20170938 Ver 1_Appendix O - Air Quality Analysis Report_20170731

Appendix O
CSX CCX Intermodal Rail Terminal & Second Mainline
Edgecombe and Nash Counties, North Carolina
Project No. 643009004
APPENDIX O
AIR QUALITY ANALYSIS REPORT

Appendix O
CSX CCX Intermodal Rail Terminal & Second Mainline
Edgecombe and Nash Counties, North Carolina
Project No. 643009004
THIS PAGE INTENTIONALLY LEFT BLANK

Air Quality General Conformity Analysis
CCX Intermodal Terminal
Appendix O Air Quality Supporting Documentation
General Conformity Applicability Analysis
Carolina Connector Intermodal Terminal
A-1

Air Quality General Conformity Analysis CCX Intermodal Terminal
EXECUTIVE SUMMARY
CSX Intermodal Terminals, Inc. (CSXIT) is proposing to construct the Carolina Connector (CCX)
Intermodal Freight Terminal to provide intermodal service to business and industry within eastern
North Carolina. The proposed Carolina Connector project site is located on the CSXT A -Line
between Rocky Mount and Battleboro, North Carolina.
A general conformity analysis must be conducted if a federal action would result in the generation
of air emissions that would exceed the conformity threshold levels (de minimis) of the pollutants(s)
for which an air basin is nonattainment or maintenance. Because the project is located in a
maintenance area for the 1997 8 -hour ozone standard and is receiving federal permits, a general
conformity applicability analysis is required for the ozone precursors oxides of nitrogen (NOx) and
volatile organic compounds (VOC). A general conformity analysis must demonstrate that the
emissions from both construction and operation of the CCX would conform to the ozone State
Implementation Plan (SIP) for the Rocky Mount maintenance area.
A general conformity applicability evaluation was conducted for the CCX to determine if the total
NOx or VOC emissions generated by the construction or operation of the terminal would exceed
the annual de minimis levels specified in the General Conformity Rule. Because maximum air
emissions generated during the construction and operation of the CCX will occur during different
calendar years, emissions during each phase were evaluated separately.
Results of the general conformity applicability evaluation indicate that neither NOx nor VOC
emissions will exceed the annual de minimis levels specified in the General Conformity Rule
(100 tons per year of either pollutant) during either the construction or operation phase of the
CCX. Consequently, the Proposed Action will conform with the ozone SIP for the Rocky Mount
maintenance area; the CCX terminal will not trigger additional conformity requirements for NOx or
VOC. A Record of Non -Applicability (RONA) can be issued for the project.
1.0 DESCRIPTION OF PROPOSED ACTION
CSXIT is proposing to construct the CCX (Proposed Action) to provide intermodal service to
business and industry within eastern North Carolina. The proposed Carolina Connector project
site is located on the CSXT A -Line between Rocky Mount and Battleboro, North Carolina.
I_d'

Air Quality General Conformity Analysis CCX Intermodal Terminal
Containerized freight has revolutionized shipping, opening global markets and helping to keep
the price of manufactured goods low. At the CCX, containerized goods will arrive on trains or
trucks, will be sorted and transferred by electric gantry cranes to other trains or trucks, and then
shipped to their final destinations. The combination of rail and truck transportation combines the
superior fuel efficiency of trains and the door-to-door flexibility of trucks.
The CCX will be a state-of-the-art rail facility equipped with efficient, innovative, and
environmentally friendly technology including electric, quiet cranes and facilities constructed to
meet high standards for energy consumption. The facility is projected to initially handle
265,000 loads annually with a capacity of 400,000 loads annually. The project will create an
estimated $310 million in public benefits for North Carolina, including air emissions reductions,
reduction in overall truck traffic, and lowered highway maintenance.
The site development will consist of lead tracks allowing trains to safely access the CCX site from
the north and south, the intermodal terminal area, office buildings, roads, stormwater
management basins, and ancillary facilities with appropriate buffers from surrounding land uses.
The intermodal facility features numerous rail tracks to efficiently sort multiple trains, with internal
roads and container staging areas to allow well -organized truck access and loading.
2.0 AIR QUALITY STATUS OF PROJECT AREA
Common air pollutants that cause health, environmental, and property damage are emitted by
sources all over the United States. The U.S. Environmental Protection Agency (USEPA) calls
these pollutants "criteria air pollutants" because the agency has regulated them by developing
criteria (science -based guidelines) as the basis for setting permissible levels in the ambient air.
One set of limits (primary standard) protects human health; another set of limits (secondary
standard) protects human welfare by preventing environmental and property damage.
A geographic area that meets or does better than the primary National Ambient Air Quality
Standards (NAAQS) is called an attainment area; areas that do not meet the primary NAAQS are
called nonattainment areas. Areas that were originally designated as nonattainment but which
have improved their air quality sufficiently to have been redesignated to attainment are called
maintenance areas.

Air Quality General Conformity Analysis CCX Intermodal Terminal
The criteria air pollutants are: carbon monoxide (CO), ozone (Os), particulate matter (PM),
including PM less than 10 microns in diameter (PM,o) and PM less than 2.5 microns in diameter
(PM2.5), sulfur dioxide (SO2), NO, and lead (Pb). NOX and VOC are also regulated by USEPA as
ozone precursors. In addition to the federal NAAQS for criteria pollutants, the North Carolina
Department of Environmental Quality (NCDEQ) has adopted ambient air quality standards in the
North Carolina Administrative Code (NCAC) Title 15A Subchapter 2D Section 0400.
The Rocky Mount NAAQS evaluation area, which includes all of Nash and Edgecombe counties,
is designated as attainment for all criteria pollutants. However, prior to January 5, 2007, Nash
and Edgecombe counties were designated as nonattainment for the 1997 8 -hour ozone standard
of 0.08 parts per million (ppm). As a result, Nash and Edgecombe counties are currently
designated as a maintenance area for the 1997 ozone standard. This designation, valid until
2027, requires additional scrutiny of potential air quality impacts.
3.0 GENERAL CONFORMITY BACKGROUND
The 1990 Clean Air Act (CAA) Amendments include the provision of general conformity, which is
intended to ensure that federal actions conform to a nonattainment or maintenance area's SIP.
The General Conformity Rule is codified in 40 CFR 51, Subpart W and 40 CFR 93, Subpart B,
Determining Conformity of General Federal Actions to State or Federal Implementation Plans
("General Conformity Rule"). NCDEQ's general conformity rules, codified in NCAC Title 15A
Subchapter 2D Section 1600, expired on February 1, 2016; therefore, the federal General
Conformity Rule is the only applicable regulation.
The General Conformity Rule regulates air pollutant emissions associated with actions that are
federally funded, licensed, permitted, or approved, and ensures emissions do not adversely
impact a nonattainment or maintenance area's progress toward attaining or maintaining the
NAAQS. In short, general conformity, if applicable, refers to the process to evaluate plans,
programs, and projects to determine and demonstrate that they satisfy the requirements of the
Clean Air Act and applicable SIP. Under general conformity, emissions associated with the
construction and operation of the CCX must be evaluated for applicability.
The process to determine conformity for a proposed action involves two steps: applicability and
determination. Applicability is an assessment of whether a proposed action is subject to the

