Morgantown Coal Barge Unloading Facility

Environmental Review Document

Application for Approval to Modify a Generating Station:
Mirant Mid Atlantic is seeking approval from the Maryland Public Service
Commission (PSC) to modify the existing Morgantown Generating Station by
adding a new coal barge unloading facility under the requirements of a "non-
utility" generator in Subtitle 79 of the Title 20 Code of the Maryland Regulations
(COMAR). The approval in this case would be based on recommendations from
interested local, state and federal agencies to ensure compliance with federally
delegated, state regional and local environmental laws and regulations. This
Environmental Review Document submitted with the modification application is
filed with the PSG, pursuant to the PSG Regulations found in COMAR 20.79.01
through 20.79.03. The application and environmental review document includes
a description of the site and existing power plant installations, all proposed
changes or alterations of the site and plant, the new or altered associated
facilities, the environmental and other impacts of the project, and the
environmental and other benefits to be realized from the project.
Facility Description:
The Morgantown Generation Station is 525 acre site on the Potomac River, just
south of Route 301 at the Potomac River Nice bridge near the town of Newburg,
Maryland. The facility consists two base loaded 620 MW coal and residual oil
fired boilers, six peaking #2 oil fired combustion turbines (2x20 MW Frame 5 and
4x65 MW Frame 7), two auxiliary boilers, associated fuel handling and storage
facilities and electric transmission facilities. Coal is delivered to the Morgantown
Station by CSXT unit train. The coal is unloaded using an enclosed rotary railcar
dumper and is either transferred by conveyor directly to the station bunkers or
placed into storage using a stacker reclaimer. Residual oil is delivered to the
Station by pipeline and No.2 oil is delivered barge.
Constructing the coal barge unloading facility at Morgantown will expand and
diversify the coal supply base for both the Chalk Point and Morgantown Stations.
These Stations were designed in the 1960-1970s to burn Northern Appalachian
coal (Pennsylvania, Western Maryland, and Northern West Virginia). The
Northern Appalachian coal region production has undergone significant changes
during the last 3-4 decades characterized by mine closures, reduced production
and the consolidated of producers. These changes have resulted in fewer mines
producing the quality of coal to meet both Morgantown and Chalk Point's coal
quality requirements. Additionally, Morgantown and Chalk Point are captive to a
single delivering railroad, CSX Transportation.
The coal barge unloader will allow Mirant to diversify its coal supply base by
accessing the Central Appalachian Region (Central and Southern West Virginia,
Southern Virginia and Kentucky) and offshore coal supply from Columbia and
Venezuela. Central Appalachian coal will be transported by rail to the Tidewater
Piers in Virginia by either CSX Transportation or Norfolk Southern, loaded into
barges and shipped to Morgantown. Offshore coal will be off loaded from ocean
going vessels at a deepwater port (Tidewater Virginia or Baltimore) and then
transferred to barges for shipment to Morgantown. Both of these scenarios will
significantly expand Morgantown and Chalk Point's coal supply base and create
a transportation alternative resulting in optionality for both facilities.
The Morgantown Generating Station new coal barge unloading facility will consist
of a dock, unloader, a transfer and distribution system and a rail loading facility.
The coal barge unloading facility is sized to unload 5.0 million tons of coal per
year, the annual consumption rate of both Morgantown and Chalk Point. In
addition, Mirant will maintain the capability of the existing Morgantown railcar
unloading system for back up capability. An overall site plan of the barge
unloading facility is shown on drawing SP-1. The barge unloader's overall flow
schematic is shown in drawing FS-1.
The coal barge unloader's transfer and distribution system will be integrated into
Morgantown's existing coal handling system as much as possible. The coal
transfer system is designed to provide the capability to transfer coal from barges
directly to the plant, to on-site storage or to railcars for transport to Chalk Point.
The railcar loading capability allows the barge unloader to transfer coal directly to
railcars for transport to Chalk Point or reclaim coal from on-site storage for
transport to Chalk Point.
