Remediation - Engaging Communities, Transforming Properties

CECONY and O&R formerly owned, own, or manage numerous real properties in the greater New York City area. Among these are former electric generation and distribution facilities and former Manufactured Gas Plants (MGPs), that were operated as early as the mid-1800s until the mid-twentieth century to convert coal to gas for lighting, cooking, and other uses prior to the widespread use of electricity and the advent of natural gas pipelines. Due to changes in generation technology, demand, and user distribution, these facilities were relocated, consolidated with other operations, or retired. Properties that have been consolidated or are no longer serving a utility function are available either for re-use for another utility function within the company or may be considered surplus. Surplus property may be divested so that it can serve a new productive function in the community in which it is located. Many former properties, particularly the former MGPs, were divested decades ago prior to the modern era of environmental cleanup standards and regulations.

CECONY and O&R are committed to investigating and remediating impacts from their former operations in a manner that is consistent with the associated properties’ current or anticipated future use and applicable law, while at the same time benefiting the communities where they were located. In support of these commitments and goals, currently or formerly owned utility properties are investigated and remediated as necessary by a dedicated staff of scientists, engineers, and technical experts (the Remediation Group), that has been in place since the early 1990s. The work performed by the Remediation Group has matured into a comprehensive Site Investigation and Remediation (SIR) program that includes a community outreach component as described further below. The SIR program staff lead the company’s efforts to investigate these properties for the presence of historic operations impacts, and if necessary, undertake remediation in close coordination with federal, state, and local regulators. The company develops comprehensive work plans to complete investigations and remediation in accordance with applicable laws, regulations, and cleanup standards. Where possible, we seek to coordinate such activities with third-party redevelopment plans to achieve efficient remedies that repurpose the sites for productive use.

We work diligently to manage the SIR Program in a cost-effective, prudent and regulatorily consistent manner. Towards this goal, Con Edison and O&R prepare and submit required annual reports to the New York State Public Service Commission that present in detail the company’s management of the SIR program. Specifically, these detailed reports describe the measures that the Remediation group takes to manage the SIR program in a manner that is consistent with established administrative and accounting controls as well as regulatory requirements, track the company’s progress in investigating and remediating properties, and provide anticipated cost and schedule projections for the coming year. In addition, on an annual and quarterly basis, the company sets and re-evaluates its financial reserves to account for the reasonably estimable and probable cost projections associated with the rehabilitation of its SIR program sites through investigation and remediation, as applicable.

A robust community outreach effort is a key component of our remediation and redevelopment programs. We meet regularly with property owners, community stakeholders, elected officials, and government agencies to discuss stakeholders’ concerns. Public information sessions, notices, and project updates are critical components of our comprehensive approach. Project milestones and public reports are regularly posted on our MGP web page and in site-specific publicly accessible document repositories within the nearby community. The company also has a dedicated hotline to address community questions, which is particularly helpful during remediation work. Additionally, we seek input from elected officials, non-governmental organizations and local community members in advance of and during remediation planning and implementation stages.

Con Edison’s rehabilitation strategy for properties formerly used for utility operations that the company still owns includes seeking their redevelopment, as appropriate, in support of New York State Climate Leadership and Community Protection Act (CLCPA) sustainability-related initiatives. Such projects include an energy hub to help support renewable energy interconnections, battery storage facilities, and charging stations for electric vehicles. The redevelopment projects entail assessments of existing conditions, remediating identified residual contamination to applicable standards, and construction / installation of new facilities.

To prepare for the sale of real property that is owned by the company but no longer needed, we perform certain activities, including an environmental assessment or investigation, the implementation of remedial action if deemed necessary, and ultimately, formal reclassification to “non-utility” status. The SIR activities identified by the SIR program staff and implemented at the properties are developed to comply with relevant regulatory mandates of minimizing impacts to human health and the environment as appropriate for their use or anticipated use, while at the same time considering benefits to the communities where they are located.

Environmental assessments are typically conducted by our SIR program staff and follows a multi-step process. Initially, data and information are obtained about the history of a property prior to ownership and during the company’s development and operations on the property. Due to the long industrial history of certain parcels, the next stage of assessment often entails site investigation and serves to determine the current environmental conditions. The findings from the assessment or investigation are used to determine what, if any, remedial action may be necessary to render the property suitable for potential sale. These determinations are made based on the intended future use/re-use of the property, land management activities for non-utility properties and applicable regulatory requirements. Decisions regarding remedial actions are typically made in consultation with the New York State Department of Environmental Conservation (DEC) by an integrated company team of technical and management staff, which usually includes senior SIR program staff, Real Estate, Law, Facilities, Community Relations, and Corporate Affairs.

