October 15 2011
Ecowatchers comment of JFK Deicing study:
Jamaica Bay Ecowatchers
Working to preserve, protect and enhance the natural resources of Jamaica bay
56 West 14th road,
Broad Channel, New York, NY 11693
October 10, 2011
Albany, NY 12233-1011
RE: Comments on Port Authority- Water Quality Monitoring Report for JFK SPDES Permit
Dear Commissioner Martens:
The Jamaica Bay Ecowatchers have reviewed the Water Quality Monitoring Report and have a number of issues and concerns with the report. They are indicated below with the relevant statement from the report in italics (and page noted) and our concern noted immediately following and underlined. Our comments indicate our concern with the methodology employed as well as some of the revelations disclosed from the samples taken.
I ) Data Collection Concerns
1) Methods for data collection for report model
- auto sampler problems
i. Construction at Outfall 010 and along the JFK bay runway limited the use of an autosampler at a second site although monitoring equipment was temporarily installed at Outfall 011 prior to removal due to construction.( page 5)
ii Equipment problems with the autosampler resulted in a discontinuous record of velocity measurements during the model verification period. (Page 8)
* It is our position that the model is not accurate as the auto sampler was obviously not operating properly and that the model and subsequent report produced without that input is lacking critical data.
- high glycol numbers recorded discounted for input into the model and in place more favorable numbers used:
i Outfall 013 samples on December 21, 2009 were reported to have an average p-glycol concentration of 21,500 mg/l, which appeared to be too high for the February 9-16,2010 event mean concentration used in the model verification. This concentration results in a glycol loading that exceeds the amount of glycol applied in the Outfall 013 drainage area; therefore, this result is not possible. One possible explanation is that the sample concentration used in the loading calculation was measured during a storm event other than the calculated event (i.e.,February 9-16, 2010). For this reason, a propylene glycol concentration of 10,170 mg/l was used for the model verification event. (pg 11)
ii For outfalls that were not sampled during the 2009-2010 deicing season and where no glycol use was reported, the glycol concentrations were assumed to be zero.( page 10)
- It appears that the higher recorded numbers, from actual samples taken ,were discounted and in their place numbers were submitted for the model loading that were half of those actually recorded. In addition we do not think that it is accurate to assume that because no glycol was “reported” used that an assumption can be made that the loading from these areas is zero.
iii An additional source, which is not included in the model, is the glycol that shears off of the aircraft during takeoff over the water.(pg 25)
* With 81 flights per hour it would seem critical to attempt to introduce into the model the impact that this glycol that shears off the plane and lands in the water is having –it is another attempt, in our view, to diminish or reduce the glycol loading that is actually taking place .
c) Acute Toxicity Mixing Zones
i NYSDEC’s guidance provides two alternative methods for determining the distance, including: Alternative 1) 5 times the local water depth, and Alternative 2) 50 times the Discharge Length Scale. The PortAuthority recommends that the AMZ distances be based on Alternative 2.
If we understand this correctly once again the decision was made to use the less restrictive choice for the model. Alternative 2 appears to allow for a greater distance to be used to establish the AMZ as opposed to alternative 1
II ) Toxic loading from outfalls as indicated in sample results are extremely distressing as they depict toxins being released from many outfalls and one can only wonder at the long term effects on not only the water quality but also the bottom sediment of the surrounding areas and the organisms that live there. These concerns relate to statements made in the report such as:
a. Fifteen outfalls showed at least one toxic contaminant exceeding the moststringent water quality criterion for the contaminant at the outfall.( page 2)
b The calculated in-stream concentrations of total copper at Outfall 022 exceeded the chronic standard, which applies to the dissolved form of copper.
c The calculated AMZ concentrations of total cyanide at Outfalls 010 and 011 exceeded the chronic standard of 1 ug/l as free cyanide.( page 2)
d Nine outfalls showed at least one analyte exceeding the most stringent, non- acute water quality standard at the edge of the AMZ.( page 2)
e. The calculated concentrations for each analyte that exceeded the NYS water quality standards at the edge of the AMZ are highlighted in Tables 6-7, 6-8, 6-9 and 6-10. The chronic, fish consumption, and wildlife type standards were exceeded for some analyte concentrations.( page 37)
2) We are shocked at the shear volumes of gallons of deicing fluids discharged into the waters of this national park -752,000 gallons of deicing fluids used in 2009/10 season.
