In recent weeks I have expressed concern about the delays regarding the start of the library construction project. As I indicated to e list readers last week – construction has not yet started at the library,all the contracts have not been executed by those who were awarded bids. The library has been closed for weeks, inconveniencing library patrons.
I am requesting that the Town Board invite our construction lawyer, TRITON, the architect for the library project to a meeting to discuss this matter. How does this information impact the project in time and cost? There are no guarantees that the geothermal will be approved by the state and at what location. Does this impact the other contracts?
Dear Mr. Feiner:
This is in response to your email, and is lengthy because you stated contract
decisions must be made this week so I have tried to be comprehensive. In order
to assist you with reviewing the contract mentioned in your email, I have
attached information regarding applications for geothermal wells and included at
the end of this message some links to additional information. Please note that,
as far as I know, your email to me of 2/23/07at 11:17 PMis the first direct
communication this office has received on behalf of the Town of Greenburgh
regarding this project, although we have heard rumors of a pending proposal. A
number of drilling contractors are familiar with our application process and
requirements, but I don't know what contractor you have hired or are considering
so I will try to cover everything here. I hope you find this helpful. First, I
will attempt to answer the questions presented in your email.
To my knowledge, the DEC has NOT received applications to drill geothermal wells
at the Greenburgh library.
Staff of the Division of Mineral Resources have NOT made any verbal promise
whatsoever regarding any potential future application to drill wells which would
require permits from us, either at the current proposed locations (which are NOT
before us for review at this time) or some other locations around the library.
Once received, the applications to drill will be reviewed for a number of
things, including the proposed locations and the proposed well drilling and
construction methods. (Note that each individual well requires a separate
application.) With respect to the proposed locations, I am aware of concerns
about proximity of the library site to an aqueduct which supplies drinking water
to New York City. When we receive the applications, we will confirm distance to
the aqueduct with the New York City Department of Environmental Protection
(NYCDEP) and determine the need for any special conditions or considerations
based on that distance.
In addition to the above review, we are also required to determine whether the
proposed locations are in an area of historical or archeological significance,
and if they are then we are required to obtain a sign-off by the Office of
Parks, Recreation and Historical Preservation (OPRHP). You can do a preliminary
check of this using one of the links below, and if the locations are in an area
of potential significance, you can contact OPRHP for a sign-off prior to
submitting applications or you can submit the applications and wait for us to do
it.
Finally, we are required to have the proposed locations screened by DEC's Region
3 Division of Environmental Permits. The purpose of this screening is to
determine the need for any other DEC permits such as those required for stream
crossings, wetlands, fluid discharge, etc. Assuming that you (1) provide
complete applications, (2) there are no other permits needed, and (3) there are
no extraordinary issues which need to be addressed, this process typically takes
between 4 and 6 weeks before permits can be issued. OPRHP involvement as
mentioned above or concerns related to protecting the aqueduct can lengthen this
time period. Without applications before us, we cannot predict the length of
any additional required time period or whether special drilling conditions such
as directional drilling or deviation surveys may be required to ensure that the
aqueduct is not intercepted. If your initial applications do not provide
sufficient information to answer these questions or to complete other aspects of
our review, we will issue a notice of incomplete applications and wait for your
responses. To help ensure complete applications, you and the contractor should
carefully review the following:
Items 1 through 4 on the attached sheet are the required components of your
application. The forms are all available for download at http://www.dec.state.ny.us/website/dmn/ogforms.htm.
Include in the application the following information related to the Casing and
Cementing Program:
- Estimated depth to bedrock and proposed surface casing setting depth.
Standard well requirements prescribe that all fresh water zones encountered in
unconsolidated and bedrock formations be cased to a depth at least 75' below the
base of fresh water or 75' into competent bedrock (whichever is deeper), and
cemented by a method approved by the Department. However, we recognize the
unique siting, construction and operating characteristics of geothermal wells as
compared to other regulated wells, and the Department may grant waivers to
standard well requirements provided environmental protection and public safety
are not compromised. If such
waiver is requested, please describe the proposal and include justification. In
addition:
- Provide specifications for surface casing (i.e., casing weight in lb./ft. and
casing grade).
- Provide cement slurry weight in pounds per gallon.
- Provide cement yield in cubic feet per sack.
- Provide number of sacks and calculated volume of cement in cubic feet that
will be pumped including 25 % excess.
