2017-01-04.17TMP0019M.RAPRAWP.Draft … Columbus Circle New York, New York 10023 Prepared by: Langan Engineering, Environmental, Surveying, and Landscape Architecture, D.P.C. 360 West

Remedial Action Work Plan

For

50 Hudson Yards

New York, New York

NYC TAX BLOCK 705, LOTS 29, 30, 32, 39, 45, 46 & 50

E-Designation E-137

CEQR Number 03DCP031M

OER Number 17TMP0019M

Prepared for:

50 HYMC OWNER LLC

60 Columbus Circle

New York, New York 10023

Prepared by:

Langan Engineering, Environmental, Surveying, and Landscape Architecture, D.P.C.

360 West 31st Street, 8th Floor


January 4, 2017

Remedial Action Work Plan 50 Hudson Yards New York, New York Langan Project No. 170265201

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CERTIFICATION

I, Jason J. Hayes, am currently a registered professional engineer licensed by the State of New York. I performed professional engineering services and had primary direct responsibility for designing the remedial program for 50 Hudson Yards site in New York, NY (OER No. 17TMP0019M). I certify to the following:

I have reviewed this document, to which my signature and seal are affixed.

Engineering Controls, if required for this remedial action, will be designed by me or a person under my direct supervision and designed to achieve the goals established in this Remedial Action Work Plan (RAWP) for this site.

Engineering Controls, if required, for this remedial action are accurately reflected in the text and drawings of the RAWP and are of sufficient detail to enable proper construction.

This RAWP has a plan for handling, transport and disposal of soil, fill, fluids and other materials removed from the property in accordance with applicable city, state and federal laws and regulations. There is also a plan for importation of all soil, fill and other material from off-site in accordance with all applicable city, state and federal laws and requirements. This RAWP has provisions to control nuisances during the remediation and all invasive work, including dust and odor suppression.

Name

NYS PE License Number

Signature

Date

PE Stamp


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REMEDIAL ACTION WORK PLAN

TABLE OF CONTENTS

CERTIFICATION ............................................................................................................................. II TABLE OF CONTENTS ................................................................................................................. III LIST OF ACRONYMS ..................................................................................................................... VI EXECUTIVE SUMMARY ............................................................................................................... IX COMMUNITY PROTECTION STATEMENT ....................................................................... XVII 1.0 SITE BACKGROUND ............................................................................................................. 1 1.1 Site Location and Current Usage ............................................................................................. 1 1.2 Proposed Redevelopment Plan ................................................................................................. 2 1.3 Description of Surrounding Property ...................................................................................... 3 1.4 Summary of Past Site Uses and Areas of Concern ................................................................. 4 1.5 Summary of Remedial Investigation Field Work ................................................................... 5 1.6 Summary of Environmental Findings ..................................................................................... 5 2.0 DESCRIPTION OF REMEDIATION .................................................................................... 8 2.1 Remedial Objectives .................................................................................................................. 8 3.0 REMEDIAL TRACK ANALYSIS .......................................................................................... 9 3.1 Summary of Proposed Remedial Action.................................................................................. 9 3.2 Threshold Criteria ................................................................................................................... 10 3.3 Balancing Criteria ................................................................................................................... 10 4.0 REMEDIAL ACTION ............................................................................................................ 15 4.1 Summary of Proposed Remedial Action................................................................................ 15 4.2 Soil Cleanup Objectives and Soil/ Fill Management ............................................................ 17

4.2.1 Estimated Soil/Fill Removal Quantities ............................................................................ 17 4.2.2 Waste Characterization Grids ........................................................................................... 17 4.2.3 Documentation Soil Sampling .......................................................................................... 17 4.2.4 Quality Assurance/Quality Control ................................................................................... 18 4.2.5 Import of Soils .................................................................................................................. 18 4.2.6 Reuse of On-site Soils ....................................................................................................... 18

4.3 Engineering Controls .............................................................................................................. 18 4.3.1 Composite Cover System .................................................................................................. 18 4.3.2 Waterproofing/Vapor Barrier System ............................................................................... 18

4.4 Institutional Controls .............................................................................................................. 19 4.4.1 Site Management Plan ...................................................................................................... 20

4.5 Qualitative Human Health Exposure Assessment ................................................................ 20 5.0 REMEDIAL ACTION MANAGEMENT ............................................................................. 26 5.1 Project Organization and Oversight ...................................................................................... 26 5.2 Site Security ............................................................................................................................. 26 5.3 Work Hours ............................................................................................................................. 26 5.4 Construction Health and Safety Plan .................................................................................... 26 5.5 Community Air Monitoring Plan ........................................................................................... 27

5.5.1 VOC Monitoring, Response Levels, and Actions ............................................................. 27


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5.5.2 Particulate Monitoring, Response Levels, and Actions .................................................... 28 5.6 Agency Approvals .................................................................................................................... 28 5.7 Site Preparation ....................................................................................................................... 28

5.7.1 Pre-Construction Meeting ................................................................................................. 28 5.7.2 Mobilization ...................................................................................................................... 28 5.7.3 Utility Marker Layouts, Easement Layouts ...................................................................... 29 5.7.4 Dewatering ........................................................................................................................ 29 5.7.5 Equipment and Material Staging ...................................................................................... 29 5.7.6 Stabilized Construction Entrance ...................................................................................... 29 5.7.7 Truck Inspection Station ................................................................................................... 29 5.7.8 Extreme Storm Preparedness and Response Contingency Plan ........................................ 30 5.7.9 Storm Preparedness ........................................................................................................... 30 5.7.10 Storm Response ................................................................................................................ 30 5.7.11 Storm Response Reporting ............................................................................................... 31

5.8 Traffic Control ......................................................................................................................... 31 5.9 Demobilization ......................................................................................................................... 31 5.10 Reporting and Record Keeping .............................................................................................. 32

5.10.1 Daily Reports .................................................................................................................... 32 5.10.2 Record Keeping and Photo-Documentation ..................................................................... 32

5.11 Complaint Management .......................................................................................................... 32 5.12 Deviations from the Remedial Action Work Plan ................................................................ 33 6.0 REMEDIAL ACTION REPORT .......................................................................................... 34 7.0 REMEDIAL ACTION REPORT CERTIFICATION ........................................................ 35 8.0 SCHEDULE ............................................................................................................................. 35


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FIGURES

Figure 1 - Site Location Map

Figure 2 - Site Plan

Figure 3 - Surrounding Land Use and Sensitive Receptors Map

Figure 4 - Proposed Development Plan

Figure 5 - Excavation Plan

Figure 6 - Composite Cover System Layout

Figure 7 - Waterproofing/Vapor Barrier System Layout

Figure 8 - Truck Route Map

TABLES

Table 1 – Summary of Track 1 Unrestricted Use Soil Cleanup Objectives

APPENDICES

Appendix A - Architectural Development Plans

Appendix B - Previous Environmental Reports (CD)

