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Susitna-Watana Hydroelectric Project Document
ARLIS Uniform Cover Page
Title:
Air quality study, Study plan Section 15.9 : Initial study report -- Part A:
Sections 1-6, 8-10
SuWa 223
Author(s) – Personal:
Author(s) – Corporate:
HMMH [that is, Harris, Miller, Miller & Hanson Inc.]
AEA-identified category, if specified:
Initial study report
AEA-identified series, if specified:
Series (ARLIS-assigned report number):
Susitna-Watana Hydroelectric Project document number 223
Existing numbers on document:
Published by:
[Anchorage : Alaska Energy Authority, 2014]
Date published:
June 2014
Published for:
Alaska Energy Authority
Date or date range of report:
Volume and/or Part numbers:
Final or Draft status, as indicated:
Document type:
Pagination:
v, 25 p.
Related work(s):
The following parts of Section 15.9 appear in separate files:
Part A ; Part B ; Part C.
Pages added/changed by ARLIS:
Notes:
All reports in the Susitna-Watana Hydroelectric Project Document series include an ARLIS-
produced cover page and an ARLIS-assigned number for uniformity and citability. All reports
are posted online at http://www.arlis.org/resources/susitna-watana/
Susitna-Watana Hydroelectric Project
(FERC No. 14241)
Air Quality Study
Study Plan Section 15.9
Initial Study Report
Part A: Sections 1-6, 8-10
Prepared for
Alaska Energy Authority
Prepared by
HMMH
June 2014
INITIAL STUDY REPORT AIR QUALITY STUDY (15.9)
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TABLE OF CONTENTS
1. Introduction ....................................................................................................................... 1
2. Study Objectives................................................................................................................ 1
3. Study Area ......................................................................................................................... 2
4. Methods and Variances in 2013 ....................................................................................... 2
4.1. Document Existing Conditions ............................................................................... 2
4.1.1. Variances......................................................................................... 2
4.2. Estimate Project Emissions ..................................................................................... 2
4.2.1. Variances......................................................................................... 3
4.3. Summarize Baseline Fossil Fuel Generation Emissions ......................................... 3
4.3.1. Variances......................................................................................... 3
4.4. Analyze and Compare Emissions ........................................................................... 4
4.4.1. Variances......................................................................................... 4
4.5. Identify Best Management Practices ...................................................................... 4
4.5.1. Variances......................................................................................... 4
5. Results ................................................................................................................................ 5
5.1. Existing Conditions ................................................................................................. 5
5.1.1. Meteorology and Climate ............................................................... 5
5.1.2. Weather Station Data ...................................................................... 5
5.1.3. Ambient Air Quality ....................................................................... 6
5.2. Project Emissions .................................................................................................... 8
5.2.1. Construction Equipment Emissions ................................................ 8
5.2.2. Fugitive Dust Emissions ................................................................. 9
5.2.3. Transportation-Related Emissions .................................................. 9
5.2.4. Operations-Related Emissions ........................................................ 9
5.3. Baseline Fossil Fuel Generation Emissions .......................................................... 10
5.4. Comparison of Emissions ..................................................................................... 11
5.4.1. With-Project Emissions ................................................................ 11
5.4.2. Without-Project Emissions ........................................................... 11
5.5. Identification of Best Management Practices ....................................................... 12
6. Discussion......................................................................................................................... 12
7. Completing the Study ..................................................................................................... 13
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8. Literature Cited .............................................................................................................. 13
9. Tables ............................................................................................................................... 14
10. Figures .............................................................................................................................. 20
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List of Tables
Table 5.1-1. Available Regional Climate Summaries Representative of the Project Site ............ 14
Table 5.1-2. National Ambient Air Quality Standards ................................................................. 15
Table 5.1-3. Observed Ambient Air Quality Concentrations – Denali National Park and MSB
Ambient Monitors ......................................................................................................................... 16
Table 5.1-4. Observed Ambient Air Quality Concentrations from Anchorage Ambient
Monitors ........................................................................................................................................ 16
Table 5.1-5. Observed Ambient Air Quality Concentrations from Fairbanks Ambient
Monitors ........................................................................................................................................ 17
Table 5.1-6. Worst Observed Ambient Air Quality Concentrations ............................................ 17
Table 5.3-1. Railbelt Energy Region Net Generation Summary1 ................................................. 18
Table 5.3-2. Railbelt Electric Generation Emission Summary by Utility .................................... 18
Table 5.4-1. Estimated 2011 Power Generation Emission Rate1 in Railbelt Region ................... 19
Table 5.4-2. Estimated Emission Displacement for the Project based on 2011 Net
Generation and Emission Data...................................................................................................... 19
List of Figures
Figure 5.1-1. Alaska Climate Zones ............................................................................................. 20
Figure 5.1-2. Weather Station Data Locations Representative of the Project Site ....................... 21
Figure 5.1-3. Alaska Non-Attainment and Maintenance Areas Relative to Project Site .............. 22
Figure 5.1-4. ADEC and National Park Service Air Monitoring Locations ................................. 23
Figure 5.3-2. Railbelt Power Generation in 2011 by Fuel Type ................................................... 25
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LIST OF ACRONYMS, ABBREVIATIONS, AND DEFINITIONS
Abbreviation Definition
AAC Alaska Administrative Code
ADEC Alaska Department of Environmental Conservation
ADOT&PF Alaska Department of Transportation & Public Facilities
AEA Alaska Energy Authority
AP-42 Compilation of Air Pollutant Emission Factors
ASOS Automated surface observation systems
CAA Federal Clean Air Act of 1970
CAAA Clean Air Act Amendments of 1990
CO Carbon Monoxide
CO2 Carbon Dioxide
COOP Cooperative Observer Program
DOT Alaska Department of Transportation and Public Facilities
EPA United States Environmental Protection Agency
FERC Federal Energy Regulatory Commission
ILP Integrated Licensing Process
ISR Initial Study Report
MSATs Mobile Source Air Toxics
NAAQS National Air Quality Standards
NO2 Nitrogen Dioxide
NPS National Park Service
O3 Ozone
Pb Lead
PM10/PM2.5 Particulate matter less than 10 microns/Particulate Matter less than 2.5 microns
PRM Project River Mile
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Abbreviation Definition
Project Susitna-Watana Hydroelectric Project
PSD Prevention of Significant Deterioration
RSP Revised Study Plan
SO2 Sulfur Dioxide
SPD study plan determination
VMT Vehicle Miles Traveled
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1. INTRODUCTION
On December 14, 2012, Alaska Energy Authority (AEA) filed with the Federal Energy
Regulatory Commission (FERC or Commission) its Revised Study Plan (RSP) for the Susitna-
Watana Hydroelectric Project No. 14241 (Project), which included 58 individual study plans
(AEA 2012a). Section 15.9 of the RSP described the Air Quality Study. This study focuses on
assessing the current conditions of the study area against applicable state and national air quality
standards and evaluating the Project’s air quality impact against these standards. RSP Section
15.9 provided goals, objectives, and proposed methods for data collection regarding air quality.
