APPENDIX G

Air Quality Modeling Protocol & Air Quality

Impact Analysis Documentation

Air Quality Modeling Protocol

October 15, 2013 mk017-13 Ms. Margaret Valis Chief, Impact Assessment and Meteorology NYSDEC – Division of Air Resources 625 Broadway Albany, NY 12233-3254 Subject: Caithness Long Island II, LLC

Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County, New York Atmospheric Dispersion Modeling Protocol

Dear Ms. Valis: TRC has been retained by Caithness Long Island II, LLC (Caithness) to prepare a prevention of significant deterioration (PSD) permit application for a proposed approximately 752-megawatt (MW) combined cycle power facility to be constructed in the Town of Brookhaven, Suffolk County, New York. The approximate Universal Transverse Mercator (UTM) coordinates of the Caithness Long Island Energy Center II are 673,621 meters Easting, 4,520,851 meters Northing, in Zone 18, NAD83. Caithness is proposing to install two (2) General Electric (GE) 7FA.05 combustion turbines at the facility. The combustion turbines will be primarily natural gas-fired with distillate fuel oil with a sulfur concentration of no greater than 15 ppm (“ultra-low sulfur diesel” or “ULSD”) as backup fuel. Dry low NOx burners and Selective Catalytic Reduction (SCRs) will be used, in addition to water injection when firing ULSD, to reduce nitrogen oxides (NOx) emissions from the combustion turbines. The firing of primarily natural gas and ULSD as backup in the combustion turbines will minimize emissions of particulate matter with an aerodynamic diameter less than 10 microns (PM-10), sulfur dioxide (SO2) and sulfuric acid mist (H2SO4). Additionally, an oxidation catalyst will be installed to control the emissions of carbon monoxide (CO) and volatile organic compounds (VOC). Exhaust gases from each combustion turbine will flow into an adjacent heat recovery steam generator (HRSG) equipped with natural gas-fired duct burners. Each HRSG will produce steam to be used in the steam turbine generator. Combustion products will be discharged through two (2) exhaust stacks. Supporting auxiliary equipment includes a gas/ULSD fired auxiliary boiler, two (2) emergency diesel generators, and an emergency diesel firepump.

Ms. Margaret Valis October 15, 2013 Page 2 of 2

Enclosed please find two (2) copies of the atmospheric dispersion modeling protocol for the Caithness Long Island Energy Center II project located in the Town of Brookhaven, Suffolk County, New York. The enclosed protocol contains a project and site description and a preliminary site plan. The protocol also contains a detailed description of the modeling methodology proposed for the air quality impact analysis to be included in the PSD permit application. Please feel free to contact me or Ted Main at 201-508-6954 or 201-508-6960, respectively, should you have any questions regarding the enclosed protocol. We look forward to working with you on this project. Sincerely, TRC

Michael D. Keller Senior Project Manager cc: A. Coulter, U.S. EPA

M. Garber, Caithness R. Ain, Caithness T. Grace, Caithness M. Murphy, Beveridge and Diamond S. Gordon, Beveridge and Diamond T. Main, TRC C. Adduci, TRC K. Maher, TRC TRC Project File 206458 W:\keller\mk017-13.ltr.doc

AIR QUALITY MODELING PROTOCOL

Prepared for

Caithness Long Island II, LLC

Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County,

New York

Submitted to

New York State Department of Environmental Conservation

Prepared by

TRC 1200 Wall Street West, 5th Floor

Lyndhurst, New Jersey 07071

October 2013

i

TABLE OF CONTENTS Section Page

1.0 INTRODUCTION ............................................................................................................... 1-1

2.0 AREA DESCRIPTION ........................................................................................................ 2-1

3.0 FACILITY DESCRIPTION ................................................................................................. 3-5

3.1 Equipment/Fuels ............................................................................................................ 3-5 3.2 Operation ........................................................................................................................ 3-5 3.3 Selection of Sources for Modeling ................................................................................ 3-6 3.4 Exhaust Stack Configuration and Emission Parameters ............................................. 3-6 3.5 Good Engineering Practice Stack Height ...................................................................... 3-7

4.0 REGULATORY REQUIREMENTS .................................................................................... 4-1

4.1 New Source Review ........................................................................................................ 4-1 4.1.1 Attainment Status ....................................................................................................... 4-1 4.1.2 Prevention of Significant Deterioration ............................................................... 4-2 4.1.3 Preconstruction Ambient Air Quality Monitoring Exemption ............................ 4-3

4.2 New York State Requirements ...................................................................................... 4-4

5.0 MODELING METHODOLOGY ......................................................................................... 5-1

5.1 Model Selection .............................................................................................................. 5-1 5.2 Surrounding Area and Land Use ................................................................................... 5-1 5.3 Meteorological Data ....................................................................................................... 5-2 5.4 Land Cover Analyses ...................................................................................................... 5-4

5.4.1.1 Methodology ....................................................................................................... 5-4 5.5 Sources ............................................................................................................................ 5-7 5.6 Load Analysis .................................................................................................................. 5-7 5.7 Startups/Shutdowns....................................................................................................... 5-7 5.8 1-Hour NO2 Modeling..................................................................................................... 5-9 5.9 Receptor Grid ............................................................................................................... 5-10

5.9.1 Basic Grid ............................................................................................................. 5-10 5.10 Background Ambient Air Quality ................................................................................. 5-11 5.11 NAAQS/NYAAQS Analysis .......................................................................................... 5-11 5.12 PSD Increment Analysis ............................................................................................... 5-12 5.13 Additional Impact Analyses ......................................................................................... 5-12

5.13.1 Assessment of Impacts Due to Growth ................................................................ 5-12 5.13.2 Assessment of Impacts on Soils and Vegetation ................................................. 5-12 5.13.3 Impact on Visibility .............................................................................................. 5-13 5.13.4 Impacts on Class I Areas ...................................................................................... 5-13

5.14 Modeling Submittal ...................................................................................................... 5-13

6.0 NEW YORK STATE ENVIRONMENTAL QUALITY REVIEW ANALYSES ..................... 6-1

6.1 Fine Particulates (PM-2.5) ............................................................................................. 6-1 6.2 Acid Deposition ............................................................................................................. 6-2 6.3 Toxic Air Pollutant Analysis .......................................................................................... 6-2 6.4 Accidental Releases ....................................................................................................... 6-3 6.5 Combustion Turbine Visible Plume Analysis ............................................................... 6-3

6.5.1 TRC Visible Plume Model ..................................................................................... 6-4

ii

TABLE OF CONTENTS (Continued)

Section Page

6.5.2 Combustion Visible Plume Modeling Methodology .............................................. 6-5 6.6 LIPA Project Cumulative Impact Assessment .............................................................. 6-6 6.7 Local Large Combustion Source Cumulative Analysis ................................................. 6-6 6.8 Greenhouse Gas Emissions ........................................................................................... 6-6

7.0 REFERENCES .................................................................................................................... 7-1

LIST OF TABLES

Table No. Page Table 3-1: Combustion Turbine Source Parameters ................................................................... 3-10 Table 3-1: Combustion Turbine Source Parameters (continued) .............................................. 3-11 Table 3-2: Combustion Turbine Emission Rates ........................................................................ 3-12 Table 3-3: Auxiliary Boiler Exhaust Characteristics and Emissions .......................................... 3-13 Table 3-4: Emergency Diesel Generator Exhaust Characteristics and Emissions .................... 3-14 Table 3-5: Emergency Diesel Fire Pump Exhaust Characteristics and Emissions .................... 3-15 Table 4-1: Comparison of Proposed Project Emissions Increases to PSD Significant Modification

Thresholds and Non-attainment NSR Major Modification Thresholds ..................... 4-7 Table 4-2: National Ambient Air Quality Standards, PSD Increments, Significant Monitoring

Concentrations, and Significant Impact Levels .......................................................... 4-8 Table 4-3: New York Ambient Air Quality Standards ................................................................. 4-9 Table 5-1: Comparison of Surface Parameters for the Brookhaven Airport Meteorological Tower

and the Facility Site .................................................................................................... 5-14 Table 5-2: Combustion Turbine Modeled Emission Rates and Exhaust Parameters During Rapid

Startup on Natural Gas ............................................................................................... 5-15 Table 5-3: Maximum Measured Ambient Air Quality Concentrations ...................................... 5-16

LIST OF FIGURES

Figure No. Page Figure 2-1: Site Location Map ...................................................................................................... 2-3 Figure 2-2: Site Location Aerial Photograph ............................................................................... 2-4 Figure 3-1: Preliminary Site Plan ................................................................................................. 3-9 Figure 5-1: Full Modeling Domain and 3-Kilometer Radius Around the Caithness Long Island

Energy Center II Site .................................................................................................. 5-17 Figure 5-2: Wind Rose for the Brookhaven Airport Meteorological Tower (2008 – 2012) ...... 5-18 Figure 5-3: Location of the Proposed Caithness Long Island Energy Center II and the

Brookhaven Airport .................................................................................................... 5-19 Figure 5-4: Land Use Within One Kilometer (4-Sectors) of the Brookhaven Meteorological

Tower ......................................................................................................................... 5-20 Figure 5-5: Land Use Within One Kilometer of the Brookhaven Meteorological Tower .......... 5-21 Figure 5-6: Land Use Within One Kilometer of the Caithness Long Island Energy Center II

Site ............................................................................................................................. 5-22 Figure 5-7: Land Use Within Five Kilometers of the Brookhaven Airport Meteorological

Tower ..........................................................................................................................5-23

iii

TABLE OF CONTENTS (Continued)

LIST OF FIGURES

Figure No. Page Figure 5-8: Land Use Within Five Kilometers of the Caithness Long Island Energy Center II

Site ............................................................................................................................. 5-24 Figure 5-9: Land Use (NLCD 2006) Within One Kilometer of the Brookhaven Meteorological

Tower .......................................................................................................................... 5-25 Figure 5-10: Land Use (NLCD 2006) Within One Kilometer of the Caithness Long Island Energy

Center II Site .............................................................................................................. 5-26

1-1

1.0 INTRODUCTION

Caithness Long Island II, LLC (Caithness) is proposing to construct an approximately 752-

megawatt (MW) primarily natural gas fired 2-on-1 combined cycle power facility (Caithness

Long Island Energy Center II or CLI-II) on a parcel of land that borders the existing Caithness

Long Island Energy Center in the Town of Brookhaven, Suffolk County, New York. The

proposed facility (combustion turbines) will be primarily fueled by natural gas with ultra-low

sulfur diesel (ULSD) as emergency backup.

Because the proposed facility is located in an attainment area for sulfur dioxide (SO2), nitrogen

dioxide (NO2), carbon monoxide (CO), and particulate matter with an aerodynamic diameter

less than 10 micrometers (m) (PM-10) and will potentially emit more than 100 tons per year of

several air pollutants, it will be subject to 6 NYCRR Part 231/Prevention of Significant

Deterioration (PSD) permitting. Further, the project is subject to the New York State

Environmental Quality Review Act (SEQRA) and the potential environmental impacts of the

project will be assessed and discussed in a Draft Environmental Impact Statement (DEIS) to be

reviewed by the Town of Brookhaven, serving as Lead Agency. This protocol is prepared to

satisfy the air quality assessment requirements of both the SEQRA DEIS and Part 231/PSD

construction permit review process. The additional SEQRA air quality assessment requirements

are presented in Section 6.

For PM-2.5, Suffolk County is in the process of being redesignated from nonattainment to

attainment status. U.S. EPA established annual and 24-hour National Ambient Air Quality

Standards (NAAQS) for PM-2.5 in 1997, and strengthened the 24-hour NAAQS in 2006. When

these NAAQS were established, EPA determined that the New York City (NYC) metro area,

encompassing NYC and surrounding counties (including Suffolk County) in New York,

Connecticut and New Jersey should be designated as nonattainment. Since then, PM-2.5

concentrations have steadily improved, and, in 2010 and 2012, respectively, U.S. EPA

determined (based on multiple years of data) that the entire NYC metro area had attained the

PM-2.5 annual and 24-hour NAAQS, paving the way for formal redesignation (75 Fed. Reg.

69589; 77 Fed. Reg. 76867).

New York submitted a formal PM-2.5 redesignation request in June 2013. The submission

included a maintenance plan to ensure continued compliance with the PM-2.5 NAAQS. The

plan provides recorded and projected emissions inventories of PM-2.5 and its precursors,

including future motor vehicle emissions budgets (MVEBs) for transportation conformity

purposes. U.S. EPA has already determined that New York’s MVEBs are adequate. Since April

2013, U.S. EPA has proposed fifteen (15) PM-2.5 nonattainment area redesignation requests for

approval, with twelve (12) already finalized. Formal action on New York’s redesignation request

1-2

is expected in the near future – well in advance of agency action on CLI-II’s air permit

application. Therefore, for the purposes of this air quality modeling protocol, the proposed

project’s air quality modeling analyses will assess the project’s compliance assuming the area

that the project is to be located in is designated attainment for PM-2.5.

Non-attainment New Source Review (NNSR) rules will apply to NOx and volatile organic

compound (VOC) emissions (as precursors to the non-attainment pollutant ozone). Caithness

expects that emissions of nitrogen oxides (NOx), PM-10, PM-2.5, and CO will exceed the

pollutant specific PSD significant emission rates (SER) and, consequently, an air dispersion

modeling analysis will be required for these pollutants. Furthermore, an air quality assessment

to determine the potential impact of the project emissions on the NAAQS/NYAAQS will be

prepared to satisfy the requirements for the SEQRA DEIS.

Suffolk County is designated as moderate non-attainment for the 8-hour ozone standard. Since

the existing facility is a major source, if potential annual emissions of NOx and/or VOC exceed

the major source thresholds (i.e., 25 tons per year of NOx and/or 25 tons per year of VOC), the

proposed facility will be subject to NNSR.

The air quality analysis will be required to demonstrate that CLI-II will be compliant with all

applicable PSD increment levels, National Ambient Air Quality Standards (NAAQS), and New

York Ambient Air Quality Standards (NYAAQS). Initially, the air quality impact of the proposed

facility will be modeled using potential emission rates to determine if the facility will yield

significant air quality impacts (i.e., maximum modeled concentrations greater than the PSD

significant impact concentrations). The significance modeling will be performed for multiple

operating loads. The pollutant-specific “worst-case” operating scenario determined from the

significance modeling analysis will be used in all subsequent modeling, including any PSD

increment and multiple source NAAQS/NYAAQS analyses, if necessary.

On August 20, 2013, representatives from Caithness and TRC Environmental Corporation

(TRC), Caithness’ environmental consultants on the project, attended a pre-application meeting

with representatives of the New York State Department of Environmental Conservation (DEC)

in Albany, New York. The meeting was held to discuss key issues related to the permitting of the

proposed facility. This modeling protocol has been prepared to describe the techniques that are

proposed for completing the air quality modeling analyses for both the SEQRA DEIS/FEIS and

the Part 231/PSD requirements that will be required to demonstrate that CLI-II will comply with

requirements related to ambient impacts, such as compliance with ambient air quality

standards, PSD increments (for the Part 231/PSD air permit application), and state ambient

guideline concentrations for air toxics. The proposed modeling procedures are intended to be

consistent with guidance provided by U.S. EPA in the “Guideline on Air Quality Models” which

appears in the Code of Federal Regulations (CFR) at Appendix W of 40 CFR Part 51, the “Draft

1-3

Guidance for PM-2.5 Modeling”, March 4, 2013, Stephen D. Page, Director, OAQPS, and by DEC

in “NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact Analysis”

(DAR-10).

2-1

2.0 AREA DESCRIPTION

The proposed CLI-II facility would be located on an approximately 81.3-acre parcel that is

controlled by Caithness. The project site is located south of the Sills Road interchange (Exit 66)

of the Long Island Expressway (LIE) (Interstate 495), within the Town of Brookhaven, Long

Island, New York. The project site’s southwestern border is adjacent to an existing electric

generating facility operated by Caithness Long Island, LLC, an affiliate of Caithness.

The project site is located in the Town of Brookhaven’s L-1 Industrial District, which permits

electric generating facilities by special permit issued by the Town Board. As noted above, the

project site’s southwestern border is adjacent to an existing electric generating facility operated

by Caithness Long Island, LLC. Farther south of the existing electric generating facility is the

Zorn Industrial Park. Immediately adjacent to the project site to the west is the Sills Industrial

Park, located off Old Dock Road. The most prominent nearby land uses include a Long Island

Power Authority (LIPA) transmission line right-of-way (ROW) and the main line of the Long

Island Rail Road. The recently completed Yaphank Correctional Facility is located to the east,

beyond the LIPA ROW. The Brookhaven Landfill is nearby, located approximately 1 ½ miles to

the south-southeast of the CLI-II facility. The proposed electric generating facility will be

located approximately 0.3 miles from the nearest residences (to the northwest) across the Long

Island Rail Road ROW and Sills Road (Route 101). The Patchogue-Yaphank Road (County

Route 101) interchange with the Long Island Expressway (LIE) is located approximately 2,300

feet (0.4 miles) north of the property.

