MASON CO. REVISED ENVIRONMENTAL CHECKLISTmyweb.hcc.net/pkands/docs/sepa_checklist.pdf · MASON COUNTY Revised SEPA Checklist ADAGE Mason LLC (ADAGE) Nominal 60 MW Woody Biomass Electric

MASON CO. REVISED ENVIRONMENTAL CHECKLIST

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BACKGROUND

1. Name of proposed project, if applicable:

ADAGE Mason LLC (ADAGE)

Nominal 60 MW Woody Biomass Electric Power Plant

Port of Shelton Lease Area

2. Name of applicant:

ADAGE Mason, LLC

3. Address and phone number of applicant and contact person:

F. Reed Wills

President

225 Wilmington West Chester Pike

Suite 302

Chadds Ford, PA 19317

(610) 358-3404

Jim Gaston

Project Manager

1620 Olympic Highway North

Suite 4

Shelton, WA 98584

(509) 713-0467

4. Date checklist prepared:

The SEPA Checklist for this project was originally submitted on June 28, 2010. This

revised checklist to the original submittal provides additional information to address

questions raised during the review process.

5. Agency requesting checklist:

Mason County Department of Community Development

Barb Adkins

Department Manager

Mason County Building I

411 North 5th

PO Box 279

Shelton, WA 98584

6. Proposed timing or schedule (including phasing, if applicable):

A development process schematic has been provided as Exhibit 1 with information on the

timing of planned construction and startup activities related to the proposed woody

biomass electric power plant.

MASON COUNTY Revised SEPA Checklist



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7. Do you have any plans for future expansion, or further activity related to or connected

with this proposal: If yes, explain.

No.

8. List any environmental information you know about that has been prepared, or will be

prepared, directly related to this proposal.

The following is a summary of the environmental studies that have been completed for

the proposed project. Each study is attached in its entirety as a reference for this SEPA

Checklist.

After the initial SEPA Checklist was filed, ADAGE finalized its real estate rights under

an Option to Ground Lease agreement signed with the Port of Shelton in August 2010.

The project description in the initial SEPA Checklist was based on a significantly larger

project footprint of up 160 acres, which includes the 87 acres. All environmental studies

evaluated conditions across the 87 acre site, and in some cases covered the entire

160 acres originally identified. Please refer to the site map attached with each study for

the specific site boundaries evaluated.

Phase 1 Environmental Site Assessment (ESA) – A Phase 1 ESA was conducted in

October 2009. During the site and area reconnaissance, no ―recognized environmental

conditions‖ as defined by ASTM International (ASTM) standards were identified. Please

see Exhibit 2 for the complete ESA.

Preliminary Geotechnical Engineering Report – A preliminary geotechnical investigation

was conducted in March 2010 to determine if site conditions were suitable for

construction of the proposed facility. The assessment concluded that site conditions

appear geotechnically suitable for construction and on-site infiltration of stormwater

runoff appears to be geotechnically feasible. On-site sand and gravel deposits are

suitable for use as fill material during construction. Please see Exhibit 3 for the complete

document.

Geotechnical Engineering Report: East Capitol Prairie Road Extension – In response to

comments received from Mason County, a second geotechnical investigation was

conducted in August 2010 to assess conditions along the East Capitol Prairie Road

realignment. The investigation found that the native soils in the area consist primarily of

glacial till and outwash soils that are considered stable in their native condition and

suitable for construction of the proposed road extension. The proposed alignment is not

located in a Landslide Hazard Area (LHA) as defined in Title 17 of the Mason County

Code (MCC). The investigation identified a LHA approximately 75 to 100 feet north of

the proposed road as it approaches East Production Road. This distance exceeds the

minimum 50 foot setback required by the MCC. No evidence of instability was observed




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on these slopes. The investigation concludes that the proposal will not reduce LHA

stability. See Exhibit 3A for the complete document.

Archaeological Resources Assessment – An archaeological resources assessment was

prepared to determine if archaeologically or culturally significant items were present at

the Site and, if so, would these resources be impacted by the proposed project. The

Squaxin Island Tribe was notified prior to the start of the project and invited to observe

the field work. No archaeological or cultural resources were identified during the study.

Please see Exhibit 4 for the complete assessment.

Preliminary Biological/Ecological Evaluation – A preliminary biological/ecological

evaluation of the project site was completed in February 2010. The survey indicated that

there are no priority species on the Site or on immediately adjacent property. Priority

species that have been documented in the general area are not likely to occur on the Site

because the Site does not meet habitat requirements for these species. Johns Creek,

located approximately ¾ of a mile north of the Site, is used by several endangered

species of salmon and steelhead. Biologists observed no evidence that the surface water

at the Site is hydrologically connected to Johns Creek or its tributaries. A wetland was

observed approximately 500 to 1300 feet north of the proposed Site on an adjacent parcel

of land within the Industrial Park. A wetland study was conducted to obtain additional

information on the off-site wetlands. Please see Exhibit 5 for the complete results of the

biological/ecological evaluation.

Wetlands Delineation and Mitigation Report - During the biological/ecologic evaluation,

a wetland area was identified on Port property, north of the site. A Wetlands Delineation

and Mitigation Study was conducted in June 2010 to establish the limits of the wetland

and buffer area and to rank the wetland area that would potentially be impacted by

planned road construction. During the study, a field investigation was conducted and the

extent of the wetlands logged and marked. These locations were then surveyed for

inclusion on site plans. The wetland was ranked as a Class III wetland (out of four

classes). On July 29, 2010, a meeting with representatives of the consultant, Washington

Department of Ecology (Ecology), Washington Department of Natural Resources

(WDNR) and Mason County was held at the site to discuss the results of the wetland

delineation survey, wetland classification, and surface water conditions in the

surrounding area. During the meeting the wetland delineation was verified. The wetland

was also determined to have a high intensity use profile and a 150 foot buffer area around

the wetland was established. Following that meeting, two modifications were made to

the original wetlands delineation report. Although, the WDNR Streamtype map indicated

a fish bearing stream in the area surrounding the wetland, during the site visit it was

determined there was no defined channel within in the wetland and no defined channel

leaving the wetland. The report was modified to reflect conditions observed in the field.

This determination supports the conclusion of the Biological Evaluation that concluded

the Site’s surface water is not hydrologically linked to Johns Creek. In addition, on the

basis of discussions during the site visit, the wetland category was changed from a




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Category III wetland to a Category II wetland. Please see Exhibit 6 for the original study.

The amended study is attached as Exhibit 6A.

Traffic Impact Analysis - A traffic study was completed in June 2010 to identify potential

traffic impacts related to the construction and operation of the power plant. The study

was prepared based on Washington State Department of Transportation (WSDOT),

Mason County, and City of Shelton design standards and focused on current roadway

conditions and intersection congestion, forecasts of traffic generated by the proposed

facility, estimates of future delays due to traffic from the proposed facility, and, evaluated

the need for mitigation strategies. The study showed that based on WSDOT design

manual procedures the project will not have significant impacts. Please see Exhibit 7 for

the complete Study.

Traffic Impact Analysis (Revised). The June 2010 Traffic Impact Analysis was revised

to address additional questions raised by the Mason County Department of Public Works.

The study reviewed potential routes for fuel deliveries within the county over the life of

the projects as well as construction delivery routes. In addition, the modeling in the study

was extended from a 5 year to 20 year time frame for evaluating intersection congestion.

The study also analyzes the need for acceleration and deceleration lanes and the need for

a 4-way stop at the intersection of Johns Prairie Road and Brockdale Road. The revised

report confirmed the conclusion that the proposal will not have significant impacts on

traffic, now or over the life of the plant. Please see Exhibit 7A for the complete Study.

Acoustical Analysis - A noise study assessed the proposal’s sound-producing activities,

including handling, chipping and grinding of biomass, power generation, cooling, and

emergency equipment. The study identified noise mitigation techniques to reduce noise

to levels below applicable standards. Further acoustical studies will be performed if

required to ensure that the Site complies with the local standards based on the equipment

and placement of equipment chosen for the final design. Please see Exhibit 8 for the

complete Study.

Addendum to June 3, 2010 Report: ADAGE has modified the original proposal so that

the facility will receive wood that has been processed to 4 inch minus size prior to arrival

at the Site. The extensive modifications to the site design eliminate the need for a

Grinder at the facility on a daily basis. If there is an emergency situation where wood

cannot be processed before delivery to the site, a portable grinder will be brought to the

Site for a limited period of time (limited to 480 hours per year). The proposal was also

modified to include an enclosure around the Wood Hog that is used to process oversized

fuel. The study evaluated a reduction of stack noise based on additional information

from the fan vendor and the potential use stack noise mitigating techniques. The analysis

concludes that county and state regulations will be met during day and night hours.

Please see Exhibit 8A for the additional analysis.




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Economic Impact Analysis – An economic impact study was conducted in March 2010 to

assess the impact on local economies of the proposed facility. The study estimated the

economic impact in Mason and Grays Harbor Counties from additional sales in the local

economy, job creation, and added employee income during construction and operation.

During the planned 30 month construction period the following impacts were projected:

$125 million in additional local sales including $82 million in construction goods and

services, $22 million of indirect sales and $21 million of induced sales.

793 jobs created, with 450 people directly employed in the construction of the plant

plus 152 indirect and 191 induced jobs within the 2-county region.

$42 million in total income with $30 million in wages and salaries paid to

construction workers and supervisors directly at the Site, $6 million from indirect

impacts, and $6 million from induced impacts, all within the local economy.

During facility operations, the following annual economic impacts were projected:

$63 million in total annual sales including $30 million in direct sales, $27 million of

indirect sales and $5.5 million of induced sales all in the local economy.

213 jobs created with 24 jobs in operating and maintaining the plant and 115 jobs

furnishing fuel wood feedstock plus 74 indirect jobs from the operation of the plant

and fuel wood feedstock delivery operations.

$11 million in annual income to workers in the two counties with $3 million from

operation of the plant, $5.6 million from fuel wood feedstock delivery, another $0.9

million from indirect jobs, and an additional $1.6 million in income induced from the

operation of the biopower plant and fuel wood feedstock delivery.

Please see Exhibit 9 for the complete economic analysis.

Best Management Practices Report (BMPR) - ADAGE is committed to protecting human

health and the environment. ADAGE has retained a highly respected local engineering

firm (Robinson/Noble) with specific expertise in the hydrogeology of the Johns Prairie

aquifer to develop Best Management Practices (BMPs) for implementation by ADAGE...

The attached Best Management Practices Report (BMPR) identifies the procedures

ADAGE will take to assure maximum protection of the aquifer. The BMPR includes the

construction and facility Stormwater Pollution Prevention Plan (SWPPP), Emergency

Response Plan (ERP), Spill Prevention and Countermeasures Control Plan (SPCC) along

with other BMPs for the facility. Please see Exhibit 9A for the complete report.




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Additional studies and analyses were conducted as part of ongoing permitting activities

(e.g., air modeling for the air permit submittal). These reports are discussed in the

following sections.

In addition, the following figures provide general information on the site design and

configuration:

Figure 1 shows a process flow diagram.

Figure 2 shows the general site location.

Figure 3 shows the site topography.

Figure 4 shows the site plan and site limits.

Figure 4A shows the cut and fill quantities for the road realignment

Figure 4B shows the cut and fill quantities for the site

Figure 4C shows the power island

9. Do you know whether applications are pending for governmental approvals of other

proposals directly affecting the property covered by your proposal? If yes, explain.

To ADAGE’s knowledge, there are no other applications pending for governmental

approvals of other proposals that will impact the property proposed for the woody

biomass electric power plant.

10. List any government approvals or permits that will be needed for your proposal, if

known.

The attached table, Exhibit 10, summarizes the permitting and approvals required for the

proposed facility along with the current status of each permit/approval.

11. Give a brief, complete description of your proposal, including the proposed uses and the

size of the project and site. There are several questions later in this checklist that ask you

to describe certain aspects of your proposal. You do not need to repeat those answers on

this page. (Lead agencies may modify this form to include additional specific information

on project description.)

Introduction

ADAGE Mason LLC (ADAGE), a limited liability company whose members are

AREVA Renewables Inc (AREVA) and DEGS Biomass, LLC (DEGS), is proposing to

construct a clean woody biomass power plant producing a nominal 60 megawatts (MWs)

of electricity in Mason County Washington, northwest of the City of Olympia. The plant

will be located approximately two miles northeast of the City of Shelton in quadrangles

8 and 9 of Township 20 North, Range 3 West in the Johns Prairie Industrial Park.

On June 28, 2010, ADAGE submitted a SEPA checklist to Mason County describing this

project. In the four months that have passed, the ADAGE project has changed

considerably. This revised SEPA Checklist describes the modified ADAGE proposal and




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incorporates information responsive to comments from the County, interrelated agencies

and the public that were received on the original ADAGE proposal.

Site Selection

This site was selected based on a variety of factors including existing infrastructures, as

well as new infrastructure being constructed in the vicinity of the site. Some of these

critical criteria are listed below:

Access to an existing electrical transmission system that would benefit from local

power generation

Abundant availability of forest residual feedstock;

Existing industrial activity surrounding the project site, specifically forest industry

businesses

Proximity to major roadways to allow fuel supply trucks easy access into and out of

the proposed plant site

Proximity and potential to connect to public water and waste water services

As stated, the Johns Prairie Industrial Park (operated by the Port of Shelton) and the

surrounding area is home to many other forest products companies such as Shearer

Brothers, Simpson Lumber, Belco Forest Products, and McFarland Cascade. In

August 2010, ADAGE entered into an Option to Ground Lease agreement with the Port

of Shelton to lease approximately 87 acres of property within the Park. Prior to

construction the facility must receive a Notice of Construction Order issued by the

Olympic Region Air Quality Agency (ORCAA) that ensures the facility will meet all

state and federal air quality regulations. The ADAGE project must also obtain a number

of other permits including a Mason County Conditional Environmental Permit for

Constructing over a Critical Aquifer Recharge Area and A Special Use Permit for

structures over 45 Feet in height. Permit requirements are summarized in Exhibit 10.

Renewable Energy

The ADAGE woody biomass has been developed in response to Washington’s renewable

energy goals as outlined in Initiative 937. Initiative 937 requires electric utilities that

serve more than 25,000 customers in the state of Washington to obtain 15 percent of their

electricity from new renewable resources by 2020. Investor-owned utilities, municipal

utilities, rural electric cooperatives, and public utility districts are subject to this standard.

These utilities must use eligible renewable resources or acquire equivalent renewable

energy credits (RECs), or a combination of both, to meet the following annual renewable

energy source levels:

At least three percent of its load by January 1, 2012, and each year thereafter through

December 31, 2015

At least nine percent of its load by January 1, 2016, and each year thereafter through

December 31, 2019

At least 15 percent of its load by January 1, 2020, and each year thereafter.

http://www.secstate.wa.gov/elections/initiatives/text/I937.pdf




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Eligible renewable resources include electricity produced from: water; wind; solar

energy; geothermal energy; landfill gas; wave, ocean, or tidal power; gas from sewage

treatment facilities; fuel (must meet specified standards); and biomass energy based on

animal waste or solid organic fuels from wood, forest, or field residues, or dedicated

energy crops. Specifically excluded from the definition of renewable resources are wood

pieces that have been treated with chemical preservatives such as creosote,

pentachlorophenol, or copper-chrome arsenic; black liquor (a byproduct of paper

production); wood from old growth forests; and municipal solid waste.

The inclusion of forest materials in Initiative 937 reflects the voters’ recognition that

forest residuals can make a large contribution to the renewable energy resources in

Washington where working forest are plentiful and wind and solar potential are limited.

Unlike wind and solar projects that have capacity factors between 25 and 35 percent, the

ADAGE clean woody biomass project will produce base load electric generation that will

flow into the grid with typical system availability of 90 percent or better. Base load

energy is beneficial in that it is more easily managed by the electrical transmission

infrastructure than intermittent energy sources such as wind or solar and, therefore, places

less stress on the transmission system. Woody biomass projects help to sustain and grow

the Washington economy due to the hundreds of construction and operations jobs created

for each new biomass project.

ADAGE Biopower

The Plant being proposed by ADAGE is relatively simple. The facility will combust

clean woody biomass in a traditional Bubbling Fluid Bed (BFB) boiler to make steam.

BFB technology is well proven and used at hundreds of locations throughout the United

States and Europe. The steam will pass through a very efficient turbine generator to

make electrical power. In general, the plant is divided into several areas of specific

purpose.

Biomass fuel in 4 inch and smaller size will be delivered to the fuel yard area where it

will be screened for correct sizing and stored for delivery to the boiler. Additional

information about fuel processing and handling can be found in Exhibit 10A.

The Boiler Island houses the steam boiler that combusts the biomass fuel and delivers

steam to the Turbine Island. The Boiler Island also houses the highly efficient air

pollution control systems that treat and clean the flue gases, reducing emissions to

meet stringent health-based state and federal regulations.

The Turbine Island uses steam to spin a generator and make electrical power that is

delivered to the project switchyard and then interconnected through protective relays

to the Bonneville Power Association (BPA) transmission system. The steam

exhausted from the turbine moves through an air cooled condenser (similar to the

radiator in an automobile) where air flow cools the steam back to water which is

pumped back to the boiler and recycled through the process. The system has very

few losses and therefore water requirements at the plant will be minimal.




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Figure 4C shows the facility layout consisting of two main components: the boiler area

(―Boiler Island‖) and the turbine areas (―Turbine Island‖). Exhibit 11 provides a

discussion on the technical aspects of the facility.

The primary fuel for the proposed BFB boiler will be limited to clean woody biomass,

with Ultra Low Sulfur Distillate (ULSD) fuel used only for boiler startup, shutdown and

boiler bed stabilization. The facility’s annual consumption of woody biomass will be

approximately 600,000 green tons of the more than seven and half million green tons of

clean woody biomass generated in the region. The combustion of this fuel will produce

approximately 18,200 tons of wood ash per year. Ultra low sulfur diesel use is expected

to be less than ½ of one percent of the Project/s annual use.

The Plant will produce electricity 24 hours a day, 365 days per year (operating hours)

except for outages. The plant will be operated by Duke Energy Generation Services

(DEGS) which currently operates more than 5100 MWs of power at over 32 different

U.S. facilities. The expected capacity factor of the facility is 90 percent or greater. The

Plant will accept fuel and other deliveries Monday through Friday between the hours of

7a.m. and 10p.m. (receiving hours).

Access to the ADAGE facility will be from the north by way of Production Road. A

recently built but unopened road running through the Site connecting Production Road to

East Capitol Prairie Road will be rerouted to the western portion of the leased property.

A buffer of approximately 300 feet will remain between the re-routed road and the

western Site boundary. Trucks accessing the facility will enter the Industrial Park from




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the north via East Johns Prairie Road. The ADAGE site will have only one ingress and

egress for daily activity although emergency vehicles could enter through an emergency

access gate from the south if necessary.

Eligible Woody Biomass

The ADAGE facility will use the abundant clean, naturally occurring woody biomass

generated from logging and milling activities in Mason County and the surrounding

region. Woody biomass fuel is a commodity that is currently purchased and sold

regularly in the fuel markets that serve Washington users. ADAGE will pay for all of its

fuel. Consistent with this fact, ADAGE will not receive a tipping fee.

The proposed facility will comply with air permitting regulations specific to industrial

boilers combusting wood and wood residues. In April 2010, ADAGE submitted an Air

Permit Application to the ORCAA. The ORCAA permit will stipulate that woody

biomass will conform to the following definition:

Approved Boiler Fuels: The Permittee shall combust only clean woody biomass,

natural gas, propane, and ultra low sulfur diesel fuel. For the purpose of this permit

condition, clean woody biomass means untreated wood or untreated wood products

including clean untreated lumber, tree stumps (whole or chipped), tree limbs (whole

or chipped) and slash. This also includes, but is not limited to, wood, wood residue,

bark, or any derivate fuel or residue thereof, in any form, including but not limited

to sawdust, sander dust, biomass chips, scraps, slabs, millings, shavings, and pallets

made from wood or other forest residues.

Although the air permit application requests the flexibility of installing natural gas,

propane and Ultra Low Sulfur Distillate oil for boiler start-up like functions, ADAGE has

concluded it will use ULSD for this project.

Only fuels listed in the final ORCAA air permit (see definition above) will be allowed to

be combusted in the proposed boiler. ADAGE will have strict operating procedures

(including visual inspection of the clean woody biomass prior to acceptance) that prevent

the use of non-clean woody biomass materials. In the event ADAGE desired to add new

fuels to those accepted for use at the plant, ADAGE would need to initiate a new

permitting process with ORCAA, similar to the public process that is currently ongoing.

ADAGE Fuel Planning, Aggregation, and Delivery

The fuel requirements for the Mason County facility will be secured primarily through

long term contractual agreements with industrial timberland landowners and regional

processors. However, a small portion of the feedstock is expected to be secured under

short term agreements with family foresters in Mason County and the surrounding region.

Feedstock will generally be supplied from resources within a 50 mile radius of the

Shelton site. Several sources including industrial, academic, and government agencies

have analyzed biomass availability and estimated commercial fuel sources to exceed

seven and half million green tons of woody biomass residuals produced annually from




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timber harvesting operations within the economic radius of the Shelton facility. ADAGE

has independently verified a sustainable, recoverable yield of 43 green tons per harvested

acre, based on only 50 percent of the total slash generated being collected. This

economically viable fuel source conservatively exceeds the 35 green ton per acre basis

for ADAGE’s sustainable 20-year fuel plan. Conventional equipment will be employed

to collect, process, load and deliver the woody biomass to the facility.