Appendix C - Soil/Materials Management Plan

Appendix D - Construction Health and Safety Plan

Appendix E - Citizen Participation Plan

Appendix F - Sustainability Statement


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LIST OF ACRONYMS

Acronym Definition

AGV Air Guidance Values

AOC Area of Concern

ASTM American Society of Testing and Materials

BCP Brownfield Cleanup Program

bgs Below Ground Surface

BOA Brownfield Opportunity Areas

BTEX Benzene, Toluene, Ethylbenzene, and Total Xylenes

CAMP Community Air Monitoring Plan

CEQR City Environmental Quality Review

CFR Code of Federal Regulations

CHASP Construction Health and Safety Plan

CO Certificate of Occupancy

COC Contaminants of Concern

DER Division of Environmental Remediation

DNAPL Dense Non-Aqueous Phase Liquid

EC/IC Engineering Control and Institutional Control

el Elevation

ELAP Environmental Laboratory Accreditation Program

EPA United States Environmental Protection Agency

ESA Environmental Site Assessment

FDNY Fire Department of New York

GPS Global Positioning System

HAZMAT Hazardous Materials

HAZWOPER Hazardous Waste Operations and Emergency Response

LNAPL Light Non-Aqueous Phase Liquid

LTANKS Leaking Underground Storage Tanks

MEP Mechanical, Electrical and Plumbing

MRCE Mueser Rutledge Consulting Engineers

MTBE methyl tert butyl ether

NAVD88 North American Vertical Datum of 1988

NOC Notice of Completion

NYC New York City


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Acronym Definition

NYCDCP New York City Department of City Planning

NYCDEP New York City Department of Environmental Protection

NYCDOB New York City Department of Buildings

NYCOER New York City Office of Environmental Remediation

NYCRR New York Codes, Rules and Regulations

NYSDEC New York State Department of Environmental Conservation

NYSDOH New York State Department of Health

NYSDOT New York State Department of Transportation

OSHA United States Occupational Health and Safety Administration

PCBs Polychlorinated Biphenyls

PCE Tetrachloroethene

PE Professional Engineer

PGW Protection of Groundwater

PID Photoionization Detector

PM Particulate Matter

PPE Personal Protective Equipment

ppm Parts Per Million

QA/QC Quality Assurance/Quality Control

QHHEA Qualitative Human Health Exposure Assessment

RA Registered Architect

RAO Remedial Action Objectives

RAWP Remedial Action Work Plan

RAR Remedial Action Report

RCRA Resource Conservation and Recovery Act

RI Remedial Investigation

RIR Remedial Investigation Report

RIWP Remedial Investigation Work Plan

SCOs Soil Cleanup Objectives

SCG Standards, Criteria and Guidance

SGV Standards and Guidance Values

SMP Site Management Plan

SMMP Soil/Materials Management Plan

SVOCs Semivolatile Organic Compounds


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Acronym Definition

TAL Target Analyte List

TCE Trichloroethene

TCL Target Compound List

TCLP Toxicity Characteristic Leaching Procedure

TOGS Technical and Operational Guidance Series

UST Underground Storage Tank

VCP Volunteer Cleanup Program

VOCs Volatile Organic Compounds


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EXECUTIVE SUMMARY

This Remedial Action Work Plan (RAWP) and site-specific Construction Health and Safety Plan (CHASP) have been developed on behalf of 50 HYMC OWNER LLC for the proposed development located at 50 Hudson Yards (alternately 413 Tenth Avenue, 427 Tenth Avenue, 503 West 33rd Street, 507 West 33rd Street, 504-514 West 34th Street and 516-520 West 34th Street) in the Midtown/ Hudson Yards neighborhood of Manhattan, New York (the site). The site was assigned an E-Designation (E-137) for hazardous materials (Hazmat) and noise (window wall attenuation and alternate means of ventilation) by the New York City Department of City Planning (NYCDCP) following the Hudson Yards Rezoning (CEQR #03DCP031M) and requires coordination with the New York City Office of Environmental Remediation (NYCOER).

Site Location and Current Usage

The site is located at 50 Hudson Yards in the Midtown/ Hudson Yards neighborhood of Manhattan, New York and is identified as Block 705 and Lots 29, 30, 32, 39, 45, 46 and 50 on the Borough of Manhattan Tax Map. The site is 70,920 square feet and is bound by West 34th Street to the north, Tenth Avenue to the east, West 33rd Street to the south, and Hudson Boulevard to the west. The site is improved with seven multi-story buildings and associated parking areas. Additional details by lot are as follows:

• Lot 29 is 7,900 square feet and is improved with a five-story building.

• Lot 30 is 4,937 square feet and is improved with a three-story building.

• Lot 32 is 1,856 square feet and is improved with a four-story mixed commercial and residential building with a full basement.

• Lot 39 is 15,176 square feet and is improved with an asphalt parking lot and a two-story former fast food restaurant with partial basement.

• Lot 45 is 9,875 square feet and is improved with one two-story building with a full basement level.

• Lot 46 is 29,000 square feet and is improved with two buildings (one two-story and one 12-story) with an adjoining parking lot to the northwest. The 12-story building on Lot 46 includes a full basement level and a partial sub-basement level.

• Lot 50 is 2,176 square feet and is undeveloped.


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Summary of Proposed Redevelopment Plan

The proposed development project consists of the construction of a new 12-story commercial tower with a cellar, and two sub-cellar levels. The superstructure design may be revised at a later date to accommodate a taller building; however, the extent of subgrade structures is not anticipated to change significantly. Sidewalk elevations range from elevation (el) 38.181 and el 21.66 (sloping from northeast to southwest - from Tenth Avenue and West 34th Street to Hudson Boulevard and West 33rd Street). The site will be excavated into bedrock to accommodate foundation components and the cellar and two sub-cellar levels with a general top of slab at el -4.5. General excavation will be completed to 35 to 45 feet below grade surface (bgs). The current zoning designation is C6-4, which permits a wide range of high-bulk commercial uses. The proposed use is consistent with existing zoning for the property.

The cellar and two sub-cellar levels will cover the majority of the site, with the exception of Lot 50 located in the western portion of the site. The cellar level will contain bicycle storage, tenant storage areas, a central elevator bank, tenant break rooms, locker rooms, security storage room, and mechanical, telecommunication, storm water tank, fuel oil control and electrical rooms. The first sub-cellar level will contain commercial amenities, a loading dock, delivery storage, mechanical rooms, refuse rooms, water service and fire pump room, mail room storage, and electrical and mechanical rooms. Two subway connection tunnels are planned for the southwest portions of the first sub-cellar level beneath Hudson Boulevard and West 33rd Street. The second sub-cellar level will contain storage rooms, parking, a below-grade loading dock, a water tank room, service elevator lobbies, and a fuel oil storage tank room.

The first floor will contain retail areas, central elevator banks, entrance lobbies, a car drop-off port, a truck elevator, and a bike ramp. The second floor will include areas open to the first floor lobbies, retail spaces, offices, and commercial tenant amenities. Floors 3 through 5 will contain commercial office space and tenant amenities. The sixth floor will contain a central and outside air plant, engineering, electrical, exhaust, and control rooms. Floors 7 through 12 will contain offices and tenant amenities. Mechanical areas will be located on the roof.

