15.0 WATER RESOURCES
15.1 Introduction
In order to greatly minimize water use, TGE proposes to use an air-cooled condenser for process cooling. As detailed in proposed Stipulation 11, TGE's water-related analysis proposes to study the following five areas:
· Quantity, quality and source of water being used (see Section 15.2); · Generation and treatment of wastewater (see Section 15.3); · Flooding, storm water management, and spill prevention (see Section 15.4); · Protection of surface water quality and aquatic ecology (see Section 15.5); and · Protection of tidal wetlands (see Section 15.6).
15.2 Water Supply
With air-cooling of the steam cycle, TGE will minimize its water use needs to an average of approximately 0.1 mgd under normal baseload operating conditions without steam production. This represents about a 97 percent reduction compared to the water needs of a similar-size plant using evaporative cooling towers.
15.2.1 Water Demand and Supply
In the Application, TGE will present a detailed estimate of the hourly and daily peak and the hourly and daily average water supply needs and consumptive water losses of the Project. The water balance will be further defined by water/steam cycle versus domestic uses. Furthermore, TGE has had discussions with the New York City Department of Environmental Protection regarding different water sources that could be utilized for non-potable domestic and steam make-up water. The following sources have been discussed with the City: the municipal water supply, Newtown Creek WPCP effluent, and Brooklyn-Queens Aquifer water. The Application will evaluate these alternatives.
At this time the projected source water demand of the Project ranges from approximately 250 gallons per minute to 6,600 gallons per minute, depending on mode of operations and steam demand.
15.2.2 Water Sources
TGE is studying a variety of water sources for various Project flows. Some Project flows will require water delivery at potable standards for most parameters, and some - at much more stringent standards.
High purity demineralized water is required for steam cycle makeup, combustion turbine inlet air-cooling, and compressor wash water. Use of high purity demineralized water is necessary in the steam turbine and combustion turbine compressors to limit scale formation and minimize corrosion of internal system components. Water used for steam send out will be treated to steam system purity specifications.
Various alternative source waters are available in the general project area that could be considered for the Project, as follows:
· Newtown Creek WPCP Final Effluent
· Brooklyn-Queens Groundwater Aquifer
· City Municipal (Potable) Water System
· East River
Newtown Creek WPCP Final Effluent
The New York City Department of Environmental Protection operates at 310 million gallons per day water pollution control (treatment) plant in Brooklyn -- the Newtown Creek WPCP. This plant currently treats sanitary and combined sewerage to a level close to secondary treatment standards. The treated effluent is discharged to the receiving waters via two outfalls. Approximately 20 percent of the plant effluent is discharged to Whale Creek and 80 percent is discharged to the East River via the India Street Outfall.
The wastewater effluent from the Newtown Creek WPCP in its current and future state of treatment can potentially be further treated to produce high-quality demineralized water for producing steam or for other plant flows. The water treatment equipment would take the Newtown Creek WPCP effluent and treat the water to steam source water quality (meeting the Con Edison steam water quality requirements) utilizing advanced treatment techniques such as microfiltration followed by reverse osmosis and other treatment steps as necessary. Having a source of treated effluent available for steam production and other industrial uses may in result in some potential for "off-loading" demand on the municipal supply (which must meet potable water standards) with a replacement alternative that may be suitable for industrial purposes but not drinking water. It would also reduce the current discharge to the East River.
Brooklyn-Queens Aquifer
Certain areas of Queens and Brooklyn are experiencing flooding of basements due to rising ground water levels. This is a result from greatly reduced use of the Brooklyn-Queens Aquifer as a source of drinking water. The former Jamaica Water Company, now owned by the New York City Department of Environmental Protection, had various decommissioned wells located in Queens and Brooklyn, and the system can produce 65 million gallons per day. This water can be reclaimed and treated to meet Federal and State drinking water standards.
TGE is studying a plan for utilizing some of the Brooklyn-Queens Aquifer water by means of a treatment plant that would bring the old Jamaica Water Company supply to drinking water standards and pump the treated water into the City's potable water distribution system. TGE would extract water from the City's potable water distribution system near the Project site to further treat the water to steam source quality. This concept would result in no net use of City reservoir water and could help the City control the rising ground water level.