West of the proposed project site is the Medford area of the Town of Brookhaven, while

northwest and northeast are the areas of Gordon Heights and Yaphank, respectively. The

community of Shirley is located to the east while Bellport is to the south and Patchogue is

located to the southwest. The proposed site lies on the boundary between the flat coastal region

to the south and the elevated terrain region toward the interior of Long Island. Southern Long

Island’s topography is generally flat, rising from mean sea level (MSL) to approximately 110 feet

above MSL. On the north side of Long Island, some hills rise more than 300 feet above MSL.

The elevation of the site is 107 feet above MSL. Figure 2-1 presents the proposed facility’s

location on the U.S. Geological Survey (USGS) 7.5-minute topographic map (Bellport, New York

Quadrangle) for the surrounding area.

The proposed facility will be located at approximately 40º 49' 14" North Latitude, 72º 56' 28"

West Longitude, North American Datum 1983 (NAD83). The approximate Universal Transverse

Mercator (UTM) coordinates of the facility are 673,621 meters Easting, 4,520,851 meters

2-2

Northing, in Zone 18, NAD83. Figure 2-2 shows an aerial photograph of the facility location and

the surrounding area.

Caithness Long Island II, LLC Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County, New York

Figure 2-1. Site Location Map Source: USGS 7.5 Minute Quadrangle Maps – (Bellport, NY)

Site Location

Caithness Long Island II, LLC Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County, New York

Figure 2-2. Site Location Aerial Photograph Source: Google Earth, 2013

Site Location

Existing Caithness Long Island Energy Center

3-5

3.0 FACILITY DESCRIPTION

3.1 Equipment/Fuels

The CLI-II facility will consist of two (2) General Electric (GE) 7FA.05 combustion turbines at

the proposed facility site. Hot exhaust gases from the combustion turbines will flow into two (2)

heat recovery steam generators (HRSGs). The HRSGs will be equipped with gas fired duct

burners. The HRSGs will produce steam to be used in the steam turbine. Upon leaving the

HRSGs, the turbines exhaust gases will be directed to two (2) exhaust stacks. Other ancillary

equipment at the proposed facility will include a 69.3 MMBtu/hr gas/ULSD fired auxiliary

boiler, a 2.5 MMBtu/hr diesel firepump, and two (2) 18.2 MMBtu/hr emergency diesel

generators.

Caithness is proposing to utilize pipeline quality natural gas as the primary fuel for the

combustion turbines and duct burners with ultra-low sulfur distillate fuel oil (with a maximum

sulfur content of 0.0015%, by weight) as emergency backup.

Emissions from the combined cycle units will be controlled by the use of dry low-NOx burner

technology (during natural gas firing), water injection (during ULSD firing), and SCR for NOx

control, an oxidation catalyst for CO and VOC control, and the use of clean low-sulfur fuels (i.e.,

natural gas and ULSD) to minimize emissions of SO2, PM/PM-10/PM-2.5, and H2SO4. Spent

steam from the steam turbine will be sent to an air cooled condenser (ACC) where it will be

cooled to a liquid state and returned to the HRSGs.

3.2 Operation

The combined cycle units will be operated to follow electrical demand (i.e., dispatch mode), but

will be designed and permitted to operate on a continuous basis. The combined cycle units

typically will not operate at steady-state below 46% load and the duct burners will not operate

below 90% load conditions for the combustion turbines. The HRSG’s steam production will

follow the combustion turbines loads and higher HRSG steam output will only occur if duct

firing is employed during combustion turbines full load operation.

The combustion turbines/duct burners are proposed to operate 8,760 hours per year while the

auxiliary boiler is proposed to operate up to 4,800 hours per year. Up to 720 hours per year per

combustion turbine (as well as the auxiliary boiler for 400 hours per year) are proposed to

operate on ULSD. Each emergency diesel generator (as well as the emergency diesel firepump)

is proposed to operate up to 250 hours per year.

3-6

3.3 Selection of Sources for Modeling

The emission sources responsible for most of the potential emissions from the CLI-II are the two

(2) combustion turbines. These units will be included in and are the main focus of the modeling

analyses. The modeling will include consideration of operation over a range of turbine loads,

ambient temperatures, and operating scenarios. Initial modeling of the turbines by themselves

will be conducted to identify those operating conditions for each pollutant and averaging period

that yield the maximum modeled impacts. Any subsequent modeling incorporating other

emissions units at the facility or other facilities will include the turbines operating conditions

that yield the maximum modeled impacts. Modeling conducted for PM-10 and PM-2.5 will

include filterable and condensable PM.

Ancillary sources (emergency diesel generators, fire pump, and auxiliary boiler) will also be

included in the modeling for appropriate pollutants and averaging periods. The emergency

equipment may operate for up to one-half hour in any day for readiness testing and maintenance

purposes. Operation of the emergency equipment for longer periods of time in an emergency

mode would not be expected to occur when the turbines are operating. In order to facilitate

startup of the CTGs and steam turbine generator, as well as for maintenance purposes, the

auxiliary boiler may operate simultaneously with the combustion turbines for up to two hours.

Although only limited operation is expected from the emergency equipment, initial modeling to

assess short-term facility impacts will assume concurrent operation of the emergency equipment

for readiness testing (i.e., less than 1-hour per day) with the combustion turbines.

3.4 Exhaust Stack Configuration and Emission Parameters

The preliminary general arrangement for the proposed facility is presented in Figure 3-1.

Preliminary exhaust characteristics of the turbines/heat recovery steam generator stacks during

different operating scenarios are provided in Table 3-1. Exhaust parameters are presented for

gas/oil firing at four ambient temperatures (-10 degrees Fahrenheit, 0 degrees Fahrenheit, 51

degrees Fahrenheit, and 100 degrees Fahrenheit), six loads (46%, 50%, 54%, 75%, 90%, and

100%), with and without duct firing, and with and without evaporate cooling. Table 3-2 presents

the preliminary potential emission rates for each of the operating scenarios. Emission rates and

stack parameters for forty (40) ambient temperatures and load combinations will be used to

determine the “worst-case” operating scenario for the turbines. Note that per U.S. EPA PM-2.5

modeling guidance, the emissions of PM-2.5 should account for NO2 and SO2 precursor

emissions (U.S. EPA, 2013). Caithness proposes to use a numerical screening approach

suggested by the Northeast States for Coordinated Air Use Management (NESCAUM) in a May

30, 2013 comment letter to George Bridgers (Air Quality Modeling Group, U.S. EPA) responding

to “Draft Guidance for PM-2.5 Permit Modeling” released by U.S. EPA on March 4, 2013. The

3-7

approach calls for the use of a 7 percent per hour SO2 to sulfate conversion rate and a 5 percent

per hour NO2 to nitrate conversion rate. The direct PM-2.5 emission rate is then increased

accordingly by adding these incremental emissions. NESCAUM notes that it believes this

method “would provide a conservative, definitive, and defensible value of the estimated

contribution of secondary particulates”. (NESCAUM, 2013)

Finally, Tables 3-3 to 3-5 present the preliminary stack parameters and emission rates for the

auxiliary boiler, emergency diesel generators, and emergency diesel firepump, respectively. As

discussed in Section 3.3, the emergency diesel generators and emergency diesel firepump will be

included in the modeling analysis for appropriate pollutants and averaging periods when used

for readiness testing (i.e., less than 1-hour per day).

3.5 Good Engineering Practice Stack Height

Section 123 of the Clean Air Act (CAA) Amendments required the United States Environmental

Protection Agency (U.S. EPA) to promulgate regulations to assure that the degree of emission

limitation for the control of any air pollutant under an applicable State Implementation Plan

(SIP) was not affected by (1) stack heights that exceed Good Engineering Practice (GEP) or (2)

any other dispersion technique. The U.S. EPA provides specific guidance for determining GEP

stack height and for determining whether building downwash will occur in the Guidance for

Determination of Good Engineering Practice Stack Height (Technical Support Document for the

Stack Height Regulations), (EPA-450/4-80-023R, June, 1985). GEP is defined as “…the height

necessary to ensure that emissions from the stack do not result in excessive concentrations of

any air pollutant in the immediate vicinity of the source as a result of atmospheric downwash,

eddies, and wakes that may be created by the source itself, nearby structures, or nearby terrain

obstacles.”

The GEP definition is based on the observed phenomenon of atmospheric flow in the immediate

vicinity of a structure. It identifies the minimum stack height at which significant adverse

aerodynamics (downwash) are avoided. The U.S. EPA GEP stack height regulations specify that

the GEP stack height be calculated in the following manner:

HGEP = HB + 1.5L

Where: HB = the height of adjacent or nearby structures, and L = the lesser dimension (height or projected width of the adjacent or nearby structures).

A preliminary site plan for the proposed facility is shown in Figure 3-1. A GEP stack height

analysis has been conducted using the U.S. EPA approved Building Profile Input Program with

PRIME (BPIPPRM, version 04274). Controlling structures include the combustion turbine

3-8

building (85 feet above grade), steam turbine generation building (108 feet above grade), the air

cooled condenser (97 feet above grade) and the heat recovery steam generators (HRSGs) (97 feet

above grade). The GEP stack height for the two individual stacks was calculated to be 270 feet

(82.30 meters) above grade. Current plans call for the construction of two (2) 170 foot stacks to

serve the two (2) proposed combustion turbines and one (1) 170 foot auxiliary boiler stack.

Direction-specific downwash parameters for the two (2) combustion turbine exhaust stacks will

be determined using BPIPPRM, version 04274. Direction-specific downwash parameters for the

additional ancillary equipment exhaust stacks to be modeled (i.e., auxiliary boiler, emergency

diesel generators, and emergency diesel firepump) will also be determined using BPIPPRM,

version 04274. Any direction-specific building downwash parameters will be input to the PSD

modeling analysis.

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025 OIL/WATER SEPARATOR

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044 FUEL OIL UNLOADING AREA

042 FUEL OIL TANK

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117 FUEL GAS HEAT EXCHANGER

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140 AIR COMPRESSORS

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142 DESICCANT AIR DRYER

135 WATER WASH SKID

148 VT AND SURGE CUBICLE

150 HEAT RECOVERY STEAM GENERATOR

151 STACK

079 OVERHEAD CRANE

153 BOILER FEEDWATER PUMPS

156

155 DUCT BURNER VALVE SKID

157 BLOWDOWN TANK

158 BLOWDOWN TANK DRAIN SUMP

143 CYCLE CHEMICAL FEED SKID

161 LPEC RECIRCULATION PUMPS

162 CEMS SHELTER

163 AMMONIA VAPORIZER

164 AMMONIA STORAGE TANK

165

166 AMMONIA FORWARDING PUMPS

167 AMMONIA CONTAINMENT AREA

169

170

171 SCR REMOVAL AREA

172 AUX BOILER

178 ACC ELECTRICAL MODULE

179

180 NITROGEN BOTTLES

181 CO2 BOTTLE RACK AREA

182

183

SEPTIC TANK

182

APRELIMINARY

J. PEDLEY

- PRELIMINARY -

NOT FOR CONSTRUCTION

CONFIDENTIALTHESE DRAWINGS ARE CONFIDENTIAL IN NATURE. ANY MISUSE OR UNAUTHORIZED DISTRIBUTION

OF THE DRAWINGS CONTAINED HEREIN WILL BE A VIOLATION OF THIS CONFIDENTIALITY

REQUIREMENT AND SUBJECT THE VIOLATOR TO LIABILITY. REVIEW OF THESE MATERIALS BY

RECIPIENT SHALL CONSTITUTE AN ACCEPTANCE OF THESE TERMS AND THE TERMS OF ANY UNDERLYING

CONFIDENTIALITY AGREEMENT WE MAY HAVE EXECUTED IN OBTAINING THIS INFORMATION FROM A

THIRD PARTY. IF THE RECIPIENT IS NOT IN AGREEMENT WITH THE OBLIGATION OF

CONFIDENTIALITY THEN THE DRAWINGS SHALL BE RETURNED TO THE ORIGINATOR.

J. PEDLEY

J. DEDRICKSON

P010-042-PP-001-GE

PLOT PLAN

M. HICKS

M. HICKS S. HANNI

SCANNER AIR BLOWER SKID

191

056

188

058

058 CLOSED COOLING WATER PUMP SKID

056 CONDENSATE PUMPS

184

CONDENSATE POLISHERS

185

186

CONDENSATE DRAINS PUMPS

187

188

DEAERATOR/CONDENSATE HOLDING TANK

189

ACC CLEANING SKID

191

054

CCW HEAD TANK

193

MAINT/WAREHOUSE BUILDING

LEACHATE FIELD

WATER WASH/FALSE START DRAINS TANK

196

DEMIN WATER TREATMENT TRAILERS

193

01-24-11

054

086

167

169

FUEL OIL UNLOADING CONTAINMENT

AREA

119

008 BOILER FEEDWATER BUILDING

008

194

195

BLOWDOWN HEAT EXCHANGER

CARTRIDGE FILTER

194

195

BPRELIMINARY

J. PEDLEYM. HICKS S. HANNI 02-01-11

136A GAS COMPRESSOR COOLERS

103

103 GENERATOR REMOVAL AREA

SERVICE/FIRE WATER STORAGE TANK

SERVICE WATER FORWARDING PUMPS

AIR COOLED CONDENSER

AMMONIA UNLOADING AREA

AMMONIA UNLOADING CONTAINMENT

CPRELIMINARY

J. PEDLEYM. HICKS S. HANNI 02-09-11

J. PEDLEYM. HICKS S. HANNID

ISSUED FOR BID PROPOSAL

03-11-11

J. HERMANN

SJAE SKIDS

S C A L E I N F E E T

50 0 50 100

SCALE: 1" = 50’-0"

LEGEND

K

L

M

N

TIE-IN LOCATIONS

FUEL GAS (OWNER) SEE P010-042-SP-001-GE

TELEPHONE (OWNER) SEE P010-042-SP-001-GE

WATER (OWNER) SEE P010-042-SP-001-GE

CONSTRUCTION POWER (OWNER) SEE P010-042-SP-001-GE

082

086

091

165

148

126

122 082

STG ROTOR REMOVAL AREA

178

187

142 140

010183

050

067

052

186

185

184

062

STG ELECTRICAL MODULE

HRSG ELECTRICAL MODULE

170

S. HANNIE

PRELIMINARY

D. SHORT

079

11-11-11A. FAZEL

166

179

FUEL GAS DRAINS TANK

HP STEAM DRAINS TANK

LP STEAM DRAINS TANK

S. HANNIF

PRELIMINARY

D. SHORTA. FAZEL

190

192

190 AUX BOILER DEAERATOR & BFW PUMPS

192 AUX BOILER AMMONIA FLOW CONTROL UNIT

199 ACC DUCT

CHEMICAL LAB

196

12-01-11

300’-0"

PROPERTY BOUNDARY

S. HANNIG

PRELIMINARY

A. FAZEL M. HAWKEN OPEN

136A

177 BULK HYDROGEN STORAGE

199

150’-0"

130

100

STG STEP UP TRANSFORMER

042

091099

177

164

SEENOTEN1

NOTES:

N1. TRUCK DELIVERY/HAUL OFF (FUEL OIL/AMMONIA/ WASTE WATER) TRAFFIC FLOW IS DEPICKED BY ARROWS.

072 BREAKER

149 DISCONNECT SWITCH

149

072

076

097

EMERGENCY DIESEL GENERATOR

189

131

117

PLANT NORTH

TRUE NORTH

5%%

d10’

44"

043

CL BRG #2 CL BRG #2

CL BRG #1CL BRG #1

UP

F

UP

F

UP

F

GASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGAS

CB-C

G 105.0

INV. 101.5

CB-B

G 102.00

INV. 98.75

GASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGASGAS

MH-C

G 105.5

N INV. 98.76

S INV. 98.51

CB-E

G 104.0

N INV. 99.50

S INV. 99.25

MH-F

T 105.5

E INV. 97.16

W INV. 97.06

SE INV. 98.74

MH-D

T 106.4

E INV. 100.15

S INV. 100.05

CB-F

G 104.5

INV. 101.0

CB-G

G 104.5

E INV. 99.85

W INV. 99.60

CB-D

G 104.5

INV. 101.0

MH-H

T 106.0

S INV. 96.29

NW INV. 96.19

MH-E

T 106.0

N INV. 98.60

W INV. 98.50

DRAWING NUMBER

DATEREV

C

I

S

IN

K

881E

4

TIEW

C

I

S

IN

K

881E

4

TIEW

Kiewit Power9401 Renner BoulevardLenexa, Kansas 66219

PROJ MGR

ENG MGR

LEAD ENG

CHECKED BYDRAWN BYDESIGN BY

ENGINEER/DESIGNORIGINATOR

CAITHNESS ENERGY, LLC

CAITHNESS LONG ISLAND ENERGY

CENTER II PROJECT

GE 2x1 7FA.05

3-10

Table 3-1: Combustion Turbine Source Parameters

Operating

Case

Fuel

Ambient

Temperature (F)

Operating

Load (%)

Duct Burner Operation (On/Off)

Modeling Stack Parametersb Evaporative

Cooler Operation (On/Off)

Exhaust Temperature

(K)

Exhaust Velocity (m/s)a

Exhaust Flow

(acfm)

Case1 Gas -10 100 Off Off 367.8 24.0 1,272,233 Case2 Gas -10 100 On Off 356.8 23.5 1,245,833 Case3 Gas -10 54 Off Off 358.2 16.0 847,400 Case4 Gas 0 100 Off Off 367.4 23.9 1,266,267 Case5 Gas 0 100 On Off 357.0 23.5 1,241,867 Case6 Gas 0 75 Off Off 362.9 19.4 1,026,967 Case7 Gas 0 50 Off Off 356.6 15.2 802,183 Case8 Gas 51 100 Off Off 361.4 22.0 1,162,333 Case9 Gas 51 100 On Off 356.3 21.9 1,156,967 Case10 Gas 51 90 On Off 351.7 19.7 1,044,883 Case11 Gas 51 75 Off Off 356.8 17.3 917,000 Case12 Gas 51 46 Off Off 352.7 14.0 738,683 Case13 Gas 100 100 Off Off 370.4 21.2 1,122,133 Case14 Gas 10 100 Off On 371.9 22.2 1,173,650 Case15 Gas 100 100 On Off 369.9 21.4 1,132,567 Case16 Gas 100 100 On On 370.8 22.3 1,181,817 Case17 Gas 100 90 On Off 366.0 19.2 1,014,567 Case18 Gas 100 90 On On 370.5 22.1 1,171,450 Case19 Gas 100 75 Off Off 362.5 16.2 854,817 Case20 Gas 100 50 Off Off 361.1 14.5 766,567

aBased on a stack diameter of 18.5 feet.

