ELK HILL REGIONAL INDUSTRIAL PARK CLAY COUNTY

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ELK HILL REGIONAL INDUSTRIAL PARK CLAY COUNTY ENERGY PROJECT SITE SUITABILITY 2009 Department of Energy Development and Independence Energy and Environment Cabinet Commonwealth of Kentucky

FOREWORD The Manchester-Clay County Chamber of Commerce and County Government submitted this site for evaluation for potential development as an alternative energy facility. The site was evaluated against preliminary criteria which identifies characteristics beneficial for development of a wind, solar, biomass, nuclear, or coal-to liquid (CTL) / coal-to-gas (CTG) facility. This site benefits from its available acreage, location within the Eastern Kentucky Coal Fields, and location within an industrial park created from a mountain top removal mine site. Geological assets for the site also rank well for potential carbon sequestration. Cover photo (2006) - Proposed development site

The Manchester-Clay County Chamber of Commerce and County Government offers available acreage at the Elk Hill Regional Park (also referred to as the Clay County Industrial Park) for evaluation as a potential energy facility. The development of an energy facility, whether for CTL/CTG, wind, nuclear, solar or biomass, must consider basic common factors which include assets like access to transportation, general topography, proximity to public access areas, and available utilities. GENERAL SITE CONSIDERATIONS Ownership The site property is owned in fee by the Elk Hill Regional Industrial Authority. Aerial photograph of the site Page 1

Size The available site area is 1,000 acres. The site is located five miles east of Manchester in Clay County and sits south of the Hal Roger Parkway, north of US 421, and east of KY 149. The Elk Hill Regional Industrial Park was a former mountain top removal mine site, and has been redeveloped for industrial use. A former veneer plant is currently an out-parcel of the available acreage, but could be obtained if needed. The site is removed from residential areas by its elevation and location and there are no nearby residential areas. Adjoining properties include mine sites and undeveloped land. Adjacent out-parcel Topography The site elevation depicted on a United States Geological Survey (USGS) topographic map is between 1,400 and 1,800 above mean sea level (AMSL); however, due to the recent mining, the current elevations are relatively flat with large areas prepared for development. Site development should take into consideration those areas which are Page 2

filled in determining appropriate foundation design. The site is configured in two large flat areas with a ravine between the areas. Currently the road access between the two areas is by gravel road. Portions of development site Floodplain and Wetlands The site was evaluated for impact to floodplains and wetlands. Based on the US Fish and Wildlife s digital wetlands data, no wetland areas have been identified at the site. The site is not identified as within floodplain areas on the Flood Insurance mapping for the area. Site observations confirm the site is on a ridge top with no depressions or low areas noted. Site Hazards Environmental databases were reviewed to determine if there was regulatory evidence of an environmental impact at the site or a nearby property. Based upon a review of a 2006 FirstSearch Technology Corporation Environmental Database Report, the site was not listed in any of the environmental databases searched, nor were there any listed Page 3

facilities within the search radius. Site observations did not identify any obvious evidence of environmental impact. A former veneer plant was observed within the industrial park, but detailed information regarding this facility was not obtained. Oil and Gas Wells Data maintained by the Kentucky Geologic Survey (KGS) and site observations indicate that there are two or more gas wells and one or more 'incomplete' and/or 'other' wells located on the site. The locations of any wells should be determined to evaluate whether wells or gathering lines must be closed or relocated for the development of an energy facility. Sensitive Areas The proximity of non-attainment areas and Class I Visibility Areas to the site was examined for potential impacts to air quality or limitations on a required air permit for a CTL/CTG or biomass facility. This site benefits by being located more than fifty miles from the nearest air pollution non-attainment area, Ashland, KY Huntington, WV. The site also benefits from being greater than 130 miles east of Mammoth Cave, the closest Class I Visibility Area. State water data was searched to determine if designated impaired streams in the area might affect discharge requirements for an energy facility. The site location is approximately 15 miles south of the confluence of Red Bird River and the South Fork of the Kentucky River. The local watershed is the Red Bird River Watershed and the HUC 11 is 05100203010. Stream Use Designations for the South Fork of the Kentucky River (mile point 30) are warm water aquatic habitat, primary contact recreation, secondary contact recreation, and domestic water supply. Site drainage flows north into Hayes Fork and south into Lynn Log Fork. Hayes Fork flows into Hector Creek that flows to the Red Bird River. Lynn Log Fork flows into Elk Creek, which flows into the Red Bird River. None of the creeks for immediate discharge are identified as impaired. Page 4