On February 1, 2013, FERC staff issued its study determination (February 1 SPD) for 44 of the
58 studies, approving 31 studies as filed and 13 with modifications. RSP Section 15.9 was one of
the 31studies approved with no modifications.
Following the first study season, FERC’s regulations for the Integrated Licensing Process (ILP)
require AEA to “prepare and file with the Commission an initial study report describing its
overall progress in implementing the study plan and schedule and the data collected, including an
explanation of any variance from the study plan and schedule” (18 CFR 5.15(c)(1)). This Initial
Study Report on the Air Quality Study has been prepared in accordance with FERC’s ILP
regulations and details AEA’s status in implementing the study, as set forth in the FERC-
approved RSP (referred to herein as the “Study Plan”).
2. STUDY OBJECTIVES
The primary goal and objective of the air quality analysis is to ensure that the proposed Project
does not violate National Ambient Air Quality Standards (NAAQS) per 40 CFR Part 50 and state
air quality standards in Alaska Administrative Code (AAC) 18 AAC 50 (under the authority of
Alaska Statutes [AS] 46.03 and 46.14). The national and state air quality regulations are
designed to maintain and/or improve air quality by controlling or reducing emissions of air
pollutants. The air quality impact analysis is subject to the state and national ambient air quality
standards and state and national attainment designations (i.e., attainment, non-attainment,
maintenance).
The following are the primary objectives of the Air Quality Study:
• Assess the current conditions of the area against applicable state and national air quality
standards.
• Review and summarize existing air monitoring data in the area.
• Determine attainment status of the study area (i.e., unclassifiable/attainment, non-
attainment, maintenance).
• Quantify short-term (construction) and long-term (operational) emissions.
• If applicable, analyze ground-level impacts using air dispersion models.
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• If applicable, evaluate indirect mobile source emissions from additional traffic generated.
• Compare Project emissions to the Without-Project alternative.
• Evaluate potential emission reductions from Railbelt fossil-fuel utility plants if the
Project is operating.
• Develop information to be used in the identification of potential mitigation measures, if
necessary, to reduce emissions during construction.
3. STUDY AREA
As established by RSP Section 15.9.3, the study area for the Air Quality Study is comprised of
the immediate vicinity of the Project area and the greater Railbelt region.
4. METHODS AND VARIANCES IN 2013
In 2013, AEA implemented components of the Study Plan as described below.
4.1. Document Existing Conditions
AEA implemented the methods as described in the Study Plan for documenting existing
conditions in the study area (RSP Section 15.9.4.1) with no variances.
Air monitoring reports prepared by the Alaska Department of Environmental Conservation
(ADEC) were reviewed to assess the existing conditions of the area. There is little existing
ambient monitoring data available for the vicinity of the Project site, so the study team
investigated state and National Park Service (NPS) monitoring data to help characterize the air
quality within the study area. AEA coordinated with ADEC and NPS to use the most relevant
data available to support the existing conditions section. The monitoring data have been
compiled and compared to applicable standards for criteria pollutants in tables. Criteria
pollutants, as defined by the U.S. Environmental Protection Agency (EPA), are nitrogen dioxide
(NO2), sulfur dioxides (SO2), carbon monoxide (CO), particulate matter (PM10/PM2.5), lead (Pb),
and ozone (O3).
4.1.1. Variances
There were no variances in implementing study methods for documenting existing conditions
during 2013.
4.2. Estimate Project Emissions
AEA implemented the methods as described in the Study Plan for estimating emissions from
construction equipment and related activities (RSP Section 15.9.4.2), with the exception of the
variance described below (Section 4.2.1).
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The Study Plan provides for the quantification of specific information on construction
equipment, along with other Project construction details such as air and rail schedules that are
not yet available. As provided in the Study Plan (RSP Sections 15.9.7, 15.9.11), however, the
quantitative analysis required in this study requires inputs from other licensing studies, such as
Geology and Soils Characterization (Study 4.5), Transportation Resources (Study 15.7), as well
as from Project engineering and feasibility studies. Because these other studies were ongoing in
2013, the analyses contemplated in the Study Plan were deferred pending completion of these
other studies.
Although the quantification analyses were deferred during 2013, the study team completed a
qualitative assessment of potential Project-related emissions to provide information on the
sources and types of emissions likely to occur during Project construction and operation,
including the types of operations and equipment expected for the construction of the Project and
transportation-related activities.
4.2.1. Variances
As explained above, the quantitative analysis of future emissions associated with Project
construction was deferred in 2013. Despite this variance, Study Plan objectives will be met by
completing this assessment in the next study season, when data from studies used for this
analysis becomes available.
4.3. Summarize Baseline Fossil Fuel Generation Emissions
AEA implemented the methods as described in the Study Plan for summarizing baseline fossil
fuel generation emissions (RSP Section 15.9.4.3) with no variances.
The study team summarized baseline fossil fuel generation emissions in the area. Baseline
emissions were summarized for Railbelt generating facilities and were comprised of criteria
pollutant and greenhouse gas emissions for each generating facility. The team used the emission
source data from ADEC to summarize the pollutant emissions along with generation data from
AEA.
As noted in the Study Plan, in preparing this summary, the study team did not conduct additional
monitoring or data collection at existing power generation sites because the source emission and
generation data were already summarized by ADEC and AEA for the Railbelt region.
4.3.1. Variances
There were no variances in implementing study methods for summarizing fossil fuel generation
emissions during 2013. However, the team did not utilize information identified by HDR in
Section 7.3.1.2 of the Data Gap Analysis as contemplated in the Study Plan (RSP Section
15.9.4.3) because emissions and generation data from ADEC and AEA were available for the
Railbelt region.
