NATIONAL ENVIRONMENTAL POLICY ACT
ENVIRONMENTAL ASSESSMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
PROPOSED SOLAR PHOTOVOLTAIC SYSTEM AT THE
EPA EDISON FACILITY
EDISON, NEW JERSEY
U.S. Environmental Protection Agency
Facilities Management and Services Division
Architecture, Engineering, and Asset Management Branch
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
AUGUST 2009
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
1.0.
2.0.
3.0.
4.0.
5.0.
6.0.
TABLE OF CONTENTS
PURPOSE AND NEED
.1. THE ENVIRONMENTAL ASSESSMENT
2 EDISON FACILITY DESCRIPTION AND VICINITY
.3. THE EDISON FACILITY MISSION
4 THE PROPOSED ACTION
5 PURPOSE AND NEED
DESCRIPTION OF THE PROPOSED ACTION
2.1. PROPOSED ACTION
2 2 SITE ALTERNATIVES
2.3. COMBINED ALTERNATIVE
2.4. No ACTION ALTERNATIVE
2 5 ALTERNATIVE SITES ELIMINATED FROM CONSIDERATION
AFFECTED ENVIRONMENT
3.1. GROUND RESOURCES
3 2 WATER RESOURCES
3 3 AIR QUALITY
3.4. BIOLOGICAL RESOURCES
3 5 CULTURAL RESOURCES
3 6 NOISE
3.7. VISUAL RESOURCES
3 8 LAND USE
3.9. HUMAN HEALTH AND SAFETY
3.10. UTILITIES AND INFRASTRUCTURE
3 11 WASTE MANAGEMENT
3.12. TRANSPORTATION AND PARKING
3.13. SOCIOECONOMICS
314 ENVIRONMENTAL JUSTICE & PROTECTION OF THE CHILDREN
ENVIRONMENTAL CONSEQUENCES
4.1. GROUND RESOURCES
4 2 WATER RESOURCES
4 3 AIR QUALITY
4.4. BIOLOGICAL RESOURCES
4 5 CULTURAL RESOURCES
4.6. NOISE
4.7. VISUAL RESOURCES
4 8 LAND USE
4.9. HUMAN HEALTH AND SAFETY
4.10. UTILITIES AND INFRASTRUCTURE
411 WASTE MANAGEMENT
4.12. TRANSPORTATION AND PARKING
4 13 SOCIOECONOMICS
414 ENVIRONMENTAL JUSTICE & PROTECTION OF THE CHILDREN
CUMULATIVE IMPACTS
FINDINGS & CONCLUSION
6.1. FINDINGS: IMPACT ANALYSIS
6.2. CONCLUSIONS: MITIGATION ACTION SUMMARY
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
7.0. REFERENCES 58
8.0. AGENCIES & PERSONS CONSULTED 62
9.0. LIST OF PREPARERS 62
LIST OF FIGURES
FIGURE 1.2-1: EDISON FACILITY VICINITY MAP 2
FIGURE 1.2-2: EDISON FACILITY CAMPUS MAP 3
FIGURE 2.1-1: EDISON FACILITY CAMPUS MAP WITH PROPOSED SPVS LOCATIONS 7
FIGURE 2.2-1: AERIAL VIEW OF SITE 1 9
FIGURE 2.2-2: AERIAL VIEW OF SITE 7 10
FIGURE 2.5-1: EDISON FACILITY SPVS ALTERNATIVE SITES 11
FIGURES.7-1: AERIAL VIEW AND SURF ACE VIEW (TO THE EAST) OF SITE 1 21
FIGURE 3.7-2: AERIAL VIEW AND SURF ACE VIEW (TO THE SOUTHEAST) OF SITE 7 21
FIGURE 4.7-1: AERIAL AND SURFACE RENDERING OF THE PROPOSED SITE 1 42
LIST OF TABLES
TABLE 2.2-1: COMPARISON OF POTENTIAL SPVS LOCATIONS 10
TABLE 3.4-1: ENDANGERED AND THREATENED ANIMAL SPECIES FOR MIDDLESEX COUNTY 17
TABLE 3.4-2: ENDANGERED AND THREATENED PLANT SPECIES FOR MIDDLESEX COUNTY 18
TABLE 3.6-1: EDISON NOISE STANDARDS (EDISON, 1999) 20
TABLE 4.3-1: EQUIPMENT MODELED FOR AIR QUALITY ANALYSIS 35
TABLE 4.3-2: CONSTRUCTION AIR QUALITY EMISSIONS (TONS) 36
TABLE 4.3-3: DISMANTLING AIR QUALITY EMISSIONS (TONS) 36
TABLE 4.3-4: OPERATIONS & MAINTENANCE AIR QUALITY EMISSIONS (TONS) 37
TABLE 4.3-5: ANNUAL EMISSION SAVED USING RENEWABLE ENERGY SOURCE (TONS) 37
TABLE 4.8-1: HEAVY EQUIPMENT NOISE LEVELS 40
TABLE 5.0-1: EDISON FACILITY PROJECTS 53
LIST OF APPENDICES
APPENDIX A: PHOTOGRAPHS OF THE EDISON FACILITY A-l
APPENDIX B: AIR QUALITY COMPUTATIONS B-l
APPENDIX C: PUBLIC AGENCY COORDINATION AND CONSULTATION C-l
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ACRONYMS & ABBREVIATIONS
AC Alternating current
ACHP Advisory Council on Historic Preservation
ACM Asbestos-containing material
AEAMB Architecture, Engineering, and Asset Management Branch
AIHA American Industrial Hygiene Association
ANSI American National Standards Institute
AOC Areas of concern
APE Area of Potential Effect
AST Aboveground storage tank
ATSDR Agency for Toxic Substances and Disease Registry
BERA Baseline Ecological Risk Assessment
BLM Bureau of Land Management
BMP Best management practice
BNL Brookhaven National Laboratory
CAA Clean Air Act
CEQ [US] Council on Environmental Quality
CFR Code of Federal Regulations
CO Carbon Monoxide
CO2 Carbon Dioxide
CX Categorical Exclusion
CWA Clean Water Act
dB Decibel
dBA A-weighted Decibel
DC Direct current
DEP Department of Environmental Protection
DESC Defense Energy Support Center
DLA Defense Logistic Agency
DOE [US] Department of Energy
DOT [US] Department of Transportation
EA Environmental Assessment
ECOS Environmental Conservation Online System
EDR Environmental Data Resources, Inc.
EIS Environmental Impact Statement
EISA Energy Security and Independence Act
EMS Environmental Management System
EO Executive Order
EPA [US] Environmental Protection Agency
EPAct 2005 Energy Policy Act of 2005
EPCRA Emergency Planning and Community Right-to-Know Act
ESA Endangered Species Act
FAQ Frequently Asked Question
FEMA Federal Emergency Management Agency
FNSI Finding of No Significant Impact
FIRM Flood Insurance Rate Map
FWCA Fish and Wildlife Coordination Act
FWS [US] Fish and Wildlife Service
FY Fiscal Year
GAO Government Accountability Office
in
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GSA General Service Administration
HABS Historic American Building Surveys
HAER Historic American Engineering Record
HUD Housing and Urban Development
HRMP Historic Resources Management Plan
IPP Independent Power Producer
kVA kilovolt ampere
kW kilowatt
kWh kilowatt-hours
LQG Large quantity generator
MAP Metropolitan Architects and Planners, Inc.
MCUA Middlesex County Utilities Authority
MNA Monitored natural attenuation
MO A Memorandum of Agreement
MSL Mean sea level
NAAQS National Ambient Air Quality Standards
NCSS National Cooperative Soil Survey
NEPA National Environmental Policy Act
NESC National Electrical Safety Code
NFG Nationwide Facilities Guide
NHP [New Jersey] Natural Heritage Program
NJ New Jersey
NJAC New Jersey Administrative Code
NJDEP New Jersey Department of Environmental Protection
NJFO New Jersey Field Office
NOAA National Oceanic and Atmospheric Administration
NOX Nitrous dioxide
NPC Noise Pollution Clearinghouse
NPDES National Pollution Discharge Elimination System
NRCS Natural Resources Conservation Service
NREL [US Department of Energy] National Renewable Energy Laboratory
O3 Ozone
OHRC Occupational Health Resource Center
OPA Oil Pollution Act
ORD Office of Research and Development
OSHA Occupational Safety and Health Administration
OSWER Office of Solid Waste and Emergency Response
PA Programmatic Agreement
Pb Lead
PCB Polychlorinated biphenyl
PHS Public Health Service
PL Public Law
PM Particulate Matter
POL Petroleum, Oil, Lubricant
PPA Power Purchase Agreement
PPE Personal protective equipment
PSE&G Public Service Electric and Gas
PV Photovoltaic
RCRA Resource Conservation and Recovery Act
REC Renewable energy certificate
RFP Request for Proposal
IV
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SDWA Safe Drinking Water Act
SHEM Safety, Health, and Environmental Management
SHEMD [US Environmental Protection Agency] Safety, Health, and Environmental Management
Division
SHPO State Historic Preservation Office
SIP State Implementation Plan
SO2 Sulfur Dioxide
SWM Storm Water Management
SPCC Spill Prevention, Control, and Countermeasures
SPVS Solar Photovoltaic System
TCE Trichloroethylene
US United States
USAGE United States Army Corps of Engineers
U.S.C. United States Code
USCB United States Census Bureau
USDA United States Department of Agriculture
USGS United States Geological Survey
UST Underground storage tank
UXO Unexploded ordnance
VOC Volatile organic compound
WMA Wildlife Management Area
WMP Water Management Plane
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
1.0. PURPOSE AND NEED
1.1. THE ENVIRONMENTAL ASSESSMENT
This Environmental Assessment (EA) was prepared in accordance with the National
Environmental Policy Act (NEPA) (42 United States Code [U.S.C.] §§ 4321, et. seq.), the
Council on Environmental Quality (CEQ) Regulations for NEPA (40 Code of Federal
Regulations [CFR] 1500 - 1508), the United States (US) Environmental Protection Agency's
(EPA) Procedures for Implementing the National Environmental Policy Act and Assessing the
Environmental Effects Abroad of U.S. Environmental Protection Agency Actions (40 CFR Part
6), and current EPA guidance and policy. The purpose of this EA is to assess whether the
Proposed Action would pose a potential significant impact on the environment and to determine
whether an Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FNSI)
is required for the Proposed Action.
1.2. EDISON FACILITY DESCRIPTION AND VICINITY
The EPA's Edison Facility is a campus of laboratories and offices in Edison, New Jersey
(hereafter referred to as the Edison Facility), located 30 miles south of New York City in the
southeast portion of Edison Township at 2890 Woodbridge Avenue. The Edison Facility is
accessible from Woodbridge Avenue (Route 514), which is in close proximity to the New Jersey
(NJ) Turnpike, Garden State Parkway, and Routes 1 and 287. The Edison Facility resides on a
205-acre parcel consisting of 20 permanent buildings and numerous temporary trailers, including
laboratories, administrative offices, storage buildings, and guard houses. The 205 acres were
historically part of the US Army Raritan Arsenal.
Middlesex County College on the west, Raritan Center on the south and east, and Woodbridge
Avenue on the north surrounds the site. A residential area lies across Woodbridge Avenue to the
North and the Raritan River lies beyond the Raritan Center to the south.
Figure 1.2-1 includes an aerial map showing the Edison Facility and its vicinity, while Figure
1.2-2 shows the layout of the Edison Facility Campus. Photographs of the Edison Facility are
included in Appendix A.
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Former Raritan
Arsenal Boundary
State of New Jersey
i-Map Service
Figure 1.2-1: Edison Facility Vicinity Map
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Figure 1.2-2: Edison Facility Campus Map
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
1.3. THE EDISON FACILITY MISSION
The Edison Facility supports the activities of several national and regional EPA organizations.
These organizations include the following:
Region 2 Division of Environmental Science and Assessment
Region 2 Division of Emergency and Remedial Response
Region 2 Division of Enforcement and Compliance
Region 2 Pesticides and Toxic Substances Program
Office of Research and Development (ORD), Urban Watershed Management Branch
Office of Solid Waste and Response (OSWER), Environmental Response Team East
The Edison Facility also houses components of the Federal Emergency Management Agency
(FEMA), the Agency for Toxic Substances and Disease Registry (ATSDR), the Public Health
Service (PHS), and the General Services Administration (GSA).
The Edison Facility provides comprehensive analytical support data for enforcement, compliance
assistance, and monitoring of Superfund sites, coastal waters, several Brownfield sites, and three
nationally recognized estuaries in New York, New Jersey, Puerto Rico, and the US Virgin
Islands. The Edison Facility also supports emergency response operations, Superfund removal
actions, pesticide and toxic substances enforcement, laboratory data quality assurance and
quality control, field monitoring and sampling, and helicopter operations.
The Edison Facility has been at the forefront of EPA's response to the environmental
emergencies in the New York City metropolitan area. EPA deployed its rapid response team to
the World Trade Center attack from the Edison Facility. The Edison Facility's location in the
New York City metropolitan area and its proximity to several major highways allow it to serve
as a critical staging area for collaboration with multiple agencies involved in disaster mitigation
efforts. Its location and unique national and regional response expertise and laboratory
capability make it a valuable resource in the Agency's Homeland Security and counter-terrorism
activities. (EPA Nationwide Facilities Guide [NFG], 2009).
1.4. THE PROPOSED ACTION
EPA is proposing to lease a portion of their Edison Facility property to an Independent Power
Producer (IPP) for a 10-year term, with a 10-year lease renewal option, to build and operate a
solar photovoltaic system (SPVS) or solar panel array. The IPP would be solely responsible for
the cost of construction, operations and maintenance, and the dismantling of the SPVS when the
lease expires. The IPP and EPA would enter into a Power Purchase Agreement (PPA). The PPA
would set a price per kilowatt-hour (kWh) for the electricity generated by the SPVS, and Edison
Facility would agree to purchase the energy generated from the SPVS to meet the facility's
energy demands. The Edison Facility would benefit by having a set price for the electricity
supplied by the SPVS. Power generated by the SPVS that is in excess of the Edison Facility
needs could be provided to the common grid and sold to benefit the IPP.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Although Edison Facility would purchase the energy generated by the SPVS, the solar array
would not be directly tied to the Edison Facility. The local utility, Public Service Electric and
Gas (PSE&G), would connect it to the utility grid. The electricity generated by the SPVS would
offset, in whole or in part, the electrical needs of the Edison Facility for the foreseeable future.
When the lease agreement expires, the dismantling and removal of the SPVS will be required.
The IPP selection process and the SPVS technical specifications and details will be determined
and fully defined through a competitive bidding process scheduled to begin later this calendar
year.
1.5. PURPOSE AND NEED
Within the past several years, costs and demand for energy produced through fossil fuel
resources, such as crude oil and natural gas, have increased dramatically. In response to this,
Congress passed the Energy Policy Act of 2005 (EPAct 2005). Among the many energy
conservation measures, EPAct 2005 directs the federal government to use more renewable
energy, with a goal of using 7.5% of the EPA's total utility usage or more as renewable energy
by 2013. Solar power is among the renewable energy sources promoted in EPAct 2005. In
addition, the Energy Security and Independence Act (EISA) of 2007 specifies targets for energy
efficiency and fossil fuel use reduction by federal facilities. Specifically, new federal buildings
should be designed so that they are "carbon-neutral" by 2030.
The SPVS would provide the Edison Facility with a cost-efficient renewable energy source that
would offset energy requirements for years into the future while meeting federal government
renewable energy directives in EPAct 2005 and EISA.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
2.0. DESCRIPTION OF THE PROPOSED ACTION
As stated previously in Section 1.4, the EPA proposes to lease a portion of the Edison Facility
property to an IPP to build and operate an SPVS or solar panel array. This section will describe
the components of the Proposed Action including the leasing action, electrical connectivity,
construction, operations and maintenance, and dismantling of the SPVS. For the purposes of this
analysis, the terms IPP and contractor are interchangeable.
2.1. PROPOSED ACTION
2.1.1. Leasing Action
EPA enlisted the assistance of the Defense Logistic Agency's (DLA's) Defense Energy Support
Center (DESC) for the leasing and contracting process. DESC will publish a Request for
Proposal (RFP) that will be circulated publicly. The RFP would request IPPs to develop a
proposal for the leasing, construction, maintenance and operation, and dismantling of an SPVS.
EPA anticipates, and DESC has concurred, that the construction, operation and maintenance, and
dismantling of such an SPVS would be consistent with similar projects around the country. The
IPP would be required to obtain all necessary federal, state, and local permits and comply with
EPA policy directives, instructions, memoranda, and all applicable Edison Facility
environmental plans.
2.1.2. SPVS and Electrical Connections to the Utility Grid
Depending on the location(s) selected on the Edison Facility campus and the type of solar arrays
chosen (e.g., fixed or tracking arrays) for the development of the SPVS, the SPVS could generate
between 966 to 4,646 kilowatts (kW) of solar power. The power produced by the solar panels
would be approximately 400 Volts Direct Current (DC). Inverters would be used to transform
DC to Alternating Current (AC) and transformers would be installed to step up voltage to the
required 480 volts to tie into the electrical utility grid. (EPA, Photovoltaic [PV] Feasibility
Assessment, 2008).
Overhead lines would be utilized for an SPVS located near the power grid. Overhead and
potentially underground utility power lines would be necessary for an SPVS located some
distance away. To protect the integrity of the system during electrical failures and lightning
strikes, the installation of a 15-kilovolt ampere (kVA) combination fused cutout/lightning
arrestor is anticipated at all locations where the SPVS connects to the electrical infrastructure.
The purpose of the arrestor would be to shut down the SPVS immediately if there is a main
power system failure.
It is anticipated that the power produced from the SPVS would offset most of (and possibly all)
the energy needs of the Edison Facility. Electric meters would be placed at each location where
the SPVS connects to the power grid. The meters would record the total electrical demand on
the solar panels and Edison Facility power consumption. There would be potential for the
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production of excess power, in particular during weekends when electrical power demand of the
Edison Facility is less than the amount of energy produced by the solar panels. The IPP would
have the right to sell this power. The SPVS would not produce power at night and would not
have any storage capabilities.
2.1.3. SPVS Installation
This EA analyzes two locations where an SPVS could be installed, hereafter referred to as Site 1
and Site 7. Figure 2.1-1 shows the general layout of the Edison Facility and the proposed SPVS
locations at Site 1 and Site 7. Site 1 is comprised of open, landscaped ground and would require
the solar panels to be embedded into the ground with concrete footings (see Section 2.2.1 for
more on Site 1). Site 7 contains warehouses and the solar panels would be embedded into
existing slab foundation (see Section 2.2.2 for more on Site 7). Photos of Site 1 and Site 7 can be
found in Appendix A.