3-11

Table 3-1: Combustion Turbine Source Parameters (continued)

Operating

Case

Fuel

Ambient

Temperature (F)

Operating

Load (%)

Duct Burner Operation (On/Off)

Modeling Stack Parametersb Evaporative

Cooler Operation (On/Off)

Exhaust Temperature

(K)

Exhaust Velocity (m/s)a

Exhaust Flow

(acfm)

Case21 Oil -10 100 Off Off 408.6 24.2 1,281,217 Case22 Oil -10 100 On Off 405.8 24.3 1,285,917 Case23 Oil -10 50 Off Off 402.1 15.8 837,083 Case24 Oil 0 100 Off Off 409.8 24.2 1,280,083 Case25 Oil 0 100 On Off 405.7 24.2 1,280,850 Case26 Oil 0 75 Off Off 403.8 19.5 1,034,033 Case27 Oil 0 50 Off Off 402.1 15.7 828,367 Case28 Oil 51 100 Off Off 406.9 24.1 1,276,550 Case29 Oil 51 100 On Off 405.8 24.3 1,286,483 Case30 Oil 51 90 On Off 404.7 22.2 1,172,350 Case31 Oil 51 75 Off Off 403.8 19.1 1,012,400 Case32 Oil 51 50 Off Off 402.1 15.4 813,500 Case33 Oil 100 100 Off Off 416.4 24.6 1,299,233 Case34 Oil 100 100 Off On 418.3 25.6 1,356,217 Case35 Oil 100 100 On Off 406.0 24.2 1,279,617 Case36 Oil 100 100 On On 407.2 25.2 1,332,733 Case37 Oil 100 90 On Off 404.7 21.9 1,157,917 Case38 Oil 100 90 On On 405.1 22.6 1,197,433 Case39 Oil 100 75 Off Off 406.1 18.6 984,917 Case40 Oil 100 50 Off Off 402.2 15.3 808,567

aBased on a stack diameter of 18.5 feet.

3-12

Table 3-2: Combustion Turbine Emission Rates

Operating Case

Modeled Emission Rate (g/s)b NOx CO PM-10/PM-2.5a SO2

Case1 2.09 1.27 1.31/1.49 0.24 Case2 2.61 1.59 2.05/2.28 0.30 Case3 1.40 0.85 1.26/1.38 0.16 Case4 2.08 1.27 1.31/1.49 0.24 Case5 2.58 1.58 2.04/2.26 0.30 Case6 1.68 1.02 1.29/1.43 0.19 Case7 1.32 0.81 1.26/1.37 0.15 Case8 1.94 1.18 1.30/1.47 0.22 Case9 2.43 1.49 2.00/2.21 0.28 Case10 2.29 1.40 2.04/2.24 0.26 Case11 1.55 0.94 1.27/1.41 0.18 Case12 1.19 0.73 1.25/1.36 0.14 Case13 1.78 1.08 1.29/1.44 0.21 Case14 1.88 1.14 1.30/1.46 0.22 Case15 2.29 1.40 2.03/2.23 0.26 Case16 2.37 1.45 2.02/2.22 0.27 Case17 2.15 1.31 2.04/2.23 0.25 Case18 2.34 1.42 2.02/2.22 0.27 Case19 1.42 0.87 1.27/1.40 0.16 Case20 1.17 0.71 1.25/1.35 0.14 Case21 6.64 1.35 3.02/3.56 0.53 Case22 8.22 1.66 3.78/4.44 0.59 Case23 4.16 0.84 2.02/2.35 0.33 Case24 6.64 1.35 3.02/3.56 0.53 Case25 8.22 1.66 3.78/4.44 0.59 Case26 5.33 1.08 2.65/3.08 0.42 Case27 4.16 0.84 2.02/2.35 0.33 Case28 6.64 1.35 3.02/3.56 0.53 Case29 8.22 1.66 3.78/4.44 0.59 Case30 7.67 1.55 3.78/4.39 0.54 Case31 5.30 1.08 2.65/3.08 0.42 Case32 4.10 0.83 2.02/2.35 0.33 Case33 6.33 1.29 3.02/3.54 0.50 Case34 6.60 1.34 3.02/3.56 0.52 Case35 7.85 1.59 3.78/4.41 0.56 Case36 8.03 1.63 3.78/4.42 0.58 Case37 7.35 1.49 3.78/4.37 0.52 Case38 7.57 1.54 3.78/4.38 0.54 Case49 5.01 1.02 2.65/3.05 0.40 Case40 3.86 0.78 2.02/2.33 0.31

aFilterable plus condensable, and applying NESCAUM, 2013 for secondary PM-2.5. bPer combustion turbine.

3-13

Table 3-3: Auxiliary Boiler Exhaust Characteristics and Emissions

Emission Parameter

Pollutant Gas Firing Oil Firing

g/s g/s NOx 0.10 0.87 CO 0.31 0.34

PM-10/PM-2.5a 0.03/0.04 0.13/0.19 SO2 0.006 0.002

Exhaust Parameter Exhaust Height (ft above grade) 170 Exhaust Height (m above grade) 51.82

Exhaust Temperature (deg F) 306

Exhaust Flow (acfm) 21,675

Exhaust Velocity (ft/sec) 65.00

Exhaust Velocity (m/sec) 19.81

Inner Diameter (ft) 2.66

Inner Diameter (m) 0.81

Stack Base Elevation (ft) 107 aFilterable plus condensable, and applying NESCAUM, 2013 for secondary PM-2.5.

3-14

Table 3-4: Emergency Diesel Generator Exhaust Characteristics and Emissions

Emission Parametera Pollutant g/sa

NOx 2.47

CO 1.46

PM-10/PM-2.5b 0.08/0.25 SO2 5.09E-04

Exhaust Parameter Exhaust Height (ft above grade) 15 Exhaust Height (m above grade) 4.57

Exhaust Temperature (deg F) 865

Exhaust Flow (acfm) 37,450

Exhaust Velocity (ft/sec) 447.3

Exhaust Velocity (m/sec) 136.34

Inner Diameter (ft) 1.333

Inner Diameter (m) 0.41

Stack Base Elevation (ft) 107 aPer diesel generator. bFilterable plus condensable, and applying NESCAUM, 2013 for secondary PM-2.5.

3-15

Table 3-5: Emergency Diesel Fire Pump Exhaust Characteristics and Emissions

Emission Parameter Pollutant g/s

NOx 0.31

CO 0.22

PM-10/PM-2.5a 0.017/0.038

SO2 0.0001 Exhaust Parameter

Exhaust Height (ft above grade) 20 Exhaust Height (m above grade) 6.10

Exhaust Temperature (deg F) 1,057 Exhaust Flow (acfm) 1,863

Exhaust Velocity (ft/sec) 363.0 Exhaust Velocity (m/sec) 110.64

Inner Diameter (ft) 0.33

Inner Diameter (m) 0.10

Stack Base Elevation (ft) 107 aFilterable plus condensable, and applying NESCAUM, 2013 for secondary PM-2.5.

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4.0 REGULATORY REQUIREMENTS

Air quality modeling requirements are specified under U.S. EPA and DEC regulatory programs

including PSD and NNSR programs, and the New York Codes, Rules and Regulations (NYCRR)

for preconstruction permits, minor source operating permits, and major source operating

permits. All applicable requirements that include air quality impact assessments are outlined in

this section.

4.1 New Source Review

The NSR program consists of the NNSR and PSD programs. Applicability of these programs to

the proposed facility is determined based upon the attainment status and the potential

emissions of the proposed facility. New York’s NNSR requires the use of lowest achievable

emission rate (LAER) controls and compliance with emission offset requirements should facility

emissions exceed applicable thresholds. PSD requires the application of best available control

technology (BACT).

4.1.1 Attainment Status

The U.S. EPA has established National Ambient Air Quality Standards (NAAQS) for each of the

following criteria air pollutants: PM-10, PM-2.5, sulfur dioxide (SO2), ozone (O3), nitrogen

dioxide (NO2), carbon monoxide (CO), and lead (Pb). Areas in which the NAAQS are being met

are referred to as attainment areas. Areas in which the NAAQS are not being met are referred to

as non-attainment areas. Areas that were formerly non-attainment areas but are now in

attainment and covered by a maintenance plan are referred to as maintenance areas. Areas for

which sufficient data are not available to determine a classification are referred to as

unclassifiable. The federal attainment status designations of areas in New York with respect to

NAAQS are listed at 40 CFR 81.333. The facility is located in Suffolk County in the New Jersey-

New York-Connecticut Air Quality Control Region (AQCR).

The location of the proposed facility is in an area currently designated as attainment for SO2,

NO2, CO, and PM-10. Suffolk County, however, is designated as moderate non-attainment for

the 1997 8-hour ozone standard, marginal non-attainment for the 2008 8-hour ozone standard,

and non-attainment for PM-2.5 (1997 and 2006 standards). Under the marginal non-

attainment designation for 8-hour ozone, modifications at existing major facilities emitting

more than 25 tons per year of NOx and/or VOC are subject to NNSR for these pollutants and

require the application of LAER controls and emission offset requirements. Note that for PM-

2.5, a clean data determination has been issued by U.S. EPA for Suffolk County, indicating that

the County has attained compliance with the PM-2.5 standards. Consequently, New York

4-2

submitted a formal PM-2.5 redesignation request in June 2013 which is currently under review

by U.S. EPA Region II. Caithness anticipates U.S. EPA will redesignate Suffolk County as

attainment for PM-2.5 before the FEIS is issued and well before an air permit is issued and

construction commences. As such, for the purposes of this air quality modeling protocol and for

the preparation of the DEIS, the proposed project’s air quality modeling analyses will assess the

project’s compliance assuming the area that the project is to be located in is designated

attainment for PM-2.5.

4.1.2 Prevention of Significant Deterioration

New York has adopted the PSD program which is administered through the DEC permitting

process under 6 NYCRR Part 231, and applies to a new or modified major facility located in an

attainment area. Any fossil fuel fired steam electric plant with a heat input capacity greater than

250 mmBTU/hr with potential emissions greater than 100 tons per year of any regulated

pollutant criteria pollutant (or 100,000 tons per year of greenhouse gases) is considered a

“major” source and is subject to the PSD regulations. The existing Caithness Long Island Energy

Center is an existing major PSD source. The addition of CLI-II constitutes a major modification

because regulated criteria pollutant increases will exceed the PSD Significant Emission Rates, as

shown in Table 4-1. As such, CLI-II will be subject to PSD review.

Facilities subject to PSD must perform an air quality analysis (which includes atmospheric

dispersion modeling) and a best available control technology (BACT) demonstration for those

pollutants that exceed the pollutant specific Significant Project Thresholds identified in the

regulations. The PSD SERs and NNSR thresholds are provided in Table 4-1. (Note that since

NOx and VOC are precursors to ozone formation, NOx and VOC emissions will be controlled to

the more stringent LAER emission levels if they exceed the NNSR thresholds).

Dispersion modeling for the PSD requirements consists of three analyses: a significance analysis,

a NAAQS/NYAAQS analysis, and a PSD increment analysis. The significance analysis compares

the maximum-modeled ambient concentrations from the proposed facility to the significant

impact levels (SILs) listed in Table 4-2 for each pollutant. If the modeled concentrations for the

proposed facility are less than the SILs, then more detailed NAAQS/NYAAQS and PSD

increment analyses are not required under PSD regulations. However, if the modeled

concentrations are greater than the SILs, then NAAQS/NYAAQS and PSD increment analyses

are required for that pollutant. The NAAQS and PSD increments are listed in Table 4-2 while

the NYAAQS are listed in Table 4-3. For DEIS/FEIS assessment purposes, Caithness will only

compare the air quality concentrations to the NAAQS/NYAAQS which are health-based

standards, while the PSD increments are regulatory-driven thresholds which have no health

impact basis.

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4.1.3 Preconstruction Ambient Air Quality Monitoring Exemption

As discussed previously, PSD regulations require an applicant to perform an air quality analysis

for those criteria pollutants emitted in quantities exceeding the SERs (and for which there are

NAAQS) shown in Table 4-1. This analysis can include the collection of up to one year of

ambient air quality monitoring data. Preliminary facility emissions indicate that air quality

monitoring could be required for some of the pollutants listed in Table 4-1.

Pursuant to the DEC’s PSD regulations (6 NYCRR Section 231-12.4), DEC may exempt a

proposed PSD source, otherwise subject to the one-year pre-construction ambient monitoring

requirement, if existing quality assured ambient air quality data are available from alternate

locations that are representative of, or conservative, as compared to conditions at the proposed

facility location.

Background data for CO and PM-10 was obtained from a monitoring station located in Queens

County, New York (EPA AIRData # 36-081-0124), approximately 75 km west of the proposed

facility. The monitor is located at Queens College (NYSDEC Air Monitoring Building, CUNY

Queens College Campus, 65-30 Kissena Boulevard, Flushing). This monitor is located in one of

the five boroughs of New York City that has a higher population density and higher density of

industrial facilities than the Brookhaven area on Long Island. Further, this monitor is located in

an area with a greater amount of mobile and point sources of air emissions as compared to the

project area. Thus, this monitor would be considered to conservatively represent the ambient air

quality within the project area.

Background data for NO2 was obtained from a monitoring station located in Bronx County, New

York (EPA AIRData # 36-005-0133), approximately 79 km west of the proposed facility. The

monitor is located at the Botanical Gardens (Pfizer Plant Research Lab, 200th Street and

Southern Boulevard). This monitor is also located in one of the five boroughs of New York City

that has a higher population density and higher density of industrial facilities than the

Brookhaven area on Long Island. Further, this monitor is located in an area with a greater

amount of mobile and point sources of air emissions as compared to the project area. Thus, this

monitor would also be considered to conservatively represent the ambient air quality within the

project area.

Background data for SO2 was obtained from a Holtsville monitoring station located in Suffolk

County, New York (EPA AIRData # 36-103-0009), and approximately 10 km west of the

proposed facility. The monitor is located at Sagamore Junior High School (57 Division Street).

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This monitor’s close proximity and upwind to the Project would qualify it to be representative of

the ambient air quality within the project area.

Background data for PM-2.5 was obtained from a Babylon monitoring station located in Suffolk

County, New York (EPA AIRData # 36-103-0002), and approximately 41 km west-southwest of

the proposed facility. The monitor is located at the Farmingdale Water District (72 Gazza

Boulevard). This monitor is located in an area of Long Island that is closer to the five boroughs

of New York City and has a greater amount of mobile and point sources of air emissions as

compared to the project area. Thus, this monitor would be considered to conservatively

represent the ambient air quality within the project area.

To support the Part 231/PSD air permit application anticipated to be filed in 2014, Caithness is

requesting an exemption from the requirement to perform preconstruction ambient air quality

monitoring for CO, NO2, SO2, PM-10, and PM-2.5 on the basis that existing quality assured

ambient air quality data is available from alternate locations that are representative or

conservative, as compared to conditions at the planned facility location (see Section 5.10 and

Table 5-4).

4.2 New York State Requirements

Applicable DEC air regulations are identified below:

Part 200 defines general terms and conditions, requires sources to restrict emissions,

and allows DEC to enforce NSPS, PSD, and NESHAP. Part 200 is a general applicable

requirement; no action is required by the facility.

Part 201 requires existing and new sources to evaluate minor or major source status and

evaluate and certify compliance with all applicable requirements. The proposed facility

will represent a modified major Part 201 source, seeking a construction permit under

Part 201 with this application, and may apply for a Title V operating permit under 201-6

for the new facility at the time of air permit application or within one year of

commencing operation.

Part 202-1 requires a source to conduct emissions testing upon the request of DEC.

Permit conditions covering construction of the proposed facility will likely require stack

testing as a condition of receiving its certificate to operate.

