aom-eAP ^^ Consolidated Edison Company of New York, Inc. -• ^i 4 Irving Place, New York, N.Y. 10003 July 14, 2000 C^VC-BH Ms. Susan Steinberg PUBLIC SERVICE C0W1MISSI0N i (Tto-MOiVoun East River Environmental Coalition BECES^EO ^ -^ T)o VJ2 P.O. Box 1619 ,)UL19 2000 ^.^^^^^ Peter Stuyvesant Station New York, NY 10009 FILES ALBANY, NY. Dear Ms. Steinberg: Thank you for your letter of June 5, 2000 to Stephen A. Kurtz detailing the East River Environmental Coalition's ("EREC") issues and concerns regarding Consolidated Edison Company of New York, Inc.'s ("Con Edison") East River Generating Station ("Station") and the East River Repowering Project ("Project"). In addition, we have also received correspondence from New York State Senator Martin Connor, Congress Member Nydia Velazquez, City Council Member Kathryn Freed, and Community Board No. 3, stating many of the same issues raised in your June 5 letter. We appreciate your need to be fiilly informed, and therefore we included EREC in our June 1, 2000 distribution of the Article X application. We welcome your input and recognize the importance of our ongoing dialogue with you. We have been actively reviewing and collecting information to provide to you in response to your letter. As part of this effort, we met with EREC, Downtown Residents for Community Empowerment ("DRCE"), representatives of local elected officials, community leaders, and other interested parties on June 26, 2000 to gain additional input and to clarify further the issues of concern to the community. We would like to take this opportunity to respond to the following issues raised in your letter: Issues Involving the Station and Neighboring Community a) Spill/Exceedance Reports Con Edison will provide EREC with a written summary of all chemical, oil, opacity and State Pollutant Discharge Elimination System ("SPDES") incident reports for the Station from January 1997 through June 2000, as reported to New York State and/or V ( New York City environmental regulators. This summary will be provided to EREC under separate cover on or about September 15, 2000. b) Emergency Planning Program Con Edison has in place a comprehensive emergency planning program, including written procedures, addressing its gas, electric, and steam operations. This program receives periodic review from federal, state and local regulators. We welcome the opportunity to share this information with you and can assist in facilitating discussion between EREC and Con Edison's Emergency Planning organization at a mutually convenient time. c) Lower East Side Electric Distribution Con Edison will provide EREC with an analysis comparing the electric reliability of the local area network to both our service territory and the State of New York. This analysis will also be provided.to EREC on or about September 15, 2000. d) Noise Reduction Program Con Edison has initiated a comprehensive program to address noise from its operations at or in the vicinity of the Station. Actions undertaken to date include: (i) construction of a sound-absorbing enclosure around the vacuum truck used to clean and repair Fuel Oil Tank No. 2; and (ii) modifications of Station and substation operating procedures, including equipment testing and operation. In addition. Con Edison will be implementing a noise reduction program for the Station. A major element of the program includes installation of soundproofing materials and equipment to reduce noise from various Station systems. Issues Involving Air Quality e) Reduction of Air Emissions at the Station Con Edison is currently evaluating measures to further reduce air emissions from the Station. Such measures being evaluated include the reduction of oil burning at the Station, installation of new emission control technologies and combustion optimization strategies. We will provide EREC with the results of this evaluation on or about September 30, 2000. f) Air Quality/Dispersion Analysis of Emissions at the Station Con Edison will conduct a cumulative air quality dispersion analysis for the existing Station, including the Project. Upon its completion, this analysis will be provided to EREC and made available publicly. g) Neighborhood Air Quality Improvement Program Con Edison is participating in and funding a $5 million Air Quality Improvement Program in cooperation with the Natural Resources Defense Council, the Northeast States for Coordinated Air Use Management, the New York State Department of Environmental Conservation ("NYSDEC"), and community groups. This program is designed to demonstrate real and quantifiable reductions in local air contaminant levels throughout the City of New York. The program includes a plan to reduce exhaust emissions from garbage trucks serving the neighborhood around the Station. We would like to take this opportunity to request EREC's participation in this program. We believe your participation would be a valuable asset to the program and provide an important voice for the neighboring community. h) Dispersion Modeling Analysis of PM2 5 Con Edison has conducted a preliminary analysis of the potential emissions of PM25 from the Station, including the Project. Using the available New York City background data and very conservative, health protective assumptions, the analysis demonstrates that the localized impacts in the vicinity of the Station would be well within proposed National Ambient Air Quality Standards ("NAAQS") for PM2 5. i) Health Impacts of Emissions with Emphasis on Fine Particles At the request of the New York State Department of Health, Con Edison has conducted a health risk evaluation for non-criteria contaminants for the Station, including the Project. The evaluation demonstrates that health risks for these non- criteria contaminants are below the established USEPA health risk levels. This evaluation is being provided as part of the July 2000 supplement to Con Edison's June 1 Article X application. Please note that the analysis for PM2 5 described in (h) above treats PM2 5 as a criteria contaminant and demonstrates compliance with the proposed NAAQS, which is designed to be protective of human health. j) Inclusion of Pending Projects in Air Analysis EREC requested that Con Edison's Article X application "include air quality analyses from all pending projects in which Con Edison has a financial interest." As reported in the June 30 New York Daily News, Key span and an unregulated affiliate of Con Edison have suspended plans to build a 500 MW generating station in Greenpoint, Brooklyn. The Project is the only generation siting project in which Con Edison currently has a financial interest. All Project air quality analyses are included in the June 1 application, as supplemented by our July 2000 filing. Issues Involving the Project k) Construction Impact Mitigation Program Con Edison has retained a respected civic planning and consulting firm to assist in the development and implementation of a Construction Impact Mitigation Program for the Project. The scope of the program will include pre-engineering and construction impact mitigation (including gas, steam, electric, and water interconnection routes), communication with the community, and coordination with government agencies. As the program develops, information will be communicated to, and input will be sought from, the public through a variety of means, including our next public forum (tentatively scheduled for September 2000), our Project Web site (www.coned.com/errp), smaller community meetings, and distributed materials. 1) Parking Impacts of the Project and the East 16,h Street Workout Facility Con Edison has conducted studies to evaluate the traffic and parking impacts of the Project and the East 16th Street workout facility construction and operation. These studies have been incorporated in the July 2000 supplemental filing. m) Recreational Areas As stated in the June 1 Article X application, the recreational fields, owned and maintained by Con Edison north of the Station, will remain unaffected by all Project construction activities. In addition. Con Edison has been working extensively with local community groups and governmental agencies (including New York City Department of Environmental Protection ("NYCDEP"), NYSDEC, and New York City Economic Development Corporation ("NYCEDC")) in a joint effort to minimize impacts to the recreational areas in the vicinity of the Project, specifically Stuyvesant Cove Park. As part of this effort. Con Edison is working with NYCEDC and NYCDEP to expedite interconnection construction that may be required for the Project within the park's current construction schedule to mitigate potential impacts on the neighboring community. n) Analysis of Alternatives to the Project Your June 5 letter requested that "Con Edison commit to examine modifications to the East River, East 74th Street, East 60th Street, West 59th Street, Hudson Avenue, and Waterside plants.. .as an alternative to the expansion of the East River facility." Con Edison's June 1 Article X application does present analyses of several of these alternatives. The application also notes Con Edison's position that the planned sale of the First Avenue properties makes the Waterside site unsuitable as an alternative site for power generation. The June 1 Article X application also presents analyses of other energy supply alternatives, including steam demand reductions and distributed generation. Con Edison believes it has adequately addressed the reasonable scope of alternatives required under Article X. Our planning staff is available