DrumPPA_Attachment_12_Initial_Scope_of_Work_Planning_Package_(ISOWPP)_Environmental_Assessment.pdf

INITIAL SCOPE OF WORK PLANNING PACKAGE (ISOWPP)

FOR THE

ENVIRONMENTAL ASSESSMENT OF A PROPOSED BIOMASS

FACILITY

ON

US ARMY GARRISON FORT DRUM

11 Oct 2012

Prepared by U.S. Army Environmental Command

ISOWPP for Ft Drum Biomass EA i 11 Oct 2012

Initial Scope of Work Planning Package (ISOWPP) for the

U.S. Army Garrison Fort Drum Biomass Facility Environmental Assessment

Table of Contents

1.0 PURPOSE OF AND NEED FOR THE PROPOSED ACTION

1.1 Need for Action

1.2 Purpose of Action

1.3 Energy Security

1.4 Climate Change

1.5 Legislative Requirements, Executive Orders and Policy Requiring Increasing Energy Efficiency

2.0 PROPOSED ACTION, ALTERNATIVES, AND SCREENING CRITERIA

2.1 Screening Criteria

2.2 Proposed Action and Alternatives

2.3 No Action Alternative

2.4 Alternatives Screened From Further Consideration

2.4.1 Iraqi Freedom Drive Site on USAG Fort Drum

2.4.2 Gray Street Site on USAG Fort Drum

2.4.3 Construct and Operate Renewable Energy Facility Off-Post

2.4.4 Purchase Renewable Energy Credits (RECs)

2.4.3 Non-Competitive Purchase of Energy from ReEnergy Holdings LLC, a Biomass Power Facility on USAG Fort Drum

3.0 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES

3.1 Construction

3.2 Electrical Tie-In

3.3 Water and Sewer Tie-In

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3.4 Operations and Maintenance

3.5 Estimated Capacity

3.6 Emissions Control

3.7 Other Facility Features

4.0 VALUED ENVIRONMENTAL COMPONENT (VEC) ASSESSMENT OF

ENVIRONMENTAL IMPACTS ASSOCIATED WITH ALTERNATIVES

4.1 Anticipated Impacts to VECs Under the No Action Alternative

4.2 VEC Level of Analysis Expected for the Proposed Biomass Facilit

5.0 STUDIES REQUIRED

6.0 CONSULTATIONS AND AGENCY COORDINATION

7.0 EXISTING DOCUMENTS

8.0 REVIEWERS AND APPROVERS

9.0 PUBLIC, AGENCY, AND STAKEHOLDER PARTICIPATION

9.1 Newspaper Announcements

9.2 Document Availability for Public Review

10.0 SUPPORTING POINTS OF CONTACT

11.0 PROPOSED TIMELINE

12.0 ACRONYMS

Tables

Table 1-1 Summary of Legislation and Executive Orders Supporting a Biomass Facility on USAG Fort Drum

Table 4-1 Anticipated Impacts to VECs Under the No-Action Alternative (Baseline Conditions)

Table 4-2 Anticipated Level of Analysis, by VEC, Required for Proposed Action Alternative

Table 9-1 Newspaper Information

Table 9-2 Public Venue Availability of the Final EA / Draft FNSI

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Figures

Figure 2-1 Greenfield Site Locatin (Proposed Action)

Figure 2-2 Alternate Location of Proposed Action, Iraqi Freedom Drive Site

Figure 2-3 Alternate Location of Proposed Action, Gray Street Site

Figure 3-1 Select Parameters of the Proposed Action (Greenfield Site)

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Initial Scope of Work Planning Package (ISOWPP) for the

U.S. Army Garrison Fort Drum Biomass Facility Environmental Assessment

1.0 PURPOSE OF AND NEED FOR THE PROPOSED ACTION

The Army is evaluating ways to become more efficient users of energy and recognizes that the current pattern of energy use from non-renewable sources poses operational risks to Soldiers, installations, and the environment. To address these threats, the Army has established a Senior

Energy Council (SEC) which recognizes the need to reduce total energy consumption while increasing the use of renewable energy sources to promote greater energy security. The SEC has determined that Army bases, tactical operations, and Soldier training require secure and uninterrupted access to energy. The current state of dependence on fossil fuels and a vulnerable electric power grid jeopardizes the security of Army installations and mission capabilities. Furthermore, the fluctuating costs of fossil fuel energy represent a sizable percentage of the Army’s overall operating budget and also pose a threat to execution of the

Army’s mission. To address these issues, the SEC has specifically established five energy security goals which include:

1. Reduction of energy consumption

2. Increase in energy efficiency across platforms and facilities

3. Increased use of renewable/alternative energy

4. Increased assurance of access to sufficient energy supplies

5. Reduction of adverse impacts on the environment

Implementation of these goals will better support Army operations abroad, the operational efficiency of Army installations, and support national efforts to reduce greenhouse gas (GHG) emissions.

1.1. Need for Action

Currently, the Army derives less than 2.1 percent of its energy from renewable energy sources and must more than triple this amount of electricity consumed that is derived from renewable

ISOWPP for Ft Drum Biomass EA 2 11 Oct 2012 sources by 2013. As an installation, United States Army Garrison (USAG) Fort Drum currently derives less than 0.02 percent of its energy from renewable sources. In addition, USAG Fort

Drum has no agreements in place that would meet energy security goals, such as agreements for provision of electricity to installation facilities by an on-post generator.