Summary of Past Uses of Site and Areas of Concern

A review of previous reports, available historical Sanborn fire insurance maps, topographic maps, and aerial photographs revealed that the site was developed with several multi-story buildings as early as 1890. Historic site use included a leather factory, engraving supply shop, paper bailing, lard oil refinery, coal yard, glass company, cutting company, metal and manufacturing company, auto parts company, chemist facility, elevator company and a furniture finishing and assembly warehouse.

The identified Areas of Concern (AOC) are described below.

1 Elevations are in North American Vertical Datum of 1988 (NAVD88).


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AOC 1 – Documented Contaminated Historic Fill Material

Previous reports document the presence of historic fill at the site, and laboratory analyses of soil samples collected from the historic fill material confirmed the presence of semivolatile organic compounds (SVOC) and metals at concentrations above 6 New York Codes Rules and Regulations (NYCRR) Part 375 Unrestricted Use Soil Cleanup Objectives (SCO).

AOC 2 – Historical Site Use

Historical site use included a leather factory, engraving supply shop, paper bailing, lard oil refinery, coal yard, glass company, cutting company, metal and manufacturing company, auto parts company, chemist facility, elevator company and a furniture finishing and assembly warehouse. Potential contaminants, including solvents, petroleum products, SVOCs, metals and polychlorinated biphenyls (PCB) were likely used during historical site operations. Spills or leaks of these contaminants may have impacted the subsurface soil, soil vapor and groundwater.

AOC 3 – Petroleum Bulk Storage on Site

Historical fuel oil and gasoline storage was reported on site Lots 29, 30, 39, 45 and 46. A Certificate of Occupancy (CO) dated October 15, 1947 identified a gasoline tank as approved for installation by the New York Fire Department (NYFD) in Lot 30. COs dated January 14, 1948 and August 7, 1951 indicate NYFD approval of fuel oil installation in Lots 29 and 39. One 10,000-gallon #6 fuel oil tank was observed in a vault beneath the 33rd Street sidewalk along Lot 46. One 1,080-gallon #2 fuel tank was observed in the Lot 45 building basement. The 1,080-gallon tank is encased in concrete, with the exception of a portion of the top that is chipped away. One 1,000-gallon tank was observed in the basement of Lot 29.

AOC 4 – Historic Use at Adjoining Properties

524 West 36th Street, which is located approximately 350 feet north (cross-gradient) of the site, includes a ten-year history of gasoline tank overfills. Groundwater monitoring is on-going at the property, and groundwater contamination was observed to be present within the bedrock zone. The former BP Service Station, located across Tenth Avenue to the northeast of the site, contains multiple Leaking Underground Storage Tanks (LTANKS) and NY Spills listings. Elevated petroleum-related volatile organic compounds (VOC) (e.g., benzene, toluene, ethylbenzene, and total xylenes [BTEX]) and methyl tert butyl ether (MTBE) were detected in groundwater. Light non-aqueous phase liquid (LNAPL) was detected in one of the wells at the property. A stipulation list to conduct cleanup and removal of petroleum discharges in reference to the spill was signed and returned to New York State Department of Environmental Conservation (NYSDEC) on August 23, 2004. Site-wide remedial excavations and groundwater remediation were conducted between 2006 and 2008 as part of redevelopment of the property. Remediation of the groundwater within the underlying bedrock was completed to the extent feasible in 2013 and the spill was closed. During redevelopment of 440 Tenth Avenue (immediately north of the former BP Service Station), a new spill (NYSDEC Spill No. 1309801) was reported due to elevated VOC soil vapor concentrations. The property at 509 West 34th Street, which adjoins the site to the north, is listed in the Brownfield Cleanup Program (BCP) program as Site No. C231094.


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Summary of Remedial Investigation Field Work

Langan completed the scope of work listed below in accordance with the NYCOER-approved September 15, 2016 Remedial Investigation Work Plan (RIWP).

1. A Geophysical Survey

2. Advancement of 16 soil borings and collection and analysis of 30 soil samples – Of the 30 soil samples, 21 soil samples (including two duplicates) were collected from the shallow subsurface (0 to 2 feet below surface cover) fill, one soil sample was collected from native soil, and 8 soil samples were collected from fill immediately above the refusal depth (e.g., top of rock) or the groundwater interface.

3. Installation of one permanent groundwater monitoring well and collection and analysis of three groundwater samples

4. Installation of seven soil vapor probes and collection and analysis of one sub-slab soil vapor samples, six soil vapor samples and one ambient air sample

Summary of Environmental Findings

1. Sidewalk elevations on site range from el 38.18 and el 21.66 (sloping from northeast to southwest – from Tenth Avenue and West 34th Street to Hudson Boulevard and West 33rd Street).

2. Historic fill material was observed immediately below the existing at-grade surface to depths of:

a. 8 feet bgs along the northeast portion of the site;

b. 9.5 to 10 feet bgs in the southeast portion of the site;

c. 10 feet bgs in the central portion of the site;

d. 10 to 10.5 feet bgs in the southwest portion of the site; and

e. 15.5 feet bgs along the northwest portion of the site.

In areas of the site with buildings containing cellar and sub-cellar levels, historic fill was observed immediately below existing slabs to depths of 0.8 to 2.8 feet below the slab. Fill material generally consisted of light to dark brown, fine to medium sand with trace gravel and silt, and varying quantities of glass, brick fragments, concrete, wood, slag, and coal ash. Dark staining was observed in boring EB-17 between 1 and 1.5 feet bgs (northwest portion of the site). Odors and elevated photoionization detector (PID) readings were not encountered in any of the borings.

3. A native sand layer consisting of brown fine sand with trace medium sand, gravel and silt was observed from 10 to 18 feet bgs in the eastern portion of the site (EB-7) and from 15 to 24 feet bgs in the northwestern portion of the site (EB-17).

4. Based on field observations and geotechnical borings completed by Mueser Rutledge Consulting Engineers (MRCE) during their October 2016 geotechnical investigation, bedrock was encountered beneath the fill material or native layers at:


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a. 7 to 10 feet bgs in the northeast portion of the site;

b. 6 to 15 feet bgs in the southeast portion of the site;

c. 17.6 feet bgs in the southwest portion of the site; and

d. 25.3 feet bgs in the northwest portion of the site.

Four borings were completed by MRCE in areas of the site with buildings containing cellar and sub-cellar levels. Bedrock was encountered at depths between 5 and 11 feet below the slab.

5. During the soil boring investigation, limited quantities of perched groundwater were encountered above the bedrock in the eastern portion of the site at 16 feet bgs (EB-7 [el 18.8]) and in the western portion of the site at 11.8 feet bgs (EB-17 [el 23.9]). During groundwater sampling activities on October 26, 2016, groundwater was encountered from 9.52 to 9.82 feet bgs (MR-5P [el 26.98] and MW-7 [el 25.06], respectively) in the eastern portion of the site and at 13.13 feet bgs (MR-16P [el 9.1]) in the western portion of the site. Regional groundwater is inferred to flow west toward the Hudson River, following the influence of local topography.

