HomeMy WebLinkAbout900 King Street HDR Environmental Review Technical Memo 2021-4-5
hdrinc.com
P a g e | 1
Environmental Review Technical Memo
Date: Monday, April 05, 2021
Project: 900 King Street Redevelopment
To: Chairman Robert Goodman and Members of the Village of Rye Brook Planning
Board
cc: Jennifer Gray, Michal Nowak, Chris Bradbury
From: HDR: Noemi Castillo
Michael Musso
Subject: Review of PUD Site Plan documentation (Air Quality, Noise, Vibration and
Hazardous Materials), provided March 8 and March 29, 2021
Introduction
Henningson Durham & Richardson Architecture and Engineering, PC (HDR) performed
a review of the Site Plan application submittals, provided to HDR on March 8 and March
29, 2021, for the purpose of determining compliance with the Air Quality, Noise, Vibration,
and Hazardous Materials sections of the November 2020 Final Environmental Impact
Statement (FEIS) and associated Findings Statement, prepared for the property located
at 900 King Street. The Site Plan submittals received to date were also reviewed against
HDR’s July 10, 2020 Environmental Review Technical Memo and other technical
memoranda we prepared during the EIS review. This memo provides HDR’s comments
on the Site Plan application submittals, with focus on the Site Plan Approval Drawings
dated March 25, 2021 and the Construction Management Plan dated February 18, 2021.
The Site Plan application submittals included:
Site Plan Application Planning Board Submission 2.19.2021
(provided to HDR on March 8, 2021)
• Exterior Building Permit Application, dated February 19, 2021
• Site Plan Application, dated February 19, 2021
• Steep Slope Work Permit Application, dated February 23, 2021 not reviewed
• Wetlands Permit Application, Dated February 23, 2021 not reviewed
• Preliminary Stormwater Pollution Prevention Plan, prepared by JMC, dated February 18,
2021 not reviewed
• AKRF Site Plan Application Transmittal Memo, dated February 18, 2021
• Building Permit Checklist & Zoning Analysis, dated February 19, 2021
• Village of Rye Brook Building Department Memo regarding the Preliminary
Zoning/Building Analysis, dated March 4, 2021 not reviewed
• Site Drawings
o Site Plan Approval Drawings JMC, dated February 18, 2021 (33 sheets)
o Topographic and Utility Map, JMC, dated August 16, 2017
P a g e | 2
TS-1 Topographic and Utility Map
TS-2 Topographic and Utility Map
o Planting Plan (2 Sheets), JMC, dated May 2, 2019, revised February 18, 2021
not reviewed
o Architectural Site Plan Drawings (16 Sheets), Perkins-Eastman, dated February
18, 2021 not reviewed
• Construction Management Plan, dated February 18, 2021
• Concept Plan Stamped Certified Resolution, dated February 2, 2021
• SEQRA Finding Statement Stamped Certified Resolution, dated February 2, 2021
• SEQRA Findings Statement, dated February 2, 2021
• Site Plan Referral Stamped Certified Resolution, dated February 2, 2021
• 900 King Street Zoning Code Amendments Stamped Certified Resolution 2021-2-2.pdf
• AI Engineers (Dolph Rotfeld Engineering) Site Plan Application Review Memo, dated
March 6, 2021
• Snyder & Snyder, LLP Site Plan Application Review Letter, date March 8, 2021 submitted
on behalf of the Arbors
• Hardesty & Hanover, Site Plan Application Review Memo, dated March 8, 2021
• Veneziano & Associates Site Plan Application Review Letter, dated February 18, 2021
Site Plan Application Planning Board Submission – Supplemental Materials,
3.25.2021 (provided to HDR on March 29, 2021)
• AKRF Site Plan Application Supplemental Transmittal Memo, dated March 25, 2021
• Required Contents Outline, dated March 25, 2021
• List of Drawings, dated March 25, 2021
• Draft EFS and Consultant Memos Requirements, dated March 25, 2021
• AKRF Response Memo to Hardesty & Hanover, Site Plan Application Review Memo,
dated March 8, 2021 not reviewed
• JMC Response Memo to AI Engineers (Dolph Rotfeld Engineering) Site Plan Application
Review Memo, dated March 6, 2021 not reviewed
• JMC Proposed Sanitary Sewer Main Memorandum, dated March 25, 2021 not reviewed
• Site Plan Approval Drawings (33 sheets), JMC, dated February 18, 2021, revised March
25, 2021
• Planting Plan (2 sheets), JMC, dated May 2, 2019, revised March 24, 2021. not reviewed
• Project Description, dated March 25, 2021
General
It is recommended that the applicant confirm with the Village the needs for specific
approvals / permits for construction. HDR understands that these may include a
Demolition Permit and single or Phased Building Permits, which will be required after
Site Plan approval.