1.2. Purpose of Action

The purpose of the proposed action is to provide USAG Fort Drum energy from a renewable source while simultaneously securing the installation’s critical missions moving into the future by increasing the installation’s energy security.

USAG Fort Drum has been selected by the US Army’s Energy Initiatives Task Force (EITF) as a viable location for supporting the development of a biomass facility that could provide USAG

Fort Drum energy from a renewable source while simultaneously increasing the installation’s energy security. The EITF mission is to “[s]trengthen Army energy security and sustainability by developing a comprehensive capability, and planning and executing a cost-effective portfolio of large-scale renewable energy projects by leveraging private sector financing.”1 The EITF vision is “[s]ecuring Army installations with energy that is clean, reliable and affordable.”2

Currently the Army faces significant threats to its energy requirements both home and abroad.

Addressing energy security and sustainability is operationally necessary, financially prudent, and essential to mission accomplishment. The goal is to enhance USAG Fort Drum’s energy security while ensuring applicable government procurement competition requirements are appropriately addressed for the provision of energy. In doing so, the Installation strives to continue to encourage a culture that recognizes the value of sustainability measured not just in terms of financial benefits, but also in terms of maintaining mission capability, quality of life, relationships with local communities, and the preservation of options for the Army’s future. The

Installation recognizes the need to improve efficiencies in energy management for the benefit of current and future missions and is moving forward to improve its energy security status.

The EITF is one of the initiatives of the Assistant Secretary of the Army for Installations, Energy and

Environment.

1 EITF, 2012. Available from the Web http://www.armyeitf.com/index.php/about-eitf/mission-and-vision; accessed October 5, 2012.

2 2 EITF, 2012. Available from the Web http://www.armyeitf.com/index.php/about-eitf/mission-and-vision; accessed October 5, 2012.

http://www.armyeitf.com/index.php/about-eitf/mission-and-vision� http://www.armyeitf.com/index.php/about-eitf/mission-and-vision�

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Additional data and background information further supporting the purpose and need is expounded on below.

1.3. Energy Security

Energy security is a concept that is increasingly viewed as essential to ensuring and protecting the long term viability of USAG Fort Drum operations. Safe and reliable access to energy is critical to virtually all activities on USAG Fort Drum. The Department of the Army has increasingly recognized the threats to its installations and operations posed by increasing costs of centrally distributed, over-burdened, utility-provided energy grids, as well as the vulnerabilities posed by potential disruption of military installation energy supplies. Many of these challenges were directly addressed by the 2010 Quadrennial Defense Review (QDR) which cited the need for Department of Defense (DoD) installations to “assure access to reliable supplies of energy to meet operational needs”3

1.4. Climate Change

. The current state of dependence on fossil fuels and a vulnerable electric power and transmission grid supplies jeopardizes the security of the installation and its critical education, training and operational missions.

The US is by far the largest consumer of energy in the world, accounting for approximately 20 percent of global energy use.4 The Army is projected to remain one of the largest energy users in the US into the foreseeable future. In 2010, the Army consumed almost 10,000,000 megawatt hours (MWh) of electricity on its facilities. Of this energy, approximately two percent was derived from renewable energy sources and an estimated 5,500,000 metric tons of carbon dioxide (CO2) equivalents were generated. This high level of energy usage, particularly energy used for electrical energy generation, results in high levels of GHG emissions which are associated with global climate change.5

3 DoD, 2010. Quadrennial Defense Review Report. Prepared by the Department of Defense (February 2010). Available from the Web http://www.defense.gov/qdr/images/QDR_as_of_12Feb10_1000.pdf;

accessed October 10, 2012.

4 DOE, 2009. Energy Information Agency, “Annual Energy Review of 2008,” Department of Energy (June 2009). See also, S. Null, Defense Sustainability: Energy Efficiency in the Battlefield (Feb. 2010).

5 In 2009, total US greenhouse gas emissions were 6,633.2 Tg or million metric tons CO2 equivalent. The primary greenhouse gas emitted by human activities in the US was CO2, representing approximately 83 percent of total greenhouse gas emissions. The largest source of CO2, and of overall greenhouse gas emissions, was fossil fuel combustion. Within the US, fossil fuel combustion accounted for 94.6 percent of CO2 emissions in 2009. Electricity generators consumed 36 percent of US energy from fossil fuels and emitted 41 percent of the CO2 from fossil fuel combustion in 2009. Emissions from electricity generation http://www.defense.gov/qdr/images/QDR_as_of_12Feb10_1000.pdf�

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Climate change, national security, and energy independence pose related global challenges to the US and its military.6 Climate change acts as a threat multiplier for instability in some of the most volatile regions of the world.7

The DoD 2011 Strategic Sustainability Performance Plan (SSPP) and the DoD 2010 QDR highlight the importance of managing climate change effects and DoD’s critical interests therein.

The QDR states the climate change/energy security issue as follows:

If steps are not taken to limit the anticipated climate change impacts, increased global instability, unrest, and displacement of vulnerable third world populations is projected to accelerate. These populations are most susceptible to influence by radical ideological groups that are identified as the most pressing threat to US security in coming decades, and therefore, it ultimately only makes sense for the US military to lead efforts to counter these security threats posed by global warming. Population displacement increases potential for conflicts around the world and therefore contributes to deterioration in the global security environment. The US military therefore has a large stake in ensuring containment of the impacts of global warming.