The fuel for annual plant operations will be gathered and transported from hundreds of

individual plots per year at multiple locations both within and outside of Mason County.

Over the long term the fuel will be transported to the site using essentially the same

transit routes year after year. Please see the Traffic Impact Analysis (Revised)

(Exhibit 7A) for identification of major fuel supply routes for the project.

Specific details on fuels are presented in Exhibit 10A.

Ash Handling, Storage and Shipment

The proposed project will generate approximately 18,200 tons per year of ash

(22,000 tons per year wetted to a 20 percent moisture content). This estimate is based on

numerous studies of the fuel available to ADAGE in the project wood basket. The

facility will produce wood ash which is derived from the burning of clean wood, and

consists of bottom ash and fly ash. Upon initial plant operation the ash will be landfilled

in Klickitat County. ADAGE will apply for a Beneficial Use Determination with Ecology

after initial operation to qualify the ash for a beneficial use. For details, see Exhibit 11A.

Air Emissions Profile

The ADAGE project will result in emissions from the power plant stationary equipment

and from the mobile sources that will frequent the site. Emissions from stationary

sources, the boiler and associated plant equipment, fuel yard conveyors etc. are governed

by the federal and state stationary source air permitting standards designed to protect

human health and welfare. Mobile source emissions are not regulated by an air

permitting process. Mobile source emissions and their impacts are managed by federal

and state transportation standards that ensure protection of the environment through

(i) standards placed on the mobile source fuels and engine design and (ii) emission

control standards. Prior to construction the facility must receive a Notice of Construction

Order issued by the Olympic Region Air Quality Agency (ORCAA) that ensures the

facility will meet all state and federal air quality regulations.

Water and Wastewater

The ADAGE project has been designed to have a very small consumptive water use.

Closed loop cooling systems will be used extensively and therefore water make-up will

be solely for a limited number of process losses. Cooling of steam fully utilized by the

steam turbine power system will be provided by an air cooled condenser unit. Because

no water is required to cool the steam and no particulate emissions result from cooling

tower drift, this unit will provide superior environmental performance compared to

traditional cooling systems. The condensed steam will be recycled through the steam




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generation system dramatically minimizing the requirement for water from the local area.

A power plant of similar size using traditional water cooling would evaporate over

220,000,000 gallons of water per year, while the ADAGE air cooled system will

evaporate zero gallons per year. The air cooled condenser does not have the potential to

emit air pollution.

Potable and process water will be supplied by the City of Shelton’s regional water

distribution system. The plant will utilize approximately 35 gallons per minute (gpm) of

process water; a comparably sized water-cooled system would consume more than

500 gpm. ADAGE’s water consumption will be less than ½ of one percent of the City’s

water system’s current capacity of approximately 7500 gpm. Wastewater (process and

sanitary) will be discharged to the regional wastewater sewer system operated by the City

of Shelton municipal system. The plant will discharge approximately 30 gpm of

wastewater which equates to less than one percent of the City’s expanded treatment

plant’s capacity of 4.4 million gallons per day. Please reference the Utilities section of

the SEPA checklist for additional information.

Emergency Support Equipment

The Plant will include an emergency generator and emergency fire water pump. This

emergency equipment will be supplied and paid for by ADAGE, and fueled with ULSD

fuel oil. The equipment will only operate a limited number of hours (250 hours per year

or less) for testing purposes under normal conditions. This equipment will be fueled by

the same above ground storage tank that will supply the boiler system ULSD burners.

The emergency support equipment ensures that the plant will operate safely even in the

event of an unexpected loss of power. The proposed emergency equipment will be

designed to meet the strict emission limits imposed by NSPS Subpart IIII.

Additional information on emergency support systems at the facility is presented in the

BMPR in Exhibit 9A.

12. What is the location of the proposal? Give sufficient information for a person to

understand the precise location of your proposed project including a street address, if any,

and section, township, and range, if known. If a proposal would occur over a range of

area, provide the range or boundaries of the site(s). Provide a legal description, site plan,

vicinity map, and topographic map, if reasonably available. While you should submit any

plans required by the agency, you are not required to duplicate maps or detailed plans

submitted with any permit applications related to this checklist.

The plant will be located on portions of two parcels in Mason County, in the

southwestern corner of the Port of Shelton’s 400 acre Johns Prairie Industrial Park

located at 500 East Export Road. The proposed power plant will located on

approximately 87 acres (Site) in Sections 8 and 9 of Township 20N, Range 3W. The

facility is located approximately 0.5 miles northeast of the city limits of the City of




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Shelton. Maps showing the location of the facility relative to surrounding features are

attached as follows:

A legal description of the project property is provided in Exhibit 12. The site location is

shown on Figure 2; site topography is shown on Figure 3, and the site layout is shown in

Figure 4.

B. ENVIRONMENTAL ELEMENTS

1. EARTH

a. General description of the site (circle one): Flat, rolling, hilly, steep slopes,

mountainous, other.

The majority of the 87-acre site is relatively flat with small areas where slopes exceed

15 percent. More information on the site topography is provided on Figure 3.

b. What is the steepest slope on the site (approximate percent slope)?

Previous land clearing activities have extensively altered the natural terrain across the

Site. These activities have resulted in two small man-made areas with slopes exceeding

the 40 percent threshold requiring evaluation under the Mason County Resource

Ordinance (MCRO) Section 17.01.100.A.1.f.

In the southeast corner of the Site, an earthen berm was constructed potentially as an

access road or control berm during previous land clearing activities. Side slope

grades along the existing berm are approximately 50 percent in some areas. Land

clearing activities were last performed on the Site in the 1950s and it is believed the

berm was constructed at that time. The existing berm is covered with vegetation and

has been in a stable condition for more than 50 years. The existing berm is located

in a portion of the Site that will be left as a natural vegetation buffer area and will

not be cleared during construction, except to allow for installation, inspection and

maintenance of the perimeter facility fencing. No additional action is proposed in

this area.

In the northeastern corner of the Site, there is a former small borrow pit with slopes

exceeding 100 percent. This area will be filled and stabilized as part of planned

construction activities.

In addition to these man-made features, to the north of the Site is a large natural hill.

The slopes on the southern and western sides of the hill range from 20 to 30 percent, as

shown on Figure 3. The proposed facility will be located south of this hill. The truck

staging area is over 100 feet south of the hilled area. No active work areas are planned

on slopes exceeding 15 percent. These areas will be left in their current state except for




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the minimum amount of clearing and grading required to construct perimeter fencing

and on-site roads. The flat area between the toe of slope and the truck staging area will

be cleared but minimal grading is planned for this area - just enough to allow road

construction. The Mason County Forest Practices Act requires evaluation where

disturbed areas containing slopes exceeding 15 percent are within 200 feet of the Site.

In this instance, no additional protection of this slope will be required for the following

reasons:

The tree clearing operations on sloped areas will be minimal and limited to that

required for installation, inspection and maintenance of the perimeter facility

fencing.

Clearing activities will be conducted at the base of the slope but grading will be

minimal in these areas, just what is necessary for road grading.

The soil throughout this area is free draining and does not appear to exhibit any

seepage, and therefore would not be classified as a Landslide Hazard Area in

accordance with MCRO 17.01.100.A.1.e.

In February 2007, an agreement was reached between the Port of Shelton, Mason

County, and Manke Family Resources (Manke) to construct a road connecting East

Capitol Prairie Road to East Production Road, through the Johns Prairie Industrial Park.

The intent of the new road was to provide greater access for residential traffic from the

south and to allow Manke to expand their sand and gravel operations southeast of the

industrial park by abandoning a section of Capitol Hill Road. The agreement stated that

the road construction was to be completed within four years. Construction plans for the

new road were approved by the Mason County Public Works Department.

In accordance with the agreement, Manke completed the road construction in the

summer of 2010 and the County chip-sealed the road, for which they were reimbursed

by Manke. A permanent right-of-way easement to the County for public access will be

granted by the Port of Shelton and Manke. Once the right-of-way easements are filed

and the roadway is opened, the old Capitol Hill Road will be closed and the right-of-way

will be vacated per the original relocation agreement

The road constructed by Manke bisects the 87-acre parcel which ADAGE has proposed

to lease for the planned development. As part of their lease arrangements, ADAGE has

agreed to relocate a portion of the new road onto other Port property. Only the portion

of the road south of East-West Road will be relocated. The portion of the road north of

East-West Road, which was partially constructed prior to ADAGE’s selection of the

Site, will not be changed. The cost of the rerouted road will be borne by ADAGE and

the road will be constructed in accordance with Mason County specifications. During a

meeting in August 2010 ADAGE, the Port of Shelton and Mason County Public Works

agreed on the final rerouting of the road presented in the Checklist. Exhibit 12A is a

copy of a letter the Mason County Department of Public Works sent to the Mason

County Department of Community Development explaining the relocation of East




Page 15

Capitol Hill Road through the Port of Shelton property. Figure 4A shows the current and

proposed route for the portion of the road that will bisect ADAGE’s property. The road

will carry, on average, an estimated 162 personal vehicles per day.

A geotechnical study was performed in March 2010 to evaluate geotechnical conditions

at the site. A second study was conducted in August 2010 to evaluate geotechnical

conditions along the new route of East Capitol Prairie Road and to assess the potential

impacts associated with the proposed construction. Observations of soil in test pits

excavated during the investigation indicated localized fill and upper native soil layers

(maximum 2 feet) over native sand and gravel till and outwash soils. Glacial soils

extended to the maximum depths of the test pits (10 to 11.5 feet bgs) and to over 35 feet

based on borings results in the original preliminary geotechnical investigation

(Exhibit 3A).

In general, the on-site native soils consist of sand and gravel, with a varying silt content

near the surface and a varying presence of cobbles. These soils are considered generally

acceptable for use as structural fill; however, cobbles and boulders can result in non-

uniform compaction of fill lifts. Cobbles larger than 6 inches in size will be screened out

prior to use as structural fill. The study concluded that the native granular soils observed

along the route will provide suitable support for roadway pavements. It is anticipated that

excavations can be accomplished with conventional earthmoving equipment.

The August 2010 geotechnical investigation (Exhibit 3A) found that the proposed road

extension alignment is not located in a LHA as defined in Title 17 of the MCC.

Approximately 75 to 100 feet north of the northern segment of the road, slopes appear to

be 40 percent or slightly steeper, and would qualify as a LHA. No evidence of instability

was observed on these slopes. Native soils in the area consist primarily of glacial till and

outwash soils that are considered stable in their native condition. The road extension will

be located 75 to100 feet from the top of the LHA slope, exceeding the minimum 50 foot

setback required by the MCC. On the basis of the results of this assessment, the report

concluded that LHA stability is not anticipated to be reduced as a result of the proposed

development based on current plans.

During construction, excavations will be sloped or shored in accordance with local, state

and federal regulations, including current OSHA and WISHA excavation and trench

safety standards. It is anticipated that temporary excavations will require side slopes of

1.5H: 1V or flatter, to maintain slope stability based on observed soil conditions in the

test pits. Unsuitable soils along the route identified during construction will be removed

and replaced with structural fill as needed to bring the site to planned subgrade

elevations.

Permanent cut or fill slopes (e.g., for roadway cuts or embankment side slopes) will be

graded with slopes of 2H: 1V or flatter. Embankment side slopes will be compacted to

the recommended degree to the slope face with no loose soil zone on the slope face. Bare




Page 16

soil areas following construction will be revegetated with grass, shrubs and trees with a

surface covering of bark, straw or other approved material to reduce the potential for

erosion and improve overall slope stability.

Positive drainage will be provided during construction and maintained throughout the life

of the planned improvements. Road subgrades will be crowned or sloped to provide

drainage below the pavement section. Surface runoff into utility trenches should be

prevented during construction.

During road construction, vegetation will be removed in an area approximately 60 feet

wide over the length of the road. Once road construction is complete, disturbed areas will

be stabilized and revegetated.

Following subgrade construction, the road will be paved. The base or top course material

will conform to Section 9-03.9(3) for Crushed Surfacing per the 2010 WSDOT M41-10

manual. Crushed surfacing material will be placed and compacted in horizontal lifts,

using equipment and procedures that will produce uniform moisture contents and

densities throughout each lift. Crushed surfacing will be compacted to at least 95 percent

of the maximum dry density per the ASTM D 1557 test method. Fill lifts will not exceed

ten inches loose thickness.

Overall, the geotechnical study shows that no on-site impacts are anticipated with this

project. No structural mitigation is considered warranted for this project.

c. What general types of soils are found on the site (for example, clay, sand, gravel, peat,

muck)? If you know the classification of agricultural soils, specify them and note any

prime farmland.

No prime farmland will be impacted by the construction and operation of the ADAGE

facility. As part of the preliminary geotechnical assessment of the Site (Exhibit 3), five

borings were advanced to depths between 31 and 61 feet below ground surface. Each

boring was logged and the following summary table prepared describing the various

stratum observed at the Site.

Description

Approximate Depth to

Bottom of Stratum (ft) Material Encountered Consistency/Density

Stratum 1 Varies from 0.5 to 0.8 Topsoil (silty fine sand with abundant

roots) Loose

Stratum 2 Varies from 17.5 to 22.5 Sandy gravel with trace to some silt Medium Dense to Dense

Stratum 3 All borings completed in

this unit except 1

Interbedded fine sand with variable

gravel and silt content and sandy gravel

with trace to some silt

Dense to very dense




Page 17

On-site soils generally consist of sand and gravel deposits with relatively low fines

content. The sand was generally in a medium dense to very dense condition. The Site

has not been used for agricultural purposes and no agricultural soils were found during

the preliminary geotechnical assessment.

In addition, test pits were dug as part of the rerouting of the road (Exhibit 3A). The

result of the test pit observations indicated localized fill (i.e., disturbed soils due to

former activities at the site) and upper native soil layers (maximum 2 feet) over native

sand and gravel till and outwash soils. In general, the native soils consist of sand and

gravel with varying quantities of silt and cobbles. Glacial soils were observed to extend

to the maximum depths of the test pits (10 to 11.5 feet bgs).

d. Are there surface indications or history of unstable soils in the immediate vicinity: If so,

describe.

There is no history of unstable soils in the immediate vicinity of the Site. No indications

of unstable soils were observed during either the Phase 1 ESA or the geotechnical

assessment. In general, the onsite soils appear stable and non-erosive and do not meet

the criteria for Erosion Hazard Areas as defined by MCRO 17.01.104. There was no

evidence of earth movement except on artificial slopes which will be remediated as part

of this proposal (e.g., former borrow pit area). No soils or geological conditions have

been identified which would present a potential danger to public health and safety or to

adjacent properties. No areas of seepage have been observed suggesting the potential for

slope failure. No areas that have the potential for soil liquefaction, stream bank erosion,

or wave undercutting have been identified.

The portion of the County Road that will be realigned will be constructed on similar

soils to that for the power plant, based on test pit observations along the planned route.

No indication of unstable soils has been observed in this area of the Site. The

geotechnical investigation (Exhibit 3A) found that the proposed road extension

alignment is not located in a LHA as defined in Title 17 of the MCC. Native soils in the

area consist primarily of glacial till and outwash soils that are considered stable in their

native condition. Approximately 75 to 100 feet north of the northern segment of the

road, slopes appear to be 40 percent or slightly steeper and would qualify as a LHA. No

evidence of instability was observed on these slopes. The distance between the road and

the top of the LHA slope exceeds the minimum 50 foot setback required by the MCC.

On the basis of the results of this assessment, the report concluded that LHA stability is

not anticipated to be reduced as a result of the proposed development based on current

plans.




Page 18

e. Describe the purpose, type, and approximate quantities of any filling or grading

proposed. Indicate source of fill.

Conventional excavation (cut) and embankment (fill) construction will be required to

relocate organic soils not suitable for subgrade construction and to establish relatively

flat areas for facility development. Due to the existing topography of the site, cut and

fill requirements will be minimal and can be balanced across the site. Cut and fill

quantities will average less than three feet across the site, typical for most site

development projects. Fill soils will be provided from onsite excavations – for example,

organic soils will be used to construct screening berms and other non structural elements

at the site as well as provide topsoil in grassed or landscaped areas.

Grading operations at the Site and for road construction does not meet the definition of

Surface Mining under the state of Washington RCW 78.44.031(17)(d)(i) which states

that ―Surface mining shall exclude excavations or grading used: (i) primarily for on-site

construction. In addition, Mason County has adopted the International Building Code

(IBC). Excavations for construction purposes are excluded as Surface Mining under the

IBC code. No minerals will be extracted from the site.

Grading plans have been developed to balance the cut and fill quantities such that no

off-site disposal or borrow site will be required. The following table provides a

summary of the approximate cut and fills quantities estimated to be required for site

development based on the proposed site plan and cut-fill plan (Figures 4A and 4B).

Area Approximately Quantities

Cut (CY) Fill (CY)

Powerplant and Adjacent Infrastructure 25,500 20,500

Presettling / Biofiltration / Infiltration Ponds 60,000 4,000

County Roadway Construction 15,000 15,000

Fuel Handling Facility and Onsite Roadways 80,000 86,000

Topsoil Berms 55,000

TOTALS 180,500 180,500

f. Could erosion occur as a result of clearing, construction, or use? If so, generally

describe.

ADAGE has identified the site areas that are at risk for erosion and has designed the

construction and operation plans to ensure that no material level of erosion will occur.

During construction, approximately 46.5 acres on the Site will be cleared and graded for

industrial purposes and related uses (such as the topsoil stockpile area). Additional

clearing (approximately 10 acres) will be needed for the stormwater drainage ponds




Page 19

associated with the county road construction. This equates to a total of 56.5 acres that

will be cleared. In Item B.1.b, four areas were identified which have the greatest

potential for erosion:

Southeast corner of site – this area has slopes that exceed 50 percent. The slopes in

this area were constructed approximately 50 years ago and appear stable based on

visual observation. This area will be included in the perimeter buffer zone and will

not be disturbed except for the area required for installation, inspection and

maintenance of the perimeter facility fencing.

Northeast corner of site – this area has slopes that exceed 100 percent. A man-made

burrow pit in this area will be filled as part of site construction to eliminate the

potential for erosion.

North central portion of site (hill) – this area has slopes of approximately 0 to 30

percent within 200 feet of the Site. Currently the slopes are covered with vegetation

and appear stable. The site design (see Figure 4) does not call for clearing or cutting

of these slopes except where it is required for installing, inspecting, and maintaining

the perimeter fencing. The truck staging area and perimeter access road will be

located over 100 feet south of the base of this slope. Approximately 1 acre will be

cleared for on-site road grading within 100 feet of the base of the slope.

North of the site - As discuss in B.1.b, approximately 75 to 100 feet north of the

northern segment of the rerouted road, slopes appear to be 40 percent or slightly

steeper and would qualify as a LHA. No evidence of instability was observed on

these slopes. The road extension will be located 75 to100 feet from the top of the

LHA slope, exceeding the minimum 50 foot setback required by the MCC.

Due to the relatively flat existing grades across most of the Site, the potential for erosion

during construction is minimal and can be controlled with the use of BMPs for erosion

control as presented in the Construction Stormwater Pollution Prevention Plan (SWPPP)

within the BPMR (in Exhibit 9A). Due to the steep slopes along the road re-alignment

additional care will be taken during construction. Disturbed areas will be stabilized by

revegetating as soon as possible after completion of construction activities in that area.

Similar conditions will apply to portions of the Port property impacted by utility and

road construction.

Operations will be limited to developed areas of the Site and will not pose an erosion

risk.

g. About what percent of the site will be covered with impervious surfaces after project

construction (for example, asphalt or buildings)?

The following is a breakdown of the approximate areas of impervious surfaces based on

the site plan shown in Figure 4.




Page 20

Site Area Acres Percentage1

Powerplant Roof Cover: 2 2.3%

Powerplant Onsite Circulation/Access: 2 2.3%

Solid Fuel Storage Area: 3 3.4%

Fuel Handling Covered Area (Conveyors & Other

Structures): 3 3.4%

Fuel Handling Traffic Area: 3 3.4%

Administrative Parking Area: 0.5 0.6%

Truck unloading Area (drive through dumpers): 0.1 0.1%

Stormwater Pond Areas (including surrounding berms): 5.9 6.8%

Total Impervious Surfaces: 19.5 22.4% 1Based on total 87 acre site

The proposed County Road is not included in the above total. A portion of the road will

be located on part of the 87 acre Site being developed and will encompass

approximately 2.8 acres of impervious surface as summarized below.

Off-Site Roadway Area Acres

E. Capitol Prairie Road (Perimeter): 2.0

E. Capitol Prairie Road (Offsite Connector Road): 0.8

Total Impervious Surfaces: 2.8

h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any.

The greatest potential for erosion will occur during construction, prior to site

stabilization. The use of BMPs to prevent and contain erosion will be included in the

contract requirements for the selected Contractor. Prior to the start of construction, the

Soil Erosion and Sediment Control Plan and Construction SWPPP contained in the

BMPR (Exhibit 9A) will be updated based on the final design. These documents

identify the steps that will be taken to control erosion and sedimentation during each

phase of construction. The Contractor will be required to provide BMPs for each stage

of construction, including road construction, including practices such as sediment traps,

check dams, stabilized construction entrances, storm inlet protection, silt fencing,

mulching, or other means of protection.