Air Quality General Conformity Analysis CCX Intermodal Terminal
General Conformity Rule. During a general conformity applicability assessment, air emissions
are evaluated on an annual (i.e., calendar year) basis. If the emissions associated with the project
exceed the applicability thresholds for North Carolina under the General Conformity Rule, a
General Conformity Determination would be required for the project. If the emissions associated
with the project are less than the applicability thresholds, the project is said to conform to the
North Carolina SIP.
4.0 GENERAL CONFORMITY APPLICABILITY ASSESSMENT
Although the air quality assessment for the CCX included all criteria pollutants, because Nash
and Edgecombe counties are currently designated as a maintenance area for the 1997 8 -hour
ozone standard, a general conformity applicability assessment is only required for the ozone
precursors NOx and VOC. The applicability assessment was conducted for both the construction
phase and operational phase of the CCX to determine if the total NOx or VOC emissions from
either phase of the project would exceed the annual de minimis levels specified in 40 CFR
93.153(b)(1), 100 tpy of either pollutant.
Sources evaluated for conformity can be classified into two general types of emission sources:
nonroad sources (most construction equipment; locomotives) and onroad sources (onroad cars
and trucks). Emissions factors for both nonroad and onroad equipment were developed using
USEPA's MOVES2014a model (USEPA, 2014). MOVES2014a provides emission factors for CO,
NOx, PM,o, PM2.5, SO2, VOC, and greenhouse gases in grams per vehicle mile travelled for
various vehicle types, vehicle model years, and travel speeds.
Area -specific inputs for the MOVES2014a model were obtained from NCDEQ. This information
included local meteorological inputs, 2016 vehicle type distribution, and 2018 Inspection and
Maintenance (I/M) program data for Edgecombe County. As no data for local fuel parameters
were provided, national default fuel data were used. Other assumptions, including the trip length
and the number of trips per year, are detailed in the sections below. The following model years,
based on weighted averages of the model year population data and speeds, were used to select
the vehicle emission factors from the MOVES2014a output:
Passenger car: 2007 model year, 45 miles per hour and rural restricted road types
Passenger truck, 2004 model year, 45 miles per hour and rural restricted road types

Air Quality General Conformity Analysis
CCX Intermodal Terminal
Single unit short haul truck (asphalt and gravel trucks), 2005 model year, 45 miles per
hour and rural restricted road types
Single unit short haul truck (onsite water truck), 2005 model year, 15 miles per hour and
rural restricted road types
Combination long haul truck, 2006 model year and 45 miles per hour for 10% of the time
on rural restricted roadways and 55 miles per hour for 90% of the time on rural
unrestricted roadways
Following is a discussion of the sources of emissions factors, activity levels, load data, and
assumptions used to calculate emissions for this analysis. Detailed emissions calculations are
provided at the conclusion of this appendix.
4.1 Construction Phase Air Emissions
Construction of the CCX, which has a footprint of approximately 400 acres, is expected to take
approximately 65 weeks. Construction emissions from year one were assumed to begin on
January 1 and proceed through December 31 as a worst case estimate.
Construction -phase air emissions quantified in this applicability assessment included:
Fuel combustion emissions from the operation of nonroad construction equipment (e.g.,
off road dump trucks, drum rollers, soil compactors, farm tractors, excavators, bulldozers,
graders, loaders, backhoes, forklifts, hostler trucks, asphalt pavers, and asphalt
compactors) on-site
Fuel combustion emissions from the operation of onroad construction equipment (e.g.,
asphalt and gravel dump trucks, water trucks) to and from the site
Fuel combustion emissions from the operation of personal vehicles to transport
construction workers to and from the site
Volatile organic compound emissions from asphalt paving operations
4.1.1 Construction Phase Nonroad Emissions Calculations
Nonroad sources associated with construction include off road dump trucks, drum rollers, soil
compactors, farm tractors, excavators, bulldozers, graders, loaders, backhoes, forklifts, hostler
M.