Highlights

Below are some highlights that exemplify our remediation, land use and management activities. The examples listed were implemented during the last five years, with the exception of East 173rd St. MGP, which was completed in 2009.

• A major sustainability project that is underway is the Brooklyn Clean Energy Hub (“BCEH”) that will help facilitate interconnections for third-party off-site renewable clean energy projects (including offshore wind) and enhance CECONY’s electric grid. The site of the BCEH is the former Hudson Avenue Generation Station, which included a steam generation plant, electrical switch house, gas turbine electric generation peaking units, and a Major Oil Storage Facility (MOSF). In addition to the BCEH, the former MOSF was redeveloped as a new electrical substation (Vinegar Hill Substation) to support interconnections and prepare the local grid for increased demand.
• The East 173rd Street MGP Works remedial action completed by CECONY was pivotal in supporting the New York City’s Parks Department redevelopment initiative for Starlight Park (Bronx) for use by the local communities, which included soccer and baseball fields, public green space, and walking and exercise trails. Selection of the remedy entailed a robust community outreach and participation by Bronx River Alliance, a community advocacy group. CECONY worked closely with community groups and NYSDEC to address public concerns.
• In Peekskill, CECONY remediated a portion of a former MGP site located in a growing hi-tech manufacturing community on the city’s waterfront. Contaminated soil was removed from a privately-owned vacant lot, and the subject properties are ready for future development. CECONY is preparing to return to a separate area downgradient from this site to dredge MGP-impacted sediment from the adjacent Peekskill Bay. The dredging project will include the removal of broken-down piers and a sunken barge, enhancing bay access. CECONY solicited and incorporated community input into this clean-up plan, which will enhance the environment and quality of life in the area.

• CECONY has made a positive impact in the waterways in Queens, specifically Flushing Creek. Sediments containing contaminants were successfully excavated from the area of the creek bed adjacent to the former Flushing Industrial Park, which we operated from 1923 to the 1980s. CECONY restored the dredged area with clean granular fill material and received closure from DEC and DOH. Remediation of the creek sediments was conducted in coordination with third-party developer’s substantial high-rise residential redevelopment project.
• In the Bronx, CECONY has been collaborating with the New York City Economic Development Corporation (EDC) on the remediation of a former MGP site located on the Hunts Point peninsula. The former MGP is being remediated through the New York State Brownfield Cleanup Program, parcel by parcel, with EDC constructing storm hardening measures in coordination with the remediation work. The remediated parcels have been and are expected to enhance the use of the peninsula through waterfront greenspace, modernized food distribution centers, and other community-benefiting infrastructure.
• Remedial action was recently completed at the former Port Chester Substation, a non-utility property located in Westchester County. Completion of the remedy represents the final step of the SIR process at this property and allows it to potentially be sold through a competitive bidding process.

Minimizing Impact

In addition, Con Edison actively and routinely assesses current and ongoing operations to identify and implement practices to help minimize impacts to the properties, the environment and surrounding communities. These assessments include periodic reviews of the current processes / activities and management of materials, with a focus on eliminating and reducing waste and identifying, where feasible, more environmentally compatible products used during operations. The following is an example of waste minimization that was put into practice during a remediation/redevelopment initiative:

• Recently, CECONY sought a Beneficial Use Determination (BUD) to support the efficient redevelopment of two properties simultaneously. Its application to the DEC for a BUD entailed the re-classification of surplus soil generated during redevelopment of a non-utility CECONY property located in eastern Queens County (Brinkerhoff property) for use as backfill during remediation/closure of a former Major Oil Storage Facility (MOSF) located in Brooklyn (Hudson Avenue Generation Station). DEC approved the BUD application. Re-use of the soil both avoided the need to transport and dispose of clean material from the Brinkerhoff property at landfills and benefitted the Hudson Avenue MOSF closure by substantially reducing the number of truck miles (and associated emissions) that would have been needed had backfill been procured from a distant clean fill source. This also reduced the cost of soil backfill necessary for redevelopment of the former MOSF as a new electrical substation.

As a complement to its waste reduction initiatives and as a proactive measure to support responsible waste management and help limit potential future liabilities, CECONY has developed a robust program to regularly review and assess the treatment, storage, and disposal facilities (TSDFs) to which it sends its wastes. This program entails obtaining and reviewing the TSDFs’ operating permits; records associated with the past performance of each facility to help identify performance issues or violations; financial records; and changes in operational process(es), as well as physical inspections of the TSDFs. These reviews and assessments are used to develop and maintain a comprehensive list of Con Edison-approved TSDFs that must be used for waste management activities throughout CECONY during the course of business operations, including all its contractors and subcontractors.

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