- Note that a minimum of two centralizers are required on the surface casing.
Provide installation depths.
Item 3 on the attached sheet describes the required plat. Given the concern
which has already been identified regarding proximity to the aqueduct, please
include a separate tabular listing of each well and distance from the proposed
well location to the aqueduct. In addition, please expand the plat to include
the aqueduct and label the distance between the aqueduct and any proposed well
location that is within 1000 feet of the centerline of the aqueduct. If the
library is proposing to employ directional drilling methods or deviation
surveys, please describe such in the application.
Item 4 on the attached sheet is an Environmental Assessment Form (EAF). Please
ensure that all responses are complete, including the following:
You must respond to Question 15 characterizing waste storage and disposal for
well drilling operations. You must indicate how any fluids used for drilling or
encountered during drilling will be contained and final disposition of fluids.
You must indicate final disposition of the drill cuttings. In addition, if well
bleed is to be used during actual geothermal well operation, the planned method
of fluid disposal and any required authorization or permit must be noted. If no
bleed is planned during well operation, please so indicate.
In your response to Question 18, it should be noted that federal USEPA
authorization or permit is required-please indicate the name of the USEPA
contact for such determination. You may want to contact Dennis McChesney in the
USEPA's Manhattanoffice (212-637-4232) to discuss federal requirements. In
addition for EAF Question 18, please indicate any required local approvals if
such are required for traffic disturbance if there will be any, fluid disposal
(if a sanitary sewer drain is proposed), source of water for drilling
operations, or anything else directly related to drilling operations.
Note that after we receive applications but before we issue permits, an
inspector from this office will visit the site. Additional information
requirements may be identified as a result of that visit.
http://www.dec.state.ny.us/website/dmn/depthfee.htm
Fee calculator. This fee applies to each individual well permit application.
If the applicant is a municipality, the fee may be waived. This determination
will be made after receipt and review of the application and organizational
report. If you believe you are eligible to have the fee waived, you may include
a request for such waiver with your applications in lieu of including the fee,
and we will notify you as quickly as possible whether the waiver is approved or
the fee is required.
http://www.dec.state.ny.us/website/dmn/ccase.htm
Additional details regarding casing and cement requirements.
http://www.oprhp.state.ny.us/nr/
Site for checking whether your proposed locations are historically or
archeologically significant. The contact person at OPRHP if you require
additional information, or find the locations are sensitive and need a sign-off
is:
Mr. Douglas Mackey
Archeology Unit
NYS Office of Parks, Recreation and Historic Preservation
PeeblesIslandState Park
P.O. Box189
Waterford, NY12188-0189
518-237-8643
http://www.geoexchange.org/publications/ny.htm
Summary of New YorkStateregulations on geothermal wells, provided by the
Geothermal Heat Pump Consortium - I'm providing this as an additional source of
information just in case I've omitted something above.
I have copied two members of my staff on this email, Ted Loukides and Peter
Briggs. Mr. Loukides will most likely handle your applications when they are
submitted. You may contact any of the three of us at 518-402-8056 with
additional questions.
Sincerely,
Kathleen F. Sanford
Chief, Permits Secton
Bureau of Oil & Gas Regulation
NYSDEC Division of Mineral Resources
625 Broadway, 3rd Floor
Albany, NY 12233-6500
518-402-8056
kfsanfor@gw.dec.state.ny.us
>>> <feiner98@aol.com> 2/23/07 11:17 PM >>>
There is some confusion regarding the town's application to use geothermal
technology at our soon to be built new Greenburgh library.
To your knowledge - has any application been submitted to the NYS DEC re:
library and geothermal technology?
To your knowledge - has any verbal promises been made that we can dig the wells
needed for geothermal at the Greenburgh library site?
Is there any possibility that the application, once submitted, will be rejected?
Has the state DEC made a promise that some location around the library can be
used - even if it is not the location currently under review?
Within the next week or so I will be asked to sign a contract with contractors
who will be constructing the library for the town. The construction depends on a
positive response re: geothermal application. I'd appreciate a response as soon
as possible. If there is a possibility that geothermal won't be approved at the
Greenburgh library the town will have to rebid the library project.
I am also available by phone: 914 993 1540 or by cell: 914 438 1343.
PAUL FEINER
GreenburghTownSupervisor
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