City Municipal System
This supply of water is reliable and would provide the required average and peak supply needs anticipated at this time. Whether used in the plant industrial process or not, municipal water will be the source for the Project potable/domestic uses, which are minimal. The utilization of the City's municipal supply as an emergency back-up supply for steam make-up water is also contemplated.
East River
Due to the anticipated aquatic biology issues with respect to new intakes along the Hudson River estuarine system, including the East River, TGE will not withdraw river water and will not construct any intake structures in surface water bodies such as the East River.
15.2.3 Water Infrastructure
The Application will present in detail the proposed water-related infrastructure and all water and sewer interconnections between the WPCP and the Project site. It will also include an analysis of potable water supply at the site in terms of quantity, quality, and pressure.
Advanced water treatment steps will be required for any of the proposed sources waters being proposed to be used as steam, HRSG makeup water, and for other plant non-potable uses. A demineralization system will be constructed for some of the process flows. The Application will include a description of the chemical requirements for the water supplied to the Project. For steam cycle makeup water, TGE will indicate any quality criteria that are more stringent than the New York State standards for potable water, and will describe the treatment processes that will be required to obtain the desired chemistry.
To support its conclusions regarding desired water sources and infrastructure, TGE intends to conduct the following investigations and technical studies.
· Treatability study on the Newtown Creek WPCP effluent to determine the treatment steps needed to produce specified steam quality water and water for other project needs.
· Discussions with the NYCDEP, and other agencies to the extent necessary, to determine the availability and acceptability of using Newtown Creek effluent for the Project.
· Treatability study to determine the steps that would be necessary to bring Brooklyn-Queens Aquifer ground water to a quality that meets Federal, State and City drinking water quality standards.
· Discussions with the NYCDEP, and other agencies to the extent necessary, to determine the availability and acceptability of using Brooklyn-Queens Aquifer water.
15.3 Wastewater
15.3.1 Regulatory Applicability
The Public Service Law requires the Siting Board to issue a Certificate only if it finds that the Project "will not discharge any effluent that will be in contravention of [state water quality] standards." PSL168.2(c)(iii).
For new electric generating projects that discharge water into municipal sewer systems, the federal government has adopted the so-called "pretreatment standards for new sources" (PSNS) under 40 CFR 423. The pretreatment standards are meant to ensure that the quality of effluent from an industrial source is sufficient to allow it to be treated in a publicly owned treatment works (POTW). NYCDEP also requires these pre-treatment standards of new industries (15 RCNY 19-04). The application will demonstrate compliance with these requirements.
15.3.2 Information Requirements and Methodology
Wastewater flows generated by the Project will include sanitary flows, blowdown from the steam cycle, floor drains, and plant service uses. The site is presently connected to the New York City sewer system. Project wastewater will be discharged to the sewer system in compliance with the City's Sewer Use Ordinance.
The Application will analyze the Newtown Creek WPCP upgrades and schedule for compliance with its discharge permit, and will demonstrate that the Project would minimize any effects on the WPCP's ability to meet that schedule. TGE will also present copies of any agreements with NYCDEP for wastewater or an update on the status of any negotiations.
If wastewater effluent is selected as the source water for the Project, approximately 40 percent (4 MGD) will be rejected during advanced water treatment steps. It is proposed to return the reject water via discharge to an existing City sewer or a dedicated force main. The Application will show that such discharge is in compliance with the requirements of the City's Sewer Use Ordinance and both Federal and City of New York Industrial Pretreatment requirements
15.4 Flooding, Storm Water and Spill Prevention
15.4.1 Flooding and Wave Action
A substantial portion of the site is located within the 100-year floodplain, and thus qualifies as a special flood hazard area. The State Environmental Conservation Law empowers municipalities to enact floodplain land use ordinances and building requirements. At the same time, NYSDEC's own regulations (6 NYCRR 500) require that certain requirements be met for development in the 100 year floodplain, including the use of flood-resistant construction materials (per FEMA reference standard) and design of new or replacement sanitary sewage conveyance systems to minimize infiltration with floodwaters. The New York City Building Code (administered by the Department of Buildings) contains many of the same requirements.