Air Quality General Conformity Analysis
CCX Intermodal Terminal
trucks, asphalt pavers, and asphalt compactors. Emission factors for nonroad construction
equipment were calculated using MOVES2014a. The anticipated equipment types, including
engine tier classifications and engine ratings, were based on equipment planned for the project.
All nonroad equipment will be diesel -fired and all of the construction was assumed to take place
during calendar year 2018.
MOVES2014a was run for a single hour in January and a single hour in July to obtain winter and
summer emission factors in grams per horsepower -hour (g/hp-hr). Load factors for each piece of
equipment were also obtained from MOVES2014a. The worst case emission factor between the
winter and summer hours was used as a conservative estimate. Calculation assumptions for the
various nonroad construction equipment are outlined in Table A-1.
Table A-1. Calculation Assumptions for Construction Phase Nonroad Sources
Emissions Vehicle
®Calculation Methodology
Group Type &Nonroad Rating Equipment hp rating based on specific vehicles quoted from potential
Construction All (h p) grading contractor, when available. When unavailable, hp based off
Table 2-04 of EPA -21A-2001 documentation.
Average engine life, in hours, was estimated from PSR Table 1, based
on engine size, in hp. Engine life was divided by typical hours of
Nonroad operation per year, based on NONROAD2008a SCCs, to define engine
Construction All Tier life in years. Engine life in years was divided by 2 to determine the
average age of the equipment. Estimated age was compared to
40 CFR 89 to assign Tier.
4.1.2 Construction Phase Onroad Emissions Calculations
Onroad sources associated with construction include onroad travel for construction vehicles (e.g.,
asphalt and gravel dump trucks, water trucks) and employee commuter vehicles. Travel for the
asphalt dump trucks will be from a local asphalt plant to the project site, while travel for the gravel
Equipment number based on quote from potential grading
Nonroad
All Number
contractor. Equipment for asphalt paving based on subjective
Construction
estimation of typical asphalt operation.
Equipment type was matched to associated NONROAD2008a SCC
Nonroad
Hours
code. Typical yearly hours of operation for the SCC vehicle was
All
Construction
per Day
divided by 52 weeks per year and 5 days per week to achieve
estimated operation in hours per day.
Nonroad
Days per
All equipment estimated to be in operation 5 days per week for 52
All
Construction
Year
weeks.
Average engine life, in hours, was estimated from PSR Table 1, based
on engine size, in hp. Engine life was divided by typical hours of
Nonroad operation per year, based on NONROAD2008a SCCs, to define engine
Construction All Tier life in years. Engine life in years was divided by 2 to determine the
average age of the equipment. Estimated age was compared to
40 CFR 89 to assign Tier.
4.1.2 Construction Phase Onroad Emissions Calculations
Onroad sources associated with construction include onroad travel for construction vehicles (e.g.,
asphalt and gravel dump trucks, water trucks) and employee commuter vehicles. Travel for the
asphalt dump trucks will be from a local asphalt plant to the project site, while travel for the gravel

Air Quality General Conformity Analysis
CCX Intermodal Terminal
dump trucks will be from a local quarry to the project site. The water truck will be used to water
roadways and storage piles to minimize fugitive dust during construction. Emissions factors for
onroad equipment were based on the averaged summer and winter emission factors for each
vehicle type. Employee vehicles were assumed to be a 50/50 split of passenger cars and pickup
trucks, and construction vehicles were assumed to be single unit short -haul trucks. Emission
factors were broken down by vehicle type, season, model year, and vehicle speed. For this
analysis, employee vehicle speeds of 45 miles per hour and construction truck speeds of 15 miles
per hour were used to conservatively reflect these emissions. Additional calculation assumptions
for the construction -phase onroad sources are outlined in Table A-2.
Table A-2. Calculation Assumptions for Construction Phase Onroad Sources
Onroad Asphalt and Trips per
Construction GravelDayDay
Onroad
Construction
Onroad
Construction
Onroad
Construction
Onroad
Construction
Employee
Trips per
Vehicles
Day
Water
Trips per
Truck
Day
All
Trips per
Year
Asphalt and
Gravel
Trip
Length
Trucks
Onroad Employee
Construction Vehicles
Onroad Water
Construction Truck
Trip
Length
Trip
Length
Total volume of material (i.e., asphalt or gravel) estimated for the site
was divided by volume per truck (324 cu ft), based on typical dump
truck, to estimate total truckloads. The total number of truckloads
was divided by 60 days of paving operation, assuming 2 round trips
per truck per day, to estimate equipment count. Equipment count
was multiplied by 4 one-way trips to achieve trips per day.
250 workers each commuting a single round-trip per day to site,
5 days per week for 52 weeks.
Assumes a single trip per day, 5 days per week for 52 weeks.
Trips per day were multiplied by 52 weeks per year and 5 days per
week to achieve trips per year.
Known asphalt manufacturer is located 5 miles from site. Similarly,
known gravel quarry is 5 miles from site. Assumes each one-way trip
is 5 miles.
Estimated that 80% of staff reside within Nash and Edgecombe
counties, commuting an average of 10 miles to site. The remaining
20% of employees reside outside of Nash and Edgecombe counties,
commuting an average of 20 miles to the site. The average trip
length was calculated as: trip length=(0.8*10)+(0.2*20).
5 mile estimation for water truck onroad dust suppression near site.
4.1.2 Asphalt Paving Emissions Calculations
VOC emissions will result from asphalt paving of a portion of the terminal. VOC emissions form
asphalt paving were calculated based on information contained in the Resignation Demonstration
and Maintenance Plan for the Rocky Mount, North Carolina 8 -Hour Ozone Nonattainment Area
an

Air Quality General Conformity Analysis
CCX Intermodal Terminal
(North Carolina Department of Environment and Natural Resources, Division of Air Quality,
June 19, 2006) and the North Carolina Department of Transportation for asphalt specifications
(Application Rates and Weights for Estimating Purposes Table). As a conservative estimate, the
seasonal adjustment factor for warmer weather used in Appendix C.2 of the Rocky Mount Ozone
Maintenance Plan was used as a worst case estimate of VOC emissions. Additional calculation
assumptions for construction -phase asphalt paving are outlined in Table A-3.
Table A-3. Calculation Assumptions for Construction Phase Asphalt Paving
missions Vehicle Calculation Methodology
Grour .-
MI
Asphalt All Emission VOC emission factor for emulsified asphalt from:
Factor http://digital.ncdcr.gov/cdm/ref/collection/p249901coII22/id/650992
Asphalt All Seasonal Seasonal factor to account for majority of paving in spring/summer:
Factor http://digital.ncdcr.gov/cdm/ref/collection/p249901coll22/id/650992
4.2 Operational Phase Air Emissions
Air emissions from operation of the CCX will occur primarily from tractor trailers moving cargo to
and from the terminal and from employee vehicles. Additional emissions will also occur from
idling locomotives and from hostler trucks being used at the site. Minimal ancillary process
equipment that will generate air pollution emissions (e.g., comfort heating systems, emergency
generators) will be installed on-site; emissions from these sources were not estimated. These
sources would be covered under requirements for stationary sources; therefore, emissions from
these sources would not be included in a general conformity applicability assessment.
Operational emissions assume that all equipment will be operated at the site 18 hours per day for
312 days per year.
Operational -phase air emissions quantified in this applicability analysis included:
Fuel combustion emissions from the operation of trucks to transfer containers to and from
the terminal
Fuel combustion emissions from the operation of personal vehicles to transport CCX staff
to and from the terminal
Fuel combustion emissions from the operation of locomotive engines at the terminal
P •

