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HomeMy WebLinkAbout2019.07.08 HDR Memo Air Quality and Noise Reviews hdrinc.com 1 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 Environmental Review Technical Memo Date: Monday, July 08, 2019 Project: 900 King Street Redevelopment – Demolition Phase To: Village Board of Trustees From: HDR: Noemi Castillo Michael Musso Subject: Technical Review of Site Plan Application for Demolition (Air Quality, Noise and Hazardous Materials Conditions) Introduction As requested, Henningson Durham & Richardson Architecture and Engineering, PC (HDR) performed a technical review of the Draft 900 King Street Redevelopment Demolition Management and Logistics Plan, dated June 21, 2019 and revised July 1, 2019, and other related documents that have been submitted as part of the Site Plan approval request for partial demolition at 900 King Street. The owner of the property located at 900 King Street, Town of Rye Tax Parcel 129.68-1-13 (Site) has applied to the Village of Rye Brook’s Board of Trustees for Site Plan approval to demolish the existing office building on the Site. This Technical Memo focuses on a review of air quality, noise, and hazardous materials considerations associated with the proposed demolition. HDR understands that early phase demolition is contemplated to occur this summer so that a portion of demolition and site preparation can be completed before the start of the school year. We have submitted prior comments on the larger project – including the above-noted environmental items and considerations during demolition and construction - based on our reviews of specific sections of the DEIS and pFEIS documents. Some of the same comments and recommendations are included herein, with specific focus on the demolition plans submitted for the work proposed this summer. Recommendations offered below may be considered as Site Plan approval conditions. The related documents submitted by the applicant include: • Cover Memorandum for the Demolition Management and Logistics Plan Draft, dated July 1, 2019 • Demolition Management and Logistics Plan Draft, dated June 21, 2019 and revised July 1, 2019 • Site Demolition Plans, dated June 6, 2019 and revised June 21, 2019 • Sign Affidavit, dated June 21, 2019 • Affidavit of Mailing, dated June 17, 2019 • Letter to the Village Board for Site Plan Approval to Demolish Existing Office Building, dated June 6, 2019 hdrinc.com 2 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 • Letter to the Planning Board for Wetlands and Steep Slope Approvals, dated June 6, 2019 • Short Form Environmental Assessment Form, dated June 6, 2019 • Demolition Permit Application, dated May 24, 2019 • Site Location Map, dated April 3, 2018 • Phase I Demolition Noise Analysis Results table, emailed to HDR by ARKF on July 3, 2019. HDR also participated on conference calls with applicant representatives from AKRF on June 25 and July 8, 2019 to further review and receive clarifications on the demolition plans. Overview The Applicant, Rye King Associates, LLC, is requesting a Site Plan approval for initial demolition activities at the site. The Applicant is now requesting Site Plan approval for a two phase demolition on the Site. The two phase demolition would allow for partial demolition work to occur during the summer months while the Blind Brook Middle and High Schools are not in session. The majority of Phase 1 would be targeted for completion prior to the first day of school (e.g., September 5, 2019). Phase 1 would include the removal of the existing office building including removal of the foundation walls and slab of the 2-story ‘western’ portion of the building and the filling, re-grading, and vegetation of this area. Activities related to the re-grading and seeding of the area within the building footprint may continue through September (i.e., after the start of the school year). Phase 2 of the demolition (after the start of the school year) would include removal of the parking lot, associated concrete areas and light fixtures, and the 3-story eastern building slab and the replanting of this area with grassy vegetation. Phase 2 of the demolition would occur within one year of the issuance of the demolition permit for Phase 1 unless another site plan is approved for the site or the Board of Trustees approves an extension. This Technical Memo focuses on the plans and Site Plan application submittals related to Phase 1 and 2 demolition only; future construction / site re-development are not addressed herein. HDR understands that those items are still under Village review as part of the pFEIS. The Applicant has prepared a Demolition Management and Logistics Plan, revised July 1, 2019, which summarizes the Phase 1 demolition process and lists the measures that will be undertaken to avoid or minimize potential environmental impacts from demolition. HDR, on behalf of the Village Board of Trustees, conducted a review of the Air Quality, Noise, Vibration, and Hazardous Materials sections of this Demolition Management and Logistics Plan. HDR’s comments are identified in this memo and are recommended to be incorporated into conditions accompanying the Site Plan approval, as well as a revised Demolition Management and Logistics Plan. Based on our review of the documents submitted for the Phase 1 demolition and discussions held with AKRF, HDR feels that EIS comments related to demolition have been appropriately addressed for this subject Site Plan application that is before the Village Board of Trustees, with the inclusion of the following recommendations offered below as Site Plan approval conditions . hdrinc.com 3 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 General Comments and Recommendations • If Site Plan approval is granted by the Village Board of Trustees for Phase 1 and 2 demolition, it is understood that it may be contingent on Site Plan review / approval by the Planning Board regarding Steep Slopes and Wetlands. Comments offered below in this Technical Memo may serve as Site Plan approval conditions; however, they should be reviewed in light of any Planning