6. Fill soil sample results were compared to 6 NYCRR Part 375 Unrestricted Use and Restricted Commercial Use SCOs.

a. One VOC, trichloroethene ([TCE] maximum [max.] 12 milligrams per kilogram [mg/kg]) was detected in two samples and total xylenes (max. 0.27 mg/kg) was detected in one sample at concentrations above Unrestricted Use SCOs, but below their respective Restricted Commercial Use SCOs.

b. Ten SVOCs were reported at concentrations exceeding Unrestricted Use SCOs, including 3-methylphenol/4-methylphenol (max. 1.8 mg/kg), benzo(a)anthracene (max. 52 mg/kg), benzo(a)pyrene (max. 38 mg/kg), benzo(b)fluoranthene (max. 49 mg/kg), benzo(k)fluoranthene (max. 14 mg/kg), chrysene (max. 50 mg/kg), dibenzo(a,h)anthracene (max. 7 mg/kg), dibenzofuran (max. 10 mg/kg), indeno(1,2,3-cd)pyrene (max. 24 mg/kg), and naphthalene (max. 21 mg/kg). Of these SVOCs, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene, also exceeded Restricted Commercial Use SCOs.

c. Pesticides, including 4,4’-DDD (max. 0.0329 mg/kg), 4,4’-DDE (max. 0.0422 mg/kg), 4,4’-DDT (max. 0.0497 mg/kg), and dieldrin (max. 0.00779 mg/kg) were reported at concentrations exceeding Unrestricted Use SCOs, but below Restricted Commercial Use SCOs.

d. PCBs and herbicides were not detected at concentrations above Unrestricted Use SCOs.

e. Metals including barium (max. 1,100 mg/kg), copper (max. 460 mg/kg), lead (max. 2,400 mg/kg), and mercury (max. 730 mg/kg), were reported at concentrations exceeding Restricted Commercial Use SCOs. Trivalent chromium, silver and zinc exceeded their Unrestricted Use SCOs. Metals were analyzed for toxicity characteristic leaching


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procedure (TCLP) analysis during the preliminary waste characterization. Hazardous lead was identified in soil.

f. No compounds were detected in soil at concentrations above Part 375 SCOs in samples collected within native material (EB-7 from 12 to 14 feet bgs and from 14 to 16 feet bgs).

g. Generally, soil chemistry is similar to sites with historic fill in the City of New York.

7. VOCs, SVOCs, PCBs, and pesticides were not detected at concentrations exceeding NYSDEC Technical and Operational Guidance Series (TOGS) 1.1.1 Ambient Water Quality Standards and Guidance Values (SGV). The metals antimony, iron, magnesium, manganese, selenium and sodium were detected above Class GA SGVs in the unfiltered groundwater samples. However, only antimony (max. of 5.6 micrograms per liter [µg/L]), magnesium (max. of 76,200 µg/L), manganese (max. of 771.3 µg/L), selenium (max. of 15 µg/L) and sodium (max. of 644,000 µg/L) were detected above SGVs in filtered groundwater samples. These metals are considered representative of regional groundwater quality.

8. Soil vapor samples collected during the Remedial Investigation (RI) were compared to New York State Department of Health (NYSDOH) Final Guidance for Evaluating Soil Vapor Intrusion and Soil Vapor Intrusion Air Guidance Values (AGV) and Decision Matrices. Methylene chloride (max. of 5.18 micrograms per cubic meter [µg/m3]) was detected at concentrations below the NYSDOH AGV of 60 µg/m3. TCE was detected at a maximum concentration of 156 µg/m3 above the NYSDOH AGV of 2 µg/m3. Tetrachloroethene (PCE) was detected at a maximum concentration of 60.2 µg/m3 above the NYSDOH AGV of 30 µg/m3. Petroleum-related BTEX VOCs were detected at a maximum concentration of 460.6 µg/m3. Concentrations of chlorinated compounds, including PCE and TCE, require action ranging from monitoring to mitigation per the NYSDOH matrices.

Summary of the Remedial Action

The proposed remedial action is a Track 1 Unrestricted Use remedial action. The proposed remedial action achieves protection of public health and the environment for the intended use of the property. The proposed remedial action achieves all of the remedial action objectives established for the project; addresses applicable standards, criterion, and guidance; is effective in both the short-term and long-term; reduces mobility, toxicity and volume of contaminants; is cost effective and implementable; and uses standards methods that are well established in the industry.

The proposed remedial and development actions will consist of the list below.

1. Implementation of a Community Air Monitoring Program (CAMP) for particulates and VOCs

2. Selection of NYSDEC Part 375 Track 1 Unrestricted Use SCOs

3. Site mobilization involving security setup, equipment mobilization, utility mark outs and marking & staking excavation areas


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4. A Waste Characterization Study was completed at the site and soil samples were collected using a methodology compatible with general disposal facility requirements based on previous experience.

5. Implementation of soil erosion, pollution and sediment control measures in compliance with applicable laws and regulations

6. Excavation and removal of soil and fill exceeding Unrestricted Use (Track 1) SCOs - The proposed excavation will extend into bedrock. Existing buildings at the site will be demolished prior to implementation of the remedy. General excavation will extend to between 35 to 45 feet below sidewalk grade (into bedrock) to accommodate foundation components for the cellar and two sub-cellar levels. The general top of sub-cellar slab elevation is -4.5.

About 30,000 tons of soil will be excavated and removed from this site. Excavated material is anticipated to comprise historic fill material, native sand and bedrock. Based on field observations and geotechnical borings completed by MRCE during their October 2016 geotechnical investigation, bedrock was encountered beneath the fill material or native layers at:

7 to 10 feet bgs in the northeast portion of the site;

6 to 15 feet bgs in the southeast portion of the site;

17.6 feet bgs in the southwest portion of the site; and

25.3 feet bgs in the northwest portion of the site.

In areas of the site with buildings containing cellar and sub-cellar levels, bedrock was encountered at depths between 5 and 11 feet below the slab.

7. Excavation and removal of hazardous lead as identified in the December 9, 2016 Preliminary Waste Characterization Report - The hazardous lead will be further delineated prior to off-site disposal.

8. Screening of excavated soil/fill for indications of contamination by visual, olfactory and instrumental (i.e., monitoring with a PID) means - Excavated materials will be appropriately segregated on site to prevent comingling materials of different types and contamination.

9. Management of excavated materials including temporarily stockpiling and segregating in accordance with defined material types and to prevent co-mingling of contaminated material and non-contaminated materials

10. Removal of underground storage tanks (UST) (if present) and closure of petroleum spills in compliance with applicable local, state and federal laws and regulations

11. Transportation and off-site disposal of soil/fill material at permitted facilities in accordance with applicable laws and regulations for handling, transport, and disposal, and this plan

12. During the RI, limited quantities of perched groundwater were encountered between 9.52 and 16 feet bgs (corresponding to el 26.98 to el 18.8, respectively). Considering the excavation depth, limited or localized dewatering, if required, will be conducted in compliance with New York City


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Department of Environmental Protection (NYCDEP) permitting requirements, including any pretreatment required for discharge to the municipal sewer system.