3) We are also dismayed by the implications of the impact, even if accepting the results of this questionable report, in the drop in dissolved oxygen in the bays northern waters after deicing events. In some cases it appears that the impact is (attachment G-25 page 287) seen in a reduction of 13.5 mg/l to below 4 mg/l.
4) We are distressed to see samples that show that Ethylene Glycol was present when we, the environmental community, have been told for years now that this is substance is no longer being used at JFK .(A limited number of samples contained e-glycol. Ethylene glycol was measured at four outfalls during the 2008-2009 deicing season and at three outfalls during the 2009-2010 season page 11)
Our review leads us to believe that as a result of the issues stated that the ultimate outcome, the Model, is flawed and underestimates the impact the massive glycol and toxic loading of the bay that is taking place as a result of the discharges from the outfalls at JFK airport.
The DEC’s continued acceptance of the harmful practices of the Port Authority allowed under the current SPDES permit is outrageous. The technologies have long since been developed and put in use at other airports to recapture the harmful deicing and anti icing fluids for re use. The impact this continues to have on the bay in conjunction with the toxic loading into the bay from these outfalls is certainly not conveyed accurately in this flawed report. We call on the DEC to take real and meaningful steps to force the Port Authority to be responsible for their harmful releases. It is our understanding that under the clean water act the state is delegated the authority by the federal government to allow the state to regulate such discharges as those at JFK airport in our view that regulation should not be the continued issuance of SPDES permits that allow these harmful discharges to continue unchecked. Even by this report’s conclusions, which we believe severely underestimates the glycol loading and its effects, the areas of Bergen and Thurston Basins are not meeting Dissolved Oxygen standards as mandated under the CWA and the DEC must force the Port Authority to take necessary corrective action immediately. Our organization testified at the DEC hearing in 2007 and yet over four years later we see no real changes in the airports practices .
Daniel T Mundy,
Jamaica Bay Ecowatchers
Monday June 27 1011
JAMAICA BAYNITROGEN AGREMEENT
The Jamaica Bay Ecowatchers are pleased to have helped negotiate this landmark agreement for Jamaica Bay. This accord will have lasting positive impacts for decades to come. It will require upgrades to the waste treatment plants that will finally make meaningful reductions in the nitrogen outputs that harm the waters and marshlands of the bay. With ultimately achieving a 50% reduction in nitrogen levels the waters of the bay will be cleaner, clearer, free of harmful algae blooms and see increased levels of necessary dissolved oxygen so critical for the marine life that inhabits it. In addition the restoration funding will ensure the ability to continue the successful marshland restoration that will create new acres of saltwater marsh islands, considered to be the most productive environmental areas on the planet and critical offsets to the carbon emissions now threatening the Global Climate.
We commend Commissioner Holloway and the NYC DEP for investing the necessary funding to ensure the future of this city’s largest open space and most important natural resource for future generations. We also want to thank the NYS DEC and our other partners for helping to bring these negotiations to a successful conclusion.
This historic agreement is a model for showcasing the possibilities of bringing together the Regulatory, Municipal agency, Environmental and local stakeholder input to forge a contract that incorporates all of the various knowledge, concerns and priorities of each group with differences overcome due to the common shared goal of saving this unique estuary.
We believe that to date this is the single most important agreement addressing the concerns that threaten this unique environmental jewel and its signing is a milestone that will be looked back upon by future generations as one of wisdom and foresight.by