Figure 2.1-1: Edison Facility Campus Map with Proposed SPVS Locations
Source: (EPA Metropolitan Architects and Planners [MAP], 2003)
It is anticipated that lines connecting the SPVS to the main grid circuits would utilize existing
overhead lines or be placed underground in trenches that could be as deep as three feet. Where
these underground lines run under roadways, trenches might be filled with concrete. Following
placement of the line in an underground trench, the line would be covered with earth and the
disturbed areas would be graded to maintain current drainage patterns.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
The project area would require a staging area for solar panel assembly. Clearing and grading of
the land and potential trenching activities would require heavy equipment. It is anticipated that
heavy equipment use would not last more than 30 days. Most of the construction process would
be the installation of the solar panels, which could last as long as 45 days.
2.1.4. Operation and Maintenance
A security fence with a gate would enclose the entire SPVS. Operation and maintenance of the
SPVS would be the responsibility of the IPP. The efficiency of the panels is dependent upon
their cleanliness. As a result, the contractor would conduct regular inspections of the SPVS and
would clean as needed via pressure washing with water or blowing compressed air. (VanGeet,
2009). However, cleaning activities would likely be infrequent based upon frequent precipitation
events in New Jersey. Additionally, panels that break or malfunction would require repair or
replacement. All maintenance activities would occur on an as-needed basis and would not
require the use of any heavy equipment.
2.1.5. Dismantling of the SPVS
At the end of the lease, the contractor would dismantle and remove the SPVS. An SPVS
installed on an open area would require surface restoration. If an SPVS is installed upon an
existing foundation structure, then the contractor would remove all evidence of the solar panels
and would leave the foundation intact. It is anticipated that the dismantling of the SPVS would
take approximately 45 days.
2.2. SITE ALTERNATIVES
At this time, there is no preferred site for the SPVS. The Edison Facility has undergone previous
evaluations in feasibility studies to determine the potential for cost-effective photovoltaic
installations at the Edison Facility Campus. As a result of these analyses and consultation with
EPA personnel, two sites, Site 1 and Site 7, were chosen as possible locations for the
construction and operation of the proposed SPVS. The following discussion presents three
reasonable site alternatives, Site 1, Site 7, and both Sites 1 and 7. Other site alternatives
eliminated from further consideration are discussed in Section 2.3.
2.2.1. Sitel
Site 1 is located in an open field along Woodbridge Avenue. There are two rows of newly
planted trees between Woodbridge Avenue and Site 1. The site is an open field approximately
3.5 acres in size, of which approximately 2.5 acres would be available for the SPVS. Since this
site is an open grassy area, the construction of the SPVS would require the installation of
concrete footings. The solar panel modules would be installed at an approximate 40-degrees tilt,
facing due South, away from the road. While the local electrical utility transmission lines are
readily available within 25 feet, connection to the grid at 480 Volts would require the installation
of a step-up transformer. Figure 2.2-1 shows two aerial views of Site 1: the first, on the left,
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shows the site highlighted in yellow, relative to the Edison Facility; the second shows a closer
aerial view of the proposed location.
Figure 2.2-1: Aerial View of Site 1
2.2.2. Site?
Site 7 is made up of two large, underutilized warehouses, which are in a state of disrepair
(Buildings 245 and 256). Site 7 is located on the southern boundary of the Edison Facility
grounds and is on level ground surrounded on three sides by rising terrain. Site 7 is not visible
from the surrounding areas due to the high-rising ground around the site and surrounding tree
cover and underbrush. To the northwest of Site 7 is the Middlesex County College. The other
sides of the site are wetlands and other industrial areas associated with the Raritan Center. The
current standing warehouses would be demolished and the SPVS would be constructed on the
remaining slab foundation. Again, the fixed solar panel modules would have an approximate 40-
degrees tilt, facing due South. This site may connect to existing utility lines located
approximately 40 feet from the site, or, if inadequate, may require the installation of new utility
lines on existing poles or through an underground utility conduit (i.e., trenches). As with Site 1,
connection to the grid at 480 volts would require a step-up transformer. Figure 2.2-2 shows two
aerial views of Site 7: the first, on the left, shows the site highlighted in yellow, relative to the
Edison Facility; the second shows a closer aerial view of the proposed location.
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Figure 2.2-2: Aerial View of Site 7
2.2.3. Site Comparison
Table 2.2-1 presents the potential power generating capability of the site alternatives considered.
A power density of 0.92 kW/100 square feet (ft2) was used based on the highest efficiency fixed
solar array modules available tilted at 40 degrees and facing due south. The power generation
for the sites is DC and would be converted to AC to be compatible for the local power grid.
Table 2.2-1: Comparison of Potential SPVS Locations
PV System Area Power Rated System Rated System Annual
Location Available Density Capacity Capability Production
(sqfeet) (kW/100ft2) (kW/DC) (kW/AC) (kWh)
Sitel
Site?
Both Sites
105,000
400,000
505,000
0.92
0.92
0.92
966
3,680
4,646
725
2,760
3,485
1,587,750
6,044,400
7,632,150
Notes: kW - Kilowatt. DC = Direct Current. AC = Alternating Current kWh = Kilowatt Hour
(DOE, 2008), (EPA, PV Feasibility Assessment, 2008)
In 2007, the Edison Facility was billed for 4,714,656 kWh of electrical use, and in 2008, it was
billed for 4,702,067 kWh. (Snyder, 2009).
2.3. COMBINED ALTERNATIVE
A third possible alternative is to construct and operate an SPVS at both Sites 1 and 7. The
decision to develop both Sites 1 and 7 would be made by the IPP in determining the most
economically viable project at the Edison Facility. It is assumed for the purposes of this EA that
construction and dismantling activities at the sites would occur sequentially (i.e., not
simultaneously) and that operation and maintenance activities would occur concurrently, with
both Sites 1 and 7 operational at the same time.
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2.4. No ACTION ALTERNATIVE
Under the No Action Alternative, the SPVS would not be installed on the Edison Facility
grounds nor would there be the creation of a renewable energy source. The current grid supplied
energy source would continue to supply power to the Edison Facility. It is likely that power rates
would continue to increase, and the Edison Facility would continue to consume non-renewable
resources until implementation of EPA energy conservation goals and alternative methods of
meeting the requirements of the Energy Policy Act of 2005.
2.5. ALTERNATIVE SITES ELIMINATED FROM CONSIDERATION
Five other sites were considered as possible SPVS siting locations but due to limiting
characteristics and other land use constraints were eliminated from further consideration. The
locations of these sites are shown in Figure 2.5-1.
Figure 2.5-1: Edison Facility SPVS Alternative Sites
The sites considered but rejected for further study include the following:
Site 2: Site 2 is the existing site of an experimental green parking lot adjacent to the main
roadway, Bonhamtown Road, in the Edison Facility. EPA's Facilities Management and
Services Division along with EPA' s Office of Water and EPA's Pollution Prevention
Office have sponsored this experiment using a special type of porous asphalt. Utilizing
the area for an SPVS at this location would interfere with the experimental site. Upon
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
consultation with the pilot project stakeholders, this site was eliminated from further
consideration. (Amon, 2009; Swanhorst, 2009; Pernice, 2009; EPA, PV Feasibility
Assessment, 2008).
Site 3: Site 3 is the roof of Building 212. The building would need a new roof
membrane prior to construction of any solar project development. Installing a new roof
on a building of this age would be cost-prohibitive and not in line with the master
planning process for the site. Upon consultation with the EPA headquarters master
planning group, Region 2 facilities management group, and the local facilities
management group, this site was eliminated from further consideration. (Amon, 2009;
Swanhorst, 2009; Pernice, 2009; EPA, PV Feasibility Assessment, 2008).
Site 4: Site 4 is an open field east of Bonhamtown Road. The site is currently being
used to store building demolition materials once located on the Edison Facility. This site
is also being considered as a location for future new laboratory facilities; therefore, upon
consultation with the EPA headquarters master planning group, Region 2 facilities
management group, EPA programs site personnel, and the local facilities management
group, this site was eliminated from further consideration. (Amon, 2009; Ridge, 2009;
Lee, 2009; Swanhorst, 2009; Pernice, 2009).
Site 5: Site 5 is a small field west of Pershing Avenue located in a wooded area with a
step-in elevation. This site would require extensive tree and vegetative clearing and is
also considered for future new laboratory expansion; therefore upon consultation with the
EPA headquarters master planning group, Region 2 personnel, the EPA programs site
personnel, and the local facilities management group, the site was eliminated from further
consideration. (Amon, 2009; Ridge, 2009; Lee, 2009; Swanhorst, 2009; Pernice, 2009).
Site 6: Site 6 is located outside the Edison Facility fenced area and consists of old
building structures. The site is located across a set of raised railroad tracks on the west
side of the Edison Facility. This site has encumbered access due to the raised railroad
tracks and lacks site security. In addition, a solar program consultant from the
Department of Energy (DOE) advised EPA that this site has limited access to existing
utility lines and would, therefore, be less economically viable for a PPA. For the
foregoing reasons, the site was eliminated from further consideration. (Amon, 2009;
Ridge, 2009; Lee, 2009; Swanhorst, 2009; Pernice, 2009).
Additional sites: The DOE solar program consultant selected and analyzed the above
sites upon conferring with EPA site and headquarters facility management personnel. The
sites analyzed are the most viable and economical sites available within the Edison
Facility campus based on the recommendation and experience of the DOE consultant.
Though the Edison Facility has numerous other open spaces and buildings, DOE
recommended and analyzed the above five sites, in addition to Site 1 and Site 7, based on
numerous PPA factors .
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
3.0. AFFECTED ENVIRONMENT
The affected environment studied and addressed in this EA focuses on the current environmental
resources that could be affected by the Proposed Action at the Edison Facility and its
surrounding areas. It was determined that the following areas and resources have the potential to
be affected by the Proposed Action and are discussed to determine the presence of significant
impacts.
Data sources reviewed for the affected environment include government documents from federal
entities, the State of New Jersey, Middlesex County, and Edison Township; communications and
interviews with Edison Facility staff and personnel; Environmental Data Resources, Inc.
(EDR) reports, and field reconnaissance conducted on April 16 and May 28, 2009 of the Edison
Facility campus and surrounding areas.
3.1. GROUND RESOURCES
3.1.1. Geology
EPA's Edison Facility is located in the Coastal Plain physiographic province, approximately 0.25
mile southeast of the fall line, the geographical demarcation between the Coastal Plain and the
Piedmont physiographic provinces. Specifically, the Edison Facility is underlain by the Coastal
Plan sediments that make up the recently deposited Raritan formation. (NJDEP i-Map).
The Raritan Formation overlies the Passaic formation of the Newark Basin, representing the
beginning of a series of major transgressions and regressions of the seas during Cretaceous time.
The Raritan was formed during a period of transgression (sea level rise), which created a
progradational alluvial plain, consisting of clay, sand, lignite, and gravels deposited in coastal
and near shore marine environments. Subdivided units within the formation include the Raritan
Fire Clay, Farrington Sand Member, Woodbridge Clay Member, Sayreville Sand Member, and
South Amboy Fire Clay Member (oldest to youngest, respectively). (USGS, 2003).
3.1.2. Topography
The Edison Facility is topographically level. According to the U.S. Geological Survey (USGS)
quadrangle map (South Amboy, New Jersey, 1995), Site 1 is located at an elevation of
approximately 100 feet above mean sea level (MSL), and Site 7 is located at an elevation of
approximately 60 feet above MSL. The prevailing aerial topography of the Edison Facility and
surrounding areas slopes gently southeast, toward the Raritan River. (EDR Report, 2009).
During original development activities, these two sites were graded as level. No swales, pits, or
other irregular topography is located on either of the proposed sites.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
3.1.3. Soils
The U.S. Department of Agriculture (USD A) Natural Resources Conservation Service (NRCS)
leads the National Cooperative Soil Survey (NCSS) and is responsible for collecting, storing,
maintaining, and distributing soil survey information for privately owned lands in the United
States. According to NRCS mapping, both of the proposed sites and much of the Edison Facility
is mapped as Urban Land, which is a designation for areas mostly covered with pavement,
concrete, buildings, or otherwise compacted or disturbed soils. Soils mapped in the surrounding
site area, which most likely make up the soils on the Edison Facility, are typified by clays, sandy
soils, loams, and gravel deposits. The Edison Facility is not in an area considered to be "prime
farmland" and mineral resources are not known to exist in the noted soil unit. (USDA NRCS,
Web Soil Survey). Historical mining operations in the vicinity of the proposed sites have
included limited gravel and clay mining operations.
3.2. WATER RESOURCES
3.2.1. Surface Water
According to USGS mapping, no surface water features are mapped on the Edison Facility
property. Wetlands are mapped on the southeastern corner of the Edison Facility, but no
wetlands are present at the proposed site locations. The wetland drains across the southeastern
property boundary through a drainage culvert under the railroad line. Wetlands are discussed
further in Sections 2.2.3 and 3.2.3 of this report. The culvert runs underground temporarily,
emerges, and drains into Red Root Creek located approximately 4,000 feet southeast of the
Edison Facility. (NJDEP i-Map). This creek is a tributary of the Raritan River, which is located
approximately 1.5 miles southeast of the Edison Facility. According to the National Park
Service's National Wild and Scenic Rivers system, no federally designated wild and scenic rivers
are located on, or within two miles of, the Edison Facility, including the Raritan River.
3.2.2. Ground Water
EPA's Edison Facility is located within the Lower Raritan River watershed; no potable wells are
located on the property. (NJDEP i-Map). The Edison Facility uses municipally supplied water
for all operational purposes including laboratory, sanitary, and drinking water.
Numerous monitoring wells associated with ongoing ground water monitoring are located on the
Edison Facility property. These monitoring wells are associated with soil and ground water
contamination identified on the property resultant from past use as the Raritan Arsenal. The
former Raritan Arsenal covered approximately 3,200 acres and extended from Woodbridge
Avenue (the northern boundary of the Edison Facility) to the Raritan River.
Three areas of concern (AOC) that are under investigation by the U.S. Army Corps of Engineers
(USAGE) are located on the Edison Facility property. Proposed Site 1 is located within an area
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
of concern (i.e., AOC 8). Proposed Site 7 is not in an area of concern an, as such, no monitoring
wells resided on Site 7. (USAGE, 2008).
Ground water contamination in the area of Site 1 was the result of Trichloroethylene (TCE)
degreasing operations that occurred in the vicinity of former buildings that resided on this site.
A 2005 sampling event detected TCE concentrations in ground water on Site 1 ranging up to 170
micrograms per liter (|ig/l). The remediation strategy chosen for the entire Raritan Arsenal is
known as monitored natural attenuation (MNA). This strategy assumes that contaminants will
degrade over time through natural biological and chemical processes. This cleanup method is
typically selected when receptor pathways are incomplete and the potential impact to human
health or the environment is limited. Experts predicted that the MNA strategy would occur for
40 years, beginning in 1999. (USAGE, 2008).
Depths-to-ground water measurements in the monitoring wells on the Edison Facility are
recorded as part of the ongoing Raritan Arsenal ground water monitoring program. Ground
water at Site 1 has been detected at depths of 30 to 40 feet below grade. Ground water in the
vicinity of Site 7 has been detected at depths of 10 to 15 feet below grade. Groundwater flows
across the Edison Facility in a southeasterly direction. (USAGE, 2008).
3.2.3. Floodplains and Wetlands
No floodplains are mapped on the Edison Facility site. According to the FEMA Flood Insurance
Rate Map (FIRM) for Edison, New Jersey (Community Panel number 340261 0006 C), dated
June 19, 1985, the entire Edison Facility property area is mapped as Zone C, an area of minimal
flooding outside of the 500-year floodplain. The closest mapped floodplain, associated with the
Raritan River, is located approximately 4,000 feet southeast of the Edison Facility. (FEMA,
1985).
According to the US Fish and Wildlife Service (FWS), wetlands are adjacent east of Site 7, on
the southeastern portion of the Edison property. No wetlands are mapped directly on Site 1 or
Site 7. This wetland area has been identified as a palustrine, forested, broad-leaved deciduous,
seasonally flooded wetland system. This system is characterized by impounded, shallow, non-
tidal freshwater, woody plants and trees, and is seasonally flooded or saturated. This wetland,
mapped over approximately 11 acres of an undeveloped portion of the Edison Facility campus,
drains across the southeastern boundary through a drainage culvert as discussed above.
3.3. AIR QUALITY
Air quality in a given location is based on the concentration of various pollutants in the
atmosphere. The federal Clean Air Act (CAA), 42 U.S.C. §§ 7401-7671(q), as amended,
stipulates that emissions sources must comply with the air quality standards and regulations that
have been established by federal, state, and county regulatory agencies. EPA established the
National Ambient Air Quality Standards (NAAQS) for six criteria pollutants: ozone (63), carbon
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
monoxide (CO), nitrogen dioxide (NOX), sulfur dioxide (862), particulate matter equal to or less
than 10 and 25 microns in diameter (PM-10/PM-2.5), and lead (Pb).
EPA designates all areas of the United States as having air quality better than ("attainment") or
worse than ("nonattainment") the NAAQS. The EPA designates the Edison area within
Middlesex County as being in nonattainment of the NAAQS for ozone and PM-2.5. (EPA Green
Book, 2009; NJ Bureau of Air Quality Planning, 2009).
Areas that exceed the NAAQS require preparation of a State Implementation Plan (SIP) detailing
how the state would attain the standard within mandated time frames. Section 176(c) of the
CAA provides that a federal agency cannot support an activity in any way unless the federal
agency determines that the activity would conform to the SIP for attaining and maintaining the
NAAQS.
If emissions from a federal action do not exceed de minimis thresholds (based on the degree of
nonattainment of the area), and if the federal action is not considered a regionally significant
action, it is exempt from further conformity analysis. The definition of a regionally significant
action is one whose total emissions meets or exceeds 10% of the air quality control area's
emission inventory for any criteria pollutant. Edison, New Jersey, is in a nonattainment area for
ozone and PM-2.5. The applicable de minimis thresholds for Middlesex County are 100
tons/year.
3.4. BIOLOGICAL RESOURCES
Biological resources consist of native or naturalized plants and animals, along with their habitats.
The Endangered Species Act (ESA) of 1973 and the Fish and Wildlife Coordination Act
(FWCA) of 1934 provide a framework for conservation of vegetative and wildlife resources, and
can be supplemented with sound conservation principles to minimize impacts to vegetation and
wildlife communities.
