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HomeMy WebLinkAbout2018.11.02 HDR Memo hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon 1 Environmental Review Technical Memo Date: Friday, November 02, 2018 Project: 900 King Street Redevelopment DEIS PUD Concept Plan and Preliminary Site Plan To: Paul S. Rosenberg, Mayor, and the Village of Rye Brook Board of Trustees From: HDR: Michael Musso, Joshua Gillespie, Noemi Castillo, Angela Stowe, Subject: Technical Review of Air Quality, Noise and Hazardous Materials Sections Overview As requested, Henningson Durham & Richardson Architecture and Engineering, PC (HDR) performed a technical review of the Draft Environmental Impact Statement (DEIS) dated September 12, 2018, submitted to the Village of Rye Brook Board of Trustees by Rye King Associates, LLC, as part of a petition to amend Section 250-7 E, Planned Unit Development (PUD) regulations of the Village Code and an application for a PUD Concept Plan regarding the property located at 900 King Street, Town of Rye Tax Parcel 129.68-1-13. The Proposed Action would construct 269 units of age-targeted housing and related infrastructure, including driveways, walkways, garage and surface parking, site lighting, signage and stormwater management facilities. HDR conducted a substantive review of the Air Quality, Noise and Hazardous Materials sections of the DEIS on behalf of the Village Board of Trustees. HDR’s comments are identified in this memorandum and are recommended to be incorporated into the Final Environmental Impact Statement (FEIS) for the project. Air Quality A technical review of the air quality assessment that was conducted by AKRF, Inc. (AKRF) for the proposed 900 King Street Redevelopment DEIS, as summarized in Chapter 13, Air Quality and Chapter 16, Construction. Summary of Operational Air Quality Assessment – Chapter 13 An air quality assessment was performed by AKRF to assess the potential for the proposed project to impact ambient air quality from stationary and mobile sources. The assessment consisted of: • A summary of existing ambient air quality conditions in the project area based on the New York State Department of Environmental Conservation (NYSDEC) air quality monitoring stations nearest to the Project Site. • A review of the nearby sensitive receptors. • A description of the Future without the Proposed Project conditions. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon • An analysis of stationary air emission sources using the AERSCREEN model to predict worst-case 1-hour average concentrations. These values were used to prepare a comparison of the predicted maximum modeled pollutant concentrations from the proposed project’s Heating, Ventilation and Air Conditioning (HVAC) Systems to the National Ambient Air Quality Standards (NAAQS) for NO2 and PM2.5. • A screening assessment for the mobile air emission sources to determine if a detailed mobile air quality analysis is required. Existing Ambient Air Quality Conditions Data from NYSDEC air quality monitoring stations located in the Bronx were summarized for existing concentrations of carbon monoxide (CO), sulfur dioxide (SO2), particulate matter less than 10 microns (PM10), nitrogen dioxide (NO2) and lead. Data from a monitoring station located in the City of White Plains, Westchester County were summarized for existing concentrations of particulate matter less than 2.5 microns (PM2.5) and ozone. With the exception of ozone, the monitored data for all pollutants were below the NAAQS. Comment: The data in the DEIS was based on the NYSDEC New York State Ambient Air Quality Report for 2016, which the DEIS states is the most recent year for which data are available. However, the NYSDEC New York State Ambient Air Quality Report for 2017 is available (https://www.dec.ny.gov/chemical/8536.html). Future Without the Proposed Project Per the DEIS, the existing on-Site office building utilizes an HVAC system that is smaller than what is proposed for the proposed project. Therefore, the pollutant concentrations in the Future without the Proposed Project would be similar or less than those predicted for the Proposed Project. Comment: It should be noted that the last sentence in the first paragraph in Section 13.3 of the DEIS incorrectly states that the “….pollutant concentrations in the Future with the Proposed Project (the “Build” condition) would be similar or less than those predicted for the Proposed Project.” Potential Impacts of the Proposed Project – Stationary Sources The DEIS presents the results for the stationary sources analysis that was performed for NO2 and PM2.5 using the AERSCREEN model. The analysis consisted of determining the potential for adverse air quality impacts from combustion sources of the proposed multifamily residential buildings. Since building heights in the surrounding area were determined to be similar to or greater than the proposed buildings, elevated sensitive receptors were not considered. Sensitive receptors at ground levels and lower elevations were identified along King Street, North Ridge Street, Ivory Hill Lane and Blind Brook High School. The sources considered were the HVAC systems, which were assumed to be natural gas-fired systems. All emissions were modeled as being exhausted from a single stack from the top of the proposed four-story portion of the Independent Living building. The maximum projected concentrations that were generated from the AERSCREEN model for the proposed project HVAC systems, when combined with the existing ambient concentrations, were predicted to be below the NAAQS. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon Comment: The assumption of HVAC systems being natural gas fired systems may be a reasonable assumption, but not conservative. This statement should be revised in the DEIS. The DEIS should discuss why additional criteria pollutants were not modeled, such as PM10. Section 13.4.1 of the DEIS states “…no significant adverse air quality impacts would be expected from the Proposed Project on lower elevations.” However, the statement should be based on elevated sensitive receptors. In addition, the DEIS should clarify if receptors along Ivy Hill Crescent, Arbor Drive, and within the Proposed Project site along the existing and new pedestrian paths and new sidewalks were considered in the model. If not, why not? The stationary source analysis considered the HVAC systems of the Independent and Assisted Living buildings. However, the proposed project also includes 24 residential townhomes and an underground parking area that would accommodate 173 parking spaces. While the emissions from the HVAC systems for the townhomes would be considered negligible, the DEIS does not address emissions from the underground parking area. In addition, as discussed above the stationary source analysis consisted of modeling a single stack from a four-story building. This is identified in the DEIS as being conservative. However, the proposed multifamily residential buildings consists of three- and four-stories. Since the receptors of concern are ground level, placing a stack on a four-story building is not conservative. The proposed project would include one or more standby emergency generators. The generators are not expected to be installed on the eastern side of the proposed multifamily residential buildings. Comment: However, it is recommended that the applicant be required as a condition to the permit/approvals for the proposed project to not place generators on the east side of the project site to avoid disturbance to receptors in that area, including the Village Hall, Rye Brook Police Department and Rye Brook Fire Department. Potential Impacts of the Proposed Project – Mobile Source Screening A mobile source screening assessment was performed for CO at the traffic study area intersections. However, none of the intersections met the criteria for a detailed mobile analysis. Comment: It should be noted that the DEIS mentions the more stringent criteria to be applied when a State Implementation Plan (SIP) intersection is located within 0.5 mile of the project. However, this criteria is no longer included in the NYSDOT TEM. In addition, Section 13.4.2 states the traffic study area included nine intersections, but then states that screening was performed at 11 intersections. It should be clarified if nine or 11 intersections were screened for air quality. Summary of Construction Air Quality Assessment – Chapter 16 A qualitative assessment was performed for the construction scenario. Construction will include emissions from stationary and mobile sources and is estimated to have a duration of approximately 30 months. Peak construction activities are anticipated to last 21 months, with hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon the maximum number of works on-site (180 workers per day) to occur during construction months 20 and 21 and the maximum number of truck trips of 140 weekly trips during construction month 21. As per the DEIS, a Construction Management Plan (CMP) will be prepared and implemented. The DEIS provides the following list of erosion and dust control measures and measures to minimum emissions from construction vehicles and equipment that would be implemented. Erosion and Dust Control Measures: • Minimizing the area of soil that is disturbed at any one time; • Minimizing the amount of time during which soils are exposed; • Installing truck mats or anti-tracking pads at egress points to clean the trucks’ tires prior to leaving the Project Site; • Watering of exposed areas during dry periods; • Using drainage diversion methods (e.g., silt fences) to minimize soil erosion during Site grading; • Covering stored materials with a tarp to reduce windborne dust; • Limiting on-Site construction vehicle speed to 5 miles per hour (mph); and • Using truck covers/tarp rollers that cover fully loaded trucks and keep debris and dust from being expelled from the truck along its haul route. Construction Vehicles and Equipment Control Measures: • Ultra-low sulfur diesel would be utilized for all construction equipment and vehicles; • All equipment would be properly maintained; and • Idling of construction or delivery vehicles or other equipment would not be allowed when the equipment is not in active use. Comment: These control measures should be a listed as conditions included in the approvals/permits for the proposed project. In addition, use of best available technology (“BAT”) for reducing emissions, such as diesel particulate filters (“DPFs”) or diesel oxidation catalysts (“DOCs”), on all nonroad diesel-powered vehicle rated at 50 horsepower or more should be required. Since the project site is adjacent to sensitive receptors, the proposed project should also be required to prepare and implement a Community Air Monitoring Plan (CAMP). The focus of the CAMP would be to monitor airborne particulate levels during demolition, soil removal/handling activities and other activities that could potentially generate airborne particulates. The CAMP should include action levels and steps to be taken shall these action levels be met or exceeded. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon Noise A technical review of the noise assessment that was conducted by AKRF for the proposed 900 King Street Redevelopment DEIS, as summarized in Chapter 14 Noise and Chapter 16 Construction for the proposed project. Below is a summary of HDR’s review, including comments/recommendations. Summary of Operational Noise Assessment – Chapter 14 A noise assessment was performed by AKRF to assess the potential for the proposed project to impact existing noise levels at noise-sensitive receptors from stationary and mobile sources. The assessment consisted of: • A summary of existing noise levels in the project area based on noise monitoring that was performed near noise-sensitive receptors. • A description of the Future without the Propose Project conditions. • An analysis of potential impacts from mobile sources for the proposed project using proportional modeling. • A comparison of the predicted noise levels from mobile sources to the New York State Department of Environmental Conservation (NYSDEC) noise impact criteria. • A qualitative discussion regarding noise levels anticipated from the proposed project’s Heating, Ventilation and Air Conditioning (HVAC) Systems. Noise Standards and Guidelines The Village does not currently have a noise code/ordinance, however regulations and guidance exists from both federal and state agencies. According to the NYSDEC, an ambient noise level of 55 to 65 A-weighted decibels (dBA) at a sensitive receptor (defined as residences, schools, hospitals and other environments requiring serenity) and at the property line should not be exceeded over a one-hour period. The most conservative approach utilizes the property line. The property line should be the point of reference when adjacent land use is proximal to the property line. The following information is based on NYSDEC’s “Assessing and Mitigating Noise Impacts Program Policy”, dated February 2, 2001 (NYSDEC Noise Program Policy): • Increases in noise ranging from 0 to 3 dBA should have no appreciable effect on receptors. • Increases from 3 to 6 dBA may have potential for adverse noise impact only in cases where the most sensitive of receptors are present. • In non-industrial settings the noise level should probably not exceed ambient noise more than 6 dBA at the receptor. Increases of more than 6 dBA may require a closer analysis of impact potential depending on existing noise levels and the character of surrounding land use and receptors. • An increase in noise levels approaching 10 dBA is perceived as a doubling of noise level and deserves avoidance and mitigation measures. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon • In non-industrial settings, an ambient noise level of 65 dBA should be viewed as the “upper end” limit during daytime hours to allow for undisturbed speech. • In industrial/commercial settings, an ambient noise level of 79 dBA should be viewed as the “upper end” limit. The goal in “industrial/commercial” areas that exceed 65 dBA should be to not exceed the ambient noise level, therefore any new facilities should attempt to operate at a noise level 10 dBA or more lower than the ambient. The DEIS utilizes similar noise impact criteria, and focused on not increasing noise levels more than 6 dBA at a receptor or resulting in a Future with the Proposed Action noise levels greater than 65 dBA. Comment: Based on the NYSDEC Noise Program Policy, appropriate receptor locations may be either at the property line of the parcel on which the facility is located or at the location of use or inhabitance on adjacent property. However, the most conservative approach utilizes the property line. The DEIS did not include a sensitive receptor along the eastern side of the property line near Village Hall, Rye Brook Police Department and Rye Brook Fire Department. In addition, the DEIS recognizes schools and hospitals as “most sensitive receptors”. However, a 3 dBA noise level increase limit was not used for Site #4, representative of the Blind Brook High School. Existing Ambient Air Quality Conditions Existing noise levels were monitored at six sites on a weekday during the AM peak hour (7:30 to 9:30 AM) and PM peak hour (4:30 to 6:30 PM). The dominant source of noise at the six sites was determined to be vehicular traffic noise. Measured noise levels ranged from 58.1 to 72.5 dBA during the AM peak hour and 59.0 to 70.3 dBA during the PM peak hour. Comment: Weekend existing noise levels were not measured. A discussion of the weekend vehicular traffic anticipated for the Propose Project should be added and, if deemed to be necessary, the