Construction Management Plan (CMP), dated February 18, 2021
As stated in the CMP,HDR agrees that the CMP will evolve. However, HDR has the
following comments on the February 18, 2021 of the CMP:
P a g e | 3
General
• “EFS” should be defined upon first use in document.
• Construction days and hours should be noted in the CMP as well as the Site
Plan Drawings, for compliance with the Findings Statement.
Air Quality
• Section 7 - Fugitive Dust Avoidance Plan of the CMP:
o First sentence should be revised to state: “In order to minimize potential
air quality impacts associated with demolition and construction
activities…”
o The last bullet should be revised to state: “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 In addition to the text in the final paragraph, the following statement
should be added: “On-site visual monitoring of dust conditions will be
performed to identify potential adverse air quality impacts from airborne
dust and, potentially, the need implement a Community Air Monitoring
Plan (CAMP). Should visual inspection of actual emission and dust
conditions during construction warrant, a CAMP shall be implemented.”
Noise
• Sections 10.1.1 through 10.1.3 should be modified to clarify that: “Noise barriers
shall be maintained throughout the demolition and construction activities.”
• Section 10.1.1 should be revised to more clearly define the limits of the noise
barrier to be constructed along Arbor Drive. As per the Findings Statement, the
noise barrier should be constructed between the Main site Entrance [to the
existing parking lot] and the southern site boundary [near Ivy Hill Lane].
• The last sentence in Section 10.1.1 should be revised to clarify that “Gates in
the barrier to provide authorized access to the construction site shall be closed
at all times except when needed for access/egress.”
• It should be clarified that measures listed in Section 10.2 are application during
demolition and construction activities.
• Section 10.2, the following bullet should be added “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.
Vibration
• Section 9 – Vibration Monitoring Plan should be modified to state that the VMP
will also be implemented during the use of construction impact devices (such
as, jackhammers, pavement breakers, pile drivers, pneumatic tools, etc.)
P a g e | 4
• The warning trigger levels and permissible threshold levels should be defined
clearly in the CMP. Exceedance of the permissible threshold level should result
in a stop work order.
Hazardous Materials
• Section 3.3 – Abatement Activities:
o The end of the first sentence should be revised to state: “…..shall be
completed prior to building demolition and disturbance of existing slab.”
o The first sentence in the second paragraph should be revised to state
“Prior to demolition surveys for asbestos-containing materials (ACM) and
other regulated building materials would be conducted throughout the
existing structure.”
o It is understood that the Material Management Plan (MMP) is
forthcoming. Please refer to pages 56 through 58 for information that
should be included in the MMP.
Comments on the Site Plan Approval Drawings dated March 25, 2021
General
• Implementation of the CMP throughout construction Phases 1 through 7 is not
mentioned on the Site Plan Approval Drawings. This should be added as a note
to the Site Plan Approval Drawings.
• Construction days and hours should be noted in the CMP as well as the Site
Plan Drawings.
Air Quality
• The following air quality control measures were recommended by HDR during the
technical review of the EIS, to be required as a permit/approval condition during
demolition and construction activities, and were included in the Findings
Statement.
o Installing truck mats or anti-tracking pads at egress points to clean the
trucks’ tires prior to leaving the Project Site:
Based on a review of the Site Plan Approval Drawings dated
March 25, 2021, Drawing C-200 notes that stabilized construction
entrance/exits would be established during Construction Phase I
Work (Demolition). However, the location of these are not shown
until Drawing C-201, Construction Phase 2 Work (Road and Site
Utilities). Drawing C-200 should be revised to show the proposed
stabilized construction entrance/exits.
Item #3 on Drawing C-200 should clearly state that the stabilized
construction entrance/exits shall be established prior to the start
of any construction activity or site disturbance, and shall remain
on-site and in use through completion of Phase 7 Work.
P a g e | 5
As per Drawings C-202 through C-204, a concrete truck
washout/truck washdown area will be included for Construction
Phases 3 through 6. Please confirm that Phases 1, 2 and 7 will not
include any concrete work.
o Covering stored materials with a tarp to reduce windborne dust
The covering of stored materials is not included in the Site Plan
Approval Drawings. This should be added.
o Limiting on-Site construction vehicle speed to 5 miles per hour (mph)
The construction notes on Drawings C-200 through C-205 should
clearly state that on-Site construction vehicle speed is limited to 5
mph. In addition, will signs be installed throughout the site stating
this?
o Trucks shall not be allowed to idle for longer than three minutes
The construction notes on Drawings C-200 through C-205 should
clearly state that trucks shall not idle for longer than three minutes.