The Application will include an identification of any potential impacts of tidal surges and storm surges on the Project. Development of the site would involve site remediation, re-grading, construction of buildings and other structures, re-surfacing, and landscaping. These improvements are expected to alter the site's storm water flow characteristics. The Application will include a storm water management plan that addresses the changes in runoff quantity and quality and discusses mitigation of potential environmental impacts (see Section 15.4.2).
In addition, the Application will discuss coastal policies related to flooding and erosion control. The policies are designed to minimize damage to property and lives due to flooding and erosions. TGE will ensure that the proposed plant and appurtenant facilities can withstand severe storm events.
15.4.2 Stormwater Management
TGE proposes to submit Notices of Intent (NOI) for coverage under two State Pollutant Discharge Elimination System (SPDES) general permits: General Permit 93-06 - Storm Water Discharges Associated with Industrial Activity from Construction Activities; and General Permit 98-03 - Storm Water Discharges Associated with Industrial Activity except Construction Activity. The former NOI will be submitted with the Application, and the latter NOI will be submitted during construction.
Storm water is presently and will in the future be discharged into the East River. However, the storm water system at the site must be altered due to Project construction and then operation. The site will have greater rooftop coverage and less pavement than at present. It is expected that storm design will follow New York State's new Storm Water Management Design Manual (available in draft form as of June 2001). The purposes of storm water management at the site are to minimize erosion during construction and to control the discharge of rooftop and pavement oil and grease and other contaminants into surface waters. The storm water management plan will consist of an engineering report, design plans, and technical specifications for an efficient storm water drainage system. The volume and rate of storm water runoff under both pre-construction and post?construction conditions will be used to quantify the potential impacts for parameters of concern and develop suitable mitigation measures.
15.4.3 Spill Prevention
TGE would maintain sufficient on-site fuel oil storage to provide a reliable supply when natural gas is curtailed. Project operation would also require limited amounts of lubricating oils and certain other industrial chemicals, which would be stored in specially designed, covered containment areas. The Project would also require chemicals for boiler feedwater treatment and Selective Catalytic Reduction for control of NOx. Summaries of typical chemical usage, quantity, and storage methods during construction and operation will be provided in the Application.
All chemical storage areas on site would be situated indoors with appropriate containment. Containment would be accomplished through the installation of curbs and drains. Following observation of any spilled material, clean-up and off-site disposal to an appropriate location would be implemented. Both during construction and operation, the potential for spills would be minimized, and adverse impacts mitigated, through proper design, containment systems, and implementation of a spill prevention and contingency plan. The Application will discuss all of the site's present spill prevention plans and protocols, and will state in conceptual form what adjustments to these plans are necessary because of the construction of a new generating station. It is expected, however, that given the site's active environmental management measures, the current plans will form the basis of the Project's final plans. Oil that is presently stored on-site is tightly controlled in an aboveground tanks with containment areas consisting capable of holding at least 110 percent of each tank's capacity.
15.5 Surface Water and Aquatic Resources
TGE expects minimal impacts to surface water bodies. The potential impacts to be studied are those from the construction of a steam interconnection corridor under the East River and those from the reconstruction of a pier to accommodate barge deliveries. The steam interconnection will be placed at sufficient depth under the East River, so that no temporary or permanent disruption will occur to the East River Federal Navigation Channel, or to dredging operations that are undertaken to accommodate shipping. Pier repair is expected to have minimal impacts to the river bottom and may augment aquatic habitat. No thermal discharge is proposed to any surface water. No new or modified intake structures along any surface water body are proposed.
15.5.1 Regulatory Applicability
Section 10 of the Rivers and Harbor Act of 1899 forbids the obstruction or alteration of navigable waters of the United States without first obtaining a permit from the Secretary of the Army. This authority has been delegated to the USACE. Construction of utility lines well under the navigable waterway appears to also fall under this category.