Board comments on steep slopes and wetlands. The Village should also reserve the right to impose additional conditions for the future Phase 2 demolition based on actual Phase 1 demolition activities, plan compliance, and observations made. • It is understood that if this Site Plan application is approved, a demolition permit would be needed from the Building Department prior to commencement of Phase 1 demolition. The Building Inspector may request additional details on the Demolition Plans (e.g., vibration monitoring; condition surveys of specific utilities / building materials; site restoration measures) or have additional requirements. An inventory of all utilities (still active and inactive) that service the existing 900 King Street building should be provided during the demolition permit phase of the project. The applicant’s plan to keep certain utilities on-line (e.g., water for washing and fire protection) and shutting off other utilities should be discussed with the Building Department. A pre- abatement site conditions walk thru to confirm baseline interior building conditions (presence of furniture, office supplies, cleaners, paints, etc.), approaches for abatement needs, etc. should be conducted with the Village in advance of Phase 1 demolition work. • Comments offered herein may also be applicable for future demolition and construction work; however, it is understood that site re-development outside the subject demolition application is still under Village review as part of the pFEIS. Noise • As stated above, the primary purpose of the phased demolition is to avoid potential noise impacts to the Blind Brook Middle and High Schools. However, it should be noted that there is still the potential for noise impacts at the schools during Phase 2 of the demolition activities, as well as during construction activities. As noted, the Village should also reserve the right to impose additional conditions for the future Phase 2 demolition based on actual Phase 1 demolition activities and observations made. • The following commitment made by the Applicant should be included as a Permit/Approval condition: Construction equipment that makes an audible noise beyond the property line will be limited to the periods of 8:00 AM to 6:00 PM during weekdays and 9:00 AM to 4:00 PM on Saturdays. Demolition activities will not occur on Sundays or holidays. The applicant has noted that Saturday work during the summer may be needed to complete Phase 1 demolition prior to the start of the school year. • The Demolition Management and Logistics Plan reiterates the highest predicted noise modeling results at the Arbors Condos, as reported in the preliminary Final Environmental Impact Statement (pFEIS) for the Site dated May 14, 2019. These maximum predicted noise levels are 70.1 dBA, an increase of approximately 12.0 dBA hdrinc.com 4 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 above the existing condition, on the north side of Ivy Hill Crescent during site demolition and ground clearing activities; and 65.7 dBA, an increase of approximately 7.6 dBA above the existing conditions, for the townhouses on the south side of Ivy Hill Lane. In addition, the pFEIS also reports a predicted noise level of 81.8 dBA, an increase of approximately 11.8 dBA above existing conditions, for the Village Hall Police and Fire Departments. However, the applicant has provided the predicted total and incremental noise levels during the Phase I demolition activities for the Arbors Condos, Blind Brook School, Village Hall and Police and Fire departments. The applicant predicts that noise level increases during Phase I demolition will not exceed 6 dBA. Although no monitoring of noise is proposed, it is recommended that the Building Department monitor site activities and request in-field noise level readings - if warranted - to confirm the noise levels are not above the applicant’s modeled criteria. • The following noise control measures should be required as a permit/approval condition during demolition activities. These can be added to the Demolition Plans prior to the start of Phase 1 demolition: o Noisy equipment including trucks, should be located away from, and shielded from, sensitive receptors, to the extent practicable; o Equipment, including the mufflers on the equipment, should be required to be properly maintained; o The site should be configured to minimize back-up alarm noise to the extent feasible and practicable; o Trucks should not be allowed to idle for longer than three minutes. The applicant has stated that Phase 1 demolition activities may require an average of 25 truck- trips per week (up to 16 per day). o Generators should be placed on the west side of the Project Site facing the Parkway, which would avoid direct line of sight from the generators to the surrounding sensitive receptors, including The Arbors, Village Hall, and Village Hall Police and Fire Departments. Models with Level 1 or 2 sound enclosures should be selected. o Equipment predicted to increase noise levels at the property boundary by more than 6 dBA or to a noise level greater than 65 dBA would include path controls. Vibration • As agreed to by the Applicant in the Demolition Management and Logistics Plan, the permit/approval should include a condition that a vibration monitoring program at The Arbors community and at the Tennessee Gas Pipeline (2 stations / monitoring points) will be implemented during demolition to ensure that vibration levels do not exceed the thresholds that could potentially result in damage to adjoining property, utilities, etc. • The Demolition Plan should include a listing of TGPL contact, along with the contacts for all existing subsurface utilities at the site and adjacent properties (water, sewer, gas, electric, fiber / cable). It is recommended that the applicant make a notification to each utility entity (TGPL and all others) prior to the start of Phase 1 demolition, and report to the Building Department on such notifications and any feedback received. hdrinc.com 5 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 • It is the applicant’s responsibility