Siting considerations for any energy facility include the presence of Threatened and Endangered (T&E) species in the area, the presence of significant cultural or historical resources in and around the project area, and proximity to public access areas and airports. Federal and state listings of T&E species were reviewed to determine if there is any documented evidence that a sensitive species has occurred on the USGS Ogle, Kentucky topographic quadrangle. No federally listed species are listed as present on the Ogle quadrangle. State listed species include the northern Breek Lamprey. Based on the site s history as a mine site, it is unlikely that critical habitat occurs on the property; however, a thorough survey should be conducted prior to development. Site development area Based on reference to National Register Properties, National Register Districts, and Inventoried (potentially eligible) Sites, no previously recorded eligible or potentially eligible properties were identified at or within 100 meters of the project area. Additionally, the disturbance associated with mountain top removal mining methods indicates that it is unlikely that undisturbed cultural or archaeological areas remain. Page 5

Distance from public access areas and airports is critical for successful CTL/CTG or alternative energy sites to minimize environmental impact, hazards to air traffic, and to mitigate potential risks and costs associated with development. The site is located within the Daniel Boone National Forest. The Beech Creek Wildlife Management Area is located 2-3 mile to the north of the site and the Redbird Wildlife Management Area is located about 7 miles to the east of the site. No commercial airfields are located within 10 miles of the site. However, Sky Airport is mapped approximately 3 miles west of the site. Site contacts have reported that this is a grass landing strip that is not in service. The use of this field should be confirmed to ensure that hazards to small aviation from the processes and equipment at an alternative energy facility are addressed. Geological Assets Siting considerations for a biomass or CTG/CTL process must take into account available geological assets for potential sequestration. Analysis by the KGS ranked the geologic assets of the proposed site as good. Both deep and shallow oil fields appear in the vicinity, and target formations with the potential for sequestration are also located near the site. The graphic on the following page was prepared by the KGS to illustrate some of the geologic assets at the site, which is identified as L on the map. The proximity of faults to a site may impact the development of a nuclear, biomass, or CTL/CTG facility. According to information obtained from KGS (Seismic Risk Map of Kentucky), the site has low seismic risk. There are no reported faults within ten miles of the proposed site. The closest identified faults are the White Mountain Fault System, located 14 miles southwest of the site, and the Pine Mountain Fault, located 21 miles southeast of the site (KGS Petroleum Geology Map). Page 6

Utilities The site benefits because of its existing infrastructure. Broadband access to the internet by fiber optic cable was taken into consideration during the initial design and development of the industrial park. Additionally, potable water is available from the Page 7

Manchester system, as is sewage treatment. Natural gas is available from Wiser Gas by a 4 inch line, roads are adequate and electricity is provided by Jackson Energy by a 69 kv line. Site utilities are placed underground. Transportation Currently, site access is by US 421, a 2-lane paved road. An interchange with the Hal Rogers Parkway has been funded and road and right-of-way plans were due to Department of Highways Central Office in April and May 2007. Based upon information obtained from the Kentucky Transportation Cabinet in March 2009, construction has not been completed. The addition of the interchange with the Parkway will dramatically improve road access and make the site accessible from both sites of the industrial park. Interior roads within the site are asphalt in the section closest to US 421 and gravel in the section closest to the Parkway. Interior road at the site Although not a significant siting consideration for a solar, nuclear or wind facility, a biomass or CTG/CTL facility will require several transportation options due to the substantial feedstock required for these technologies. This site lacks rail or barge Page 8

availability, leaving truck transport as the only existing means of transport. The nearest rail line is located about 3 miles to the east. Although internal roads are present on site, these may need to be upgraded for coal or other material transport. Transmission Any energy facility will require access to electric transmission points. A 69kV line should be an adequate capacity to carry generated power from a solar facility in Kentucky. A nuclear, biomass, wind or CTL/CTG facility would require access to larger electric transmission points. The site is currently served by a 69 kv electrical supply line. The nearest 161 kv is reportedly 5 miles distant, with the nearest substation approximately 10 miles distant. Representatives of East Kentucky Power previously reported that a right-of-way may have to be obtained to bring high power lines to the site. That right-of-way would have to be routed through the Daniel Boone National Forest. Cost estimates for construction of lines capable of supporting 161 kv are in the range of $500,000 per mile, meaning one line would cost about $5,000,000. Natural gas is used as a feedstock and fuel in CTL/CTG and for some biomass facilities, making access to a supply important. Additionally, if the facility makes synthetic natural gas, access to a transmission pipeline will be important in getting products to market. The Clay County Industrial Park has an 8" inch gas transmission line adjacent to it. Currently, a 4" inch line extends into the park from the 8" line. According to the site sponsor, natural gas is one of the most abundant natural resources available to Clay County. The supply is so great that there is reportedly not enough room in the transmission lines to move the available gas out of the area to markets. Water Supply Available water supply is a critical project component for the development of a CTG/CTL, biomass or nuclear facility. The site is not reported to have an abundance of water available on site. The site receives water from the City of Manchester. A large Page 9