13. Importation of materials to be used for backfill and cover in compliance with this plan and with applicable laws and regulations

14. Performance of all activities required for the remedial action, including acquisition of required permits, in compliance with applicable laws and regulations

15. As part of construction (not a remedial engineering control), a composite cover system will be

installed over any residual (existing) soil/fill remaining at the site following development

(excavation is anticipated to extend to bedrock). If any residual soil exceeds the SCOs, the cover

system would be considered an engineering control. The composite cover system will consist of:

a. A 12-inch concrete slab at the base of the elevator pits in the central portion of the second

sub-cellar level and along the southern perimeter of the site;

b. A 6-inch slab on grade throughout the second sub-cellar level;

c. A 12-inch slab beneath the tenant domestic water tanks in the central portion of the

second sub-cellar level; and

d. A 12-inch slab beneath the fuel oil storage tank pump rooms in the northeastern portion

of the second sub-cellar level.

16. As part of construction (not a remedial engineering control), a waterproofing/vapor barrier system

(with a minimum thickness of 20 mils) will be installed per manufacturer’s specifications beneath

the concrete building slab and along the subsurface walls.

17. Submission of a Remedial Action Report (RAR) that describes remedial activities, certifies remedial requirements were achieved, and lists any deviations from this RAWP, if applicable


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COMMUNITY PROTECTION STATEMENT The NYC Office of Environmental Remediation (NYCOER) provides governmental oversight for the cleanup of contaminated property in New York City (NYC). This Remedial Action Work Plan (“cleanup plan”) describes the findings of prior environmental studies, shows the location of identified contamination at the site, and describes the plans to clean up the site to protect public health and the environment.

This cleanup plan provides protection for neighboring communities and also includes many other elements that address common community concerns, such as community air monitoring, odor, dust and noise controls, hours of operation, good housekeeping and cleanliness, truck management and routing, and opportunities for community participation. The purpose of this Community Protection Statement is to explain these community protection measures in non-technical language to simplify community review.

Project Information:

Site Name: 50 Hudson Yards

Site Address: 413 Tenth Avenue, 427 Tenth Avenue, 503 West 33rd Street, 507 West 33rd Street, 504-514 West 34th Street and 516-520 West 34th Street

NYCOER Project Number: 17TMP0019M

Project Contacts:

NYCOER Project Manager: Taylor Hard, 212-788-7426

Langan Site Project Manager: Joseph Good, 212-479-5448

Langan Site Safety Officer: William Bohrer, 212-479-5533

Remedial Investigation and Cleanup Plan: Under the oversight of the NYCOER, a study of this property (called a remedial investigation) has been performed to identify past property usage, to sample and test soils, groundwater and soil vapor, and to identify contaminant sources present on the property. The cleanup plan has been designed to address all contaminant sources that have been identified during the study of this property.

Identification of Sensitive Land Uses: Prior to selecting a cleanup, the neighborhood was evaluated to identify sensitive land uses nearby, such as schools, day care facilities, hospitals and residential areas. The cleanup program was then tailored to address the special conditions of this community.

Health and Safety Plan: This cleanup plan includes a Construction Health and Safety Plan (CHASP) that is designed to protect community residents and on-site workers. The elements of this Remedial Action Work Plan (RAWP) are in compliance with applicable safety requirements of the United States Occupational Safety and Health Administration (OSHA). This RAWP includes protective elements including those discussed below.


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Site Safety Coordinator: This project has a designated site safety coordinator to document CHASP implementation. The safety coordinator maintains an emergency contact sheet and protocol for management of emergencies. The site safety coordinator is identified at the beginning of this Community Protection Statement.

Worker Training: Workers participating in cleanup of hazardous waste on this project are required to be trained in a 40-hour hazardous waste operators training course and to take annual refresher training. This pertains to workers performing specific tasks including removing hazardous waste and installing related cleanup systems in hazardous waste areas.

Community Air Monitoring Plan: Community air monitoring will be performed during this cleanup project to protect the community from contaminants, dust and odors. Air samples will be tested in accordance with a detailed plan called the Community Air Monitoring Plan or CAMP. Results will be regularly reported to the NYCOER. This cleanup plan also has a plan to address any unforeseen problems that might occur during the cleanup (called a ‘Contingency Plan’).

Odor, Dust and Noise Control: This cleanup plan includes actions for odor and dust control. These actions are designed to prevent off-site odor and dust nuisances and includes steps to be taken if nuisances are detected. Generally, dust is managed by application of physical covers and by water sprays. Odors are controlled by limiting the area of open excavations, physical covers, spray foams and by a series of other actions (called operational measures). The project is also required to comply with applicable NYC noise control standards. If you observe problems in these areas, please contact the on-site Project Manager or NYCOER Project Manager listed on the first page of this Community Protection Statement document.

Quality Assurance: This cleanup plan requires that evidence be provided to illustrate that all cleanup work required under the plan has been completed properly. This evidence will be summarized in the final report, called the Remedial Action Report. This report will be submitted to the NYCOER and will be reviewed.

Stormwater Management: To limit the potential for soil erosion and discharge, this cleanup plan has provisions for stormwater management. The main elements of the stormwater management include physical barriers such as tarp covers and erosion fencing, and a program for frequent inspection.

Hours of Operation: The hours for operation of cleanup will comply with the NYC Department of Buildings (NYCDOB) construction code requirements or according to specific variances issued by that agency. For this cleanup project, the hours of operation will conform to requirements of the NYC Department of Buildings.

Complaint Management: The contractor performing this cleanup is required to address all complaints. If you have any complaints, you can call the facility Project Manager or the NYCOER Project Manager listed on the first page of this Community Protection Statement document, or call 311.

Utility Mark-outs: To promote safety during excavation in this cleanup, the contractor is required to first identify all utilities and must perform all excavation and construction work in compliance with NYCDOB regulations.


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Soil and Liquid Disposal: All soil and liquid material removed from the site as part of the cleanup will be transported and disposed of in accordance with all applicable City, State and Federal regulations, and required permits will be obtained.

Soil Chemical Testing and Screening: All excavations will be documented by a field engineer, geologist, or scientist under the direct oversight of a Professional Engineer or Qualified Environmental Professional. In addition to extensive sampling and chemical testing of soils on the site, excavated soil will be screened continuously using hand-held instruments, by sight, and by smell to ensure proper material handling and management, and community protection.

Stockpile Management: When not in use, soil stockpiles will be kept covered with tarps to prevent dust, odor and erosion. Stockpiles will be frequently inspected. Damaged tarp covers will be promptly replaced. Stockpiles will be protected with silt fences, as required. Hay bales will be used, as needed, to protect storm water catch basins and other discharge points.

Trucks and Covers: Loaded trucks leaving the site will be covered in compliance with applicable laws and regulations to prevent dust and odor. Trucks will be properly recorded in logs and records and placarded in compliance with applicable City, State and Federal laws, including those of the New York State Department of Transportation. If loads contain wet material that can leak, truck liners will be used. All transport of materials will be performed by licensed truckers and in compliance with applicable laws and regulations.

Imported Material: All fill materials proposed to be brought onto the site will comply with rules outlined in this cleanup plan and will be inspected and approved by a qualified worker located on the site. Waste materials will not be brought onto the site. Trucks entering the site with imported clean materials will be covered in compliance with applicable laws and regulations.