The barge unloader's 600-foot long dock will extend approximately 11 OO-feet
channelward into the Potomac River parallel to Morgantown's existing oil barge
channel. No dredging will be required to deepen or expand the existing Potomac
River or Morgantown channels. The dock will be able to accommodate two
15,000 DWT hopper barges. The 600-foot long dock includes a 50 X 42 foot
main platform constructed on steel pipe piles, a concrete deck, a fender system
and four 48" diameter steel pipe monopile dolphins. The main dock platform
supports the unloader, acts as a fender structure and supports the receiving
conveyor gallery that transfers the coal to the transfer tower on shore. A 1,200
TPH pedestal-mounted vertical-screw mechanical unloader is installed on the
dock. During the unloading process the barge will shift along the fender line
using a continuous cable haul system. Barge unloading will be conducted as a
drop and swap operation. A tug will bring a loaded barge to the dock and take
the empty barge back to its supply point. Approximately 265 to 350 barges
deliveries per year will be needed to meet the two Station's coal supply.
The dock unloader will feed an approximate 860 foot long 1200 TPH enclosed
conveyor BC-1 , which conveys the coal to the on shore transfer tower TT -1. An
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approximate 1850-foot enclosed and covered conveyor BC-2 (350-foot enclosed
and 1500-foot covered) will transfer the coal from transfer tower TT -1 to transfer
tower TT -2. An approximate 760-foot covered conveyor BC-3 will then transfer
the coal to the existing coal yard transfer tower at the breaker house where the
process will be integrated into the existing Morgantown coal handling system. At
that point coal can be transferred directly into the plant, placed in onsite storage
using Morgantown's existing stacker-reclaimer or transferred to railcars for
shipment to Chalk Point. The general arrangements of conveyors BC-1, BC-2
and BC-3 are shown in drawings GA-1 through 3.
There are two rail loading options being considered. Option 1 is directly
connected to the transfer station at the breaker house and allows for direct
transfer from barge to railcar. Option 2 is a satellite operation that does not allow
for direct barge to railcar transfer. Both railcar loading systems require two 1000
TPH approximately 600-foot (BC-4) and approximately 400-foot (BC-5) covered
conveyors that transfer coal to an elevated railcar loader.
Mirant is projecting to start construction in mid-2006 and commission the barge
unloader in the fourth quarter of 2007. A conceptual schedule for the permitting
and construction of the project is presented in Attachment A.
Air Emission Sources:
The barge unloader and its associated conveyor system and railcar loader will be
a source of fugitive particulate matter (PM) and particulate matter with a diameter
less then 10 um (PM-10) emissions. Fugitive PM and PM-10 emissions will
occur at several points of the barge's coal unloading, transfer and railcar loading
operations. The barge unloader will not be a source of any other pollutants.
The barge unloader has 7 activities that will be a source of fugitive PM and PM-
10 emissions. They are the conveyor's 4 transfer towers, the dock unloader, the
railcar transfer, and the railcar loader. These 7 emission points are projected to
emit a total of 3.33 tons/year of PM and 1.15 tons/year of PM-1 O. These
emissions were determined using EPA AP-42 emission factors and a maximum
coal throughput of 5.0 million ton/year. The emissions by activity and back-up
emission calculations are presented in Attachment B.
The actual emission increases from the proposed project will be less than what is
reported above. With the barge unloader in operation, Morgantown's existing
railcar unloading operation and its associated emissions will be reduced or
eliminated all together. Because of Mirant's desire to maintain rail as a coal
delivery option, the Company will not propose netting emissions from the
reduced or discontinued rail operations.
To determine if the emission increases associated with barge unloader are
considered a significant modification to an existing major source and must under
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go Prevention of Significant Deterioration (PSD) [40 CFR 52.21 & COMAR
26.11.06.04] review, the emission increases are compared to PSD Significant
emission thresholds. Table 1 shows the barge unloaders emission increases
are well below the PSD emission thresholds 25 tons/yr for PM and 15 tons/yr for
PM-10. The barge unloader is considered a minor modification and will not have
to undergo PSD review.