3.4.1. Vegetation and Wildlife
The Edison Facility grounds are largely urban, comprised of paved and landscaped areas,
including turf/grass, trees, and shrubs. Areas surrounding the Edison Facility are mostly
developed and interspersed with small wooded and vegetated areas, which most likely provide
habitat for animal species. There is limited wildlife on and near Site 1 and Site 7 due to urban
and residential development in the area. Wildlife observed during previous field studies included
rabbits, crows, mockingbirds, deer, mallards, black ducks, and common egrets. (USAGE
Baseline Ecological Risk Assessment [BERA], 2008). Common tree species located on or
within the Edison Facility campus include red oak and pitch pine, shrub species such as crab
apple, and grass species such as switch grass. (EPA, 1990).
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
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Site 1 is comprised of an open field with a large grassy area and a few bordering trees. Site 1 is
also bordered by paved parking lot areas and roads, administrative buildings, the laboratory
gatehouse, and a small landscaped park area located west of Site 1.
Site 7 includes little vegetation on the site. Site 7 is bordered by paved roads, landscaped
turf/grass, and tree buffers, in addition to larger forested areas to the north, northeast and east of
the grounds.
3.4.2. Endangered, Threatened and Rare Species
Various federal and state government databases and sources were reviewed to determine the
presence of endangered, threatened and rare species or their critical habitats. Sources include the
EDR Report, New Jersey Department of Environmental Protection (NJDEP) Division of Fish
and Wildlife, NJDEP Division of Parks and Forestry, NJ DEP i-Map, and FWS. Based on a
review of these sources, no federally listed Designated Wilderness Areas, Wilderness Wildlife
Preserves, or threatened or endangered species' Critical Habitats reside within a one-mile radius
of the Edison Facility, and no state-designated Wildlife Management Areas or state parks reside
within Middlesex County. (EDR Report, 2009; NJDEP i-Map; NJDEP Water Management
Areas [WMAs], 2009).
According to species lists and databases maintained by FWS, National Oceanic and Atmospheric
Administration, the NJDEP Division of Fish and Wildlife and the NJDEP Natural Heritage
Program (NHP), several listed threatened and endangered species as potentially located within or
near Middlesex County, New Jersey. These species are listed in Table 3.4-1 and Table 3.4-2.
(FWS ECOS, 2009; FWS, 2009; USACE BERA, 2008).
Table 3.4-1: Endangered and Threatened Animal Species for Middlesex County
Group/ /-. TVT o -L-J- TVT Classification
r Common Name Scientific Name
1 ype State Status Federal Status
Birds
Birds
Birds
Birds
Birds
Invertebrates
Fishes
Fishes
Insects
Mammals
Mammals
Mammals
Mammals
Reptiles
Reptiles
Reptiles
Piping plover
Red knot
Roseate tern
Pied-billed grebe
Black crowned night heron
Dwarf wedgemussel
Brook trout
Shortnose sturgeon
Northeastern beach tiger
beetle
Indiana bat
Alleghany woodrat
Eastern puma
Right whale
Bog turtle
Hawksbill sea turtle
Kemp's Ridley sea turtle
Charadrius melodus
Calidris canutus rufa
Sterna dougallii dougallii
Podilymbus podiceps
Nycticorax nycticorax
Alasmidonta heterodon
Salvelinus fontinalis
Acipenser brevirostrum
Cicindela dorsalis dorsalis
Myotis sodalis
Neotoma magister
Puma concolor cougar
Balaena glacialis
Clemmys muhlenbergii
Eretmochelys imbricata
Lepidochelys kempii
Endangered
Threatened
Endangered
Endangered
Threatened
Endangered
N/A
Endangered
Endangered
Endangered
Endangered
N/A
Endangered
Endangered
Endangered
Endangered
Threatened
Candidate
Endangered
N/A
N/A
Endangered
Candidate/
Under Review
Endangered
Threatened
Endangered
Candidate/
Under Review
Endangered
Endangered
Threatened
Endangered
Endangered
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Table 3.4-2: Endangered and Threatened Plant Species for Middlesex County
^ «-, TVT o x-j- TVT Classification
Group Common Name Scientific Name _ _ _, , , _
State Status Federal Status
Flowering Plants
Flowering Plants
Flowering Plants
Flowering Plants
Flowering Plants
Flowering Plants
Flowering Plants
Flowering Plants
American chaffseed
Bog asphodel
Hirsts' panic grass
Knieskern's beaked-rush
Seabeach amaranth
Sensitive joint-vetch
Small whorled pogonia
Swamp pink
Schwalbea americana
Narthecium americanum
Dichanthelium hirstii
Rhynchospora knieskernii
Amaranthus pumilus
Aeschynomene virginica
Isotria medeoloides
Helonias bullata
Endangered
Endangered
Endangered
Endangered
Endangered
Endangered
Endangered
Endangered
Endangered
Candidate/
Under Review
Candidate/
Under Review
Threatened
Threatened
Threatened
Threatened
Threatened
While the species referenced above could potentially be located in Middlesex County, only one
of the federally listed species was identified as possibly extant/present in Edison Township: the
Indiana bat. (FWS, 2009). Previous NEPA reviews and ecological surveys indicated that this
species has not been observed on the grounds of or in the vicinity of the Edison Facility and that
the site was unlikely to contain suitable habitats for this species or other endangered, threatened,
or rare species. Based on this information, and the fact that the Proposed Action's project area
has continued to remain developed, it is unlikely that the Edison Facility currently contains
federally or state-listed endangered, threatened or rare species.
According to previous NEPA reviews for construction projects at the Edison Facility site,
federally or state-listed endangered, threatened, and rare species are unlikely to exist on or be in
the vicinity of the site. These previous NEPA reviews included federal and state database
reviews and/or site-specific surveys conducted for the Edison Facility between 1988 and 1998.
(EPA, 1990; EPA, 1998b).
In addition, recent ecological surveys and database reviews were conducted for a USAGE 2008
BERA for the former Raritan Arsenal. As a result of this survey, records exist of state-listed
endangered species in the vicinity of the former Raritan Arsenal. These observations indicate the
possibility of such species existing in the vicinity of the Edison Facility. However, the Edison
Facility has continued to remain developed, with little to no vegetation for suitable habitats. In
addition, the previously noted observations did not include observations of any nesting or
breeding for the state-listed species, nor did the surveys include observations specifically on the
Edison Facility grounds. Therefore, it is unlikely that the Edison Facility site currently contains
habitats for these state-listed endangered species.
3.5. CULTURAL RESOURCES
The proposed project sites are located on a portion of the Former Raritan Arsenal Historic
District and are managed using the 1992 Historic Resources Management Plan for the U.S.
Environmental Protection Agency's Edison Facility, Former Raritan Arsenal, Edison Township,
Middlesex County, New Jersey (HRMP), and the 1992 Memorandum of Agreement (MO A)
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
between EPA, the Advisory Council on Historic Preservation (ACHP) and the New Jersey State
Historic Preservation Office (SHPO). The Historic Resources Management Plan (HRMP) uses
zones to identify areas within the Edison Facility property related to the Former Raritan Arsenal.
Since the inception of these documents, the Edison Facility property has been subject to the
requirements contained in the MO A, which state that all buildings on the property shall be
treated as historic. To satisfy the terms of the MOA and maintain mission requirements, EPA
completed a Historic American Building Surveys/Historic American Engineering Record
(HABS/HAER) documentation on eleven buildings as mitigation for demolition. After
submission of the completed HABS/HAER documentation, it is available at the SHPO.
Additionally, the MOA states that EPA will consult with the New Jersey SHPO on any
significant modifications to the Edison Facility. If the EPA and SHPO cannot resolve
differences during consultation, then EPA will invite the ACHP's comments.
As detailed in the HRMP, Site 1 is located within historic Zone 4, which is listed as significant
solely for the architectural value of the buildings and structures that once existed there. The
HRMP notes that this zone is unlikely to yield any archeological resources because of the
extensive construction disturbance. Portions of the foundations of the demolished buildings are
under fill dirt in the existing field. There are buildings associated with the Former Raritan
Arsenal Historic District within the viewshed of the Proposed Action.
As detailed in the HRMP, Site 7 is located within historic Zone 7 and located at the back side of
the Edison Facility property. Earthen berms and mature woods surround the south side of Site 7,
and Middlesex Community College bounds it to the northwest. There are mature stands of trees
and brush shielding Site 7 from the community college. Zone 7 contains Korean War-era
warehouses (Buildings 245 and 246), which are listed as contributing elements to the Raritan
Arsenal Historic District. Due to the scope of the Proposed Action, sightlines, topography of the
Proposed Action area, and vegetation within the proposed project area, an area of potential effect
(APE) of one-eighth mile was determined appropriate.
On May 26, 2009, a cultural resources professional meeting the Secretary of the Interior's
Professional Qualification Standards conducted SHPO research and a site visit. The SHPO
research consisted of file reviews for any built features that would be potentially eligible for
listing on the National Register. The New Jersey and National Register listings and the county
surveys were reviewed.
Additionally, six historic buildings located off EPA property are located within the APE, during
the SHPO file review. None of these historic buildings within the APE are listed in the New
Jersey or National Registers. The Heritage Studies of Princeton, New Jersey identified six
buildings during the 1978 Middlesex County Survey. Of these six historic buildings, only two
historic structures are within the viewshed of Site 1, the Bonhamton School and the Bonhamton
Grace Reformed Church. The standards in place for determining eligibility in 1978 dictated that
neither was deemed eligible for listing on the National Register, due to the loss of integrity of the
settings. The 1908 Bonhamton School, presently housing aMontessori school, is an excellent
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
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example of a neoclassical building with Colonial Revival elements. The Bonhamton Grace
Reformed Church, constructed in 1876, is a good example of vernacular Gothic Revival
architecture. While these buildings are now considered historic as examples of distinct styles
and have maintained integrity of design, modern intrusions surround them, which include the
large four lane Woodbridge Avenue, contemporary architecture, and modern additions to the
surrounding houses.
During the site visit, it was apparent that no historic buildings located off the Edison Facility
property were within the sightline of Site 7 due to the mature vegetation and berms that bound
the site.
3.6. NOISE
The US has a noise law known as the Noise Control Act of 1972 (42 U.S.C. 4901-4918);
however, state and local authorities generally address noise enforcements regulations. (Shapiro,
1991). As of this writing, New Jersey is the only state whose government must approve local
noise ordinances. (Noise Pollution Clearinghouse [NPC], 2001). See Table 3.6-1 for an outline of
the Edison Facility noise standards. Consistent with industrial areas, the dominant noise feature
of the immediate vicinity is road traffic noise emanating from Woodbridge Avenue, on the
Northwestern side of the Edison Facility. Neither Site 1 nor Site 7 has any significant noise
issues.
Table 3.6-1: Edison Noise Standards (Edison, 1999)
Sound Source Property Receiving Property Category
Category
Multi-dwelling unit building
Residential
Commercial or public spaces
or rights -of-way
Industrial
Another Dwelling W/in
Multi-dwelling Unit Bldg
7AM-10PM
45
-
-
-
10PM-7AM
40
-
-
-
Residential
7AM-10PM
55
55
65
65
10PM-7AM
50
50
50
50
Commercial
All Times
65
65
65
65
Industrial
All Times
75
75
75
75
The following are exempt from the sound level limits:
Noise from domestic power tools, lawn mowers, and agricultural equipment when operated with a muffler
between the hours of 8AM-8PM on weekdays and 9AM-8PM on weekends and legal holidays, provided that
they produce less than 85 A-weighted decibels (dBA) at or within any real property line of a residential property
Sound from church bells and church chimes when a part of a religious observance or service
Noise from construction activity, provided all motorized equipment used in such activity is equipped with
functioning mufflers, except as provided in subsection 12-27.7b, 6. of this section
Noise from snowblowers/throwers and snow plows when operated with a muffler for snow removal
Noise from stationary emergency signaling devices that conforms with the provisions of NJAC 7:29
Noise from an exterior burglar alarm of any building or motor vehicle, provided such burglar alarm shall
terminate its operation within 15 minutes after it has been activated
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3.7. VISUAL RESOURCES
The Edison Facility consists of approximately 20 permanent buildings and numerous temporary
trailers on a 205-acre campus, housing laboratory support, office, and storage functions. These
buildings were once part of the Raritan Arsenal, a large military installation in Edison Township.
Site 1, as depicted in Figure 3.7-1, is located on the northern portion of the Edison Facility and is
visible from Woodbridge Avenue and the residential area north of Woodbridge Avenue. There
is a double line of newly planted trees on the Edison Facility grounds between the proposed
SPVS and Woodbridge Avenue.
Figure 3.7-1: Aerial view and surface view (to the east) of Site 1
Site 7, as depicted in Figure 3.7-2, to the southeast of the Edison Facility within an area of low
ground with steeply rising ground to the North and East. The high ground surrounding Site 7 has
trees covered with heavy underbrush.
Figure 3.7-2: Aerial view and surface view (to the southeast) of Site 7.
Neither Site 1 nor Site 7 has any significant visual impacts. Additional photos of Site 1 and Site
7 can be found in Appendix A.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
3.8. LAND USE
The Edison Facility property is zoned in the Township of Edison's District 5 for civic use. The
civic zoning designation is used for municipal and governmental uses. Properties to the
northeast and southeast are zoned for Light Industrial uses. The Edison Facility adjoins Thomas
Edison County Park at the facility's southwestern corner, which is zoned for Public Parks and
Recreation. The grounds of Middlesex Community College are zoned for civic use, and adjoin
the Edison Facility at the southwestern boundary. A property that is mapped as vacant adjoins
the Edison Facility to the west, but was recently developed with townhouses (this property is
shown as residential on the future Land Use Plan). Properties to the northwest of the Edison
Facility, across Woodbridge Avenue, are zoned as Institutional/Private School, Places of
Worship, and Residential.
The future Land Use Plan for District 5 shows zoning designations for properties to the north,
west, south, and southwest of the Edison Facility that are the same as current zoning. Property to
the northeast and southeast of the Edison Facility, which is currently zoned for light industrial
use, is part of the future Riverfront and Center Revitalization District. This future revitalization
district will revise current zoning designation to encourage mixed-use development with open-
space and access to the Raritan River. (NJDEP i-Map).
Properties located adjacent to Site 7 are zoned for light industrial purposes and as parkland; an
industrial park is located southeast of the site and the Thomas Edison County Park is located to
the south. Tree lines separate Site 7 from adjacent properties. Off-site properties located
adjacent to Site 1 include a Montessori school and a church. Site 1 is visible from Woodbridge
Avenue and from adjacent properties.
3.9. HUMAN HEALTH AND SAFETY
The Edison Facility currently has safety, health, and environmental programs and systems in
place to comply with Occupational Safety and Health Administration (OSHA) requirements.
This includes policies and procedures to document programmatic safety and health-related goals
and performance. Existing policies and protocol at the Edison Facility include the EPA Facility
Safety, Health and Environmental Management (SHEM) Manual, a multi-facility Environmental
Management System (EMS) and an occupational health and safety plan. (SHEM Audit, 2005).
In addition, the Edison Facility provides regular training for their personnel, and a Health and
Safety Committee meets every six weeks to discuss emerging issues and resolve ongoing
problems. Other existing safety and security measures in place include fencing surrounding the
Edison Facility campus, a manned entrance guard house with a stationary guard, and a guard
who conducts interior and exterior tours of the buildings on site. (EPA Edison, 2009).
Site 1 has a fence bordering the field where it is adjacent to Woodbridge Avenue. Site 7 includes
the warehouse buildings in poor condition, which could pose human health and safety concerns.
The warehouse buildings are known to contain lead-based paint, but other hazardous substances,
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
such as asbestos-containing materials (ACMs) have been previously remediated. (SHEM Audit,
2005; Cho, 2009). A fence also borders Site 7 on the southwest and northwest side, where it is
adjacent to Middlesex County College. This fence borders College Drive to the southwest and a
parking lot to the northwest.
3.10. UTILITIES AND INFRASTRUCTURE
The affected environment associated with existing utilities and infrastructure at the Edison
Facility include electrical utility management, potable water and wastewater management,
stormwater management, and storage tank management.
3.10.1. Electrical Utility Management
In 2007, the Edison Facility was billed for 4.71 million kWh of electrical use, and in 2008, it was
billed for 4.70 million kWh. (Snyder, 2009). Currently, electricity is largely provided by
PSE&G. The Edison Facility also maintains a 100-kW diesel-powered emergency generator for
use during local power outages. In addition, the Edison Facility has three solar water-heating
systems that are the primary source of hot water in their respective areas. All three solar water-
heating systems consist of a preheat tank (between 66 and 120 gallons) and various numbers of
roof-mounted, single-glazed, liquid evacuated tube collectors. (EPA Greening, 2009). The
Edison Facility generally operates on a standard federal weekday schedule of 12 hours per
workday, Monday through Friday (6:00 am to 6:00 pm).
In order to offset energy consumption, the Edison Facility purchases electricity from local
sources and has implemented energy conservation systems and green power contracts. For
example, the Edison Facility executed a contract for fiscal year (FY) 2008 to procure green
power in the form of renewable energy certificates (RECs). This green power purchase supplied
the Edison Facility with enough RECs to offset 100% of the annual electricity consumption for
FY 2008 and the first half of FY 2009. Procured through DESC, these contracts support
renewable energy generation from wind and biomass resources in nine states.
3.10.2. Potable Water and Wastewater Management
The total annual water consumption by the Edison Facility is estimated to be approximately 4.4
million gallons per year. Approximately 450-500 employees work in the Edison Facility on a
regular basis. (EPA Greening, 2009; EPA NFG, 2009). Water is used for mechanical systems,
sanitary needs, laboratory processes, and irrigationthough the latter has been largely
eliminated. (EPA Greening, 2009).
Buildings within the Edison Facility receive drinking water supplied by the local municipality,
the Middlesex Water Company. (EPA Water Management Plan [WMP], 2006). Temporary
laboratory trailers use water provided by a local distributor. Incoming water supplied by
Middlesex Water Company is split and flows through two parallel metered pipes in a metering
shed. The locked metering shed is located in a separate fenced area outside of the northeast
corner of the EPA property, near Site 1. A second set of isolation valves are located to the north-
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
west of the Building 200, also near Site 1. (EPA WMP, 2006). The Edison Facility also
maintains an EMS with water conservation goals and developed a Water Management Plan in
2006 to document and promotes water efficiency and conservation.
Wastewaters from the Edison Facility include sanitary wastes and discharges from laboratory
sinks. These wastewaters are discharged to the Township of Edison and the Middlesex County
Utilities Authority (MCUA) treatment works. (SHEM Audit, 2005). The Edison Facility
maintains a policy prohibiting the discharge of chemicals, hazardous wastes, or analytical wastes
to the sinks. Based on the Edison Facility's conformance with this policy, no permit or
monitoring is required by the local treatment works. In addition, no point sources from the
Edison Facility are subject to permitting under the National Pollution Discharge Elimination
System (NDPES) for direct discharge of wastewater to state or national waters. (SHEM Audit,
2005).