Air Quality General Conformity Analysis
CCX Intermodal Terminal
Fuel combustion emissions from the operation of hostler trucks used at the terminal.
4.2.1 Operational Phase Nonroad Emissions Calculations
Nonroad sources associated with operation are limited to idling locomotives, hostler trucks, and
electric gantry cranes, as the CCX will be automated and not use other nonroad equipment typical
of other intermodal terminals. At peak capacity, the CCX is expected to process 35, large, line -
haul locomotives per day, with each locomotive having an average of two to three engines.
Although line -haul locomotives operate in a high-power cycle while in transit, emissions estimates
while on-site were based on a low-power idle cycle of 250 brake horsepower (bhp). Each engine
is anticipated to idle for a total of 30 minutes while in the facility. The gantry cranes will be electric
and will not result in any emissions. Additional calculation assumptions for the operation -phase
nonroad sources are outlined in Table A-4.
Table A-4. Calculation Assumptions for Operational Phase Nonroad Sources
4.2.2 Operational Phase Onroad Emissions Calculations
Onroad sources associated with operation include tractor -trailer traffic and employee commuter
vehicles. For operations, emissions assume a drayage of 170 tractor trailer trucks per day in
A-10
6 gantry cranes were estimated to be used at the Rocky Mount
Nonroad
Gantry
facility based on a comparison to the similar CSX intermodal facility
Number
Operation
Cranes
in Ohio. The gantry cranes will be electric and will not generate air
emissions.
Facility operations will be automated, and therefore no nonroad
Nonroad
Hostler
operation equipment is expected. Due to their multipurpose use,
Number
Operation
Trucks
5 hostler trucks were assigned onsite as a conservative, subjective
estimate.
All emissions factors based on 2020 Calendar Year for Large Line -
Nonroad
Locomotives
Emission
haul locomotives, per:
Operation
Factors
nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P100500B.TXT
Nonroad
Engines
Estimated average of 2.5 engines per train based on personal
Locomotives
Operation
per Train
communication.
Nonroad
Trains
Locomotives
35 trains per day based on CSX estimate for full capacity.
Operation
per Day
Nonroad
Engine
Estimated 0.5 hours of on-site engine idle time at 250 brake
Operation
Locomotives
bhp -hr
horsepower.
4.2.2 Operational Phase Onroad Emissions Calculations
Onroad sources associated with operation include tractor -trailer traffic and employee commuter
vehicles. For operations, emissions assume a drayage of 170 tractor trailer trucks per day in
A-10

Air Quality General Conformity Analysis
CCX Intermodal Terminal
2018, increasing to 290 trucks per day by 2027, the year the Rocky Mount area ceases being
designated as a maintenance area. Emissions factors for onroad equipment were based on the
averaged summer and winter emission factors for each vehicle type. Employee vehicles were
assumed to be a 50/50 split of passenger cars and pickup trucks, and operational trucks were
assumed to be combination long-haul trucks. Emission factors were broken down by vehicle type,
season, model year, and vehicle speed. For this analysis, employee vehicle speeds of 45 miles
per hour were used to conservatively reflect these emissions. Operational trucks were assumed
to travel at 15 miles per hour for 10 percent of the time and 55 miles per hour for the remaining
90 percent of the time. Additional calculation assumptions for the operation -phase onroad
sources are outlined in Table A-5.
Table A-5. Calculation Assumptions for Operational Phase Onroad Sources
Onroad Employee Trips per
150 employees onsite during operation phase. Each employee
Operation Vehicles Day
expected to make a single -round trip per day.
The site is expected to have daily drayage of 170 trucks in 2018,
Onroad Tractor Trips per
increasing to 397 by 2035. Linearly interpolated to determine
Operation Trailers Day
estimated drayage of 290 in year 2027. Drayage multiplied by two to
account for trucks travelling both to and from the site.
Onroad All Trips per
Trips per day multiplied by 6 days of operation per week for
Operation Year
52 weeks per year.
Estimated that 80% of staff reside within Nash and Edgecombe
Onroad Employee Trip
counties, commuting an average of 10 miles to site. The remaining
Operation Vehicles Length
20% of employees reside outside of Nash and Edgecombe counties,
commuting an average of 20 miles to the site. The average trip
length was calculated as: trip length=(0.8*10)+(0.2*20).
The CCX site is located approximately 6.1 miles from the onramp to
Interstate 95 (major north/south transit) and 8.4 miles from the
onramp to Interstate 64 (major east/west transit). Average travel
Onroad Tractor Trip
distance on local roads = 7 miles. The highway travel distance from
Operation Trailers Length
the onramp to the border of Nash or Edgecombe county was
measured via Google Earth to determine the length of travel within
Rocky Mount Maintenance area. The average of the distances in the
four directions (north, south, east, west) = 19 miles.
4.4 Emissions Results
Tables A-6 and A-7 summarize the calculated project construction and operational emissions
compared to the General Conformity de minimis emission levels for the project area. The
A-11

Air Quality General Conformity Analysis
CCX Intermodal Terminal
emissions include all of the construction segments noted above. A review of the total construction
emissions in Table A-6 shows that both NOx and VOC are well below the general conformity de
minimis emission levels. Therefore, the project does not require a formal general conformity
determination and would result in no significant air quality impact for emissions from construction.
Table A-6. Comparison of Construction Emissions to Conformity Applicability Levels
A review of the total operation emissions in Table A-7 shows that both NOx and VOC are well
below the general conformity de minimis emission levels. Therefore, the project does not require
a formal general conformity determination and would result in no significant air quality impact for
emissions from operation of the intermodal terminal.
Table A-7. Comparison of Operation Emissions to Conformity Applicability Levels
de minimis
Emissions During
Emissions
Pollutant
Emissions (tpy)
Construction Phase (tpy)
Conforming?
NOx
100
48.4
Yes
VOC
100
14.1
Yes
A review of the total operation emissions in Table A-7 shows that both NOx and VOC are well
below the general conformity de minimis emission levels. Therefore, the project does not require
a formal general conformity determination and would result in no significant air quality impact for
emissions from operation of the intermodal terminal.
Table A-7. Comparison of Operation Emissions to Conformity Applicability Levels
5.0 CONCLUSION
Calculated emissions for the Carolina Connector Project are less than the general conformity
applicability thresholds for both NOx and VOC. Because the calculated emissions are less than
the de minimis emission levels, the project is not subject to the general conformity provisions and
a Record of Non -Applicability (RONA) can be issued by the U.S. Army Corps of Engineers. A
summary of emissions by segment for both construction and operation is provided in Tables A-8
and A-9, respectively.
A-12
de minimis
Emissions During
Emissions
Pollutant
Emissions (tpy)
Operation Phase (tpy)
Conforming?
NOx
100
66.0
Yes
VOC
100
4.7
Yes
5.0 CONCLUSION
Calculated emissions for the Carolina Connector Project are less than the general conformity
applicability thresholds for both NOx and VOC. Because the calculated emissions are less than
the de minimis emission levels, the project is not subject to the general conformity provisions and
a Record of Non -Applicability (RONA) can be issued by the U.S. Army Corps of Engineers. A
summary of emissions by segment for both construction and operation is provided in Tables A-8
and A-9, respectively.
A-12

