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HomeMy WebLinkAbout2019.10.10 Revised HDR Noise Review Memo hdrinc.com P a g e | 1 Environmental Review Technical Memo Date: Thursday, October 10, 2019 Project: 900 King Street Redevelopment To: Peter Feroe, AKRF cc: Jennifer Grey, Michal Nowak, Chris Bradbury From: HDR: Noemi Castillo Michael Musso Subject: Revised Memo - Technical Review of Informal, Draft proposed Revised PFEIS sections (Air Quality, Noise, Vibration and Hazardous Materials) Introduction As requested, Henningson Durham & Richardson Architecture and Engineering, PC (HDR) performed a technical review of the informal Draft 900 King Street Redevelopment Revised preliminary Final Environmental Impact Statement (pFEIS), circulated by AKRF and dated July 24, 2019, prepared for the property located at 900 King Street. These proposed revised pFEIS sections were prepared to address comments provided in HDR’s June 14, 2019 Technical Memo regarding a review of the original pFEIS, dated May 14, 2019, and to circulate proposed language and edits to the Village’s consultants for endorsement/further comment prior to the full revised pFEIS being submitted. The informal submission was provided to the Village of Rye Brook (Village) consultants, including HDR, to obtain guidance as to whether the Applicant has adequately addressed the technical comments received on the May pFEIS for the project. HDR issued this Technical memo focusing on a review of air quality, noise, vibration, and hazardous materials assessments associated with the Proposed Project on August 21, 2019. Based on telephone conversations with AKRF on September 6 and September 23, 2019, this technical memo has been revised. Revisions are shown as underlined text. We understand that further technical review of proposed demolition activities will be dictated by the applicant’s demolition approval application process. As detailed below, comments previously provided by HDR on these assessments have not been fully addressed with the informal July 24, 2019 submittal. In addition, additional HDR recommendations are offered below to be considered for the full revised pFEIS documents and/or as permit/approval conditions. P a g e | 2 Air Quality • Maximum Predicted PM2.5 Concentrations – o The project includes single three- and four-story Independent Living (IL) and Assisted Living (AL) buildings as well as 20 two-bedroom residential townhouses and a parking facility. The operational maximum total predicted 24-hour and annual average PM2.5 concentrations provided in the revised pFEIS include the predicted concentrations for the proposed townhouses and the parking facility but does not include the predicted concentrations for the IL and AL buildings. The maximum predicted PM2.5 concentrations for the full development of the Revised Proposed Project should be reported in the pFEIS and confirmed to not exceed the National Ambient Air Quality Standards (NAAQS). o The revised pFEIS states that the “….the maximum predicted 24-hour and annual average PM2.5 concentrations from the vehicles using the garage when conservatively combined with the maximum stationary source concentrations are of 24.5 µg/m3 and 8.2 µg/m3, respectively. The 24-hour value includes predicted concentrations of 6.7 µg/m3 and 2 µg/m3, from emissions within the parking facility and townhouses, respectively, and a background level of 15.8 µg/m3.” However, per Table 2.13-2 and 3.-13-2, the 24-hour PM2.5 concentration from the townhouses was predicted to be 1.2 µg/m3 (not 2 µg/m3). Please clarify. o After discussions with AKRF, HDR understands that AKRF will clarify the pFEIS text to note that the modeled concentrations indicated include all project stationary and mobile sources. • Background data – The Applicant states in the pFEIS that the background concentrations of all criteria pollutants provided in Table 3.13-1 are based on the 2017 New York State (NYS) Ambient Air Quality Report. However, only the PM2.5, NO2, and SO2 values are from the 2017 NYS report. The remaining values appear to be from the 2016 NYS report. The background concentrations reported in Table 3.13-1 should all be from the most recent NYS report. At this point, the NYSDEC has released the 2018 NYS report. Therefore, the pFEIS (Table 3.13-1 and the analysis values) should be updated based on the 2018 values. In addition, the values reported in Table 3.13-1 for NO2 and SO2 should be in ppb to avoid confusion and the need to convert units. • Initial Stationary Screening – A concluding statement should be provided for Response 118 that clearly states which pollutants the screening assessment was performed for and which one of those screened in for an analysis. • Mobile Sources – Section 2.13.2 of the revised pFEIS still states that the study area includes 11 locations. Please revise to 12 locations, as per Response 115 in the revised Chapter 3: Response to Comments. P a g e | 3 • Dust monitoring should be included as a control measure, in addition to the proposed dust suppression. [The next bullet discusses monitoring]. • HDR notes that the following statement has been included in the July 24, 2019 revised pFEIS:”In the unlikely event that airborne dust from the Project Site creates an adverse impact to the BBRUFSD, procedures would be in place to immediately alert the on-Site construction manager and the Village so that appropriate measures could be taken to ameliorate the potential temporary impact and, if determined necessary by the Village’s Special Engineering Consultant, initiate a CAMP. However, if dust conditions are observed, the need for particulate monitoring may be required in conjunction with dust suppression measures. The monitoring results will dictate the need for a CAMP. • After discussions with AKRF, HDR understands that AKRF will clarify that on-site visual monitoring of dust conditions will