water tank (485,000 gallons) is on site. It has been reported that there may be large volumes of water in surface impoundments and abandoned underground mines in the area that could be captured and pumped to the site. Drought experienced during the summer of 1999 caused the city to seek water resources found in abandoned coal mines in the area. Following the summer of 1999, the KGS conducted a study of the abandoned Lee County No. 47 mine near Manchester. The KGS calculated available water resources for this one mine at 460 million gallons with a recharge rate of 210,000 gallons per day (gpd) or 145 gallons per minute (gpm). 485,000 gallon water tank located on site The site is located approximately 15 miles south of the confluence of the Red Bird River and the South Fork of the Kentucky River. Mean annual stream flow for the South Fork of the Kentucky River at mile point 30 is 300,267 gallons per minute (gpm) or 432 million gallons per day (MGD). The low-flow 7Q 2 is 2,873 gpm or 4.1 MGD and the lowflow 7Q 10 is 673 gpm or 1.0 MGD. The low-flow 7Q 10 is the lowest mean flow during seven consecutive days over a ten-year period. The low-flow 7Q 2 is the lowest mean Page 10

flow during seven consecutive days over a two year period. The nearest USGS gaging station is 19 miles downstream from Oneida, Kentucky at mile point 11.1 of the South Fork of the Kentucky River. The lowest mean annual flow recorded at station 03281500 is 185,367 gpm (267 MGD). No public water intakes are within 25 miles downstream of the site. Typically, a CTL/CTG or biomass facility requires a minimum of 2,500 gpm or 3.6 MGD for process or cooling water needs, and a nuclear facility requires a minimum of 8,000 gpm or 11.5 MGD for cooling water needs. Access to a water source adequate to supply the required volumes is not economically feasible at this time. Thus, based upon reported current available water supply at the site and that significant capital would be required to pipe water from the South Fork Kentucky River (> 10 miles distant) to the site, it does not appear that adequate amounts of water are readily available to support a CTL/CTG, biomass or nuclear facility at this location. Workforce Availability Development of a CTL/CTG, biomass, or nuclear facility would require access to an adequate supply of construction and skilled labor. According to the Kentucky Cabinet for Economic Development in 2008 the Clay County labor market includes ten counties with more than 95,000 potential workers. Page 11

Clay County labor market Source: www.thinkkentucky.com Civilian Labor Force Clay County Labor Market Area 2007 Oct. 2008 2007 Oct. 2008 Civilian Labor Force 7,021 6,876 99,515 98,588 Employed 6,261 6,206 92,324 91,409 Unemployed 760 670 7,191 7,179 Unemployment Rate %) 10.8 9.7 7.2 7.3 Source: U.S. Department of Labor, Bureau or Labor Statistics Other General Characteristics The proximity to military sites was reviewed in order to consider the potential impact of an energy facility to military training routes or long range radar. Based upon information produced by the Federal Aviation Administration s Department of Defense Screening Tool, an Air Defense and Homeland Security Radar, Weather Surveillance Radar or military operation is located within a 20 mile radius of the site. An aeronautical study would be required prior to development. Atmospheric extremes, such as tornadoes, are capable of structurally damaging a facility and must be considered particularly during siting for a solar, nuclear, or wind Page 12

facility. Based upon Federal Emergency Management Agency (FEMA) mapping, the site is at low risk for tornado activity. TECHNOLOGY SPECIFIC CONSIDERATIONS CTL/CTG In addition to the common factors described above for energy site development, unique factors specific to a particular technology must be considered. For a CTL/CTG facility, access to coal resources is important. Clay County is located within the Eastern Kentucky Coal Fields with numerous sources of coal available. However, there are certain assets which are not yet available or would need upgrading. The level of electrical power available to the site will need to be upgraded. Electrical service with at least a 161 kv line is needed both for operations and as a transmission point for the sale of excess power. Access to power at this level will require up to 10 miles of transmission line and potentially new right-of-way. Additionally, a comprehensive plan to obtain a steady and reliable source for water at the rate of 2,500 gpm will be necessary in order for the site to operate a water cooled CTL/CTG facility. Air cooled technology is a possibility, but requires more electrical service and is more expensive. The site relies solely on roads for transportation, making the connection with the Hal Rogers Parkway even more imperative. Solar Adequate solar radiation is critical to the successful generation of solar power. A successful site should be relatively free from land cover, and not within a mile of a corporate city boundary. The Elk Hill Regional Industrial Park has an average direct normal solar radiation of 3.5 KWh/m 2 /day and an annual average solar radiation for twoaxis flat plates of 5.84 KWh/m 2 /day. Based upon this average solar radiation, too much cloud cover and haze is present to be effective as a large scale facility. Due to current development of this site for industrial use, the site benefits from sizeable areas free of Page 13

