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HomeMy WebLinkAbout20260098 56 Duplainville Rd Regeneron Sketch Plan Comment Response Letter 03.17.2026C.T. MALE ASSOCIATES Engineering, Surveying, Architecture, Landscape Architecture & Geology, D.P.C. 50 Century Hill Drive, Latham, NY 12110 518.786.7400 FAX 518.786.7299 www.ctmale.com Civil Engineering • Environmental Services • Survey Services • Land Services • Architecture • Energy & Building Systems Services • Electrical Engineering March 17, 2026 VIA EMAIL & HAND DELIVERY Susan Barden, Administrator of OPED City of Saratoga Springs City Hall 474 Broadway Saratoga Springs, New York 12866 Re: Regeneron Saratoga Project Responses to Verbal Comments 56 Duplainville Road City of Saratoga Springs, Saratoga County, NY C.T. Male Project No. 25.0998 Dear Susan: C.T. Male Associates Engineering, Surveying, Architecture, Landscape Architecture & Geology, D.P.C. (C.T. Male), on behalf of Regeneron Pharmaceuticals, Inc. (Regeneron or Applicant), has compiled written responses to verbal questions and comments made by the Saratoga Springs Planning Board at the February 26, 2026 Planning Board regular meeting, which are provided below. In addition, the following attachments are provided to supplement the comment responses and overall application. List of Attachments Noise Information for Cooling Towers and 4 MW Generators Attachment 1 Table of Estimated Sound Levels at the Southern Site Boundary Attachment 2 Updated Site Master Plan (V2) Attachment 3 SCWA Letter of Service Attachment 4 Attachments 1-2 are referenced in the comment responses below, and Attachments 3 -4 are provided to further support this application. No significant changes or additions to the Site Master Plan were made, only plan refinements such as: • Shifted the Duplainville Road guard booth further south into the site. • Refined the electrical and mechanical layout on the northwest side of the site. • Optimized the locations of the bulk chem, bulk gas, and compactors. C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 2 Responses to Verbal Comments and Questions #1 Noise: Provide additional noise impact details in the form of cut sheet information and a narrative update. #1 C.T. Male Response: With respect to noise at the southernmost property boundary along Adams Road (the approximate transition area from residential to industrial zoning), an evaluation of noise impacts was completed for the equipment that is planned to be permanently located outside of the building. The methods described were consistent with the New York State Department of Environmental Conservation (NYSDEC) document titled Assessing and Mitigating Noise Impacts, Department ID: DEP-00-1, Issuance Date: October 6, 2000, Revised: February 2, 2001. Sources within this evaluation included the following equipment: Exterior Noise Source Proposed Units dBA at 50’ 4 MW Back-Up Generators 4 Estimated 87 dBA with enclosures to provide 25 dBA reduction at each unit Fire Pump Transformer 1 57 Generator Transformers 2 57 34.5KV Transformers 2 70 4.16 KV Transformers 2 70 4,000-ton Cooling Tower 2 68 8,000-ton Cooling Tower 2 69 Noise specifications for the cooling towers and emergency back-up generators are included as Attachment 1. During typical operations, which would not include the emergency generators operating, the calculated sound pressure level at the southern end of the site is approximately 53.2 dBA, and assumes the southern property boundary as a single receptor. Upon inclusion of the four back-up generator units operating at the same time, the sound pressure level is calculated to be approximately 68.25 dBA. These estimated sound pressure levels do not take into account any vegetation, berms, or buildings on-site and only account for the decrease in sound pressure levels over increasing distance from the source as per the reference document. At distances greater than 50 feet, every distance doubling causes a 6 dB reduction in sound. Cumulative impacts are calculated per the following approach as specified in the NYSDEC guidance document, where the difference between two sound levels receives an additive factor, which is applied to the higher of the two sound levels: C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 3 The guidance document indicates that ambient noise sound pressure levels (SPL) in industrial or commercial areas may exceed 65 dBA with a high end of approximately 79 dB(A) (EPA 550/9-79-100, November 1979). The table in Attachment 2 summarizes cumulative SPL associated with the equipment evaluated, and demonstrates that the cumulative SPL of 53.2 dBA without the generators in operation is well below the referenced guideline range for outdoor noise, and that the cumulative SPL of 68.25 dBA with the generators in operation is at the low end of the guideline range for outdoor noise for industrial or commercial areas. It is important to note that the emergency back-up generators will be within noise attenuating enclosures and will only run in the event of a power outage or during routine testing and cycling for maintenance purposes. Therefore, the generators can be characterized as temporary or infrequent sources of noise. The generators are necessary for the safety and security of the proposed facility and the products that Regeneron produces. The levels of noise that are expected to be generated at the site do not appear to meet the definition of “unreasonable noise” as defined in Chapter 148 of the City of Saratoga Springs Code. In addition, noise in the property’s General Industrial zoning district is expected and allowed, and included in the definition