3.10.3. Stormwater Management
The current Stormwater management system at the Edison Facility is designed to collect and
direct a portion of Stormwater offsite to the municipal Stormwater collection system. The
direction of Stormwater onsite is accomplished through the use of above ground Stormwater
diversion mechanisms, below ground Stormwater piping systems, and wetlands, which serve as a
drainage basin. Above ground Stormwater diversions include the use of sloped paved areas (e.g.,
sidewalks, parking lots and roadway areas), curbing, open culverts, storm drain inlets, and sloped
grassy areas and embankments. Underground Stormwater diversions include piping systems that
collect Stormwater and direct it to specific outfalls.
The majority of Stormwater runoff from Edison Facility site eventually flows offsite through a
drainage outfall culvert on the east side of Edison property, near the intersection of Pershing
Avenue and the railroad track. Stormwater runoff originating from Site 1 flows into a drainage
pipe collection system and is directed towards this outfall. Stormwater runoff originating from
Site 7 flows into a drainage pipe collection system, which is then directed to the wetlands on
southeast portion of the Edison Facility site before ultimately flowing to the drainage outfall.
The Edison Facility currently has two storm water-related research activities. First, a porous
parking lot is under construction and will allow for testing the materials' effectiveness in
achieving ground water recharge and pollutant removal. This parking lot is located to the south
of Site 1. (EPA Stormwater Management [SWM], 2008). Second, the Edison Facility's Urban
Watershed Management Branch participates in research investigating pipelines on-site to detect
and locate leaks, evaluating pipeline structural integrity, telemetric monitoring, and infiltration
and exfiltration studies. Some of this research is conducted on-site, and this research facility is
located to the north of Site 7. (EPA MAP, 2003).
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
3.10.4. Storage Tank Management
The Edison Facility does store sufficient quantities (greater than 10,000 pounds) of petroleum
products and laboratory samples to warrant community right-to-know reporting pursuant to
Executive Order (EO) 13148, Greening the. Government through Leadership in. Environmental
Management, and the Emergency Planning and Community Right-to-Know Act (EPCRA). A
review of the recent facility SHEM audits indicated the following: (SHEM Audit, 2005)
Fuel oil is stored in a 10,000-gallon underground storage tank (UST) (located near
Buildings 205 and 209, south of Site 1 and north of Site 7).
Diesel fuel is stored in a 500-gallon aboveground storage tank (AST) (associated with the
Edison Facility emergency power generator, located near the guard shack, east of Site 1).
There are no known leaking USTs located at grounds of the Edison Facility.
The Edison Facility does not maintain a Spill Prevention, Control, and Countermeasures (SPCC)
plan, per CWA and Oil Pollution Act (OPA) regulations (codified in 40 CFR Part 112), because
the facility does not meet the threshold requirements. While an SPCC plan is not required, the
Edison Facility maintains a combined Oil and Hazardous Substance Contingency Plan to
address concerns regarding potential releases. In addition, the Edison Facility maintains relevant
UST registrations and conducts periodic inventory monitoring in accordance with New Jersey
regulations. (SHEM Audit, 2005).
3.11. WASTE MANAGEMENT
This section describes the affected environment associated with solid, hazardous, and sanitary
waste management.
3.11.1. Solid Waste Management
The non-hazardous solid waste stream produced by the Edison Facility includes standard office
waste and non-hazardous laboratory wastes. Based on previous EPA SHEMD audit reports, the
Edison Facility has implemented a recycling program for several non-hazardous solid wastes.
Based on site personnel interviews, the Edison Facility's solid waste and recycling is removed by
Midco Waste Systems and then transported to the appropriate recycling and disposal facilities.
The solid waste management practices at both Site 1 and Site 7 currently fall under the same
environmental management program at the Edison Facility.
3.11.2. Hazardous Waste Management
Based on previous SHEMD audit reports, the Edison Facility has implemented hazardous waste
management programs as a part of their environmental management system. (SHEM Audit,
2005). The Edison Facility is subject to hazardous waste management regulations for the
handling, storage, and disposal of laboratory-related hazardous wastes.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
The Edison Facility operates as a large quantity generator (LQG) under New Jersey Resource
Conservation and Recovery Act (RCRA) regulations, since it routinely generates quantities of
hazardous waste in excess of the 1,000 kg/month threshold for non-acute hazardous waste and
occasionally generates more than 1 kg of acutely hazardous waste. The majority of these waste
streams generated by the Edison Facility consist of spent organic solvents, corrosive liquids from
various analytical processes, toxic metals and pesticides, and solid laboratory waste. (SHEM
Audit, 2005).
Wastes generated by the Edison Facility's analytical activities are initially placed in labeled
satellite accumulation containers (as appropriate for the type of waste) in each laboratory where
hazardous wastes are generated. Wastes from all laboratory operations are subsequently moved
to the Edison Facility 90-day central accumulation area, located behind Building 209, when the
satellite containers become full and prior to off-site shipment for treatment, storage, or disposal.
The accumulated hazardous materials and wastes are picked up and managed by Veolia and then
transported to the appropriate disposal or treatment facilities.
In addition, medical wastes at the Edison Facility are generated in the Occupational Health
Resource Center (OHRC) in Building 200. The Edison Facility is registered with the NJDEP as
a medical waste generator, and medical wastes are managed by appropriately licensed
biomedical waste disposal vendors that maintain permits to operate in New Jersey and New
York. (SHEM Audit, 2005).
At Site 1, there is an existing ground water contamination plume, for which the monitoring and
remediation activities have been handled by the USAGE. No known hazardous wastes are
generated due to these activities, and no other hazardous substances are known to exist at this
site.
At Site 7, based on the age of the two warehouse buildings, the building surfaces are expected to
contain some lead-based paint. (Cho, 2009). In 1984, the warehouse buildings were identified as
having ACM. (SHEM Audit, 2003). These facilities have undergone remediation and no longer
contain ACM. No other hazardous substances or wastes are known to exist at Site 7. (Cho,
2009).
3.11.3. Sanitary Waste
Currently, sanitary waste generated at the Edison Facility in the restrooms, sinks and wastewater
drains in the buildings is treated by the local wastewater treatment works, the Middlesex County
Utilities Authority. (SHEM Audit, 2005). Sanitary wastes are not currently collected on Site 1 or
Site 7.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
3.12. TRANSPORTATION AND PARKING
The Edison Facility is located 30 miles south of New York City and is accessible from
Woodbridge Avenue (Route 514), proximally located to the New Jersey Turnpike, Garden State
Parkway, and Routes 1 and 287.
There are six primary roads on the Edison Facility:
Bonhamtown Road runs generally northwest/southeast through the main part of the
Edison Facility, and provides the main entry point.
Williams Avenue runs roughly east to west and ends at Bonhamtown Road.
Industrial Road runs roughly east to west and ends at Bonhamtown Road.
Casad Road runs roughly east to west, south of the main complex, and ends at Pershing
Avenue.
Pershing Avenue runs northwest to southeast and provides access to the section of the
Edison Facility across the railroad tracks to the west.
Avenue D runs roughly east to west and provides primary access to Site 7.
The Township of Edison does not provide mass transit to or on the Edison Facility campus,
although there are nearby bus stops. There are two nearby train stations with service by New
Jersey Transit and/or Amtrak. The closest train station is Metuchen, located approximately two
miles north, and it is served by New Jersey Transit while Amtrak serves the Metropark station
located approximately four miles north. The nearest commercial airport, located approximately
19 miles north, is Newark Liberty International Airport, for transportation to and from the
region. A helicopter pad on site is utilized by EPA researchers for transport. The helicopter pad
is also made available for other local and regional contingency operations. Parking capacity is
more than adequate at the Edison Facility.
3.13. SOCIOECONOMICS
The Edison Facility employs approximately 462 personnel, comprised of scientists, professional
staff, technical support contractors, and visiting scientists and students. This workforce
represents a relatively minor portion of the Middlesex County year-2008 estimated population of
789,102 and year-2000 labor force of 391,203. (US Census Bureau [USCB], 2008a). According
to the 2000 census, the Middlesex County workforce was comprised of 40.6% of persons
employed in management, professional, and related occupations; 28.4% in sales and office
occupations; 12.8% in production, transportation, and material moving occupations; 11% in
service occupations; 7.1% in construction, extraction, and maintenance occupations; and 0.1% in
farming, fishing, and forestry occupations.
3.14. ENVIRONMENTAL JUSTICE & PROTECTION OF THE CHILDREN
3.14.1. Environmental Justice
EO 12898, Federal Actions to Address EnvironmentalJustice in Minority Populations and Low-
Income Populations., is designed to focus the attention of federal agencies on the human health
and environmental conditions in minority communities and low-income communities. Data for
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Middlesex County presents a 2007 median household income of $75,069 with 6.6% of persons
living below the poverty level. The Middlesex County median income is higher than State of
New Jersey and U.S. levels, and poverty rates are lower than the State of New Jersey and the
U.S. rates. Data for the State of New Jersey presents a 2007 median household income of
$67,142 with 8.5% of persons living below the poverty level, while 2007 Census data presents
U.S. median income of $50,233 with 12.5% of persons living below the poverty level. (USCB,
2008b) Middlesex County racial demographics include 68.8% White (17.1% Hispanic or Latino,
53.7 non-Hispanic), 10.8% African American, 0.3% American Indian or Alaskan Native, 18.6%
Asian, 0.1% Native Hawaiian or other Pacific Islander, and 1.4% two or more races.
3.14.2. Protection of the Children
EO 13045, Protection of Children from Environmental Health Risks and Safety Risks, requires
federal agencies to identify and assess if its activities, including Proposed Actions, would have a
disproportionate effect on infants and children. As children's bodily systems, including
neurological, immunological and digestive systems, are still developing, it is important to
address any potential impacts that a proposed project may have on the health and well-being of
children who are located in the vicinity of, or could come in contact with, a proposed project.
There are no facilities within the Edison Facility grounds to which children would have access.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
4.0. ENVIRONMENTAL CONSEQUENCES
This section addresses the impacts anticipated during the construction, operation and
maintenance, and dismantling of the proposed SPVS on the Edison Facility. The following
subsections outline potential impacts to environmental resources as a result of construction,
operation and maintenance, and dismantling of the SPVS. This section analyzes construction
and dismantling impacts collectively, because dismantling impacts are generally similar in scope
to construction impacts. Where differences in construction and dismantling impacts exist, the
text will provide appropriate discussion of the different impacts. The Combined Alternative
(where both sites would be developed) and the No Action Alternatives are not individually
analyzed throughout this section since the analysis is generally the same for each resource area.
See Sections 4.1 and 4.2 for more on the discussion of the Combined and No Action
Alternatives.
Combined Alternative
The Combined Alternative would result in the development of both Sites 1 and 7. If this
alternative were chosen, the development of sites would occur sequentially, not simultaneously.
Impacts from the Combined Alternative would be the same as the individual site impacts
discussed below for Sites 1 and 7. It is not anticipated the Combined Alternative would have
compounding impacts since development would occur sequentially. As with of each of the
individual site alternatives, the use of Best Management Practices (BMPs) during construction,
operation, and dismantling of the SPVS would negate significant or cumulative impacts if both
sites were chosen for development.
No Action Alternative
Under the No Action Alternative, the SPVS would not be constructed at either Site 1 or Site 7
and, therefore, all the resources discussed below would experience no impacts.
4.1. GROUND RESOURCES
4.1.1. Construction and Dismantling
Geology
The Edison Facility is located within the Coastal Plain physiographic province and is underlain
by thick terrace sediment deposits. Excavation during construction activities is not expected to
exceed 6 feet below grade, significantly shallower than the underlying geologic formation.
Because geologic features would not be encountered during construction or dismantling of the
SPVS, potential impacts caused by encountering geologic formations and/or impacts to geologic
formations themselves are unlikely.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Topography
The ground disturbance for the Proposed Action would include excavation for the installation of
concrete footers for the individual solar panel supports, potential trenching for installation of
power line conduit, installation of security fencing, and installation of a water-permeable
aggregate layer (such as gravel) to control vegetation and prevent runoff. Both sites are level
and significant excavation to change topography would not be required during construction of
the Proposed Action. Therefore, there is no potential for impact to topography on the site or
surrounding properties during construction. Similarly, dismantling of the SPVS would not
include significant excavation or other topography altering activities; therefore, dismantling of
the SPVS would not impact topography.
Soils -Erosion Concerns
Site 1 is currently undeveloped and consists of a small open grassy field occupying
approximately 105,000 ft2 (2.41 acres). Construction of the SPVS at Site 1 would entail the
disturbance or removal of grasses and some topsoil for over more than one acre. Since ground
disturbance exceeds the one-acre disturbance threshold, construction activities would require
permitting for compliance with local land disturbance regulations. Upon dismantling of the
SPVS at Site 1, the footings would be removed and the surface regarded and restored.
Site 7 is approximately 400,000 square feet (9.18 acres). If Site 7 were selected, the existing two
warehouses would be demolished for construction of the array; however, the existing slab-on-
grade foundation would remain to provide the base for the construction of the SPVS. The
existing asphalt parking area around the structures would remain for accessibility. Because the
concrete slab and asphalt parking would remain, soil stabilization efforts would be limited to
areas disturbed during construction staging and/or demolition activities, if any. Disturbed areas
would be minimal and would not exceed one acre. Because the concrete slab is planned to
remain, the power line conduit within the footprint of the array would be installed aboveground
and the solar panel bases would be attached directly to the slab. This negates the need to
excavate utility trenches and foundation bases. Minor excavation to upgrade and existing
drainage system to accommodate storm water runoff from the concrete pad may be required. Silt
fencing countermeasures installed as part of demolition would be required to be incorporated
into the overall sediment control plan. Based on the lack of soil disturbance during construction
and dismantling of the proposed SPVS at Site 7, the potential for soil erosion is not significant.
If Site 7 is utilized, existing utility power lines may require upgrading to carry power to the grid.
Installation of new electric power utility lines underground along existing roadways or on
existing utility poles may be necessary. If underground utility lines are installed, the use of
BMPs, such as trench and cover methods or horizontal directional drilling, will negate significant
soil erosion. Permanent erosion control measures undertaken following the completion of
trenching would include the stabilization of all disturbed areas with vegetation or pavement.
Based on the use of BMPs to control erosion during utility line installation, soil erosion during
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
installation of utilities is not significant. Erosion control measures would be required to be in
place prior to the start of construction and dismantling phases.
Vehicular access to each of the sites is available via existing paved roads, negating the need for
temporary construction roads; therefore, sediment control measures would not be required or
necessary along the existing roadways.
Soils -Contamination and Unexploded Ordnance (UXO) Concerns
Solar panels may contain trace levels of heavy metals within their components, depending on the
manufacturer. It is unlikely that these components would leach heavy metals during installation
or dismantling; however, potential soil contamination could result during construction and
dismantling of the SPVS from leakage of petroleum from construction equipment and dielectric
fluid from transformers installed to support the SPVS. Quantities of dielectric fluid stored in
transformers would be minimal and modern dielectric fluid does not contain polychlorinated
biphenyls (PCBs). BMPs and equipment maintenance significantly reduce the potential of a
release from equipment or transformers. Therefore, the risk of soil contamination during
construction, operation, or dismantling of the Proposed Action is not significant.
Based on the past use of the Edison Facility as the Raritan Arsenal, contaminated soils have a
potential to be encountered during excavation performed as part of construction of the SPVS.
However, based on the anticipated shallow depths of excavation, it is unlikely that the
significantly contaminated soils would be encountered. The reviewed information regarding
ongoing remedial actions performed as part of the former Raritan Arsenal does not indicate the
presence of significant soil contamination above the ground water table. (USAGE, 2008).
Excavations are not expected to reach the ground water table. Therefore, the existing soil
contamination located at the Edison Facility does not have a potential to cause an impact during
construction.
Unexploded ordinance (UXO) has been previously identified on the former Raritan Arsenal
property, the northern portion of which is currently occupied by the Edison Facility.
Identification and abatement of UXO has been completed by the Army at the former Raritan
Arsenal. (Cho, 2009). UXO was not identified at either of the proposed solar array locations.
(GAO, 1992). Although no UXO were identified in these areas, the presence of UXO cannot be
completely discounted. Note that UXO discovered during the study were deemed inert and
unlikely to detonate upon contact. It is unlikely that any UXO would be encountered during
construction activities associated with the Proposed Action, and it is unlikely that UXO would
present a risk. However, the construction contractor is expected to properly account for and
mitigate these potential risks.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
4.1.2. Operation and Maintenance
Geology
No geologic features would be encountered during operation and maintenance of the proposed
SPVS and impacts from or to geologic features would not occur.
Topography
Operation and maintenance to the SPVS would not include significant excavation or other
topography altering activities. Operation and maintenance of the SPVS would not impact
topography.
Soils
The long-term operation of the SPVS is not anticipated to result in significant environmental
impacts to the quality of soils at the Edison Facility or in the surrounding area. Localized soil
heating may occur in the vicinity of the array due to the absorption of heat by the solar panels
from the sun, but the impact would be minimal and is unlikely to affect soil conditions.
Ongoing environmental investigation/remediation in the area of Site 1 in connection with the
USAGE investigation of the Raritan Arsenal would include the installation of additional soil
borings in order to collect soil and ground water samples. These borings represent temporary
sampling features that would not require ongoing monitoring. This investigation would
reportedly occur in August 2009, prior to construction of the Proposed Action. Based on the
passive nature of the proposed SPVS, unplanned future investigation/remediation is not likely to
be affected by the operation of the SPVS.
4.1.3. Conclusion
Impacts from the Proposed Action to ground resources, including geology, topography, and soils,
are expected to be minimal at both of the proposed sites due to the existing improved and graded
surface at the proposed sites. Additionally, the existing soil contamination located at the Edison
Facility is unlikely to be encountered or otherwise affect the construction or operation of the
SPVS, and the discovery of UXO is not expected.
4.2. WATER RESOURCES
4.2.1. Construction and Dismantling
Surface Water
Since there are no surface water resources or wetlands located on proposed Site 1 or Site 7, no
direct impacts are anticipated.
Potential indirect impacts to nearby surface waters include siltation caused by soil erosion
primarily from Site 1, which includes the most ground disturbing activities for construction and
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
dismantling of the SPVS. Site 7 requires minimal excavation due to construction of the SPVS on
an existing foundation. Use of BMPs to comply with state and local sediment control laws
would control any siltation or erosion from this site during the construction and dismantling
phases.