noise analysis should include a typical Saturday, including obtaining existing noise levels. Similarly, the DEIS is silent on nighttime noise level (10 PM to 7 AM) increases due to the Proposed Project. Future Without the Proposed Project Per the DEIS, the background growth in existing traffic is anticipated to result in a noise level increase of up to 2 dBA in the Future without the Proposed Project when compared to existing noise levels for receptors sites 1, 2, and 3 located along King Street. Noise level increases of up to 2 dBA would be barely perceptible. The maximum increase in noise level anticipated in the Future without the Proposed Project at the site entrance on Arbor Drive is approximately 4 dBA, which would be perceptible. However, noise levels at this location would remain below the NYSDEC recommended noise level of 65 dBA for residential uses. Comment: Noise levels in the Future without the Proposed Project for Site 5, Border of 900 King Street and Hutchinson Parkway, and Site 6, Border of 900 King Street and Arbor Drive Townhouses are not discussed in Section 14.3. However, Section 14.4.1 states that: “At receptor sites 5 and 6, where the Hutchinson River Parkway is the dominant source of noise, existing noise levels are assumed to be representative of noise levels in the Build condition hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon because vehicular traffic on the Hutchinson River Parkway would not change appreciably with the implementation of the Proposed Project; therefore, future noise levels would remain comparable to the measured existing noise levels.” It may be helpful to state this first in Section 14.3 rather than staying silent on noise levels in the Future without the Propose Project for Sites 5 and 6. Potential Impacts of the Proposed Project – Mobile Sources The DEIS presents the results of the mobile source analysis that was performed using proportional modeling. The analysis consisted of determining the Future With the Proposed Project noise level and determining the incremental change in noise due to the Proposed Project for comparison with the NYSDEC noise impact criteria. Existing noise levels at Sites 1, 2 and 3 are over the 65 dBA NYSDEC recommended noise level for residential uses and are predicted to remain above 65 dBA in the Future With the Proposed Project. However, the increase in noise level due to the proposed project is anticipated to be less than 1 dBA at these sensitive receptors. The maximum increase in noise level at Sensitive receptor Site 4 would be up to 1.6 dBA, which would not be perceptible and would not exceed the NYSDEC noise impact criteria. Noise levels for Sites 5 and 6 were not predicted. Per the DEIS, the main source of noise at these two receptors is the Hutchinson River Parkway, which the proposed project is not expected to increase appreciably. Comment: The proposed project consists of adding a sensitive receptor to the area, residences. The noise levels from the on-site movement of traffic, including trucks, should be assessed to determine the noise level increases for the proposed sensitive receptors, as well as the Arbors Townhouses. The Future With the Proposed Project noise levels presented in Table 14-4 are lower than those provided in Table 14-3 for the Future Without the Proposed Project. Please explain or correct. Potential Impacts of the Proposed Project – Stationary Sources A qualitative discussion is provided in the DEIS regarding noise levels anticipated from the proposed project’s Heating, Ventilation and Air Conditioning (HVAC) Systems. The DEIS commits that the proposed buildings’ mechanical systems would be designed to avoid producing a 6 dBA or more increase at nearby receptors. In addition, the DEIS commits that the emergency power systems installed exterior to the building would be designed to avoid producing a 6 dBA or more increase at nearby receptors. Comment: The total noise level from the proposed project should not result in an increase of 6 dBA or more at nearby receptors. In addition, the total noise level from the proposed project should not cause interior noise levels within the proposed buildings greater than 45 dBA. This includes noise from all sources, including mobile sources as well as the combined noise level from stationary sources, as opposed to on an individual basis. In addition, it is recommended that the applicant be required as a condition to the permit/approvals for the proposed project to not place generators on the east side of the project site to avoid disturbance to receptors in that area, including the Village Hall, Rye Brook Police Department and Rye Brook Fire Department. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon Summary of Construction Noise Assessment – Chapter 16 A noise analysis was performed for the construction scenario. Construction will include emissions from stationary and mobile sources and is estimated to have a duration of approximately 30 months. Peak construction activities are anticipated to last 21 months, with the maximum number of works on-site (180 workers per day) to occur during construction months 20 and 21 and the maximum number of truck trips of 140 weekly trips during construction month 21. As per the DEIS, potential temporary noise impacts could result from noise due to the construction of the proposed project. The DEIS provides the following list of noise control measures that would be implemented. • As early in the construction period as logistics would allow (likely by the start of the superstructure phase of construction pending service provisions from Con Edison), diesel- or gas-powered equipment would be replaced with electrical-powered equipment such as welders, water pumps, bench saws, and table saws (i.e., early electrification) to the extent feasible and practicable; • Where feasible and practicable, the construction site would be configured to minimize back-up alarm noise. In addition, all trucks would not be allowed to idle more than 3 minutes at the construction site; • Contractors and subcontractors would be required to properly maintain their equipment and mufflers; • Where logistics allow, noisy equipment, such as cranes, concrete pumps, concrete trucks, and delivery trucks, would be located away from and shielded from sensitive receptor locations; • Noise barriers constructed from plywood or other materials surrounding the construction site would be utilized to provide shielding. The barriers would be at least 12 feet tall. Where logistics allow, truck deliveries would take place behind these barriers; and • Per the DEIS, the feasibility and potential effectiveness of these measures will be evaluated to determine whether noise levels at surrounding receptors resulting from construction of the Project could be substantially reduced. Maximum noise levels during construction at 12 noise-sensitive receptor sites are predicted to range from 57.4 dBA to 84 dBA, resulting in an increase of 0.3 to 21 dBA. Per the DEIS, “construction of the Proposed Project would be expected to result in elevated noise levels at nearby receptors and noise due to construction would at times be noticeable and highly objectionable. However, at receptors other than those directly adjacent to the Project Site, noise from construction would be intermittent and of limited duration, and estimated construction noise levels would not exceed NYSDEC noise screening thresholds. Consequently, in the Applicant’s opinion noise associated with the construction of the Proposed Project would not rise to the level of a significant adverse noise impact at receptors not directly adjacent to the project. At receptors immediately adjacent to the Project Site, construction of the Proposed Project would result in large noise level increases and high noise levels during the most noise-intensive hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon construction activities at the adjacent work areas. These noise levels would have the potential to occur for approximately 21 months. Therefore, in the Applicant’s opinion, construction noise at these receptors would rise to the level of significant, but temporary, adverse impact.” The noise control measures presented in the DEIS should be a listed as conditions included in the approvals/permits for the proposed project. In addition, the predicted increases would be greater than 10 dBA and for a duration of approximately 21 months. Although temporary, exposure to this much of an increase in noise for almost two years would cause an annoyance and disturbance to the adjacent receptors. The noise analysis should determine if a noise barrier greater than 12 feet and/or with noise absorbent material would reduce the noise level increase. In addition, equipment predicted to increase noise levels at the property boundary by more than 6 dBA or to a noise level greater than 65 dBA should be required to include path controls. The DEIS states that these temporary noise impacts would only occur during the daytime hours, Monday through Saturday, and that construction would not regularly occur during evening and overnight hours or on Sundays. It is recommended that the approvals/permits for the proposed project restrict construction hours to Monday through Saturday and NOT allow construction to occur during evening and overnight hours or on Sundays. Table 16-4 of the DEIS provides existing noise levels for the sensitive receptors included in the construction noise analysis. However, it is not stated if this noise measurement data is from a weekday or Saturday. Since construction may occur on Saturdays, the noise analysis should be performed for both a typical weekday and Saturday. The DEIS states that “Typical façade construction, including insulated glass windows and some kind of alternate means of ventilation (i.e., air conditioning) would be expected to provide approximately 25 dBA reduction in interior noise levels compared to exterior levels for a closed-window condition.” A source for this value should be provided. Hazardous Materials HDR, at the request of the Village of Rye Brook, has performed a technical review of the Phase I and Phase II Assessments of Chapter 15, Hazardous Materials Chapter. The analysis of the Hazardous Materials Chapter, included a Phase I Environmental Site Assessment, dated October 2017 (Phase I) and a Subsurface (Phase II) Investigation, dated January 2018 to assess the potential for hazardous materials on-site. A hazardous material is generally defined as any substance