cited below of the “general industrial” use, which is a permitted principal use in the district: “The manufacture, fabrication, processing, reduction, and/or destruction of any article, substance, or commodity, or any other treatment thereof in such a manner as to change the form, character, and/or appearance, and incidental storage, sales, and distribution of such products. General industrial uses may produce noise, vibrations, illumination, or particulate that is perceptible to adjacent land users. These industrial uses typically have outdoor storage areas.” C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 4 #2 Truck Traffic: Heavy truck traffic through residential and central corridors of the city is a local public concern. Truck traffic routes should be provided, including paths directly to and from the facility. #2 C.T. Male Response: Based on this comment, we understand that there is some level of community-wide concern from truck traffic on State highways through the downtown core and residential areas, primarily Broadway (Routes 9/50), Van Dam Street (Route 9N), and Lake Avenue to Washington Street (Route 29). According to the Traffic Assessment for this project prepared by Creighton Manning that was previously submitted, Regeneron will generate fewer truck trips and fewer overall peak hour vehicle trips than Quad Graphics was expected to generate when Building 9 was approved by the Planning Board in 1998 (i.e. the prior SEQR record). Regeneron will have fewer employees at this site and is a less trucking intensive business than Quad Graphics. To project expected truck trips for the proposed facility, a comparison to existing truck traffic associated with the Regeneron Red Mill Campus was conducted. The peak hour trip generation and truck traffic estimate is summarized in the following table: Operator Red Mill Campus (2,372 employ.) Saratoga Campus (1,000 employ. = 42%) Expected Peak Hour Trips Regeneron - At expected peak capacity - 1,000 employees over 3 shifts - Peak hour employees = 750 23-25 trucks/day 10-11 trucks/day 319 trips (PM peak) Quad Graphics (1998 SEQR record) - Through Building 9 occupation - 1,686 employees over 3 shifts - Peak hour employees = 778 68 trucks per day 389 trips (PM peak) The table indicates that the existing Regeneron Red Mill Campus currently generates approximately 23-25 trucks per day, which is significantly less than the truck traffic considered in the prior SEQR record for Quad Graphics through Building 9 occupation. It is anticipated that the proposed Saratoga Campus will generate 10-11 trucks per day based on the size comparison to the Red Mill Campus. The existing off-site and on-site roadway system can accommodate the addition of future truck traffic since the site will generate significantly less truck traffic than the prior use. No trucks will be routed down Adams Road, and all truck traffic will enter and exit the site at the Duplainville Road entrance, traveling from Geyser Road (CR-43) from the east C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 5 or west to Cady Hill Blvd. (CR-44), and to Duplainville Road (CR-46). Regeneron is not proposing a dedicated off-site truck route to dictate how the trucks will arrive on Geyser Road at this time. Though if the City has specific routes of concern, please share with Regeneron for evaluation. We understand that the traffic assessment will be reviewed by an outside consultant with comments provided to the Planning Board at a later date. Additional responses to traffic- related comments will be provided after completion of the outside consultant review. #3 Parking Phasing: Provide a phase breakdown of parking spaces lost throughout the construction process and indicate whether or not temporary parking will be necessary as phases go in. #3 C.T. Male Response: The number of parking spaces lost during the construction of the different sub-project planned for the site, and the potential need for temporary parking areas at the site will be determined as part of each site plan submission package, which will be submitted to the City at a future date. This level of site planning and logistical detail is not available with the sketch plan provided. Organization and phasing of parking at the site during construction will be done so that no new off-site parking is required (i.e. expansion of the project footprint), no additional tree or buffer clearing is required, and adequate parking will be provided to safely accommodate each shift of employees. #4 Parking Spaces: The site plan currently shows 1,000 proposed parking spaces (for a total of 1,493 spaces) for 750 maximum employees at peak shift. Please indicate why this amount of parking is necessary. #4 C.T. Male Response: Below is a basic summary of the proposed parking plan comparing existing conditions to proposed conditions at full build out. Existing Surface Parking 839 spaces Displacement of Surface Parking from Projects - 346 spaces Additional Parking Proposed (Parking Garage) 1,000 spaces Total Parking at Full Build Out 1,493 spaces Net Parking Gain 654 spaces What was submitted as part of this application is a parking garage of up to 1,000 spaces, which is the maximum amount of new parking projected to be needed at full build out of the site, totaling 1,493 spaces including new garage parking and remaining surface C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 6 parking. The actual number of spaces in the parking garage will be developed in the future and included in a future site plan submission with a parking garage design and circulation plan. The justification for having 1,493 spaces on