Equipment Decontamination: All equipment used for cleanup work will be inspected and washed, if needed, before it leaves the site. Trucks will be cleaned at a truck inspection station on the property before leaving the site.

Housekeeping: Locations where trucks enter or leave the site will be inspected every day and cleaned regularly to ensure that they are free of dirt and other materials from the site.

Truck Routing: Truck routes have been selected to: (a) limit transport through residential areas and past sensitive nearby properties; (b) maximize use of city-mapped truck routes; (c) limit total distance to major highways; (d) promote safety in entry to highways; (e) promote overall safety in trucking; and (f) minimize off-site line-ups (queuing) of trucks entering the property. Operators of loaded trucks leaving the site will be instructed to minimize to the extent possible stopping or idling in the local neighborhood.

Final Report: The results of all cleanup work will be fully documented in a final report (called the Remedial Action Report) that will be available for public review online. A link to the online document repository and the public library with Internet access nearest the site are listed on the first page of this Community Protection Statement document.

Long-Term Site Management: If long-term protection is needed after the cleanup is complete, the property owner will be required to comply with an ongoing Site Management Plan (SMP) that calls for


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continued inspection of protective controls, such as site covers. The SMP is evaluated and approved by NYCOER. Requirements that the property owner must comply with are defined either in the property’s deed or established through a city environmental designation registered with the NYCDOB. A certification of continued protectiveness of the cleanup will be required from time to time to show that the approved cleanup is still effective. The remedial action described in this document will achieve the remedial objectives; comply with applicable environmental standards, criteria and guidance; and conform to applicable laws and regulations.


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REMEDIAL ACTION WORK PLAN

1.0 SITE BACKGROUND

This Remedial Action Work Plan (RAWP) and site-specific Construction Health and Safety Plan (CHASP) have been developed on behalf of 50 HYMC OWNER LLC for the proposed development located at 50 Hudson Yards (alternately 413 Tenth Avenue, 427 Tenth Avenue, 503 West 33rd Street, 507 West 33rd Street, 504-514 West 34th Street and 516-520 West 34th Street) in the Midtown/ Hudson Yards neighborhood of Manhattan, New York (the site). The site was assigned an E-Designation (E-137) for hazardous materials (Hazmat) and noise (window wall attenuation and alternate means of ventilation) by the New York City Department of City Planning (NYCDCP) following the Hudson Yards Rezoning (CEQR #03DCP031M) and requires coordination with the New York City Office of Environmental Remediation (NYCOER).

The RAWP describes remedial activities to be implemented during construction to satisfy the requirements of the Hazmat E-Designation Program and obtain a Notice of Satisfaction. The CHASP addresses site-specific contaminant hazards, contaminants of concern (COC) and safety requirements associated with remediation and mitigation activities in accordance with American Society of Testing and Materials (ASTM) and Occupation Safety and Health Administration (OSHA) guidelines.

1.1 Site Location and Current Usage

The site is located at 50 Hudson Yards (alternately 413 Tenth Avenue, 427 Tenth Avenue, 503 West 33rd Street, 507 West 33rd Street, 504-514 West 34th Street and 516-520 West 34th Street) in the Midtown/ Hudson Yards neighborhood of Manhattan, New York and is identified as Block 705 and Lots 29, 30, 32, 39, 45, 46 and 50 on the Borough of Manhattan Tax Map. The site is 71,203 square feet and is bound by West 34th Street to the north, Tenth Avenue to the east, West 33rd Street to the south, and Hudson Boulevard to the west. A Site Location Map is included as Figure 1 and a Site Plan is included as Figure 2. The site is improved with seven multi-story buildings and associated parking areas. Additional details by lot are as follows:

• Lot 29 is 7,900 square feet and is improved with a five-story building.

• Lot 30 is 4,938 square feet and is improved with a three-story building.

• Lot 32 is 1,856 square feet and is improved with a four-story mixed commercial and residential building with a full basement.

• Lot 39 is 15,919 square feet and is improved with an asphalt parking lot and two-story former fast food restaurant with partial basement.

• Lot 45 is 9,875 square feet and is improved with one two-story building with a full basement level.


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• Lot 46 is 28,637 square feet and is improved with two buildings (one two-story and one 12-story) with an adjoining parking lot to the northwest. The 12-story building on Lot 46 includes a full basement level and a partial sub-basement level.

• Lot 50 is 2,078 square feet and is undeveloped.

1.2 Proposed Redevelopment Plan

The proposed development project consists of the construction of a new 12-story commercial tower with a cellar and two sub-cellar levels. The superstructure design may be revised at a later date to accommodate a taller building; however, the extent of subgrade structures is not anticipated to change significantly. Sidewalk elevations range from elevation (el) 38.182 and el 21.66 (sloping from northeast to southwest - from Tenth Avenue and West 34th Street to Hudson Boulevard and West 33rd Street). The site will be excavated into bedrock to accommodate foundation components and the cellar and two sub-cellar levels with a general top of slab at el -4.5. General excavation will be completed to 35 to 45 feet below grade surface (bgs). The current zoning designation is C6-4, which permits a wide range of high-bulk commercial uses. The proposed use is consistent with existing zoning for the property.

The cellar and two sub-cellar levels will cover the majority of the site, with the exception of Lot 50 located in the western portion of the site. The cellar level will contain bicycle storage, tenant storage areas, a central elevator bank, tenant break rooms, locker rooms, security storage room, and mechanical, telecommunication, storm water tank, fuel oil control and electrical rooms. The first sub-cellar level will contain commercial amenities, a loading dock, delivery storage, mechanical rooms, refuse rooms, water service and fire pump room, mail room storage, and electrical and mechanical rooms. Two subway connection tunnels are planned for the southwest portions of the first sub-cellar level beneath Hudson Boulevard and West 33rd Street. The second sub-cellar level will storage rooms, parking, a below-grade loading dock, a water tank room, service elevator lobbies, and a fuel oil storage room.

The first floor will contain retail areas, central elevator banks, entrance lobbies, a car drop-off port, a truck elevator, and a bike ramp. The second floor will include areas open to the first floor lobbies, retail spaces, offices, and commercial tenant amenities. Floors 3 through 5 will contain commercial office space and tenant amenities. The sixth floor will contain a central and outside air plant, engineering, electrical, exhaust, and control rooms. Floors 7 through 12 will contain offices and tenant amenities. Mechanical areas will be located on the roof. Development plans are provided in Appendix A.

2 Elevations are in North American Vertical Datum of 1988 (NAVD88).


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1.3 Description of Surrounding Property

The site is located in an urban area characterized by multi-story mixed-use, residential, commercial, institutional, parking and transportation/utility buildings. The following table summarizes the adjoining and surrounding land usage:

Direction Adjoining Properties

Surrounding Properties Block No.