Part 202-2 requires sources to submit annual emission statements for emissions tracking

and fee assessment. Pollutants are required to be reported in an emission statement if

certain annual thresholds are exceeded. Facility emissions will be reported as required.

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Part 211-3 defines general opacity limits for sources of air pollution in New York State.

General applicable requirement facility-wide visible emissions are limited to 20% opacity

(6-minute average) except for one continuous six-minute period per hour of not more

than 57% opacity. Note that the opacity requirements under Part 227-1 (see below) are

more restrictive and supersede the requirements of Part 211-3.

Part 225-1 regulates sulfur content of fossil fuels. The proposed combustion turbines,

auxiliary boiler, and emergency equipment for the CLI-II project will use 0.0015% sulfur

ULSD.

Part 227-1.2 sets a 0.10 lb/mmBtu particulate limit for oil-fired stationary combustion

installations with a maximum heat input capacity exceeding 250 mmBtu/hr. The

combustion turbines and auxiliary boiler at CLI-II will comply with this emission limit

when operating on ULSD.

Visible emissions (opacity) for stationary fuel-burning equipment are regulated under 6

NYCRR Subpart 227-1.3. Facility stationary combustion installations must be operated

so that the following opacity limits are not violated; 227-1.3(a) 20% opacity (six minute

average), except for one six-minute period per hour of not more than 27% opacity.

Part 227-2 sets NOx RACT emission limits for combustion sources. Caithness expects

that the BACT/LAER emissions limits established under Part 231 will be equal to or

lower than the 227-2 RACT limits.

Part 231 requires New Source Review of new major sources and/or major modifications

of existing facilities in both attainment and non-attainment areas in New York State.

Subpart 231-6 applies NNSR requirements to major modifications. Subpart 231-8

applies PSD requirements to major modifications to existing major facilities.

Part 242 establishes the New York State component of the CO2 Budget Trading Program.

Program requirements, including allowance allocations, account reconciliation,

monitoring and reporting and regulatory timelines are addressed in these rules.

Part 243 regulates the Clean Air Interstate Rule (CAIR) NOx ozone trading program.

Program requirements, including allowance allocations, banking, account reconciliation,

NOx monitoring and reporting and regulatory timelines are addressed in Part 243.

Parts 244 and 245 establish the CAIR annual NOx and SO2 Trading Programs, which are

designed to mitigate interstate transport of fine particulates and sulfur dioxide. Program

4-6

requirements, including allowance allocations, banking, account reconciliation,

monitoring and reporting and regulatory timelines are addressed in these rules.

Part 251 establishes carbon dioxide (CO2) emission standards for new major electric

generating facilities (defined as facilities that have a generating capacity of at least 25

megawatts (MW)), and for increases in capacity of at least 25 MW at existing electric

generating facilities.

Under 6 NYCRR 257, New York’s ambient air quality standards, project emissions must

be such as not to exceed state ambient air standards for SO2, PM, CO, photo-chemical

oxidants, NO2, fluorides, beryllium, and hydrogen sulfide.

CLI-II will meet DEC guidelines for ammonia (NH3) slip by controlling the ammonia

injection rate and employing good operating practices.

In addition to the previously discussed emissions and applicability related regulations, the

proposed facility will also be required to incorporate the New York State air quality requirements

where applicable to the air quality assessment. These requirements are specified in:

DAR-1 Guidelines for the Control of Toxic Ambient Air Contaminants; and

DAR-10 NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact

Analysis.

In addition, the DEC published an interim policy, CP-33 / Assessing and Mitigating Impacts of

Fine Particulate Matter Emissions, on December 29, 2003 addressing the requirements for PM-

2.5 air quality modeling. A PM-2.5 air quality modeling analysis for the proposed facility will be

conducted following the procedures outlined in this interim policy guidance document.

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Table 4-1: Comparison of Proposed Project Emissions Increases to PSD Significant Modification Thresholds and Non-attainment NSR Major Modification Thresholds

Pollutant

Proposed Project

Emissions Increases

(tons per year)

PSD Significant

Modification Thresholds

(tons per year)

NNSR Major Modification Thresholds

(tons per year)

Carbon Monoxide 236.5 100 NA

Sulfur Dioxide 20.1 40 40a

Particulate Matter (PM) 144.7 25 NA

Particulate Matter less than 10 microns (PM-10)

144.7 15 NA

Particulate Matter less than 2.5 microns (PM-2.5)

144.7 10 10a

Nitrogen Oxides 197.1 40 25c/40a

Ozone (VOC) 73.9 40 25c

Greenhouse Gases (GHG) 2,683,123 75,000b NA

Lead <0.6 0.6 NA

Fluorides NA 3 NA

Sulfuric Acid Mist 13.7 7 NA

Hydrogen Sulfide NA 10 NA

Total Reduced Sulfur (including H2S)

NA 10 NA

Reduced Sulfur Compounds (including H2S)

NA 10 NA

Note: Pursuant to 40 CFR 52.21 (b) (23) (i). aUnder 6 NYCRR Part 231, new sources with potential emissions greater than or equal to 100 tons per year and modifications to existing major sources with emissions greater than or equal to 40 tons per year of SO2, 40 tons per year of NOx, or 10 tons per year of PM-2.5 are subject to NNSR for PM-2.5. In as much as NYSDEC has demonstrated attainment and has filed a redesignation request, Caithness anticipates Suffolk County to be designated attainment by U.S. EPA Region II before the final air permit is granted. bCO2 NSR threshold for a major modification to an existing major source. cAs precursors to ozone.

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Table 4-2: National Ambient Air Quality Standards, PSD Increments, Significant Monitoring Concentrations, and Significant Impact Levels

Pollutant Averaging

Period NAAQSa (g/m3)

Class II PSD Increment

(g/m3)

Significant Monitoring

Concentrations (g/m3)

Significant Impact Level

(g/m3)

Carbon Monoxide

(CO)

1-Hour 8-Hour

40,000 10,000

-- --

-- 575

2,000 500

Nitrogen Dioxide (NO2)

1-Hour Annual

188 100

-- 25

-- 14

7.5b 1

Ozone (VOC)

8-Hour 150 -- -- --

Coarse Particulate

Matter (PM-10)

24-Hour Annual

150 --

30 17

10 --

5 1

Fine Particulate

Matter (PM-2.5)

24-Hour Annual

35 15

9 4

4 --

1.2 0.3

Sulfur Dioxide (SO2)

1-Hour 24-Hour Annual 3-Hour

196 365 80

1,300

-- 91 20 512

-- 13 -- --

7.8c 5 1

25 Lead (Pb)

3-Month 0.15 -- 0.1 --

Note: (--) indicates there are no standards for this pollutant. aAll short-term (1-hr, 3-hr, 8-hr, and 24-hr) standards except ozone, PM-2.5,PM-10, and 1-hour SO2 and NO2 are not to be exceeded more than once per year. For 8-hr ozone, EPA uses the average of the annual 4th highest 8-hour daily maximum concentrations from each of the last three years of air quality monitoring data to determine a violation of the standard. For 24-hour PM-10, EPA uses the 6th highest 24-hour maximum concentration from the last three years of air quality monitoring data to determine a violation of the standards. For 24-hour PM-2.5, EPA uses the 98th percentile 24-hour maximum concentration from the last three years of air quality monitoring data to determine a violation of the standard. For the 1-hour NO2 NAAQS, compliance would be determined by the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area and for the 1-hour SO2 NAAQS, compliance would be determined with the 3-year average of the 99th percentile of the daily maximum 1-hour average at each monitor within an area. bPer guidance from NYSDEC. cInterim SIL per August 12, 2010 memorandum “Guidance Concerning the Implementation of the 1-hour SO2 NAAQS for the Prevention of Significant Deterioration Program" from Steven Page (Director of U.S. EPA OAQPS).

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Table 4-3: New York Ambient Air Quality Standards

Pollutant Averaging Period

NYAAQS

(ug/m3)

Sulfur Dioxide (SO2)

3-Hour 1,3001

24-Hour 3651

Annual 802

Nitrogen Dioxide (NO2) Annual 1002

Particulate (PM-10) 24-Hour 1503

Fine Particulate (PM-2.5) 24-Hour N/A

Annual N/A

Total Suspended Particulate

(TSP)

24-Hour 2501

Annual 754

Carbon Monoxide (CO) 1-Hour 40,0001

8-Hour 10,0001

Ozone (O3) 1-Hour 2351

8-hour N/A

Lead (Pb) Quarterly N/A

Gaseous Fluorides (as F)5

12-Hour 3.702

24-Hour 2.852

1-Week 1.652

1-Month 0.802

Beryllium 1-Month 0.012

Hydrogen Sulfide5 1-Hour 142

1 Not to be exceeded more than once per year. 2 Not to be exceeded. 3 Fourth highest concentration over a three year period. 4 Geometric mean of the 24-hour average concentrations over 12-month period. 5Pollutant will not be emitted from the proposed facility.

Source: 6 NYCRR 257

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5.0 MODELING METHODOLOGY

Air quality dispersion modeling will be performed consistent with the procedures found in the

following documents: Guideline on Air Quality Models (Revised) (U.S. EPA, 2005), New Source

Review Workshop Manual (U.S. EPA, 1990), Screening Procedures for Estimating the Air

Quality Impact of Stationary Sources (U.S. EPA, 1992), DAR-10: NYSDEC Guidelines on

Dispersion Modeling Procedures for Air Quality Impact Analysis (NYSDEC, 2006), and Draft

Guidance on PM-2.5 Modeling (U.S. EPA, 2013).

5.1 Model Selection

The U.S. EPA has compiled a set of preferred and alternative computer models for the

calculation of pollutant impacts. The selection of a model depends on the characteristics of the

source, as well as the nature of the surrounding study area. Of the four classes of models

available, the Gaussian type model is the most widely used technique for estimating the impacts

of nonreactive pollutants.

The U.S. EPA AERMOD model is proposed to be used. The AERMOD model was designed for

assessing pollutant concentrations from a wide variety of sources (point, area, and volume).

AERMOD is currently recommended for modeling studies in rural or urban areas, flat or

complex terrain, and transport distances less than 50 kilometers, with one hour to annual

averaging times.

AERMOD (version 12345 with PRIME) will be used for the preliminary modeling of the

proposed facility’s potential emissions to determine the maximum ambient air concentrations.

The regulatory default option will be used in the dispersion modeling analysis.

5.2 Surrounding Area and Land Use A land cover classification analysis was performed to determine whether the urban source

modeling option in AERMOD should be used in quantifying ground-level concentrations. The

urban option in AERMOD accounts for the effects of increased surface heating on pollutant

dispersion under stable atmospheric conditions. Essentially, the urban convective boundary

layer forms in the night when stable rural air flows onto a warmer urban surface. The urban

surface is warmer than the rural surface because the urban surface cools at a slower rate than the

rural surface when the sun sets. The methodology utilized to determine whether the facility is

located in an urban or rural area is described below.

The following classifications relate the colors on a United States Geological Survey (USGS)

topographic quadrangle map to the land use type that they represent:

5-2

Blue – water (rural);

Green – wooded areas (rural);

White – parks, unwooded, non-densely packed structures (rural);

Purple – industrial; identified by the large buildings, tanks, sewage disposal or filtration

plants, rail yards, roadways, and, intersections (urban);

Pink – residential or commercial (urban or rural determination based upon aerial

photography); and,

Red – roadways and intersections (urban)

The USGS map covering the area within a 3-kilometer radius of the site was reviewed and

indicated that the majority of the surrounding area is denoted as blue, green, or white, which

represents water, wooded areas, parks, and non-densely packed structures. Additionally, the

“AERMOD Implementation Guide” published on October 19, 2007 cautions users against

applying the Land Use Procedure on a source-by-source basis and instead consider the potential

for urban heat island influences across the full modeling domain. This approach is consistent

with the fact that the urban heat island is not a localized effect, but is more regional in character.

Because the urban heat island is more of a regional effect, the Urban Source option in AERMOD

will not be utilized since the area within 3 kilometers of the proposed site as well as the full

modeling domain (20 kilometers by 20 kilometers) is predominantly rural (as illustrated by

Figure 5-1).

5.3 Meteorological Data

For any Part 231/PSD and/or DEIS air quality modeling analysis conducted using the AERMOD

model, two meteorological datasets are required: 1) hourly surface data and 2) upper air

sounding data. According to the Guideline on Air Quality Models (Revised) (2005), the

meteorological data used in an air quality modeling analysis should be selected based on its

spatial and climatological representativeness of a proposed facility site and its ability to

accurately characterize the transport and dispersion conditions in the area of concern. The

spatial and climatological representativeness of the meteorological data are dependent on four

factors:

1. The proximity of the meteorological monitoring site to the area under consideration; 2. The complexity of the terrain; 3. The exposure of the meteorological monitoring site; and, 4. The period of time during which data were collected.

Meteorological data sets from the Long Island MacArthur Airport, Brookhaven/Shirley Airport,

the National Weather Service Forecast Office in Upton (Brookhaven National Laboratory), and

the Farmingdale Republic Airport were evaluated to determine the availability and data quality

5-3

of meteorological data for air quality modeling purposes. This evaluation determined that the

Brookhaven Calabro Airport in Shirley provides high quality surface data in close proximity to

the project site. This protocol further presents a detailed summary of the one hourly surface

dataset from the Brookhaven Calabro Airport and one twice daily upper air sounding dataset

from Brookhaven National Laboratory in Upton. Each of these meteorological datasets was

reviewed using the U.S. EPA criteria. The primary data set used for this analysis is a recent five

year period (2008 – 2012) of hourly meteorological data collected by the meteorological tower at

the Brookhaven Calabro Airport in Shirley, Suffolk County, New York. Brookhaven Calabro

Airport (also referred to as Brookhaven Airport) is located at 40º 49' 16" North Latitude, 72º 52'

03" West Longitude, NAD83, approximately 6 kilometers east of the facility site at an elevation

of approximately 70 feet above mean sea level.

An Automated Surface Observing System (ASOS) station at the Brookhaven Airport (WBAN

54790) was installed on September 29, 1999 with a height of 33 feet (10 meters). These data

were examined by year for specific “modeling completeness,” which evaluates all of the

coincident meteorological parameters to determine if an individual hour of data is sufficient to

perform a dispersion calculation. Namely, the data recovery rates for wind direction, wind

speed, temperature, ceiling height, and opaque sky cover were determined. The percent

recovery by year for these modeling parameters exceeds the minimum criterion of 90 percent for

all five years, which is the criterion for determining an acceptable modeling completeness.

The Brookhaven Airport meteorological tower location is such that the recorded data are free of

interferences caused by nearby natural or manmade structures and provide an excellent

representation of dispersion characteristics within the local area. A wind rose displaying the

composite wind rose for all five years (2008 – 2012) of wind speed and direction for the

Brookhaven Airport meteorological tower is shown in Figure 5-2. Over the five (5) year period,

predominant winds varied from the south-southwest, west-northwest, and northwest. The

average wind speed over the five years is 3.60 meters per second. Calm winds during the five

years had an average frequency of 3.52 percent. Additionally, the wind data recorded at the

Brookhaven Airport meteorological tower is consistent from year to year indicating a stable

climatic regime with few extreme conditions.

Concurrent upper air sounding data from Brookhaven National Labs (WBAN 94703) at Upton,

New York was used with the hourly surface dataset to create the meteorological dataset required

for the modeling analysis. Brookhaven National Labs is approximately 8 kilometers to the

northeast of the facility site. Based on an examination of the spatial distribution of seasonal and

annual mixing heights using Holzworth’s Mixing Heights, Wind Speeds, and Potential for Urban

Air Pollution Throughout the Contiguous United States (U.S. EPA, 1972), upper air

meteorological conditions in the Upton area are considered representative of the air regime at

the facility site.

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Both the surface and upper air sounding data will be processed using AERMOD’s meteorological

processor, AERMET (version 12345). The output from AERMET will be used as the

meteorological database for the modeling analysis and will consist of a surface data file and a

vertical profile data file. Figure 5-3 shows the location of the Brookhaven Airport meteorological

tower in relation to the facility site.

TRC also evaluated the data sets from the Long Island MacArthur Airport in Islip and the

Republic Airport in Farmingdale. TRC concluded that the meteorological data recorded at the

Brookhaven Calabro Airport meteorological tower and upper air data recorded from Brookhaven

National Laboratory in Upton, are most representative of the air regime at the facility site and

are suitable to be used in an atmospheric dispersion modeling study because:

Due to the proximity of the Brookhaven Airport meteorological tower to the facility site

and the lack of significant intervening terrain features, overall climatological conditions

would be expected to be quite similar;

The meteorological tower is well sited and in an area free of obstructions to wind flow;

and,

The quality of the available data is good, exceeding U.S. EPA data recovery guidelines

and displaying consistency from year to year of the available data record.

5.4 Land Cover Analyses

5.4.1.1 Methodology As noted above, the AERMOD modeling system uses AERMET to process meteorological data.

Values of three surface characteristics (surface roughness length, Bowen ratio, and albedo) are

required inputs for AERMET. Albedo is a measure of the reflectivity of the surface; Bowen ratio

is a measure of the heat and moisture fluxes (i.e., flows) from the surface; roughness length is a

measure of terrain roughness (obstacles to wind flow) as “seen by” surface wind.