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4.4. Analyze and Compare Emissions
AEA implemented the methods as described in the Study Plan for comparing future estimated
With-Project emissions to emissions estimated for Without-Project emissions. The study team
compared the potential emissions from other Railbelt fossil-fueled facilities to provide the
equivalent annual generation of power as the Project if the Project is not implemented, or the
installation of new generation facilities for the future using a similar fuel mix to the current
Railbelt facilities.
The study team prepared an initial emissions comparison of the With-Project and Without-
Project scenarios. The With-Project emissions displacement from the Project was estimated by
calculating a pollutant-specific pound per megawatt hour based on the Railbelt utilities’
generation and emission data obtained from AEA and ADEC. The Without-Project emissions
assumed emissions from the With-Project scenario would not be displaced, but rather generated
within the Railbelt region to meet the additional demand.
The study team anticipates that these Project emissions comparison scenarios will be further
refined during the next study season as more information related to the construction and
operation of the Project is developed through engineering and other investigations.
4.4.1. Variances
There were no variances in implementing study methods for comparing future estimated With-
Project emissions to emissions estimated for Without-Project emissions during 2013.
4.5. Identify Best Management Practices
AEA implemented the methods as described in the Study Plan for summarizing baseline fossil
fuel generation emissions (RSP Section 15.9.4.3) with no variances.
The study team prepared an initial list of best management practices to reduce air emissions
related to the construction and operation of the Project. These best management practices were
identified based on an Internet review of mitigation measures developed and/or employed for
other similar construction activities along with reviewing dust mitigation measures conducted by
ADEC and the Alaska University Transportation Center. This list will be further refined during
the next study season as more information related to the construction and operation of the Project
is developed through engineering and other investigations.
4.5.1. Variances
There were no variances in implementing study methods for identifying best management
practices during 2013.
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5. RESULTS
5.1. Existing Conditions
AEA gathered existing meteorological and air quality information to document baseline
conditions of the study area. Air quality is dependent on a combination of many factors,
including the type and amount of pollutants emitted, the size and topography of the air basin, and
prevailing meteorological conditions. The significance of the pollutant concentration is
determined by comparing a certain area’s conditions with federal and state air quality standards.
The existing conditions of the study area are summarized and presented in this section.
5.1.1. Meteorology and Climate
Due to its large size, Alaska has a diverse climate that is characterized by wide temperature
ranges and weather conditions. This diversity can be attributed to Alaska’s high latitude
location, variable topographical features, and ocean influence, including moving ice.
The geographical landscapes of Alaska have a significant effect on the state’s climate. As shown
in Figure 5.1-1, there are five principal climatic zones that characterize the climate of Alaska:
Maritime, Maritime Continental, Transitional Maritime and Continental, Continental, and Arctic.
The Project area falls primarily within the Transitional Maritime and Continental climate zone.
Conditions within the Transitional Maritime and Continental climate are best described as a sub-
arctic climate consisting of mild temperatures compared to Alaska standards, which is due
mainly to the proximity of the coast. Precipitation tends to be lighter compared to the maritime
regions; however, there tends to be more snow in the winter compared to the southeast.
The Project site lies in the Susitna River valley with the Alaska Range to the north and the
Talkeetna Mountains to the south. These topographical features can also influence weather and
precipitation and contribute to temperature inversions, which can lead to pollution and smog.
Temperature inversions are an increase in temperature with height and typically occur during the
winter months when the lower levels of the atmosphere are extremely cold and the temperature
increases with height, which can trap airborne pollutants closer to the ground surface.
In order to characterize the climate and the meteorology of the study area, a review of nearby
weather station data was conducted.
5.1.2. Weather Station Data
There are automated surface observing systems (ASOS) stations maintained in the area of the
Project site by the National Weather Service and NPS, along with the Cooperative Observer
Program (COOP), a volunteer-based monitoring system. The closest stations’ temperature and
precipitation data were reviewed to characterize the weather and climate in the area. The closest
stations representative of the Project site were Talkeetna, Gulkana, Denali National Park
Headquarters, Palmer, and Big Delta. Figure 5.1-2 shows the station locations relative to the
Project site and Table 5.1-1 shows the climate statistics from each station. Information pertaining
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to each station was obtained from the National Weather Service data climate page
(http://pafg.arh.noaa.gov/cliMap/akClimate.php).
The data show the average annual minimum temperature ranging from 16°F to 28°F and the
maximum average temperature ranging from 34°F to 47°F. Annual average precipitation totals
range from 9 to 18 inches, with the highest totals found at Talkeetna and the Denali National
Park Headquarters location.
5.1.3. Ambient Air Quality
5.1.3.1. Air Quality Standards
Pursuant to the Federal Clean Air Act of 1970 (CAA), EPA established National Ambient Air
Quality Standards (NAAQS) for major pollutants known as “criteria pollutants” (see Table
5.1-2). Currently, EPA regulates six criteria pollutants: ozone (O3), carbon monoxide (CO),
nitrogen dioxide (NO2), sulfur dioxide (SO2), particulate matter, and lead (Pb). Particulate matter
(PM) is organized in two particle size categories: particles with a diameter less than 10
micrometers (PM10) and those with a diameter of less than 2.5 micrometers (PM2.5). ADEC has
established ambient air quality standards under 18 AAC 50.010 and these standards are similar to
the NAAQS for criteria pollutants; however, ADEC also includes an 8-hour standard for
ammonia and a 30-minute standard for reduced sulfur.
Table 5.1-2 shows the primary and secondary NAAQS for the criteria pollutants along with the
ADEC ambient air quality standards. The NAAQS are two-tiered. The first tier (primary) is
intended to protect public health; the second tier (secondary) is intended to prevent further
degradation of the environment. Section 176(c) of the CAA requires federal agencies to ensure
that all of their actions conform to applicable implementation plans for achieving and
maintaining the NAAQS. Federal actions must not cause or contribute to any new violation of
any standard, increase the frequency or severity of any existing violation, or delay timely
attainment of any standard.
5.1.3.2. Attainment Classifications
The standards in Table 5.1-2 apply to the concentration of a pollutant in outdoor ambient air.