Table 1: Emission Increase Summary
Additional minor sources have also been permitted at Morgantown in the recent
years. They include the new auxiliary boiler and the Snyfuel Process. These two
sources are permitted to emit a total of 5.05 tons/yr of PM and 4.71 tons/year of
PM-10. The permitted emissions from these sources are presented in Table 2.
These sources were minor sources or minor source modifications and were
permitted as such.
Table 2 : Previous Permitted Emission Increase
Source I PM (tn/yr) I PM 10 (tn/yr)
Aux. I
Boiler
I
snyfuel
l Process
4.410 4.410
0.640 0.300
ITotal 5.050 4.710
Applicable Air Emission Standards:
Because the barge unloader is a minor modification under the PSD rules there
are no Federal permitting or PSD related emission control requirements. Further
there are no applicable Federal new source performance standards (NSPS) or
hazardous air pollutants (HAPs) standards for this facility.
The barge unloader will be subject to the following Maryland Department of The
Environments Air Quality Regulations.
Visible Emission Limit [COMAR 26.11.06.02C (1)] - Requires opacity to
be less than 20 percent.
.
d
Visible Emission Limit [COMAR 26.11 .O6.02C (3)] - Requires no visible
emission across property line from material handling actives.
.
Particulate Matter from Material Handling and Construction [COMAR
26.11.06.030 (1 )-(6)] - Requires reasonable precautions to prevent
particulate matter from becoming airborne from material handling
actives.
.
.
Toxic Air Pollutants [COMAR 26.11.15.04 & .07] - Requires new
sources to quantify toxic emissions and demonstrate compliance with
toxic air pollutants screening levels.
The Morgantown barge unloader is to incorporate the best engineering design
and operational practices to minimize fugitive dust at all the unloading, loading,
and conveyor transfer stations. The barge unloader will incorporate in its design
the following fugitive dust suppression technology: (a) enclosed and covered
conveyors, (b) enclosed transfer stations, (c) telescoping loader, and (e) a
partially enclosed railcar loader. The control efficiencies for these designs are
found in the following table.
Table 3: Design Control Efficiencies
Design
Control Efficiency
Enclosed Transfer Stations
-
90%
75%
75%
Telescooina Loader
Partially Enclosed Railcar Loadout /Loader
The MDE Permit to Construction Form (Form 5) for the Barge Unloader is
presented in Attachment C.
The barge unloader's fugitives hazardous air pollutants emission rates were
calculated and were compared to their appropriate toxic screening level emission
rates. The hazardous air pollutant emissions rates are all well below the toxic
screening levels. The MDE Toxic Emission Forms (Form 5A & 58) and back up
calculations are presented in Attachment D.
Water and Terrestrial Related Impacts:
Station Location
The Morgantown Station is located in Charles County Maryland on the northeast
bank of the Potomac River. The Station is 41.5 nautical miles upstream from the
confluence of the Potomac River with the Chesapeake Bay and 53.5 nautical
miles downstream from Washington, D.C. Several small marinas are located
"
directly above and below the Station. The U.S. Naval Test Center at Dahlgren,
VA lies directly across the river from Morgantown.
Geomorphology and Flows and Obstructions
In the vicinity of the plant, the Potomac River is approximately 1 O,OOO-ft wide. A
navigation channel, located closer to the Maryland bank, is maintained by the
U.S. Army Corps of Engineers. Water depths vary from about 82-ft at mid-
channel to 10-ft at the channel lines. The mean annual freshwater discharge is
approximately 13,400 cfs. The spring tidal flow is approximately 220,000 cfs
downstream during the ebb stage and upstream during the flood stage.
At the Station, a dredged channel, 200 to 260 feet wide and perpendicular to the
intake structure, is maintained out to a distance of approximately 1200 feet. The
channel was originally dredged to 50-ft. Siltation over the years has reduced the
depth at centerline to about 40-ft.
The plant property extends for approximately 1/4-mi along the main stem of the
Potomac River. Fifty percent of this length is "hardened" with riprap or concrete
structures associate with the facility's intake and outfall. Dolphins are located off
shore where the current barge docking area is, along the intake channel. \
Sheet ice, in general, does not form in the Potomac River near the Station. .