The U.S. EPA’s AERSURFACE tool (most recent version dated 13016) was used to determine the

needed surface characteristic values. AERSURFACE was developed by the U.S. EPA to provide

realistic and objectively determined surface characteristic values for use in the AERMET

meteorological preprocessor. Although the use of AERSURFACE is not required for regulatory

applications involving AERMOD, the U.S. EPA states that the calculation methods

recommended in the AERSURFACE User’s Guide (U.S. EPA, 2008) and implemented in

AERSURFACE should be followed unless a case-specific justification is provided for an

alternative method.

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The AERSURFACE User’s Guide (U.S. EPA, 2008) was followed in order to obtain realistic and

reproducible surface characteristic values for input to AERMET. Land cover data from the

United States Geological Survey (USGS) National Land Cover Dataset 1992 (NLCD92) archives

was used as the input to AERSURFACE. This dataset provides land cover data at a spatial

resolution of 30 meters and based on a 21-category classification scheme.

The recommended default value of one (1) kilometer was used to define the radius of the study

area used for surface roughness. Additionally, surface roughness lengths were determined for

four (4) sectors. These sectors were based upon the following:

Sector 1: 30 to 137 degrees

Sector 2: 137 to 285 degrees

Sector 3: 285 to 355 degrees

Sector 4: 355 to 30 degrees

These sectors were partitioned in this manner in order to develop land cover areas with

consistent land use classifications (i.e., mostly water, mostly commercial, mostly residential,

etc.). The temporal resolution of surface characteristic outputs was set to monthly. After

reviewing snow cover data collected at the Long Island MacArthur Airport station

(approximately 14 kilometers west-southwest of the facility site, and the station nearest to the

site for which snow cover data was recorded), it was determined that the site had experienced

continuous snow cover for more than half the days in a given month four (4) times during the

2008 – 2012 period. These months were January 2009, February 2010, January 2011, and

February 2011. These four (4) months were categorized as “winter with snow”. All other winter

months (i.e., December, January, and February) were categorized as “winter without snow”.

Additionally, for all other months, the default month-to-season associations in AERSURFACE

were followed.

Finally, the surface moisture conditions at the site relative to climatic normals were

characterized as either average, wet, or dry. The 29-year climatic normal precipitation (1984 –

2012), as recorded at Long Island MacArthur Airport, Islip, New York is 46.11 inches per year,

which is the nearest station that has a climatic record of precipitation. As defined in the

AERSURFACE User’s Guide, average conditions are defined as the middle 40th percentile, or at

Long Island MacArthur Airport, a range from 41.70 to 50.52 inches per year. Correspondingly,

wet conditions are defined as the upper 30th percentile and dry conditions are defined as the

lower 30th percentile. The surface moisture conditions, as determined by evaluating

precipitation data collected at Long Island MacArthur Airport during the five years (2008 –

2012), are as follows:

5-6

2008: Wet (52.17 inches)

2009: Wet (52.70 inches)

2010: Average (43.07 inches)

2011: Wet (52.34 inches)

2012: Average (44.73 inches)

AERSURFACE will be run five times to account for the moisture variability across the five (5)

year period.

Current U.S. EPA guidance calls for the use of surface parameters based on the area surrounding

the meteorological measurement site. Section 5.3 previously discussed and justified the

selection of surface level meteorological data from the Brookhaven Airport meteorological tower

as representative of the facility site. Figure 5-4 is provided to show the land uses surrounding

the Brookhaven Airport meteorological tower site.

In order to compare the land use surrounding the IPEC meteorological tower and the facility site

and the associated surface parameters, AERSURFACE was run for each site. A single 360 degree

wide sector was used in each case for the purpose of obtaining average values of surface

roughness length for the area surrounding each site. Figures 5-5 and 5-6 present the surface

parameters within 1-kilometer of the Brookhaven Airport meteorological tower and the facility

site, respectively. Refer to Figures 5-7 and 5-8 for graphics presenting the surface parameters

within a 10 km x 10 km square centered on the Brookhaven Airport meteorological tower and

the facility site, respectively. Table 5-1 provides the resulting monthly values for each of the

surface parameters, the ratio of the monthly values at each site, and annual averages of the

surface parameter values and ratios.

Review of the values in Table 5-1 show that: (1) the monthly albedo values are identical at each

site; (2) the Bowen ratio is slightly higher at the project site but always within 7 percent of the

value at the Brookhaven Airport; and (3) surface roughness lengths are more variable, as would

be expected, since surface roughness is determined based on a more limited area. Natural

logarithms were used to compare the respective surface roughness lengths at the two sites

consistent with the manner in which this parameter is used by AERMOD.

Since the NLCD92 data is over 20 years old, TRC also examined the surface land use within 1-

kilometer of the Brookhaven Airport meteorological tower and the facility site based on

NLCD2006 data (see Figures 5-9 and 5-10, respectively. It’s worth noting that Figure 5-10 (the

facility site using 2006 data) shows much more “developed” land use within 1-kilometer than

can be seen in Figure 5-5 (the facility site using 1992 data). Further, Figure 5-10 (the facility site

using 2006 data) also shows more land use similarity with Figure 5-9 (the Brookhaven Airport

5-7

using 2006 data) since the area around the facility site has become more “developed” over the

past 20 years and will continue that trend with the addition of the proposed facility.

Based on these comparisons, it is concluded that differences in land cover surrounding the

Brookhaven Airport meteorological tower and facility site will not have any significant effect on

the associated surface parameters used in AERMOD and that the land cover surrounding the

Brookhaven Airport meteorological tower is suitably representative of land cover at the facility

site.

5.5 Sources

The proposed facility will consist of various types of emission sources. The AERMOD technical

manual will be used to set up the various sources to develop a logical and comprehensive

modeling assessment. The following identifies the types of sources and how they will be

assessed.

Combustion Turbine Exhaust Stacks – Single point sources Ancillary Equipment Exhaust Stacks – Single point sources

5.6 Load Analysis The proposed facility’s combustion turbines will be operated over a range of loads. The DEIS

and air permit application will provide a detailed discussion of all the sources at the proposed

facility and how they are assessed in the air quality analyses. The combustion turbine operating

cases will be modeled to determine which case is the “worst-case” operating scenario for each

pollutant and averaging period. These “worst-case” loads will then be used for any subsequent

NAAQS or PSD increment modeling, including additional facility sources and potentially offsite

sources.

5.7 Startups/Shutdowns Startup is a short-term, transitional mode of operation for the combined cycle unit. In combined

cycle operation, where the exhaust gases are directed through a HRSG to produce steam for a steam

turbine generator, additional startup time is necessary in order to reduce thermal shock and

excessive wear in both the HRSG and the steam turbine. Emission rates of some pollutants may be

higher during startup operations because emissions controls may not become fully effective until a

minimum threshold operating load and or control device temperature is attained. The need for

additional modeling to account for predicted short-term facility impacts during startup of the

combined cycle unit will be assessed for those criteria pollutants whose short-term emission rates

during startup may exceed those during normal operation and for which a short-term NAAQS or

PSD increment has been defined (i.e., for CO and NO2). Furthermore, in order to facilitate startup

5-8

of the CTGs and steam turbine generator, as well as for maintenance purposes, the auxiliary boiler

may operate simultaneously with the combustion turbines for up to two hours.

The facility will require “cold starts,” which are typically based on one startup after 72 hours or more

of shutdown, warm starts (based on 24 hours to 72 hours of shutdown), and hot starts (based on 4

hours to 24 hours of shutdown). In combined cycle operation, where the exhaust gases are directed

through a HRSG to provide steam to a steam turbine, additional startup time is necessary in order to

reduce thermal shock and excessive wear in both the HRSG and the steam turbine. It should be

noted that the different types of startup modes result in different time periods of turbine shutdowns.

A cold gas-fired rapid start requires approximately 1 hour, a warm gas-fired rapid start requires

approximately 0.8 hours, and a hot gas-fired rapid start requires approximately 0.5 hours. The

combustion turbines also require a 0.5 hour shutdown period.

A cold gas-fired conventional start requires approximately 4.6 hours, a warm gas-fired conventional

start requires approximately 2.5 hours, and a hot gas-fired conventional start requires

approximately 1.3 hours. The combustion turbines also require a 0.3 hour shutdown period.

A cold oil-fired conventional start requires approximately 4.6 hours, a warm oil-fired conventional

start requires approximately 2.8 hours, and a hot oil-fired conventional start requires approximately

0.8 hours. The combustion turbines also require a 0.3 hour shutdown period.

The worst-case startup/shutdown emissions for CO and NOx will be modeled if the pollutant(s) has

higher emissions during startup and shutdown conditions when compared to normal operation.

Startup emissions and associated stack parameters have been estimated based on vendor data and

are shown in Table 5-2.

During the operational year, Caithness is proposing 10 cold gas-fired rapid starts, 52 warm gas-fired

rapid starts, and 260 hot gas-fired rapid starts. Further, Caithness is also proposing 2 cold gas-fired

conventional starts, 5 warm gas-fired conventional starts, and 3 hot gas-fired conventional starts.

Finally, Caithness is proposing 2 cold oil-fired conventional starts, 5 warm oil-fired conventional

starts, and 3 hot oil-fired conventional starts.

After discussions with the Department, only warm and hot gas-fired rapid starts are proposed to be

evaluated (for 1-hour NO2, 1-hour CO, and 8-hour CO) since the number of cold gas-fired rapid starts

(10) can be deemed to occur infrequently (i.e., transient events). Further, it should also be noted

that Caithness is only proposing 10 conventional starts on ULSD and 10 conventional starts on

natural gas. These conventional starts are proposed not to be evaluated since they can also be

deemed to occur infrequently (i.e., transient events).

5-9

Because the startup/shutdown durations from some types will be shorter than some of the averaging

periods modeled, the modeled concentrations for these averaging periods that extend beyond the

start-up duration will be determined based on the combination of the startup conditions for the

appropriate amount of time and the worst-case full-load pollutant- and averaging period-specific

operating scenario determined in the combustion turbine load analysis.

In summary, the worst-case startup/shutdown emissions for CO and NOx will be modeled if the

pollutant(s) have higher emissions during startup and shutdown conditions when compared to

normal operation for short-term averaging periods. For annual averaging periods, start-ups will

only be included in the modeling analysis if the potential to emit for the facility increases due to

the inclusion of start-ups into the annual potential to emit calculation.

5.8 1-Hour NO2 Modeling

The air quality modeling analysis for the 1-hour NO2 NAAQS will be performed consistent with

the guidance and procedures established in the March 1, 2011 guidance memorandum from

Tyler Fox (EPA OAQPS) titled “Additional Clarification Regarding Application of Appendix W

Modeling Guidance for the 1-Hour NO2 NAAQS” (Memorandum). Based upon the discussion in

the memorandum regarding the treatment of intermittent sources it is proposed that only

equipment or operating scenarios that “are continuous or frequent enough to contribute

significantly to the annual distribution of daily maximum 1-hour concentrations” will be

included in the 1-hour NO2 modeling analysis.

This methodology, per the examples provided in the Memorandum, would exempt any facility

equipment or operating scenarios from 1-hour NO2 compliance modeling that does not operate

on a normal daily or routine schedule. For example, potential emergency equipment is not

expected to be tested more than once per week for more than 1-hour and thus, would not be

expected to contribute significantly to the annual distribution of maximum 1-hour

concentrations. For these reasons, and consistent with the Memorandum, it is proposed that the

1-hour NO2 modeling will not include the emergency diesel generators and emergency diesel

firepump.

Startup and shutdown conditions that are expected to contribute to the annual distribution of

daily maximum concentrations due to their frequency on a yearly basis will be included in the air

quality modeling analysis for the 1-hour NO2 standard.

Additional refinements of the 1-hour NO2 modeling will include the incorporation of seasonal

hour-of-day NO2 background concentrations and the use of an ambient NO2 equilibrium ratio

and PVMRM. PVMRM options are proposed to conservatively assume an in-stack NO2/NOx

ratio of 0.5 and an ambient NO2 ratio of 0.9. If additional analysis is required, Caithness will

5-10

consult with NYSDEC/U.S. EPA to define alternative appropriate in-stack and ambient NO2

ratios consistent with U.S. EPA guidance.

Three (3) years (2010 – 2012) of hourly NO2 data was obtained from a monitoring station

located in Bronx County, New York (EPA AIRData # 36-005-0133), and approximately 79 km

west of the proposed facility. The monitor is located at the Botanical Gardens (Pfizer Plant

Research Lab, 200th Street and Southern Boulevard). Missing hourly Botanical Gardens data

was filled with the maximum value on either side of the missing hour(s). Ninety-six (96)

seasonal hour-of-day NO2 background concentrations were calculated for use in PVMRM.

Five (5) years (2008 – 2012) of hourly ozone data (for use with PVMRM) was obtained from the

Holtsville monitoring station located in Suffolk County, New York (EPA AIRData # 36-103-

0009), approximately 10 km west of the proposed facility. The monitor is located at Sagamore

Junior High School (57 Division Street). Missing hourly Holtsville data from was either filled

with data from the upwind Babylon monitoring station located in Suffolk County, New York

(EPA AIRData # 36-103-0002), approximately 41 km west-southwest of the proposed facility,

linearly extrapolated, or filled with data from the upwind Queens College monitoring station

located in Queens County, New York (EPA AIRData # 36-081-0124), approximately 75 km west

of the proposed facility.

5.9 Receptor Grid

5.9.1 Basic Grid

The AERMOD model requires receptor data consisting of location coordinates and ground-level

elevations. The receptor generating program, AERMAP (Version 11103), will be used to develop a

complete receptor grid to a distance of 10 kilometers from the proposed facility. AERMAP uses

digital elevation model (DEM) or the National Elevation Dataset (NED) data obtained from the

USGS. The preferred elevation dataset based on NED data will be used in AERMAP to process the

receptor grid. This is currently the preferred data to be used with AERMAP as indicated in the U.S.

EPA AERMOD Implementation Guide (U.S. EPA, 2009). AERMAP will be run to determine the

representative elevation for each receptor using 1/3 arc second NED files that will be obtained for an

area covering at least 10 kilometers in all directions from the Facility. The NED data will be

obtained through the USGS Seamless Data Server (http://seamless.usgs.gov/index.php).

The following rectangular (i.e. Cartesian) receptors will be used to assess the air quality impact of

the proposed facility:

Consistent with DAR-10 guidance, fine grid receptors (70 meter spacing) for a 20 km (east-

west) x 20 km (north-south) grid centered on the proposed facility site.

5-11

Receptors will be placed along the facility fence line or property boundary every 25 meters. Grid

receptors within the fenced plant property will be excluded from the grid as public access will be

precluded in this area.

5.10 Background Ambient Air Quality

Based on review of the locations of DEC ambient air quality monitoring sites, the closest DEC

monitoring sites will be used to represent the current background air quality in the site area, if

necessary. Background data for CO and PM-10 was obtained from a monitoring station located

in Queens County, New York (EPA AIRData # 36-081-0124), approximately 75 km west of the

proposed facility. The monitor is located at Queens College (NYSDEC Air Monitoring Building,

CUNY Queens College Campus, 65-30 Kissena Boulevard, Flushing). Background data for NO2

was obtained from a monitoring station located in Bronx County, New York (EPA AIRData # 36-

005-0133), approximately 79 km west of the proposed facility. The monitor is located at the

Botanical Gardens (Pfizer Plant Research Lab, 200th Street and Southern Boulevard).

Background data for SO2 was obtained from a Holtsville monitoring station located in Suffolk

County, New York (EPA AIRData # 36-103-0009), approximately 10 km west of the proposed

facility. The monitor is located at Sagamore Junior High School (57 Division Street).

Background data for PM-2.5 was obtained from a Babylon monitoring station located in Suffolk

County, New York (EPA AIRData # 36-103-0002), approximately 41 km west-southwest of the

proposed facility. The monitor is located at the Farmingdale Water District (72 Gazza

Boulevard).

The monitoring data for the most recent three years (2010 – 2012) are presented and compared

to the NAAQS in Table 5-3. The maximum measured concentrations for each of these pollutants

during the last three years are all below applicable standards and are proposed to be used in a

NAAQS analysis should one be required.

5.11 NAAQS/NYAAQS Analysis

Per 6 NYCRR Subpart 231-6.6, the net impact of the emissions of a contaminant subject to non-

attainment new source review cannot exceed the established significant impact level. However,

should modeled concentrations be greater than the SILs for one or more pollutants subject to

PSD review, NAAQS/NYAAQS analyses for those pollutants will be performed. The first step of

conducting the NAAQS/NYAAQS analysis will be to determine the pollutant specific area(s) of

impact of the proposed facility. The area of impact corresponds to the distance at which the

model calculated pollutant concentrations fall below the SILs. The second step is obtaining off-

site major source inventories within the area of impact plus a distance to be determined based

upon discussions with DEC. Discussions with DEC will be centered on the development of an

5-12

off-site source inventory and the procedures recommended for preparing a multiple source

inventory. These off-site major sources would be included in the NAAQS/NYAAQS modeling

analysis along with all sources at the proposed facility. The resultant concentrations will then be

added to the representative background concentration for comparison to the NAAQS/NYAAQS.