Climate change and energy are two key issues that will play a significant role in shaping the future [US] security environment. Although they produce distinct types of challenges, climate change, energy security, and economic stability are inextricably linked. The actions that the Department takes now can prepare us to respond effectively to these challenges in the near term and in the future.8 accounted for the largest portion (33 percent) of US greenhouse gas emissions in 2009. USEPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2009 (April 2011).

6 CNA, National Security and the Threat of Climate Change (2007) 7 Id. For example, the CNA report notes: “Projected climate change will seriously exacerbate already marginal living standards in many Asian, African, and middle eastern nations causing widespread political instability and the likelihood of failed states.”

8 DoD, 2010. The QDR then summarizes the anticipated impacts of climate change upon DoD: “First, climate change will shape the operating environment, roles, and missions that we undertake….Second, DoD will need to adjust to the impacts of climate change on our facilities and military capabilities.”

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Likewise, the SSPP notes the ability of unrestrained climate change to “directly interfere with an installation’s ability to carry out its mission.”9

1.5. Legislative Requirements, Executive Orders and Policy Requiring Increasing Energy Efficiency

Thus, for all of the foregoing reasons, the proposed action would advance US, DoD, and Department of the Army national and security interests.

In addition to reducing resource consumption and improving energy security, the Army and

USAG Fort Drum must meet the requirements of numerous Federal statutes, Executive Orders

(EOs), and mandates which require changes in our nation’s energy consumption and production and require reductions in GHG emissions. The Army and USAG Fort Drum must strive to attain the energy targets outlined in the Energy Policy Act of 2005 (EPAct 2005). EPAct 2005 requires that in Fiscal Years (FY) 2010 thru 2012, five percent of the total electricity consumed by the federal government shall come from renewable energy sources. The required percentage of electricity consumed from renewable sources rises to at least 7.5 percent by FY 2013. Under

EO 13423, at least 50 percent of the renewable energy used must come from “new renewable sources” placed in service after 01 January 1999. In addition, EO 13423 requires federal agencies to reduce GHG emissions through reduction of energy intensity by (i) three percent annually through FY 2015 or (ii) 30 percent by FY 2015. Along with these requirements, the

National Defense Authorization Act of 2007 (NDAA 2007) requires that 25 percent of DoD’s total electric energy consumption come from renewable sources by 2025. Numerous other statutes and requirements also create a framework that increases the need for the Army to take action.

A list of these related to the purpose and need of the proposed action is included below in Table

1-1.

9 DoD, Strategic Sustainability Performance Plan –FY 2011 (Oct. 2011). The SSPP provides some examples of direct military mission interference anticipated to result from unaddressed climate change:

“[T]raining can be limited through the occurrence of more red and black flag days (high heat and humidity conditions); by the loss of land to either sea level rise or the need to set aside more land for endangered species; and by more frequent restrictions on live fire training where heat and decreased precipitation have increased the area’s fire hazard.”

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Table 1-1. Summary of Legislation and Executive Orders Supporting a Biomass Facility on

USAG Fort Drum Federal Mandate Topic • Performance Target

Energy Policy Act

(EPAct) of 2005

Electricity use for federal government from renewable sources

• At least 3% of total electricity consumption (FY 2007-2009), 5% (FY

2010-2012), 7.5% (FY 2013 +)

Executive Order (EO)

13423 Total consumption from renewable sources

• At least 50% of required annual renewable energy consumed from

“new” renewable sources

Energy Independence and Security Act (EISA) of 2007

Total consumption from renewable sources

• 25% by FY 2025 – “Sense of

Congress”

Fossil fuel use in new / renovated Federal buildings

• Reduce 55% by FY 2010; 100% by

EO 13514 GHG emission reduction

• DoD Goal: Reduce Scope 1 & 2 GHGs by 34% by FY 2020

• DoD Goal: Reduce Scope 3 GHGs by

13.5% by FY 2020

National Defense

Authorization Act

(NDAA) of 2010 Renewable Fuels Use

• Directs the Secretary of Defense to consider renewable fuels in aviation, maritime, and ground transportation fleets

Facility Renewable Energy Use

• Produce or procure 25 % of the total quantity of facility energy needs, including thermal energy, from renewable sources starting in FY 2025

In working towards these objectives, the Army and USAG Fort Drum will support implementation of goals, strategies, mandates and directives outlined in the 2010 QDR, EOs 13514 and 13423, EPAct 2005, EISA 2007, Office of the Secretary of Defense Policy – DoD Instruction 4170.11, DoD Managers Handbook, Army Policy – Army Regulation 420-1 Army Facilities Management, and The U.S. Army Energy and Water Campaign Plan for Installations. These documents highlight and address the need to increase the production and use of power derived from renewable energy sources.

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2.0 PROPOSED ACTION, ALTERNATIVES, AND SCREENING CRITERIA

2.1. Screening Criteria

USAG Fort Drum has gone through a rigorous screening process to determine what installation sites are available to support implementation of the proposed action’s purpose. In order to be considered a viable alternative and carried forward for analysis, the site must meet the following screening criteria consistent with the purpose and need of USAG Fort Drum:

• Mission Compatibility. Must be compatible with the military missions and training occurring at USAG Fort Drum and on other nearby military installations. Site development and operations may not adversely impact training activities.

• Grid Access and Electrical Tie-in Potential (Renewable Energy). Must be close to transmission facilities (substations) or have technical viability and economic justification to building new electrical lines for interconnection to the distribution system or grid on

USAG Fort Drum. The infrastructure must be capable of transporting, or being upgraded to transport, electricity generated by the biomass facility.

