Monday, September 28, 2009

Civics Comment on Glenwood Landing Power Station Permit Renewal

The United Civics of Glen Head and Glenwood Landing today submitted comments to the New York State Dept. of Environmental Conservation on National Grid's application to renew its State Pollution Discharge Elimination System (SPDES) permit for the Glenwood Landing Power Station.

Other groups that submitted comments are the
Citizens Campaign for the Environment, Coalition to Save Hempstead Harbor, Hempstead Harbor Protection Committee, Town of Oyster Bay, and Network for New Energy Choices.


The Glen Head – Glenwood Civic Council is an alliance of the six civic groups (Glen Knolls-Glen Head Estates, Glenwood-Glen Head, Harbor View, Hill Terrace, Todd Estates civic associations and the Radcliff Manor neighborhood association) active in the neighborhoods closest to the Glenwood Landing Power Station. Our member organizations are particularly interested in land use and water quality issues that impact Hempstead Harbor and nearby neighborhoods.

The Council, along with its member organizations, often works with the Coalition to Save Hempstead Harbor on matters of mutual interest and serves as technical advisor to the Hempstead Harbor Protection Committee. Collectively, we pride ourselves on our efforts to balance the many competing interests in our community from a civic-based point of view.

Our comments concerning the application to renew the SPDES permit for the Glenwood Landing Generating Station follow:

• Immediate, cost-effective steps should be taken to reduce the entrainment and impingement of marine life.

We understand that a fish return system, continuously operated traveling screens, and aggressive pump shutdowns when one or both of these systems are not operating are already in place. We believe that adding variable speed pumps to these measures could significantly reduce the toll on marine life in a cost-effective manor. We believe that variable speed pumps should be installed and brought on line as soon as possible. The installation of variable speed pumps should be accompanied by a monitoring schedule sufficient for determining the effectiveness of the pumps and the impact of their use on marine life.

We do not believe that it is appropriate to delay installation of variable speed pumps until 2013, when the Public Service Agreement (PSA) between National Grid/KeySpan and the Long Island Power Authority expires. Rather, when the PSA expires, the permit and advisability of other recommended technologies should be reevaluated based upon whatever decisions are made about the Glenwood Landing facility at that time.

• The owner of the Glenwood Landing facility and the identity of the permit holder should be clarified.

The permit, fact sheet, and application should list the actual owner of the facility. Although National Grid has acquired KeySpan, KeySpan is listed as the owner/operator in the SPDES fact sheet and is referred to again in that document. The permit requirements should pertain specifically to the operation of the Glenwood Landing facility regardless of any change in who operates it or who holds the permit. If KeySpan is somehow attached to the permit, will this have any bearing on future operation, installation of best technologies, or permitting?

• More details concerning closed-cycle cooling that are specific to the Glenwood Landing facility should be provided.

We understand that closed-cycle cooling is currently considered the most effective means of reducing the amount of water used for cooling, thereby producing a presumed 95% reduction in the entrainment and impingement of marine animals. We also understand that DEC has determined, at least for the moment, that closed-cycle cooling is not appropriate for the Glenwood Landing facility due to limited space and other considerations.

As this decision could, potentially, be a significant factor in determining whether a utility presence is maintained or expanded in Glenwood Landing in the foreseeable future, with significant impacts on the environment, quality of life in nearby neighborhoods, and tax base, we request answers to questions such as:

• How much space would a closed-cycle cooling system require for the Glenwood Landing facility operating at the current capacity (below 15%).

• How long it would take to design and install such a system?

• Could such a system be retrofitted if, in the future, the Glenwood Landing facility began operating at more than 15% capacity?

• What is the maximum distance from operating units that a closed-cycle system can efficiently be sited? Must the system be located directly on the waterfront? Could the siting of the system threaten public acquisition of the former propane storage facility on Shore Road in the Town of Oyster Bay?

• What specific local ordinances are referenced in the fact sheet relating to siting of a closed-cycle cooling system at the Glenwood Landing facility? Why are these ordinance relevant (in past conversations with this community, the utilities have expressed the view that they are not bound by local ordinances)?

• What are the local, state, and federal noise limitations for the site and what are the noise levels emitted by a closed-cycle system?

• What is the source of the water for the system and how is the water delivered?

• What are the dimensions of the cooling tanks that would be required at the Glenwood Landing facility operating at the present capacity and/or the structures that house them? What would the dimensions be if the operation of the facility were stepped up?

Any evaluation of closed-cycle cooling for the Glenwood Landing facility should include informing the community about all aspects of the system that will affect residents and resources, including the potential for increased noise levels, the size and location of any structure needed to house the system, the efficacy and/or impacts of siting the system beyond the immediate area of the specific power generation units, and the water resources and effluent requirements needed to operate the system.

If these impacts are determined to be minimal, the benefit of closed-cycle cooling (i.e., a major reduction in the mortality of marine life in Hempstead Harbor) would likely outweigh them. Assuming that the Glenwood Landing facility continues to operate after the expiration of the PSA and if, after a full assessment of the potential impacts and efficacy of closed-cycle cooling for the facility, it is determined that closed-cycle cooling is the best technology for the site, the permit should require that this technology be used in 2013.

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