HomeMy WebLinkAbout07.10.2020 HDR Memo
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Environmental Review Technical Memo
Date: Friday, July 10, 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 third draft of the preliminary FEIS sections (Air
Quality, Noise, Vibration and Hazardous Materials), dated July 2, 2020
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 third draft of the preliminary Final Environmental Impact
Statement (pFEIS), dated July 2, 2020, prepared for the property located at 900 King
Street. The third draft of the pFEIS was provided as a result of comments from the Village
of Rye Brook (Village) Board and consultants in February 2020 on the January 2020
pFEIS.
We have confirmed that prior HDR comments regarding information and analyses to be
included in the pFEIS have been addressed, with the exception of mitigation for the
potential increases in noise levels at the Arbor condos and at the Village Hall, Police
Department and Fire Department, as discussed in this memo and previous memos.
Permit approval conditions for the Village’s consideration at a later time during Village
permitting required prior to mobilization for demolition / construction activities, are also
provided below. If applicable, these recommendations could also be used for the
Village’s pFEIS findings statement.
Noise
Arbors
As per prior comments over the course of reviewing the project, HDR recommends
that prior to the start of construction and demolition activities the Village consider
requiring the applicant to install a 12 foot tall noise barrier along the entire
perimeter of the Project Site on the western property line for the purpose of
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shielding the Arbors Condos, in addition to the barrier along the southern property
boundary already committed to in the pFEIS..
• Significantly elevated noise levels are anticipated at the Arbors condos during
construction for up to 17 months.
o 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.
o 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.
o These noise increases would be perceived by residents using their
outdoor space as a doubling of noise.
o Although the pFEIS claims that interior noise levels during construction
would be expected to be 45 dBA, which is considered acceptable, any
outdoor use would be disrupted by this noise increase which could be
perceived as a doubling of noise.
o The applicant claims in the July 2, 2020 pFEIS submission memo that the
assumed simultaneous demolition and ground clearing activities is not
likely to occur. However:
The applicant does not commit to not performing these activities
simultaneously; and
Other construction activities are predicted to increase noise levels
by up to 9 dBA intermittently over the course of another 11 months
during the construction period.
Village Hall, Police Department and Fire Department
As per prior comments over the course of reviewing the project, HDR recommends
that prior to the start of construction and demolition activities the Village consider
requiring the applicant to install a 12 foot tall noise barrier along the entire
perimeter of the Project Site on the eastern property line for the purpose of
shielding the Village Hall, Police Department, and Fire Department occupants, 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.
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• Noise walls could reduce noise levels for the benefit of the Village Hall, Police
Department and Fire Department occupants. The Fire Department has been
confirmed to include sleeping quarters that would be used during the day during
construction hours.
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;
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
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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.
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.
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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.
• Prior to starting demolition / construction (i.e., during Village permit stage), a site
vibration monitoring plan should be prepared and 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.
• 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
• 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.
• It is recommended that the Village Building Department track progress on
abatement activities conducted (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
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.
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• 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.