• Transportation Infrastructure. Must be close to or adjoining a public road that currently supports tractor trailer traffic and not require the development of new or upgraded USAG

Fort Drum control access points in support of commercial traffic. Close proximity to a public road would also need to support minimal disturbance from the biomass facility operation to daily post operations and mission.

• On-Installation Energy Generation Potential for Increased Energy Security. Must allow USAG Fort Drum to have greater control of and/or access to its energy supplies while reducing the possibility of external distribution failures. Should be able to meet Fort

Drum’s 2011 maximum load requirement of 28 megawatts (MW) or a substantial portion thereof. Consumption during 2012 was higher than 2011 and some growth is expected to continue.

• Topographic and Soil Factors: Must have topography, aspect, slope, and soils compatible with a biomass power facility.

• Environmental Factors. Must allow acceptable accommodation of sensitive natural and cultural resources.

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• Safety & Unexploded Ordnance (UXO). Must involve minimized exposure to UXO and damage from munitions. Must not conflict with military training activities or jeopardize personal safety of those constructing or operating the facilities. Ongoing operational needs, such as increased truck traffic to serve a biomass power plant, must not adversely impact traffic safety or security risk.

• Compliance with Federal Mandates and DoD or Army Goals. Must enhance compliance with government mandates and DoD and Army goals and objectives regarding renewable energy production, energy security, increased energy efficiency, and GHG emissions reduction.

• Utility Considerations. Must be reasonably acceptable to local utility companies, the current electric supplier, and not unreasonably interfere with local utilities’ ability to absorb intermittent impacts and variance in peak energy generation.

• Feasible for Operations of a 28MW Facility. The site must be large enough for a renewable sources power generation facility, to include ancillary structures and storage areas, capable of meeting USAG Fort Drum’s maximum installation load of 28 MW.

2.2. Proposed Action and Alternatives

The Army’s proposed action is to enable development of a privately-owned biomass facility, on

USAG Fort Drum, that would enable Fort Drum to competitively purchase energy generated on

USAG Fort Drum property from renewable resources. The proposed action is anticipated to be a competitive action where power is procured through a long-term Power Purchase Agreement

(PPA), in accordance with the Federal Acquisition Regulation (FAR) and applicable US Code

(USC), to include FAR Part 41 for a 10 year PPA and 10 USC 2922a for up to a 25 year PPA.

The site for the proposed action, referred to as the Greenfield Site, is near the intersection of

New York State Route 26 and Steinhilber and Bedlam Roads (Figure 2-1).

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Figure 2-1. Greenfield Site Location (Proposed Action)

2.3. No Action Alternative

Under the No Action alternative, USAG Fort Drum would not make a site available for development of a new privately-owned biomass power facility.

USAG Fort Drum’s Sustainability Program would continue even if the Army selected the No

Action alternative to be analyzed in the EA. In other words, the program will continue whether or not the Army decides to proceed with enabling competition for the provision of on-site renewable energy power generation on Fort Drum. The Sustainability Program is therefore to be assumed in the EA document to be part of the No Action alternative; i.e., part of the baseline environmental conditions. Additionally, the ReEnergy biomass facility on USAG Fort Drum would continue to be developed and operated in accordance with existing lease agreements under the No Action alternative.

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2.4. Alternatives Screened From Further Consideration

2.4.1. Iraqi Freedom Drive Site on USAG Fort Drum

The construction and operation of a biomass power facility near the intersection of Iraqi

Freedom Drive and New York State Route 11 (Figure 2-2) did not meet the transportation and

28MW facility factors listed in the above screening criteria. Additionally, this site is adjacent to a installation control access point and development of the site for a biomass facility would significantly impede traffic flow through the gate.

Figure 2-2. Alternate Location of Proposed Action, Iraqi Freedom Drive Site

2.4.2. Gray Street Site on USAG Fort Drum

The construction and operation of a biomass power facility near the intersection of New York

State Route 971V and Gray Street (Figure 2-3) did not meet the topographic and 28MW facility factors listed in the above screening criteria.

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Figure 2-3. Alternate Location of Proposed Action, Gray Street Site

2.4.3. Construct and Operate Renewable Energy Facility Off-Post

The construction and operation of a renewable energy facility off-post would not provide USAG

Fort Drum with the necessary energy security. USAG Fort Drum is an installation of critical importance to the Army. Energy supply and transmission must be protected through on-post energy generation. In addition, EO 13423, section 2(b), states a preference that federal agencies implement new renewable energy generation projects on agency property for agency use. Likewise, to reinforce that preference, EPAct 2005, section 203, provides federal agencies a double credit toward the agencies' renewable energy consumption mandate if the renewable energy is produced and used on-site.

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2.4.4. Purchase Renewable Energy Credits (RECs)

The purchase of RECs would not provide renewable energy development on USAG Fort Drum and would therefore not enhance the installation’s energy security posture. RECs are purchased on the open market and/or through a REC brokerage. A REC typically represents delivery of one megawatt-hour of renewable energy to the grid and all associated environmental benefits of displacing one MWh of conventional energy. RECs allow the environmental attributes associated with renewable energy production to be monetized and marketed. This alternative would not alleviate the energy threats to installations or enhance energy security. Energy dependence on off-post electrical supplies and transmission would continue. Moreover, since

RECs may arise from renewable energy production that occurs at facilities far distant from the installation, the REC purchases are unlikely to provide the environmental and socio-economic benefits associated with localized renewable energy production.