to document existing (pre-demolition) conditions of all subsurface utilities to the extent feasible, and to rectify any damage to such caused by demolition work. Air Quality (Dust Control) • Plans for monitoring should be included as a permit/approval condition and in the Demolition Management and Logistics Plan with action levels and the appropriate responses outlined. It is understood that dust suppression will be employed during the demolition work, to eliminate visible dust conditions at the site property lines at all times. • The permit/approval should include a condition that a community air monitoring plan (CAMP) will be implemented if field conditions (on-site, or at any property line) warrant. It is recommended that the Building Department periodically review dust controls and visible levels of dust during the Phase 1 work, and if sustained high dust conditions are observed, work may be stopped and down-wind particulate monitor stations may be required. • The following dust control measures should be required as a permit/approval condition during demolition activities, some of which are listed in the Demolition Management and Logistics Plan: o Ultra-low sulfur diesel should be utilized for all equipment and vehicles; o All equipment should be properly maintained; o Idling of construction or delivery vehicles or other equipment would not be allowed when the equipment is not in active use; o Non-road diesel engines with a power rating of 50 hp or greater and controlled truck fleets would utilize BAT technology for reducing DPM emissions. Diesel particulate filters (DPFs) have been identified as being the tailpipe technology currently proven to have the highest reduction capability. Contracts would specify that all diesel non-road engines rated at 50 hp or greater would utilize DPFs, either installed by the original equipment manufacturer or retrofitted. Retrofitted DPFs must be verified by EPA or the California Air Resources Board. Active DPFs or other technologies proven to achieve an equivalent reduction may also be used; o Use of dust suppression units supplied by water trucks and/or hydrants, if permission is granted by the Fire Department; o Covering stockpiled soil to reduce windborne dust; o Cleaning the asphalt parking lot and driveway, including the construction entrance, and adjacent roadways (Arbor Drive and King Street) used for access to the site; and o Using truck covers/tarp rollers to cover fully loaded trucks. Hazardous Materials • All interior abatement (asbestos, lead-based paint; older electrical equipment such as light fixtures, switches, caulking that could contain mercury, PCBs, or other regulated hdrinc.com 6 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 materials), as required, should be completed prior to disturbing existing building walls, slab and foundation (i.e., during Phase 1 demolition). • It is recommended that the Village Building Department track progress on asbestos containing material (ACM) and lead-based paint and abatement. The Applicant should prepare a Materials Management Plan (MMP) prior to the start of demolition. The plan should provide procedures to follow if unforeseen contaminants or hazardous materials are encountered, such as odors, sheen, petroleum and/or USTs. For instance, the MMP should include a plan for the contractor to monitor exposed soils when encountered during all demolition and earthwork activities for evidence of contamination (i.e., unsuspected tanks, staining, odors, etc.). Upon encountering any areas of contamination, the MMP should include an action response where soil disturbance should cease in the affected area of the excavation, the Village Building Department should be notified, and an environmental consultant should respond to the site to properly address the contamination condition. Any contamination conditions encountered should be addressed in accordance with all local, state, and federal regulations, including Spill notification to NYSDEC and Westchester County Department of Health (if necessary), excavation, removal, stockpiling, and off-site disposal of the contaminated soil, and performance documentation (i.e., soil endpoint sampling) to confirm that the contamination area has been properly removed. Copies of agency correspondence should be submitted to the Building Department. The MMP should reference applicable Federal, State, and local rules and regulations such as, but not limited to, the Resource Conservation and Recovery Act (RCRA) that govern regulated waste materials that if present may need to be handled appropriately during demolition: regulated wastes that may exist in the 900 King Street building (waste oils, heating oils; cleaners / detergents; paints, caulks, ACM, LBP, etc.). It is noted that some wastes may have required timeframes for removing._ The MMP should also describe how waters generated during the demolition work (i.e., dust suppression, wash waters from road or equipment cleaning) and sediments accumulated from the soil erosion / sediment control measures will be handled. • It is the applicant’s sole responsibility to manage, characterize, transport, and dispose/recycle all building and other materials generated as part of demolition in accordance with all applicable rules and regulations. It is recommended that a list of transporters and potential recycling / disposal facilities that will accept demolition materials be provided to the Village Building Department prior to the start of work. It is further recommended that the applicant submit an inventory (demo materials / types, including abated materials; quantities removed; off-site destinations and disposal/recycling documentation) to the Building Department within 30 days of the completion of Phase 1 demolition work. hdrinc.com 7 1 International Boulevard, 10th FloorSuite 1000Mahwah, NJ 07495-0027 (201) 335-9300Suite 1000Mahwah, NJ 07495-0027 (201) 335-9300 • Copies of all abatement filings (e.g., New York State Department of Labor for ACM) and memos describing abatement work completed should be furnished to the Building Department within 45 days after completion.