trees or other land cover that could impact a solar facility. Solar installations in large mass can be a visual distraction to local communities. This site benefits from its location away from residential or urban areas. The site is approximately 5 miles east of Manchester, Kentucky. Solar insolation map Wind The most critical component for a successful wind facility is adequate and consistent wind speed. In order to generate enough power to be a utility class facility, a mean average wind speed at 60 meters of 5.6 meters per second (m/s) or greater is required. Information obtained from AWS Truewind, indicates that the average wind speed at 60 Page 14

Mean wind speed 4.33 m/s meters for the site is 4.33 m/s. Without adequate wind speed, other factors, such as foundational concerns, potential visual impacts, telecommunication interference, impacts to birds and bats, as well as operational concerns such as ice shedding, noise, blade drop and throw, and flicker are moot. Wind speed measurements to accurately assess the available resource at any potential development site would be required prior to final planning. Biomass An adequate feedstock supply environment includes available crop residues, animal manure, forest residues from former silviculture or clearing, primary and secondary mill residues, urban residues (i.e., wood scraps from local business such as lumberyards), landfill gas, domestic wastewater, or switchgrass. Information obtained from the Page 15

National Renewable Energy Laboratory indicates that the total biomass available within Clay County is 53,664 tonnes/year. Biomass in Clay and its surrounding Counties is 463,397 tonnes/year. Depending on the type of feedstock utilized, these supplies (<500,000 tonnes/year) may not provide adequate feedstock; further investigation would be required. Further investigation is also recommended to determine if a steady and reliable source for water at the rate of 2,500 gpm is present in order for the site to operate a water cooled biomass facility. Nuclear A limiting factor to the development of a nuclear facility is available water supply. A minimum of 8,000 gpm or 11.5 MGD of water is required to meet basic facility needs. As previously mentioned, a comprehensive plan to obtain a steady and reliable source for water at the rate of 8,000 gpm will be necessary in order for the site to operate a water cooled nuclear facility. Based upon reported current available water supply at the site and that significant capital would be required to pipe water from the South Fork of the Kentucky River to the site, it does not appear that adequate amounts of water are readily available to support a nuclear facility at this location. Without adequate water supply, other factors, such as safety issues, proximity to population centers and atmospheric conditions are moot. SUITABILITY In summary, the site, although located within the Eastern Kentucky Coal Fields in an industrial park with some established infrastructure and large acreage, is not well suited for a potential alternative energy facility at this time. The need for adequate water supply, limited transportation, location within the Daniel Boone National Forest, and absence of established high transmission lines provide potential site constraint. The site scored a total of 832 points, representing 69% of the total available points for a CTL/CTG facility, and a total of 820 points, representing 65% of the total available points for a biomass facility. Page 16

Although scoring a total of 539 points, representing 58% of the total available points for a solar facility, in order to have a cost effective concentrated solar panel (CSP) facility, a minimum of 6.75 kwh/m 2 /day is required; therefore, this site may have too much cloud cover and haze to be effective as a large scale utility facility. Sizeable, cleared areas on the property and distance from residential or urban communities make this site desirable for solar panel placement; however, it is recommended that a cost-benefit analysis be conducted prior to further investigate solar facility viability at this location. Due to a low average mean wind speed, this location is not a viable location for a utility scale wind facility. Similarly, a lack of demonstrated adequate and continuous water availability means this site is not a viable location for a nuclear facility at this time. Page 17

Kentucky Department for Energy Development and Independence http://www.energy.ky.gov/ 500 Metro Street 12 th Floor, Capital Plaza Tower Frankfort, KY 40601 (502) 564-7192 or (800) 282-0868 Smith Management Group www.smithmanage.com 1405 Mercer Road Lexington, KY 40511 (859) 213-8936 Clay County Government 102 Richmond Road, Suite 201 Manchester, KY 40962 (606) 598-2071