Air Quality General Conformity Analysis
CCX Intermodal Terminal
Table A-8. Summary of Emissions from Construction of the Carolina Connector Project
Source Category
Emissions (tpy)
NO,
VOC
Nonroad Construction
30.58
2.39
Onroad Construction
18.27
2.95
Asphalt Paving
--
8.74
Total Construction
48.85
14.08
Table A-9. Summary of Emissions from Operation of the Carolina Connector Project
Source Category
Emissions (tpy)
NOX
VOC
Nonroad Operation
22.51
1.08
Onroad Operation
43.49
3.67
Total Operation
66.00
4.75
A-13

Table A-10. Construction Phase - Nonroad Source Emissions
Note: Load Factors from NONROAD2008a, based on SCC
Emission Factors and Operating Limits
Emissions
Rating
Hours
Days Per
Load
THC
NOx
PM10
PM2.5
CO
SO2
CO2e
Engine Description
(hP)
Number
Total hP
Per Day
Year
Tier
Factor
(g/hp•hr)
(g/hp•hr)
(g/hp•hr)
(g/hp•hr)
(g/hp•hr)
(g/hp-hr)
(g/hp•hr)
Off Road Dump Trucks
350
15
5250
6.3
260
4
0.59
0.16
2.52
0.01
0.01
0.15
0.003
536.41
Drum Rollers
131
1
131
2.9
260
3
0.59
0.22
2.63
0.40
0.39
1.51
0.004
536.21
Soil Compactors
253
3
759
1.9
260
2
0.59
0.38
3.82
0.18
0.18
1.26
0.004
535.78
Farm Tractors
500
2
1000
3.3
260
2
0.59
0.20
2.62
0.21
0.21
1.38
0.004
536.28
Excavators (large)
417
4
1668
4.2
260
3
0.59
0.20
2.63
0.26
0.26
1.47
0.004
536.28
Excavators (medium)
161
2
322
4.2
260
3
0.59
0.22
2.63
0.42
0.41
1.53
0.004
536.21
Bulldozers (medium)
166
3
498
3.5
260
2
0.59
0.41
3.91
0.27
0.26
1.46
0.004
535.68
Bulldozers (large)
312
1
312
3.5
260
4
0.59
0.16
2.51
0.01
0.01
0.14
0.003
536.41
Off -Road Water Truck
350
1
350
6.3
260
4
0.59
0.16
2.52
0.01
0.01
0.15
0.003
536.41
Road Graders
173
1
173
3.7
260
3
0.59
0.22
2.63
0.42
0.40
1.53
0.004
536.21
Loaders
180
2
360
2.9
260
2
0.59
0.38
3.82
0.18
0.18
1.26
0.004
535.78
Backhoes
77
5
385
4.4
260
2
0.21
0.98
5.22
0.55
0.54
6.50
0.005
693.26
Forklifts
93
10
930
2.5
260
1
0.59
0.62
5.42
0.75
0.73
3.98
0.004
594.37
Cranes
194
5
970
3.8
260
2
0.43
0.36
4.04
0.14
0.14
0.83
0.004
530.02
Asphalt Pavers
91
5
455
3.2
260
2
0.59
0.45
4.49
0.37
0.36
3.99
0.004
594.90
Asphalt Compactors
8
5
40
1.9
260
1
0.43
0.87
5.36
0.57
0.55
4.53
0.004
587.86
Hostler Trucks (listed as subgroup
96
5
480
4.8
260
3
0.59
0.22
2.63
0.42
0.41
1.53
0.004
1 536.21
Note: Load Factors from NONROAD2008a, based on SCC
Emissions
THC
NOx
PM10
PM2.5
CO
SO2
CO2e
Engine Description
(Ib/hr)
(tpy)
(Ib/hr)
(tpy)
I (Ib/hr)
(tpy)
(Ib/hr)
(tpy)
(Ib/hr)
(tpy)
(Ib/hr)
(tpy)
(Ib/hr)
(tpy)
Off Road Dump Trucks
1.07
0.87935
17.20
14.111061
0.08
0.06619
0.08
0.06420
1.01
0.83016
0.0177
0.01450
3662.96
3005.46
Drum Rollers
0.04
0.01429
0.45
0.17021
0.07
0.02609
0.07
0.02531
0.26
0.09777
0.0006
0.00023
91.37
34.72
Soil Compactors
0.37
0.08968
3.78
0.91362
0.18
0.04373
0.18
0.04242
1.24
0.29987
0.0036
0.00086
528.94
128.00
Farm Tractors
0.25
0.10850
3.41
1.45637
0.28
0.11833
0.27
0.11478
1.79
0.76461
0.0047
0.00201
697.55
298.20
Excavators (large)
0.43
0.23418
5.70
3.11476
0.57
0.31278
0.56
0.30340
3.19
1.74253
0.0078
0.00428
1163.49
635.27
Excavators (medium)
0.09
0.05062
1.10
0.60163
0.18
0.09575
0.17
0.09288
0.64
0.35007
0.0015
0.00083
224.58
122.62
Bulldozers (medium)
0.27
0.11954
2.54
1.13988
0.18
0.07903
0.17
0.07665
0.95
0.42636
0.0023
0.00105
346.98
155.97
Bulldozers (large)
0.06
0.02835
1.02
0.45805
0.00
0.00186
0.00
0.00180
0.06
0.02568
0.0011
0.00047
217.69
97.85
Off -Road Water Truck
0.07
0.05862
1.15
0.94074
0.01
0.00441
0.01
0.00428
0.07
0.05534
0.0012
0.00097
244.20
200.36
Road Graders
0.05
0.02395
0.59
0.28473
0.09
0.04515
0.09
0.04379
0.34
0.16546
0.0008
0.00039
120.66
58.04
Loaders
0.18
0.06688
1.79
0.68134
0.09
0.03261
0.08
0.03163
0.59
0.22363
0.0017
0.00064
250.88
95.46
Backhoes
0.17
0.09863
0.93
0.52821
0.10
0.05602
0.10
0.05434
1.16
0.65749
0.0008
0.00047
123.57
70.12
Forklifts
0.75
0.24786
6.56
2.17201
0.91
0.30117
0.88
0.29213
4.81
1.59290
0.0048
0.00160
718.99
237.99
Cranes
0.33
0.16551
3.71
1.83706
0.13
0.06345
0.12
0.06155
0.76
0.37586
0.0033
0.00163
487.37
241.25
Asphalt Pavers
0.26
0.10829
2.66
1.09083
0.22
0.08957
0.21
0.08689
2.36
0.96828
0.0024
0.00097
352.08
144.53
Asphalt Compactors
0.03
0.00800
0.20
0.04914
0.02
0.00520
0.02
0.00505
0.17
0.04152
0.0002
0.00004
22.29
5.39
Hostler Trucks (listed as subgroup
0.14
0.08686
1.64
1.03235
0.26
0.16430
0.25
0.15937
0.96
0.60069
0.0023
0.00142
1 334.78
210.41
TOTALS
4.57
2.39
54.43
30.58
3.36
1.51
3.26
1.46
1 20.35
9.22
0.057
0.0324
1 9588.4
5741.6