However, sheet ice which has formed in the freshwater portion of the river
upstream of the site near Washington, D.C. does accumulate along the shoreline
at Morgantown.
Siltation is a problem in the Potomac River. In the vicinity of the Morgantown
Station, extensive shoaling has occurred. The siltation can be attributed to a
decrease in river velocity as the estuary widens, allowing suspended particles to
settle.
Vegetated Habitat
A littoral marsh area is located just south of the plant. The emergent species
found there include: Spartina a Itern iflora. S. cynosuroides, S. patens, Atriplex
patula, Eleocharis parvula, Typha angustifolia, Lilaeopsis chinensis, Iva
frutescens, Scirpus american us, S. pungens, S. robustus, Acnida cannabina,
Pluchea purpurescens, Kosteletzkya virginica and Rumex verticillatus.
A Submerged Aquatic Vegetation (SA V) study was performed in the Spring (May
25) and Summer (September 1) of 2004. A kayak was used to paddle transects
of the shoreline from the discharge canal to the mouth of Pasquahanza Creek,
out to a depth of about 6 feet. The only grass beds noted were concentrated at
the mouth of Pasquahanza Creek. The beds continued north along the shoreline
(to 30' offshore in places) for approximately 300 feet from the creek mouth. The
most abundant species in the creek and along the shoreline was Myriophyllum
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spicatum (Eurasian watermilfoil). To a lesser degree, Vallisneria americana (wild
celery) was found mixed in with the milfoil in the creek and along the shoreline.
Floating pieces of Ruppia maritima (widgeon grass) was found tangled in mats of
other debris being pulled towards the Station's intake structure, but no beds of
widgeon grass were noted during the survey.
The project will take place well north of the SA V bed locations and should have
no impact on the vegetation.
Wildlife (fish/shellfish, birds, mammals)
The Potomac River estuary at Morgantown Station falls into both the oligohaline
and mesohaline salinity regimes, depending on the time of the year and flows. A
number of fish and shellfish species are concentrated around the Station. Finfish
are present either as generally permanent residents such as white perch and
gizzard shad, seasonal residents like bay anchovy or juveniles of species
seeking the protection of the estuary like menhaden, or as adults during
spawning runs like striped bass or shad. Blue crab, American oyster and
brackish water clam are the main shellfish found in the area. Fish and shellfish
should not be impacted by this project. The biggest concern for a project such as
this one would be oyster bed disturbances. This area is on the cusp of being too
fresh for oyster production. The closest oyster beds (Pascahana bar) are located
just south of the proposed structure.
Waterfowl are abundant on the Potomac River during the winter months. The
river around the project site is considered by DNR to be a waterfowl staging area.
This project however, shouldn't have any impacts on the present waterfowl use
of the area directly in front of the facility. There are already barges using the site
and any additional lighting, structures in the river and traffic will be concentrated
in these industrial use areas.
There are probably no aquatic or semi-aquatic mammals using the present intake
area where this work is proposed. Beaver, otter and muskrat activities are more
likely concentrated further inland on the site or in the tidal wetlands found in
PasquahanzaCreek.
Recreational Uses (fishing, hunting, boating)
The recreational uses of the Potomac River in the area surrounding the site are
primarily fishing, hunting and boating. There is a good deal of fishing that takes
place in the warm water plume of the facility's discharge. This area is located to
the north of the proposed project and shouldn't be impacted by the proposed
project. Neither will the new construction preclude small craft from being able to
follow the shoreline along Mirant's waterfront.
Hunting for waterfowl is allowed in the Potomac River. There are two blinds
licensed near the facility, both around Pasquahanza Creek. In the past, the
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company purchased the blind rights, but in recent years Mirant has stopped that
practice. The proposed construction and associated extra barge traffic shouldn't
have any impact on this activity.
Recreational boat traffic in this part of the Potomac River is generally not
concentrated. The activities at Dahlgren tend to keep people moving through the
area and there are no attractions such as waterfront restaurants or sandy
beaches that tend to draw boaters, other than the marina at Aqualand, which is
located north of the 301 Nice Bridge. An increase in barges to the facility should
not impede the flow of boat traffic in the area nor will the proposed pier and
conveyor act as a barricade to small craft from hugging the shoreline along
Mirant's waterfront in the case of inclement weather.