Lot No. Description

North

706

17 Vacant Lot

West 34th Street followed by vacant lots, parking lots, multi-story commercial

and mixed-use buildings

(509 West 34th Street)

20 4-story Commercial Building


29 Parking Lot

(435 Tenth Avenue)

South 702

7501

Hudson Yards Eastern Rail Yard Redevelopment (multi-

story commercial-use construction)

Multi-story commercial and residential buildings, Hudson Yards Eastern Rail Yard

Redevelopment

(500 West 33rd Street)

175

Hudson Yards Eastern Rail Yard Redevelopment (multi-

story commercial-use construction)

(530 West 33rd Street)

East 731 1 18-story commercial building Multi-story commercial and residential

buildings, transportation/ utilities, institutions (460 West 34th Street)

West 705 53

Hudson Park and Boulevard and 7-Line Hudson Yards

Station Construction sites, Jacob K. Javits Center


Sensitive receptors (e.g., schools, hospitals, day care facilities) located within a 500-foot radius of the site are listed in the following table:

Number Name

(Approximate distance from the site) Address

1 Metropolitan Community Church

(500 feet northwest) 466 West 36th Street


2 City Knoll Middle School

(500 feet east) 425 West 33rd Street


3 Harlem Village Academy

(500 feet southeast) 450 West 33rd Street



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Land uses for the surrounding area and the location of sensitive receptors within 500 feet of the site are shown on Figure 3.

1.4 Summary of Past Site Uses and Areas of Concern

A review of previous reports, available historical Sanborn fire insurance maps, topographic maps, and aerial photographs revealed that the site was developed with several multi-story buildings as early as 1890. Historic site use included a leather factory, engraving supply shop, paper bailing, lard oil refinery, coal yard, glass company, cutting company, metal and manufacturing company, auto parts company, chemist facility, elevator company and a furniture finishing and assembly warehouse.

The identified Areas of Concern (AOC) are described below.

AOC 1 – Documented Contaminated Historic Fill Material

Previous reports document the presence of historic fill at the site, and laboratory analyses of soil samples collected from the historical fill material confirmed the presence of semivolatile organic compounds (SVOC) and metals at concentrations above 6 New York Codes Rules and Regulations (NYCRR) Part 375 Unrestricted Use Soil Cleanup Objectives (SCO).

AOC 2 – Historical Site Use

Historical site use included a leather factory, engraving supply shop, paper bailing, lard oil refinery, coal yard, glass company, cutting company, metal and manufacturing company, auto parts company, chemist facility, elevator company and a furniture finishing and assembly warehouse. Potential contaminants, including solvents, petroleum products, SVOCs, metals and polychlorinated biphenyls (PCB) were likely used during historical site operations. Spills or leaks of these contaminants may have impacted the subsurface soil, soil vapor and groundwater.

AOC 3 – Petroleum Bulk Storage on Site

Historical fuel oil and gasoline storage was reported on site Lots 29, 30, 39, 45 and 46. A Certificate of Occupancy (CO) dated October 15, 1947 identified a gasoline tank as approved for installation by the New York Fire Department (NYFD) in Lot 30. COs dated January 14, 1948 and August 7, 1951 indicate NYFD approval of fuel oil installation in Lots 29 and 39. One 10,000-gallon #6 fuel oil tank was observed in a vault beneath the 33rd Street sidewalk along Lot 46. One 1,080-gallon #2 fuel tank was observed in the Lot 45 building basement. The 1,080-gallon tank is encased in concrete, with the exception of a portion of the top that is chipped away. One 1,000-gallon tank was observed in the basement of Lot 29.

AOC 4 – Historic Use at Adjoining Properties

524 West 36th Street, which is located approximately 350 feet north (cross-gradient) of the site, includes a ten-year history of gasoline tank overfills. Groundwater monitoring is on-going at the property, and groundwater contamination was observed to be present within the bedrock zone. The former BP Service Station, located across Tenth Avenue to the northeast of the site, contains multiple Leaking Underground Storage Tanks (LTANKS) and NY Spills listings. Elevated petroleum-related volatile organic


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compounds (VOC) (e.g., benzene, toluene, ethylbenzene, and total xylenes [BTEX]) and methyl tert butyl ether (MTBE) were detected in groundwater. Light non-aqueous phase liquid (LNAPL) was detected in one of the wells at the property. A stipulation list to conduct cleanup and removal of petroleum discharges in reference to the spill was signed and returned to New York State Department of Environmental Conservation (NYSDEC) on August 23, 2004. Site-wide remedial excavations and groundwater remediation were conducted between 2006 and 2008 as part of redevelopment of the property. Remediation of the groundwater within the underlying bedrock was completed to the extent feasible in 2013 and the spill was closed. During redevelopment of 440 Tenth Avenue (immediately north of the former BP Service Station), a new spill (NYSDEC Spill No. 1309801) was reported due to elevated VOC soil vapor concentrations. The property at 509 West 34th Street, which adjoins the site to the north, is listed in the Brownfield Cleanup Program (BCP) program as Site No. C231094.

1.5 Summary of Remedial Investigation Field Work

The Remedial Investigation (RI) was performed between October 17 and 26, 2016 to supplement previous environmental data obtained from previous investigations and to satisfy the E-Designation for Hazardous Materials (E-137) assigned to the site as a result of the City Environmental Quality Review (CEQR #03DCP031M). The RI included:

1. A Geophysical Survey

2. Advancement of 16 soil borings and collection and analysis of 30 soil samples – Of the 30 soil samples, 21 soil samples (including two duplicates) were collected from the shallow subsurface (0 to 2 feet below surface cover) fill, one soil sample was collected from native soil, and 8 soil samples were collected from fill immediately above the refusal depth (e.g., top of rock) or the groundwater interface

3. Installation of one permanent groundwater monitoring well and collection and analysis of three groundwater samples

4. Installation of seven soil vapor probes and collection and analysis of one sub-slab soil vapor samples, six soil vapor samples and one ambient air sample

1.6 Summary of Environmental Findings

A remedial investigation was performed and the results are documented in the December 9, 2016 Remedial Investigation Report (RIR). Environmental findings include the following:

1. Sidewalk elevations on site range from el 38.18 and el 21.66 (sloping from northeast to southwest – from Tenth Avenue and West 34th Street to Hudson Boulevard and West 33rd Street).

2. Historic fill material was observed immediately below the existing at-grade surface to depths of:





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In areas of the site with buildings containing cellar and sub-cellar levels, historic fill was observed immediately below existing slabs to depths of 0.8 to 2.8 feet below the slab. Fill material generally consisted of light to dark brown, fine to medium sand with trace gravel and silt, and varying quantities of glass, brick fragments, concrete, wood, slag, and coal ash. Dark staining was observed in boring EB-17 between 1 and 1.5 feet bgs (northwest portion of the site). Odors and elevated photoionization detector (PID) readings were not encountered in any of the borings.

3. A native sand layer consisting of brown fine sand with trace medium sand, gravel and silt was observed from 10 to 18 feet bgs in the eastern portion of the site (EB-7) and from 15 to 24 feet bgs in the northwestern portion of the site (EB-17).

4. Based on field observations and geotechnical borings completed by Mueser Rutledge Consulting Engineers (MRCE) during their October 2016 geotechnical investigation, bedrock was encountered beneath the fill material or native layers at:

a. 7 to 10 feet bgs in the northeast portion of the site;

b. 6 to 15 feet bgs in the southeast portion of the site;

c. 17.6 feet bgs in the southwest portion of the site; and

d. 25.3 feet bgs in the northwest portion of the site.