Table A-11. Construction Phase - Onroad Mobile Source Emissions
Emission Factors and Operating Limits
VOC
(g/start)
NOx
(g/start)
Trips Per
Trips Per
Trip Length
VOC
NOx
PM10
PM2.5
CO
SO2
CO2e
Vehicle Location
Rating (hp)
Day
Year
(mi)
(g/mile)
(g/mile)
(g/mile)
(g/mile)
(g/mile)
(g/mile)
(g/mile)
Asphalt dump trucks (asphalt) CCX - Rocky Mount
120
138
35,844
5
0.86
5.84
0.50
0.46
2.95
0.010
1109.07
Asphalt dump trucks (sub -asphalt) CCX - Rocky Mount
120
138
35,844
5
0.86
5.84
0.50
0.46
2.95
0.010
1109.07
Asphalt dump trucks (ballast) CCX - Rocky Mount
120
1,205
313,419
5
0.86
5.84
0.50
0.46
2.95
0.010
1109.07
Asphalt dump trucks (asphalt) CCX - Rocky Mount
120
603
156,709
5
0.86
5.84
0.50
0.46
2.95
0.010
1109.07
Employee Vehicles (personal) CCX - Rocky Mount
From MOVES
500
130,000
12
0.08
0.23
0.01
0.01
5.05
0.003
432.57
On -Road Water Truck CCX - Rocky Mount
300
1
260
5
2.09
1 11.00
1 0.97
1 0.90
1 5.20
1 0.017
1 1919.43
Vehicle
VOC
(g/start)
NOx
(g/start)
PM10
(g/start)
PM2.5
(g/start)
CO
(g/start)
SO2
(g/start)
CO2e
(g/start)
Item - Construction Equipment (2018 Only)
0.25
0.49
0.002
0.002
1.59
0.0003
29.5601
Asphalt dump trucks (sub -asphalt)
0.25
0.49
0.002
0.002
1.59
0.0003
29.5601
Asphalt dump trucks (ballast)
0.25
0.49
0.002
0.002
1.59
0.0003
29.5601
Asphalt dump trucks (asphalt)
0.25
0.49
0.002
0.002
1.59
0.0003
29.5601
Soil Compactors
0.77
0.81
0.013
0.012
7.96
0.0005
92.5634
Farm Tractors
0.25
0.49
0.002
0.002
1.59
0.0003
29.5601
Emissions
Location
VOC
(Ib/day) (tpy)
NOx
(Ib/day) (tpy)
PM10
(Ib/day) (tpy)
PM2.5
(Ib/day) (tpy)
CO
(Ib/day) (tpy)
SO2
(Ib/day) (tpy)
CO2e
(Ib/day) (tpy)
Running
20.7 2.7
137.4 17.9
11.5 1.5
10.6 1.4
134.7 17.5
0.3 0.0
31219.7 2.1
Start-up
2.00E+00 2.60E-01
3.16E+00 4.11 E-01
2.22E-02 2.89E-03
1.99E-02 2.59E-03
1.61E+01 2.09E+00
1.73E-03 2.25E-04
2.38E+02 3.09E+01
TOTALS
1 22.72 2.95
1 140.52 18.27
1 11.53 1.50
1 10.60 1.38
1 150.75 19.60
1 0.268 0.035
1 31457.6 133.0

Table A-12. Construction Phase - VOC Asphalt Emissions
Emulsified Asphalt Emission Seasonal Adjustment Emissions
Asphalt Type (gallons) Factor Factor Emissions (tons/day)' (tons/project)
Hot Mix and Emulsified Asphalt 60,000 9.2 1.33 0.146 8.74
Aa a wuraL case esurnaUe, are seasunar aaJusunenL iauur rur 7 rnunur5 ur Paving was urea even awugn paving rur ure PruJecL is esurrraLeu w ue ou aay5.
Asphalt Assumptions
NC Redesignation demonstration and maintenance plan for the Rocky Mount, North Carolina 8 -hour ozone nonattainment
area
Methodology for VOC from asphalt: http://digital.ncdcr.gov/cdm/ref/collection/p249901coII22/id/650992
https://fl h.fhwa.dot.gov/resou rtes/design/tools/cfl/docu ments/Esti mat
Estimate of gallons/sq ft (note: area) of asphalt emulsion = 0.27gal/sq yd ingTable.pdf
NCDOT specifications for asphalt in 2002 "was hot mix and emulsified asphalt with hot mix but not cutback asphalt"
Area of the site (400 ft x 5,000 ft) converted to yd
222,222
Number of gallons of emulsified asphalt used (assume 0.27 gal/yd2):
60,000
Emission factor (9.2 Ib VOC/barrel of asphalt)
9.2
Seasonal adjustment factor from NC (1.33 for March - November)
1.33
Number of gallons per barrell (42)
42
Number of days for paving
60