be performed to identify potential adverse air quality impacts from airborne dust and, potentially, the need for a CAMP. Noise • The first paragraph in Section 2.14.1 should be revised to state Noise Receptor Sites 5 and 6. • There is currently no on-site movement of traffic. Therefore, please remove the added sentence in Response 128. Although deliveries to the site are anticipated to be minimal, the project will include other vehicles accessing the site. Per Section 12.5.1 of the DEIS, the Proposed Project would generate at total of 70 trips during the weekday AM peak hour, a total of 80 trips during the weekday midday peak hour and 90 trips during the weekday PM peak hour. The anticipated peak hour noise level from these vehicle trips at the proposed on-site townhouses and IL and AL buildings, and the Arbors Townhouses should be determined and reported in the revised pFEIS. After discussions with AKRF, HDR understands that AKRF will use existing modeled data at the site driveway and Arbor Drive to discuss in the pFEIS the anticipated noise levels from vehicles using the on-site roadways on their way to/from the on-site garage. • The following should be clarified in the Chapters 2 and 3 of the pFEIS: Mechanical equipment should be designed to avoid a combined 6.0 dBA increase at nearby receptors, from all project-generated stationary and mobile sources. At receptors where the existing noise level is less than 65 dBA during the daytime hours, the project-generated stationary and mobile sources should not cause the future noise levels to exceed 65 dBA. • Noise levels should be predicted at the Harkness Tennis Court during the operational phase, not just construction. After discussions with AKRF, HDR understands that AKRF will add to the pFEIS a discussion that operational noise levels were modeled at King Street and Arbor Drive, with a predicted noise level increment less than 1.0 dBA, and that this location is a conservative P a g e | 4 representation of the park (at the tennis court) which is along these roadways but set back further. • The response to comments now cites in Response 149 Table 19-3 of the CEQR Technical Manual. However, it is not explained and is unclear how this table is used. A 25 dBA reduction is not stated in this Table. • The Blind Brook Middle/High School West Façade (facing Arbor Drive) does have windows on the southern half of that façade. As such, assuming the windows would remain closed at all times during construction or demolition activities, a 20 to 25 dBA reduction should be used for the analysis as opposed to 35 dBA. After discussions with AKRF, HDR understands that AKRF will replace the text in the last paragraph of page 3-134/135 of the informal July 24, 2019 pFEIS that begins, "As such, noise levels interior..." with o As stated above, standard facade construction (e.g., with regular size windows), provides at least 25 dBA attenuation from exterior noise levels, assuming windows remain closed at all times. Given that there are no facade penetrations for ventilation and there is a relatively small amount of glazing in an otherwise brick facade, noise levels interior to these classrooms would benefit from facade attenuation in excess of 25 dBA. Therefore, given maximum exterior noise levels from construction of approximately 70.6 dBA at this location, noise levels in these classrooms would be expected to be approximately 45 dBA or lower during construction, which would be considered acceptable for classroom use. • Per Table 2.16-2 of the DEIS, increases in noise levels greater than 10 dBA are anticipate during construction at the Arbors condos (North Side of Ivy Hill Crescent), Blind Brook Middle/High School West Façade (facing Arbor Drive) and the Village Hall, Police Department and Fire Department. As such, the Applicant should be required to not only erect a 12-foot noise barrier along the perimeter of the Project Site on Arbor Drive for the purpose of shielding the Blind Brook Middle/High School West Façade, but also erect a 12-foot noise barrier along the perimeter of the Project Site on the western property line for the purpose of shielding the Arbors Condos, and along the perimeter of the Project Site on the eastern property line for the purpose of shielding the Village Hall, Police Department and Fire Department prior to the start of demolition and construction activities. After discussions with AKRF, HDR understands that AKRF will inquire as to whether there are sleeping quarters in the Police Department and Fire Department and whether they are utilized during daytime hours. As of now, all three barrier walls are being recommended. • 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 applicant will ensure compliance with the construction noise control commitments. P a g e | 5 Vibration • The monitoring plan should include a listing of a Tennessee Gas Pipeline 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 (Tennessee Gas Pipeline and all others) prior to the start of demolition and construction activities, and report to the Building Department on such notifications and any feedback received. • It is the applicant’s responsibility to document existing (pre-demolition / pre- construction) conditions of all subsurface utilities to the extent feasible, and to rectify any damage to such caused by the proposed work. 