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HomeMy WebLinkAbout02.06.2020 HDR Memo hdrinc.com P a g e | 1 Environmental Review Technical Memo Date: Thursday, February 06, 2020 Project: 900 King Street Redevelopment To: Jennifer Gray, Michal Nowak, Chris Bradbury cc: From: HDR: Noemi Castillo Michael Musso Subject: Technical Review of the second draft of the January 3, 2020 preliminary FEIS 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 Air Quality, Noise, Vibration, and Hazardous Materials sections of the second draft of the preliminary Final Environmental Impact Statement (pFEIS), dated January 3, 2020, prepared for the property located at 900 King Street. This second draft of the pFEIS was provided as a result of comments from the Village of Rye Brook (Village) Board and consultants on previous drafts of the pFEIS, including an informal Draft 900 King Street Redevelopment Revised pFEIS, dated July 24, 2019, circulated by AKRF to the Village’s consultants. The revised January 3, 2020 pFEIS was prepared to assess a revised Proposed Action, consisting of the removal of l 16 Independent Living (IL) units, for a new total of 136 IL units, 20 townhouse units and 94 Assisted Living (AL) beds. In addition, the gross square footage (gsf) of the revised Proposed Action has been reduced by another 20,280 gsf, for a new revised total of 355,902 gsf. The January 3, 2020 Air Quality, Noise, Vibration, and Hazardous Materials sections were also prepared to address previous comments, including those provided in HDR’s June 14, 2019 Technical Memo regarding a review of the original (May 2019) pFEIS, and HDR’s October 10, 2019 Technical Memo regarding the proposed language and edits included in the July 24, 2019 informal Draft Revised pFEIS. As detailed below, some prior HDR comments on our assessments have not been fully addressed with the January 3, 2020 submittal. Recommendations for supplemental information / clarifications for the pFEIS Record, and/or for consideration at a later time during Village permitting required prior to mobilization for demolition / construction activities, are provided below. We note that based on our review of the revised pFEIS documents (January 2020), the reduction in project scale does not substantially affect our focused reviews of environmental conditions, air quality, and noise. P a g e | 2 Air Quality • Initial Stationary Screening (applicable to Chapters 2 and 3) – o The pFEIS was revised to state which pollutants were screened and provides a footnote for those pollutants for which neither screening nor analysis was performed. The footnote states that “Consistent with the DEIS, the revised Proposed Project would not result in significant emissions of SO2, lead or ozone. Therefore, further analysis for these pollutants is not warranted.” However, the DEIS does not directly confirm that these parameters were indeed evaluated and ‘screened out’, or directly discuss why these parameters were not screened or assessed (e.g., for the built scenario or for the demolition / construction phase). The applicant should provide a follow-up statement to address this item. o Currently, the results of the air quality parameter screening is not provided. The pFEIS should clearly state that based on the screening, only NO2 and PM2.5 were identified to be further assessed for the stationary sources. • Maximum Predicted PM2.5 Concentrations (applicable to Chapters 2 and 3) – o Parking analysis – Since a NAAQS is provided for Carbon Monoxide (CO) on a 1-hour basis and an 8-hour basis, the applicant should explain why a CO 1-hour analysis is not required, and why only predicted emissions for CO 8-hour is provided. 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. As stated in previous Technical Memos, the total 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). Section 2.13.4, “Parking Analysis,” states that the total maximum predicted 24-hour and annual PM2.5 concentrations are 24.4 µg/m3 and 7.6 µg/m3, respectively These values do not appear to include the emissions predicted from all stationary sources, as shown in the table below. The table below was prepared by HDR to calculate the operational maximum total concentrations predicted, as per the information provided in different sections of the pFEIS. The operational maximum total predicted 24-hour and annual average PM2.5 concentrations should include all stationary sources (IL/AL Buildings and the Townhouses) as well as the parking facility and the existing background concentrations. Furthermore, the inclusion of this table in the revised pFEIS may help present the results more clearly. P a g e | 3 Pollutant Averaging Period Maximum Modeled Impact Background Concentration 3 Total Concentration NAAQS IL/AL Buildings (HVAC)1 Townhouses (HVAC)2 Parking Garage PM2.5 24-hour 2 1.2 6.7 15.7 25.6 35 Annual 0.1 0.5 1.1 6.0 7.7 12 Notes: 1 See Table 2.13-2. 