If the modeled concentration plus the background concentration is less than the

NAAQS/NYAAQS, the proposed facility is considered acceptable relative to the

NAAQS/NYAAQS. Caithness will demonstrate that its modeled impact plus representative

background concentrations will be in compliance with the NAAQS/NYAAQS presented in Table

4-2 and 4-3, respectively.

5.12 PSD Increment Analysis

Should modeled concentrations be greater than the SILs, the source must also demonstrate

compliance with the PSD increments established for SO2, NO2, and PM-10/PM-2.5. The

proposed facility is located in a PSD Class II area. Caithness will demonstrate that its modeled

impact will be in compliance with the Class II PSD increments presented in Table 4-2.

5.13 Additional Impact Analyses

In addition to assessing impacts on the NAAQS and PSD increments, facilities subject to PSD

review must assess the potential impact for the area as a result of growth, and the potential

impacts to soils, vegetation, and visibility in the area surrounding the proposed facility.

5.13.1 Assessment of Impacts Due to Growth The proposed facility will be reviewed to assess the potential for affecting local and regional

industrial, commercial, and residential growth. Factors that will be examined include the effects

the transient working force will have during construction. If an increase in the permanent

working force is required, the effects on the local growth will also be examined. Other effects to

growth that will be examined include the air quality constraints the emissions from the proposed

facility will have on precluding new growth, and the potential for drawing new industrial growth

due to the electricity generated.

5.13.2 Assessment of Impacts on Soils and Vegetation

Pursuant to PSD regulations, an assessment of the potential impacts of the proposed facility on

soils and vegetation will be prepared. The methodology outlined in A Screening Procedure for

the Impacts of Air Pollution Sources on Plants, Soils, and Animals, EPA 450/2-81-078 will be

used. This assessment will compare the maximum-modeled facility impacts plus background to

pollutant-specific concentration levels. These pollutant-specific concentration levels are

minimum pollutant concentration levels at which damage to the natural vegetation and

5-13

predominant crops could occur. Therefore, if the maximum-modeled concentrations are less

than the pollutant-specific concentration levels, then no damage to vegetation will be

anticipated. The specific impact criteria levels to be used for the comparison will be identified for

predominant soil and vegetation types based upon a review of the current literature.

5.13.3 Impact on Visibility

An assessment of the proposed facility’s potential impact on visibility within the surrounding

area will be performed using the U.S. EPA VISCREEN model (version 13190).

5.13.4 Impacts on Class I Areas

There are two (2) Class I areas within 300 km of the proposed facility: the Brigantine Wilderness

area located in the Edwin B. Forsythe National Wildlife Refuge in New Jersey, approximately

182 kilometers southwest of the proposed facility and the Lye Brook Wilderness area in

Vermont, approximately 248 kilometers north of the proposed facility. The Federal Land

Manager (FLM) for each of these Class I areas has be notified by letter and requested to

determine if assessments of impacts in the Class I areas will be required. Copies of both the

letter and the FLM’s response will be included in the agency correspondence appendices of the

DEIS and PSD permit application.

5.14 Modeling Submittal

The permit application for the proposed facility will include a section detailing the modeling

methodology and results from the modeling analysis. All final stack parameters and emission

rates will be presented in the DEIS and technical support document to the Part 231/PSD permit

application. All modeling input and output files used in the analysis will be submitted in

electronic format (DVD-ROM) to the reviewing agencies.

Table 5-1: Comparison of Surface Parameters for theBrookhaven Airport Meteorological Tower and the Project Site

Albedo(ra)

Bowen Ratio(Boa)

Surface Roughness Length(zoa)

Albedo(rs)

Bowen Ratio(Bos)

Surface Roughness Length(zos)

Albedo(rs/ra)

Bowen Ratio

(Bos/Boa)

Surface Roughness Length

(ln zos/ln zoa)1 0.16 0.88 0.176 0.16 0.92 0.761 1.00 1.05 0.162 0.16 0.88 0.176 0.16 0.92 0.761 1.00 1.05 0.163 0.15 0.69 0.212 0.15 0.74 0.924 1.00 1.07 0.054 0.15 0.69 0.212 0.15 0.74 0.924 1.00 1.07 0.055 0.15 0.69 0.212 0.15 0.74 0.924 1.00 1.07 0.056 0.15 0.50 0.219 0.15 0.53 1.065 1.00 1.06 ‐0.047 0.15 0.50 0.219 0.15 0.53 1.065 1.00 1.06 ‐0.048 0.15 0.50 0.219 0.15 0.53 1.065 1.00 1.06 ‐0.049 0.15 0.88 0.215 0.15 0.92 1.059 1.00 1.05 ‐0.0410 0.15 0.88 0.215 0.15 0.92 1.059 1.00 1.05 ‐0.0411 0.15 0.88 0.215 0.15 0.92 1.059 1.00 1.05 ‐0.0412 0.16 0.88 0.176 0.16 0.92 0.761 1.00 1.05 0.16

Ann. Avg. 0.1525 0.74 0.206 0.1525 0.78 0.952 1.00 1.06 0.03

Month

Brookhaven Airport Met Tower CLI‐II Ratio of Surface Parameters

5-15

Table 5-2: Combustion Turbine Modeled Emission Rates and Exhaust Parameters During Rapid Startup on Natural Gas

Event Elapsed

Time (min)

Stack NOx (lb/event)

Stack NOx (lb/hr)

Stack CO (lb/event)

Stack CO (lb/hr)

Stack Exhaust Velocity

(m/s)

Stack Exhaust

Temperature (Degrees F)

Cold Startup 60 118.0 118.0 331.0 331.0 14.4 170

Warm Startup 45 78.0 78.0 181.0 181.0 14.4 170

Hot Startup 30 48.0 48.0 172.0 172.0 14.4 170

Shutdown 29 11.0 11.0 157.0 157.0 14.4 170

Type of Startup or Shutdown Event

Cold Warm Hot Startup Shutdown

Startup Startup

Duration of Turbine at 0% load prior to Start-up (hours) 72 24 4 --

Maximum Duration of Start-up or Shut-down Event (hours) 1.0 0.8 0.5 0.5

Maximum Number per Year 10 52 260 322

Note: Due to the infrequency of cold startups, modeling of these transient events for 1-hour NO2, 1-hour CO, and 8-hour CO is not proposed.

5-16

Table 5-3: Maximum Measured Ambient Air Quality Concentrations

Pollutant Averaging

Period

Maximum Ambient Concentrations (g/m3) NAAQS

(g/m3) 2010 2011 2012

SO2

1-Houra 3-Hour

24-Hour Annual

45.1 43.5 28.8 10.3

55.8 55.8 26.2 5.8

35.4 24.6 13.4 2.7

196 1,300 365 80

NO2 1-Hourb Annual

131.6 37.8

114.1 39.2

111.3 35.0

188 100

CO 1-Hour 8-Hour

3,910 1,955

2,185 1,610

1,955 1,265

40,000 10,000

PM-10 24-Hour 50 40 32 150

PM-2.5c 24-Hour Annual

26.1 8.5

21.7 8.8

18.7 8.0

35 15

a1-hour 3-year average 99th percentile value for SO2 is 45.3 ug/m3. b1-hour 3-year average 98th percentile value for NO2 is 118.4 ug/m3. c24-hour 3-year average 98th percentile value for PM-2.5 is 23 ug/m3; Annual 3-year average value for PM-2.5 is 8.4 ug/m3. High second-high short term (1-, 3-, 8-, and 24-hour) and maximum annual average concentrations presented for all pollutants other than PM-2.5 and 1-hour SO2 and NO2. Bold values represent the proposed background values for use in any necessary NAAQS/NYAAQS analyses. Monitored background concentrations obtained from the DEC website.

20-km x 20-km Domain

3-Kilometer Radius

664000

664000

665000

665000

666000

666000

667000

667000

668000

668000

669000

669000

670000

670000

671000

671000

672000

672000

673000

673000

674000

674000

675000

675000

676000

676000

677000

677000

678000

678000

679000

679000

680000

680000

681000

681000

682000

682000

683000

683000

45

110

00

45

110

00

45

12

00

0

45

12

00

0

45

13

00

0

45

13

00

0

45

14

00

0

45

14

00

0

45

15

00

0

45

15

00

0

45

16

00

0

45

16

00

0

45

17

00

0

45

17

00

0

45

18

00

0

45

18

00

0

45

19

00

0

45

19

00

0

45

20

00

0

45

20

00

0

45

21

00

0

45

21

00

0

45

22

00

0

45

22

00

0

45

23

00

0

45

23

00

0

45

24

00

0

45

24

00

0

45

25

00

0

45

25

00

0

45

26

00

0

45

26

00

0

45

27

00

0

45

27

00

0

45

28

00

0

45

28

00

0

45

29

00

0

45

29

00

0

45

30

00

0

45

30

00

0

45

31

00

0

45

31

00

0

Source: Long Island East and Long Island West30- x 60-Minute USGS Topographic Quadrangles

0 1,000 2,000Meters $

FULL MODELING DOMAIN ANDTHREE-KILOMETER RADIUS

AROUND THE CLI-II PROJECT SITE CAITHNESS LONG ISLAND

ENERGY CENTER II TOWN OF BROOKHAVEN, NEW YORK

FIGURE 5-1

Project Site

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-1_CLIEC_II_Topo_2013-08-14.mxdOCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Caithness Long Island II, LLC Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County, New York

Figure 5-2: Wind Rose for Brookhaven Calabro Airport Meteorological Tower (2008 – 2012)

Source: WRPLOT – Lakes Environmental

Figure 5-3 Location of Caithness Long Island Energy Center II and the Brookhaven Calabro Airport

Sector 1: 30° to 137°

Sector 2: 137° to 285°

Sector 3: 285° to 355°

Sector 4: 355° to 30°

Source: USGS NationalLand Cover Dataset, 1992

0 100 200 300 400 500Meters $

LAND USE WITHIN 1-KM (4 SECTORS)OF BROOKHAVEN AIRPORT

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-4

Brookhaven Airport Meteorological Tower

Land Use, 1992Open Water

Low Intensity Residential

High Intensity Residential

Commercial/Industrial/Transportation

Quarries/Strip Mines/Gravel Pits

Deciduous Forest

Evergreen Forest

Mixed Forest

Pasture/Hay

Row Crops

Urban/Recreational Grasses

Woody Wetlands

Emergent Herbaceous Wetlands

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-4_BrkhvnAirport_LU1992_2013-08-14.mxdOCTOBER 2013OCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Source: USGS NationalLand Cover Dataset, 1992

0 100 200 300 400 500Meters $

LAND USE WITHIN 1-KM OFBROOKHAVEN AIRPORT

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-5

Brookhaven Airport Meteorological Tower

One-kilometer Radius

Land Use, 1992Open Water

Low Intensity Residential

High Intensity Residential

Commercial/Industrial/Transportation

Quarries/Strip Mines/Gravel Pits

Deciduous Forest

Evergreen Forest

Mixed Forest

Pasture/Hay

Row Crops

Urban/Recreational Grasses

Woody Wetlands

Emergent Herbaceous Wetlands

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-5_BrkhvnAirport_LU1992_2013-08-14.mxdOCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Source: USGS NationalLand Cover Dataset, 1992

0 100 200 300 400 500Meters $

LAND USE WITHIN 1-KM OFCLI-II PROJECT SITE

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-6

Project Site

One-kilometer Radius

Land Use, 1992Open Water

Low Intensity Residential

High Intensity Residential

Commercial/Industrial/Transportation

Quarries/Strip Mines/Gravel Pits

Deciduous Forest

Evergreen Forest

Mixed Forest

Pasture/Hay

Row Crops

Urban/Recreational Grasses

Woody Wetlands

Emergent Herbaceous Wetlands

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-6_CLIEC_II_LU1992_2013-08-14.mxdOCTOBER 2013OCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Source: USGS NationalLand Cover Dataset, 1992

0 1,000 2,000Meters $

LAND USE WITHIN FIVE KILOMETERS OFTHE BROOKHAVEN AIRPORTMETEOROLOGICAL TOWER

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-7

Brookhaven Airport Meteorological Tower

10 km x 10 km Region

Land Use, 1992Open Water

Low Intensity Residential

High Intensity Residential

Commercial/Industrial/Transportation

Quarries/Strip Mines/Gravel Pits

Deciduous Forest

Evergreen Forest

Mixed Forest

Pasture/Hay

Row Crops

Urban/Recreational Grasses

Woody Wetlands

Emergent Herbaceous Wetlands

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-7_BrkhvnAirport_LU1992_2013-08-14.mxdOCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Source: USGS NationalLand Cover Dataset, 1992

0 1,000 2,000Meters $

LAND USE WITHIN FIVE KILOMETERS OFTHE CLI-II PROJECT SITE

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-8

Project Site

10 km x 10 km Region

Land Use, 1992Open Water

Low Intensity Residential

High Intensity Residential

Commercial/Industrial/Transportation

Quarries/Strip Mines/Gravel Pits

Deciduous Forest

Evergreen Forest

Mixed Forest

Pasture/Hay

Row Crops

Urban/Recreational Grasses

Woody Wetlands

Emergent Herbaceous Wetlands

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-8_CLIEC_II_LU1992_2013-08-14.mxdOCTOBER 2013OCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Source: USGS NationalLand Cover Dataset, 2006

0 100 200 300 400 500Meters $

LAND USE WITHIN 1-KM OFBROOKHAVEN AIRPORT

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-9

Brookhaven Airport Meteorological Tower

One-kilometer Radius

Land Use, 2006Developed, Open Space

Developed, Low Intensity

Developed, Medium Intensity

Developed High Intensity

Barren Land (Rock/Sand/Clay)

Deciduous Forest

Evergreen Forest

Mixed Forest

Grassland/Herbaceous

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-9_BrkhvnAirport_LU2006_2013-08-14.mxdOCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

Source: USGS NationalLand Cover Dataset, 2006

0 100 200 300 400 500Meters $

LAND USE WITHIN 1-KM OFCLI-II PROJECT SITE

CAITHNESS LONG ISLANDENERGY CENTER II

TOWN OF BROOKHAVEN, NEW YORKFIGURE 5-10

Project Site

One-kilometer Radius

Land Use, 2006Developed, Open Space

Developed, Low Intensity

Developed, Medium Intensity

Developed High Intensity

Barren Land (Rock/Sand/Clay)

Deciduous Forest

Evergreen Forest

Mixed Forest

Shrub/Scrub

Grassland/Herbaceous

Cultivated Crops

R:\Projects\GIS_2013\206458_CLIEC_II\mxd\Air\Fig5-10_CLIEC_II_LU2006_2013-08-14.mxdOCTOBER 2013

1200 Wall Street West, 5th Fl.Lyndhurst, NJ 07071201-933-5541

6-1

6.0 NEW YORK STATE ENVIRONMENTAL QUALITY REVIEW ANALYSES

In addition to the air quality modeling analyses required for the Part 231/PSD permit

application, the CLI-II project will be required to address the following air quality issues as part

of the State Environmental Quality Review (SEQR) process:

Fine Particulates (PM-2.5);

Acid Deposition;

Toxic Air Pollutants;

Accidental Releases;

Visible Plumes;

Long Island Power Authority (LIPA) Project Cumulative Analysis;

Local Large Combustion Source Cumulative Analysis; and

Greenhouse Gas Emissions

This section provides a summary of the methodology to be used to address each of these air

quality issues. These analyses will not be included in the Part 231/PSD permit application, but

will be included in the Project’s Environmental Impact Statement (EIS).

6.1 Fine Particulates (PM-2.5) The NYSDEC published policy CP-33 / Assessing and Mitigating Impacts of Fine Particulate

Matter Emissions on December 29, 2003 addressing the requirements for PM-2.5 air quality

modeling for New York State.

The NYSDEC policy requires any proposed facility with potential annual PM-10 emissions

greater than 15 tons per year (tpy) to conduct an air quality modeling analysis for PM-2.5.

Because the CLI-II project will have potential annual PM-10 emissions greater than 15 tpy, the

proposed facility is subject to PM-2.5 air quality modeling.

In addressing PM-2.5 air quality impacts, it will be conservatively assumed that all PM-10

emissions are PM-2.5. Furthermore, a qualitative discussion on the potential secondary

formation of PM-2.5 due to precursor emissions from the proposed facility will be included in

the PM-2.5 assessment.

Note that per U.S. EPA PM-2.5 modeling guidance, the emissions of PM-2.5 should account for

NO2 and SO2 precursor emissions (U.S. EPA, 2013). Caithness proposes to use a numerical

screening approach suggested by the Northeast States for Coordinated Air Use Management

(NESCAUM) in a May 30, 2013 comment letter to George Bridgers (Air Quality Modeling Group,

6-2

U.S. EPA) responding to “Draft Guidance for PM-2.5 Permit Modeling” released by U.S. EPA on

March 4, 2013. The approach calls for the use of a 7 percent per hour SO2 to sulfate conversion

rate and a 5 percent per hour NO2 to nitrate conversion rate. The direct PM-2.5 emission rate is

then increased accordingly by adding these incremental emissions. NESCAUM notes that it

believes this method “would provide a conservative, definitive, and defensible value of the

estimated contribution of secondary particulates”. (NESCAUM, 2013)

The air quality modeling analysis for PM-2.5 will be conducted following the same methodology

outlined for the Part 231/PSD air quality modeling analyses. Results of the PM-2.5 air quality

modeling analysis will be compared to the significant impact levels (SILs) referenced in 6

NYCRR Subpart 231-12. Specifically, the maximum modeled 24-hour and annual PM-2.5

concentrations will be compared to the significant impact levels (SILs) 1.2 ug/m3 and 0.3 ug/m3,

respectively. If the maximum modeled PM-2.5 concentrations are less than the NYSDEC SILs,

then the project will be considered to have insignificant impacts for PM-2.5 and no further

analyses will be required.