Other potential indirect impacts to nearby surface waters could result from the release and
subsequent runoff of dielectric fluids used in the transformers or any fuel or oil from
construction and/or dismantling equipment. The potential for leaks or releases of dielectric
fluids, fuels, and oils is minimal due to use of BMPs and implementation of spill prevention
plans; therefore surface water contamination caused as a result of the construction and
dismantling of the SPVS is not significant.
Ground Water
Excavation at Site 1 would include the installation of concrete footer bases for the solar panels,
security fencing, and potential trenching for electrical utility conduit. These excavation activities
are not expected to exceed a depth of six feet below grade. Similarly, dismantling activities are
not expected to exceed a depth of six feet below grade. Based on the ongoing ground water-
monitoring program on the Edison Facility, the depth to ground water at Site 1 is approximately
30 to 40 feet below grade, well below the expected maximum depth of excavation.
If Site 7 is used for the installation of the SPVS, excavation would be limited, and the array
would be anchored directly to the existing concrete slab remaining from the warehouse
demolition and electrical conduit would be installed on top of the slab. The maximum depth of
excavation on this site is not expected to exceed six feet. The depth-to-ground water
measurement on this site is approximately 10 to 15 feet below grade. Based on the approximate
maximum excavation depth, the ground water table is unlikely to be intercepted during
construction or dismantling activities.
Potential ground water contamination sources that may exist during construction and dismantling
of the SPVS are limited to leakage of petroleum from construction equipment and dielectric fluid
from transformers. In the unlikely event of leakage, impacts to ground water would be localized
and limited. Therefore, the potential for contamination impacts to ground water during
construction of the proposed SPVS is not significant.
An ongoing ground water-monitoring program by the USAGE on the Edison Facility (associated
with the Raritan Arsenal) has identified ground water contamination at Site 1. Based on the
depth-to-contaminated ground water measurement on this site (approximately 30 to 40 feet),
dissolved- and vapor-phase volatile organic compound (VOC) contamination is unlikely to be
encountered during construction excavation or dismantling of the SPVS. Significant ground
water contamination has not been identified in the vicinity of Site 7. Two to four monitoring
wells are located at Site 1. If the SPVS were to be constructed at Site 1, solar panels will not be
placed in a manner that would damage or limit access to the monitoring wells.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Floodplains and Wetlands
The Raritan River floodplain resides approximately 4,000 feet southeast of the Edison Facility;
no floodplains are mapped on the Edison Facility or closer than 4,000 feet. Based on the
distance between the Edison Facility and the floodplain, the Proposed Action does not have a
potential to impact floodplain resources.
No wetlands are mapped on Site 1 or Site 7 of the Edison Facility; however, wetlands are
mapped on the southeastern corner of the facility, approximately 1,700 feet south from Site 1,
and immediately southeast of Site 7. The greatest potential for impact to the wetland is siltation
from runoff during construction and dismantling activities. Use of erosion control BMPs would
prevent soil erosion at the proposed sites. State and local regulations require that sediment
control measures be in place prior to the start of construction. Therefore, the likelihood that
wetlands on the Edison Facility would be impacted by soil erosion is not significant.
As established earlier, the risk of a fuel spill due to construction and dismantling equipment
failure or spill from a transformer is considered minimal. If a spill from equipment or a
transformer were to occur, it would likely be localized to a small area near the equipment and
could easily be abated. Therefore, the risk of contamination from spills to wetlands from
construction of the proposed SPVS is not significant.
4.2.2. Operation and Maintenance
Surface Water
To ensure soil erosion concerns do not extend during the operation and maintenance phase,
permanent erosion control measures at Site 1 would include a permeable layer of aggregate and
vegetation that stabilizes soils and allows water to permeate into the soil. Aboveground runoff
during a heavy rain event would be supplemented by stormwater inlets located south of the site
that drain to a culvert that exists on the Edison Facility property across the southeastern
boundary.
The potential for leaks or releases of dielectric fluids, fuels, and oils is minimal due to use of
BMPs and implementation of spill prevention plans. Additionally, transformers are sealed for
operation, and no removal or refilling of fluids occurs as part of operation and maintenance.
Therefore, the lack of fluid handling negates the risk of spillage from routine maintenance.
Ground Water
Potential ground water contamination sources that may exist during operation and maintenance
of the SPVS are limited to leakage of dielectric fluid from transformers. In the unlikely event of
leakage, impacts to ground water would be localized and minimal based on the limited quantities
of dielectric fluid stored in transformers.
Operation and maintenance of the proposed SPVS is not expected to affect the ongoing ground
water-monitoring program by the USAGE on the Edison Facility. If requested by the USAGE,
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
August 2009
SPVS equipment should be taken out of service to accommodate the ongoing remediation effort
at Site 1; no remediation/investigation efforts are underway at Site 7.
Floodplaim and Wetlands
The environmental consequences to floodplains and wetlands as part of operation and
maintenance of the proposed SPVS are similar to those expected for surface waters. Significant
impact to wetlands or floodplains is unlikely.
4.2.3. Conclusion
Impacts from soil erosion and accidental spills to water resources, including surface water,
ground water, floodplains, and wetlands are expected to be minimal at both of the proposed sites
and do not present a potential for significant impact to the environment.
4.3. AIR QUALITY
Edison, NJ, is in a nonattainment area for PM-2.5 and Ozone. Since Ozone is not a pollutant that
is emitted directly into the atmosphere, Ozone precursor pollutants, such as CO and VOCs, must
be analyzed to determine the potential for Ozone impacts. Based on the nonattainment status for
both these pollutants, the threshold for significant air pollutants is 100 tons/year for PM-2.5, CO,
and VOCs. To determine if the Proposed Action would contribute to air pollution above these
thresholds, an air conformity applicability analysis was conducted. Air quality impacts
associated with the construction, operations and maintenance, and dismantling of the SPVS are
primarily related to increases in vehicle emissions associated with the heavy equipment in the
construction and dismantling and the delivery of construction materials via truck to and from the
workplace.
The U.S. EPA Non-Road Emissions Model (1999) was used to calculate the air emissions. A
sample set of equipment was set up for construction, operation, and dismantling the proposed
SPVS. Table 4.3-1 depicts the equipment used in the model.
Table 4.3-1: Equipment Modeled for Air Quality Analysis
Phase
Construction
Operation
Dismantling
Equipment
Bulldozer, Crane, Welder, Front End Loader, Flatbed Truck, Concrete
Truck, Backhoe, Scraper, Dump Truck, Grader, Trencher
Pressure Washer, Air Compressor
Bulldozer, Crane, Front End Loader, Flatbed Truck, Backhoe, Scraper,
Grader, Dump Truck
Appendix B presents details on the air emission calculations used in this analysis. All emissions
calculations were completed using the worst case scenario and included no natural mitigation
measures.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
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4.3.1. Construction and Dismantling
Construction and dismantling activities that have the potential to result in air emissions impacts
include fugitive dust impacts from surface disturbance and ground excavation activities
(primarily at Site 1), building removal and demolition (during the construction phase at Site 7),
use of construction equipment (during construction phase at both sites), equipment removal
(during the dismantling phase at both sites), and an increase in vehicle access to the site (during
the construction and dismantling phases). Any air emissions impacts associated with construction
and dismantling the SPVS would be temporary in nature and easily mitigated by applying BMPs
such as watering the ground on a regular basis during construction to reduce fugitive dust and
prohibiting the idling of trucks.
Construction activities from the equipment listed in Table 4.3-1 would cause a temporary
increase in all areas of NAAQS criteria pollutants. The emissions associated with construction
are shown in Table 4.3-2. Site 7 includes emissions associated with the demolition of the
existing buildings structures. As shown in the table, emissions would be below de minimis
standards. As a result, there would be a minor adverse, but less than significant, air quality
impact associated with construction emissions.
Table 4.3-2: Construction Air Quality Emissions (tons)
VOC CO NOX CO2 SO2 PM
Sitel
Site?
De minimis Standard
% De minimis
0.09
0.14
100
0.14%
0.38
0.59
100
0.59%
0.72
1.03
100
1.03%
54.55
77.85
N/A
N/A
0.19
0.27
100
0.27%
0.08
0.11
100
0.11%
As shown in the table, emissions would be below de minimis standards. As with construction,
activities involving dismantling would create fugitive dust impacts; however, these impacts
would be temporary in nature and easily mitigated by applying BMPs, such as watering the
ground on a regular basis during construction. As a result, there would be a minor adverse, but
less than significant, air quality impact associated with the dismantling of the SPVS.
Table 4.3-3: Dismantling Air Quality Emissions (tons)
VOC CO NOv CO, SO, PM
Sitel
Site 7
De minimis Standard
% De minimis
0.07
0.11
100
0.11%
0.28
0.45
100
0.45%
0.53
0.81
100
0.81%
39.24
61.55
N/A
N/A
0.13
0.21
100
0.21%
0.05
0.09
100
0.09%
4.3.2. Operations & Maintenance
The primary contributors to air emission in the operation and maintenance phase of the project
are from the use of air compressors and the pressure washers. For the purposes of this analysis,
weekly washing and blowing with compressed air was assumed as a worse case. The emissions
associated with operations and maintenance are shown in Table 4.3-4. Unlike construction and
dismantling, there would be no ground disturbance and therefore no fugitive dust impacts
associated with operations and maintenance. As a result, there would be little to no air quality
impact associated with operations and maintenance emissions.
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Table 4.3-4: Operations & Maintenance Air Quality Emissions (tons)
VOC CO NOv CO, SO, PM
Sitel
Site?
De minimis Standard
% De minimis (worse case)
0.0034
0.0103
100
0.01%
0.1421
0.4264
100
0.42%
0.0007
0.0021
100
0.00%
0.2879
0.8638
N/A
N/A
0.0001
0.0002
100
0.00%
0.0000
0.0001
100
0.00%
4.3.3. Conclusion
The emissions associated with the Proposed Action would increase emissions by less than 2.0%
annually and would not hinder maintenance of the NAAQS within the region of influence.
Temporary fugitive dust impacts would be temporary in nature and easily mitigated with regular
watering of the affected ground; vehicle emissions impacts would be mitigated as much as
possible by prohibiting truck idling. Based on these findings, there would be an adverse, but
insignificant, impact associated with air quality emissions due to Proposed Action. Additionally,
the use of renewable energy creates a positive impact by reducing the greenhouse gas footprint
of the Edison Facility.
The energy generated by the solar panel array would create no air emission in them but would
result in a net savings of air emissions not being generated through conventional means for the
production of the electrical power. Table 4.3-5 depicts the annual savings generated by the use
of the SPVS creating the energy from a renewable source.
Table 4.3-5: Annual Emissions Saved Using Renewable Energy Source (tons)
Site 1 Savings
Site 7 Savings
Both Site Savings
No Action
2.76
10.52
13.38
0
1,370.00
5,215.00
6,585.00
0
3.27
12.45
15.72
0
(Watts, 2009)
4.4. BIOLOGICAL RESOURCES
4.4.1. Construction and Dismantling
Vegetation and Wildlife
Under the Proposed Action the majority of Site 1 would be disturbed for SPVS construction and
dismantling activities, including the open field of landscaped turf and trees. Portions of the
forested and wetland areas adjacent to Site 7 would potentially be disturbed or removed due to
construction activities (e.g., connections to the transmissions lines). Construction and
dismantling impacts to either site are expected to be minimal and insignificant because the sites
are already currently developed, construction BMPs would be utilized, and no long-term changes
in biological habitat would be anticipated to result.
Endangered, Threatened and Rare Species
Based on the previous ecological surveys, referenced in Section 3.4, it is unlikely that there are
any federally or state listed endangered, threatened, or rare species in the immediate area of the
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Proposed Action at either site alternative. However, state-listed endangered or threatened bird
species were previously observed to be present in the vicinity of Edison Facility. It is unlikely
such species would be adversely impacted by construction or dismantling activities at either site
alternative. Both Site 1 and Site 7 are currently developed with little to no vegetation, and
neither site would be expected to have suitable habitats for breeding or nesting. Therefore, it is
unlikely any endangered, threatened or rare species would be significantly impacted by
construction activities associated with the Proposed Action.
In addition, the FWS Northeast Regional Office was consulted in May 2009 regarding federally
listed endangered, threatened, and rare species within the Proposed Action's project area, and
this office deferred to the FWS New Jersey Field Office (NJFO). The FWS New Jersey Field
Office currently maintains a policy (effective March 2009) that does not require federal agencies
such as the EPA to seek consultation with the FWS if existing information and field surveys
demonstrate that no potentially suitable habitat is located within the project's action area (i.e., the
affected environment). (FWS NJFO, 2009). The FWS New Jersey Field Office provides a
template for federal agencies to document the FWS's policy not to provide concurrence with a
"no effect" determination. This letter is included in Appendix C.
4.4.2. Operation and Maintenance
Vegetation and Wildlife
Possible impacts from the operation and maintenance of the proposed SPVS may result from
typical anticipated maintenance activities. Maintenance activities include removing and
trimming of any trees or vegetative that would potentially shade the SPVS panels. However, it is
expected that little to no trees on either site would be affected by this, as both sites currently have
very few trees.
In addition, the SPVS array may create perching opportunities for birds. This would not be
anticipated to harm the wildlife, but may require more frequent cleaning and washing of the solar
panels to remove possible bird droppings. (DOE, 2009). EPA has included language the SPVS
scope of work that requires the contractor to use environmentally preferable products for any
cleaning that will take place during the operation and maintenance phase. Thus, this would not
be expected to significantly impact the surrounding wildlife and vegetation.
Lastly, the SPVS site design is expected to include measures such as fencing to prevent predators
and other animals from entering the site. None of the above-mentioned potential impacts on
vegetation and wildlife are expected to be significant or adverse.
Endangered, Threatened and Rare Species
Based on previous ecological surveys, referenced in Section 3.4, it is unlikely any federally or
state listed endangered, threatened and rare species would have habitats in the immediate vicinity
of the SPVS. However, state-listed bird species were previously observed to be present in the
vicinity of Edison Facility. It is unlikely such species would be adversely impacted by operation
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
and maintenance activities at either site alternative. Any impacts resulting from operation and
maintenance of the SPVS are expected to be negligible. For example, the SPVS may create
perching opportunities for birds, but the panels would not likely be suitable nesting or breeding.
It is unlikely any endangered, threatened, or rare species would be impacted by operation and
maintenance activities associated with the SPVS.
4.4.3. Conclusion
The Proposed Action is not expected to impose significant impacts on local vegetation and
wildlife or any endangered, threatened, and rare species. There would be no anticipated
significant impacts on biological resources resulting from the construction, operation and
maintenance, or dismantling of the proposed SPVS at any of the Proposed Action alternatives.
4.5. CULTURAL RESOURCES
The Proposed Action would not have an impact on either the buildings associated with the
Former Raritan Arsenal Historic District or the two historic properties located off-site (i.e.,
Bonhamton School and the Bonhamton Grace Reformed Church).
Mitigation has been completed for the EPA owned buildings located on Site 1, FIRMP Zone 4,
through HABS/HAER documentation as required in the MOA. If Site 7 were chosen as the
location for the solar array, it would be necessary to remove the two Korean War-era
warehouses, Buildings 245 and 246. These buildings are considered contributing elements to the
Raritan Arsenal Historic District, and as such, adverse effects to this area would be mitigated
through a Level One HABS/HAER recordation.
As previously stated, the area surrounding the non-EPA owned historic properties has not
retained integrity of setting. The Proposed Action would not introduce viewshed concerns that
could produce adverse effects to cultural resources. Additionally, the Proposed Action is
temporary as the SPVS would be leased for 10 years to a contractor with an option to operate for
10 more years. Therefore, the introduction of the SPVS to the viewshed of these buildings
would not be permanent. The Edison Facility property is currently fenced, and additional fences
that may be constructed for the Proposed Action are not anticipated to create viewshed concerns.
Due to the degraded setting of the historic properties within the viewshed and the temporary
nature of the Proposed Action, none of the actions associated with the Proposed Action,
including construction, operation and maintenance or dismantling, would affect cultural and/or
historic resources within and near the project sites.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
August 2009
4.6. NOISE
4.6.1. Construction and Dismantling
Vehicles and equipment involved in the SPVS construction and dismantling would generate the
primary noise from the Proposed Action. The typical noise levels generated by these activities
range from 74 to 84 A-weighted decibels (dBA) at approximately 50 ft from the source. Table
4.6-1 illustrates the anticipated sound pressure levels at a distance of 50 ft for the miscellaneous
heavy equipment.
Table 4.6-1: Heavy Equipment Noise Levels
Equipment Type Number Used Noise Levels (dBA)
Bulldozer
Backhoe (rubber tire)
Front Loader (rubber tire)
Dump Truck
Concrete Truck
Concrete Finisher
Crane
Flat-bed Truck (18 Wheel)
Scraper
Grader
Trenching Machine
1
1
83
74
80
78
82
79
82
78
84
83
77
Estimate based on typical construction scenario
(DOT, 1981)
There would be a temporary increase in noise during construction and dismantling activities
associated with the Proposed Action. Construction noise would be comparable to noise
generated from trucks and heavy equipment used in the surrounding commercial industries.
In the unlikely event that all of the equipment would be active at once, the noise level generated
by at Site 1 could reach 68.27 decibels (dB) at 500 feet from the site, well within the Edison
criteria for an Industrial site (see Table 3.6-1). For the two sensitive receptors (Bonhamton
School and Bonhamton Grace Reformed Church), which are located on the north side of
Woodbridge avenue approximately 1,200 feet from the center of Site 1, the noise emanating
from the construction at Site 1 would be indistinguishable from the traffic noise emanating from
the nearby and intervening Woodbridge Avenue.
Noise impacts associated with Site 7 would be almost completely muted by the rising terrain and
vegetation surrounding the site. Because of the terrain and buffer vegetation, any noise that
would emanate from construction activities at Site 7 is not expected to significantly impact the
nearby Middlesex County College campus. Additional noise at Site 7 may include noise
emanating by transmission line trenching activities, if required.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
4.6.2. Operation and Maintenance
The operation of the solar panels would be virtually silent for a fixed array. An array that is
tracked to align itself with the relative position of the sun would have very minimal noise
emanating from the small electrical motors powering the tracks as they align the surface to face
the sun. Maintenance of the solar panels would include washdown of the solar panels with water
or using air blowers to remove any dust or debris, but this activity would be very infrequent.
(VanGeet, 2009). Pressure washers, air blowers, and compressors would result in temporary and
minimal noise impacts.