2 See Table 2.13-3. 3 See Table 2.13-1. • HDR NOTE: It is understood that regarding potential Air Quality impacts, all construction mitigation measures will be installed and in effect during demolition and construction activities, as applicable. Noise • Per the pFEIS, increases in noise levels up to 12 dBA are anticipated at the Arbors condos (North Side of Ivy Hill Crescent) during portions of the approximately 6 months of site demolition and ground clearing. In addition, these same residents would also experience a noise level increase of up to 9 dBA intermittently over the course of another 11 months during the construction period. These noise increases would be perceived by residents using their outdoor space as a doubling of noise. As such, prior to the start of construction and demolition activities, the Applicant should be required to erect a 12-foot noise barrier along the entire perimeter of the Project Site on the western property line for the purpose of shielding the Arbors Condos, in addition to the barrier along the southern property boundary already committed to in the pFEIS. • Per the pFEIS, increases in noise levels up to 11.8 dBA are anticipated at the property to the east (including Village Hall, Police Department and Fire Department). In addition, interior nose levels would be approximately 57 dBA during the most noise-intensive periods of construction, which exceed the interior noise level limit of 45 dBA. Therefore, prior to the start of construction and demolition activities on the Project Site, the Applicant should be required to erect a 12-foot noise barrier along the entire perimeter of the Project Site on the eastern property line for the purpose of shielding the Village Hall occupants • HDR NOTE: It is understood that all construction noise mitigation measures will be in effect during demolition and construction activities, including, but not limited to, the erection of the noise barriers. P a g e | 4 Vibration • Prior to starting demolition / construction (i.e., during Village permit stage), the site vibration 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. • HDR NOTE: 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 • As per HDR prior comments, it is understood that all interior building 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. Recommendations for Permit/Approval Conditions Following the Village Board’s pFEIS findings, it is understood that specific Village approvals (e.g., Final Site Plan; Building Permits for demolition; etc.) will be required to specify conditions related to the future demolition and construction phases of the project. HDR recommendations (for future reference) are provided below for each of our main review categories. If applicable, these recommendations could also be used for the Village’s pFEIS findings statement. 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 the Draft Demolition Site Plan application (that was withdrawn). 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 without creating standing or flowing of water; o Covering stored materials with a tarp to reduce windborne dust; P a g e | 5 o Limiting on-Site construction vehicle speed to 5 miles per hour (mph); o Using truck covers/tarp rollers that fully cover hauled materials and keep debris and dust from being expelled from the truck along its haul route; o On-site visual monitoring of dust conditions to identify potential adverse air quality impacts from airborne dust and, potentially, the need implement a Community Air Monitoring Plan (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. It is recommended that the Building Department request in-field noise level readings - if warranted based on site work activities - to confirm the noise levels are not above the applicant’s modeled criteria at property lines. 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. P a g e | 6 Details on the noise barriers to be constructed should be provided for review prior to mobilization. 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; 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. Outreach to contacts of the subsurface utilities on and around the project site shall be documented to the Building Department. Hazardous Materials • It is recommended that the Village Building Department track progress on abatement activities conducted during demolition (asbestos containing material (ACM), lead-based paint, and other materials that may be encountered). • As agreed to (and as noted in the revised PFEIS), the Applicant shall prepare a Materials Management Plan (MMP) prior to the start of excavation or ground P a g e | 7 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 correspondences (NYSDOL, etc.) 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; 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.