Commercial Uses (fisheries, barge traffic)
According to the Potomac River Fisheries Commission (PRFC), the official body
in charge of fisheries on the main stem of the Potomac River, no pound nets are
typically located in the immediate vicinity of the proposed work. There are gill
netters that set up near the facility during the season for that fishery (generally
November through March), although it appears the fishing is more concentrated
around the plant's discharge, north of the proposed work site. Crabbing is
another commercial fishery in the river. Commercial crabbers in the Potomac
River typically use pots and trot lines. Both can be run anywhere outside of the
federally designated channel. The season generally runs from April through
November. It is probable that crabbers work the shallow offshore areas in front
of the Station during the commercial season, although the work proposed should
have little impact on such uses. Commercial oyster harvesting in that part of the
river is nonexistent at this time, according to the PRFC.
Required Permits
The construction of the Barge Unloader requires the submittal of a Joint
Federal/State Application for the alteration of any floodplain, waterway, tidal or
nontidal wetland in Maryland [40 CFR 233 and COMAR 26.23]. The application
is presented in Attachment E. Both Federal and State agencies will review the
permit. On the State level, this permit will be reviewed by MDE. Neither tidal nor
nontidal wetlands will be impacted for this project, but the Department of Natural
Resources will have input on time of year restrictions for the in-stream work to
take place, as well as input on any species of concern that may be in the area. It
is anticipated that the process should be fairly routine.
The Army Corps of Engineers is the Federal reviewing agency and the lead
agency for work in waterways. It is anticipated from conversations with the
Corps that they will make the determination that the work meets the terms and
conditions of the Maryland State Programmatic General Permit (MDSPGP-2).
R
The Barge Unloader's onshore construction will take place within the Intense
Development Overlay (100) portion of Morgantown's Chesapeake Bay Critical
Area Plan. The barge unloader's construction and operation conform to activities
allowed in the 100 area. The Morgantown Station has a Critical Area
Conservation Plan in place and a bank of credit for permanent disturbances
within the 100 of the Critical Area. Mirant will update the Critical Area Plan to
include the additional impervious surface created by the Barge Unloader's
construction.
Summary of Additional Impacts-Effects:
Aesthetic Impacts
The Barge Unloader's construction footprint is within an existing developed
industrial zone. There will be minimum additional environmental impacts from
either the construction or operation of the barge unloader. No areas of
previously undisturbed land will be required for the construction of the Barge
Unloader. The bulk of the onshore project development will take place in
Morgantown's existing coal and rail yard. The project will require no increased
water use on the site, or create any new waste products or discharges.
This portion of the Potomac River is developed on both sides. Dahlgren U.S.
Naval Test Center, the Harry Nice Bridge, US Route 301 and multiple marinas all
add to an overall industrial feel to the area surrounding the Morgantown
Generating Station. The addition of the Barge Unloader will have only minimal
impacts on the River's existing view shed and noise levels.
Increased Barge Traffic Impacts
The project will increase commercial river traffic by approximately one barge
round trip per day. This portion of the Potomac River has only limited
commercial water borne traffic. The additional impact on existing commercial or
recreational river traffic in the Potomac River Channel will be minimal.
Construction Impacts
The Barge Unloader will be constructed over an 18-month period. All
construction impacts will be temporary in nature. Construction materials will be
brought to the site by truck, rail or barge. Morgantown's existing transportation
facilities are all capable of accommodating this temporary increase in road, rail or
barge traffic.
There will be increases in storm water runoff from the new facility. The storm
water runoff will be routed to the existing storm water collection system. The
Storm Water Pollution Prevention Plan will be updated to include and identify the
increased potential runoff from the project.
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Economic Impacts
Mirant expects that there will be no increase in employment at the Station for
operating the Barge Unloader. With the Barge Unloader in operation, rail traffic
into the Morgantown Station will decrease. There will no additional road traffic
associated with the operation of the new facility.
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