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 materials), as required, should be completed prior to any demolition activities including but not limited to disturbing existing building walls and the existing slab. • The MMP should also describe how waters generated during the demolition work (i.e., excess waters generated during dust suppression, wash waters from road or equipment cleaning) and sediments accumulated from the soil erosion / sediment control measures will be handled. After discussions with AKRF, HDR understands that AKRF will update the pFEIS to state that the dust suppression activities would not be expected to generate standing or flowing water; rather they would be de minimis moistening activities. Recommendations for Permit/Approval Conditions Air Quality • The following air quality control measures should be required as a permit/approval condition during demolition and construction activities. Many of these have been previously noted by HDR, during our technical reviews of the May 2019 pFEIS and Demolition Site Plan application. o Minimizing the area of soil that is disturbed at any one time; o Minimizing the amount of time during which soils are exposed; o Installing truck mats or anti-tracking pads at egress points to clean the trucks’ tires prior to leaving the Project Site; o Watering of exposed areas during dry periods; o Covering stored materials with a tarp to reduce windborne dust; o Limiting on-Site construction vehicle speed to 5 miles per hour (mph); o 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. P a g e | 6 o On-site visual monitoring of dust conditions to identify potential adverse air quality impacts from airborne dust and, potentially, the need for a CAMP. o Ultra-low sulfur diesel shall be utilized for all construction equipment and vehicles; o All equipment shall be properly maintained; o Idling of construction or delivery vehicles or other equipment shall not be allowed when the equipment is not in active use. o Trucks shall not be allowed to idle for longer than three minutes. 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 Non-road diesel engines with a power rating of 50 horsepower (hp) or greater and controlled truck fleets (i.e., truck fleets under long-term contract with the project) including but not limited to concrete mixing and pumping trucks shall utilize Best Available Tailpipe (BAT) technology for reducing diesel particulate matter emissions. Diesel particulate filters (DPFs) have been identified as being the tailpipe technology currently proven to have the highest reduction capability. Contracts shall specify that all diesel non-road engines rated at 50 hp or greater shall 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. Noise • The following noise control measures should be required as a permit/approval condition during demolition and construction activities. Many of these have been previously noted by HDR, during our technical reviews of the May 2019 pFEIS and Demolition Site Plan application. o Erection of a noise barrier that is 12 feet tall along the perimeter of the Project Site on:  Arbor Drive along the southern property boundary, with the exception of the site entrance;  the western property boundary; and  the eastern property boundary. Details on the noise barriers to be constructed should be provided for review. The noise barrier should be maintained throughout the demolition and construction activities. o Noisy equipment, such as cranes, concrete pumps, concrete trucks, and delivery trucks, shall be located away from, and shielded from, sensitive receptors, such as the school, to the extent practicable; P a g e | 7 o Equipment, including the mufflers on the equipment, shall be required to be properly maintained; o Electrification of construction equipment to the extent feasible and practicable shall be undertaken as soon in the construction process as logistics allow; o The site shall be configured to minimize back-up alarm noise to the extent feasible and practicable; o Trucks shall not be allowed to idle for longer than three minutes. o Generators shall be placed on the west side of the Project Site facing the Parkway, which shall 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 shall be selected. o Equipment anticipated to increase noise levels at the property boundary by more than 6 dBA or to a noise level greater than 65 dBA shall include path controls. o Coordination with the School District. o The days of the week and time of day restrictions codified in the Village Noise Code, with the exception of the morning start time, as discussed in Section 2.16.2.2 of the DEIS, “Construction: Potential Traffic Impacts on the MS/HS”; Vibration • The permit/approval shall include a condition that a vibration monitoring program at The Arbors community and at the Tennessee Gas Pipeline (2 stations/ monitoring points) shall be implemented during demolition and during the use of construction impact devices (such as, jackhammers, pavement breakers, pile drivers, pneumatic tools, etc.) to ensure that vibration levels do not exceed the thresholds that could potentially result in damage to adjoining property, utilities (water, sewer, gas, electric, fiber / cable), etc. • Vibration monitoring shall be conducted in accordance with any demolition- related approvals from the Village Hazardous Materials • It is recommended that the Village Building Department track progress on asbestos containing material (ACM) and lead-based paint and abatement. • As agreed to the revised PFEIS, the Applicant shall prepare a Materials Management Plan (MMP) prior to the start of excavation or ground disturbance work. The MMP in accordance with the revised PFEIS shall be included as a permit/approval condition. Demolition shall occur in accordance with applicable regulations (OSHA, NYSDOL, etc.), and in accordance with any demolition- related approvals from the Village. • Copies of agency correspondence shall be submitted to the Building Department. • 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; P a g e | 8 quantities removed; off-site destinations and disposal/recycling documentation) to the Building Department within 30 days of the completion of work. • Copies of all abatement filings (e.g., New York State Department of Labor for ACM) and memos describing abatement work completed shall be furnished to the Building Department within 45 days after completion.