4.6.3. Conclusion
The noise associated with the Proposed Action would be greatest during construction and
dismantling of the SPVS. Although impacts are anticipated to be adverse at times during the
construction and dismantling phases, they would be for short periods of time and only occur
during work hours to minimize the impact to any nearby receptors. They are not anticipated to be
significant due to significant levels of street traffic and other industrial noises currently present
surrounding the site and the presence of thick foliage and other natural noise barriers. The noise
associated with the operation and maintenance of the solar panels would be virtually non-
existent; and therefore not be significant.
4.7. VISUAL RESOURCES
The area around the Edison Facility is fully developed with a combination of industrial, housing
and commercial uses. The relatively low profile of the proposed SPVS means that there would
be little visual impact to the areas directly surrounding the proposed project sites. Due to the
temporary nature of the Proposed Action, the SPVS would not negatively impact existing
buildings or spaces within the APE. The placement of the SPVS on Site 1 would allow it to be
partially visible from non-EPA owned properties, predominantly from the area north of and
along Woodbridge Avenue. The solar panels would stand approximately 10-12 feet tall at the
highest point.
The SPVS at Site 1 would create changes to the landscaped grounds and the Edison Facility
viewscape. Figure 4.7-1 provides an artist's conception of how the SPVS at Site 1 would appear
from directly overhead and from the west side of the array looking to the North. Site 1 would
also be enclosed within a security fence that would limit public access but would still provide
passing traffic with a view of the solar panels.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
August 2009
Figure 4.7-1: Aerial and surface rendering of the proposed Site 1
While the change in viewscape would be visible from Woodbridge Avenue, the SPVS would be
aligned to face away from the Avenue and toward the sun. This would prevent any possible
problems with sun glint, reflection, or glare from the panels. The double tree line between the
proposed SPVS and Woodbridge Avenue would also provide a partial sight barrier to the panels.
These trees are very young and it is anticipated they would grow and with time provide even
more of a visual barrier. As a result, the impacts would be minor and not significant.
Site 7 is located to the Southeast of the Edison Facility in an area that has high ground to the
north and west. The high ground around Site 7 is tree covered and also has heavy underbrush.
As a result, Site 7 is not visible from the surrounding areas outside the Edison Facility grounds
and therefore would not have visual effects to non-EPA owned properties. Similarly to Site 1,
Site 7 would also be enclosed within a security fence that would limit access. The orientation of
the panels at Site 7 would be similar to how they are depicted for Site 1 in Figure 4.7-1.
4.8. LAND USE
The SPVS would be installed under a land lease agreement with the IPP. The term of the lease is
expected to be 10 years with an option to extend for a second 10-year term. Based on the terms
of the lease, the SPVS would be dismantled at that time and the site would be returned to its
previous use. In the case of the proposed Site 1, the land is currently vacant and unused. Site 7
is currently unused; however, it is improved with two vacant warehouses, both of which would
be demolished to construct the array if this site is selected. If site 7 were to be selected, the
SPVS would be dismantled upon termination of the lease and would be vacant. Based on the
lease terms, the Proposed Action would only have a temporary impact on the land use of the
selected site(s), but no significant impact to the long-term land use is expected.
Operation of the SPVS appears to be consistent with current zoning designations for the EPA
property; however, project authorization through the Edison Township Zoning Board would be
required. Based the Proposed Action's alignment with current zoning and the passive nature of
the Proposed Action, the potential for adverse effects to land use of neighboring properties is not
significant.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
4.9. HUMAN HEALTH AND SAFETY
4.9.1. Construction and Dismantling
Implementation of the Proposed Action would involve activities typical of construction projects.
The contractor would be expected to ensure that construction and dismantling activities comply
with OSHA standards and other applicable engineering and construction standards and codes,
such as the National Electrical Safety Code (NESC). The contractor is expected to plan for
potential site-specific risks (e.g., possible UXOs) and potential risks specific to solar array panel
installation (e.g., danger of electric shock). Construction workers are expected to receive
appropriate safety training, hold the proper certifications, and be knowledgeable in solar panel
installation and its applicable hazards and precautions. For example, prior to installation, solar
panels would be expected to remain in a shaded staging area and not in direct sunlight, to prevent
possible burns from handling the panels. In addition, the contractor is expected to develop a
worker health and safety plan which would need to be in accordance with any existing health and
safety plans at the Edison Facility.
At Site 1, where there is an existing ground water contamination plume, construction and
dismantling activities may require additional personal protective equipment (PPE) for workers,
such as protective clothing and gear. However, this is unlikely, given that the ground water is
not expected to be disturbed. The contractor is expected to coordinate with EPA and the USAGE
to ensure that proper precautions are taken and best practices are implemented.
At Site 7, during the construction phase, where there are existing warehouse facilities subject to
demolition, workers may be exposed to additional health and safety risks, such as rust, fugitive
dust, rubble, falling hazards, and falling overheard components. Risks from handling ACM are
not anticipated, as the facilities have previously undergone ACM removal and remediation.
(Cho, 2009). However, there may be potential risks associated with the handling of demolished
building materials that contain lead-based paint. The contractor is expected to provide
appropriate health and safety training as well as proper PPE, respirators or other protection for
their workers.
4.9.2. Operation and Maintenance
The Proposed Action would involve operation and maintenance activities that may expose on-
site personnel to health and safety risks. The SPVS site design is expected to be protected on all
sides; safety and security measures would likely include enhanced fencing, locked entrances, and
signage to prevent unauthorized entrance onto the site, and to protect against danger of electric
shock. Because the contractor would be responsible for all aspects of operating and maintaining
the SPVS, they would also be responsible for training their personnel on related health and safety
precautions related to the SPVS. The contractor would be expected to ensure that operation and
maintenance activities comply with all applicable health and safety standards (e.g., OSHA).
While EPA and other Edison Facility personnel are not expected to participate in the operation
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
and maintenance of the SPVS, the Edison Facility would likely train their personnel on basic
safely protocol, such as whom to notify if they observe an issue at the SPVS site.
4.9.3. Conclusion
Health and safety risks are expected to be minimal and temporary, and the contractor is expected
to effectively manage these risks with measures such as developing a worker health and safety
plan, providing PPE for workers, implementing protocols during SPVS operations, and
installing secure fencing. Therefore, the potential health and safety impacts resulting from
construction, operation and maintenance, and dismantling of the SPVS are expected to be
minimal and insignificant.
4.10. UTILITIES AND INFRASTRUCTURE
4.10.1. Construction and Dismantling
Electrical Utility Management
Construction and dismantling of the proposed SPVS would be expected to temporarily require
additional electrical demand to serve construction equipment and other typical activities.
Construction and dismantling of the SPVS may also require temporary electrical utility service
interruptions for the Edison Facility. For Site 1, connection to the utility transmission line would
be readily available within 25 feet. For Site 7, connection to the utility transmission line would
be located approximately 40 feet from the site. Construction of the SPVS at Site 7 may require
additional trenches and lengthier connections to the utility transmission lines. Connections to the
transmission lines would be constructed along existing roadways' right-of-way.
After the SPVS is dismantled, the Edison Facility would no longer provide solar-derived
electrical power to the electrical utility company. The utility would be expected to anticipate for
this change in electrical demand, reverting back to providing the previous electrical power
demand prior to the construction and operation of the SPVS. Though the Edison Facility would
no longer purchase the majority of electrical power through a contract involving the SPVS, the
Edison Facility would continue with normal operations and would continue to obtain service
from a local electrical utility company.
None of the above-mentioned impacts are expected to be significant.
Potable Water and Wastewater
There would likely be a temporary increased use of the potable water and wastewater
infrastructure due to an increase in site personnel during construction and dismantling activities.
In addition, because of ground disturbance and digging activities, some of the existing potable
water and wastewater lines at Site 1 or Site 7 may require relocation or removal. Site 7 may also
require relocation or removal of existing connections or fixtures, due to the demolition of the
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
existing storage facilities. Temporary water service interruptions at the Edison Facility are
unlikely, but may be necessary during construction activities.
Stormwater Management
Stormwater runoff originating from any of the site alternatives would likely have an increase in
sediment due to expected ground disturbance during construction activities associated with the
Proposed Action. Disturbed areas are expected to be graded and designed appropriately so that
Stormwater flow is still directed to the existing Stormwater collection network and toward the
drainage outfall culvert. EPA has inserted sustainable development requirements into the project
scope of work to require the contractor to ensure the Stormwater profile of the site meets all
federal requirements (e.g., EISA Stormwater management requirements). The contractor would
be expected to implement BMPs for erosion/sediment control and Stormwater management
during these activities to minimize impacts on the existing Stormwater collection system,
wetlands, and other environmental resources. Specifically, the contractor would be expected to
implement precautions to prevent polluted runoff from affecting the porous parking lot south of
Site 1, as wells as the wetlands and Urban Watershed Management Branch research facility near
Site 7. In fact, the Stormwater projects near Site 1 could likely help mitigate any potential
Stormwater management issues originating from Site 1.
It is possible that there may be a temporary increase in Stormwater runoff from Site 1 because of
the removal of the landscaped turf and increase in impervious paved area. However, site designs
are expected to incorporate BMPs, and the contractor will be required to ensure the design meets
all federal Stormwater requirements. In addition, at Site 1, new drainage structures or other
Stormwater management facilities may need to be constructed to connect to the existing
Stormwater drainage network.
At Site 7, there would likely be no significant increase in impervious area, as the site is already
developed with mostly impervious area. As with Site 1, the contractor will be required to ensure
the design meets all federal Stormwater requirements. New Stormwater drainage connections
may need to be constructed to direct flow into the nearby wetlands, and some existing drainage
structures may need to be removed or relocated. In addition, there may be additional ground
disturbance due to the possible trenches for connecting the SPVS to the electrical transmission
lines.
After dismantling the SPVS at Site 1, the contractor is expected to remove the concrete footings
and return the grounds to their previous condition (i.e., landscaped turf). This would likely
reduce the Stormwater runoff back to its pre-development conditions. At Site 7, the concrete slab
would remain in place, and Stormwater runoff quantity would not be affected.
Storage Tank Management
The Proposed Action would not include changes or improvements to any existing fuel storage
tanks, nor is the Proposed Action expected to include construction of any new fuel storage tanks.
Because the storage tanks (and any associated pipes or connections) are not located on or
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
adjacent to Site 1 or Site 7, the storage tanks not expected to be disturbed by construction or
dismantling activities. In addition, the tanks are not located in the anticipated pathways of heavy
equipment or delivery trucks. Thus, no expected impacts on storage tank management would
result from the construction and dismantling activities associated with the Proposed Action.
4.10.2. Operation and Maintenance
Electrical Utility Management
The Edison Facility would continue to operate on a standard federal weekday schedule of 12
hours per workday, Monday through Friday (6:00 am to 6:00 pm). No significant increase in
worker population is expected in the near future, and thus, there would be no significant
electrical power demand increase or reduction resulting from this.
The Edison Facility would continue to obtain electric service from an electrical utility company,
which is currently PSE&G. The utility would obtain the solar-derived photovoltaic electricity
from the SPVS, and in turn, provide electrical power to the Edison Facility through an offset.
The SPVS electrical production would be metered and measured, as the Edison Facility's
consumption is metered and measured. The Edison Facility's electrical usage would be charged
an additional flat rate if the usage exceeds the SPVS production. However, the electrical power
delivery to the Edison Facility would not be based upon the SPVS' collection and production
(i.e., the utility would continue to provide electricity to the Edison Facility, even when the
Edison Facility's demand exceeds the SPVS production). This includes emergency and other
situations as well; if the SPVS temporarily undergoes maintenance, operates at a lower
efficiency, or is shut down due to damage or system failure, the Edison Facility would continue
to obtain electrical service from the local utility. During power outages where the local utility
and/or power grid are unable to provide electrical service to the Edison Facility, the existing
emergency generator on site would be used temporarily. The SPVS would not produce electrical
power when the sun is not present and would not have any energy storage capabilities.
Based on a review of the Proposed Action site alternatives' electrical production capacities (refer
to Table 2.2-1), it is anticipated that the Proposed Action at Site 1 could meet approximately
30% of the current existing electrical power demand, and Site 7 could meet more than 100% of
the current Edison Facility electrical power demands. The combined alternative at Site 1 and 7
would also more than meet the electrical power demand of the Edison Facility.
While normal operations would continue, the Edison Facility would no longer purchase the
majority of their electrical power from the local utility, and the SPVS would provide an
additional electrical power source for the local electric grid. It is expected that the SPVS would
reduce the electricity demand on the local electrical utility providers. The Edison Facility would
still procure green power Renewable Energy Certificates (RECs) as a swap for the solar REC's
developed under this project.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Potable Water and Wastewater
There would likely be a minor increase in the potable water use due to cleaning and washing of
the proposed SPVS; however, this maintenance is likely to be infrequent, as the contractor is
expected to rely on precipitation as much as possible to wash the solar panels. Washdown from
these cleaning activities would be expected to drain into the wastewater or stormwater collection
system. If floor drains are constructed on the SPVS concrete slab and connected to the
wastewater collection system, this would contribute to a minor increase in the use of the Edison
Facility's wastewater infrastructure.
Stormwater Management
It is possible there would be a minor increase in the stormwater runoff water use due to
cleaning/washing of the proposed SPVS, although this would likely be infrequent. Washdown
from these activities would be expected to drain into the wastewater or stormwater collection
system, but it is possible that the washdown would infiltrate into the ground or surrounding
vegetated areas. However, the water would not be expected to contain toxic or hazardous
substances or a significant increase in sediment. Therefore, there would be no anticipated
adverse impacts on the stormwater runoff.
Storage Tank Management
No significant impacts to storage tank management are expected to occur due to the operation
and maintenance of the proposed SPVS. It is unlikely the SPVS would contribute to the
occurrence of power outages. Operation and maintenance activities associated with the Proposed
Action at any of the site alternatives would likely result in no impacts on the storage tank
management.
4.10.3. Conclusion
Construction activities associated with the Proposed Action at either site alternative would have
negligible impacts on the existing utilities and infrastructure management.
After construction is completed, the operation and maintenance of the SPVS at either site
alternative would reduce demand on the local electric utility and would create additional
electrical power for the local grid. The anticipated impact on the electrical utility management
would be potentially beneficial but not significant. Other operation and maintenance activities
associated with the Proposed Action would likely result in minimal impacts on the existing
potable water, wastewater and stormwater infrastructure.
Dismantling activities at either site alternative would likely result in similar impacts from
construction of the SPVS. In addition, the SPVS would no longer provide solar-derived
electrical power to the local electrical utility, but the Edison Facility would continue its normal
operations and receive electrical power from the local utility company.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
No significant impacts are expected to result from construction, operation and maintenance, or
dismantling of the SPVS.
4.11. WASTE MANAGEMENT
4.11.1. Construction and Dismantling
Solid Waste
Construction of the proposed SPVS would be expected to temporarily generate solid wastes.
Solid wastes that would be generated may include concrete, scrap wire, masonry, packing
materials, and debris. EPA is inserting recycling and reuse requirements that meet all federal
requirements into the project scope of work, the contractor will be required to ensure the design
meets all federal pollution prevention requirements. The contractor would be directed to recycle
materials, where feasible, thereby reducing the amount of debris disposed in landfills. Solid
waste not recycled by the contractor would likely be directed to an approved landfill, and it is
possible that some solid waste (e.g., concrete rubble) would be left on site per EPA's direction.
At Site 1, demolition of existing buildings would not occur and the solid waste generation at this
site is anticipated to be minimal. Because Site 1 previously included building facilities, some
concrete, rubble and other aggregates (i.e., beneath the topsoil and sod) may be removed during
construction activities. The amount of waste generated by the Proposed Action at Site 1 would
likely not have a significant impact on the operating life of the landfill.
At Site 7, there would be a large volume of solid waste generation, including a potentially large
volume of waste containing lead-based paint due to the demolition of the existing storage
facilities. Per New Jersey disposal regulations, the contractor would need to make a
determination for the appropriate type of disposal (i.e., determine if the demolition wastes are
classified as hazardous or solid waste). (NJDEP, 2004b). If the demolition wastes containing
lead-based paint are not classified as hazardous waste then the contractor will dispose of the
waste in a municipal solid waste landfill. In addition, the buildings are made of steel frame,
concrete masonry, and roofing materials, which would require removal and demolition. The
remaining concrete slab building foundation would be reused as the concrete slab foundation of
the SPVS. Some of the solid wastes from Site 7, particularly the steel from the buildings, are
likely to be recycled. Because of the volume expected to be generated from demolition and
because of the opportunity for steel recycling, the Proposed Action at Site 7 can possibly be both
beneficial and adverse. However, no significant impacts to solid waste management are
anticipated to result.
Solid wastes would be generated when dismantling the SPVS components; these wastes would
be disposed of or recycled. PV panels are generally accepted at and safe for landfills, because
the panel and solar cell materials are usually encased in glass or plastic, and most of the materials
are insoluble. (DOE, 2009; DOE National Renewable Energy Laboratory [NREL] EA, 2007).
However, as stated previously, some constituents could be classified as toxic or hazardous
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
substances, a situation that is prompting the PV industry to develop recycling processes for
modules. Because solar panel disposal is in its infancy, it is not possible to specify if the
dismantled SPVS panels would ultimately be able to be recycled. (DOE NREL EA, 2007).
Thus, the dismantling of the SPVS would likely create solid waste and would create an adverse,
but insignificant, impact on the local receiving landfill with respect to solid waste management.
It is expected that the solid wastes generated from the dismantling activities would be the
responsibility of the utility/operating contractor.
Hazardous Waste
At Site 1, there is an existing ground water contamination plume. However, no hazardous waste
management impacts are expected to result from activities associated with this contamination,
given that the construction activities are not expected to disrupt the ground water table. The
contractor is expected to coordinate with EPA and the USAGE to ensure that proper precautions
are taken and best practices are implemented.
At Site 7, construction activities would create a potentially large volume of waste containing
lead-based paint, due to the demolishing of the warehouse buildings. Per New Jersey disposal
regulations, the contractor would need to make a determination for the appropriate type of
disposal (i.e., determine if the demolition wastes are classified as hazardous or solid waste).
(NJDEP, 2004b). If the demolition wastes containing lead-based paint are classified as
hazardous waste then the contractor will need to make additional arrangements to properly
manage, transport, and dispose of the waste, and the contractor may be required to remediate the
waste prior to disposal. No significant increase in hazardous wastes or impacts to hazardous
waste management are anticipated.
In addition, the following potential impacts may occur and would apply to both site alternatives:
It is likely the construction and dismantling activities would require the use of potentially
hazardous materials, such as petroleum, oils and lubricants (POLs). All hazardous
materials and construction debris used during construction and dismantling activities
would be handled, stored, and disposed of in accordance with federal, state, and local
regulations and laws.