Prior to the start of construction, the Site will be cleared in accordance with the Port’s

Forest Management Plan. The project will disturb land to convert timber land to other

uses and is therefore subject to the requirements for Class IV Forest Practices. Slopes

which are to be undercut will be stabilized. Stormwater SWPPPs will include temporary

measures to stabilize soils including steep slopes. Steep slopes will be cut back to stable




Page 21

grades, jute matting will be installed, seed and fertilizer will be applied to revegetate

disturbed soil, and other soil stabilization measures will be taken as appropriate.

If, during construction, unstable soil conditions are identified, steps will be taken to

stabilize the area in accordance with MCRO 17.01.100 for Landslide Hazard Areas and

MCC 17.01.104 for Erosion Hazard Areas. The Soil Erosion and Sediment Control Plan

will be modified to address the newly observed conditions.

The potential for erosion is limited during operations. Disturbed areas will be stabilized

during construction and maintained during operations as discussed in the BMPR. High

traffic areas will be paved/seal coated to stabilize the soils. Stormwater runoff will be

diverted to on-site sedimentation basins.

2. AIR

a. What types of emissions to the air would result from the proposal (i.e. dust, automobile,

odors, industrial wood smoke) during construction and when the project is completed?

If any, generally describe and give approximate quantities, if known

Air emissions during construction

Environmental impacts will be minimized by hiring only contractors that adhere to best

management practices. These practices include, for example, limiting airborne

emissions of dust during site-grading and related activities via frequent watering of

exposed surfaces. Disruption of local traffic will be kept to a minimum, thus

minimizing emissions from local vehicles. More generally, federal, state, and local

regulations and ordinances will be adhered to, and construction-time will be kept to the

minimum, consistent with the goals of efficient and safe site development.

Air emissions during operation

The project will result in air emissions from the power plant’s stationary equipment, on-

site mobile equipment, and fugitive sources. These emissions have been described and

quantified in the permit-application to ORCAA and will be kept to a minimum,

consistent with federal and state air permitting requirements. Emissions from off-site

vehicles are not regulated via air permitting, but these impacts were evaluated in a

supplemental analysis, as summarized below and described in more detail in

Exhibit 12B.

Three agencies have jurisdiction over the ambient air in the proposed project area: the

U.S. Environmental Protection Agency (EPA), the Washington State Department of

Ecology (Ecology), and the Olympic Region Clean Air Agency (ORCAA). ADAGE

has applied for a Notice of Construction (NOC) permit from ORCAA; this application

demonstrates compliance with Washington’s General Regulations for Air Pollution

Sources, WAC 173-400, and WAC 173-460, Controls for New Sources of Toxic Air

Pollutants. The application and information regarding ORCAA’s review are available at




Page 22

http://www.orcaa.org/news-and-information/public-involvement/notice-of-application-

received/ADAGE-mason-county/

ORCAA requested that ADAGE provide additional information regarding how the

project would comply with the requirements of Washington’s fossil fuel CO2 Mitigation

rules and Best Available Control Technology for fine particulate matter (PM2.5). In

conjunction with the PM2.5BACT analysis, the estimates of maximum potential

emission rates for PM, PM10, PM 2.5, and sulfur dioxide (SO2) were updated. The

following table summarizes the addenda that ADAGE submitted following the initial

application. Copies of these materials are provided in Exhibit 12B.

Submittal

Date

Document Title Subject

June 21, 2010 ADAGE Mason - TAPs update (2010-6-

21).pdf

Revision to Table 2-17

June 29, 2010 Addendum 0106292010_Mason.pdf Revised SO2 emissions and HCl

compliance approach

July 13, 2010 Addendum 0207122010_Mason..pdf PM2.5 BACT Evaluation

September 20,

2010

ADAGE Mason LLC CO2 Mitigation

Plan 09202010.pdf

ADAGE CO2 Mitigation Plan

September 29,

2010

ADAGE_Mason_AERMOD_Results_S

ummary-SO2_1hr.pdf

Potential 1-hr SO2Impacts

September 30,

2010

ORCAA 093010 signed.pdf Updated PM10 and PM2.5 Emission

Rates

The following table lists the maximum potential emissions from the project, as provided

in the NOC application, with updates for PM, PM10, PM2.5 and SO2, as described in

the addenda.

http://www.orcaa.org/news-and-information/public-involvement/notice-of-application-received/adage-mason-county/

http://www.orcaa.org/news-and-information/public-involvement/notice-of-application-received/adage-mason-county/




Page 23

Estimated Potential to Emit (PTE) Criteria Air

Pollutants (tons per year)

Source Operation PM PM1

0

PM2.5 NOx SO2 H2S

O4

CO VOC Fluori

des

Woody Biomass

Fluidized Bed Boiler

66.4 66.4 66.4 232.4 83.0 4.0 245.7 33.2 4.7

Woody Biomass

Handling and Processing

1.33 0.63 0.1 -- -- -- -- -- --

Fly Ash Handling 0.05 0.02 0.003 -- -- -- -- -- --

Boiler Support Material

Handling

1.67 0.79 0.12 -- -- -- -- -- --

Portable Biomass

Grinder/Chipper

Combustion Emissions

0.2 0.2 0.2 6.91 0.003 2.24E

-04

1.58 0.2 --

Emergency Generator &

Storage Tank

0.02 0.02 0.02 0.4 0.001 0 0.4 0.4 --

Emergency Fire Pump

& Storage Tank

0.01 0.01 0.01 0.2 0.06 0 0.2 0.2 --

Project Total PTE

Excluding Fugitive

Sources

69.7 68.1 66.9 239.9 83.1 4.0 247.9 34.0 4.7

Fugitive Source

Operation

PM PM1

0

PM2.5 NOx SO2 H2S

O4

CO VOC Fluori

des

In-plant Paved Roads 24.9 4.8 0.7 -- -- -- -- -- --

Portable and Stationary

Biomass

Grinder/Chipper

Emissions

11.91 0.6 0.3 -- -- -- -- -- --

Woody Biomass Pile

Processing

1 0.05 0.01 -- -- -- -- -- --

Woody Biomass Pile

Wind Erosion

0 0 0 -- -- -- -- -- --

Total Fugitive Source

PTE

37.8 5.5 1.0 0.0 0.0 0.0 0.0 0.0 0.0

Project Total PTE

Including Fugitive

Sources

107.5 73.5 67.9 239.9 83.1 4.0

247.9 34.0 4.7

Notes:

(a) The proposed boiler will be capable of using natural ultra low sulfur distillate fuel for startup, shutdown, and bed

stabilization purposes, and will use woody biomass for normal operations.

(b) Tons per year (TPY) emission estimates are based on a boiler heat input of 758 MMBtu/hr and maximum allowable

emission factors in lbs/MMBtu.




Page 24

According to U.S. EPA’s Prevention of Significant Deterioration (PSD) program, the

proposed project is classified as a Minor Source. As such, per EPA, an ambient air

quality analysis for project-related impacts is not required. However, we have followed

the State of Washington’s more stringent rules, and so performed such an analysis,

which demonstrates compliance with all applicable air quality standards. For details,

please see the NOC Application.

With respect to green house gas (GHG) impacts, the proposed facility would create a

418,000 ton per year credit to the atmospheric carbon pool, due both to the replacement

of fossil-fueled power-generation with renewable-source power-production, and to the

avoidance of emissions that would occur if the biomass were instead allowed to decay

without energy-capture. The GHG analysis is presented in Exhibit 13.

Off-site Emissions from Mobile Sources

ADAGE evaluated emissions from the off-site, on-road vehicles expected to service the

proposed facility. The evaluation indicated that, primarily due to the implementation of

federal regulations on diesel fuel and diesel trucks, emissions from all motor vehicles in

the County and the City of Shelton will decrease over time, regardless of whether the

proposed facility is built and operated. The evaluation also indicated that ADAGE-

vehicle-related incremental impacts to ambient air at specific locations of interest - such

as schools, ball fields, and health-care facilities - would, be quite small. Indeed, air

quality at these locations is generally good — even when meteorological conditions are

poor, such as during inversions — and emissions from ADAGE-related vehicles would

not change this situation. The complete study can be found in Exhibit 12B.

Emissions from Idling Trucks

From time to time, fuel delivery trucks may arrive at the Site before the facility is open

for deliveries, and may idle within the plant’s staging area. ADAGE will take

reasonable measures to reduce truck-idling times and emissions associated therewith.

Signs will be posted indicating good idling practices, and ADAGE will enforce these

practices. To ensure that PM2.5 emissions from idling trucks will not generate an

unacceptable impact, ADAGE evaluated daily and annual idling-related impacts to

ambient air from fuel trucks. The analysis assumed, conservatively, that trucks idled for

10 minutes. Impacts at the schools and other local facilities of interest were evaluated as

described and depicted in the graphic in Exhibit 12B. This evaluation indicated that

emissions from trucks idling at the ADAGE site would not significantly affect air

quality at these locations. As noted above, in general, the air quality is currently quite

good.

Emissions from the Collection of Biomass

The proposed ADAGE project does not encompass the physical activities directly

associated with supplying the biomass fuel. ADAGE will contract with large industrial

land-owners for exclusive rights to retrieve slash materials from the harvest units that

the owners log. ADAGE will also contract with fuel suppliers that specialize in fuel




Page 25

production and/or fiber supplies. The suppliers will gather, process, and deliver the fuel

from the land owners and other sources.

A significant fraction of the ADAGE fuel will originate as slash materials generated

during logging and reforestation activities that currently produce saw timber and

pulpwood for the Washington fiber markets. Some of the slash will be ground into fuel

at the landing and transported from the forest in chip vans. Some slash will be

transported in bulk form to fuel production facilities where slash will be processed to

hog fuel that serves the wood boiler fuel market. In addition, some ADAGE fuel will

come from pulp chip plants that generate pulp chips and bark, with the bark portion

supplying the wood fuel market.

Emissions from fuel processing

Some of the fuel will be processed by electric devices and some by in-woods diesel-

powered mechanical processors. The flow of fuel from the industrial timberlands

surrounding the facility will be diverse, since the harvest units vary in size, species mix,

and age across the six-county supply-region. A typical logging operation harvest unit is

60 to 80 acres and may take two to three months to log. The slash collection and

processing will cumulatively take only several weeks. Because the supply of materials

will come from various points in a wide geographical area, the incremental diesel

emissions associated with collecting and processing the fuel will be a small fraction of

the emissions generated by current operations within harvest units. In addition, the

increasingly stringent federal regulations with regard to diesel fuel and diesel engines,

for both on-road and ―non-road‖ vehicles will result in substantially smaller amounts of

emissions from all sources over time. The expected effects of these regulations are

depicted below.




Page 26




Page 27

Impacts of Emissions with regard to Acidity of Precipitation and Water-bodies

ADAGE evaluated the maximum potential from the proposed facility to increase the

acidity (that is, reduce the pH) of precipitation and/or local surface waters. The

evaluation encompassed impacts from emitted hydrogen chloride (HCl), hydrogen

fluoride (HF), and sulfuric acid (H2SO4), as well as impacts from:

Sulfur dioxide (SO2), which can form sulfuric acid (H2SO4),

Nitrogen dioxide (NO2), which can form nitric acid (HNO3)

Carbon dioxide (CO2), which can form the weak acid, carbonic acid (H2CO3).

As detailed in Exhibit 13A, the analysis indicated that the pH of precipitation and

surface waters would not be significantly altered by the proposed facility, nor would

there be a significant increase in local concentrations of CO2.

Dust Control

The woody biomass utilized by ADAGE would average between 35 and 55 percent

moisture content. Woody biomass in this moisture range will not generate significant

quantities of dust when unloaded from trucks, transferred by conveyor or handled by the

front end loaders. Conveyers will be covered to prevent fugitive dust emissions. The

majority of the woody biomass handled on-site will be relatively large in size (4 inches

by ¼ inch). A limited number of fines, typically less than 10 percent, will be present but

these fines will be moist and mixed with larger biomass such that they are not expected

to blow from the storage piles in the wind or as they are handled. In the unlikely event

that fugitive dust from the handling of wood in the storage piles was to become an issue,

the pile or operation can be dampened with water to control dusting.

A more significant potential for fugitive dust emissions is related to the dust produced

from paved and unpaved roadways by the tires of fuel delivery trucks. The major roads

and areas frequented by trucks will be paved. Paved roads produce less dust than

unpaved roads. Additionally, techniques such as wetting or sweeping will be employed

as necessary to control road silt on the facility property.

The emissions of fines from the fuel handling system and road silt from truck traffic are

called fugitive emissions, and ADAGE has studied the impact of fugitive emissions in

the Ambient Air Quality modeling analysis submitted to ORCAA. The analysis

indicates that fugitive emissions will not have a significant impact on air quality.

Odor Control

The ADAGE facility is an industrial electric-generating facility using wood as fuel. The

facility will not use, manufacture or release chemicals that cause odors past the site

borders as might be associated with pulp and paper production, or from saw mills or

panel board manufacturing plants. Poorly managed woody biomass fuel has been a

source of odor at biomass facilities in some instances. The majority of the ADAGE

wood supply will arrive as pre-processed biomass and will be stored under cover and out




Page 28

of the weather. Most often the woody biomass fuel will be turned over in a time frame

of less than two weeks. For the majority of the operating year, processed fuel (chipped

or ground to 4 inches and smaller pieces), will be delivered to the covered storage area

that will house up to seven days of fuel. The covered storage area will feed the boiler

continuously and therefore the fuel will turn over on a very regular basis. An outdoor

uncovered storage area will be utilized from time to time to meet supply and usage

schedules, or when the covered storage is unavailable. This fuel will be groomed into a

pile(s) by front end loaders or similar equipment and fed directly to the boiler storage or

the covered storage areas. ADAGE has discussed outdoor fuel pile management and the

plant in general with the Mason County emergency response officials and has

incorporated their suggestions into our fuel yard design and operational plans.

Storage areas, outdoor and under cover, will be managed to control dust and odors.

Odor problems do not typically occur in properly managed wood piles. Odor is

typically associated with decay and normally occurs in piles that are not turned over in a

timely fashion. Significant decomposition of stored processed biomass (which can

cause odor issues and high internal pile temperatures) typically does not occur in the

first 90 days of storage. Many biomass facilities have relied on processed fuel storage

volumes equivalent to months and even as much as a year’s worth of operation.

Processed wood fuel at the ADAGE site will be utilized on a first-in, first-out basis to

the extent possible, and on-site processed biomass storage will normally not exceed 30

days, greatly reducing any potential for fire hazards or odor issues. Decomposition also

reduces the energy value of the biomass material, and it is therefore in the best interest

of the facility to ensure that this does not occur. The proposed facility will provide base

load power and will operate continuously except for occasional maintenance outages.

ADAGE does anticipate storing small volumes, up to seven days, of unprocessed

biomass in solid form at a designated area on site. This material, broken tree parts,

chunks, butts, slash bundles, etc., will be utilized on an infrequent basis to bridge gaps in

the processed fuel supply chain. The material would be ground when necessary by

portable equipment and managed in the processed storage systems in a similar fashion to

the biomass that arrives routinely by truck. Unprocessed solid woody materials can be

stored for a year or more before appreciable decay and potential odors arise. ADAGE

will turn this material over on a routine basis (annually is expected) to insure the fuel is

utilized before it degrades and loses value.

b. Are there any off-site sources of emissions or odor that may affect your proposal? If so,

generally describe.

No, there are no such sources that would affect our proposal. The proposed plant is

located in an industrial area that includes other existing emission sources; no emission

interaction is anticipated from the proposed plant with these nearby emission sources.

The proposed plant will be using the Best Available Control Technology (BACT) to

minimize emissions, thus minimizing the potential air quality impacts on the




Page 29

surrounding environment. The Mason County area is currently in attainment for state

and federal air quality standards. On the basis of the modeled maximum impacts from

the proposed facility and existing background concentrations, the facility will not result

in noncompliance with these standards.

c. Proposed measures to reduce or control emissions or other impacts to air, if any.

Other impacts to air will be reduced and controlled as follows. ORCAA is the

governing body that reviews new sources in Mason County. Per ORCAA Rule

6.1.4(a)(2) ―Requirements for Approval,‖ new stationary sources in an attainment or

unclassified area must employ Best Available Control Technology (BACT) for

pollutants not previously emitted or whose emissions would increase as a result of the

new stationary source. BACT as defined in ORCAA Regulation 1, Rule 1.4 and WAC

173-400-030, is as follows:

Best Available Control Technology (BACT) means an emissions

limitation based on the maximum degree of reduction for each air

pollutant subject to regulation under chapter 70.94 RCW emitted from,

or which results from, any new or modified stationary source which the

permitting agency, on a case-by-case basis, taking into account energy,

environmental, and economic impacts and other costs, determines is

achievable for such stationary source or modification through

application of production processes and available methods, systems,

and techniques, including fuel cleaning, clean fuels, or treatment or

innovative fuel combustion techniques for control of such air pollutant.

In no event shall application of the best available control technology

result in emissions of any pollutants which would exceed the emissions

allowed by any applicable standard under 40 CFR Part 60, Part 61,

and Part 62. Emissions from any stationary source utilizing clean fuels,

or any other means, to comply with this paragraph shall not be allowed

to increase above levels that would have been required under definition

of BACT in the Federal Clean Air Act as it existed prior to enactment of

the Clean Air Act Amendments of 1990.

In addition, WAC 173-400-113(1) and ORCAA Regulations Rule 6.1.4(a)(1) require

new sources of air pollution that emit toxic air pollutants (TAPs) to comply with the

requirements of Chapter 173-460 WAC, also known as the Washington Air Toxics

Regulation. The requirements of WAC 173-460 are applicable to projects that result in

an increase in emissions of any TAP above de minimis levels. The BACT analysis is

presented in the NOC Application.

At the request of ORCAA, ADAGE performed an additional BACT evaluation

specifically for PM2.5, as detailed in Exhibit 13B. ADAGE also performed a Toxic Air

Pollutant Analysis, as detailed in the NOC Application.




Page 30

The proposed bubbling fluidized bed (BFB) boiler will utilize a combination of proven,

reliable and state-of-the-art air pollution control devices and techniques to minimize

emissions of air pollutants. Individual pollutants and groups of pollutants will be

controlled as follows.

NOx Control – The BFB Boiler will employ Selective Catalytic Reduction (SCR)

technology which is the most effective post-combustion control available for a solid

fuel-fired boiler. The SCR utilizes 19 percent aqueous ammonia and a catalyst (similar

to a catalytic converter on an automobile) to destroy NOx by breaking it down into

elemental N2 and water vapor. The BFB with SCR system will achieve a nitrogen oxide

(NOx) emission limit of 0.07 lb per MMBtu based on a 30 day average. A large

component of NOx (called Thermal NOx) arises from the breakdown and subsequent

reaction of nitrogen (N2) and oxygen (O2) in the combustion air. A BFB boiler operates

at a lower combustion temperature than conventional boilers, which minimizes the

production of thermal NOx during the combustion process. Staging the combustion air

within the boiler furnace also reduces the production of thermal NOx. The inherently

low NOx coming from the BFB and the destruction of NOx provided by the SCR system

results in extremely effective NOx control. It is ADAGE’s belief that the permitted

NOx emissions from the ADAGE boiler will be lower than any other permitted woody

biomass boiler in the state of Washington and that this will be the first biomass boiler in

the state of Washington to use SCR as a control device.

CO, VOCs, and organic HAPs – Carbon monoxide (CO), volatile organic compounds

(VOCs), and various hazardous air pollutants (HAPs)1 are emitted from combustion

sources as a result of incomplete combustion of fuel. Emissions of these air pollutants

are effectively controlled by well-designed combustion systems maintaining good

combustion practices. The bubbling fluid bed design results in the lowest CO, VOC, and

organic HAP emissions of any of the combustion systems typically employed on moist

woody biomass. The addition of sand to the combustion chamber helps maintain high

temperatures during fuel variations. The flow of air through the bed, and the turbulence

created very effectively, exposes fuel surfaces to oxygen promoting very clean and

efficient combustion.

Particulate Matter (PM) and Acid-Gas Control – Emissions of PM will be controlled

by a series of fabric filters known as a baghouse. Baghouses are among the most

effective and widely used control devices for PM, especially for microscopic particles

such as PM2.5. In a baghouse, flue gases flow through multiple chambers that contain

arrays of filter bags supported by wire cages. The flue gases flow through the bags,

1 Hazardous Air Pollutants (HAPs) are pollutants that, at sufficiently high concentrations in air, can harm health.

The specific chemicals and mixtures that are considered to be HAPs are tabulated in section 112 of the federal Clean

Air Act. Small concentrations of HAPs, such as are present in Washington, are neither known nor expected to harm

health; and incremental impacts from the proposed facility will not alter this situation.




Page 31

depositing ash on the outside while clean gas passes through to the inside. Intermittently,

and in a controlled fashion, the bags are pulsed with compressed air, so that the ash is

dislodged from the outside of the bag and dropped into hoppers whence it is vacuumed to

a storage silo.