the site by building a garage of up to 1,000 spaces includes various operational factors such as: • Shift overlap: A peak shift of 750 employees is anticipated at full capacity, but spaces are needed to accommodate workers arriving for that shift, plus workers already on shift, so more than 750 spaces are needed for a shift of 750 workers. • Snow removal and maintenance: A parking garage assists with snow removal and other lot maintenance, allowing surface lots to be cleared of snow or otherwise maintained while employee parking is moved to the parking garage. • Convenience: It provides convenience and comfort for employees by keeping their cars out of the weather during their shift. • Temporary displacement of surface parking: This may occur at the facility from time to time for staging equipment, materials, and contractor vehicles for projects on the site. The garage allows for flexibility in the use of these surface parking lots for short-term storage with minimal disruption to the employees and normal operations. • Ease of operations and best use of space: A parking garage provides more efficient use of existing impervious acreage than a surface lot. #5 Bulk Chemical Storage: Provide additional details on chemical containment design, including drums and tanks. #5 C.T. Male Response: Secondary containment and spill prevention systems are provided for bulk chemical tanks and the diesel emergency backup generators. Bulk Chemical Tank Containment Under the requirements of 6 NYCRR Part 598-3.2(b)(ii), Secondary Containment), requires all Category 2 tanks (systems installed after August 11, 1994) used to store a hazardous substance must have a secondary containment system which can contain a leak or spill. The secondary containment system must prevent spills that might result from tank rupture, failure of pumps, valves and other ancillary equipment, and overfilling from entering the land or waters of the State. Secondary containment systems must consist of one of the following: (i) a surrounding dike and impoundment system; (ii) a remote catch tank or impoundment area; or (iii) another method that is designed and installed in accordance with a code of practice developed by a nationally recognized association or independent testing laboratory and approved by the NYSDEC. The secondary containment system must be: C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 7 (i) designed and constructed with a permeability rate to the hazardous substance stored of 1 × 10-6 cm/sec or less; (ii) designed, installed, and operated to prevent any migration of hazardous substances out of the system before cleanup; (iii) designed so that overfills from connections, vents and pressure relief devices occur within the secondary containment system or are directed to another appropriate collection device; (iv) constructed, coated or lined with materials that are compatible with the substance stored and the environment. (All joints must be tight and leak-free using one or a combination of stops, grouts, coatings, gaskets or welds. The secondary containment system must have sufficient structural strength and thickness to withstand equipment and pedestrian traffic, hydrostatic forces, frost heaving and weathering); (v) placed on a foundation which prevents settlement, compression or uplift; (vi) equipped with a sump and a manually controlled pump or siphon, manually controlled dike valve, or any other manually controlled drainage system to permit the drainage of liquids resulting from leaks, spills or precipitation. Control of the pump, siphon or valve must be possible from outside of the diked area. All valves for gravity drainage systems must be locked in a closed position except when the operator is draining accumulated liquids from the containment area. Spilled or leaked substances must be removed from the secondary containment system within 24 hours of the spill or leak; and (vii) capable of containing at least 110 percent of the capacity of the largest tank or manifolded tanks that are connected in such a way as to permit the combined contents to spill, whichever is greater. Chemicals stored in bulk at the facility are anticipated to be regulated under the NYSDEC’s hazardous substance bulk storage regulations (6 NYCRR Parts 597 – 598), and as such, these materials will be required to be managed in accordance with the NYSDEC requirements for regulated chemical bulk storage systems listed above. Secondary containment at the existing Regeneron facility’s tanks includes covered areas for the tanks consisting of concrete containment areas equipped with chemically resistant coatings to meet the required permeability standard. The tank secondary containment areas are each large enough to contain more than 110% of the largest tank within the area, and are utilized for only one tank per containment area to prevent the mixing of incompatible substances. Transfer pumps associated with the tanks are located within the C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 8 tank secondary containment areas. Therefore, any leakage from the pump connections or pipe assemblies is expected to be contained. Tanks are located in areas with foundations to prevent settlement, compression or uplift, and all containment areas are equipped with sumps and manually controlled pumps to remove accumulated materials after inspection for the release of stored chemicals. For the tank truck containment areas at Regeneron’s existing facility, these locations are similarly constructed of concrete equipped with chemically resistant coating and sloped to a collection basin which does not have an outlet in