Table A-13. Asphalt Application Rates and Weights for Estimating Purposes
Application Rates and Weights for Estimating Purposes I
Material
I Application Rate or Unit Weight I
Aggregate Base
I 2225 kg/m3 (139.0 lb/ft 3) I
Hot Asphalt Mix
I 2325 kg/m3 (145.2 Ib/ft3) I
Asphalt Binder
I 6.0% by weight of mix
Antistrip
I 1.0% by weight of mix
Prime Coat
2 2
0.90 to 2.25 I/m (0.10 to 0.50 gal/yd )
(Using Asphalt Cutbacks)
assume 1.50 I/m2 (0.33 gal/yd 2) for estimating
Prime Coat
2 2
0.30 to 1.20 I/m (0.10 to 0.40 gal/yd )
(Using Asphalt Emulsion*)
2)
assume 1.20 I/m2 (0.27 gal/yd for estimating
Prime Coat
1047 I/t (251 gal/ton)
(Using Asphalt Cutbacks)
Blotter
(specified in conjunction with prime
8.0 kg/m2 (14.75 Ib/yd2)
coat)
Tack Coat
0.25 to 0.70 1/2mz (0.05 to 0 15 gal/yds)
(Using Asphalt Emulsion*)
assume 0.45 I/m (0.10 gal/yd ) for estimating
Fog Seal
0.25 to 0.70 I/m (0.05 to 0 15 gal/yd )
(Using Asphalt Emulsion*)
assume 0.45 I/m (0.10 gal/yd ) for estimating
Fog, Tack, and Prime Coats
993 I/t (233 gal/ton)
(Using Asphalt Emulsion*)
Concrete
2485 kg/m3 (155.0 Ib/ft3)
0.30 I/mom (0.20 gal/yd'-) per application
Magnesium Chloride
specific gravity of 1.3
Requires 2 applications
* If the project uses the FP -03 calculate quantity based on area and use this
value in your estimate because the FP -03 pays for the water to dilute.

Table A -14a. Constuction Phase - PM10 Unpaved Road Emissions
Engine Description
VMT (day) per
vehicle
Number
Vehicles
Total VMT
(day)
Emission Factors and Operating Limits
AP -42 Emission Factor Parameters (Section 13.2.1)
Operating Silt Content Vehicle Weight
Hours Per Day k (Ib/VMT) N a b (tons)
Emission Factor
(Ib/VMT)
Emissions Control
Efficiency (%)
Uncontrolled
Fraction
Emission Rate
(tons/year)
Off Road Dump Trucks
32
15
473
6.3
1.5
8.5
0.9
0.45
34.7
3.31
70
0.30
85.8
Drum Rollers
15
1
15
2.9
1.5
8.5
0.9
0.45
11.5
2.01
70
0.30
1.6
Soil Compactors
9
3
28
1.9
1.5
8.5
0.9
0.45
20.0
2.58
70
0.30
4.0
Farm Tractors
16
2
33
3.3
1.5
8.5
0.9
0.45
11.4
2.00
70
0.30
3.6
Excavators (large)
1
4
4
4.2
1.5
8.5
0.9
0.45
58.8
4.19
70
0.30
1.0
Excavators (medium)
1
2
2
4.2
1.5
8.5
0.9
0.45
21.4
2.66
70
0.30
0.3
Bulldozers (medium)
6
3
18
3.5
1.5
8.5
0.9
0.45
10.2
1.91
70
0.30
1.9
Bulldozers (large)
6
1
6
3.5
1.5
8.5
0.9
0.45
35.3
3.33
70
0.30
1.1
Off -Road Water Truck
47
1
47
6.3
1.5
8.5
0.9
0.45
35.0
3.32
70
0.30
8.6
Road Graders
27
1
27
3.7
1.5
8.5
0.9
0.45
16.0
2.34
70
0.30
3.4
Loaders
15
2
29
2.9
1.5
8.5
0.9
0.45
16.6
2.37
70
0.30
3.8
Backhoes
22
5
109
4.4
1.5
8.5
0.9
0.45
7.0
1.61
70
0.30
9.6
Forklifts
13
10
127
2.5
1.5
8.5
0.9
0.45
5.8
1.48
70
0.30
10.3
Cranes
38
5
190
3.8
1.5
8.5
0.9
0.45
32.8
3.23
70
0.30
33.6
Asphalt Pavers
8
5
38
3.2
1.5
8.5
0.9
0.45
18.7
2.50
70
0.30
5.2
Asphalt Compactors
8
5
38
1.9
1.5
8.5
0.9
0.45
4.6
1.34
70
0.30
2.8
Hostler Trucks (listed as subgroup of "Terminal
5
113
4.8
0.15
8.5
0.9
0.45
7.3
0.16
70
0.30
1.0
Tractors")
23
5
113
4.8
1.5
8.5
0.9
0.45
7.3
1.64
70
0.30
10.1
Table A -14b. Construction Phase - PM2.5 Unpaved Road Emissions
Engine Description
VMT (day) per
vehicle
Number
Vehicles
Total VMT
(day)
Emission Factors and Operating Limits
AP -42 Emission Factor Parameters (Section 13.2.1)
Operating Silt Content Vehicle Weight
Hours Per Day k (Ib/VMT) N a b (tons)
Emission Factor
(lb/VMT)
Emissions Control
Efficiency (%)
Uncontrolled
Fraction
Emission Rate
(tons/year)
Off Road Dump Trucks
32
15
473
6.3
0.15
8.5
0.9
0.45
34.7
0.33
70
0.30
8.6
Drum Rollers
15
1
15
2.9
0.15
8.5
0.9
0.45
11.5
0.20
70
0.30
0.2
Soil Compactors
9
3
28
1.9
0.15
8.5
0.9
0.45
20.0
0.26
70
0.30
0.4
Farm Tractors
16
2
33
3.3
0.15
8.5
0.9
0.45
11.4
0.20
70
0.30
0.4
Excavators (large)
1
4
4
4.2
0.15
8.5
0.9
0.45
58.8
0.42
70
0.30
0.1
Excavators (medium)
1
2
2
4.2
0.15
8.5
0.9
0.45
21.4
0.27
70
0.30
0.0
Bulldozers (medium)
6
3
18
3.5
0.15
8.5
0.9
0.45
10.2
0.19
70
0.30
0.2
Bulldozers (large)
6
1
6
3.5
0.15
8.5
0.9
0.45
35.3
0.33
70
0.30
0.1
Off -Road Water Truck
47
1
47
6.3
0.15
8.5
0.9
0.45
35.0
0.33
70
0.30
0.9
Road Graders
27
1
27
3.7
0.15
8.5
0.9
0.45
16.0
0.23
70
0.30
0.3
Loaders
15
2
29
2.9
0.15
8.5
0.9
0.45
16.6
0.24
70
0.30
0.4
Backhoes
22
5
109
4.4
0.15
8.5
0.9
0.45
7.0
0.16
70
0.30
1.0
Forklifts
13
10
127
2.5
0.15
8.5
0.9
0.45
5.8
0.15
70
0.30
1.0
Cranes
38
5
190
3.8
0.15
8.5
0.9
0.45
32.8
0.32
70
0.30
3.4
Asphalt Pavers
8
5
38
3.2
0.15
8.5
0.9
0.45
18.7
0.25
70
0.30
0.5
Asphalt Compactors
8
5
38
1.9
0.15
8.5
0.9
0.45
4.6
0.13
70
0.30
0.3
Hostler Trucks (listed as subgroup of "Terminal Tractors 23
5
113
4.8
0.15
8.5
0.9
0.45
7.3
0.16
70
0.30
1.0
Assumptions
k, a, b constants for PM10, PM2.5 from AP -42 Table 13.2.2-2
Silt Content % using mean value for Construction Sites from AP -42 Table 13.2.2-1
Emissions Control Efficiency is for Unpaved Road, basic watering, per: Olsen, Regg. Memorandum to Permitting Branch: Emissions Factors for Paved and Unpaved Haul Roads . Utah Dept. of Environmental Quality. March 10, 2008.