The technology being proposed by ADAGE for PM2.5 control is considered the best

available control technology (BACT). The fabric filter bags are designed for maximum

longevity and resistance to deterioration while providing optimum pore size and fly-ash

cake build-up characteristics that are highly effective. An enhanced bag design was

selected because it provides the best combination of thermal resistance and filtration

efficiency.

Combustion of wood, as of other fuels, produces trace amounts of acidic compounds,

such as hydrogen chloride (HCl), hydrogen fluoride (HF), and sulfuric acid (H2SO4).

The bulk of the ash generated by wood combustion, however, is alkaline, which serves to

neutralize these acid-gases and aerosols as they come in contact with ash in the baghouse.

In the event that the naturally alkaline ash fails to adequately neutralize acid gases,

ADAGE will employ a Dry Sorbent Injection System (DSI) that will enhance the

alkalinity in the filter cake by injecting mildly alkaline powders (sorbents) into the flue

gas stream ahead of the fabric filter. The DSI sorbent will likely be trona (sodium

carbonate); limestone and sodium bicarbonate powders are also commonly used sorbents.

Trona is a non flammable, mildly alkaline mineral and not expected to be hazardous to

the environment or aquatic life (MSDS). The trona will be stored in a steel silo located in

the interior of the power plant on impervious surface which will serve as secondary

containment. Trona will be delivered by truck and pumped into the storage silo using a

pneumatic feed system. The silo will be equipped with either a vent filter or other

particulate matter control device to control dust when loading. Spills to the ground will

be handled by the appropriate procedures. The silo area surfaces will drain to the plant

sewer systems that will flow to the City of Shelton systems to prevent ground water

contamination.

The BFB boiler, baghouse technology, NOx reduction technology and clean woody

biomass fuel combine to form a system that maximally mitigates impacts from acid gases

and from precursors of atmospheric formation of PM2.5.

Emission Monitoring and Compliance Methods – Emission monitoring and

compliance requirements are imposed by state and federal air statutes, as well as by the

ORCAA and Ecology regulations to ensure compliance with state and federal air

regulations. The following continuous emissions monitors (CEMS) will be required by

the project to ensure requirements are met;

NOx - Oxides of Nitrogen

CO - Carbon Monoxide




Page 32

SO2 - Sulfur Dioxide

COMS - Continuous Opacity monitor (COM)

ADAGE will also be using best management practices (e.g., paving of plant roadways

and covered wood conveyance systems) to minimize the generation of fugitive PM

emissions.

Ambient Air Impacts at Maximum Impact Points and other Locations, such as

Schools

As noted above, the State of Washington requires an ambient air quality impact

assessment for stationary sources of air pollutants. ADAGE performed this analysis and

presented it in detail in the NOC Application. The following is a summary of the

analytical method and the results of the analysis of impacts at local schools and other

nearby locations.

The air quality impact analysis was performed using tools and procedures developed by

USEPA and ORCAA. In particular, ADAGE used a sophisticated, computerized, air-

emissions dispersion model - namely AERMOD, which is an acronym for the American

Meteorological Society/ Environmental Protection Agency Regulatory Model. The

analysis was based on the following assumptions:

Reasonable worst-case emission rates from the proposed facility

Impacts at more than 3,400 separate locations, including along the property

boundary, in the adjacent neighborhood, and farther afield

Meteorological data from every hour of every day for five years (the years 2004-

2008), as measured at Sanderson Field

Worst-case facility-related impacts to existing background concentrations, as

reflected by measured concentrations at local air quality monitoring stations or other

suitable sites.

The results of this analysis indicated that the facility would cause no exceedences of air

quality standards.

The modeling used over estimates the expected impacts, even at the maximally affected

location, and so, by definition, at locations that are less-than-maximally affected. This

overestimation is intentional since, as is the case here, when overestimated impacts at

the maximally-affected location are acceptably small, then it follows that actual impacts

at this and other locations will be smaller still, and so result in no significant effects on

air quality. Moreover, the use of local meteorological and topographical data ensures

that conditions such as inversions and other less-than-optimal dispersion conditions are

automatically and intentionally accounted for.

To further demonstrate this point, ADAGE evaluated and graphed below, the maximum

PM2.5 impacts from the boiler emissions at various locations of particular interest, such

as at nearby schools and health-care facilities. Shown in the chart are the maximum




Page 33

modeled impacts for PM2.5 at these locations, during both the worst-case 24 hours and

worst-case year. Note that, as expected, impacts at the schools and other locations are

much smaller than impacts at the location of maximum impact. Recall that no such

maximum-location impacts, as demonstrated in the NOC Application, would result in

exceedances of the National Ambient Air Quality Standards.

Overall, then, the proposed facility will not adversely affect air quality. Moreover, once

the plant is operational, ADAGE would be required by ORCAA to follow strict

procedures to measure, monitor, and report emissions to demonstrate compliance with

the requirements established by the air permit. ORCAA is responsible to monitor

ADAGE performance and ensure compliance with any and all permitted requirements.

Maximum 24-hour PM2.5 Concentrations

0

5

10

15

20

25

30

35

40

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Woody

Biomass Boiler

Impacts

Background

Concentration

NAAQS




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Maximum Annual PM2.5 Concentrations

0

2

4

6

8

10

12

14

16

She

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Woody

Biomass Boiler

Impacts

Background

Concentration

NAAQS

Worst-case 24-hour and annual air PM2.5 concentrations for eleven locations depicted

on the map above due to measured background levels and from ADAGE woody biomass

boiler. As shown, all concentrations are well below the National Ambient Air Quality

Standards (NAAQS).

3. WATER

a. Surface

1. Is there any surface water body on or in the immediate vicinity of the site (including

year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe

type and provide names. If appropriate, state what stream or river it flows into.

There are no surface water bodies on the parcel or within 500 feet of the Site.

The biological survey (Exhibit 5) identified a wetland area approximately 500 to

1300 feet north of the planned facility location. This wetland area was delineated

and ranked in a Wetland Delineation and Mitigation Study conducted in June 2010

(Exhibit 6). Following a meeting at the site with representatives of Ecology,

WDNR, and Mason County, the study was amended to address information

developed during the meeting (Exhibit 6A). Two modifications were incorporated

into the document:




Page 35

The WDNR Streamtype map indicated a fish bearing stream in the area

surrounding the wetland. The site visit determined there was no defined channel

within the wetland and no defined channel leaving the wetland; the report was

changed to reflect these facts. This determination supports the biological

evaluation’s conclusion that the site surface water does not flow into Johns

Creek.

The wetland category was also changed from a Category III wetland to a

Category II wetland.

The identified limits of the wetland are shown on Figure 4. The wetland is separated

topographically from the Site by a large hill. Operations at the proposed facility will

not impact this area. The wetlands observed are not connected to any surface water

flows, either on or off site.

The next closest surface water body is Johns Creek, located approximately ¾ of a

mile north of the Site, which flows into Oakland Bay. The proposed project does not

include any surface water discharges to Johns Creek and will have no impact on this

water body. Figure 5 shows the location of Oakland Bay and Johns Creek in relation

to the project site.

The road realignment will be located approximately 250 feet south of the identified

wetland area. Based on the site topography, surface water from the road will be

diverted away from the wetland area and will not impact the wetland (Figure 4).

2. Will the project require any work over, in, or adjacent to (within 200 feet) the

described waters? If yes, please describe and attach available plans

No

A key issue in the original SEPA Checklist submittal was the proposed road

realignment through the wetland and buffer area, and the potential impact of that

road on the wetland. Additional information was requested in a number of areas. As

shown in Figure 4, ADAGE has revised the site layout to modify the design of the

road south of East-West Road. The revised road route will not cross either the

wetland or the wetland buffer area.

The addendum to the wetland delineation study is attached as Exhibit 6A. The

July 29, 2010 meeting confirmed the location of the wetland and buffer area, as

shown on Figure 5.

Only the portion of the road south of East-West Road (the portion on the ADAGE

site) will be relocated. The portion of the road north of East-West Road, which was

partially constructed prior to ADAGE’s selection of the Site, will not be changed;




Page 36

construction of this section of the road was permitted by Mason County prior to

ADAGE’s selection of the proposed Site and completed in 2010.

The revised route for the road will not impact the wetland or buffer area. The

proposed road will be located south of a surface water divide that runs over the large

hill housing the water tower. Surface water on the majority of the rerouted road will

drain to the south, towards the Site where it will be captured and managed with other

stormwater on the Site. On the eastern side of the hill, surface water on the road will

drain to the east (away from the wetland area) to stormwater management basins

located at the intersection of East Capitol Prairie Road and East Production Road.

This realignment represents a change from the original route of the road. The new

route is located south of the wetland area and will not impact either the wetland or

buffer area. The wetland is approximately 250 ft north of the rerouted road. The

designated buffer for this wetland is 150 ft.

The new road will require clearing approximately 8 acres of land (including drainage

facilities), some areas with slopes up to 25 percent. In addition, approximately

15,000 yards of cut and fill will be required to construct a road suitable for

residential traffic along the proposed route. Figure 4A shows the cut areas in blue

and the fill areas in red. A geotechnical assessment of the soil conditions in this area

determined deposits of uncontrolled fill will need to removed and replaced in areas

proposed for pavement. Other than that, normal construction procedures would

apply.

3. Estimate the amount of fill and dredge material that would be placed in or removed

from surface water or wetlands and indicate the area of the site that would be

affected. Indicate the source of fill material

None

4. Will the proposal require surface water withdrawals or diversions? Give general

description, purpose, and approximate quantities if known

No surface water withdrawals are proposed. No diversion to existing surface water

flows is planned.

5. Does the proposal lie within a 100-year floodplain? If so, note location on the site

plan

No.

Figure 6 shows the project site and the flood plain map for the general area.




Page 37

6. Does the proposal involve any discharges of waste materials to surface waters? If

so, describe the type of waste and anticipated volume of discharge

No.

To prevent the inadvertent discharge of spilled materials to surface waters, a BMPR

(Exhibit 9A) has been prepared describing procedures to minimize the potential

impact of the facility on human health and the environment. The BMPR includes

management plans such as a Construction SWPPP, Facility SWPPP, Spill Prevention

Control and Countermeasures (SPCC), and Emergency Response Plan (ERP). The

requirements of these plans will be updated periodically as necessary to address

changes in site design or operations.

b. Ground

1. Will ground water be withdrawn, or will water be discharged to ground water? Give

general description, purpose, and approximate quantities, if known

Water (both potable and process water) will be supplied by the City of Shelton

through an extension of the city water lines (see Exhibit 14). No on-site production

wells are planned for the facility and the plant will not use existing on-site

production wells operated by the Port of Shelton. No wastewater (sanitary or

process) will be released on site.

Stormwater will be managed on site. Because there will be no off-site discharge, an

NPDES permit will not be required. While potentially a groundwater discharge

permit would be required, this is not typically required for systems that infiltrate

only stormwater. This permit was confirmed in a conversation with Mr. Paul Stasch

of Ecology. ADAGE will submit an application for exemption to the groundwater

discharge permit based on Ecology’s instructions.

ADAGE will submit an application to Ecology as a ―Facility not Required to Obtain

Coverage‖ under Section S1.C.3 since the facility does not discharge stormwater to

surface waters under any condition, and does not discharge to a municipal storm

system. The site would still be subject to applicable requirements of the 2005

Stormwater Management Manual for Western Washington (SMMWW) for new

industrial developments, in terms of the treatment and the resulting water quality of

stormwater runoff. The facility will be subject to the requirements of Ground Water

Quality Standards (Chapter 173-200 WAC). This chapter requires that the facility

employ engineering and institutional controls to prevent the release of substances

into the soil, stormwater and groundwater. It is anticipated that applicable

stormwater requirements and groundwater protection rules will be satisfied through

implementation of the SMMWW requirements and facility engineering and

institutional controls. The facility will not discharge liquid process wastes or

wastewaters other than to the City of Shelton sanitary sewer under an appropriate




Page 38

discharge permit or as approved by Ecology and the City of Shelton. In addition,

construction activities on the site will comply with Ecology and Mason County

requirements for construction activities.

Preliminary storm drainage reports (Exhibits 15 and 15A) were prepared for

developing the onsite areas and for the realignment of East Capitol Prairie Road.

East Capitol Prairie Road and related stormwater improvements will be turned over

to Mason County following construction and Mason County will be responsible for

long-term operation and management of the facilities, therefore a separate report for

treatment and infiltration of stormwater runoff on the roadway was prepared.

The storm drainage reports were prepared using the hydrologic model from the 2005

SMMWW as adopted by Mason County. The hydrologic model determines the

required volume and bottom area for single treatment and infiltration ponds. The

single volume and area for each report was divided between several ponds as shown

on the site plan (Figure 4) in order to more closely approximate the existing natural

drainage conditions.

The final site design will meet the standards of the SMMWW incorporating the

following elements:

Preparation of stormwater site plans in accordance with Chapter 3 of the

SMMWW.

Stormwater source control and treatment BMPs in accordance with Chapter 4 of

the SMMWW. The selection of treatment facilities will be in accordance with

Figure 4.1 of the SMMWW, which includes presettling basins and oil control

facilities where required.

On-site stormwater management, runoff treatment, operations, and maintenance

in accordance with SMMWW requirements.

Preservation of natural contours to the extent practical.

Diversion of stormwater runoff around areas where woody biomass is stored to

reduce the contact between stormwater and biomass. Woody biomass materials

will be stored on impervious surfaces to prevent direct infiltration of rainwater

once it has passed through this material.

Use of conservative infiltration rates in the infiltration ponds. Infiltration rates are

expected to exceed 10 inches per hour, but the long-term design infiltration rate

for design purposes is conservatively estimated at 6.5 inches per hour. A

reduction factor of 4 was applied to this number, equating to 1.6 inches per hour.

Additional infiltration testing will be conducted for final design purposes.

A Facility SWPPP (included in BMPR in Exhibit 9A) has been prepared based on

the site design shown in Figure 4. This document will be updated based on the final

site design. Additional information on stormwater management is presented in

Item B.3.c, Water Runoff.




Page 39

The Site design has been planned such that excavations will remain above the water

table. If an unexpected condition occurs during foundation construction, then de

minimus amounts of dewatering may be required to address those conditions.

Appropriate permits and approvals will be obtained prior to proceeding and clean

extracted groundwater will be managed on site through the use of sedimentation

basins and infiltration galleries using appropriate best management practices.

2. Describe waste material that will be discharged into the ground from septic tanks or

other sources, if any (for example; domestic sewage, industrial, containing the

following chemicals…, agricultural, etc.). Describe the general size of the system,

the number of such systems, the number of houses to be served (if applicable), or the

number of animals or humans the system(s) are expected to serve

No waste material will be discharged to the groundwater. No septic tanks are

included in the Site design and no discharge of waste materials to the groundwater

are proposed under this project. Sewer service will be provided by the City of

Shelton for both sanitary and process wastewater.

See the section on Utilities for discussion of sewer service.

c. Water Runoff (Including Stormwater)

1. Describe the source of runoff (including stormwater) and method of collection and

disposal, if any (include quantities, if known). Where will this water flow? Will this

flow into other waters? If so, describe

ADAGE has designed a stormwater management system to protect the aquifer at the

Site. The system has been designed to capture and treat runoff from precipitation

events prior to infiltration back to the aquifer. Adequate capacity will be provided

within the system to be able to handle storm water runoff from a 25 year, 24 hour

storm event.

Runoff is typically generated from two sources – operations and precipitation.

Site operations may result in some runoff from equipment cleaning and other

maintenance activities. These operations will be located where the runoff water

will be captured and diverted to the process wastewater collection system. The

runoff from different areas will be separated to allow for various levels of

treatment. For example, roof drainage normally requires no treatment and can be

managed with stormwater runoff. Other runoff sources could contain components

of wood fuel or ash and will require interception, conveyance, treatment, and

disposal in accordance with the applicable requirements and will not be

infiltrated.

Stormwater runoff from precipitation is the primary source of water runoff at the




Page 40

Site. Stormwater runoff will be generated by precipitation falling on impervious

surfaces, and potentially, pervious surfaces during heavier rainfall events.

Stormwater runoff will be captured by the use of drainage swales, catch basins,

and diversion berms and diverted to the stormwater management system. The

location of stormwater management system components is shown on the site plan

(Figure 4). Stormwater that requires treatment will pass through passive

treatment areas such as constructed wetlands, biofilter swales, biofilter strips, or

other comparable systems. The use of these and other passive systems will be

evaluated for treating stormwater runoff from the fuel storage areas prior to onsite

infiltration. Stormwater which contains significant amounts of wood or sediment

materials will be screened using a debris trap, to avoid contamination and fouling

of the biological treatment structures which follow. Treated stormwater will be

allowed to reinfiltrate recharging the regional aquifer.

A variety of stormwater treatment alternatives are available as described by the 2005

SWMMM. Depending on the specifics of the individual drainage areas, the

SWMMM would require a combination of the following: pre-settling basins, oil-

control facilities, catch basin inserts, biofiltration swales, bioretention, or filter strips,

all as listed on the Figure 4.1 Treatment Facility Selection Flow Chart contained in

the SWMMM. At this time it appears that the Plant will require a basic treatment

facility as described by Step #6 of the flow chart. In addition to those already listed

above, the other options listed in Step #6 are: wetvault, treatment wetlands,

combined detention/wetpool, sand filters, and stormfilters. As necessary, presettling

basins will be required to control fines.

2. Could waste materials enter ground or surface waters: If so, generally describe

No.

As discussed in Item B.3.a., there are no bodies of surface water on the Site or

directly adjacent to the Site and no hydrologic connection exists between the Site

and the nearest permanent body of surface water in the area. Therefore, there is no

potential for waste material entering surface water.

The primary release mechanism to groundwater would be inadvertent spills and

releases from on-site operations. The major systems at the Site which will have the

potential to impact groundwater quality have been identified and, as part of the site

design, control systems developed to prevent the inadvertent releases to the

groundwater. In general these efforts would include the following:

ULSD Fuel Tank – The capacity of the ULSD fuel storage tank will be equal to or

less than 50,000 gallons. The tank, storage and associated pipeline systems will be

designed with secondary containment and impervious linings purposely designed to

prevent contamination of the ground and ground waters. These systems will meet




Page 41

applicable codes and comply with state and local requirements for handling and

storage of petroleum products.

Aqueous Ammonia - A spill containment facility with perimeter concrete walls will

be provided around the aqueous ammonia storage tank capable of holding 110

percent of the liquid volume of the tank plus precipitation from a 25- year, 24-hour

store event. The truck unloading area will be sloped to prevent the aqueous ammonia

from entering the stormwater system if a spill were to occur during truck unloading.

The area will be graded to minimize stormwater run-off from adjacent areas.

Oil Filled Transformer(s) - A spill containment facility with perimeter concrete

curbs will be provided around transformers located out of doors. These secondary

containment systems will be capable of holding 110 percent of the liquid volume of

the transformer tank plus precipitation from a 25- year, 24-hour store event.

Sorbent - Trona Un-Loading Area - The sorbents are used in the air emission control

systems and consist of a mildly alkaline powder (similar to baking soda), that is non-

flammable and non hazardous to the environment (per MSDS). The truck unloading

area will be sloped to prevent the trona from entering the stormwater system if a spill

were to occur during truck unloading. The truck unloading area will be graded to

minimize stormwater run-on from adjacent portions of the Site and will be swept

regularly to remove accumulated dry materials which will be disposed in accordance

with state and federal regulations.

ADAGE has retained a highly respected local engineering firm (Robinson / Noble)

with specific expertise in the hydrogeology of the Johns Prairie Aquifer to develop

Best Management Practices (BMPs) for implementation by ADAGE. These BMPs

provide defined procedural requirements and standards to assure maximum

protection to the aquifer. A BMPR (Exhibit 9A) has been prepared for the site

establishing procedures to prevent the uncontrolled releases to the groundwater and

responses procedures in the advent a spill were to occur. This document will be

updated as changes to the site design or operations occur

d. Proposed measures to reduce or control surface and ground water impacts, if any.

The facility design will employ ―all known, available, and reasonable methods of

prevention, control, and treatment (AKART)‖ technologies to prevent, control, and abate

pollution associated with discharges to surface and groundwater. Item B.3.c.2 identified

several areas in the facility where contaminants could inadvertently be released to

surface or groundwater and identified control BMPs to prevent these releases. A BMPR

(Exhibit 9A) has been prepared for the site establishing procedures to prevent the

uncontrolled releases to the groundwater and responses procedures in the advent a spill

were to occur. This document will be updated as necessary if changes to the site design

or operations occur.




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Prior to start up of operations, the BPMR will be updated on the final site configuration

and addressing the requirements to minimize the potential for discharges of waste

materials to groundwater during site operations. Those steps, in addition to the control

systems included in the site design, will minimize the potential for unauthorized

discharges to groundwater.

In addition, the stormwater management system will be developed to address AKART.

The site design relies on sheet flow of stormwater to the greatest extent possible to

reduce maintenance and minimize the use of catch basins which are potentially subject

to clogging. Stormwater flows will be directed to perimeter swales surrounding the

powerplant area, fuel unloading areas, and fuel storage areas. Stormwater facilities

which are expected to have a significant loading from sediments and wood debris, will

have a structure installed to trap such debris upstream of the biological treatment

processes, to reduce fouling. The ADAGE facility will be designed so that the potential

for waste material entering, and impacting groundwater quality is small, and measures

will be undertaken during construction and site operations to minimize that potential.