2.4.5. Non-Competitive Purchase of Energy from ReEnergy Holdings LLC, a Biomass Power Facility on USAG Fort Drum

A non-competitive purchase of renewable energy from the biomass facility located on USAG

Fort Drum, that is owned and operated by the private entity ReEnergy Holdings LLC, does not support the mandate to ensure, where feasible, competitive purchases of energy by Federal agencies. The ReEnergy Black River Facility is being converted from a coal to biomass facility in 2012.

3.0 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES

The proposed action is to enable development of a privately-owned biomass facility at the

Greenfield Site, a site location on USAG Fort Drum that would enable Fort Drum to competitively purchase energy generated on USAG Fort Drum property from renewable resources. Some of the components of the alternatives are provided below.

3.1. Construction

This project would involve the construction of a biomass power facility on the installation, a closed-loop system water cooling tower, ancillary support structures, electrical tie-ins to the two

USAG Fort Drum sub-stations, water and sewer tie-ins to the existing water and sewer systems, perimeter fencing, and access control gates. Construction would be to support the requirements of a biomass facility which include feedstock storage space, feedstock preparation equipment, ISOWPP for Ft Drum Biomass EA 13 11 Oct 2012 feed equipment, processing equipment, product cleaning and collection equipment, electricity generation equipment, ash and waste storage space, water for steam and cooling, and emissions control equipment. Heavy equipment would be required to clear vegetation, grade the site level, excavate several areas and erect structures. Access road to the site exist but would need to be evaluated to determine sufficiency of both the route, width, grade, surface material, and access points from public roads necessary to accommodate tractor-trailer trucks weighing up to 40 tons. An access road from the north sub-station to the site exists but would need to be evaluated to determine sufficiency of the width, grade, surface material and government-controlled access point necessary to accommodate maintenance of appropriate utilities infrastructure and emergency response vehicles. Perimeter fencing separating the facility site from the rest of the installation would require a 20-foot stand-off. An access gate to the facility site from a public road would be controlled by the developer. A gate providing access control to the rest of the installation directly from the facility site would be for limited government use (e.g., emergencies, etc.). Construction would require the developer to attain any required permits prior to beginning and should be expected to take 12-18 months for completion. Dust and noise levels would be temporarily elevated during construction, requiring the use of best management practices by the developer to mitigate impacts.

3.2. Electrical Tie-In

The facility would tie in to both USAG Fort Drum substations. Upgrades would be required to the both substations and transmission lines to ensure that power could be directed to USAG Fort

Drum. The approximate distance from the Greenfield Site to the north substation (substation #2) is approximately 1.5 miles and the transmission line that would need to be constructed is expected to approximately follow the path designated on Figure 3-1. The approximate distance from the Greenfield Site to the south substation (substation #1), dependent on route, is approximately 3.5 to 4.4 miles and would be accomplished through a combination of new-construction transmission lines and upgraded transmission lines. There are a number of alternative paths that may be taken to accomplish the tie-in to the south substation but the EA support contractor will be expected to analyze no more than six optional routes, some of which may be above-ground and some of which may be buried. One of the south substation tie-in route options include following the same route as the proposed water and wastewater lines depicted on Figure 3-1. National Grid approval would be required to interconnect at both substations, with installation of an isolating switch operated by National Grid to assure isolation when the emergency supply is operational.

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Figure 3-1. Select Parameters of the Proposed Action (Greenfield Site)

3.3. Water and Sewer Tie-In

The facility would tie in to USAG Fort Drum’s existing water and sewer system, with the proposed new-construction route including undeveloped land, as depicted on Figure 3-1 above.

Current maximum size of water line, along Iraqi Freedom Drive, which could connect to the

Greenfield site is 20 inches. Fire security at the proposed biomass facility would require delivery of 3 - 4,000 gallons of water per minute (20-24-inch lines).

3.4. Operations and Maintenance

The biomass facility would be operated 24 hours per day, seven days per week by crews on a staff of approximately 40 people required to operate the facility. Approximately 33 tractor-trailer trucks per day would be expected to transport feedstock (biomass fuel) to the facility. The loaded tractor-trailers would be expected to weigh up to 40 tons. An additional two to three tractor-trailer trucks per day would also be required to transport ash and non-combustible material from the facility for disposal in an off-post landfill. The facility operator would be responsible for ensuring no hazardous waste or hazardous material is mixed in with the delivered feedstock so as to adhere to the requirements of 10 USC 2692, which generally

ISOWPP for Ft Drum Biomass EA 15 11 Oct 2012 prohibits the storage or disposal of non-DoD owned toxic or hazardous materials on DoD installations. Egress and ingress to the facility (e.g., by employees and tractor-trailer trucks) would be accomplished through a facility-operated access control point. Operations include feedstock management, in which equipment such as front-end loaders transfer biomass material to conveyors for transport to the boilers. Biomass material could be expected to be approximately 70 percent wood chips and 30 percent New York state approved construction debris (pallets, etc) and alternative biomass facility fuel sources. Biomass wood chips would likely be green material due to higher cost of dried wood chips. Stockpiling of wood chips may be required part of the year as consistent supplies are unlikely to be available year-round. The facility would expect to include on-site storage space for 30 days of feedstock. Material would be combusted in the boiler, creating steam to drive steam turbines (linked to generators to create electricity). Alternatively, gasification technology may be utilized. Gasification is a thermal process in which the feedstock is heated in a starved-oxygen environment, which produces a gas (called synthetic gas, or syngas). Syngas can be combusted in a boiler conditioned for use in an internal combustion engine which can power a generator to create electricity. The facility would average approximately 15 percent down-time for maintenance.