order to provide containment for the amount likely to spill during a transfer. For each of the bulk tanks, a release of material would collect within the individual tank secondary containment area or within one of the dedicated truck transfer containment areas associated with bulk storage offloading. Generator Diesel Fuel Containment Fuel storage associated with emergency generator units will consist of the industry standard intrinsically located secondary contained belly tanks, typically with storage capacities on the order of 7,000 to 10,000 gallons each. All tanks used for the storage of petroleum products will be located within secondary containment and equipped with required spill and overfill prevention devices, in accordance with NYSDEC petroleum bulk storage regulations (6 NYCRR Part 613-4). At Regeneron’s existing facilities, Category 3 tank systems associated with emergency generators include 110% secondary containment capacity of the storage tank within the rupture basin, a rupture basin alarm switch to detect liquid in the containment area, a tank level gauge, a fill spill container which provides containment from drips while filling the tank, a high level float/alarm and primary and emergency tank venting. Additionally, Regeneron installs overfill prevention valves at tank fills to act as a mechanism to prevent spills from tank overfill from occurring and has enclosures present over the generator units to protect from the elements and to provide sound abatement. Detailed containment design will be provided with the site plan applications for when the bulk tank systems are constructed, as required. Please refer to Section 4 of the Part 1 Full EAF Narrative that was previously submitted for more information on proposed chemical and petroleum storage and monitoring and compliance at the facility. C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 9 #6 Waste Generation: Provide additional details on waste generation. #6 C.T. Male Response: There are two main categories of waste that will be generated at the facility during operations – hazardous waste and non-hazardous solid waste. This response provides more information on expected waste generation and management at the proposed facility, drawing from operations at Regeneron’s comparable Red Mill facility. The metrics provided in this response are reasonable estimates and projections. Hazardous Waste Please refer to Section 16 of the Part 1 Full EAF Narrative previously submitted for more information on hazardous waste generation, handling, and disposal anticipated at the proposed facility. Based on operations at the comparable Red Mill facility, hazardous waste expected to be generated at the proposed facility will likely be about 8% of the overall waste generation, totaling ±187 tons per year. This hazardous waste will be disposed of off-site as approximately 1% recycled, 96% waste to energy, and 3% incinerated. Non-Hazardous Solid Waste Solid waste, not including hazardous waste, expected to be generated at levels similar to the Red Mill facility, will include waste with and without chemicals and regulated medical waste (RMW). A breakdown of waste generation projections and expected disposal methods per each waste stream are provided below. • Non-hazardous waste (not chemicals) expected to be generated at the proposed facility will likely be about 66% of the overall waste generation for the facility, totaling ±1,484 tons per year. This non-hazardous waste (not chemicals) will be disposed of off-site as approximately 14% recycled, 1% composted, 76% waste to energy, and 9% construction and demolition debris. • Non-hazardous chemical waste expected to be generated at the proposed facility will likely be about 24% of the overall waste generation for the facility, totaling ±531 tons per year. This non-hazardous chemical waste will be disposed of off-site as approximately 75% recycled, 22% waste to energy, and 3% incinerated. • RMW expected to be generated at the proposed facility will likely be approximately 2% of the overall waste generation for the facility, totaling ±48 tons per year. This RMW will be disposed of off-site as approximately 100% waste to energy. C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 10 Waste Stream Generation Rate Percent of Waste Stream Hazardous Waste ±187 tons/yr. 8% Non-Haz. Non-Chemical ±1,484 tons/yr. 66% Non-Haz. Chemical ±531 tons/yr. 24% RMW ±48 tons/yr. 2% ±2,250 tons/yr. 100% No on-site disposal of waste will occur. No on-site waste incineration will occur. #7 Hazardous Emissions: Geyser Road Elementary School is located in proximity to the proposed facility. Additional details on hazardous emissions in context with the elementary school should be provided for evaluation. #7 C.T. Male Response: Emissions of contaminants, including combustion-related emissions will be measured against strict criteria from NYSDEC regulations to ensure that the facility is operating in a manner that is protective to public health. This will be validated by the NYSDEC during the Air Facility Registration process. Below is a summary of process and combustion-related air emissions, which is also detailed in Section 6 of the Expanded Part I Full EAF Narrative previously submitted. Process Emissions For emission sources identified as “process emission sources” as defined in 6 NYCRR Part 212-1.2(b)(19), applicants are required to submit materials in accordance with 6 NYCRR Parts 201, 212, 621, and other applicable regulations to NYSDEC. Part 212 requires applicants to precisely identify air contaminants emitted from each applicable process emission source. The following information