that poses a threat to human health or the environment. HDR’s findings, recommendations and conclusions are provided below in this technical memorandum. As part of our scope, HDR has assumed that the data provided in the reports is accurate as part of our general review and did not verify the accuracy of the data. Phase I Environmental Site Assessment – Chapter 15 AKRF performed the Phase I Environmental Assessments in accordance with the American Society for Testing and Materials (ASTM) Standard E1527-13 and the reported limitations. The objective of the Phase I was to identify recognized environmental conditions (RECs) and hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon environmental concerns associated with the Property resulting from past or current site usage and usage of neighboring properties. AKRF identified two (2) On-Site RECs (a) related to the historic storage of ignitable waste, corrosive waste, and spent halogenic solvents and (b) potential buried debris from former on- site structures that could contain historic fill of unknown origin and/or abandoned underground storage tanks (USTs). One (1) Off-Site REC was also identified: a property located approximately 350 feet north-northeast of the subject Property where, in 1994 and 1995, a parcel was identified as a carpet and upholstery cleaner (and may have used / stored / handled chemicals and wastes). Four (4) On-Site de minimis Conditions were identified including the potential for residual subsurface arsenic and insecticide associated with the historic arboretum, potential impacts from diesel generators (however, the Phase I reported that no staining or evidence of spills was observed), residual hydraulic oil observed beneath equipment in the elevator machine room during a 2014 inspection (however, no staining was observed during the Phase I inspection), and the potential for fluorescent lights, lighting fixtures, and the hydraulic elevator machinery to contain PCB- and/or mercury-containing components (including capacitors and potting compounds). On-Site Environmental Concerns identified included the potential for Asbestos Containing Materials (ACM) in the existing building materials and lead-based paint in painted surfaces, under existing layers of paint, or in historic fill beneath the existing structure and parking lot. Phase II Environmental Site Investigation – Chapter 15 The Phase II investigation was conducted to further assess the RECs and other environmental concerns identified during AKRF’s October 2017 Phase I. The Phase II scope included completion of a geophysical investigation, the advancement of nine soil borings (one converted to a groundwater monitoring well), and installation of three temporary soil vapor points. Samples retained for laboratory analyses included eight soil samples, two groundwater samples, three soil vapor samples, and one ambient air sample. AKRF concluded the analytical data from the soil, groundwater, and soil vapor sampling indicated no evidence of a release associated with the RECs or de minimis condition observations identified during the Phase I. Additionally, there was no reported evidence of hazardous, non-hazardous, and/or petroleum-like releases (e.g., odors, staining, or elevated PID readings) during soil, groundwater, or soil vapor sampling with the exception of evidence of an ongoing hydraulic oil condition that was noted on the concrete slab floor in the elevator machine room (soil sampling in the elevator machine room suggest the condition has not affected subsurface soils). The following table identifies the soil borings collected and the rational for each as reported in the Phase II. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon ACM, lead-based paint and PCB surveys and sampling were not included as part of the Phase II scope of work. Conclusions and Recommendations It appears that the Phase I has been completed in conformity with the applicable ASTM standard. The RECs identified were investigated as part of the Phase II in accordance with industry practice. Based on the RECs identified the scope of the sampling and laboratory analysis appears reasonable and appropriate. The conclusion that there is no evidence of a release appears reasonable. However, due to the RECs identified the majority of the samples were collected in the shallow soils. The Village should note that, due to the significant earthwork proposed as part of the development, deeper excavation may reveal differing soils conditions and/or contamination in areas not tested as part of this investigation. Additionally, ACM and lead-based paint surveys and abatement as recommended in the DEIS by AKRF will reduce the risk to hazardous materials during building demolition. Should the project and demolition / development move forward, it is recommended that the Village Building Department track progress on ACM and lead-based paint surveys and abatement. Surveys and abatement, as required, should be completed prior to disturbing existing building materials. Although there is currently no indication of a release to the site HDR agrees that proper controls are needed to prevent exposure to site workers and the surrounding community during re-development, including demolition and construction. The