3.5. Estimated Capacity

The biomass facility is anticipated to have a capacity up to 28 megawatts (MW).

3.6. Emissions Control

The facility would be required to be compliant with the Clean Air Act (CAA) and applicable permits. Operation permits would be the responsibility of the facility operator, not USAG Fort Drum.

Nitrogen oxide (NOx): Oxygen in the air combines with nitrogen from the fuel or air to form nitrous oxides. The formation can be mitigated by the design and operation of the combustion unit, including relatively low operating temperatures. Post combustion capture will further minimize NOx emissions through the use of Selective Catalytic Reduction (SCR) and Selective

Non-Catalytic Reduction (SNCR).

Sulfur oxide (SOx): If sulfur is in the feedstock, it is released during combustion. This can be mitigated with limestone into the combustion area.

Carbon monoxide (CO) and volatile organic compound (VOC): Formed as byproducts of incomplete and/or inefficient combustion.

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Particulate matter (PM): Unburned fuel, captured in baghouse fabric filter or electrostatic precipitator.

Carbon dioxide (CO2): Formed from the combustion process, as carbon combines with oxygen from the air. Carbon capture and sequestration technology is in development but there are no commercially-available systems for reduction. CO2 resulting from the biomass feedstock

(organic matter) is considered carbon neutral by the US Environmental Protection Agency

(EPA), as the CO2 emitted is equal to the CO2 absorbed during the life cycle of the organic matter.

3.7. Other Facility Features

The proposed facility is expected to have a vapor plume stack that is approximately 220 feet in height.

4.0 VALUED ENVIRONMENTAL COMPONENT (VEC) ASSESSMENT OF

ENVIRONMENTAL IMPACTS ASSOCIATED WITH ALTERNATIVES

Section 4 of the ISOWPP is to provide a discussion of the impacts anticipated from the implementation of the Proposed Action and alternatives discussed in Section 3. This Section of the ISOWPP is intended to provide the contractor with a starting point with regard to key potential environmental impacts that would require analysis within an environmental assessment (EA) executed in accordance with the National Environmental Policy Act (NEPA) and applicable implementing regulations. A key implementing regulation for NEPA actions at

USAG Fort Drum is 32 Code of Federal Regulations (CFR) 651, Environmental Analysis of

Army Actions.

VECs are categories of environmental and socioeconomic effects where categorization is conducted to enable a managed and systematic analysis of these resources. Affected environment and environmental consequences, to include cumulative effects, would be analyzed, as appropriate, by the VEC categories listed below. Some components of each VEC category are also provided below.

Land Use. Includes types of land use, real property management, easements, viewsheds not addressed under cultural resources.

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Air Quality and Greenhouse Gas (GHS). Includes the CAA, conformity, National Ambient Air

Quality Standards, Prevention of Significant Deterioration, New Source Review, and Minor

Source Preconstruction Permitting.

Noise. Includes noise zones, noise impacts to community, noise impacts to wildlife, risks of noise complaints.

Geology and Soils. Includes bedrock properties, seismology, economically viable minerals, soil series and properties, soil erosion potential.

Water Resources. Includes surface water, groundwater, floodplains, the Clean Water Act

Section 404 permits.

Biological Resources. Includes vegetation, wildlife, threatened and endangered species, Endangered Species Act, the Migratory Bird Treaty Act, the Bald and Golden Eagle Protection

Act, the Marine Mammal Protection Act, the Magnuson-Stevens Fishery Conservation and

Management Act, the Coastal Zone Management Act, invasive species, wetlands, wildland fires.

Cultural Resources. Includes the National Historic Preservation Act, the Archaeological

Resources Protection Act, the Native American Graves Protection and Repatriation Act, State

Historic Preservation Officer consultation, Native American Tribes consultation, National

Register, historic buildings and structures, historic viewsheds.

Socioeconomics. Includes demographics, housing, economic development, public finance, quality of life, environmental justice in minority and low-income populations, protection of children from environmental health risks and safety risks.

Transportation. Includes traffic, roadways, rail transportation, air transportation, traffic volume, level of congestion.

Airspace. Includes controlled airspace, special use airspace, Military Operations Areas.

Utilities. Includes potable water, drinking water plants, wastewater, stormwater, the Clean Water

Act National Pollutant Discharge Elimination System (NPDES) Stormwater Program, NPDES permitting, solid waste, energy, heating, cooling, communications

Hazardous and Toxic Substances. Includes hazardous material, hazardous waste, underground and above ground storage tanks, asbestos, radon, lead based paint, polychlorinated biphenyls

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(PCBs), UXOs, petroleum, oil, & lubricants (POLs), the Emergency Planning and Community

Right-to-Know Act.

4.1. Anticipated Impacts to VECs Under the No Action Alternative

Table 4-1 depicts the Army’s anticipated impacts from the No Action alternative, the baseline condition.