is required to be included with each registration or permit application: • For air contaminants on the High Toxicity Air Contaminants (HTAC) list identified in 212-2.2 Table 2, applicants are required to submit the hourly emission rate potential (ERP) of each air contaminant associated with each emission source and the facility wide yearly actual annual emissions; and • For each non-HTAC air contaminant, for which the actual annual emission rate is greater than 100 pounds per year facility-wide, the applicant shall submit the contaminant’s hourly ERP associated with each emission source. With respect to process emissions from the proposed facility, the manufacturing processes expected to be conducted at the facility utilize mammalian cell culture biotechnology as the means of production, and the materials exhausted during the C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 11 production process are air and water vapor. No Hazardous Air Pollutants (HAPs) or HTAC will be used during the production process nor are any exhausted. Combustion Emissions The proposed facility will have combustion-related emissions as a result of burning natural gas in boilers, and the combustion of diesel fuel in the back-up generators. Combustion-related operations are excluded from the definition of “process operations” and are the primary source of expected air emissions from the proposed facility. Combustion-related emissions include a total of 12 HTACs. For comparison, each of these contaminants has an expected actual annual emission rate that does not exceed the respective HTAC Mass Emission Limit, which would be applicable only to process operations and not combustion operations. Of note, the expected annual emissions from combustion activities for Hexane, a non- HTAC, which is a HAP, exceeds 100 pounds per year. As such, an AERSCREEN analysis could be completed as part of the Air Facility Registration, if required by NYSDEC to demonstrate that the facility will comply with annual guidance concentration (AGC) for Hexane. AGCs are developed and implemented by NYSDEC to be protective of public health. #8 Bike Storage & EV Parking: The site plan should include locations of proposed bike storage within the facility. #8 C.T. Male Response: There is currently a bike rack on the site. Bike parking will be added to the front entrance off Adams Road/Marcel Drive as needed, once Regeneron better understands who will want to ride their bicycle to work. Regeneron encourages employees to bike to work and recognizes that there is existing bike infrastructure in place along Geyser Road and elsewhere in Saratoga Springs. There are currently four EV charging stations on the site. Similar to the bike racks, Regeneron may add more EV charging stations if and when there is demand for that by the employees, and as their site power supply allows. #9 Lighting: Provide plans for lighting fixture replacements and parking lot lighting. Lighting fixture upgrades should be compared to Quad Graphics. #9 C.T. Male Response: This comment was mostly addressed in Section 15 of the Expanded Part I Full EAF Narrative previously submitted. The proposed action will not result in light shining onto adjoining properties. Existing site and building lighting will be utilized or replaced in-kind, as needed. Additional lighting that is required for C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 12 aesthetic or safety reasons will not shine onto adjoining properties , with extra care taken to prevent lights shining toward Adams Road. In addition, the site setting demonstrates that areas of the site with exposed frontage (without vegetative buffer) face either undeveloped wooded or other industrial uses in the W.J. Grande Industrial Park with similar lighting requirements. The existing mature vegetative buffer facing Adams Road will be preserved. The Sternberg-style light posts that are present at the Marcel Drive/Adams Road entrance are not planned for replacement at this time, except for bulbs that may be replaced with an updated LED bulb, if needed. These light posts help to preserve the campus-style feel of the Adams Road entrance and provide a calm transition between the wooded Adams Road aesthetic and the industrial site interior. Paired with the wooded character of this area of the site, we believe that the Sternberg lights are appropriate for the setting and they do not need to be immediately replaced. Replacement of these, if necessary in the future, would take these environmental design considerations into account with a like kind and quality replacement. #10: Tree Planting: The city takes a carbon neutral approach to tree and green space removal. It should be indicated if new trees will be planted to replace those lost from the parking lot green space removal along the west side of the building. #10 C.T. Male Response: Landscaping plans and details will be provided with detailed site plan applications for each sub project, as necessary, and lost or displaced landscaping will be replaced as much as practicable as the site is reorganized over time. Parking lot islands do contain trees and small areas of green space, but do not function as a buffer or contiguous tract of habitat on this site. Respectfully Submitted, C.T. MALE ASSOCIATES Engineering, Surveying, Architecture, Landscape Architecture & Geology, D.P.C. Chris Koenig Project Manager Environmental Services C.T. MALE ASSOCIATES March 17, 2026 Responses to Verbal Comments Regeneron Saratoga Project Page - 13 Cc: Mark Pingel (Planning Board Chairman) Regeneron Pharmaceuticals, Inc. (Applicant) Bruce Steves, Esq. (Applicant’s Counsel)