controls proposed in the Hazardous Materials section of the DEIS address the Phase II Recommendations and are reasonable standards of practice. They include: • Any soil or fill excavated as part of future Site redevelopment activities should be managed in accordance with applicable regulations. All material intended for off-Site disposal should be tested in accordance with the requirements of the intended receiving facility. Transportation of all soil leaving for off-Site disposal should be in accordance with requirements covering licensing of haulers and trucks, placarding, truck routes, manifesting, etc. Excavation may reveal different or more significant soil hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon contamination in areas not tested as part of this investigation. If discovered, such contamination could require further investigation and/or remediation in accordance with applicable regulations. • No evidence of USTs or other buried tanks was identified during the geophysical survey or the sampling program. However, if any storage tanks or contaminated soil are encountered during redevelopment, such tanks should be registered with NYSDEC and/or the Westchester County Department of Health (WCDOH), if required, and closed and removed along with any contaminated soil in accordance with applicable regulations. • If any USTs and/or petroleum contaminated soil are encountered during the development activities, consideration should be given to installing a vapor barrier below the proposed building foundation. A membrane-type waterproofing product, if used as part of the foundation construction, could also function as a vapor barrier. • The hydraulic oil condition noted in the elevator machine room should be addressed including cleaning the residual hydraulic oil from the slab floor and properly draining the hydraulic oil reservoirs from the faulty elevator motors until they are properly repaired and/or removed. All oil soaked materials and residual hydraulic oil should be disposed of in accordance with applicable regulations. • Prior to demolition, ACM surveys would be conducted throughout the existing structure. All ACM would be removed prior to demolition by a licensed asbestos abatement contractor in accordance with applicable regulatory requirements. • Demolition activities with the potential to disturb LBP would be performed in accordance with the applicable Occupational Safety and Health Administration regulation (OSHA 29 CFR 1926.62—Lead Exposure in Construction). • If dewatering is required, treatment and discharge of dewatering fluids would be conducted in accordance with all applicable regulations and guidance, including obtaining appropriate permits. • Appropriate erosion and sediment controls would be implemented in accordance with NYSDEC Stormwater Pollution Prevention Plan (SWPPP) requirements. HDR is providing the following recommendations for consideration in order to further reduce risk of exposure and document that there are appropriate plans in place that are in accordance with all applicable rules and regulations and that aim to prevent a release to the surrounding environment or community. The proposed project plans indicate that a significant amount of earth work will be a part of development. The DEIS reports that the western portion of the site will be lowered by 42,600 cubic yards of excavation and 51,600 cubic yards of fill will be used to raise the central portion of the site. The preparation of a Materials Management Plan(s) prior to the start of construction would allow the contractor to provide plans for soil, groundwater and dust management prior to disturbance. The plans should also provide procedures to follow if unforeseen contaminants or hazardous materials are encountered during construction, such as odors, sheen, petroleum and/or USTs. hdrinc.com Use UPDATE/INSERT ADDRESS feature in ribbon Soil management included in the plan would typically address stockpiling, characterization, on- site re-use, importation, loading, transport and off-site re-use or disposal. It should also address truck routes and traffic, and staging / loading areas for both excess materials leaving the site and imported materials. As noted in Section 8.0 of the Phase II, re-use and disposal of fill materials can be complicated and, while “historic fill” was not noted during the Phase II investigation, geotechnical investigations noted 4 to 9 feet of fill present at the site. The plan would address how soils will be managed to ensure compliance with applicable regulations, including the recently adopted 6 NYCRR Part 360 Solid Waste Regulations. Dewatering sections would typically include a discussion of the required permits as well as plans for temporary storage of encountered groundwater with treatment (sediment and/or contaminants), discharge and on- or off-site disposal as required. Due to the volume of soils that will be exposed at the site, dust management and suppression should also be included in the plans. To ensure there is no dust release to the surrounding community Best Management Practices (BMPs) should be identified. Additionally plans for monitoring (visual or instrumentation) are typically included with action levels and the appropriate responses outlined.