As discussed in Item B.3.b.2, prior to the start of construction, a Construction SWPPP

will be prepared to address potential impacts during construction.

During the final design preparation, a stormwater treatment system engineering report

will be prepared and submitted to the Ecology. The report will address structural, non-

structural, and source-control BMPs. As discussed in Item B.3.b.1, because there will

be no off-site discharge, an NPDES permit will not be required. Stormwater generated

on the Site will be managed in accordance with the Mason County Stormwater Manual

and site BPMR (Exhibit 9A) based on the site design shown in Figure 4. This document

will be updated as necessary based on changes in site design or operations.

Structural source control BMPs will be used to reduce the contact between stormwater

and materials such as wood ash (e.g., the wood ash silos will be enclosed to control

wind-blown ash during truck loading).

Non-structural source control BMPs such as management procedures and good

housekeeping will be used to reduce the potential for contact between stormwater and

various substances such as wood ash (e.g., if wood ash should spill onto drainage

surfaces, it will be promptly swept up).

Stormwater that comes into contact with the stored biomass will require source control

(i.e., treatment) BMPs. Constructed wetlands and other systems will be evaluated for

use in treating stormwater runoff from the fuel storage areas prior to onsite disposal by

infiltration.




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4. PLANTS

a. Check or circle types of vegetation found on the site:

__X_ deciduous tree: alder, maple, aspen, other

__X_ evergreen tree: fir, cedar, pine, other

__X_ shrubs

__X_ grass

____ pasture

____ crop or grain

in wetland area only wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other

_____ water plants: water lily, eelgrass, milfoil, other

__X_ other types of vegetation

b. What kind and amount of vegetation will be removed or altered?

The site is predominantly undeveloped mature forest with evidence of historical logging.

The majority of the Site consists of well-drained upland soils and mature coniferous

forest. Vegetation on the Site is predominantly mature coniferous upland forest and the

dominant tree species is Douglas fir (Pseudotsuga menziesii). Representative diameter at

breast height (DBH) measurements were taken of three P. menziesii trees that were

approximately 90 to 100 feet tall and had DBH of 20 inches (in), 20 in, and 13 in. In the

northeast corner of the Site, the understory is dominated by Scotch broom (Cytisus

scoparius), which appears to follow historic logging roads. The remainder of the Site,

where the forest understory was more intact, is dominated by salal (Gaultheria shallon),.

The vegetation observed in the forested upland on-site during the biological survey

(Exhibit 5) is included in the table below.

Scientific Name Common Name

Anaphalis margaritacea Pearly everlasting

Chimaphila umbellata Pippsessewa

Corylus cornuta Beaked hazelnut

Galium trifidum Cleavers

Gaultheria shallon Salal

Linnea borealis twinflower Twinflower

Polystichum munitum Sword fern

Prunella vulgaris Self heal

Pseudotsuga menziesii Douglas fir

Rubus armeniacus Himalayan blackberry

Thuja plicata Western red cedar

Tsuga heterophylla Western hemlock




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The proposed action will result in minor impacts to biological resources (plants and

animals) and habitat quantity and quality (foraging, burrowing, and nesting).

Disturbance from construction would remove the plant communities occurring on the

facility site and along the new access road corridor. Based on the Site plan, the project

would result in development of approximately 56.5 acres of currently forested land for

buildings, wood storage, pavement, stormwater facilities and associated landscape areas.

These 56.5 acres will be cleared of vegetation in order to be developed for the project,

although a minimum 50 – 100 foot buffer would be left around the western, southern,

and northern boundaries of the Site, excluding entrances and exits. In addition,

approximately 30 acres of land will be left in natural vegetation between Capitol Prairie

Road and the property boundary on the west and Capitol Prairie Road and the facility on

the east. The permanent removal of 56.5 acres of forested land will have some impact on

vegetative volume in the Mason County area

The original proposal involved clearing of 75 acres. The Biological Evaluation for that

proposal concluded that the impact would not be significant because the vegetation is

not threatened or endangered or otherwise play a unique function in the Mason County

ecosystem. In response to comments received on the original proposal ADAGE has

significantly reduced the amount of vegetative clearing. This reduction is one of the

important changes ADAGE has made to the proposal. The modified proposal reduces

impacts to vegetation by 25% over the original proposal.

Noxious weeds have been identified at the site. A weed control plan has been prepared

to address the management of these weeds at the Site during construction (see

Exhibit 16).

c. List threatened or endangered species known to be on or near the site.

No known endangered plant species have been identified on the Site. A Preliminary

Biological/Ecological Evaluation (Exhibit 5) was prepared in January 2010 to evaluate

site conditions to determine if any threatened or endangered species would be impacted

by this project. It was the conclusion of the study that no threatened or endangered

species would be impacted either on-site or near the Site.

d. Proposed landscaping, use of native plants, or other measures to preserve or enhance

vegetation on the site, if any

The proposed site plan is to maintain a minimum 50 to 100 foot buffer for existing trees

and vegetation along the western, southern, and northern boundaries of the Site,

excluding entrances and exits.

Plantings will be added along the north, east, and west sides of the building and main

entrance. Native plants plantings are proposed near the maintenance drive, the south

building entry, stormwater management facilities on the east side of the property, and




Page 45

the main parking area. The proposed landscaping plan will include revegetation of the

existing landscape potentially damaged during construction.

Landscaping of the project site will comply with Section 17.03.036, 17.03.037, and

Section 17.07.170.

According to the Land Use Classifications in Section 17.03.034, the facility will be

classified Category VI. North and east of the Site, the adjacent property is part of the

same parcel and part of the Johns Prairie Industrial Park; to the south and west, the

adjacent property is classified as Category I. Construction will meet or exceed Mason

County and Shelton UGA landscaping code based on these classifications.

5. ANIMALS

a. Circle any birds and animals which have been observed on or near the site or are known

to be on or near the site

Birds: hawk, heron, eagle, songbirds, other ____X______.

Mammals: deer, bear, elk, beaver, other _____X_____.

Fish: bass, salmon, trout, herring, shellfish, other ___________.

During the biological survey (Exhibit 5), biologists observed few animals on site. The

presence of various off-site disturbances likely contributes to these observations. Still,

some indications of faunal use were observed. The presence of deer was indicated by

scat, tracks, and remains. Coyote and raccoon scat was also observed. A small mammal

burrow approximately 5 inches in diameter was observed in the G. shallon understory in

the forested upland. Vocalizing frogs were heard near monitoring wells and stormwater

ponds and wetlands. Woodpecker holes were observed in snags, and a red-tailed hawk

and an orange-crowned warbler were observed flying over the Site. Nuthatches and

chickadees were audible in the forested upland area.

b. List any threatened or endangered species known to be on or near the site.

The Biological Survey (Exhibit 5) concluded that there are no known threatened or

endangered species on or near the site. The study identified some threatened or

endangered animals in the area but concluded that the on-site habitat was not suitable for

these species. The following table provides a summary of the threatened and

endangered species identified near the Site.




Page 46

Scientific Name Common Name

Federal

Status

State

Status

Approx.

Distance

from Site

Marine Resources and Forage Fish

Crassostrea gigas Pacific oyster N FFMR 1 mile

N/A Hardshell intertidal clam N FFMR 1 mile

Lepidopsetta

bilineata Rock sole spawning areas N FFMR

1.75

miles

Hypomesus

pretiosus

/Ammodytes

hexapterus

Surf smelt/sand lance

spawning areas N FFMR 1 mile

Listed Species

Progne subis Purple martin N CAN 2 miles

Thomomys

masama ssp.

couchi

Shelton pocket gopher CAN LT 0.25

miles

Oncorhynchus

kisutch

Coho salmon (Puget

Sound/Strait of Georgia) SC CAN 0.6 miles

Oncorhynchus

tshawytscha Fall Chinook (Puget Sound) LT CAN 0.6 miles

Oncorhynchus

keta

Fall chum (Puget

Sound/Strait of Georgia) N CAN 0.6 miles

Oncorhynchus

mykiss

Winter steelhead (Puget

Sound) LT CAN 0.6 miles

Federal Legal Status LE Endangered: species in danger of extinction throughout all or a significant portion of its range.

LT Threatened: species likely to become Endangered within the foreseeable future throughout all or a

significant portion of its range.

SC Species of concern

CAN Candidate for listing

N Not currently listed, nor currently being considered for listing as Endangered or Threatened.

State Legal Status

LE Endangered: species, subspecies, or isolated population so few or depleted in number or so

restricted in range that it is in imminent danger of extinction.

LT Threatened: species, subspecies, or isolated population facing a very high risk of extinction in the

future.

CAN Candidate for listing

PH Priority habitat

N Not currently listed, nor currently being considered for listing as Endangered or Threatened.

FFMR Forage Fish and Marine Resources




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c. Is the site part of a migration route? If so, explain.

The proposed site is located within the Pacific Flyway, which is a flight corridor for

waterfowl and other avian fauna migration. The Pacific Flyway extends from Alaska

south to Mexico and South America.

d. Proposed measures to preserve or enhance wildlife, if any.

As noted above, the modified proposal reduces the amount of vegetative clearing by

approximately 25 percent, Also note that the impervious surfaces have been reduced

from 34 acres to 22. Areas not impervious will be either grassy or associated with the

ponds that service storm water control. The grassy areas will provide some habitat for

smaller species. The reduction in the amount of the site cleared is the maximum amount

possible without affecting the proposal’s objective of providing a reliable continuous

energy supply. The reduced impact on vegetation has a corresponding and substantial

reduction on potential wildlife impacts when compared to the original proposal. As

noted in the Mason County Comprehensive Plan, the site has been designated by Mason

County for industrial development. The County Plan has anticipated that some level of

wildlife will be displaced and a small level of unavoidable mortality will occur as part of

the Site development. The number of animals impacted by the facility will be small, as

little wildlife was observed during the site visit and the presence of off-site disturbances

seems to have limited the use of the area by various fauna. Some burrowing animals

may be killed or have their nest disturbed during logging and grading operations.

Several short-term impacts are expected within the project site during due to the clearing

forested habitat. Animals will be affected by direct habitat loss through site clearing and

indirect habitat loss by displacement, changes in topography, shelter, food availability,

or by destruction of non-mobile species.

Mobile wildlife species that use the immediate project site will be displaced from much

of the 56.5 acres. Displacement may cause degradation of adjacent habitats due to the

heavier concentrations of wildlife moving into these areas, and may increase both

intraspecific and interspecific competition for resources in these areas. The ability of

adjacent habitats to "absorb" displaced wildlife during the period of disturbance depends

on the carrying capacities of those habitats and current levels of use. Displaced animals

that cannot find habitats that are below their carrying capacity will eventually vacate the

area in search of suitable habitat.

However, there are other forested lands and other natural habitats adjacent to the facility

site with extensive forested lands further away. The facility site is connected to these

off-site habitats through forest habitat north and south of the Site, as well as the off-site

forests to the south of the Site. These sites will allow some displaced animals to occupy

them. Additionally the existing native vegetation in the proposed perimeter buffer areas

would provide some wildlife habitat. Overall, the permanent removal of 56.5 acres of




Page 48

forested land will have minimal impact on biological diversity in the Mason County

area.

Once the facility is operational, the Site activity will be consistent with those of adjacent

businesses, including noise and vibrations which could affect animals in adjacent

habitats. The eastern part of the industrial park, already occupied by industrial uses,

creates a similar variety of disturbances, so animals in the Site vicinity have been

exposed to similar operational noise levels as those anticipated during operations.

Rerouting traffic from East Capitol Hill Road and the additional traffic related to Site

operations will potentially results in some injury and/or mortality of wildlife from

vehicle/animal collisions. The Mason County Department of Public Works does not

recommend signage along the roadside because they are often distracting and the local

population is aware of deer and other animals throughout the County. The speed limit

will be designated by Public Works for the relocated East Capitol Hill Road.

6. ENERGY AND NATURAL RESOURCES

a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet

the completed project’s energy needs? Describe whether it will be used for heating,

manufacturing, etc

The facility will produce electricity from clean woody biomass consistent with the goals

and objectives of Washington State Initiative 937. Facility electrical needs will be

supplied either from the on-site generated electricity or the local grid.

Towards the end of the construction period the facility will be initially operated using

ultra low sulfur distillate (ULSD) fuel, with biomass being introduced gradually until

commissioning is complete. Following commissioning, the facility will be restricted to

using limited amounts of ultra low sulfur distillate (ULSD) fuel during boiler startup,

shutdown, and bed stabilization. The use of fossil fuels will be limited to intermittent

activities. ULSD usage is expected to be less than ½ of 1% of the total annual heat

input, further detail is provided in the Exhibit 13, Green House Gas Analysis.

b. Would your project affect the potential use of solar energy by adjacent properties: If so,

generally describe

The proposal would not affect the potential use of solar energy by adjacent properties.

No structures associated with the proposed project will present a significant shadow

impact on adjacent property. Large structure shadows, such as the stack and boiler

building, will remain largely within the Site boundaries.

To assess the potential impact of proposed facility on neighboring properties, shadow

maps were prepared showing the maximum distance for shadows from man-made

structures on the site during June and December when the shadows are greatest due to




Page 49

the angle of the sun. In June, during both morning and evening periods, the shadows

from man-made structures will be confined to the Site. During December, during both

morning and evening periods, shadows may extend to the north near the new East

Capitol Prairie Road. There is also a small portion of shadow cast on Shearer Brother’s

property. Please see Exhibit 16A for the shadow maps.

Existing vegetation will remain in place around much of the perimeter of the Site so

sunlight penetration will remain unchanged or be slightly increased following Site

development.

c. What kinds of energy conservation features are included in the plans of this proposal?

List other proposed measures to reduce or control energy impacts, if any

The energy assessment to be provided as part of the building permit application would

include proposed energy conservation features. The project would meet or exceed the

energy code with improvements such as installation of energy efficient windows,

lighting and additional insulation. In addition, the project will attempt to include various

sustainable goals both during construction and operation of the completed facility.

These efforts include, but are not limited to:

Reduce pollution from construction activities by controlling soil erosion,

sedimentation and airborne dust generation as described elsewhere in this

document.

Conserve existing natural areas to the extent possible as described elsewhere in this

document.

Control stormwater quantity and quality as described elsewhere in this document.

Minimize light trespass from the Site, reduce sky glow, improve nighttime visibility

through glare reduction, and reduce impact on nocturnal environments.

Provide water efficient landscaping.

Use recycled materials to the extent possible in the facility construction materials.

Minimize the use of water during operations and construction (e.g.,, air based

cooling tower).




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7. ENVIRONMENTAL HEALTH

a. Are there any environmental health hazards, including exposure to toxic chemicals, risk

of fire and explosion, spill, or hazardous waste, which could occur as a result of this

proposal? If so, describe

The power industry serves the general public in both densely and moderately populated

communities. The industry has developed comprehensive regulations to ensure that the

risk of accidents, such as chemical spills, fires and explosions are minimized. The

ADAGE facility will be designed to meet or exceed each of these regulations.

There are a large number of biomass power facilities operating in the region that have

excellent safety records and community relations. Examples include the biomass boiler

conversion recently made by the Seattle Steam operations, which operates downtown,

and the University of Idaho biomass boiler on the Moscow campus. Duke Energy

Generation Services (DEGS), a part

owner of ADAGE, constructed,

manages and owns a biomass

cogeneration facility in downtown St

Paul, Minnesota (shown at left).

As with any electric generation

facility, the potential exists for

inadvertent releases of chemicals or

other accidents, such as those

discussed in Item B.3.c.2. Safety

systems have been incorporated into

the site design to prevent and control

chemical releases and a site wide

Environmental, Health and Safety

Management System (EHSMS)

program will be established to train

workers in procedures to prevent accidents and accidental releases. A site specific

EHSMS manual will be developed based on industry’s best practices. The manual will

address at a minimum the OSHA and WISHA laws and rules applicable to the power

industry, along with site specific information.

In addition to the EHSMA manual, management systems such as those required under a

SPCC and SWPPP have been developed and will be implemented to prevent accidents

and releases, and to control and cleanup releases if they do occur. These documents

contained in the BMPR (Exhibit 9A), will be updated as necessary if the site design or

operations warrant. Employees will be trained in these programmatic requirements and

periodic compliance audits will be conducted to ensure that employees are familiar with,

and are implementing, program requirements.




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Fuels, chemicals, and industrial gases are required substances during the construction,

start up, and operation of a thermal power generating station. As such, these materials

will be present at the ADAGE Biomass Power Plant during all phases of plant life, and

do present risk of fire, explosion, or release based on specific fuel, chemical, or industrial

gas characteristics. The following discussion is intended to provide an overview of the

types of materials, safety standards, and procedures that will be utilized by ADAGE at

the plant site to ensure this risk is as low as reasonably achievable.

ADAGE will work closely with the Mason Fire District 5 as well as and local emergency

response officials to assure that response to potential site hazards has been pre-planned,

trained for, and that appropriate equipment is available.

Project Construction

Hazardous materials that will be used during project construction include gasoline,

diesel fuel, oil, lubricants, and small quantities of solvents and paint. There are no

feasible alternatives to these materials for operation of construction vehicles and

equipment. No acutely hazardous substances will be used or stored onsite during

construction.

Diesel fuel is the hazardous material with the greatest potential for safety and

environmental consequences during the construction phase due to the use of diesel

fuel in construction equipment, and the frequent refueling that may be required.

Refueling operations will be supervised by trained equipment operators. Any fuel

spilled will be promptly cleaned up, and any contaminated soil disposed of in

accordance with the applicable State and Federal requirements.

Small volumes of hazardous materials will be temporarily stored onsite inside fuel

and lubrication service trucks. Paints and solvents will be stored in flammable

material storage cabinets. Construction personnel will be trained in handling these

materials. The most likely incidents involving these hazardous materials would be

associated with minor spills or drips. Impacts to the site workers, the public or the

environment of a minor spill or leak will be mitigated through the emergency

response training program and procedures that will be implemented by project

construction contractors and employees, and by thoroughly cleaning up minor spills

as soon as they occur. Soil contaminated by a spill or leak will be disposed in

accordance with the applicable State and Federal requirements.

Project Operation

Chemicals, fuels, and industrial gases will be stored or processed in vessels

specifically designed for their individual characteristics. All hazardous materials

storage or process vessels will be designed in conformance with applicable ASME

codes. Large quantity liquid chemicals will be stored outdoors in above ground

storage tanks, or in large plastic totes. Bulk storage tanks and totes will be designed

with secondary containment structures capable of holding the tank or tote volume

plus an allowance for precipitation (typically a 25 year, 24 hour rain event).




Page 52

Small quantity chemicals will be stored in their original containers in order to

minimize risk of upset. Plant personnel working with chemicals will be trained in

proper handling technique and in emergency response procedures for chemical

spills or accidental releases. Personal protective equipment (PPE) will be provided.

The facility will be operated by Duke Energy Generation Services (DEGS). DEGS has a

proven track record for safe and reliable operation of the facilities they manage, and are

ranked in the top 10 percent for safety performance in the power generation industry.

DEG’s Total Incident Case Rate (TICR) for 2009 was 0.54. TICE is an indication of

how many incidents have occurred based on a specific mathematic calculations

established by OSHA that enable any company to report their recordable incident rates,

lost time rates and severity rates, so that they are comparable across any industry or

group. To ensure safety and reliability, inspections and planned outages will be

performed on the BFB and turbine generator and balance of plant equipment.

Appropriate safety programs will be developed to address hazardous materials storage

and use, emergency response procedures, employee training requirements, hazard

recognition, fire safety, first aid / emergency medical procedures, hazardous materials

release containment and control procedures, PPE training, and release reporting

requirements.

Most chemicals and materials used at the Site will be typical for any facility with

mechanical equipment such as cleaning solvents, lubricating oils, hydraulic oils, paint

and janitorial supplies.

Aqueous ammonia will be used as part of the air emission control system to aid in the control of

NOx emissions. Aqueous ammonia can cause severe eye irritation and burning of skin and

extremely irritating to mucous membranes if ingested or inhaled (MSDS). Aqueous ammonia is

ammonia diluted in a water solution. ADAGE will use 19 percent aqueous ammonia (ammonia

hydroxide) which is similar but somewhat stronger than household ammonia. The 19 percent

level is specifically chosen by the ammonia industry in that in this concentration, environmental

and human health risks associated with aqueous ammonia are substantially reduced. A facility

that handles more than a threshold quantity of a regulated toxic or flammable substance is

covered under EPA’s Chemical Accident Prevention program (40 CFR Part 68). Both

―anhydrous ammonia‖ and ―ammonia at concentrations of 20 percent or greater‖ are regulated

substances under the program (40 CFR §68.130, Table 1). ADAGE is proposing to use a 19

percent aqueous ammonia solution in its SCR systems, which means that the facility will not be

subject to the Chemical Accident Prevention program requirements. Fires related to ammonia

use are typically associated with the anhydrous forms; the use of aqueous ammonia almost

eliminates the potential of fire.

ADAGE will work with Mason Fire District Five officials and other local

representatives to ensure that local emergency response teams and area residents are




Page 53

aware of chemical usage at the facility. A BMP has been supplied for the storage and

handling of aqueous ammonia in Exhibit 9A.