Table 4-1. Anticipated Impacts to VECs Under the No-Action Alternative (Baseline Conditions)

VEC Anticipated Impacts

Land Use Less than significant

Air Quality and GHG Less than significant

Noise Less than significant

Geology and Soils Less than significant

Water Resources Less than significant

Biological Resources Less than significant

Cultural Resources Less than significant

Socioeconomics Less than significant

Traffic and Transportation Less than significant

Airspace Less than significant

Utilities Less than significant

Hazardous and Toxic Substances Less than significant

4.2. VEC Level of Analysis Expected for the Proposed Biomass Facility

The Army’s knowledge of issues, to include knowledge of environmental management and mission operators at USAG Fort Drum is reflected in Table 4-2, the identification of the expected level of analysis needs for the NEPA analysis document’s proposed action. Where the level of further analysis is identified as low, applicable and appropriate summaries of and/or references to prior analyses shall be provided. However, the EA support contractor is expected to apply its

ISOWPP for Ft Drum Biomass EA 19 11 Oct 2012 expertise to determine whether Table 4-2 is correct and comprehensive and, if not, to make any necessary corrections and fill any gaps identified.

The categories expected level of analysis anticipated per category is:

• Very Low: No Impact and it is self-evident that this VEC is not impacted. NEPA analysis should be one paragraph identifying the list of VECs with impacts anticipated as Very

Low.

• Low: No Impact but it is not self-evident that this VEC is not impacted. NEPA analysis should consist of one paragraph for each VEC explaining why the VEC is not impacted.

• Medium: It is not clear that this VEC will be impacted significantly. NEPA analysis should use the Army’s Quick Look Guide (http://aec.army.mil/usaec/nepa/nepa-qlg.pdf). If all of the questions can be answered, no further analysis is necessary; there is no significant impact. Appropriate level of discussions should be included in the EA.

• High: The VEC will be impacted significantly. The Army’s NEPA Analysis Guidance

Manual (http://aec.army.mil/usaec/nepa/nepa-agm.pdf) should be used as a guide for the analysis. Without mitigation, this VEC would likely drive the NEPA analysis to an environmental impact statement (EIS).

If the EA analysis concludes that the impacts of executing the proposed action are anticipated to be less than significant for each VEC, then USAG Fort Drum Garrison Commander may make a

Finding of No Significant Impact (FNSI) determination.

Table 4-2. Anticipated Level of Analysis, by VEC, Required for Proposed Action Alternative

VEC Anticipated Impacts of the Proposed Action (Greenfield Site)

Land Use Low.

• Site used to be an old asphalt plant.

• Site has also served as a contractor staging area for North Post construction activities.

• Site used for military training (e.g. Infantry units).

Air Quality and GHG Medium.

• Fort Drum area is in a moderate non-attainment for ozone.

• Emission analysis would need to cover facility and transport trucks.

• Permitting would be responsibility of power facility owner.

• A diesel fueled generator would expect to be at the facility to enable black start operation should power to the facility be cut.

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ISOWPP for Ft Drum Biomass EA 20 11 Oct 2012

VEC Anticipated Impacts of the Proposed Action (Greenfield Site)

Noise Low.

• Truck noise traffic, Geology and Soils Low.

• Construction permitting would be responsibility of power facility owner.

• Site is relatively level.

Water Resources Low-Medium.

• Process expected to result in high water usage.

• Bedrock aquifer belongs to Fort Drum, flows north.

• Site not in a floodplain.

• Cooling water tower incorporates a closed-loop system. Would be expected to use of city water, and discharge into sanitary sewer.

Biological Resources Medium.

• Facility site is adjacent to a Fort Drum bat conservation area.

• Construction of utilities will impact bat conservation area, running through it. Mitigations would be the responsibility of the facility owner.

• Source of biomass expected to be limited to a 50-mile radius of Fort Drum.

• Wetlands run through the site though should be able to be avoided via site design. Mitigations would be the responsibility of the facility owner.

• Fort Drum timbers 5 - 10,000 acres annually, selling chips to the highest bidder.

• Select construction activities limited for migratory bird protection (15 Apr – 01 Aug) and bat protection (15 Apr – 15 Oct).

Cultural Resources Low.

• A cultural resources site is about 1 mile north and may have viewshed issues from the perspective Tribal Nation review, dependent on height of stack.

• Site has had Phase 1 surveys completed; nothing identified.

• Phase 1 surveys will need to be done for any utility line routes anticipated to occur through undeveloped land.

Socioeconomics Low.

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Traffic and Transportation

Medium.

• Heavy trucks. Source of biomass being transported to site expected to be limited to a 50-mile radius of Fort Drum. Ash would be trucked off-site.

• Access control points (usage, impact to traffic, security considerations). Just south of the proposed site, Gas Alley gate is industrial, not residential, so issues should be minimal.

• Perimeter fencing would be required to control access to and provide security for (1) the site for the facility operator and (2) the rest of USAG Fort Drum. Direct access from the facility site to USAG Fort Drum would be limited and be expected to only support necessary utilities maintenance or emergency response support (emergency response support would most likely arrive via an off-post route).

• Routes 26 and 3 intersection currently at level of service (LOS) F during peak hours.

Routes 26 and Munns Corner intersection (access to Wheeler Army Airfield) at LOS F during peak hours.

• Gas Alley Gate at LOS F during peak hours.

• Congestion point at 45th Infantry Division and Route 26.

• 45th Infantry Division (Rock Cut) Gate is open only two times per day.

Public road upgrades and permitting would be responsibility of power facility owner. NY DOT highway permit required for any work on Route 26, including commercial access (e.g., addition of a truck turning lane).

Airspace Medium.

• Vapor plumes from the biomass facility cannot impact US Missile

Defense Agency (MDA) data communications site that is planned for construction south of the proposed site. Analysis by MDA has concluded that impacts of the stack and vapor plume cloud would be less than significant to MDA operations.