EPA designates all areas in the U.S. as attainment, unclassifiable, nonattainment, or maintenance
with respect to the NAAQS. If the air quality in a geographic area is equal to or is better than the
national standard, it is called an “attainment area.” Areas where air quality does not meet the
national standard are called “non-attainment areas.” Once the air quality in a non-attainment area
improves to the point where it meets the standards and the additional redesignation requirements
in the CAA [Section 107(d) (3)(E)], EPA redesignates the area as a “maintenance area.” Any
areas that cannot be classified based on available information as meeting or not meeting the
NAAQS are considered unclassifiable; however, these areas are functionally equivalent to
attainment areas.
The Clean Air Act Amendments (CAAA) of 1990 require states to designate the status of all
areas within their borders as being in or out of compliance with the NAAQS. The CAAA further
define non-attainment areas for ozone based on the severity of the violation as marginal,
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moderate, severe, and extreme. In an effort to further improve the nation’s air quality, EPA has
classified additional areas as attainment/non-attainment for a new 2008 8-hour ozone standard.
The new 2008 8-hour ozone standard is listed in Table 5.1-2.
Each state is required to draft a state implementation plan (SIP) to further improve the air quality
in non-attainment areas and maintain the air quality in attainment or maintenance areas. The SIP
outlines the measures the state will take in order to improve air quality.
The study area is currently designated as unclassifiable or attainment under 18 AAC 50.015 and
the EPA Green Book with respect to all criteria pollutants. Some areas of Alaska are designated
unclassifiable due to the limitations in the scope of the ambient monitoring networks. However,
as discussed above, these areas are considered to have ambient concentrations that are below the
levels established by the NAAQS. The closest non-attainment designated area is located in the
Fairbanks-North Pole urban area, which is designated as non-attainment for PM2.5. The Eagle
River area of Anchorage and the City of Juneau are designated by EPA as a maintenance area for
PM10. In addition, both the Municipality of Anchorage and the Fairbanks-North Pole area are
designated as a maintenance areas for CO. EPA has taken steps to reduce particulate emissions
through various actions including the Clean Diesel Program to reduce emissions from highway,
non-road, and stationary diesel engines, and the Fine Particle Implementation Rule, which
defines requirements for states in areas not meeting the NAAQS to reduce fine particulate
matter. Figure 5.1-3 shows the non-attainment and maintenance areas within the state.
As part of the 1990 amendments to the CAA, EPA has developed two conformity regulations for
transportation and non-transportation projects in non-attainment and maintenance areas.
Transportation projects are governed by the “transportation conformity” regulations (40 CFR
Parts 51 and 93). Non-transportation projects are governed by the “general conformity”
regulations (40 CFR Parts 6, 51, and 93) described in the final rule for Determining Conformity
of General Federal Actions to State or Federal Implementation plans. Because the Project is
located in an unclassifiable or attainment area, the EPA Conformity rules do not apply.
5.1.3.3. Summary of Representative Monitoring Data
To characterize the background air quality in the vicinity of the Project area, air quality data
from ADEC, EPA, and NPS were reviewed for the most recent 3-year period available (2010 to
2012) at the closest most representative monitoring stations. The Project area is sparsely
populated; therefore, there are very few criteria monitoring stations in the immediate area.
Fairbanks and Anchorage are the largest cities in the vicinity of the Project site. Anchorage is
located approximately 120 miles to the southwest of the Project, while Fairbanks is located
approximately 140 miles to the north-northeast of the Project site. There are smaller cities
located nearby that have ADEC monitoring stations, such as Palmer and Wasilla located 88
miles to the south of the Project site. NPS also operates an ozone measurement site at Denali
National Park Headquarters and is located approximately 75 miles to the northwest of the Project
site. Figure 5.1-4 shows the AEA Susitna Project relative to the closest ADEC and NPS air
monitoring locations. The data from these measurement locations are considered to be
reasonably representative of the Project site and were used to determine background air quality
of the Project area (Table 5.1-5).
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Table 5.1-3 presents the monitored data for 2010 to 2012 from the Denali and Wasilla/Palmer
area for ozone and particulate matter (PM10 and PM2.5). Table 5.1-4 presents the monitored data
from Anchorage for CO, ozone, particulate matter, and lead, while Table 5.1-5 presents the
monitoring data from Fairbanks. Table 5.1-6 summarizes the highest concentrations from all the
representative stations and is used to establish the background air quality of the Project area.
These tables summarize the publicly available monitoring data in the vicinity of the Project and
are considered to be reasonably representative of the Project site.
The measured levels from the ADEC and the NPS monitoring stations are all below the NAAQS
except for the 24-hour PM10 at Palmer (174 micrograms per cubic meter [ug/m3]) and the annual
PM2.5 concentration at Fairbanks (13 µg/m3). These exceedances occur mostly during the winter
months when inversions are common and when fossil fuel and wood burning activities are at
their highest. The combination of the mobile source, fossil fuel, and word burning activities,
along with the very cold conditions that contribute to inversions, tend to trap the pollutants near
ground level and create high ground-level concentrations of particulate matter.
5.2. Project Emissions
Construction of the Project could result in a temporary increase in emissions of some pollutants
(e.g., PM10/PM2.5 and nitrogen oxides) due to the use of construction equipment powered by
diesel fuel and a temporary increase in fugitive emissions from operation of earth-moving
equipment. Project construction would also require the transportation of people, equipment, and
materials to and from the construction worksite, which could result in a temporary increase in
rail, air, and road traffic volumes as well as emissions associated with these transportation
modes.
Specific information on construction equipment, along with other Project construction details
such as air and rail schedules, are not yet available. Therefore, general information related to
emissions from construction equipment and related activities are discussed qualitatively in this
section.
5.2.1. Construction Equipment Emissions
Typical emissions from construction equipment include nitrogen oxides (NOx), CO, particulates,
SO2, and volatile organic compounds (VOCs), and are estimated based on the type of equipment
(i.e., on-road or non-road) and on the equipment’s anticipated level of use. Fuel consumption by
construction equipment varies depending on the type of equipment, the type of activity, and the
duration of the use.
Air quality emissions from construction activities associated with automobiles and trucks are
divided into on-road and non-road equipment. On-road vehicles include cars, trucks, and
motorcycles that use gas or diesel fuel. Emission factors for these types of vehicles are typically
estimated using EPA mobile models that incorporate vehicle information (e.g., vehicle and fuel
types) for the area. The emission factors generated by the mobile models are multiplied by the
vehicle miles traveled (VMT) to estimate tons per year per pollutant.