With respect to the transport of ammonia to the Project site, WSDOT regulations require

truck tank trailers to meet strict requirements for collision and accident protection. In

addition, shippers must supply drivers with a manifest showing what is the chemical

composition of the load and educate their drivers in potential hazards and emergency

response procedures.

In the event of a spill of a reportable quantity of a chemical during shipping, the truck

driver would contact CHEMTREC and the local authorities. Contact information is

included on the shipping manifest which is stored in a location on the truck that the

driver can easily access in the event of an emergency. CHEMTREC serves as a round-

the-clock resource for obtaining immediate critical response information for incidents

involving hazardous materials and dangerous goods. CHEMTREC is linked to the

largest network of chemical and hazardous material experts in the world, including

chemical and response specialists, public emergency services, and private contractors.

CHEMTREC also assists shippers of hazardous materials with compliance with

government regulations. CHEMTREC would assist the driver in identifying actions that

need to be taken at the site such as setting up isolation distances, containing the spill

with spill kits, etc. and to dispatch the appropriate emergency response team to the site.

Included in the contract with ADAGE, each shipper will have a provision that, following

initial emergency response actions, the ADAGE emergency response contact will be

notified. ADAGE will provide additional assistance as necessary to contain and

remediate the spill in a manner that is protective of human health and the environment.

Hazardous materials shipments will comply with applicable regulations in terms of route

selection, operator training and qualifications, etc. Project truck travel will include

approximately 4 deliveries per month of aqueous ammonia. It is expected that hazardous

materials shipments would utilize SR-3 to access the Site from the east. The frequency

for serious hazardous material incidents involving large trucks is extremely low and the

infrequent delivery requirements and traffic analysis suggest potential impact from a

truck accident is highly unlikely.

As noted previously, an Emergency Response Plan has been prepared for the Site

(include in BMPR, Exhibit 9A) for the storage and use of aqueous ammonia. This

document will be maintained and updated as necessary based on the site design and

operations. The probability of a catastrophic release of aqueous ammonia during Project

operations is very small. The low release probability is a result of a number of factors,

including the stringent design standards for pressurized storage vessels, the mitigation

measures that will be built into the ammonia system at the facility, and the chemical

accident prevention program elements that the project will establish to comply with the




Page 54

requirements of the BMPR. As a result of the foregoing, potential impacts associated

with the use and storage of ammonia onsite will be less than significant.

1. Describe special emergency services that might be required.

The proposed facility will have similar needs for emergency services as other

industrial operations of this size and scope. The Johns Prairie Industrial Park area is

home to multiple industrial facilities that use, manage, handle and store large

quantities of biomass in solid and ground or chipped form. The ADAGE

requirement for biomass related emergency services will be similar to these existing

area businesses.

The one exception to this is the potential for an increased need for fire and hazmat

services due to the nature and flammability of the ULSD and aqueous ammonia.

ADAGE has initiated discussions with local emergency response officials to discuss

the project and assure that appropriate pre planning has been completed and

recommendations from local emergency responders have been considered in the site

design.

There is risk of fire due to spontaneous combustion in the processed biomass fuel

storage areas if not managed properly; however, operational procedures to minimize

spontaneous combustion from storage of the woody biomass materials have been

completed and can be reviewed in Exhibit 9A. Proper procedures for handling and

storing woody biomass fuel reduce the threat of fire to insignificant levels. Fire

water hydrants will be strategically located to provide quick access for emergency

response personnel.

There is also risk of fire for the above ground ULSD fuel oil tank. Storage of

ULSD fuels is common and engineering and design controls to prevent fire are well

known. Above-ground storage tanks have a higher risk of fires than underground

tanks, due to mechanical malfunctions, vandalism or accidents, according to the

EPA. Safeguards will be installed to prevent fires from occurring such as bollards

and concrete walls to prevent vehicle collisions, leak and fire detection systems, and

regular operations staff visual surveillance. The facility will be gated as a security

measure to prevent vandals from tampering with the tank. All federal, state and

local fire guidelines will be implemented. Fire water hydrants will be strategically

located to provide quick access for emergency response personnel.

2. Proposed measures to reduce or control environmental health hazards, if any:

To control or reduce potential environmental and health hazards associated with the

proposed facility, ADAGE has proposed the following approaches:

http://www.ehow.com/list_6652431_requirements-above-ground-storage-tank.html

http://www.ehow.com/list_6652431_requirements-above-ground-storage-tank.html




Page 55

An operating procedure has been developed to address the potential for fire due

to the wood fuel storage and can be found in Exhibit 16B.

A BMP for delivery and storage of 19 percent aqueous ammonia has been

prepared and can be found in Exhibit 9A.

Coordinate with the local emergency response officials and Haz Mat response

teams in the area to ensure all parties are familiar with operations at the plant

and aware of potential hazards including chemical use at the plant.

Develop a site specific contingency/emergency response plan for the facility

and provide regular training for employees in identifying and addressing

potential environmental health hazards. Where feasible, coordinate training

with local emergency response teams to ensure smooth response during an

actual emergency.

b. Noise

1. What types of noise exist in the area which may affect your project (for example:

traffic, equipment, operation, other)?

The ADAGE facility will be located on an industrially zoned site in the Johns

Prairie Industrial Park. The adjacent property along the eastern and northern Site

boundaries is zoned industrial. In these areas, the Site is adjacent to various wood

product facilities, generating noises derived from truck traffic, debarking, chipping

and grinding operations, among others. Measurements of ambient sound levels

were collected during the Acoustical Analysis (Exhibit 8). These included a 2-hour

measurement at both the East and South Property Lines. The 2-hour measurements

were taken at two locations with a Rion NL22 Type II sound level meter. A spot

measurement was also taken at the SE corner with a Larson Davis model 824 Type

I sound level meter (57 dBA). The maximum measured sound level on the South

property line was 50 dBA and the maximum sound level on the East property line

was 68 dBA. Additional monitoring of site noise levels based on existing

operations on surrounding properties is discussed in Exhibit 8.

2. What types and levels of noise would be created by or associated with the project

on a short-term or a long-term basis (for example: traffic, construction, operation,

other)? Indicate what hour’s noise would come from the site.

The Acoustical Analysis (Exhibit 8) focused on the noise generated during normal

operations that has the potential to be more significant than the noise created by

traffic or construction activities. This is consistent will all state and local

ordinances relative to noise. The noise created due to the traffic and construction

will fit within the normal profile of a site located within an industrial park.

Ambient noise levels were measured at the South and East property lines.




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The study defined the sound-producing activities of interest and addressed both the

individual and combined predicted noise levels along each of the four site property

lines. The sound-producing activities evaluated included: handling and processing

biomass, power generation, cooling, and emergency equipment. For additional

information and descriptions of these operations please refer to Exhibit 8 for the

complete study.

Mason County Ordinance defines the noise requirements under Section 9.36.060 as

follows:

EDNA OF NOISE

SOURCE

EDNA OF RECEIVING PROPERTY

Class A (dBA) Class B (dBA) Class C (dBA)

Class A 55 57 60

Class B 57 65 65

Class C 65 70 75

Where Class A EDNA is defined as lands where human beings reside and sleep

(residential); Class B EDNA is defined as lands involving uses requiring protection

against noise interference with speech (commercial); and Class C EDNA is defined

as lands involving economic activities of such a nature that higher noise levels than

experienced in other areas is normally to be anticipated (industrial).

The Site will be a noise sources and will be considered a Class C EDNA while the

receiving properties on the East and South lease lines will be Class A EDNA and

the North and West lease lines will be Class C EDNA.

Washington state code has different standards than Mason County. Under WAC

173-60-040 it states the following:

EDNA OF NOISE

SOURCE

EDNA OF RECEIVING PROPERTY

Class A (dBA) Class B (dBA) Class C (dBA)

Class A 55 57 60

Class B 57 60 65

Class C 60 65 70

WAC 173-60 also states that between the hours of 10:00 pm and 7:00 am, the noise

limits of the foregoing table shall be reduced by 10 dBA for receiving properties

within Class A EDNAs.




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According to these regulations, the South border West of Capital Prairie Road and

the West border are 60 dBA between 7:00 am and 10:00 pm and 50 dBA between

10:00 pm and 7:00 am. The noise limits on the remaining borders are 70 dBA 24

hours a day.

The fuel yard operations and noise levels associated with this revised SEPA

checklist are considerably different than the original ADAGE proposal. The

original included the capability to chip and grind 100% of the biomass on site using

a 1000hp electric grinder. The project also assumed loading and unloading regular

shipments of solid biomass to be fed to the grinder. This revised proposal assumes

100% of the projects fuel will come to the site ground or chipped to 4‖ and smaller

size. There are provisions for a small amount of larger solid biomass such as

chunks, butts, bundles to be used as emergency stock in the event that the normal

feed of processed biomass is interrupted. Emergency stock will never exceed 20

days of fuel volume in any given year.

Processed fuel arrives in chip vans and is unloaded by tipping the truck and

emptying the contents into receiving hoppers. The contents move by conveyor into

a processing tower that houses equipment to check for metal objects, screen the

material to check top size and reduce any pieces that are too large (greater than

4 inches) to appropriate dimensions. Typically, 80 percent to 90 percent of the fuel

is correctly sized and 10-20 percent passes through the wood hog. The wood hog is

a rotating device that grinds the 10 to 20 percent portion to the correct size.

Properly sized fuel leaves the processing tower and is conveyed to either covered or

outdoor storage areas. The fuel receiving and processing operations will operate

only between the hours of 7 a.m. and 10 p.m. Monday through Friday (receiving

hours).

The covered storage system stores up to 7 days of fuel and operates continuously

feeding two fuel storage bins adjacent to the boiler. The storage bins hold up to

1 hour of fuel and allow the boiler to be fed continuously and smoothly. The

covered storage systems and boiler feed conveyors operate quietly 24 hours a day, 7

days per week. The fuel receiving and biomass processing systems including the

magnet, sizing screens and wood hog that grinds a small portion of the fuel, will

only operate during receiving hours. The combined predicted noise levels due to

site operations during receiving hours are shown in the following table. The noise

level for each activity varies as the distance from each border changes. The

combined predicted level assumes the worst-case scenario for each of the noise

sources as described above. The natural forest buffer has not been considered

while calculating these numbers. Actual numbers are expected to be 3 to 4 decibels

less due to the tree line.

The first table shows the predicted noise levels during receiving hours:




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Point

Loading/

Unloading

Biomass

Conveying

Biomass Chipping

Power

Generation

(Boiler/Turbine)

Stack Cooling

ACC

Combined

Predicted

Max Level

Combined

Predicted

Level w/

Buffer

Max.

Allowed

per WAC

1 Hr. Leq 1 Hr. Leq 1 Hr. Leq

(dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA)

A 50 20 63 65 62 40 69 66 70

B 56 21 59 46 46 44 61 58 60

C 45 20 56 35 40 47 57 54 60

D 56 21 67 54 65 49 70 67 70

The following table shows the noise levels between the hours of 10:00 pm and 7:00

am. During these hours, the fuel loading/unloading and processing operations will

be shut down. During the 10 p.m. to 7 a.m. time period, only conveyors from the

covered storage area to the boiler storage bins will operate. The fuel processing

tower and hog will not run at night. The fuel conveyors from the storage areas are

quiet resulting in sound levels at the residential borders 47 and 45 db inclusive of

predicted tree buffer effects. The site will not accept incoming shipments of fuel

after receiving hours, therefore noise from trucks or other delivery equipment will

not occur during nighttime hours.

Point

Loading/

Unloading

Biomass

Conveying

Biomass Chipping

Power

Generation

(Boiler/Turbine)

Stack Cooling

ACC

Combined

Predicted

Max Level

Combined

Predicted

Level w/

Buffer

Max.

Allowed

per WAC

1 Hr. Leq 1 Hr. Leq 1 Hr. Leq

(dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA) (dBA)

A 50 20 63 65 62 40 69 66 70

B 56 21 59 46 46 44 61 58 50

C 45 20 56 35 40 47 57 54 50

D 56 21 67 54 65 49 70 67 70

3. Proposed measures to reduce or control noise impacts, if any.

The modified fuel yard and site design, eliminating the 1000hp grinder and

decreasing the yard footprint has greatly decreased the projects expected noise

generation. The final site will be designed to ensure compliance with Mason

County and Washington State Noise Ordinance requirements. A number of other

steps have been taken to control noise impacts at the Site. They include, but are not

limited to, the following:




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Locating the boiler and power island equipment and related systems that

operate 24/7 as far from residential areas and as close as feasible to other

industrial operations in the Park. The distance from the power island to the

nearest neighbor is approximately 1200 feet and the distance to the western

border is approximately 2600 feet.

Limiting truck receiving hours to between 7 a.m. and 10 p.m. Monday through

Friday, while designing the site layout such that trucks that may arrive before

fuel receiving hours are furthest from the residential borders. The design

ensures that truck noise in the queue area will not create nuisance noise at the

border. ADAGE calculations of truck noise idling in the staging area will

result in less than 45db at the southwest class A EDNA and even lower at the

western site border. Limiting and enforcing truck speed limits and idling

policies to further mitigate noise and emissions concerns.

Maintaining buffer areas in their native vegetated state to provide screening

from ground level sources of noise. Where necessary, understory plantings

will be added to provide additional screening around existing residential areas.

Equipping mobile equipment with mufflers and other noise attenuation

systems.

The acoustical analysis (Exhibit 8) predicted maximum p90otential equipment noise

levels based on conservative assumptions and sound profiles of preliminary

equipment choices. Mitigation measures were then applied to these estimates to

determine the predicted noise levels at the Site boundaries. Please refer to Exhibit 8

for further information. On the basis of this analysis, specific mitigation activities

to achieve required allowable noise levels for select equipment (e.g., wood hog,

boiler exhaust stack and fans) will include constructing enclosures and appropriate

sound barriers around the equipment area and other industry standard noise

mitigating techniques.

During the final design phase and after final equipment choices are made, the final

mitigation measures will be designed. ADAGE will submit their analysis to the

County with the building permit application and ensure that sound levels meet the

appropriate state and county codes at the appropriate zoning interfaces.




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In the event processed biomass deliveries to the site are interrupted, ADAGE will

have the flexibility to continue to operate the plant by grinding solid woody

biomass stored on site for emergency situations. This material will be ground by

portable diesel chippers or grinders brought to the site for this specific purpose.

The portable grinding activity is limited to a maximum of 480 hours per year by the

NOC Air Permit. Grinding will be limited strictly to receiving hours and noise

mitigating enclosures will be designed and employed to insure all noise

requirements are met. Meeting these requirements has been studied and sound

attenuating techniques such as sound deadening walls will be applied.

As indicated above, with the proposed noise mitigation measures, maximum

permissible noise levels from to Site activities will be within Mason County and

Washington noise code limits at the adjacent property lines.

8. LAND AND SHORELINE USE

a. What is the current use of the site and adjacent properties?

The site is located in the Port of Shelton Johns Prairie Industrial Park. The portion of

the Park planned for development is currently forested and managed as timber land by

the Port. According to the Port of Shelton Forest Management Plan, the land owned by

the Port has been managed through small timber sales, commercial thinning and small

even-aged harvest. The forestland is managed in two blocks; Sanderson Field

(137 acres) and Johns Prairie (170 acres). The project site is located in the Johns Prairie

Block. Timber composition in this block is predominantly 50 year old Douglas Fir

interspersed with small volumes of Western Red Cedar, Lodge Pole Pine and Red Alder.

The current Forest Management Plan (compiled January 1997) recommends salvage of

storm damage and final harvest when site clearing is required for industrial

development.

To the north and east, adjacent property is zoned industrial. Various wood product

facilities located on the adjacent property, generate noises derived from truck traffic and

grinding operations, among others. South and West of the Site is zoned residential and

is largely undeveloped.

Figure 7 shows a map of the site and the adjacent property owners and uses.




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b. Has the site been used for agriculture? If so, describe:

Our investigation did not indicate any prior agricultural use on the Site.

c. Describe any structures on the site

There are no structures on-site.

d. Will any structures be demolished? If so, what?

No structures are planned for demolition.

e. What is the current zoning classification of the site

Industrial

f. What is the current comprehensive plan designation of the site

Industrial within Shelton Urban Growth Area

g. If applicable, what is the current Shoreline Master Program designation of the site




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Not Applicable

h. Has any part of the site been classified as an ―environmentally sensitive‖ area? If so,

specify

The site and surrounding area are located over a critical aquifer recharge area. The

proposed project includes a Conditional Environmental Permit application (submitted

separately) which outlines the specific measures that ADAGE will follow to ensure that

the critical aquifer recharge area is not adversely impacted.

i. Approximately how many people would reside or work in the completed project

24

j. Approximately how many people would the completed project displace

None

k. Proposed measures to avoid or reduce displacement impacts, if any

Not Applicable

l. Proposed measures to ensure the proposal is compatible with existing and projected land

uses and plans, if any

The 2005 Port of Shelton Comprehensive Plan states the following for the heavy

industrial district in Johns Prairie:

This land use district is intended for the truly heavy industrial land uses that do

not require visibility from a major roadway: instead they require larger sites with

room for handling and storage of raw and refined materials. Offices are an

appropriate accessory land use within this district. Landscaping is an important

aesthetic component, and can be used to identify building entrances and the

public side of the facility.

This district reflects a majority of the existing uses at Johns Prairie. Many

existing port tenants fall within this category. Heavy industrial uses are defined

as those that involve the handling or processing of raw materials in an outdoor

setting, with heavy equipment; like sawmills, log yards, bulk storage of raw

materials, and concrete plants.




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The ADAGE facility fits with the expected tenant list of the heavy industrial area.

Measures to make the proposal compatible with adjacent land uses are presented

throughout the SEPA checklist and include but are not limited to the following:

The project site is located within an industrial park which is zoned, in its entirety,

industrial. Existing development in the park consists of other wood/timber

production facilities handling materials similar to the feedstock for the proposed

biomass plant. Adjacent property to the west and south is zoned residential

although limited residential development currently exists in the area.

The site plan has been developed to minimize potential impacts to existing and

future development in the adjacent property.

The facility has been designed to locate the mechanical systems to minimize the

impact to surrounding property owners.

Appropriate buffering will be placed along site boundaries near residential areas to

mitigate noise and lighting impacts in accordance with City of Shelton and Mason

County requirements.

A noise study was conducted to evaluate potential sources of noise at the Site and to

propose measures to mitigate their impacts.

A traffic study was conducted to evaluate traffic to and from the Site and to propose

measures to mitigate traffic impacts.

Directional lighting will be used in work area to direct lights downward,

minimizing the impacts to the adjoining property.

Air quality impacts will be addressed and minimized through compliance with

applicable local, state, and federal regulations and requirements.

Exhibit 17 provides a summary of steps that will be taken to mitigate potential impacts

associated with the proposed project.

9. HOUSING

a. Approximately how many units would be provided, if any? Indicate whether high,

middle, or low-income housing

Not Applicable

b. Approximately how many units, if any, would be eliminated? Indicate whether high,

middle, or low-income housing.




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Not Applicable

c. Proposed measures to reduce or control housing impacts, if any

Not Applicable

10. AESTHETICS

a. What is the tallest height of any proposed structure(s), not including antennas; what is the

principal exterior building material(s) proposed?

The tallest height of any proposed structure is the stack with a height of approximately

170 feet from adjacent grade. The proposed height of other structures at the Site is

summarized in Item 10.b.

The primary buildings on site include the following:

Power Island

Administration Building

Workshop

Covered Clean Woody Biomass Fuel Storage

The principal exterior materials for these buildings will consist of field fabricated ribbed

metal panels with batt insulation for the walls and metal standing seam panels for the

roofs. The exterior walls will have metal personnel doors, roll-up doors for truck access,

metal framed windows, and metal air intake and exhaust louvers; and the roofs will have

gutters and downspouts.

Interior surface finishes will vary. Materials will include metal liner panels, vinyl scrim

facing, concrete masonry units and gypsum board as appropriate for interior protection.

b. What views in the immediate vicinity would be altered or obstructed?

The proposed project will have minimal impact on views in the area for several reasons:

The site is relatively flat and covered with trees rising to heights of 100 feet or more.

The existing vegetation screens the surrounding views. This vegetation will be left

in buffer areas around the Site.

The tallest structure on site will be the industrial stack which rises to a height of

170 feet above the surrounding terrain. The stack will be located approximately

1700 feet from the nearest residence. Given the size of the stack (approximately

10 ft in diameter), the distance to the nearest residence, and the proximity of Douglas




Page 65

Firs and other tall tree species, etc. to the closet residential area, the stack will not

alter or obstruct existing views in the immediate vicinity.

The table below presents the approximate heights of structures greater than 45 feet

above the surrounding terrain. The proposed heights of these structures are similar

to other industrial operations in the area.

Structure Heights

Structure Height

A-frame 85 feet

Raw water tank 50 feet

Boiler House 150 feet

Turbine House 65 feet

Baghouse 90 feet

Air Cooled Condenser 95 feet

Fuel Processing Tower 75 feet

Truck Dumpers 92 feet

Stack 170 feet

A Special Use Permit Application (submitted separately) has been submitted to address

Mason County Code 17.07.450 which limits building heights to 45 feet above the

surrounding ground.