The SPVS would require components which may contain hazardous substances, such as
electrical connections to the power grid (e.g., lead soldering). Some models of solar
photovoltaic panels may also contain trace amounts of hazardous materials and heavy
metals, such as arsenic or cadmium. While solar panels are sealed under normal
operating conditions, there is the potential for minimal risks if they are damaged during
construction and dismantling activities. (DOE, 2009). However, the potentially
hazardous constituents in the solar panels are solid (i.e., they are not liquid or gaseous
and thus would not be prone to leaking or dispersing), and these materials would not
expected to cause any contamination in soils or groundwater if the panels were de-
commissioned properly upon being damaged (Fthenakis, 2009).
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While potential impacts listed above may occur during construction and dismantling, the
likelihood of such events is very small, and best practices are expected to be implemented to
ensure proper management and control of these events. Therefore, potential impacts associated
with hazardous waste from construction activities at any of the site alternative are expected to be
minimal and insignificant.
Sanitary Waste
The volume of sanitary waste generated is likely to increase during construction and dismantling
activities due to the increase of site personnel at the construction site. It is expected that portable
toilets would be provided by an external contractor. This contractor would be expected to
properly manage and dispose of the sanitary wastes through the proper wastewater treatment
authority.
4.11.2. Operation and Maintenance
Solid Waste
Solar photovoltaic panels are encased and sealed in glass or plastic and typically have useful
lives of up to 30 years. (DOE NREL EA, 2007; Brookhaven National Laboratory [BNL], 2003).
While there is a potential over the life of the SPVS for a panel to break or require replacement,
under normal operating conditions, the solar panels would not require frequent replacement or
disposal. Infrequent, isolated replacement of solar panels or other equipment over the course of
the operation and maintenance of the SPVS may occur; this would not cause a significant
increase in solid waste.
Hazardous Waste
As mentioned previously, some models of solar photovoltaic panels may also contain trace
amounts of hazardous materials, such as lead, arsenic or cadmium. It is highly unlikely that
these substances would lead to environmental contamination during operation and maintenance
(Fthenakis, 2009). In addition, while other components of the SPVS, such as the transformers,
are not expected to contain hazardous wastes (e.g., PCBs), but they may contain POLs and other
fluids. Potential leaks from these transformers would be very unlikely and insignificant. The
utility company would be expected to implement proper maintenance and inspection practices to
prevent such leaks.
Sanitary Waste
No increase in sanitary wastes are anticipated to result from the operation and maintenance of the
SPVS.
4.11.3. Conclusion
Potential impacts resulting from construction, operation and maintenance, or dismantling
activities associated with the Proposed Action are not expected to have any significant impacts
on solid, hazardous, and sanitary waste management.
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
4.12. TRANSPORTATION AND PARKING
4.12.1. Construction and Dismantling
There would be a temporary increase in traffic accessing the Edison Facility while a staging area
is set up for the construction and dismantling activities. Heavy equipment, as shown in the
Section 4.3 and 4.6, would access the Edison Facility grounds during these project phases and
could potentially hamper the traffic flow in and out of the facility during peak times. However,
once the staging area is established, this traffic surge created by large delivery trucks and heavy
equipment would then be limited to access to the Edison Facility by construction workers.
Edison Facility has adequate roads and parking to accommodate utility vehicles, negating the
need for road alterations or off-site parking. This would be true for all phases.
4.12.2. Maintenance and Operation
The IPP would be completely responsible for the operation, maintenance and upkeep of the solar
panel array. It is anticipated there would be equipment housed at the Edison Facility for the
purpose of maintaining the solar panels. Minimal traffic and parking would be required on a
periodic basis for personnel to access the site for maintenance and upkeep duties.
4.12.3. Conclusion
There would be a minor increase in traffic accessing the Edison Facility during the construction
and dismantling phases. There would be little traffic activity associated with the operations and
maintenance of the SPVS. With all vehicles operating from a staging area, there would be only a
temporary impact on parking. As a result, the Proposed Action would not result in a significant
impact to transportation or parking.
4.13. SOCIOECONOMICS
This section addresses the socioeconomic impacts anticipated from the Proposed Action. The
impacts associated with the Proposed Action are not differentiated between the three phases of
the project. Socioeconomic impacts from the Proposed Action are expected to be minimal
because of the temporary nature of the proposed activities and substantial changes in the labor
force at the Edison Facility or surrounding community is not expected.
The construction and operation of the Proposed Action is not anticipated to impact employment
at the Edison Facility or in the surrounding community. The Proposed Action would neither
create nor eliminate any jobs at the Edison Facility. The construction activities at the Edison
Facility would not be expected to require additional EPA or construction contract employees to
be brought in from outside the local area. Therefore, the Proposed Action is not expected to
cause significant change or stress on local employment, community social services (i.e., fire,
police, or health services), or community demographics.
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4.14. ENVIRONMENTAL JUSTICE & PROTECTION OF THE CHILDREN
4.14.1. Environmental Justice
The Proposed Action would not be expected to cause adverse or disproportionately high impacts
to minority or low-income communities. Although the Edison Facility resides within the
proximity of residential areas, Middlesex County has median income rates 11.6% higher than the
State of New Jersey and 49.4% higher than the U.S., and poverty rates 28.7% lower than the
State of New Jersey and 89.3% lower than the U.S., and the Proposed Action's potential impacts
would be contained to the Edison Facility grounds. Therefore there would be no significant
impact on environmental justice from the Proposed Action.
Under the No Action Alternative, no adverse or disproportionately high impacts to minority or
low-income communities are expected as a result of construction activities related to the
Proposed Action, and no impacts would be expected from the solar power plant construction and
operation because such improvements would be precluded under the No Action Alternative.
4.14.2. Protection of the Children
The Proposed Action would not produce any environmental impacts that could
disproportionately affect infants or children. There would be no potential for releases of gasses,
particulate matter, or noise that is outside the scope of a similar construction project. The
Proposed Action would not produce excessive noise, and noise is expected to occur during
working business hours. Additionally, any increases in truck or large vehicle traffic would take
place during working business hours. Furthermore, some schools such as the Mosier
Community School in Mosier, Oregon and the Satori Elementary School in Galveston, Texas,
have installed SPVSs on campus to harness energy and serve as teaching tools. The Proposed
Action would not be expected to cause adverse or disproportionately high impacts to infants or
children. Therefore there would be no significant impact on children from the Proposed Action.
Under the No Action Alternative, no adverse or disproportionately high impacts to infants or
children would occur.
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5.0. CUMULATIVE IMPACTS
The CEQ Regulations (40 CFR 1500-1508) implementing the procedural provisions of NEPA
defines cumulative effects as:
The impact on the environment which results from the incremental impact of the action
when added to other past, present, and reasonably foreseeable future actions regardless
of what agency (federal or non-federal) or person undertakes such other action (40
CFR 1508.7).
Determination of cumulative impacts involves the consideration of both the affected
environment and environmental consequences of the connected actions. The environmental
consequences in all resource areas of this Proposed Action were of insignificant to minimal
levels of impact and are not expected to contribute to cumulative impacts over time.
Direct and indirect impact analysis focuses only on those resources that may be impacted by the
Proposed Action. Cumulative impacts analysis addresses these same resources from activities
reasonably foreseeable in the future, with the potential to interact with the Proposed Action,
together with past and present activities.
At this time, there are no reasonably foreseeable major projects outside Edison Facility grounds
that would significantly impact the facility. The Edison Facility has numerous projects
completed in the past few years and several more being contemplated. Table 5.0-1 shows many
of the recent and future projects of the Edison Facility grounds.
Table 5.0-1: Edison Facility Projects
Action Start Status Completion
Permeable Parking Experiment
Renovate Parking Area
Renovate Building 238
Building 205 Lab Improvements
Building 209 Boiler Replacement
USAGE Site Investigation
OSWER Modular Labs
2008
2008
2008
2008
2007
August 2009
Spring 20 10
On-Going
Complete
Complete
Complete
Complete
Final Work Plan Awaiting
Approval
50% Design
On-Going
Complete
Complete
Complete
Complete
Fall 2009
Spring 20 10
Two projects involved parking within Edison Facility grounds. One was an expansion of the
existing parking area and the other was to install an experimental permeable asphalt parking lot.
The purpose of the experiment is to determine various impacts associated with storm water,
runoff, and permeability with differing types of soils. The permeable parking lot experiment is
still on-going. Two of the projects involved building improvements (Building 238 and 205),
updating the buildings per code requirements, and one (Building 209) where a new boiler was
installed. Each of these projects was subject to the review of environmental impacts pursuant
NEPA and its implementation regulations.
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The USAGE has a site investigation planned for the end of summer 2009. This investigation
would include the drilling of monitoring wells and soil borings in the area proposed for Site 1.
The soil borings would begin in August 2009 and be complete by early fall 2009. The
monitoring wells would not be located in the proposed location of Site 1 of the SPVS. It is not
anticipated that these test borings or monitoring wells would pose any significant impact to the
Edison Facility and they would not impact the installment of the SPVS.
There is one project currently funded and is at the approximately the 50% design stage. This
project would install six replacement trailers in support of OSWER operations. Altogether there
would be approximately 5600 square feet of lab space added, and they proposed to be installed
on Building 211 pad. Minor construction would remove the existing pad and replace it with a
gravel base to allow for underground vents and electrical connections. (Beier, 2009). This
project is also subject to the review of environmental impacts pursuant NEPA and its
implementation regulations. This action would not incur significant impacts to the SPVS or the
Edison Facility.
The addition of the SPVS would not add any significant impacts nor is it anticipated that the
cumulative impacts of all of these actions would add up to significance in any resource area. The
potential installation of the SPVS along with the OSWER modular labs, should they occur
simultaneously, would not result in any significant impacts.
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6.0. FINDINGS & CONCLUSION
6.1. FINDINGS: IMPACT ANALYSIS
Using the No Action Alternative as the baseline for assessing potential impacts from the
Proposed Action, the following potential issues and concerns have been identified:
Temporary and localized impacts to ground resources in the land disturbance areas, such
as soil erosion and sedimentation during construction;
Water resources, including wetlands and floodplains are not expected to be affected by
the Proposed Action because proper utilization of BMPs would protect against erosion
impacts and leaks and spills;
Temporary adverse, but not significant, impacts to air quality from heavy equipment
emissions and increases in fugitive dust and airborne particulates from construction and
dismantling related activities;
Adverse, but not significant, impacts to biological resources (vegetation);
No impacts to cultural resources would be expected because any impacts to the buildings
associated with the Former Raritan Arsenal Historic District would be managed through
an existing Memorandum of Agreement between the Edison Facility and the State
Historic Preservation Office (SHPO);
Temporary impacts to ambient noise from construction and dismantling related activities;
Adverse, but not significant, impacts to visual resources would occur;
Temporary adverse, but not significant, impacts to human health and safety, associated
with the handling of demolished building materials that contain lead-based paint;
Utilities services would not be expected to increase significantly as a result of the
Proposed Action;
Adverse, but not significant, impacts to waste management from construction and
dismantling activities. An increase in solid waste and possible hazardous waste (due to
the lead-based paint), would be generated from the demolishing of the warehouses at Site
7; and
Local roadways and parking are adequate to support movement of construction
equipment and materials to the project area and there would be a minor and temporary
impact to traffic accessing the Edison Facility grounds during the construction and
dismantling phases.
An analysis of available information also presents the following findings:
Threatened and endangered species are not expected to be affected by the Proposed
Action due to the lack of species and species habitat within or near the vicinity of the
Proposed Action;
Land use impacts would be expected to be consistent with existing and future land use
planning;
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Socioeconomics are not expected to be affected by the Proposed Action; and
The goals of EO 12898 related to environmental justice for minorities and the goals of
EO 13045 related to the protection of children would be maintained.
Potential benefits of the Proposed Action include:
Opportunity to recycle steel recovered from the demolishing of the warehouses at Site 7;
Reduction in greenhouse gas emissions from the utilization of renewable energy source;
and
Provide Edison Facility with a cost-efficient renewable energy source that would offset
energy requirements for years into the future while meeting government renewable
energy directives.
6.2. CONCLUSIONS: MITIGATION ACTION SUMMARY
Although no significant impacts to the environment are anticipated, EPA would ensure the
following mitigation measures are implemented to minimize potential impacts. These measures
would be implemented through provisions stipulated in design and construction contracts and
lease agreements. The potentially adverse environmental impacts related to the construction and
operation and dismantling of the Proposed Action could be minimized, mitigated, and controlled
to acceptable levels by implementation of the following measures:
EPA would require dust abatement measures, such as wetting, mulching, or seeding
exposed areas, where appropriate, to address any air quality concerns.
EPA would provide lay down (i.e., temporary material storage) areas for construction
equipment and materials within existing cleared and paved areas to minimize disturbance
to existing land and vegetation.
EPA would require contractor compliance with erosion and sediment control measures
related to stabilization of disturbed areas.
EPA would require silt fencing, or other suitable control device, to be placed around the
construction area to mitigate erosion and sediment runoff.
EPA would require all necessary measures be taken to prevent, control, and mitigate the
release of oils, trash, debris, and other pollutants to air, water, and land.
EPA would require contractors to safely handle and dispose of solid and hazardous waste
in accordance with applicable local, state, and federal regulations.
EPA would require contractors to provide appropriate health and safety training,
precautions, and other protection for their workers.
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EPA would require contractors to recycle or reuse materials to the greatest extent
possible, and to dispose of construction debris in accordance with federal, state, and local
waste disposal regulations.
EPA would require that the Proposed Action not commence without the concurrence of
the New Jersey SHPO regarding any National Register-eligible historic structure.
EPA would require, in the event that unexpected cultural resources were found during
construction activities, that work be stopped and that consultation with the New Jersey
SHPO be initiated.
EPA would require that the transportation of construction equipment and materials over
local roads be scheduled to occur after peak traffic periods, whenever possible.
EPA would require contractors to minimize construction-related noise impacts by
limiting construction-related activities to the hours between 7:00 a.m. and 5:00 p.m. on
weekdays.
EPA would require that, upon commencement, the construction phase be executed
expeditiously to minimize the period of disturbance to the affected environment.
Consideration of the activities involved in the construction, operations and maintenance, and
dismantling of an SPVS at the Edison Facility would have no significant impacts on the quality
of the human environment or on local natural resources. As a result of this EA, it is determined
that an EIS is not required for the Proposed Action. In conclusion, a FNSI is recommended to be
published for the Proposed Action.
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(Beier, 2009). Beier, John. U.S. EPA Region 2. Personal Communication, E-mail and
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(BNL, 2003). Fthenakis, Vasilis M. Overview of Potential Hazards, Chapter VII-2, Practical
Handbook ofPhotovoltaics: Fundamentals and Applications. Brookhaven National
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(Cho, 2009). Cho, Kwong. U.S. EPA, Region 2. Personal Communication, E-mail and
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Renewable Energy Laboratory (NREL). Finding of No Significant Impact and Final
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(DOE, 2008). U.S. DOE and U.S. Department of the Interior (DOI), Bureau of Land
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(Edison, 1999). Edison Township Code. Chapter XII Health Regulations and Licensing. Section
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Minority Populations and Low-Income Populations. February 11, 1994.
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(EO 13045). EO 13045: Protection of Children from Environmental Health Risks and Safety
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(EPA, 1990). U.S. EPA. Draft Environmental Impact Statement (EIS) on the Development of an
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(EPA, 1999). U.S. EPA. Non-Road Emissions Model. 1999.
(EPA, 2009). U.S. EPA. Greening EPA: Edison, New Jersey, Region 2 Laboratory. 2009.
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(EPA MAP, 2003). U.S. EPA. Prepared by Metropolitan Architects and Planners (MAP), Inc.
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(Master Plan). 2003.
(EPANFG, 2009). U.S. EPA. Nationwide Facilities Guide (NFG). 2009.
(EPA Green Book, 2009). U.S. EPA. The Green Book Nonattainment Areas for Criteria
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(EPA Greening, 2009). U.S. EPA. Greening EPA: Facilities. Edison, New Jersey - Region 2
Laboratory. Updated May 2009. Available at:
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(EPA, PV Feasibility Assessment, 2008). U.S. EPA and DOE Solar Energy Technologies
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(EPA SWM, 2008). U.S. EPA. Stormwater Management (SWM) at EPA Facilities. Edison,
NJPorous Pavement. Updated December 2008. Available at:
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(EPA WMP, 2006). U.S. EPA. Water Management Plan (WMP), U.S. EPA Region 2 - Edison
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(FEMA, 1985). Federal Emergency Management Agency. Flood Insurance Rate Map (FIRM)
for Edison, New Jersey. Community Panel Number 340261 0006 C. 1985.
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(FWS ECOS, 2009). U.S. Fish and Wildlife Service (FWS). Environmental Conservation
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New Jersey. Updated May 2009 Available at:
http://ecos.fws.gov/ecos_public/index.do.
(FWS, 2009). U.S. Fish and Wildlife Service (FWS), New Jersey Field Office (NJFO),
Endangered Species Program. Federally Listed and Candidate Species Occurrences
in New Jersey by County and Municipality. April 2009. Available at:
www.fws.gov/northeast/nifieldoffice/Endangered/munlist.pdf
(FWS NJFO, 2009). U.S. Fish and Wildlife Service (FWS), NJFO, Endangered Species
Program. New Jersey Field Office Procedures for Consultation and Technical
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(GAO, 1992). United States General Accounting Office. Report to the Honorable Bernard J.
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(FIUD, 1991). United States Department of Housing and Urban Development (FIUD). The
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(AEAMB). Personal Communication. 2009.
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(NJDEP i-Map). New Jersey Department of Environmental Protection (DEP). I-Map NJ
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Accessed May 22, 2009.
(NJDEP, 2004a). New Jersey DEP. Summary of the New Jersey Endangered Species
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(NJDEP, 2004b). New Jersey DEP, Solid and Hazardous Waste Program, Bureau of Solid &
Hazardous Waste Management. Lead-based Paint Abatement Debris Disposal
Updated January 2004. Available at: http://www.state.nj.us/dep/dshw/rrtp/lbpaint.htm
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(NPC, 2001). Noise Pollution Clearinghouse. 2009. Available at: http://www.nonoise.org.
(Pernice, 2009). Pernice, Joseph. U.S. EPA, Region 2. Personal communication, site visit. April
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(Ridge, 2009). Ridge, William. U.S. EPA, Architecture, Engineering, and Asset Management
Branch (AEAMB). Personal Communication. 2009
(SHEM Audit, 2005). U.S. EPA Safety, Health and Environmental Management (SHEM)
Division. SHEM Audit, Final Report: Region 2 Edison Laboratories. November
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(Shapiro, 1991). Shapiro, Sidney A. "The Dormant Noise Control Act." 1991.