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Utilities Medium.

• Infrastructure to support utility requirements would need to be constructed, staying within existing roadways.

• Cooling water tower incorporates a closed-loop system. Would be expected to use city water, and discharge into the sanitary sewer.

• Water, sewer, electricity, gas would likely be expected to be provided by Fort Drum on a reimbursable basis.

• Sewage would need to be pumped out.

• If on-post road access upgraded, firefighters could access in required timeframes. If firefighter access via Route 26, may not be able to meet time requirements. However, USAG Fort Drum has mutual aid agreements with local emergency response departments.

• Current maximum size of water line, along Iraqi Freedom Drive, which could connect to site is 20 inches.

• Fire security would require delivery of 3 - 4,000 gallons of water per minute (20-24-inch lines).

Hazardous and Toxic Substances

Low-Medium.

• Spill response timelines may be of concern. See above regarding firefighter response timelines.

• Potential spontaneous combustion issues (storage area).

• No UXO issues.

• May require a Phase I site assessment as follow-up to test well data from a late 1990s spill on/near site.

• The facility operator would be responsible to ensure that hazardous waste and hazardous material is not brought in with feedstock.

If during the analysis, the NEPA practitioner believes that a different level of analysis is appropriate, the contractor should make the recommendation(s) to the contract officer representative (COR).

5.0 STUDIES REQUIRED:

No studies are anticipated to be required for the direct support of this environmental analysis.

6.0 CONSULTATIONS AND AGENCY COORDINATION:

• US Fish and Wildlife Service (USFWS). Regarding Section 7 of the Endangered Species

Act. Currently there is only one federally-listed species on Fort Drum, the endangered

Indiana bat (Myotis sodalis). The Indiana bat is known to roost and forage on the installation. To be done by The Directorate of Public Works (DPW) Environmental

Division (DPW-E).

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• New York State Department of Environmental Conservation (NYSDEC). Regarding wetlands, threatened and endangered species, soil erosion. On Fort Drum, there are 31 known state-listed wildlife species (5 endangered, 8 threatened, and 18 species of concern). To be done by DPW-E.

• Department of Transportation (state and federal). LOS as related to trucks supporting biomass operations. To be done by DPW-Master Planning.

• State Historic Preservation Office for Section 106 of the National Historic Preservation

Act. To be done by DPW-E as all NYSHPO correspondence to be vetted through the installation’s Cultural Resources Office.

• US Army Corps of Engineers (USACE). Regarding wetlands.

• Local Utilities – National Grid. To be done by DPW-Operations & Maintenance.

• Native American Tribes. For any unsurveyed ground disturbance. Are three Tribal

Nations with whom consultation is required. To be done by DPW-E.

• US Missile Defense Agency. MDA is a tenant on USAG Fort Drum whose mission requirements could be impacted through inappropriate placement of towers, turbines, and other activities with the potential to impact radar.

• Federal Aviation Administration (FAA). Any FAA consultations required (e.g., stack height) would be responsibility of the biomass facility developer.

7.0 EXISTING DOCUMENTS

Documents prepared for and/or by the Army will be provided to the EA support contractor by the government. The below list does not include all relevant documents that may support the EA analysis. It will be the responsibility of the EA support contractor to identify and obtain other relevant documents required to support the EA analysis. Other relevant documents may include those prepared by industry, educational institutions, scientific bodies, and other governmental organizations.

• Environmental Assessment for Construction and Operation of a Soldier and Family Care

Clinic at Fort Drum, NY. Prepared by the DPW-E Natural Resources Branch, Fort Drum, NY. March 2012.

• Environmental Assessment for Conducting a Study of Small Wind Turbines on Fort

Drum, New York. Prepared by DPW-E Natural Resources Branch, Fort Drum, NY. June

2011.

• Integrated Natural Resource Management Plan.

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• Environmental Assessment for Implementing the Integrated Natural Resources

Management Plan (ICRMP) 2011-2015. Prepared by DPW-E Natural Resources Branch, Fort Drum, NY. September 2011.

• Integrated Cultural Resource Management Plan.

• Environmental Assessment for Implementing the Integrated Cultural Resources

Management Plan (ICRMP) 2011-2015, Fort Drum, NY. Prepared by DPW-E Natural

Resources Branch, Fort Drum, NY. August 2011.

• Environmental Assessment for Stationing Actions to Support the Grow the Army

Initiative at Fort Drum, NY. Prepared by the Environmental Planning Branch

Environmental Quality Programs Division, US Army Environmental Command (AEC), San Antonio TX, for the Directorate of Public Works Environmental Division Natural

Resources Branch, Fort Drum, NY. February 2011.

• Fort Drum Economic Impact Statement, Fiscal Year 2009, October 1, 2008 - September

30, 2009. United States Department of the Army. April 2010.

• Environmental Assessment for the Proposed Construction of New Facilities for the 20

ASOS Mission at Fort Drum, New York. Prepared by the DPW-E Natural Resources

Branch, Fort Drum, NY 13602. May 2010.

• Environmental Assessment for the Borrow Pit Facility Fort Drum, New York. Prepared by: AEC, Aberdeen Proving Ground, Maryland, for the DPW, Fort Drum, NY 13602.

January 2009.

• Transportation Plan. As related to the major roads which may be impacted by trucks supporting a biomass power facility. To be provided by DPW-Master Planning

• Traffic Studies. Traffic studies have been done within the last couple of years for both on- and off-post traffic.