Specific to Article X, the Siting Board regulations require an analysis of "significant ecosystem resources," including "wetlands, flood plains, streams." 16 NYCCR 1001.3(b)1(ii). The studies to be preformed under Stipulation 11 will include compliance with the applicable requirements of Article 15 of the Environmental Conservation Law that pertain to modifying or disturbing the course, channel or bed of any stream" with a water quality classification of C or higher. Other requirements of Article 15 pertain to excavating or placing fill below the mean high water level.
15.5.2 Surface Water Study
The surface water study proposes to address the East River, including the Bushwick Inlet. This is the only water body that will be directly affected by any component of the Project. The study will include a description of East River water quality, tidal flow, and other characteristics under various seasonal conditions. A work plan will be included in the Application that shows how water quality will be preserved during construction.
The East River is a tidal strait separating Long Island from Manhattan Island and the mainland. Approximately 16 miles in length, it extends from Willets Point at Long Island Sound to the Battery in upper New York Harbor. An additional tidal strait, the Harlem River, connects the East River with the Hudson River such that the East River has three tidal boundaries. The statutory Lower East River extends about 10.1 statute miles (16.3 kilometers) from the Battery to just west of Wards Island. Typical minimum depth in the shipping channel is about 35 feet (11 meters) MLW, but depths range downward to 80 feet (24 meters) MLW or more west of Roosevelt Island. The Lower East River is narrow and deep, with most of the shoreline bulkheaded and filled. The Project site is located on the Lower East River, about 3.3 miles north of Upper New York Harbor, where the river channel is approximately 0.6 miles wide and approximately 50 feet deep. National Ocean Service coast survey charts indicate that the channel areas are predominantly hard, rocky, or rock substrates. However, an area of sticky mud lies on the eastern shore just south of Bushwick Inlet, at the Project site, while an area of hard mud lies just north of the Williamsburg Bridge.
Title 6, Chapter X, Article 13 of the New York State Codes, Rules and Regulations (6 NYCRR 890.6) sets the classification and standards of quality and purity assigned to the surface waters within the boundaries of New York City. The entire Lower East River from River Mile (RM) 0 to RM 10.1, east of the junction with the Harlem River, is designated Class I waters. Under 6 NYCRR 701.13, the best uses of Class I saline surface waters are secondary contact recreation and fishing. In addition, these waters must be suitable for fish propagation and survival.
15.5.3 Construction Plans
The Application will include conceptual construction plans for the steam interconnection under the East River (see Section 14.3.1 above) and the pier reinforcement at the Project site. The construction plans will indicate the method of support, machinery to be used, duration of construction, contingency plans, and any associated temporary noise and traffic disruptions. TGE expects that the plans will demonstrate that all surface water quality criteria will be maintained.
15.5.4 Aquatic Resource Study
The Project will have no effect on East River water quality, migratory pathways, or habitat potential (dissolved oxygen). The only potential impacts that are proposed to be studied in the Application related to aquatic ecology are related to the localized temporary effects of work in the waterway to reconstruct a pier for the Project.
15.6 Tidal Wetlands
15.6.1 Regulatory Applicability
Federal and state legislation is concerned with the protection of water during stream disturbance or activities that can result in dredging or filling. By extension, this protection has been accorded not only to navigable waters of the United States, but also to their non-navigable upper reaches and to wetland areas, which play a role in the ecological and hydrological systems of any watershed. Article 25 of the Environmental Conservation Law, and its implementing regulations (6 NYCRR 661) define tidal wetlands under several types of ecological cover types, including the littoral zone.
15.6.2 Wetlands Study
The Application will include a delineation of the coastal areas of the Bushwick Inlet that are within the Project site. Aquatic and coastal vegetation and aquatic and terrestrial ecology adjacent to the Bushwick Inlet will be characterized. Soils will be examined. Tidal hydrology in the inlet will be described. Federal jurisdictional wetland resource areas and state jurisdictional wetland resource areas will be identified. The Project's potential impacts to any delineated jurisdictional wetlands as well as to the terrestrial and aquatic ecology of the Bushwick Inlet intertidal and coastal zones will be described. Mitigation will be proposed if necessary.
To ensure that freshwater wetland resources have been addressed in the record, the Application will include a study documenting the absence of state-designated freshwater wetlands at the Project site or along interconnections.