If the CLI-II project has maximum modeled PM-2.5 concentrations greater than the NYSDEC

PM-2.5 SILs, then an assessment of the severity of impacts, potential alternatives, and

reasonable and necessary mitigation measures will be included in the DEIS. According to the

NYSDEC, possible mitigation measures could include additional emission controls, purchasing

PM-2.5 emission offsets, and limiting operating hours.

6.2 Acid Deposition

The New York State Acid Deposition Control Act requires an applicant to quantify a proposed

facility’s contribution to the New York State total deposition of sulfates and nitrates at eighteen

defined receptors in New York State, New England and Canada. This analysis will be performed

using the procedure set forth in the March 4, 1993 memorandum from Mr. Leon Sedefian of the

DEC to the Impact Assessment and Meteorology (IAM) staff.

6.3 Toxic Air Pollutant Analysis

Air quality modeling will be conducted for potential toxic (non-criteria) air pollutant emissions

from the proposed combustion turbines and ancillary equipment. The modeling methodology

used in the toxic air pollutant analysis will be the same as used in the Part 201 air quality

analyses. Maximum modeled short-term and annual ground level concentrations of each toxic

air pollutant will be compared to the DEC’s short-term guideline concentration (SGC) and

annual guideline concentration (AGC), respectively. The DEC SGCs and AGCs to be used in the

analysis are listed in the DAR-1 (formerly Air Guide-1) tables that were published by the DEC in

October 2010.

6-3

Potential toxic air pollutant emissions from the sources will be calculated based upon the

emission factors from the most recent final version of AP-42 for each source type. Also included

in the analysis will be an assessment of impacts associated with the ammonia slip that will result

from the use of the SCR.

6.4 Accidental Releases The proposed facility is currently not planning to utilize or store large quantities of extremely

hazardous materials on site. Aqueous ammonia will be used as the reducing agent in the

project’s SCR systems for controlling NOx emissions from the turbines. Because of the need for a

constant supply, aqueous ammonia (a mixture containing less than 19 percent by weight

ammonia in water) will be stored on-site in storage tanks having 110% secondary containment.

The tanks will be designed in accordance with American Petroleum Institute (API) standards

and other applicable regulations. Due to the dilute concentration of the aqueous ammonia (less

than 20%), the project’s ammonia solution is not subject to the U.S. EPA Risk Management

Program for hazardous materials (40 CFR Part 68).

However, as part of the EIS for the CLI-II project, an assessment for the potential off-site

impacts resulting from a worst-case ammonia release scenario will be examined. The accidental

worst-case ammonia release scenario will be conducted using emission estimates based on U.S.

EPA’s Risk Management Program Guidance for Offsite Consequence Analysis (U.S. EPA, 2009).

To determine the potential worst-case impact distance, the U.S. EPA-approved Areal Locations

of Hazardous Atmospheres (ALOHA) model will be used. This accidental release model was

developed by National Oceanic and Atmospheric Administration (NOAA) and is routinely

utilized by first responders in predicting impact areas associated with hazardous material

releases. It is anticipated the facility will employ passive emission control measures and/or a

water suppression system, if necessary, to minimize ammonia emissions during an accidental

release.

6.5 Combustion Turbine Visible Plume Analysis

A major exhaust by-product of the combined cycle turbine combustion process is water vapor.

With each pound of natural gas fired, over two pounds of water vapor are formed and exhausted

to the atmosphere. Since the exhaust gas contains appreciably more water vapor than the

ambient air, an analysis will be performed to determine if the exhaust plume could condense and

become visible under normal atmospheric conditions. A visible plume formed under such

conditions is called a mixed vapor plume. When hot humid exhaust gas is vented to a cooler

humid atmosphere, the combination may be at or above the saturation level and a visible plume

will form. This is similar to seeing one's breath on a cold morning. Likewise, condensation trails

from high altitude aircraft are formed by the same mechanism.

6-4

The plume visibility analysis proposed for the CLI-II project will be performed using the exhaust

conditions for two (2) GE 7FA.05 combustion turbines in various operational configurations,

and will be assessed using a plume visibility model developed by TRC.

6.5.1 TRC Visible Plume Model

TRC's plume visibility model is a post processor that is used with hourly water vapor

concentration results from the widely recognized U.S. EPA AERMOD atmospheric dispersion

model. Water vapor is a non-reactive gas and when emitted by a combustion source at a

temperature well above its dew point its downwind dispersion characteristics may be

appropriately simulated using AERMOD. The AERMOD model will be run using the five years

of Brookhaven Airport surface data, and five years of upper air data from the Brookhaven

National Laboratory (see Section 5.3 for a detailed discussion on meteorological data selection).

The meteorological data includes wind speed, direction, temperature, dew point, and stability

parameters (sigma theta). Since the object of this study is to determine the potential total

number of hours of visible plumes (independent of the direction of the viewer), the analysis will

be simplified by using the same wind direction for each hour. In order to avoid plume reflection,

the mixing heights will be set to 10 km. Additionally, all calms will be set to 1 meter per second

and evaluated by the model. This is counter to regulatory modeling performed to ascertain air

quality impacts. In such cases calms are ignored. However, in the plume visibility analysis, calm

winds are considered very important since the vertical plume that occurs under light winds

presents a high likelihood for visible plume formation.

Visible plume formation will be determined using a matrix of flagpole receptors elevated above

the stack top and downwind spaced at 25-meter increments. The hourly water vapor

concentrations will be calculated and compared to actual meteorological observations and the

calculated saturation deficit for each hour of the recorded meteorological data. The saturation

deficit is a measure of the amount of additional water vapor that must be added to a volume of

air to bring it to saturation (i.e., 100% humidity). The elevated exhaust temperature is a

significant factor and a mixed plume temperature is also calculated. A condensed vapor plume

will be assumed to occur if the water vapor concentration exceeds the saturation deficit for each

specific location and hour modeled. Under these conditions, TRC's model assumes the vapor

plume will condense to form a visible cloud.

The visible plume analysis will be performed to determine the total number of hours the water

vapor in the combustion turbine plume condenses and forms a condensed vapor plume. The

condensed vapor plume will be identified as "visible" if it will occur during conditions that would

allow it to be viewed by the general public. This definition excludes plumes being formed at

night, and during periods of inclement weather (rain, snow, or fog) that obscure visibility. As

6-5

such, the total number of hours that the plume is considered visible will be limited to the amount

of hours during the daylight periods only (where daylight is defined as the period between ½

hour before sunrise until ½ hour after sunset). Additionally, the hours that have inclement

weather or low visibility will also be identified. Weather obscuration is defined as an hour of

inclement weather (indicated in the meteorological data record as moderate rain or snow, or

conditions where the horizontal visibility is reduced to less than ½ mile. As such, the base case

visible plume conditions will be all possible hours. A subsequent refinement of the base case

(i.e. screening of the total number of hours) will be performed to determine those hours of

visible plume that occur during daylight only. An additional refinement will determine the total

number of visible plumes that occur during the daylight period, without weather obscuration. In

this fashion, the DEIS will provide a “layered” analysis to determine the level of potential visual

impact of the combustion turbine visible plumes.

6.5.2 Combustion Visible Plume Modeling Methodology

The visible plume modeling analysis will be performed for the following parameters:

Two (2) GE 7FA.05 combustion turbines operating at 100% load on natural gas and

distillate oil, and

Five (5) years of surface data from Brookhaven Airport and five years of upper air data

from the Brookhaven National Laboratory

The visible plume analysis for the combustion turbine plumes will be assessed for several

operational conditions. These conditions will consider operation with natural gas firing without

additional water injection for NOx suppression, and oil firing where water will be injected into

the combustor. The total water content of the plume is modeled, which includes the water vapor

formed by the combustion process, and the additional water added during oil firing for NOx

suppression. Additional cases will examine the formation of visible plumes under part load

operation, for both natural gas and oil firing.

The results of the visible plume analysis will be provided in tables summarizing the frequency

distribution (i.e. number of hours and percent of hours) of visible plumes by height above the

stack top and downwind distance by fuel and unit operation. Additionally, two-dimensional

contour plots to show the distribution by height and downwind distance will be included as

graphics. Two sets of figures will be presented. One will represent the potential for a

combustion water vapor plume to occur as a percent of the total number of hours and the other

will provide a similar analysis for daylight hours only. Typically, there exist approximately 5,100

hours/year (all daylight hours) when a visible plume may be observed if one forms (accounting

for the ½ hour dawn and evening twilight periods).

6-6

6.6 LIPA Project Cumulative Impact Assessment

The scoping document issued by the Town of Brookhaven requires the DEIS to include a

cumulative air quality analysis for the proposed CLI-II project, the existing Caithness Long

Island Energy Center, and all LIPA sponsored and constructed power generation projects

recently constructed, under construction, or proposed.

Exhaust characteristics and emission rates for the LIPA projects will be obtained from the

NYSDEC and included with the proposed CLI-II project in an air quality modeling analysis. The

same modeling methodology and five years of meteorological data used in the PSD air quality

modeling analysis will be used in the LIPA project cumulative analysis. Polar receptors spaced

every 100-meters within 3-kilometers of each project, as well as a Cartesian grid with 2-

kilometer spaced receptors which covers most of Long Island, will be used to locate the

maximum modeled air quality concentrations. Maximum total concentrations will be

determined by adding the modeling results and the representative “worst case” background

concentrations presented in Table 5-3. These values will then be compared to the NAAQS and

NYAAQS.

6.7 Local Large Combustion Source Cumulative Analysis

An analysis will be conducted to examine the cumulative air quality impacts of the proposed

CLI-II project and other large combustion sources in the vicinity (i.e., within 10 miles of the

project site) that have been approved or have actions pending. Maximum total concentrations

will be determined by summing the maximum modeled concentrations and the representative

“worst case” background concentrations presented in Table 5-3. The cumulative source impacts

plus a representative background will be compared to the NAAQS and NYAAQS.

6.8 Greenhouse Gas Emissions

Greenhouse or climate change gases contribute to climate change by increasing the ability of the

atmosphere to trap heat. The principal Greenhouse Gases (GHGs) are carbon dioxide (CO2),

methane (CH4), and nitrous oxide (N2O). Because these gases differ in their ability to trap heat,

one ton of CO2 in the atmosphere has a different effect on warming than one ton of CH4. To

express emissions of the different gases in a comparable way, atmospheric chemists often use a

weighing factor called the Global Warming Potential (GWP). The concept of a GWP was

developed to compare the ability of each greenhouse gas to trap heat in the atmosphere relative

to another gas.

6-7

The EIS will:

quantify direct and indirect carbon dioxide (CO2) emissions from the project during

construction and operation of the new pipeline lateral and during construction and

operation of the new generating station;

provide a comparison of annual and total project lifetime CO2 emissions to other sources

of power generation, including both fossil fuel fired and feasible proposed Town and

region-wide alternative energy projects utilizing green energy technologies; and,

provide a menu of possible mitigation options.

The project’s compliance with Title 6 NYCRR Part 251 “CO2 Performance Standards for Major

Electric Generating Facilities” and the Regional Greenhouse Gas Initiative will also be

addressed.

7-1

7.0 REFERENCES NESCUAM, 2013. NESCAUM letter to George Bridgers, Air Quality Modeling Group, U.S.EPA,

providing comments to Draft Guidance for PM2.5 Permit Modeling, released by EPA on

March 4, 2013. Boston, Massachusetts. May 30, 2013.

NYSDEC, 2006. NYSDEC Guidelines on Dispersion Modeling Procedures for Air Quality Impact

Analysis – DAR 10. Impact Assessment and Meteorology Section, Bureau of Stationary

Sources. May 9, 2006

U.S. EPA, 2005. Guideline on Air Quality Models (Revised). Appendix W to Title 40 U.S. Code

of Federal Regulations (CFR) Parts 51 and 52, Office of Air Quality Planning and

Standards, U.S. Environmental Protection Agency. Research Triangle Park, North

Carolina. November 6, 2005.

U.S. EPA, 1992. "Screening Procedures for Estimating the Air Quality Impact of Stationary

Sources, Revised". EPA Document 454/R-92-019, Office of Air Quality Planning and

Standards, Research Triangle Park, North Carolina.

U.S. EPA, 1990. "New Source Review Workshop Manual, Draft". Office of Air Quality Planning

and Standards, U.S. Environmental Protection Agency. Research Triangle Park, North

Carolina.

U.S. EPA, 1985. Guidelines for Determination of Good Engineering Practice Stack Height

(Technical Support Document for the Stack Height Regulations-Revised). EPA-450/4-

80-023R. U.S. Environmental Protection Agency.

U.S. EPA, 1980. A Screening Procedure for the Impacts of Air Pollution Sources on Plants, Soils,

and Animals. EPA 450/2-81-078. Office of Air Quality Planning and Standards, U.S.

Environmental Protection Agency. Research Triangle Park, North Carolina. December

1980.

U.S. EPA, 2011. Additional Clarification Regarding Application of Appendix W Modeling

Guidance for the 1-Hour NO2 NAAQS. U.S. EPA. March 1, 2011.

U.S. EPA, 2013. Draft Guidance for PM-2.5 Modeling. Office of Air Quality Planning and

Standards, U.S. Environmental Protection Agency. Research Triangle Park, North

Carolina. March 4, 2013.

1

Keller, Michael

From: Margaret Valis <mxvalis@gw.dec.state.ny.us>Sent: Thursday, January 09, 2014 2:40 PMTo: Keller, Michael; Main, TedSubject: Fwd: RE: Caithness Air Quality Modeling Protocol

Mike and Ted, I received the following comments from EPA Region 2. Margaret

Margaret Valis Chief, Impact Assessment and Meteorology Section NYSDEC - Division of Air Resources 625 Broadway Albany, NY 12233-3254 ----------------------------------------------------------- (518)402-8403 mxvalis@gw.dec.state.ny.us >>> "Coulter, Annamaria" <Coulter.Annamaria@epa.gov> 1/8/2014 3:22 PM >>>

Margaret,

Thank you for the copy of your comments on the October 2013 modeling protocol for the Caithness Project. I agree with your comments but want to add a few additional ones which are below. I am commenting only on the modeling aspects of the submittal and not the emission calculations.

1. The modeling analysis should use the most recent version of AERMOD (vs 13350) and it associated preprocessors which were released on December 24, 2013.  

2. It is not clear whether AERMINUTE will be used. It should be used unless there is a sufficient reason to use the standard hourly meteorological data. 

3. If the facility would like operational flexibility to run the turbines in simple cycle mode, then this scenario should be added to the list of modeling scenarios that define the worst case impacts. 

4. Table 4‐2 needs to account for the revised PM2.5 annual NAAQS of 12 ug/m3 rather than 15 ug/m3. 5. The preconstruction monitoring waiver section proposes to use existing ambient data. However, it does not 

state which or how many years it will use.  Later in the protocol when it discusses background it states that the data was measured between 2010 to 2013. This is fine since it is 3 years and recent.  However,  this should be reconciled in the preconstruction monitoring waiver section as well.  

6. Please ensure that the applicant consults with the Fish and Wildlife Service in order to meet the Endangered Species Act requirements.   

7. Please ensure that the applicant addresses Environmental Justice in the application.  

Please let me know if you have any questions.

Thanks.