(Snyder, 2009). Snyder, Evan. U.S. EPA. Personal communication, e-mail. May 26, 2009.
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Management Branch (AEAMB). Personal Communication. 2009.
(USAGE, 2008). U.S. Army Corps of Engineers. Ground water Remedial Action Work Plan for
the Former Raritan Arsenal, Edison, New Jersey. Prepared by Weston Solutions, Inc.
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(USAGE BERA 2008). U.S. Army Corps of Engineers. Baseline Ecological Risk Assessment
(BERA) Report - Former Raritan Arsenal, Edison New Jersey. Prepared by Weston
Solutions, Inc. March 2008.
(USCB, 2008a). US Census Bureau. Middlesex County QuickFacts. 2009. Available at:
http://quickfacts.census.gov/qfd/states/34/34023.html.
(USCB, 2008b). US Census Bureau. Household Income Rises, Poverty Rate Unchanged,
Number of Uninsured Down. 2009. Available at: http://www.census.gov/Press-
Release/www/releases/archives/income_wealth/012528.html.
(USDANRCS, Web Soil Survey). U.S. Department of Agriculture (USDA) National Resources
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8.0. AGENCIES & PERSONS CONSULTED
Mr. Rob Lee, EPA
Mr. Steve Hinz, EPA
Mr. Dan Amon, EPA
Mr. Evan Snyder, EPA
Mr. Joe Pernice, EPA
Mr. Kwong Cho, EPA
Mr. John Beier, EPA
Mr. William Lawler, EPA
Mr. John Vetter, EPA
Mr. William Baer, EPA
Dr. Ruth W. Foster, NJDEP
Mr. Joseph Corleto, NJDEP
Mr. Kenneth Koschek, NJDEP
Mr. Frank McLaughlin, NJDEP
Mr. James Kelly, New England District USAGE
Ms. Sandra Friedrich, New England District USAGE
Mr. Otto VanGeet, National Renewable Energy Laboratory
9.0. LIST OF PREPARERS
Ms. Elizabeth Snee, Booz Allen Hamilton
Mr. Stephen Shiell, Booz Allen Hamilton
Ms. Julia "Carrie" Walker, Booz Allen Hamilton
Mr. Joseph Tomberlin, Booz Allen Hamilton
Mr. Joseph King, Booz Allen Hamilton
Ms. Stephanie Konopa, Booz Allen Hamilton
Mr. Joshua Guenther, Booz Allen Hamilton
Ms. Kate Donovan, Booz Allen Hamilton
Ms. Lisa Costa Urie, Booz Allen Hamilton
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APPENDIX A: PHOTOGRAPHS OF THE EDISON FACILITY
Photograph 1. View toward the northeast showing Site 1.
Photograph 2. View toward the east showing Building 18, located adjacent south of Site 1.
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Photograph 3. View toward the northwest showing Building 5, located to the west of Site 1.
Photograph 4. View toward the south showing Building 10, located to the southwest of Site 1.
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Photograph 5. View toward the northeast, showing Building 245, located at the intersection of Avenue B
and EPA Loop Road.
Photograph 6. View toward the southeast, showing Building 245 along EPA Loop Road (Building 246
visible in background).
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Photograph 7. View toward the northeast, showing Building 246, located at the intersection of Avenue D
and EPA Loop Road.
Photograph 8. View toward the southwest, showing Building 246 (with Building 245 visible in
background), at the intersection of Avenue C and an unnamed crossroad.
A-4
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
August 2009
APPENDIX B: AIR QUALITY COMPUTATIONS
Assumptions:
Equipment List and daily (8-hour) emissions came from EPA's Non-Road Model (1999)
Assumes all equipment operating at the same time at the same point.
Construction (tons)
Dozer
Front End Loader
Backhoe
Grader
Cranes
Scrapers
Trenchers
Dump Truck
Flatbed Truck
Concrete Truck
Welders
Sitel
Dozer
Front End Loader
Backhoe
Grader
Cranes
Scrapers
Trenchers
Dump Truck
Flatbed Truck
Concrete Truck
Welders
Site?
Dozer
Front End Loader
Backhoe
Grader
Cranes
Scrapers
Trenchers
Dump Truck
Flatbed Truck
Concrete Truck
Welders
Both Sites
Type Equipment
Crawler/Tractor/Dozer
Rubber Tire Loaders
Tractor/Loader/Dozer
Graders
Off Hiway Tractors
4-Stroke Gasoline
Off Hiway Trucks
Off Hiway Trucks
Off Hiway Trucks
Proposed Hours of Use
48.0
48.0
48.0
48.0
80.0
96.0
0.0
120.0
120.0
120.0
96.0
Totals
Proposed Hours of Use
48.0
144.0
96.0
48.0
160.0
48.0
160.0
160.0
160.0
40.0
144.0
Totals
Totals
Fuel
Diesel
Diesel
Diesel
Diesel
Diesel
Diesel
Gas
Diesel
Diesel
Diesel
Diesel
Days
6.0
6.0
6.0
6.0
10.0
12.0
0.0
15.0
15.0
15.0
12.0
Days
6.0
18.0
12.0
6.0
20.0
6.0
20.0
20.0
20.0
5.0
18.0
HP
750
175
175
300
300
600
100
600
600
600
25
tons
tons
tons
voc
0.000
0.002
0.002
0.001
0.000
0.000
0.000
0.001
0.001
0.001
0.000
voc
0.001
0.014
0.013
0.004
0.004
0.002
0.000
0.019
0.019
0.019
0.001
0.10
voc
0.001
0.042
0.026
0.004
0.009
0.001
0.001
0.025
0.025
0.006
0.001
0.14
0.24
CO
0.001
0.009
0.008
0.003
0.002
0.001
0.002
0.005
0.005
0.005
0.000
CO
0.007
0.054
0.049
0.017
0.019
0.009
0.000
0.074
0.074
0.074
0.002
0.38
CO
0.007
0.163
0.099
0.017
0.039
0.004
0.037
0.098
0.098
0.025
0.003
0.59
0.97
NOx
0.004
0.015
0.014
0.009
0.006
0.001
0.000
0.009
0.009
0.009
0.000
NOx
0.021
0.088
0.082
0.051
0.059
0.012
0.000
0.134
0.134
0.134
0.002
0.72
NOx
0.021
0.265
0.164
0.051
0.119
0.006
0.001
0.179
0.179
0.045
0.004
1.03
1.75
CO2
0.231
1.119
1.051
0.572
0.378
0.074
0.007
0.708
0.708
0.708
0.018
C02
1.387
6.711
6.304
3.432
3.776
0.888
0.000
10.613
10.613
10.613
0.211
54.55
C02
1.387
20.133
12.608
3.432
7.553
0.444
0.132
14.151
14.151
3.538
0.316
77.85
132.40
SOx
0.001
0.003
0.004
0.002
0.002
0.000
0.000
0.002
0.002
0.002
0.000
SOx
0.004
0.020
0.023
0.011
0.018
0.003
0.000
0.037
0.037
0.037
0.001
0.19
SOx
0.004
0.060
0.046
0.011
0.035
0.001
0.000
0.050
0.050
0.012
0.001
0.27
0.46
PM
0.000
0.002
0.002
0.001
0.000
0.000
0.000
0.001
0.001
0.001
0.000
PM
0.001
0.010
0.010
0.004
0.005
0.002
0.000
0.015
0.015
0.015
0.001
0.08
PM
0.001
0.031
0.020
0.004
0.010
0.001
0.000
0.019
0.019
0.005
0.001
0.11
0.19
B-l
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
August 2009
Maintenance & Operations (tons)
Pressure Washers
Air Compressors
Sitel
Pressure Washers
Air Compressors
Site?
Pressure Washers
Air Compressors
Both Sites
Type Equipment
Gasoline 4-stroke
Gasoline 4-stroke
Proposed Hours of Use
208.0
104.0
Total
Proposed Hours of Use
624.0
312.0
Total
Total
Fuel
Gas
Gas
Days
26.0
13.0
Tons
Days
78.0
39.0
Tons
tons
HP VOC
25 0.0001
40 0.0000
VOC
0.0033
0.0002
0.00
VOC
0.0098
0.0005
0.01
0.01
CO
0.0053
0.0004
CO
0.1372
0.0049
0.14
CO
0.4117
0.0147
0.43
0.57
NOx
0.0000
0.0000
NOx
0.0006
0.0001
0.00
NOx
0.0018
0.0003
0.00
0.00
CO2
0.0104
0.0014
C02
0.2702
0.0177
0.29
C02
0.8106
0.0532
0.86
1.15
SOx
0.0000
0.0000
SOx
0.0001
0.0000
0.00
SOx
0.0002
0.0000
0.00
0.00
PM
0.0000
0.0000
PM
0.0000
0.0000
0.00
PM
0.0001
0.0000
0.00
0.00
Dismantling (tons)
Dozer
Front End Loader
Backhoe
Grader
Cranes
Scrapers
Dump Truck
Flatbed Truck
Sitel
Dozer
Front End Loader
Backhoe
Grader
Cranes
Scrapers
Dump Truck
Flatbed Truck
Site?
Dozer
Front End Loader
Backhoe
Grader
Cranes
Scrapers
Dump Truck
Flatbed Truck
Both Sites
Type Equipment
Crawler/Tractor/Dozer
Rubber Tire Loaders
Tractor/Loader/Dozer
Graders
Off Hiway Tractors
Off Hiway Trucks
Off Hiway Trucks
Proposed Hours of Use
48.0
96.0
48.0
96.0
40.0
96.0
48.0
48.0
Total
Proposed Hours of Use
24.0
160.0
48.0
48.0
60.0
48.0
144.0
144.0
Total
Total
Fuel HP
Diesel 750
Diesel 175
Diesel 175
Diesel 300
Diesel 300
Diesel 600
Diesel 600
Diesel 600
Days
6.0
12.0
6.0
12.0
5.0
12.0
6.0
6.0
Tons
Days
3.0
20.0
6.0
6.0
7.5
6.0
18.0
18.0
Tons
Tons
VOC
0.0002
0.0023
0.0022
0.0006
0.0004
0.0002
0.0012
0.0012
VOC
0.0014
0.0279
0.0129
0.0072
0.0021
0.0021
0.0074
0.0074
0.07
VOC
0.0007
0.0466
0.0129
0.0036
0.0032
0.0011
0.0222
0.0222
0.11
0.18
CO
0.0012
0.0090
0.0082
0.0028
0.0019
0.0007
0.0049
0.0049
CO
0.0072
0.1086
0.0495
0.0334
0.0097
0.0089
0.0295
0.0295
0.28
CO
0.0036
0.1810
0.0495
0.0167
0.0145
0.0045
0.0884
0.0884
0.45
0.72
NOx
0.0036
0.0147
0.0136
0.0085
0.0059
0.0010
0.0089
0.0089
NOx
0.0213
0.1768
0.0818
0.1024
0.0297
0.0122
0.0536
0.0536
0.53
NOx
0.0107
0.2947
0.0818
0.0512
0.0445
0.0061
0.1609
0.1609
0.81
1.34
CO2
0.2311
1.1185
1.0507
0.5719
0.3776
0.0740
0.7076
0.7076
CO2
1.3866
13.4223
6.3039
6.8633
1.8882
0.8884
4.2454
4.2454
39.24
CO2
0.6933
22.3705
6.3039
3.4316
2.8324
0.4442
12.7362
12.7362
61.55
100.79
SOx
0.0007
0.0033
0.0038
0.0019
0.0018
0.0002
0.0025
0.0025
SOx
0.0044
0.0397
0.0230
0.0227
0.0089
0.0027
0.0150
0.0150
0.13
SOx
0.0022
0.0661
0.0230
0.0113
0.0133
0.0014
0.0450
0.0450
0.21
0.34
PM
0.0002
0.0017
0.0016
0.0006
0.0005
0.0001
0.0010
0.0010
PM
0.0014
0.0203
0.0098
0.0074
0.0024
0.0015
0.0058
0.0058
0.05
PM
0.0007
0.0339
0.0098
0.0037
0.0037
0.0008
0.0175
0.0175
0.09
0.14
B-2
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
APPENDIX C: PUBLIC AGENCY COORDINATION AND
CONSULTATION
c-i
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility
August 2009
United States Department of the Interior
FISH AND WILDLIFE SERVICE
New .Jersey Field Office
V27 iSorth Main Street, BuiMirsg D
PkssaiKvlle, New Jency (1*131
Tel: blM-446-9.il ft Fan: ft(».*i4ft4l,152
March 10,2009
Ti> Whom It Milv Concern:
Se> tnin laH^i, I tht I 'd.< I1!" ol \IL i* \-1 I N \ 11 > iiiii I viual iunir I - i'i« i ,nlt wilh IK I' S
ii h nai \\ iHhti "sei"1 a ivr i . i ti in-uri t kai ir iitn tin. liim' nt rt i rnnii r« i Jiuviit ITT>>
rtf rt tint li-pd^ll," I t i of i mi , j (.jotciiiL 11 iil\ lisliil Tiri LS Hr jd.etii \ n ju > orsijiu'&i uifiul
liihiUtt- i LiLral uU-iii. es iru * , ill >lt uuhulu i v ui'li ll t S^nut it , pn pu'ul .in r.n jiin , i','u , ini_ »r
IMrtllMtJ rei is i' (.nilti,!1 illL Sm it p i ', Ue, K\ii V n< Hnll -til,1.1 i. III us ' i' VI, n j'f,,'
Ii Kr.il 11 .tuf [' lo in 'it i i, hi i i» '\r in il ,.it,[tliil!<.< in In. i i Mr in 1 1.1 i i ii "1 i t J [i i 11'in. h
iiKUti \ lr» I iMtr.il .u Hun ajtru^ nr »"i-l t IIT, I p "i"v"
pp.fiime*'I u ,m lht' i1" irrrutKin JP ' "nitriennii-, np nurwLli --n:
h ;i urtA-i..-^. ni MI! i'.1 n,t t ilil'Ki J' Ltiy m! i . lii I. 'j li'ni.
Federal s_aencics are not rcquirod to cunlact the Service it u propo&od action wi!l have no effea on listad
species, or if no Issiai .qjccics arc present in the action area No liuttwr ESA consuls*? ion or coordinatiou
is noccssarv' for projects where the federal action agency or lieu-Federal project piopoiient has followed
the procedures on our web site and deienniiied thai proposed project activities will have no e/jcci u»
federally listed species. Service toncurreoCe with a m> affect delftrmDalk'Hi is is-n4 roc|uired under tfle ESA
snd will not he provided by the Nciv Jersey field Office. In addition to iJiis letter, ihe federal action
agency or 'non-!;edcral project prsponcm should relairi in their paper Hies documcnutltnn from mir weh siic
at the unns of tliesr review, including ihe relevant poit]on(s) ol' the l-'eJei'tillY iMiciJ cmil ('.eindstlan- Kpeass
{Jcfui'rencc.<< ifi ,\"ew Jei'st-v frt County ana Miinieipalif}', Note tha; uncle' the ESA. a specie* list is valid
for only 90 days; the Sen'ice roeomaiends consulting our web site regularly during projeci pLaniunQ arid
mipknieiMaiiOii Hi: updated spteie> lists and information.
fhtmk vx>u fur wourtooperuti-mi. P'kasc. contact Wendy Walsis al i&iW) 3.K3-3l)3S. extension 4k. if you
have any qucsiioits nj require further assisiance regsrdmp jixicrally Used threatctiod or endangered species.
Sincerely.
l^**~j^~Jf^^-^^fl,.
' line Davis Jr.
Supervisor
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
ENFORCEMENT AND
AUG 5 2009 COMPLIANCE ASSURANCE
Daniel D. Saunders
Deputy State Historic Preservation Officer
Historic Preservation Office
501 East State Street
PO Box 404
Trenton, NJ 08625
Subject: Section 106 Consultation on EPA's Solar Array Project at EPA's Region 2 Edison
Facility
Dear Mr. Saunders:
The U.S. Environmental Protection Agency (EPA) is considering a lease of a portion of
EPA's Edison Facility to a utility company to build and operate an array of electricity-producing
solar panels. A portion of the electricity produced by the solar panels would serve the electrical
needs ol the Edison Laboratory for the foreseeable future; the remainder of electricity produced
by the panels would be made available by the utility company to the public. The panels would be
dismantled and removed when the lease agreement expires; the term of the proposed lease is 10
years with a 10-year renewal option. The utility company selection process and the solar panel
technical specifications and details will be determined and fully defined through a competitive
bidding process scheduled to begin later this summer. The enclosed map details the project area.
This lease constitutes an "undertaking" pursuant to Section 106 of the National Historic
Preservation Act. With this in mind, and in accordance with the June 1992 Memorandum of
Agreement between your office and EPA, as well as the July 1992 Historic Resources
Management Plan (HRMP) for the Edison Facility, EPA has examined this undertaking for its
effects upon the Raritan Arsenal Historic District.
EPA has identified two potential areas where the solar array may be located: Sue 1 (located
within historic Zone 4) and Site 7 (contained within historic Zone 7). Site I within Zone 4 is
located on the southern boundary of Woodbndge Avenue. Zone 4 is listed as significant solely
for the architectural value of the buildings and structures that once existed there. (As noted in the
HRMP, this zone is unlikely to yield any archeological resources because of the extensive
construction disturbance.) However, those buildings and structures have since been removed,
and recorded as required by the HRMP.
Internet Address (URL) httpy/www.epa gov
Recycled/Recyclable PrinleO wi(H \fege\aae CM Based inks on 100% Postccnsumer, Process Chlorine Free Recycled Paper
C-3
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Environmental Assessment for the Proposed SPVS at the EPA Edison Facility August 2009
Site ? within Zone 7 is located al the southwestern portion of the Edison Laboratory property
and is bounded by berms and mature woods to the south and by Middlesex Community College
to the northwest. Zone 7 contains two large warehouses (Buildings 245 and 246), which arc
listed as contributing elements to the Raritan Arsenal Historic District. If Site 7 is chosen as the
location for the solar array, it would be necessary to remove the two warehouses. HP A believes
that the warehouses could be removed and the adverse effect mitigated through a Level One
HABS/HAER recordation.
Per the MOA, we are requesting your concurrence on our assessment of Site I, and the level
of recordation for the contributing historic elements in Site 7 should it be necessary to remove
them.
Thank you in advance for your expeditious evaluation of this request. In the interim, please
feel free to contact me at (202) 564-7157, or have your staff contact Jaime Loichinger al (202)
564-0276,
Sincerely,
Robert W. Hargrove
Deputy Federal Preservation Officer
Enclosure
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