1633 Broadway- - «•- New York, New York 10019 212,'*38.6000 NewYork Power AuthoritY 0^'F^^ February 4,2000 7 OQM^ ® r?f Ms. Debra Renner fSXC- ^' ^ Acting Secretary NYS Public Service Commission 3 Empire State Plaza, 14th Floor Albany, NY 12223 Re: New York Power Authority - Case 99-F-1627 Responses to Comments on the PAR Proposed Combined Cycle Facility Astoria, Queens Dear Ms. Renner: Enclosed are responses to comments by the New York State Department of Public Service, the New York State Department of Environmental Conservation and the New York City Department of Environmental Protection on the New York Power Authority's Pre-Application Report (PAR) for the proposed combined-cycle facility in Astoria, Queens. Please call me at 212-468-6751 if you need additional information. Sincerely, Ellen P. Koivistb Licensing Manager Enclosure \ New York State Department of Environmental Conservation Article X Pre-Applic^tton Report Comments and Responses Regarding Air Quality Aspects of New York Power Authority's Combined Cycle Project Comment 1: General Comment- Emergency or Backup Equipment The impacts of any onsite emergency or backup equipment must be addressed in this Protocol and in the Application. Response: Onsite or emergency backup equipment will be addressed pursuant to the rules and regulations of the State of New York. Specific to air regulations, 6 NYCRR Part 201 will be followed in determining if any such equipment needs to be permitted (i.e., exempt or trivial pursuant to 6 NYCRR Part 201-3). Regardless, emissions from such equipment will be included in the facility total emission summary in determining minor and major source status as well as other requirements (i.e., offsetting such emissions pursuant to 6 NYCRR Part 231-2). Finally, operation of such equipment will be included in the modeling assessment with impacts determined on a potential/worst-case basis. The air modeling protocol has been revised to reflect this comment. Comment 2: General Comment- Acidic Deposition Acidic deposition must be addressed in this Protocol and in the Application. To assist NYPA in this task, attached is the March 4, 1993 Department Policy Memo, "Source Specific Acidic Deposition Impacts for Permit Applications." Response: Acidic deposition will be addressed by NYPA and will follow the March 4, 1993 Department Policy Memo, "Source Specific Acidic Deposition Impacts for Permit Applications." The air modeling protocol has been revised to reflect this comment. Comment 3: General Comment-Model Runs All model runs of the final air quality impact analysis, together with the meteorological data used, will need to be provided for our review and verification at or before the filing of the Application. The hourly meteorological data should be provided (1 file for each year) in card image format on either CD ROMs or floppy disks. Response: The requested files will be provided, on CD ROMs, in your copy of the PSD permit application, as an appendix. New York State Depajjment of aMtfonmental Conservation Article X Pre-Application Repo^^mments and Responses Regarding Air Quality Aspects of New Yorl^wver Authority's Combined Cycle Project Comment 4: General Comment- Stack and Emission Parameters The Application must verify that the stack and emission parameters which are used for assessment of facility impact are final values. Response: The air quality analysis that will be the basis of the PSD and Article X applications will be developed using specific design stack parameters for a range of operating conditions, which will be identified in these documents. Page 2 of 2 New York City Department of Environmental Protection Article X Pre-Application Report Comments and Responses Regarding New York Power Authority's Combined Cycle Project Comment 1: Water Supply and Sanitary Sewer Connections The environmental analysis should identify the specific water mains sanitary/combined sewers, and pumping stations in the immediate area which can be used to provide water and sewer service. A detailed analysis of water demand and wastewater flow capacity is necessary to determine potential impacts. Water demand issues, including potential pressure impacts and sewer capacity issues should be assessed. Please contact this office should you need assistance gathering existing data. Response: The Article X Application will identify specific water mains sanitary sewers and pumping stations which can be used to provide water and sewer service. Water demand issues including potential pressure impacts and sewer capacity issues will be assessed. NYPA intends to use existing water mains and sewers on the site. Comment 2: Wastewater Collection Facilities For the wastewater collection analysis, please elaborate on the flow quantity and point of discharge into the City sewer system. Please disclose whether the flow will be pumped or delivered by gravity. The potential additional flow to the Bowery Bay WPCP should be quantified and the project's effect on the flow and pollutant affluent limits at the WPCP should be addressed. Response: The Article X Application will provide information on the flow