2

Annamaria

(212) 637-4016

 

 

From: Margaret Valis [mailto:mxvalis@gw.dec.state.ny.us] Sent: Wednesday, January 08, 2014 10:27 AM To: Michael (LyndhurstNJ-US) Keller; Ted (LyndhurstNJ-US) Main Cc: Coulter, Annamaria Subject: Caithness Air Quality Modeling Protocol

Attached is your electronic copy. Margaret Valis Chief, Impact Assessment and Meteorology Section NYSDEC - Division of Air Resources 625 Broadway Albany, NY 12233-3254 ----------------------------------------------------------- (518)402-8403 mxvalis@gw.dec.state.ny.us ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________

Class I Area Notification Letters and Federal Land

Manager Responses

September 26, 2013 mk015-13 Ms. Jill Webster Environmental Scientist United States Department of the Interior U.S. Fish & Wildlife Service National Wildlife Refuge System 7333 W. Jefferson Ave., Suite 375 Lakewood, Colorado 80235-2017 Subject: Caithness Long Island II, LLC

Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County, New York Need for Class I Area Air Quality and Air Quality Related Values (AQRV) Analyses for the Brigantine Wilderness Class I Area

Dear Ms. Webster: TRC has been retained by Caithness Long Island II, LLC (Caithness) to prepare a prevention of significant deterioration (PSD) permit application for a proposed approximately 752-megawatt (MW) combined cycle power facility to be constructed in the Town of Brookhaven, Suffolk County, New York. The approximate Universal Transverse Mercator (UTM) coordinates of the Caithness Long Island Energy Center II are 673,621 meters Easting, 4,520,851 meters Northing, in Zone 18, NAD83. Caithness is proposing to install two (2) General Electric (GE) 7FA.05 combustion turbines at the facility. The combustion turbines will be primarily natural gas-fired with distillate fuel oil with a sulfur concentration of no greater than 15 ppm (“ultra-low sulfur diesel” or “ULSD”) as backup fuel. Dry low NOx burners and Selective Catalytic Reduction (SCRs) will be used, in addition to water injection when firing ULSD, to reduce nitrogen oxides (NOx) emissions from the combustion turbines. The firing of primarily natural gas and ULSD as backup in the combustion turbines will minimize emissions of particulate matter with an aerodynamic diameter less than 10 microns (PM-10), sulfur dioxide (SO2) and sulfuric acid mist (H2SO4). Additionally, an oxidation catalyst will be installed to control the emissions of carbon monoxide (CO) and volatile organic compounds (VOC). Exhaust gases from each combustion turbine will flow into an adjacent heat recovery steam generator (HRSG) equipped with natural gas-fired duct burners. Each HRSG will produce steam to be used in the steam turbine generator. Combustion products will be discharged through two (2) exhaust stacks. Supporting auxiliary equipment includes a gas/ULSD fired auxiliary boiler, two (2) emergency diesel generators, and an emergency diesel firepump.

Ms. Jill Webster September 26, 2013 Page 2 of 3

Estimated potential short-term (24-hour) maximum emissions and annual emissions are presented in Table 1. The PM-10 emission rates presented in Table 1 include filterable and condensable particulates.

Table 1: Estimated Potential Emissions

Pollutant

Per Combustion Turbine Maximum Short-Term Emissions

(lb/hr) Annual Emissions1

(tpy) ULSD Fired

Nitrogen Oxides (NOx) 65.2 197.1 Sulfur Dioxide (SO2) 4.6 20.1

Particulate Matter with an aerodynamic diameter less than 10 microns (PM-10)

30.0 144.7

Sulfuric Acid Mist (H2SO4) 3.2 13.7 1Annual emissions reflect facility-wide potential-to-emit (i.e., combustion turbines with duct burners, auxiliary boiler, emergency diesel generators, and emergency diesel firepump). The Brigantine Wilderness Class I area located in the Edwin B. Forsythe National Wildlife Refuge in New Jersey is approximately 182 km southwest of the proposed facility. Following the Draft Revised FLAG guidance (2010), TRC believes that the proposed facility may be eligible for an exemption from the requirement to perform a Class I area modeling analysis because of its inherent low emissions and distance to the Class I area. We understand that the maximum short-term emission rates are used in the exemption analysis. Assuming full year operation (8,760 hours) of the combined cycle combustion turbines yields a (emission in tpy)/(distance in km) ratio (902.3 tons per year/182 km) of approximately 5.0. It is our understanding that according to the Q/D test, the FLM should consider this source (which is located greater than 50 km from the Brigantine Wilderness Class I area) and has a ratio of annual equivalent emissions (Q in tons per year) divided by distance (D in km) from the Brigantine Wilderness Class I area (km) < 10, as having negligible impacts with respect to Class I visibility impacts and that there would not be any Class I visibility impact analyses required from this source. With this letter, TRC, on behalf of Caithness, is formally requesting a determination that there is no need to perform a Class I area air quality and AQRV analysis for the Brigantine Wilderness Area as part of the facility’s PSD Air Permit application. If you should require additional information on the proposed Project or have any questions, please do not hesitate to contact me at (201) 508-6954 or mkeller@trcsolutions.com. Sincerely, TRC

Michael D. Keller Senior Project Manager

Ms. Jill Webster September 26, 2013 Page 3 of 3

cc: M. Valis, NYSDEC M. Garber, Caithness R. Ain, Caithness T. Grace, Caithness M. Murphy, Beveridge and Diamond S. Gordon, Beveridge and Diamond T. Main, TRC C. Adduci, TRC K. Maher, TRC TRC Project File 206458 W:\keller\mk015-13.ltr.doc

September 26, 2013 mk016-13 Mr. Chuck Sams Regional Air Program Manager U.S. Forest Service 1720 Peachtree Road Atlanta, GA 30309 Subject: Caithness Long Island II, LLC

Caithness Long Island Energy Center II Town of Brookhaven, Suffolk County, New York Need for Class I Area Air Quality and Air Quality Related Values (AQRV) Analyses for the Lye Brook Wilderness Class I Area

Dear Mr. Sams: TRC has been retained by Caithness Long Island II, LLC (Caithness) to prepare a prevention of significant deterioration (PSD) permit application for a proposed approximately 752-megawatt (MW) combined cycle power facility to be constructed in the Town of Brookhaven, Suffolk County, New York. The approximate Universal Transverse Mercator (UTM) coordinates of the Caithness Long Island Energy Center II are 673,621 meters Easting, 4,520,851 meters Northing, in Zone 18, NAD83. Caithness is proposing to install two (2) General Electric (GE) 7FA.05 combustion turbines at the facility. The combustion turbines will be primarily natural gas-fired with distillate fuel oil with a sulfur concentration of no greater than 15 ppm (“ultra-low sulfur diesel” or “ULSD”) as backup fuel. Dry low NOx burners and Selective Catalytic Reduction (SCRs) will be used, in addition to water injection when firing ULSD, to reduce nitrogen oxides (NOx) emissions from the combustion turbines. The firing of primarily natural gas and ULSD as backup in the combustion turbines will minimize emissions of particulate matter with an aerodynamic diameter less than 10 microns (PM-10), sulfur dioxide (SO2) and sulfuric acid mist (H2SO4). Additionally, an oxidation catalyst will be installed to control the emissions of carbon monoxide (CO) and volatile organic compounds (VOC). Exhaust gases from each combustion turbine will flow into an adjacent heat recovery steam generator (HRSG) equipped with natural gas-fired duct burners. Each HRSG will produce steam to be used in the steam turbine generator. Combustion products will be discharged through two (2) exhaust stacks. Supporting auxiliary equipment includes a gas/ULSD fired auxiliary boiler, two (2) emergency diesel generators, and an emergency diesel firepump.

Mr. Chuck Sams September 26, 2013 Page 2 of 3

Estimated potential short-term (24-hour) maximum emissions and annual emissions are presented in Table 1. The PM-10 emission rates presented in Table 1 include filterable and condensable particulates.

Table 1: Estimated Potential Emissions

Pollutant

Per Combustion Turbine Maximum Short-Term Emissions

(lb/hr) Annual Emissions1

(tpy) ULSD Fired

Nitrogen Oxides (NOx) 65.2 197.1 Sulfur Dioxide (SO2) 4.6 20.1

Particulate Matter with an aerodynamic diameter less than 10 microns (PM-10)

30.0 144.7

Sulfuric Acid Mist (H2SO4) 3.2 13.7 1Annual emissions reflect facility-wide potential-to-emit (i.e., combustion turbines with duct burners, auxiliary boiler, emergency diesel generators, and emergency diesel firepump). The Lye Brook Wilderness Class I area is located in Vermont approximately 248 km north of the proposed facility. Following the Draft Revised FLAG guidance (2010), TRC believes that the proposed facility may be eligible for an exemption from the requirement to perform a Class I area modeling analysis because of its inherent low emissions and distance to the Class I area. We understand that the maximum short-term emission rates are used in the exemption analysis. Assuming full year operation (8,760 hours) of the combined cycle combustion turbines yields a (emission in tpy)/(distance in km) ratio (902.3 tons per year/248 km) of approximately 3.6. It is our understanding that according to the Q/D test, the FLM should consider this source (which is located greater than 50 km from the Lye Brook Wilderness Class I area) and has a ratio of annual equivalent emissions (Q in tons per year) divided by distance (D in km) from the Lye Brook Wilderness Class I area (km) < 10, as having negligible impacts with respect to Class I visibility impacts and that there would not be any Class I visibility impact analyses required from this source. With this letter, TRC, on behalf of Caithness, is formally requesting a determination that there is no need to perform a Class I area air quality and AQRV analysis for the Lye Brook Wilderness Area as part of the facility’s PSD Air Permit application. If you should require additional information on the proposed Project or have any questions, please do not hesitate to contact me at (201) 508-6954 or mkeller@trcsolutions.com. Sincerely, TRC

Michael D. Keller Senior Project Manager

Mr. Chuck Sams September 26, 2013 Page 3 of 3

cc: M. Valis, NYSDEC M. Garber, Caithness R. Ain, Caithness T. Grace, Caithness M. Murphy, Beveridge and Diamond S. Gordon, Beveridge and Diamond T. Main, TRC C. Adduci, TRC K. Maher, TRC TRC Project File 206458 W:\keller\mk016-13.ltr.doc

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Keller, Michael

From: Webster, Jill <jill_webster@fws.gov>Sent: Friday, September 27, 2013 5:38 PMTo: Keller, MichaelSubject: Re: Caithness Long Island II, LLC - Need for Class I AQ Analyses for Brigantine

Wilderness Area

Mr. Keller, Thank you for sending the information regarding Caithness Long Island, LLC to be located in the town of Brookhaven, Suffolk County, New York. Based on the emission rates and distance from the Class I area (as provided in your letter dated September 26, 2013), the Fish and Wildlife Service anticipates that modeling would not show any significant additional impacts to air quality related values (AQRV) at the Brigantine Wilderness. Therefore, we are not requesting that a Class I AQRV analysis be included in the PSD permit application. Our screening of this analysis does not indicate agreement with any AQRV analysis protocols or conclusions applicants may make independent of Federal Land Manager review. Please note that we are specifically addressing the need for an AQRV analysis for the Brigantine Wilderness. Should the emissions for the nature of the project change significantly, please contact me directly so that we might re-evaluate the revised proposed project. Thank you for keeping us informed and involving the Fish and Wildlife Service's Brand of Air Quality in the project review.

On Thu, Sep 26, 2013 at 4:05 PM, Keller, Michael <MKeller@trcsolutions.com> wrote:

Ms. Webster,

TRC, on behalf of Caithness Long Island II, LLC, is formally requesting a determination (see attachment) that there is no need to perform a Class I area air quality and air quality related values analysis for the Brigantine Wilderness Class I area as part of the facility’s PSD permit application.

If you have any questions, please call or email.

Thanks for your attention.

Michael

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Michael D. Keller Senior Project Manager

Please note that effective June 3rd, 2013 our new address is

1200 Wall Street West, 5th Floor, Lyndhurst, NJ 07071

1200 Wall Street West, 5th Floor, Lyndhurst, NJ 07071

T: 201.508.6954 | F: 201.933.5601 | MKeller@trcsolutions.com

LinkedIn | Twitter | Blog | Flickr | www.TRCsolutions.com

______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ -- Jill Webster, Environmental Scientist US Fish and Wildlife Service National Wildlife Refuge System Branch of Air Quality 7333 W. Jefferson Ave., Suite 375 Lakewood, CO 80235-2017 (303) 914-3804 fax: (303) 969-5444 ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________

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Keller, Michael

From: Perron, Ralph -FS <rperron@fs.fed.us>Sent: Monday, October 21, 2013 5:18 PMTo: Keller, MichaelCc: Margaret Valis (mxvalis@gw.dec.state.ny.us); Mitchell Garber; Ross Ain; Thomas Grace;

Michael G. Murphy; Stephen Gordon (SGordon@bdlaw.com); Main, Ted; Adduci, Carla; Maher, Kevin; Sams, Charles E -FS; Holly_Salazer@nps.gov; 'Jill Webster'

Subject: RE: Caithness Long Island II, LLC - Need for Class I AQ Analyses for Lye Brook Wilderness Area

Attachments: PSD Permit Request for Determination_CLI-II.pdf; mk016-13 ltr LyeBrook.pdf

Hi Michael 

Thank you for sending the information about the proposed new facility, Caithness Long Island II, a 752 MW Dual Fueled Combined Cycle Power Generating Facility, located in Suffolk County, NY.  Based on the proposed emissions of 197 TPY NOx, 20 TPY SO2, 145 TPY PM10, and 14 TPY H2SO4, and a distance of 248 km to the Lye Brook Class I Area, the US Forest Service will not be requesting AQRV analyses of this project. 

Please keep us informed of any significant changes in this project, as well as any other proposal which may have an impact on the Lye Brook Class I Area, in the Green Mountain National Forest.

Ralph Perron Air Quality Specialist Green Mountain, White Mountain, Allegheny, and Finger Lakes National Forests cell   802‐222‐1444  http://www.fs.fed.us/air/   From: Keller, Michael [mailto:MKeller@trcsolutions.com] Sent: Friday, October 04, 2013 6:39 AM To: Perron, Ralph -FS Cc: Margaret Valis (mxvalis@gw.dec.state.ny.us); Mitchell Garber; Ross Ain; Thomas Grace; Michael G. Murphy; Stephen Gordon (SGordon@bdlaw.com); Main, Ted; Adduci, Carla; Maher, Kevin; Sams, Charles E -FS Subject: RE: Caithness Long Island II, LLC - Need for Class I AQ Analyses for Lye Brook Wilderness Area  Ralph, Per your request, please see the attached completed document. If you have any questions, please call or email. Thanks for your continued attention. Michael Michael D. Keller Senior Project Manager Please note that effective June 3rd, 2013 our new address is 1200 Wall Street West, 5th Floor, Lyndhurst, NJ 07071

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1200 Wall Street West, 5th Floor, Lyndhurst, NJ 07071 T: 201.508.6954 | F: 201.933.5601 | MKeller@trcsolutions.com

LinkedIn | Twitter | Blog | Flickr | www.TRCsolutions.com

From: Perron, Ralph -FS [mailto:rperron@fs.fed.us] Sent: Tuesday, October 01, 2013 4:28 PM To: Sams, Charles E -FS; Keller, Michael Cc: Margaret Valis (mxvalis@gw.dec.state.ny.us); Mitchell Garber; Ross Ain; Thomas Grace; Michael G. Murphy; Stephen Gordon (SGordon@bdlaw.com); Main, Ted; Adduci, Carla; Maher, Kevin Subject: RE: Caithness Long Island II, LLC - Need for Class I AQ Analyses for Lye Brook Wilderness Area  Hello Mr. Keller,   I have reviewed the 3 page document that you sent to Chuck Sams for review.  Thank you for the return phone call in response to my VM regarding fuel source.  It is my understanding that Table 1 in your attachment uses ULSD emissions as a worst case scenario, and you have shown emissions for both turbines.   Could you also complete the attached document for our records.   Thanks Ralph Perron Air Quality Specialist Green Mountain, White Mountain, Allegheny, and Finger Lakes National Forests cell   802‐222‐1444   http://www.fs.fed.us/air/     From: Sams, Charles E -FS Sent: Friday, September 27, 2013 9:27 AM To: Keller, Michael Cc: Margaret Valis (mxvalis@gw.dec.state.ny.us); Mitchell Garber; Ross Ain; Thomas Grace; Michael G. Murphy; Stephen Gordon (SGordon@bdlaw.com); Main, Ted; Adduci, Carla; Maher, Kevin; Perron, Ralph -FS Subject: RE: Caithness Long Island II, LLC - Need for Class I AQ Analyses for Lye Brook Wilderness Area   Mr. Keller, I have forwarded your email to our Air Specialist, Ralph Peron, whose responsibilities are review of air permits potentially affecting Lye Brook Wilderness.  He will contact you soon.  Please direct any future correspondence regarding the Brookhaven facility to Mr. Perron.   Thank you, Chuck Sams, NFS Eastern Region Air Program Manager   From: Keller, Michael [mailto:MKeller@trcsolutions.com] Sent: Thursday, September 26, 2013 6:06 PM To: Sams, Charles E -FS Cc: Margaret Valis (mxvalis@gw.dec.state.ny.us); Mitchell Garber; Ross Ain; Thomas Grace; Michael G. Murphy; Stephen Gordon (SGordon@bdlaw.com); Main, Ted; Adduci, Carla; Maher, Kevin Subject: Caithness Long Island II, LLC - Need for Class I AQ Analyses for Lye Brook Wilderness Area   Mr. Sams,   

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TRC, on behalf of Caithness Long Island II, LLC, is formally requesting a determination (see attachment) that there is no need to perform a Class I area air quality and air quality related values analysis for the Lye Brook Wilderness Class I area as part of the facility’s PSD permit application.   If you have any questions, please call or email.   Thanks for your attention.   Michael   Michael D. Keller Senior Project Manager   Please note that effective June 3rd, 2013 our new address is 1200 Wall Street West, 5th Floor, Lyndhurst, NJ 07071  

 

1200 Wall Street West, 5th Floor, Lyndhurst, NJ 07071T: 201.508.6954 | F: 201.933.5601 | MKeller@trcsolutions.com 

LinkedIn | Twitter | Blog | Flickr | www.TRCsolutions.com 

      ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________  This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately. ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________