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Non-road construction equipment consists of cranes, excavators, bulldozers, etc. This type of
equipment generally uses diesel oil and its emission factors are also typically estimated using
EPA emission models based on the type of equipment. The emission factor generated is then
applied to the equipment horsepower rating and anticipated hourly use to estimate tons per year
per pollutant.
5.2.2. Fugitive Dust Emissions
In addition to emissions from construction equipment burning fuel, construction activities can
also result in fugitive dust emissions from earthmoving activities. Fugitive dust emissions can
result from the following:
• Grading
• Moving soil and digging
• Loading/unloading trucks
• Moving trucks on unpaved surfaces
• Wind eroding stockpiles
The amount of dust generated from construction activities is a function of a variety of factors
including soil type, moisture content, activity, vehicle type, wind speed, precipitation, and
roadway characteristics. Fugitive dust generation will be greater during dry periods where
precipitation is at a minimum and when the soils are dryer and prone to be released into the air
when disturbed. During the winter months, frozen ground and snow cover is present, which tends
to minimize the release of fine particles from disturbed areas. Fugitive dust emissions in tons per
year are typically estimated using EPA emission factors (or similar publications) based on the
total area disturbed and the type of activity on those areas.
5.2.3. Transportation-Related Emissions
Transportation of personnel and materials to support construction operations also results in
emissions from motor vehicles, aircraft, and trains. Estimating these emissions requires
construction schedule data and information on workforce and material sources, which is not yet
available for this Project.
5.2.4. Operations-Related Emissions
Air pollutant emissions associated with operation and maintenance activities (employee, delivery
vehicle trips, and miscellaneous point sources) after construction would be minimal compared to
those associated with construction activities. As Project details are finalized, an analysis will be
conducted to quantify the emissions associated with the operation and maintenance activities.
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5.3. Baseline Fossil Fuel Generation Emissions
Fossil fuel generation emissions were summarized to determine the baseline emissions from the
Railbelt electrical generating facilities. The Railbelt electric generating facilities are comprised
of seven utilities and serve most of the Alaska population.
Baseline emissions were summarized for Railbelt generating facilities and were comprised of
criteria pollutant and greenhouse gas emissions for each generating facility. The baseline fossil
fuel generations emissions are summarized and presented in this section.
Figure 5.3-1 shows the Alaska energy regions, including the Railbelt. The Railbelt generally
extends from Homer to Fairbanks and includes the study area. The seven utilities that comprise
the Railbelt energy region include:
• Chugach Electric Association (CEA)
• Golden Valley Electric Association (GVEA)
• Anchorage Municipal Light and Power (ML&P)
• Homer Electric Association (HEA)
• Seward Electric System
• Matanuska Electric Association (MEA)
• Aurora Energy, LLC
Four of the utilities—CEA, GVEA, ML&P, and Aurora Energy—operate units that generate
electricity for the Railbelt. HEA operates the Nikiski generating plant for CEA, while Seward
Electric purchases power from CEA. MEA is in the process of constructing the 171-megawatt
(MW) Eklutna Generating Station, which is scheduled to commence operation in January 2015.
The Railbelt electrical fleet uses mostly natural gas to generate electricity, followed by oil, coal,
and hydroelectric sources. There is some wind generation, including the Fire Island site;
however, wind power was a relatively small percentage of the fleet in 2011.
Table 5.3-1 documents net generation in the Railbelt for 2011 by fuel type, and the percentage of
power generated by fuel type. The table also documents the total generation from Railbelt
facilities compared to total generation by all Alaska energy regions. The majority of electricity
generated in the region in 2011 was generated from natural gas (74 percent) followed by oil (11
percent), coal and hydroelectric (8 percent each). Less than one percent of generation was from
renewable sources (i.e., wind, biomass, etc.).
The Railbelt accounts for approximately 77 percent of total electrical generation in Alaska,
including 99 percent of the natural gas-based generation and 100 percent of coal-fired
generation. The Railbelt also accounts for approximately half of the oil-generated electricity in
the state, and 30 percent of the hydroelectric power generation is in the Railbelt. Given that the
majority of the Alaska population is in the Railbelt, electrical generation and subsequent
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emissions are the highest in the state. Figure 5.3-2 shows the Railbelt power generation by fuel
type for 2011.
Baseline emissions were summarized for Railbelt generating facilities based on 2011 operating
data (ADEC 2012, AEA 2012b). The emissions are comprised of criteria pollutants (e.g., SO2,
NOx, PM10/PM2.5, VOC) and greenhouse gas emissions (e.g., carbon dioxide [CO2]) for each
generating facility. Table 5.3-2 shows the emissions summary for each Railbelt utility including
the total emissions for each pollutant.
5.4. Comparison of Emissions
A comparison of estimated With-Project and Without-Project emissions, or potential emission
displacement from the Railbelt fossil fuel facilities and/or emissions reduction within the Railbelt
area, was estimated based on projected Project electrical generation and baseline emission
generating data. The Without-Project emissions scenario summarizes the potential emissions
from future Railbelt fossil fuel facilities to provide the equivalent annual generation power as the
Project, assuming the Project is not implemented. The Without-Project emissions estimate
assumes future electrical generation with a fuel mix similar to the current Railbelt facilities. The
With-Project and Without-Project emissions are summarized in this section.
5.4.1. With-Project Emissions
The Project is estimated to generate approximately 2,800,000 MWh (megawatt hours) annually
of clean, renewable electricity for the Railbelt region. This is approximately 55 percent of the
current Railbelt electric demand. To estimate potential emission displacement (reduction) from
the Project, a pollutant-specific pound per megawatt hour (lb-MWh) emission rate was
calculated based on the 2011 Railbelt generation data. The pollutant-specific displacement rate
was calculated by taking the total Railbelt emissions for each pollutant (see Table D.3-2) and
dividing it by the total MWh. Table 5.4-1 presents the resultant lb/MWh displacement emission
rate for each pollutant based on 2011 Railbelt generation and emissions data.
Table 5.4-2 presents the expected emission displacement in tons per year (TPY) in the Railbelt
region once the Project is in operation. The emissions displacement was estimated assuming the
2011 Railbelt emissions rate in lbs/MWh and the expected electrical production of 2,800,000
MWh from the Project. The potential displacement is approximately 55 percent of the baseline
emissions based on 2011 operating data.
The Project would eliminate the need to build up to 2,800,000 MWh of new fossil fuel plants or
increase capacity from baseline plants, and thus eliminate the criteria air pollutant and
greenhouse gas emissions associated with the fossil fuel generation facilities.