The potential visual impact of the facility on structures located within 1000 feet of the

Site will be limited due to the terrain, existing vegetation that will be left in place, and

proposed landscaping and buffer zones,

The potential visual impact of the proposed facility on surrounding views were

evaluated several ways:

ADAGE constructed a 3-D model of the facility based on the site design and

photographs from of the Site taken from the north, south, and east. The average tree

height was assumed to be 80 feet. Potential line of sites were established based on

the model.

Helium balloons were used to approximate the height of the tallest structures on the

site. Three large helium balloons were raised to heights of 100 feet, 150 feet and

200 feet above the ground surface located at the center of the power island.

Photographs were then taken from several vistas surrounding the site that would

potentially overlook the facility. The balloons were observable from two locations

off the Site. The first location is from Eagle Ridge Drive looking east. The second

view is from Johns Prairie Road and Mill Right Road looking southwest. The

photographs of the balloon study and renderings based on that data are shown in




Page 66

Exhibit 16A. These simulations demonstrate that the facility will be generally

unobtrusive and will be obscured by vegetation and trees

On the basis of this analysis, the visual impact of the proposed facility will be limited.

c. Proposed measures to reduce or control aesthetic impacts, if any:

The proposed facility will be located on the 87-acre Site within the Port of Shelton’s

existing industrial park. To the north and east of the Site, the adjacent property is zoned

industrial. Various wood product facilities are located on these adjacent properties and

have operations similar in nature to the proposed facility. To the south and west of the

Site, the adjacent property is zoned residential. and is largely undeveloped. There are

approximately 22 residences within 1000 feet of the Site.

According to the Land Use Classifications in Section 17.03.034, the Site will be

classified as a Category VI - Industrial. In accordance with Mason County and Shelton

UGA code 17.07.860, the following buffer areas will be maintained:

North and east of the Site, the adjacent properties are parts of the same parcel as part

of the Johns Prairie Industrial Park. The land uses on these properties are also

classified as Category VI. Accordingly, a 50 foot buffer and setback area will be

maintained. To the north, existing tree cover will provide screening of the proposed

Site; to the east, a stormwater basin will be located within the buffer/setback area.

South and west, the adjacent properties are classified as Category I - Residential. A

minimum buffer of 50 – 100 feet of existing trees and vegetation will be left along in

place excluding entrance and exit roads.

Figure 7A shows the zoning and land uses of the land parcels within 1,000 feet of the Site

lease line.

Where possible, the Site will maintain buffer areas in their native vegetated state to

provide screening from ground level sources of noise as well as reduce and control the

aesthetic impacts by the proposed site development. Additional understory plantings will

be added to provide additional screening around existing residential areas. A facility

color scheme will be utilized for the exteriors of the buildings and equipment in order to

minimize the contrast with the existing vegetation.

To the extent possible, measures have been taken to make the proposal compatible with

adjacent land uses or to mitigate potential impacts on surrounding property. These

measures include:

The project site is located within an industrial park which is zoned, in its entirety,

industrial. Existing development in the park consists of other wood/timber

production facilities handling materials similar to the feedstock for the proposed

biomass plant. Adjacent property to the west and south is zoned residential although

limited residential development currently exists in the area.




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The site plan has been developed to minimize potential impacts to existing and

future development in the adjacent property by locating equipment away from

residential boundaries and providing a buffer areas and screening for adjacent

properties.

The facility layout has been designed to separate the mechanical systems to from

surrounding residential property to minimize the impact to surrounding property

owners.

Appropriate buffering will be placed along site boundaries near residential areas to

mitigate noise and lighting impacts in accordance with City of Shelton and Mason

County requirements.

A noise study was conducted to evaluate potential sources of noise at the Site and

measures to mitigate potential noise impacts have been incorporated into the site

design and will meet the required standards.

A traffic study was conducted to evaluate traffic to and from the Site and to propose

measures to mitigate traffic impacts on other users of the roadways.

Directional lighting will be used in work area to control glare and direct lights

downward, minimizing the impacts to the adjoining property and the travelers on

Capitol Hill Road.

11. LIGHT AND GLARE

a. What type of light or glare will the proposal produce? What time of day would it mainly

occur?

Pole-mounted lights will be provided to meet the recommendations of the applicable

ANSI lighting standards for worker safety, and the requirements of WAC 296-800-

21005 for the minimum acceptable exterior lighting at night where employees are

working outside at night.

b. Could light or glare from the finished project be a safety hazard or interfere with views?

No. Due to the isolated location of the Site relative to normal traffic patterns, the

exterior lighting will not present a safety hazard.

Natural vegetation will be maintained at the Site in the buffer areas, screening adjacent

properties from the lights or glare. The lights will be located at a height of

approximately 20 to 40 feet above the surrounding terrain which is lower than the

existing trees in the buffer areas. These factors will prevent the Site lighting from

interfering with existing views.

c. What existing off-site sources of light or glare may affect your proposal?

None




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d. Proposed measures to reduce or control light and glare impacts, if any:

Visual screening including earthen berms will be provided in the buffer areas adjacent to

residential properties. The landscaping will meet the applicable requirements of MCC

Title 17.

Over-illumination will be reduced to avoid excessive scattering of light into the

atmosphere. Lights will utilize cutoff lenses which restrict the lateral light distribution to

greatly reduce the lighting which spills onto adjacent properties. See Exhibit 18 on

proposed lighting shrouds.

These measures will minimize light trespass from the Site, reduce sky glow, improve

nighttime visibility through glare reduction, and reduce development impact on

nocturnal environments

12. RECREATION

a. What designated and informal recreational opportunities are in the immediate vicinity?

North of the Industrial Park (more than 2400 feet north of the Site) is a baseball park and

soccer field used by the general public. Other parks and recreational facilities located

within a mile of the Site are shown on Figure 7. The proposed facility will have no

impact on existing recreational opportunities in the area.

b. Would the proposed project displace any existing recreational uses? If so, describe.

No recreational uses will be displaced.

c. Proposed measures to reduce or control impacts on recreation, including recreation

opportunities to be provided by the project or applicant, if any:

The proposed facility will have no impact on recreational opportunities in the area. The

site is more than 2400 feet from the nearest public recreational area and is screened by

both vegetation and a large hill.

13. HISTORICAL and CULTURAL PRESERVATION

a. Are there any places or objects listed on, or proposed for, national, state, or local

preservation registers known to be on or next to the site? If so, generally describe.

An Archaeological Resources Assessment was prepared for the project site (Exhibit 4).

As part of this assessment, state and other databases of known archaeologically and

culturally significant sites were researched to identify other known area resources. A

four day field investigation was conducted to evaluate field conditions. As part of the

field study, seventy-six shovel probes were excavated and their contents examined. No




Page 69

archaeological resources were identified during this study. The study concluded that this

project has no potential to affect known archaeological sites, since none were identified

at the Site. Based on a combination of negative fieldwork results, and taking into

account the high probability estimated by the Washington Department of Archaeology

and Historic Preservation's predictive model in the areas sampled, the overall probability

for archaeological resources is moderate in most of the Area of Potential Effect (APE)

with a lower probability in the far western portion of the area. The lower probability

areas surveyed included areas in the southwestern and northwestern portions of the APE.

Locations not surveyed during this study include lower-moderate probability areas in the

central-far western APE and in portions of the northeastern part of the APE.

Prior to the start of the assessment, representatives of the Squaxin Island Tribe were

contacted (by telephone and letter) and invited to be present during the field

investigation. The results of the study have been presented to tribal representatives.

b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or

cultural importance known to be on or next to the site.

None

c. Proposed measures to reduce or control impacts, if any:

Not Applicable at this time

If evidence of historically, archaeologically, or culturally significant resources are

identified at the Site during construction, construction will be suspended until the

resources are analyzed and evaluated.

14. TRANSPORTATION

a. Identify public streets and highways serving the site and describe proposed access to the

existing street system. Show on site plans, if any.

Traffic Flow during Operations

The facility produces electricity 24 hours per day, 365 days per year. However, truck

deliveries for fuel and other chemicals will be limited to a 15 hour window (7 a.m. to

10 p.m., weekdays only). ADAGE anticipates the proposed project will result in the

following changes to current traffic patterns:

Approximately 94 trucks will arrive at the site on a daily basis, averaging 6.3 trucks per

hour. This will include:

Fuel trucks – Approximately 86 fuel trucks will deliver wood to the facility during

receiving hours. This equates to an average of 5.7 fuel trucks per hour arriving at the

site. Typical trucks will be 45 feet chip vans carrying approximately 28 tons of




Page 70

chipped wood. The trailers will have an average axle loading not to exceed state

requirements of 34,000 lbs per dual axle.

Ash trucks – Approximately 3 trucks per day will haul ash from the site between the

hours of 8 a.m. and 5 p.m., five days a week. Each vehicle will carry approximately

25 to 30 tons of ash. The ash would be loaded into covered intermodal containers

approximately 13.5 feet high by 40 feet in length. The ash will be hauled to a

transfer station in Centralia. Washington, approximately 45 miles south of the site.

At the transfer station, the ash will be loaded on rail cars for haul to the Roosevelt

Landfill in Klickitat County, Washington. Following plant operation a Beneficial

Use Determination will be discussed with Ecology. If it is determined that the ash

can be beneficially reused the number of trucks traveling this distance may decrease.

Supply trucks – On average 5 supply trucks per day will deliver material to the plant

generally between the hours of 8 a.m. and 5 p.m., five days a week. These trucks

will range in size depending on the material.

There will be 4 shifts of 5 people, with shift changes at 6 a.m. and 6 p.m. There will also

be two mechanics, an office administrator and plant manager working during the week

days. The traffic study used a more conservative number of 12 people per shift.

Traffic routes for fuel vehicles will remain constant over time. The main entrance to the

plant will be via Production Road off of Johns Prairie Road. The nearest major roadways

that will be used to access the Site are US-101 to the west and SR-3 to the east. ADAGE

has signed long-term agreements with major timber firms in the area and based on input

from these firms, ADAGE has estimated the following traffic patterns:

Five primary fuel routes will be used to bring fuel from other counties into Mason

County and then subsequently to the facility. These routes include:

US-101 from the North (exit at Wallace Kneeland) - Approximately 6.5 percent of

the fuel deliveries will use this route.

US 101 from the South (exit at Wallace Kneeland ) - Approximately 27 percent of


SR-3 from the Northeast (exit at Johns Prairie Road) - Approximately 6.5 percent of


SR 108 from the Southeast (intersects with US-101 South at Kamilche and exits at

Wallace Kneeland) - Approximately 49 percent of the fuel deliveries will use this

route.

Shelton Matlock Road (County road from the west intersects to SR-102. South on

US-101 to Wallace Kneeland). - Approximately 11 percent of the fuel deliveries will

use this route.

Fuel will be sourced from both within and outside of Mason County. A map showing

major fuel source routes and percentage of truck traffic on interstate highways, state

routes, and major Mason County roads is included in Exhibit 7A.




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Overall, the project will increase traffic along Johns Prairie Road by less than 2 percent

except at the intersection of Johns Prairie Road and Production Road where the increase

will be less than 5 percent. This is based on one additional truck traveling along this

route approximately every 10 minutes.

Road Capacity

Currently, the roads and intersections impacted by the proposed ADAGE project are

designed for traffic flows in excess of 1,000 vehicles per hour. This volume compares

with an impact from the ADAGE facility of less than 6 vehicles per hour on average.

Traffic flow along Wallace Kneeland and Johns Prairie ranged from an average of 109

to 550 vehicles per hour between 7 a.m. and 10 p.m., or 11 to 55 percent of the design

capacity. The proposed ADAGE project, on average, will add less than 10 vehicles per

hour, or 1 percent of the design capacity to the total flow. The resulting traffic volume

will remain less than 60 percent of the design capacity. A summary of these average

traffic flows are shown in Exhibit 7A.

In Figure 7A is a map of Mason County showing possible routes fuel trucks will be using

for the life of the project. Construction routes are also identified in Figure Y.

Traffic Flow During Construction:

The expected traffic volumes during construction of the plant were also considered. Over

a 30 month construction schedule roughly 15 construction and equipment supply trucks

per day can be expected, yielding 30 daily trips. Truck volumes would be negligible

compared to volumes when the plant is normally operating.

ADAGE has been working with major equipment suppliers to identify truck loading

rates during construction that would require special permitting with WSDOT and the

County for height, weight, or other special conditions. Our analysis has concluded that

one truck load will require special permits and consideration. This load will be the boiler

steam drum (approximately 5.5 feet in diameter, 26 feet in length, 4 inch thick steel wall)

that will weigh close to 55 tons and must be transported as a single load. ADAGE has

been in contact with WSDOT for early discussion and pre planning of this equipment

delivery. Other construction trucks supplying material and equipment to the plant will

maintain legal load limits for both WSDOT and County road systems.

Peak construction employment is estimated to add up to 320 additional personal vehicles

per day (640 car trips) at month 19 of the construction schedule. Average personnel

construction traffic over the 30 month construction schedule is estimated at

approximately 100 personal vehicles per day, or 200 vehicle trips.

Following the peak of construction activity in month 19, the total number of vehicles will

start to be reduced, eventually to only the 48 trips a day for the operations team. At

month 28, the first fuel deliveries will begin arriving on site.




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The Traffic Impact Analysis (Revised) is included in Exhibit 7A. There is significant

additional information in the Traffic Impact Analysis that should be reviewed to

understand the full impact on traffic from the proposed ADAGE power plant.

b. Is site currently served by public transit? If not, what is the approximate distance to the

existing street system? Show on site plans, if any.

Currently there is no public transit that serves the Site directly. A review of the Mason

County Transportation Authority regional bus schedule shows the closest bus routes are

on Route 1 providing service from Shelton Belfair via SR-3, and Route 7 providing

service to north Shelton.

c. How many parking spaces would the completed project have? How many would the

project eliminate?

No parking spaces will be eliminated by this proposal. The site plan (Figure 4) calls for

the construction of 26 new parking stalls for permanent employees, including two ADA-

accessible stalls for disabled parking spaces. Adequate onsite parking will be provided

for anticipated employees and visitors. Additional parking stalls meeting Mason County

Standards will be provided as required to comply with the requirements of MCC

Title 17.08 Parking Standards.

Sufficient on-site parking will be provided for truck traffic delivering biomass to the Site

as shown in Figure 4, to prevent trucks from queuing on public roads. There will be no

off-site queuing. The site design includes a staging area for trucks to wait if they cannot

enter the Site immediately upon arrival. Once trucks enter the fenced area, there will be

additional staging areas along onsite access roadways for trucks waiting to deliver their

loads of biomass.

During construction, on-site parking will be provided for construction workers,

including two areas for craft labor and construction trailers. Additional truck parking

will be provided adjacent to a materials lay-down and storage area. The locations

provided for this parking will depend on the phase of construction, as shown on the

construction staging plan in Figure 8.

d. Will the proposal require any new roads or streets, or improvements to existing roads or

streets, not including driveways? If so, generally describe (indicate whether public or

private).

The project does not require the construction of new roads or streets. A planned County

Road extension connecting East Production Road on the north to East Capitol Prairie

Road on the south will be rerouted around the perimeter of the Site.




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The traffic study (Exhibit 7) evaluated the need for upgrades to existing roads to support

the proposed project. Procedures in the WSDOT Design manual determined left and

right turn lanes would not be warranted for Johns Prairie Road at East Production Road.

However, the study recommended radius treatment (widening of the corner pavement)

on Johns Prairie Road at East Production Road.

Traffic volumes from PUD #3 were included in the future traffic volumes estimations

discussed previously. Figure 7, page 15 "Pipeline Volumes" also includes PUD #3

volumes. Figure 8, Page 16 "2015 PM Peak Hour Volumes without Project" includes

PUD #3 along with regular traffic. Figure 9, Page 17 "2015 PM Peak Hour Volumes

with Project" includes PUD #3, regular traffic plus ADAGE traffic.

US-101 is one of the primary routes used to delivery fuel to the facility. Long term

closure of this highway could interrupt fuel transport and as such is of concern to

ADAGE. Fuel truck will be primarily traveling from the south along US 101, but some

fuel trucks will approach the Site from the north. Based on information provided by

WSDOT, the historical problem area for closures are north of the project site.

ADAGE has been in contact with WSDOT to review the historical closures of US and

State highways within Mason County and received the following information:

Wind Storm Damage - May block state highways up to 2 days.

Flooding - May block or close state highways up to 1 week (SR-8, 106, 107, 108)

rare occurrences.

Mud-Slides-Road Failures - Does occur on US 101-south of Hoodsport (up to a

week at worst case).

Winter Freeze-Thaw Cycles - May close the lower constructed routes

(SR-106/102/108/107/119) for week or more (rare occurrence).

Upon detailed review of fuel source routes and the information provided by WSDOT

identifying historical causes, locations and durations of highway closures, ADAGE has

concluded that onsite fuel storage will be adequate to support commitments for plant

reliability in the event of a typical highway closures within Mason County. If all storage

areas were full, the site could store approximately 21 days of fuel at full capacity.

However, under normal operating circumstances ADAGE expects 7 days of stored

fuel(at 100 percent plant operation) providing adequate margin for continued plant

operation in the event of a highway closure that would interrupt a portion of required

fuel supply. In summary, the information supplied by WSDOT confirms that ADAGE

will not require alternate routes for fuel delivery in the event of a highway closure within

Mason County.

Unless there was a complete closure of US 101 operations would not be impacted. If

this situation ever occurred, for example due to an earthquake or ice storm, then




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ADAGE would have the ability to reduce or cease plant operations under the terms of its

power sales contract.

After discussions with WSDOT, they see no impact to SR 3 due to the truck traffic

generated by this project.

e. Will the project use (or occur in the immediate vicinity of) water, rail, or air

transportation? If so, generally describe.

There is a rail spur adjacent to the site within the Industrial Park but ADAGE has no

current plans for using this spur or the rail line for delivery of fuel.

The use of water, rail, or air transportation is not a part of the current business plan. A

local railroad spur is located on adjacent property. Construction or operation of the

power plant will not interfere with the existing railroad spur or any other form of water,

rail, or air transportation.

Notification has been sent to the FAA regarding the project, informing them of the

proposed 170 ft stack and requesting verification that the stack will not interfere with

aviation and has the correct obstruction lighting.

f. How many vehicular trips per day would be generated by the completed project: If

known, indicate when peak volumes would occur.

Twenty four employee vehicular trips per day are anticipated, with 12 employees

expected on site per 12 hour shift. Shift change will occur at 6 a.m. and 6 p.m. daily.

During normal operation the average truck traffic will range from 80 to 100 trucks per

day. Under peak conditions truck traffic could rise to 140 trucks per day. Peak delivery

hours are planned for receiving hours which averages to 8.3 trucks per hour. The

following table indicates the projected trip generation based on peak hours 7 and 9 a.m.

and 4 to 6 p.m.

TABLE 2

Project Trip Generation

Time Period

Truck

Trips

Employee

Trips

Total

Trips

Truck

Trips

Employee

Trips

Study Study Study Typical Typical

AWDT 200 vpd 48 vpd 248 vpd 184 vpd 28 vpd

AM Peak Inbound 9 vph 4 vph 13 vph 6 vph 4 vph

AM Peak Outbound 9 vph 0 vph 9 vph 6 vph 0 vph

AM Peak Total 18 vph 4 vph 18 vph 12 vph 4 vph

PM Peak Inbound 9 vph 12 vph 21 vph 6 vph 5 vph




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PM Peak Outbound 9 vph 12 vph 21 vph 6 vph 9 vph

PM Peak Total 18 vph 24 vph 42 vph 12 vph 14 vph

g. Proposed measures to reduce or control transportation impacts, if any:

The results of the traffic study (Exhibit 7A) indicate that there will be no significant

impacts due to the proposed facility. To improve the traffic flow, the study

recommended a radius turn improvement for right hand turns from East Johns Prairie

Road onto East Production Road. In addition, the study recommended that ADAGE

make a pro-rata contribution towards WSDOT improvements at the intersection of East

Johns Prairie Road and SR-3. These recommendations will be implemented.

It should also be noted that these major road way were all constructed based on Mason

County and WSDOT standards. The County performs regular maintenance on these

roads and they are in good condition. These roads are rated for 1,000 cars per hour.

Delivery trucks will be within the RCW 46.44 regulations for axel loads. This traffic

will have a relatively de minimus impact on the wear and tear of these roads. ADAGE

will be paying taxes to help fund any improvements that will be necessary on these roads

as does every citizen of Mason County.

By current WSDOT standards, traffic counts, visual distances, and speed

limits acceleration/deceleration turning lanes on Johns Prairie Rd are not required.

However, because traffic on Johns Prairie Road typically exceeds the posted speed limit

(the County went out with a radar gun to verify this) , Mason County has a safety

concern surrounding the trucks turning onto East Production Road as well as entering

East Johns Prairie Road from East Production Road. The County has requested the

installation of an acceleration/deceleration turning lanes on Johns Prairie Road and

ADAGE has committed to funding this improvement.