Table A -14c. Construction Phase - PM10 Storage Piles Emissions
AP -42 Emission Factor Parameters (Section 13.2.4)
Material (cu/yd) Material (tons) Emissions (tons)
k Wind Speed Emission Factor
(dimensionless) (m/s) Moisture Content (%) (Ib/ton)
0.35 4.47 22.2 0.0000333
1,456,074 2,490,541 0.0415
Table A -14d. Construction Phase - PM2.5 Storage Piles Emissions
AP -42 Emission Factor Parameters Section 13.2.4
Material (cu/yd)' Material (tons) Emissions (tons)
k Wind Speed Emission Factor
(dimensionless) (m/s) Moisture Content (%) (Ib/ton)
0.053 4.47 22.2 0.0000050
1,456,074 2,490,541 0.0063
1 The entire volume of excavated soil was used as a worst case estimate
Wind Speed (U) 8-10 mph (in m/s) 4.47 Source:
Moisture Content (M) 22.2 Source: Sample TP -02
http://climate.ncsu.edu/climate/ncclimate.htmI#factors
P:\Transportation\Projects\Rail\CSX\6468-16-6133 CSX - Rocky Mount Intermodal
Yard and Leads\Deliverables\Aooendix C CSX Intermodal Lab Results.adf
Amec Foster Wheeler document lists that 80.5% of sample TP -02 passes through 200 mesh, which is 74µm and the definition of silt in AP -13.2.4 page 1
Silt Content (%) Per internal discussion, the site has a Fines value of 80.5, but no way to determine the silt vs. clay content. Revert to average value.
NOTE: The silt percentage is NOT the k factor. It is based on particle size. Confirm this refers to 10 microns and 2.5 microns
k factor: <10 µm multiplier 0.35 Source: AP -42 13.2.4-4
<2.5 µm multiplier 0.053 Source: AP -42 13.2.4-4
"The particle size multiplier in the equation, k, varies with aerodynamic particle size range " (AP -42 Section 13.2.4-4).
Convert cu/yd of soil to tons
Maximum density of sample TP -02 in pcf (pounds cubic foot) 126.7
convert to tons/cu yd: 1.710

Table A -14e. Construction Phase - PM10 Wind Erosion Emissions
AP -42 Emission Factor Parameters (Section 11.9)
Material Silt Content
N Moisture Content (%) Scaling Factor Emission Factor (Ib/hr) Emissions (tons/year)'
8.5 22.2 0.75 0.24 1.06
1
�Z) a wuiZ>L Uaac ebuinaLe, uie LaLuiaLivii abZ)unit=) uiaL wniu ciuZ)iviiZ) CnnJDwllb wni ULLui G°+ nuuiz> Nei uay anu Z)oj uayz) Nei yeas.
Table A -14f. Construction Phase - PM2.5 Wind Erosion Emissions
AP -42 Emission Factor Parameters (Section 11.9)
Emission Factor (Ib/hr) Emissions (tons/year)
Material Silt Content
N Moisture Content (%) Scaling Factor
8.5 22.2 0.105
0.14 0.61
1 As a worst case estimate, the caculation assumes that wind erosions emissions will occur 24 hours per day and 365 days per year.
Calculation using AP -42 equations in Table 11.9-1. Select Operation=Bulldozing and Material=Overburden.
P:\Transportation\Projects\Rail\CSX\6468-16-6133 CSX - Rocky Mount Intermodal Yard and
Moisture Content (M) (%) 22.2 Source: Sample TP -02 Leads\Deliverables\Appendix C CSX Intermodal Lab Results.pdf
Silt Content (%) 8.5 Per internal discussion, cannot determine silt percentage from site samples. Use 8.5%
AmecFW document lists that 80.5% of sample TP -02 passes through 200 mesh, which is 741tm, but no way to determine silt vs. clay partition. Revert to AP -42 fallback value of 8.5% silt