5.4.2. Without-Project Emissions
The Project is expected to generate 2,800,000 MWh of clean electricity for the Railbelt region. If
the Project is not constructed, the additional capacity is assumed to be generated within the
Railbelt region through new plants or increased capacity from baseline plants. Assuming the
same 2011 fuel mix for the region, the expected emissions displacement from the generation of
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electricity With-Project would not occur and would be generated within the Railbelt region from
a mix of fossil fuel generation along with some renewables. Under this scenario, emissions
detailed in Table 5.4-2 would not be displaced, but rather generated within the Railbelt region to
meet the additional demand.
5.5. Identification of Best Management Practices
The following initial list of best management practices (BMPs) was developed, which, if
implemented, could limit air quality emissions during construction-related activities.
In general, emissions from engine exhaust from construction equipment can be reduced by
minimizing idle times for heavy-duty truck engines, installing emissions control devices to
reduce diesel exhaust, and using ultra-low sulfur diesel (ULSD) or biodiesel (EPA 2006).
In addition to construction equipment BMPs, other BMPs could minimize or mitigate fugitive
dust emissions during construction activities (EPA 1999):
• Irrigation: Applying water to surface areas
• Calcium chloride: Applying chemicals or palliatives to surfaces
• Tillage: Roughening the soil and bringing clods to the surface before wind erosion starts
• Vegetative coverings: Temporary seeding and mulching bare soil to prevent wind erosion
• Barriers: Using solid board fences, snow fences, burlap fences, crate walls, bales of hay,
and similar material to control air currents and blown soil
• Adhesives: Using spray-on adhesives to form an impenetrable surface (used if other
methods prove to be difficult to work with)
The Alaska Department of Transportation and Public Facilities (DOT&PF) and the Alaska
University Transportation Center are conducting research studies to evaluate which dust
treatment practices work best for unpaved roads and runways, including the use of dust
palliatives. Dust palliatives are substances applied to the road surface to reduce airborne dust and
can include water, water absorbing products, petroleum and non-petroleum based products, and
polymer products. This study program is testing different dust reduction palliatives to compare
their effectiveness. Information from these studies will provide additional guidance on BMPs for
dust mitigation in the near future.
6. DISCUSSION
The air quality study has met the study objectives for 2013. Baseline information on air quality
and meteorology was compiled to document existing conditions. Baseline Railbelt power
generation emissions were documented. Potential Project emissions were identified and power
generation emissions in the With-Project and Without-Project scenarios were compared. BMPs
for reducing emissions during construction and operations were identified.
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Much of the information needed to complete this study is in the process of being developed
through other licensing studies, including the Geology and Soils Characterization (Study 4.5),
Transportation Resources (Study 15.7), as well as Project engineering investigations. As these
other studies and investigations are completed, the information developed in this report will be
refined and updated.
7. COMPLETING THE STUDY
[Section 7 appears in the Part C section of this ISR.]
8. LITERATURE CITED
AEA (Alaska Energy Authority). 2012a. Revised Study Plan: Susitna-Watana Hydroelectric
Project FERC Project No. 14241. December 2012. Prepared for the Federal Energy
Regulatory Commission by the Alaska Energy Authority, Anchorage, Alaska.
http://www.susitna-watanahydro.org/study-plan.
AEA. 2012b. Alaska Energy Statistics, 1960–2011 Preliminary Report. Ginny Fay, Alejandra
Villalobos Meléndez, and Corinna West. Institute of Social and Economic Research.
University of Alaska Anchorage.
ADEC (Alaska Department of Environmental Conservation). 2012. Point Source Emission
Inventory.
http://dec.alaska.gov/Applications/Air/airtoolsweb/AirPointSourceEmission/EmissionInv
entory.aspx
EPA (U.S. Environmental Protection Agency). 1999. Stormwater Management Fact Sheet, Dust
Control. EPA-832-F-99-003, September 1999.
EPA. 2006. Reducing Emissions from Construction Equipment. EPA-901-F-05-022. January
2006.
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9. TABLES
Table 5.5-1. Available Regional Climate Summaries Representative of the Project Site
Station January February March April May June July August September October November December Annual1
Talkeetna (2003-2013) Automated
Average Min Temperature (°F) 1.93 10.27 9.58 24.40 35.67 51.90 57.43 54.27 44.74 26.14 8.89 7.30 27.71
Average Max Temperature (°F) 18.43 27.76 31.30 46.13 58.82 75.08 75.54 71.93 64.74 41.91 23.86 22.91 46.53
Average Precipitation (inches) 1.16 0.64 0.38 0.64 0.85 0.95 2.29 3.58 3.21 1.80 0.65 1.37 17.51
Gulkana (2002-2013) Automated
Average Min Temperature (°F) -8.17 -2.76 -2.74 20.23 34.39 42.27 46.57 42.48 29.57 17.55 -3.25 -9.01 17.26
Average Max Temperature (°F) 6.42 18.52 26.62 44.12 59.33 67.67 68.42 65.29 50.50 33.68 11.35 5.74 38.14
Average Precipitation (Inches) 0.68 0.47 0.41 0.24 0.52 0.96 1.59 1.25 1.00 0.50 0.60 0.62 8.85
Denali Park Headquarters (1923-2003) Automated
Average Min Temperature (°F) -5.63 -3.22 1.16 12.37 29.71 38.82 42.85 39.26 30.79 12.25 1.30 -4.42 16.27
Average Max Temperature (°F) 7.65 11.51 18.00 29.16 52.19 62.45 65.52 60.61 50.22 25.90 13.34 7.94 33.71
Average Precipitation (Inches) 0.55 0.45 0.33 0.37 0.78 2.17 2.90 2.54 1.56 0.80 0.49 0.56 13.50
Palmer (2005-2013) Automated
Average Min Temperature (°F) 4.38 12.10 15.03 28.09 38.06 46.84 50.44 48.66 41.35 29.11 12.40 10.38 28.07
Average Max Temperature (°F) 18.34 27.28 32.39 45.83 58.93 64.46 66.44 64.66 56.13 42.78 25.95 24.31 43.96
Average Precipitation (Inches) 0.46 0.52 0.13 0.20 0.39 0.60 1.06 0.93 0.97 0.47 0.38 0.37 6.49
Big Delta (1945-2013) FAA ASOS
Average Min Temperature (°F) -10.43 -5.86 1.90 20.89 37.28 48.18 51.35 46.59 36.04 18.94 -0.21 -8.22 19.70
Average Max Temperature (°F) 4.26 12.26 24.87 41.40 58.05 68.00 70.38 65.82 53.84 33.06 14.42 6.72 37.76
Average Precipitation (Inches) 0.36 0.29 0.24 0.29 0.87 2.17 2.63 1.75 1.24 0.65 0.47 0.44 11.39
Note:
1 Annual Precipitation is the sum of the monthly averages.
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Table 5.5-2. National Ambient Air Quality Standards
Pollutant Averaging Time Primary Standards1,2 Secondary Standards1,3 ADEC Ambient Air Quality Standards
CO 8-hour 9 ppm (10 mg/m3) None 10 mg/m3
1-hour 35 ppm (40 mg/m3) None 40 mg/m3
Lead4 Rolling 3-Month Average5 0.15 µg/m3 Same as Primary 0.15 µg/m3
NO2 Annual Arithmetic Mean 0.053 ppm (100 µg/m3) Same as Primary 100 µg/m3
1-hour 0.100 ppm (188 µg/m3)6 None 188 µg/m3[6]
PM10 Annual Arithmetic Mean None None None
24-hour 150 µg/m3 Same as Primary 150 µg/m3
PM2.5 Annual Arithmetic Mean 12 µg/m3[8] 15 µg/m3 15 µg/m3[9]
24-hour 35 µg/m3 Same as Primary 35 µg/m3
O3 8-hour (2008 standard) 0.075 ppm Same as Primary 0.075 ppm
8-hour (1997 standard) 0.08 ppm Same as Primary None
SO2
1-hour 75 ppb (196 µg/m3)7 None 196 µg/m3[7]
3-hour None 0.5 ppm (1,300 µg/m3) 1,300 µg/m3
24-hour None None 365 µg/m3[10]
Annual None None 80 µg/m3[11]
Ammonia 8-Hour N/A N/A 2.1 mg/m3[12]
Reduced Sulfur Compounds 30-Minute N/A N/A 50 µg/m3[13]
Notes:
1 National standards (other than ozone, particulate matter, and those based on annual averages) are not to be
exceeded more than once per year. The ozone standard is attained when the fourth highest 8-hour concentration
in a year, averaged over three years, is equal to or is less than the standard. For PM10, the 24-hour standard is
attained when the expected number of days per calendar year with a 24-hour average concentration above 150
µg/m3 is equal to or is less than one. For PM2.5 the 24-hour standard is attained when 98% of the daily
concentrations, averaged over three years, are equal to or are less than the standard.
2 Primary Standards: Levels necessary to protect public health with an adequate margin of safety.
3 Secondary Standards: Levels necessary to protect the public from any known or anticipated adverse effects.
4 Lead is categorized as a “toxic air contaminant” with no threshold exposure level for adverse health effects
determined.
5 National lead standard, rolling three-month average: final rule signed October 15, 2008.
6 To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each
monitor within an area must not exceed 0.100 ppm (effective January 22, 2010).
7 Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the daily
maximum 1-hour average at each monitor within an area must not exceed 75 ppb.
8 EPA updated the NAAQS for PM2.5 to strengthen the primary annual standard to 12 µg/m3.
9 An annual arithmetic mean concentration of 15.0 µg/m3, with this standard being attained when the three-year
average of the annual arithmetic mean concentration is less than or equal to 15.0 µg/m3.
10 The 24-hour average of 365 µg/m3 not to be exceeded more than once each year.
11 Annual mean not to be exceeded.
12 To attain this standard, the 8-hour average of 2.1 mg/m3, averaged over any consecutive eight hours not to be
exceeded more than once each year.
13 For reduced sulfur compounds, expressed as sulfur dioxide: 30-minute average of 50 µg/m3 not to be exceeded
more than once each year.
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Table 5.1-3. Observed Ambient Air Quality Concentrations – Denali National Park and MSB Ambient Monitors
Pollutant Location Averaging Period 2010 2011 2012 Background Level NAAQS
Ozone1 Wasilla 8-Hour None 0.049 ppm 0.048 ppm 0.049 ppm 0.075 ppm
PM102 Palmer 24-Hour None 174 ppb 121 ppb 174 µg/ m3 150 µg/ m3
PM2.51,3 Wasilla 24-Hour 12 µg/ m3 15 µg/ m3 23 µg/ m3 23 µg/ m3 35 µg/ m3
Annual 3.1 µg/ m3 6.4 µg/ m3 5.8 µg/ m3 6.4 µg/ m3 12 µg/ m3
Ozone4 Denali
National Park 8-Hour 0.053 ppm 0.052 ppm Not Available 0.053 ppm 0.075 ppm
Notes:
1 Represents the ADEC 100 West Swanson Ave Monitoring Location.
2 Represents the ADEC South Gulkana Street Monitoring Location.
3 Represents the ADEC 100 West Swanson Ave for 2010.
4 Represents the Denali National Park Headquarters Monitoring Station.
Table 5.1-4. Observed Ambient Air Quality Concentrations from Anchorage Ambient Monitors
Pollutant Location
Averaging
Period 2010 2011 2012
Background
Level NAAQS
Lead1 Anchorage 3-Month None 0.106 µg/m3 0.111 µg/m3 0.111 µg/m3 0.15 µg/m3
CO2 Anchorage 1-Hour 8.1 ppm 6.4 ppm 7.4 ppm 8.1 ppm 35 ppm
8-Hour 6.1 ppm 4.2 ppm 5.5 ppm 6.1 ppm 9 ppm
Ozone3 Anchorage 8-Hour 0.042 ppm 0.047 ppm 0.046 ppm 0.047 ppm7 0.075 ppm
PM104 Anchorage 24-Hour 80 µg/m3 117 µg/m3 115 µg/m3 117 µg/m3 150 µg/m3
PM2.52 Anchorage 24-Hour 23.0 µg/m3 17.0 µg/m3 28.0 µg/m3 28.0 µg/m3 35 µg/m3
Annual 6.2 µg/m3 5.3 µg/m3 6.6 µg/m3 6.6 µg/m3 12 µg/m3
Notes:
1 Represents the ADEC Merrill Field Drive Monitoring Station.
2 Represents the ADEC 3201 Turnagain Street Monitoring Station.
3 Represents the ADEC 3000 East 16th Avenue Monitoring Station.
4 Represents ADEC 3335 E. Tudor Road Monitoring Station.
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Table 5.1-5. Observed Ambient Air Quality Concentrations from Fairbanks Ambient Monitors
Pollutant Location Averaging Period 2010 2011 2012 Background Level NAAQS
SO21 Fairbanks 1-Hour None 44 ppb 51 ppb 51 ppb 75 ppb
24-Hour None 29 ppb 32 ppb 32 ppb 365 ppb
CO2 Fairbanks 1-Hour 6.4 ppm 5.4 ppm 6.7 ppm 6.7 ppm 35 ppm
8-Hour 4.1 ppm 4.3 ppm 3.6 ppm 4.3 ppm 9 ppm
Ozone1 Fairbanks 8-Hour None 0.035 ppm 0.048 ppm 0.048 ppm 0.075 ppm
PM101 Fairbanks 24-Hour None 52 µg/ m3 83 µg/ m3 83 µg/ m3 150 µg/ m3
PM2.53 Fairbanks 24-Hour 52.0 µg/ m3 38.0 µg/ m3 50.0 µg/ m3 52.0 µg/ m3 35 µg/ m3
Annual 13.0 µg/ m3 10.7 µg/ m3 10.8 µg/ m3 13.0 µg/ m3 12 µg/ m3
Notes:
1 Represents the ADEC 809 Pioneer Road Monitoring Station.
2 Represents the ADEC Federal Building/2nd & Cushman Monitoring Station.
3 Represents the ADEC 675 7th Street Monitoring Station.
Table 5.1-6. Worst Observed Ambient Air Quality Concentrations
Pollutant Location Averaging Period Worst Background Levels 2010-2012 NAAQS
SO21 Fairbanks 1-Hour 51 ppb 75 ppb
24-Hour 32 ppb 365 ppb
CO2 Anchorage 1-Hour 8.1 ppm 35 ppm
8-Hour 6.1 ppm 9 ppm
Ozone3 Wasilla 8-Hour 0.049 ppm 0.075 ppm
PM104 Palmer 24-Hour 174 µg/m3 150 µg/m3
PM2.55 Fairbanks 24-Hour 52.0 µg/m3 35 µg/m3
Annual 13.0 µg/m3 12 µg/m3
Lead6 Anchorage 3-Month 0.111 µg/m3 0.15 µg/m3
Notes:
1 Represents the ADEC 809 Pioneer Road Monitoring Station.
2 Represents the ADEC 3201 Turnagain Street Monitoring Station.
3 Represents the ADEC 100 West Swanson Ave Monitoring Location
4 Represents the ADEC South Gulkana Street Monitoring Location
5 Represents the ADEC 675 7th Street Monitoring Station.
6 Represents the ADEC Merrill Field Drive Monitoring Station.
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Table 5.3-1. Railbelt Energy Region Net Generation Summary1
Energy Region Oil (MWh) Gas (MWh) Coal (MWh) Hydroelectric (MWh) Wind (MWh) Total (MWh)
Railbelt 561,271 3,730,696 387,160 394,831 1,549 5,075,507
Percent of
Railbelt Region 11% 74% 8% 8% <1% 100%2
Total Alaska
Energy Regions 1,023,521 3,785,927 387,160 1,331,640 21,382 6,549,640
Railbelt Percent
of Total Alaska
Regions
55% 99% 100% 30% 7% 77%
Notes:
1 Net Generation data obtained from Alaska Energy Statistics (AEA 2012b)
2 Total does not sum due to rounding error.
Table 5.3-2. Railbelt Electric Generation Emission Summary by Utility
Utility CO
(TPY)1
NOx
(TPY)1
PM10
(TPY)1
PM2.5
(TPY)1
SO2
(TPY)1
VOC
(TPY)1
CO2
(TPY)2
CEA 941.5 3,606 99.6 n/a 26.5 29.4 1,492,161
GVEA 335.9 1,289.7 218.7 218.7 895.79 6.2 647,191
ML&P 446.9 1,897.6 41.3 41.3 0.43 13.3 698,302
HEA 2 455 12 6 4 213,863
Aurora
Energy, LLC
458.8 792.6 83.3 7.8 838.5 2.7 381,005
MEA n/a n/a n/a n/a n/a n/a n/a
Seward
Electric
n/a n/a n/a n/a n/a n/a n/a
Total 2,185 8,041 455 268 1,767 56 3,432,522
Notes:
1 2011 emissions were obtained from ADEC website.
2 CO2 emissions were obtained from Alaska Energy Statistics (AEA 2012b).
3 N/A denotes no emissions.
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Table 5.4-3. Estimated 2011 Power Generation Emission Rate1 in Railbelt Region
Utility CO (lb-MWh)1 NOx (lb-MWh)1 PM10 (lb-MWh)1 PM2.5 (lb-MWh)1 SO2 (lb-MWh)1 VOC (lb-MWh)1 CO2 (lb-MWh)1
Railbelt
Emissions
(lb/MWh)
0.86 3.17 0.18 0.11 0.70 0.02 1,352.58
Notes:
1 Emissions were derived from total emission per pollutant divided by the total MWh produced for the Railbelt in
2011.
Table 5.4-2. Estimated Emission Displacement for the Project based on 2011 Net Generation and Emission Data
Utility CO (TPY)1 NOx (TPY)1 PM10 (TPY)1 PM2.5 (TPY)1 SO2 (TPY)1 VOC (TPY)1 CO2 (TPY)1
Potential
Emission
Offsets with
Project
(lb/MWh)
1,205 4,436 251 148 975 31 1,893,616
Percent
Reduction
from 2011
Railbelt
Emissions
-55% -55% -55% -55% -55% -55% -55%
Notes:
1 Emissions were derived from Railbelt emissions (lb/MWh) and estimated Project generation of 2,800,000
MWh.
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10. FIGURES
Figure 5.1-1. Alaska Climate Zones
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Figure 5.1-2. Weather Station Data Locations Representative of the Project Site
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Figure 5.1-3. Alaska Non-Attainment and Maintenance Areas Relative to Project Site
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Figure 5.1-4. ADEC and National Park Service Air Monitoring Locations
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Figure 5.3-5. Alaska Energy Regions
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Figure 5.3-2. Railbelt Power Generation in 2011 by Fuel Type