The City of Shelton Comprehensive Plan indicates deficiencies at several locations by

2025. In lieu of analyzing this horizon year, Adage would participate in the future

improvements at these locations within the Adage study area. Based on the above,

proposed mitigation for the Adage Mason Biomass Plant is as follows:

Provide pro-rata contribution towards WSDOT improvements at the Johns Prairie

Rd/SR-3 intersection. Approximately afternoon (4 p.m.) peak hour project trips

would be expected at this intersection. It is noted that ADAGE has been a

participant in discussions with WSDOT regarding the needs at this intersection and

will continue to participate in its future solution.

Provide pro-rata contribution towards future improvements at the E Wallace

Kneeland Blvd & Olympic Hwy N intersection as identified in the City of Shelton

Comprehensive Plan. A deficiency at this intersection is projected by the year 2022

in the Comprehensive Plan. The recommended improvements are an eastbound right




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turn lane and a 2nd northbound left turn lane. ADAGE project-related traffic is

expected to add 26 trips to this intersection during the afternoon peak hour.

Provide pro-rata contribution towards future improvements at the N 13th St & N

Shelton Spring Road/W Alpine Way intersection as identified in the City of Shelton

Comprehensive Plan. A deficiency at this intersection was projected by the years

2013 and 2025 in the Comprehensive Plan. Note however that the ADAGE TIA

(Exhibit 7A) does not indicate the same deficiency by 2015. The Comprehensive

Plan recommended improvements for 2013 are to change the intersection to an

all-way stop configuration, and restripe the northbound approach from 3 lanes to

2 lanes. The recommended improvements for 2025 are installation of a traffic signal

with northbound and southbound protected left turns. ADAGE project-related traffic

is expected to add 7 trips to this intersection during the afternoon peak hour.

Provide pro-rata contribution towards future improvements at the Wallace Kneeland

Blvd/Johns Prairie Rd & N 13th Street/Brockdale Rd intersection as identified in the

City of Shelton Comprehensive Plan. A deficiency at this intersection is projected

by the year 2025 in the Comprehensive Plan. The recommended improvements are

installation of a traffic signal with eastbound and westbound left turn protected

phases. ADAGE project-related traffic is expected to add 35 trips to this intersection

during the afternoon peak hour.

Provide pro-rata contribution towards future improvements at the Batstone Cutoff

Rd & Brockdale Rd intersection as identified in the City of Shelton Comprehensive

Plan. A deficiency at this intersection is projected by the year 2025 in the

Comprehensive Plan. The recommended improvements are construction of

northbound and southbound left turn lanes, and installation of a signal. ADAGE

project-related traffic is expected to add 3 trips to this intersection during the

afternoon peak hour.

Given the truck traffic associated with the project, along with the high speeds on

Johns Prairie Road, the project proposes to fund a right turn lane on Johns-Prairie

Road for truck traffic turning south onto East Production Road. In addition, an

acceleration lane/two way left turn lane is proposed on East Johns-Prairie Road for

exiting traffic. Design for these measures would be to Mason County standards.

ADAGE understands that Mason County may explore a future new connection route

between McEwan Prairie Road and Johns Prairie Road. Following plant operation,

ADAGE will be an active member of a State/County/stakeholder working group to

explore this potential option.

The top priority of ADAGE during site development, construction, and plant operations is safety:

safety of the residents of Mason County; safety of our vendors and contractors; and safety of the

plant personnel operating and maintaining the plant.




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For commodities transported to and from the plant site, first and foremost, ADAGE will ensure

that professional drivers are employed either directly or through supporting contractors to the

plant. These drivers will hold the appropriate professional licenses and certifications, and will

typically be local to Mason and the surrounding counties. The professional qualifications in

tandem with local knowledge of the roads and annual road conditions will help to ensure driver

safety year around. In addition, local knowledge of school zones, pedestrian usage, and other

safety sensitive areas will assist our tractor / trailer operators in maintaining safety in vehicle

operation. Moreover, most deliveries of fuel and supplies will occur during daylight hours

(receiving hours) which are typically considered the hours with the best visibility to enhance safe

operations. It is also important to note that the equipment used to transport commodities to and

from the plant will be well maintained vehicles with regular maintenance on safety important

systems including tires and brakes.

Another very important factor protecting public safety is the quality of the local road systems.

ADAGE has reviewed the local traffic routes for pavement quality, safety striping, signage, speed

limits and intersection operation. We have concluded that the quality and design of the road

systems that we will utilize within Mason County are adequate to assure safe fuel and commodity

delivery.

ADAGE also understands the importance of safety in school zones. Flashing yellow lights

identifying reduced speeds in school zones (20 mph) during arrival and departure times for

students provide a key visible safety function in protecting the students in these areas.

Lastly, our suppliers will be well aware of the times of congestion on Wallace Kneeland Blvd in

both the morning and late afternoon. These times of congestion coincide with the arrival and

departure of students from both the junior and senior high schools. We will work closely with our

fuel and commodity suppliers to minimize deliveries during these congested periods. This will

lessen the number of trucks that will be present on Wallace Kneeland when the students are –

thus raising the probability of long term safety of the students and residents of Mason County.

15. PUBLIC SERVICES

a. Would the project result in an increased need for public service (for example: fire

protection, police protection, health care, schools, other)? If so, generally describe:

Generally, the facility will have a need for public services similar to other industrial

facilities employing approximately 24 people. There is the potential for a slightly

increased need for Fire Protection due to the storage of ammonia and wood fuel on the

site. The site will meet fire code requirement and conform to good practices of NFPA.

ADAGE has met with Mason Fire District Five officials and has initiated discussions to

determine the type of equipment needed on site as well as developing best management

practices for fire prevention and emergency response.

b. Proposed measures to reduce or control direct impacts on public services, if any:

ADAGE has prepared an Emergency Response Plan (ERP) for handling emergencies at

the Site. This plan will be updated prior to operations and will be reviewed with local




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and state public service agencies. It provides opportunities for joint training with public

services to address requirements for ERP. A copy of the ERP is included in the BMPR

(Exhibit 9A). This document will also be updated periodically to address changes in site

design or operations.

ADAGE has spoken with Larry Waters and Mark Core from the Mason County

Planning and Inspection Department to discuss a fire management plan. The Plan

will be maintained on site and updated periodically if changes occur at the site. The

Fire Management plan will include the following topics:

o Requirement to conduct onsite fire fighting training and the identification of

potential fire hazards for plant personnel

o Requirement to install and maintain equipment for fighting fires. The local

fire department will be invited to participate in training with ADAGE

employees in emergency response.

Daily observations of the woody biomass storage areas will be performed by plant

personnel to identify potential fire hazards. Plant personnel will be trained on

identification of potential fire hazards.

Signs will be posted at the plant, which identify potential fire hazards.

Procedures established by the National Fire Protection Agency (NFPA) for outdoor

storage piles will be followed.

Incoming materials will be stored in areas with a clearance area.

Fine woody biomass material will be minimized in the storage areas.

Compaction of woody biomass in storage areas will be controlled as necessary to

maintain proper storage conditions.

16. UTILITIES

a. Circle utilities currently available at the site: electricity, natural gas, water, refuse

service, telephone, sanitary sewer, septic system, other:

None. The Site is currently undeveloped.

b. Describe the utilities that are proposed for the project, the utility providing the service,

and the general construction activities on the site or in the immediate vicinity which might

be needed.

Figure 9 provides potential tie in locations for utilities. These locations will be finalized

during the design process.




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Sewer - The City of Shelton provides wastewater collection and treatment services for the

residents, commercial establishments, and industries in its current service area. The

service area is currently set at the City limits; however, future service areas have been

formally acknowledged in sewer plans from 1994 forward, including the November 2001

Shelton Area Water and Sewer Regional Plan as supplemented by the December

2005/April 2006 Shelton Regional Sewer Plan Wastewater Facility Plan, which together

serve as the current plan and which are incorporated by reference. No known sewer

districts lie within the boundaries of the Shelton UGA.

Wastewater in the Shelton UGA is generally treated by private septic systems. Sewer

system plans anticipate that the planned regional sewer system will include the City of

Shelton, Washington State Patrol, and Washington Corrections Center. The Port is no

longer involved as a regional partner, but will someday become a retail customer, and its

future needs have been anticipated in the plan. In order to mitigate the existing problems

and meet the 20-year demand, the City of Shelton Comprehensive Sewer Plan and

amendments contain recommended projects and funding plans to be implemented within

the City’s Capital Facilities Plan. Projects that eliminate existing deficiencies will be

weighted higher on the inventory lists.

Twenty-year population projections are similar to those identified for water system plans.

Therefore, infiltration/inflow (I/I) improvements, monitoring of actual flows, sewer plan

updates to new horizon years and population projections, together with conservation and

water reuse are anticipated to assist in meeting revised growth levels for the City and the

Shelton UGA. When the City’s treatment plant was constructed the engineers designed

the plant to be easily expanded to meet future treatment needs of Shelton. In addition, the

City of Shelton is planning a satellite wastewater reclamation plant in the vicinity of the

Washington Corrections Center, Washington State Patrol, and Port of Shelton. Design

criteria for the satellite facility include that it must be expandable in modules. The tiering

discussion under ―Water‖ above applies as well to the issue of ―Sewer‖ service.

The City of Shelton has anticipated future extension of sewer services to the Johns Prairie

area as part of the Urban Growth Area long range plan. There are two alternative

approaches for wastewater service to the Site which are being evaluated by the City of

Shelton. Both alternatives will result in the discharge of wastewater to the Shelton

Regional Wastewater Collection System. Under both alternatives, the local aquifer

would be protected as compared to the current reliance on onsite disposal systems.

ADAGE is unable to select an alternative at this time as the City is finalizing their review

of how they’ll provide this service. The City of Shelton Letter of Water and Sewer

Service Availability (Exhibit 14) provides options the City is considering and does not

indicate which option is most likely to be selected. The City’s comprehensive planning

process (scheduled to be completed this fall) will determine what type of system the City

will choose for servicing the area and the ADAGE facility. The selected alternative

would need to meet the applicable design criteria from the City of Shelton, Mason




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County, and the Department of Ecology. A more detailed discussion of the alternatives

follows:

Wastewater Treatment Alternative 1: The first alternative would be to construct a sewer

line from the powerplant to the closest portion of the existing City of Shelton wastewater

collection system which has sufficient capacity to handle the volume of wastewater

generated by the powerplant. This alternative would require the construction of a

combination of gravity sewers and forcemains in East Production Road and East Johns

Prairie Road, to a location near the 600 Block of Johns Prairie Road. It is anticipated that

this extension of the City’s sewer main would run east along Johns Prairie Road. The

ultimate length, size, overall design, and construction of the sewer extension will be a

City permitted and managed project. Detailed impacts associated with this sewer line

extension could involve up to 4-5 months of daytime single lane closures on portions of

Johns Prairie Road.

Wastewater Treatment Alternative 2: The second alternative would be to construct a

satellite water reclamation facility (i.e., a Membrane Reactor or Package Plant) to serve

the Johns Prairie area. The impacts of constructing this alternative are unknown because

the City has not determined the proposed location of the plant or the type of facility to be

constructed. Once the location has been determined and the service area can be

identified, the required infrastructure can be designed and the impacts can be determined.

Under either of these options, ADAGE will connect to the City sewer mains at Johns

Prairie Road. A sewer service line will run from extension from the Johns Prairie road

interconnect point to the plant property boundary, or a distance of approximate 3225 ft.

This line will be constructed on the east side of Production Road in the existing Port of

Shelton utility right of way. During construction, East Production Road will be closed to

traffic for a period of approximately 1 to 2 weeks. Local traffic will be rerouted along

East-West Road to East Export Road – a diversion of less than ¼ mile.

This impact will consist of a single lane of Johns Prairie Road being closed for the two

week period during normal daytime work hours. The road would be returned to two lane

service at the end of each work day. Flaggers will be provided for traffic control

throughout the duration of construction.

The process wastewater will contain the minerals typically found in the incoming City

water although in slightly concentrated amounts along with trace water treatment

additives for conditioning the boiler water. The process wastewater will be much cleaner

than the waste water typically discharged from a residential dwelling with a very low

organic content.

Potable and Process Water - Potable and process water will be supplied by the City of

Shelton. Exhibit 14 is a letter from the City discussing requirements for water supplies

from the City’s system. The City of Shelton is currently constructing a new 16 inch




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water main to serve the Mason PUD # 3 facility on East Johns Prairie Road. The new 16-

inch water main will be located on the south side of East Johns Prairie Road. The City

will annex the Port’s existing 16-inch water main that runs along East Johns Prairie Road

and the 8-inch connecting line that runs south along East Production Road. This will

result in the provision of City water to a portion of the Industrial Park. The Port will

transfer ownership of the Port’s existing 8-inch water main serving the Johns Prairie

Industrial Park to the City of Shelton, providing water service to the entire industrial

park. This work was not being planned or executed as part of the proposed power plant

project.

To connect the Site to the water system will entail extension of the existing water main to

the Site (approximately 3300 feet of water line in the existing Port of Shelton’s existing

utility right of way on the east side of East Production Road). The water line for the

proposed project will connect to the City’s 16-inch main near the intersection of East

Johns Prairie Road and East Production Road. Because the water main is located on the

south side of Johns Prairie Rd, the connection will have minimal impact to traffic on East

Johns Prairie Road during construction of the interconnection. Construction is

anticipated to restrict traffic on a segment of East Johns Prairie Road to a single lane

during daylight hours over a 24 to 48 hour period. Flaggers will be provided for traffic

control.

Fresh water supplied by the City of Shelton will be stored in a 300,000 gallon raw water

tank. This tank will feed the boiler water make-up system and provided storage to meet

the firewater system requirements. The boiler requires water to be much purer than

drinking water to prevent corrosion of the metal components. City water will be

conditioned into boiler feedwater by removing the minerals in the water through a

combination of reverse osmosis membranes and polishing ion exchange demineralizers.

These devices remove the minerals in the city water and make it fit for boiler use. On a

periodic basis the minerals are back flushed from the water treatment system and become

part of the process wastewater. A small amount of minerals passes through the

conditioning system and into the boiler. To keep these minerals from building up in the

boiler system, a small amount of water is discharged (blown down) from the boiler

system. This water is cooled and discharged to the sanitary sewer along with other

process wastewater. These two streams (along with a small quantity of sanitary

wastewater) make up the bulk of the waste water that ADAGE will discharge to the

City’s wastewater treatment system.

Telephone Service - Telephone service will be provided by Qwest, or similar

communications provider. The Qwest telephone lines would be extended from Johns

Prairie Road along Production Road to get to the Site.

Fiber Optic Network - The existing fiber optic service operated by Mason PUD # 3 will

be extended to the project site. This will involve running a line from the PUD#3’s fiber

ESA LISTED SALMONIDS CHECKLIST

Page 83

Applicant Information Project Information

F. Reed Wills

President

225 Wilmington West Chester Pike

Suite 302

Chadds Ford, PA 19317

(610) 358-3404

Jim Gaston

Project Manager

1620 Olympic Highway North

Suite 4

Shelton, WA 98584

(509) 713-0467

Location :

The plant will be located on portions of two parcels in Mason County, in the southwestern corner

of the Port of Shelton’s 400 acre Johns Prairie Industrial Park located at 500 East Export Road.

Description:

ADAGE Mason, LLC (ADAGE) is proposing to construct a 60 Megawatt (MW) woody biomass

electric power plant in Mason County at the Johns Prairie Industrial Park just north of the city of

Shelton. The facility will be located on a 87-acre Site that is zoned industrial.

This worksheet was designed to help project proponents, and government agencies, identify

when a project needs further analysis regarding adverse effects on ESA (Endangered Species

Act) listed salmonids. Salmonids are salmon, trout and chars, e.g. bull trout. For our purposes,

―ESA Listed Salmonids‖ is defined as fish species listed as endangered, threatened or being

considered for listing.

If ESA listed species are present or ever were present in the water shed where your project will

be located, your project has the potential for affecting them, and you need to comply with the

ESA. The questions in this section will help determine if the ESA listings will impact your

project.

The Fish Program Manager at the appropriate Department of Fish and Wildlife (DFW)

regional office can provide information for the following two questions. 1. Are ESA listed salmonids currently present in the watershed in which your project will be

located? YES _X__ NO ____ Please describe.

ESA listed salmonids are present in Johns Creek approximately ¾ mile north of site but there is

no surface water connection from the property to the Creek.

2. Has there ever been an ESA listed salmonid stock present in this watershed? YES

__X___ NO _____ Uncertain _____ Please describe.

ESA listed salmonids are present in Johns Creek approximately ¾ mile north of site but there is

no surface water connection from the property to the Creek.


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If you answered “yes” to either of the above questions, you should complete the remainder

of this checklist.

PROJECT SPECIFICES: The questions in this section are specific to the project and

vicinity. 1. Name of watershed: Johns Prairie Aquifer

2. Name of nearest waterbody: Johns Creek

3. What is the distance from this project to the nearest body of water: ¾ mile

Often a buffer between the project and a stream can reduce the chance of a negative impact to

fish.

4. What is the current land use between the project and the potentially affected water body

(parking lots, farmland, etc.)?

The topography is relatively flat. Land use varies from industrial to residential. A major road

(East Johns Prairie Road) is located between the site and the Creek and would provide a barrier

to surface water flow.

5. Is the project above a:

natural permanent barrier (waterfall) YES _____ NO __X___

natural temporary barrier (beaver pond) YES _____ NO __X___

man-made barrier (culvert, dam) YES _____ NO __X___ * other (explain):

6. If yes, are there any resident salmonid populations above the blockage? YES _____ NO _____

Don’t know _____ NA

7. What percent of the project will be impervious surface (including pavement & roof area)?

Approximately 20 percent.


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FISH MIGRATION: The following questions will help determine if this project could

interfere with migration of adult and juvenile fish.

Both increases and decreases in water flows can affect fish migration. 1. Does the project require the withdrawal of:

a. Surface water? YES _____ NO __X___ Amount___________________________

Name of surface water body __None________________________________________

b. Ground water? YES _____ NO __X___ Amount ________________________

From where ___________NA____________________________________________

Depth of well _____________NA_________________________________________

2. Will any water be rerouted: YES _____ NO __X___

If yes, will this require a channel change?

3. Will there be retention or detention ponds? YES __X___ NO _____ If yes, will this be an

infiltration pond or a surface discharge to either a municipal stormwater system or a surface

water body?

Stormwater runoff will be captured by the use of drainage swales, catch basins, and diversion

berms and diverted to the stormwater management system. The location of stormwater

management system components is shown on the site plan (Figure 4). Stormwater that requires

treatment will pass through passive treatment areas such as constructed wetlands, biofilter

swales, biofilter strips, or other comparable systems. The use of these and other passive systems

will be evaluated for treating stormwater runoff from the fuel storage areas prior to onsite

infiltration. Stormwater which contains significant amounts of wood or sediment materials will

be screened using a debris trap, to avoid contamination and fouling of the biological treatment

structures which follow. Treated stormwater will be allowed to reinfiltrate recharging the

regional aquifer.

If to a surface water discharge, please give the name of the waterbody. Not applicable

4. Will this project require the building of new roads? YES __X___ NO _____

Increased road mileage may affect the timing of water reaching a stream and may impact fish

habitat.

An existing road on the parcel proposed for development will be relocated to the perimeter of the

site. The portion to be relocated is less than 1 mile in length. The revised road alignment will not

impact surface water flows on the site or to the Creek.

5. Are culverts proposed as part of this project? YES _____ NO __X___

6. Will topography changes affect the duration/direction of runoff flows? YES _____ NO

__X___ If yes, describe the changes.

7. Will the project involve any reduction of the floodway or floodplain by filling or other

partial blockage of flows? YES _____ NO ___X__

If yes, how will the loss of flood storage be mitigated by your project? Not applicable


Page 86

WATER QUALITY: The following questions will help determine if this

project could Adversely impact water quality. Such impacts can cause

problems for listed species.

Water quality can be made worse by runoff from impervious

surfaces, altering water temperature, discharging contaminants, etc. 1. Do you know of any problems with water quality, in any of the streams, within this

watershed? YES _____ NO __X___

If yes, describe.

Not applicable

2. Will your project either reduce or increase shade along or over a waterbody?

YES _____ NO __X___ (Removal of shading vegetation or the building of structures such as

docks or floats often results in a change in shade.)

3. Will the project increase nutrient loading or have the potential to increase nutrient

loading or contaminants (fertilizers, other waste discharges, or runoff) to the waterbody? YES

_____ NO __X___

4. Will turbidity be increased because of construction of the project or during operation of

the project? YES _____ NO _X____ In-water or near water work will often increase turbidity.

5. Will your project require long term maintenance, i.e. bridge cleaning, highway salting,

and chemical sprays for vegetation management, clearing of parking lots? YES _____

NO __X___ If yes, please describe.


Page 87

VEGETATION: The following questions are designed to determine if the project will affect

riparian vegetation, thereby, adversely impacting salmon. 1. Will the project involve the removal of any vegetation from the stream banks: YES

_____ NO __X___

If yes, please describe the existing conditions, and the amount and type of vegetation to be

removed.

2. If any vegetation is removed, do you plan to re-plant? YES _____ NO _____ If yes,

what types of plants will you use?

Not applicable

Documents

MASON CO. REVISED ENVIRONMENTAL CHECKLISTmyweb.hcc.net/pkands/docs/sepa_checklist.pdf · MASON COUNTY Revised SEPA Checklist ADAGE Mason LLC (ADAGE) Nominal 60 MW Woody Biomass Electric