quantity and point of discharge into the City sewer system and whether the flow will be pumped or delivered by gravity. The application will address the impact of discharge to the Bowery Bay WPCP. Comment 3: Industrial Wastewater Discharge (a) Based upon the project description provided in the Pre-Applicant Report, this facility will be designated a Significant Industrial User. As such, it will be subject to both the Local Limits, set forth in 15 RCNY Chapter 19, and Categorical limits, set forth in 40 CRF part 423. Accordingly, the proposed project would require an Industrial Wastewater Discharge Permit from NYCDEP's Industrial Pretreatment Program (IPP). NYCDEP is the authorized Control Authority for the IPP pursuant to an approval by the United States Environmental Protection Agency (EPA). New York City Department of ElBWimental Protection Article X Pre-Application Reportrt CornnComments and Responses R -ganling N^w York Power Authority's Combined Cycle Project Response: (a) Currently there are no pla.is to discharge industrial wastewater to a New York City Wastewater Treatment Plant; therefore, an industrial wastewater discharge permit from the New York City Industrial Pre-treatment Program (IPP) is not required. Industrial wastewater will be trucked off-siff, f^ - permitted facilitv NYPA will contact the NYCDEP to discuss the permitting requirements for industrial wastewater treatment. Comment 3: (b) According to the Pre-Application Report, the proposal is to discharge storm water from potentially contaminated areas, (specifically oil storage areas,) into the Combined sewer system after treatment by an oil water separator. DEP has a number of concerns in regard to this proposal. First, it should be noted that the property in question has separate sanitary and storm sewer systems. Therefore, to discharge storm water into the sanitary sewer system would be contrary to Con Edison's existing efforts on this property. Response: NYPA will use separate sanitary and storm sewer systems for the proposed facility. The Article X Application will describe stormwater contamination control activities planned for both the construction and operation of the plant. The description will include planned erosion and runoff control measures during construction and operation. The description will also address the control of spills and leaks during operation of the proposed facility. NYPA proposes to use an oil water separator system to contain potential leaks which could result in contamination for areas of concern such as the boiler and transformer area, and chemical treatment area. The description will also address control of spills cr leaks from existing and/or new facilities including transformers, chemicals and fuel oil, spills during product deliveries and other areas where potential leaks could result in contamination. NYPA proposes to use an oil-water separator systems Comment 3: (c) As stated above, the Pre-Application Report indicates that storm water from oil storage areas will be discharged to the public sewer. It is prohibited by the NYC Fire Code to have such a connection. The proposed oil water separator would be quickly overwhelmed in the even of an oil spill. The proposal also indicates that Transformer areas will be connected to the sewer system. This, again, is contrary to existing efforts by Con Edison citywide to disconnect potentially contaminated areas from the public sewer system. The proposed treatment, an oil water separator, is not adequate to address potential PCB issues and the current DEP PCB guidance criteria. Response: Each of these issues will be addressed in the application (see response to Comment 3b). The issu^. of PCB use at the proposed facility will also be addressed. Page 2 of 7 New York City Department of ETmronmentalft Protection Article X Pre-Application Report Comments and Responses ^egr. ing New York Power Authority's Combined Cycle Project Comment 3: (d) Furthermore, additional information is needed concerning the floor drains. Why is it proposed that they be discharged to the sanitary sewer system when all other process waste water is to be discharge to the SPDES outfall? Detailed plans and specification must be submitted and reviewed before such connection to the sewer are problematic and may violate the NYC sewer system, additional data are needed on all sources of wastewater discharge into the sanitary sewer system. Specifics are needed on the quantity and quality of the discharge, including average and peak flow rates. In addition, detailed data are required on the proposed on-site pretreatment system for fhese discharges, along with monitoring systems and sampling points for discharges. Response: The Article X Application will address the issue of discharge of floor drains into the sanitary sewer system. The proposed design will limit sources of discharge to the sanitary sewer system to those already in use at the Tacility. The Application will include a description of the existing on-site treatment facilities. Information on monitoring and sampling points for discharges will also be included in the Application.