Noise
• The following noise control measures were recommended during the technical
review of the EIS to be required as a permit/approval condition during demolition
and construction activities, and were included in the Findings Statement.
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 (Blind Brook
School), with the exception of the site entrance:
• It is unclear on Drawing C-200 the extent of the Temporary
12 foot high plywood construction sound fence vs. the
Temporary construction fence also labeled. This should be
clarified as the plywood noise barrier should be installed
along the entire southern property boundary of the site,
with the exception of the site entrance.
• It should be clearly stated on Drawing C-200 that the noise
barrier shall be established prior to the start of any
construction activity or site disturbance, and shall remain
on-site and in use through completion of Phase 7 Work.
• The symbol for the noise barrier should be included in the
legend shown on Demolition and the Erosion and
Sediment Control Plan legends on C-010.
Along the western property boundary:
• The Site Plan Approval Drawings do not show the required
noise barrier along the western property boundary. This
should be added. It should be noted that HDR participated
in a conference call on Thursday April 1, 2021 with AKRF,
Jennifer Gray and Sarah Brown to discuss the preliminary
P a g e | 6
results of the barrier analysis. Further submittals on this
barrier are anticipated from AKRF and the Applicant.
Along the eastern property boundary:
• The Site Plan Approval Drawings do not show the required
noise barrier along the eastern property boundary. This
should be added. It should be noted that HDR participated
in a conference call on Thursday April 1, 2021 with AKRF,
Jennifer Gray and Sarah Brown to discuss the preliminary
results of the barrier analysis. Further submittals on this
barrier are anticipated from AKRF and the Applicant.
Details on all three noise barriers to be constructed should be
provided for review and approval during the Site Plan review and
prior to mobilization. Notes on barrier inspection and maintenance
during all phases of construction should also be included.
o Trucks shall not be allowed to idle for longer than three minutes.
The construction notes on Drawings C-200 through C-205 should
clearly state that trucks shall not idle for longer than three minutes.
HDR participated in a conference call with AKRF on April 1, 2021, where the
applicant’s refined noise analysis was discussed, and ideas on the visual appearance of
the noise barriers were discussed. It is understood that the applicant will be submitting
additional information on the noise barriers in advance of the Planning Board’s May 2021
meeting, including items noted above.
Vibration
• 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.
o Implementation of a Vibration Monitoring Plan throughout construction
Phases 1 through 7 is not mentioned on the Site Plan Approval Drawings.
This should be added.
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.
o Item #5 on Drawing C-200 should be revised to include the surveying of
lead-based paint.
P a g e | 7
o Item #17 on Drawing C-200 should be clearly state that the removal of
these materials shall be completed prior to any demolition activities
including but not limited to disturbing existing building walls and the
existing slab.
• 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. The Planning Board should specify if the
MMP is required for the Site Plan review. Demolition and all other phases of work
shall be conducted in accordance with applicable regulations (OSHA, NYSDOL,
NYSDEC, etc.), and in accordance with any demolition-related approvals from
the Village, see above note recommended for Drawing ----.
o The preparation of an MMP prior the start of any construction activity or
site disturbance and implementation of an MMP throughout construction
Phases 1 through 7 is not mentioned on the Site Plan Approval Drawings.
This should be added.
It is recommended that the applicant confirm with the Village the needs for specific
approvals / permits for construction (post Site Plan review). HDR understands that these
may include a Demolition Permit, along with single or Phased Building Permits. HDR
also notes that per the applicant’s information inventory, items noted in the 3/24/2021
AKRF ‘crosswalk’ table as complete, may not be complete based on comments provided
above and by other Village Consultants.
As alluded to earlier, additional information on the noise barriers is anticipated to be
submitted as related to the Site Plan.
In addition, based on HDR’s prior reviews and Mitigations noted in the Findings
Statement, a couple of items related to noise during the operational phase of the project
(once construction is completed) are noted below. If appropriate at this time, notes can
be added to the Site Plan drawings that address these items:
• Generator models with Level 1 or 2 enclosures shall be selected.
• Deliveries during overnight hours will be limited to the maximum extent
practicable.
• The mechanical systems will be designed to avoid producing a combined 6.0 dBA
or more increase at nearby receptors. Further, at receptors where the existing
noise level is less than 6 dBA during the daytime hours, the mechanical systems
will be designed to avoid causing future noise levels to exceed 65 dBA.
HDR looks forward to continue the Site Plan review as additional information is received.