Four borings were completed by MRCE in areas of the site with buildings containing cellar and sub-cellar levels. Bedrock was encountered at depths between 5 and 11 feet below the slab.

5. During the soil boring investigation, limited quantities of perched groundwater were encountered above the bedrock in the eastern portion of the site at 16 feet bgs (EB-7 [el 18.8]) and in the western portion of the site at 11.8 feet bgs (EB-17 [el 23.9]). During groundwater sampling activities on October 26, 2016, groundwater was encountered from 9.52 to 9.82 feet bgs (MR-5P [el 26.98] and MW-7 [el 25.06], respectively) in the eastern portion of the site and at 13.13 feet bgs (MR-16P [el 9.1]) in the western portion of the site. Regional groundwater is inferred to flow west toward the Hudson River, following the influence of local topography.

6. Fill soil sample results were compared to 6 NYCRR Part 375 Unrestricted Use and Restricted Commercial Use SCOs.

a. One VOC, trichloroethene ([TCE] maximum [max.] 12 milligrams per kilogram [mg/kg]) was detected in two samples and total xylenes (max. 0.27 mg/kg) was detected in one sample at concentrations above Unrestricted Use SCOs, but below their respective Restricted Commercial Use SCOs.

b. Ten SVOCs were reported at concentrations exceeding Unrestricted Use SCOs, including 3-methylphenol/4-methylphenol (max. 1.8 mg/kg), benzo(a)anthracene (max. 52 mg/kg),


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benzo(a)pyrene (max. 38 mg/kg), benzo(b)fluoranthene (max. 49 mg/kg), benzo(k)fluoranthene (max. 14 mg/kg), chrysene (max. 50 mg/kg), dibenzo(a,h)anthracene (max. 7 mg/kg), dibenzofuran (max. 10 mg/kg), indeno(1,2,3-cd)pyrene (max. 24 mg/kg), and naphthalene (max. 21 mg/kg). Of these SVOCs, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene also exceeded Restricted Commercial Use SCOs.

c. Pesticides, including 4,4’-DDD (max. 0.0329 mg/kg), 4,4’-DDE (max. 0.0422 mg/kg), 4,4’-DDT (max. 0.0497 mg/kg), and dieldrin (max. 0.00779 mg/kg) were reported at concentrations exceeding Unrestricted Use SCOs, but below Restricted Commercial Use SCOs.

d. PCBs and herbicides were not detected at concentrations above Unrestricted Use SCOs.

e. Metals including barium (max. 1,100 mg/kg), copper (max. 460 mg/kg), lead (max. 2,400 mg/kg), and mercury (max. 730 mg/kg), were reported at concentrations exceeding Restricted Commercial Use SCOs. Trivalent chromium, silver and zinc also exceeded their Unrestricted Use SCOs. Metals were analyzed for toxicity characteristic leaching procedure (TCLP) analysis during the preliminary waste characterization. Hazardous lead was identified in soil.

f. No compounds were detected in soil at concentrations above Part 375 SCOs in samples collected within native material (EB-7 from 12 to 14 feet bgs and from 14 to 16 feet bgs).

g. Generally, soil chemistry is similar to sites with historic fill in the City of New York.

7. VOCs, SVOCs, PCBs, and pesticides were not detected at concentrations exceeding NYSDEC Technical and Operational Guidance Series (TOGS) 1.1.1 Ambient Water Quality Standards and Guidance Values (SGV). The metals antimony, iron, magnesium, manganese, selenium and sodium were detected above Class GA SGVs in the unfiltered groundwater samples. However, only antimony (max. of 5.6 micrograms per liter [µg/L]), magnesium (max. of 76,200 µg/L), manganese (max. of 771.3 µg/L), selenium (max. of 15 µg/L) and sodium (max. of 644,000 µg/L) were detected above SGVs in filtered groundwater samples. These metals are considered representative of regional groundwater quality.

8. Soil vapor samples collected during the Remedial Investigation (RI) were compared to New York State Department of Health (NYSDOH) Final Guidance for Evaluating Soil Vapor Intrusion and Soil Vapor Intrusion Air Guidance Values (AGV) and Decision Matrices. Methylene chloride (max. of 5.18 micrograms per cubic meter [µg/m3]) was detected at concentrations below the NYSDOH AGV of 60 µg/m3. TCE was detected at a maximum concentration of 156 µg/m3 above the NYSDOH AGV of 2 µg/m3. Tetrachloroethene (PCE) was detected at a maximum concentration of 60.2 µg/m3 above the NYSDOH AGV of 30 µg/m3. Petroleum-related BTEX VOCs were detected at a maximum concentration of 460.6 µg/m3. Concentrations of chlorinated compounds, including PCE and TCE, require action ranging from monitoring to mitigation per the NYSDOH matrices.


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2.0 DESCRIPTION OF REMEDIATION

The following sections describe the: 1) remediation goals for soil, groundwater, and soil vapor; 2) remedial action sufficient to achieve these goals; 3) appropriate handling and management of soil and groundwater; and 4) documentation of the quality of soil expected to remain on site.

2.1 Remedial Objectives

The following remediation and mitigation objectives have been established for the site:

Soil

Prevent direct contact with contaminated soil

Prevent migration of contaminants that would result in groundwater or surface water contamination

Prevent inhalation of or exposure to contaminants volatilizing from the soil

Groundwater

Prevent direct contact or exposure to groundwater

Soil Vapor

Minimize exposure to contaminants in soil vapor

Minimize soil vapor intrusion into future occupied structures

Remedial and mitigation measures described herein will be performed by the contractor in accordance with applicable laws and regulations and the CHASP. The remedy is protective of public health and the environment for the intended site use.


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3.0 REMEDIAL TRACK ANALYSIS

3.1 Summary of Proposed Remedial Action

The goal of the remedy selection process is to select a remedy that is protective of human health and the environment taking into consideration the current, intended and reasonably anticipated future use of the property. The remedy selection process begins by establishing remedial action objectives (RAO) for media in which chemical constituents were found in exceedance of applicable standards, criteria and guidance values (SCGs). A remedy is then developed based on the following ten criteria:

1. Protection of human health and the environment;

2. Compliance with SCGs;

3. Short-term effectiveness and impacts;

4. Long-term effectiveness and permanence;

5. Reduction of toxicity, mobility, or volume of contaminated material;

6. Implementability;

7. Cost effectiveness;

8. Community Acceptance;

9. Land use; and

10. Sustainability.

The following is a detailed description of the remedy analysis and selection to address impacted media at the site. The Track 1 Unrestricted Use cleanup scenario is evaluated below.

The Track 1 remedy includes the following items.

Selection of NYSDEC 6 NYCRR Part 375 Unrestricted Use (Track 1) SCOs

Removal of all soil/fill exceeding Track 1 SCOs throughout the site. The site will be excavated into bedrock to accommodate foundation components and the cellar and two sub-cellar levels with a general top of slab at el -4.5. General excavation will be completed to 35 to 45 feet below grade surface (bgs). No remaining soil is anticipated following the remedial excavation, and endpoint samples will not be collected.

No Engineering Controls/Institutional Controls (EC/IC) are allowed for a Track 1 cleanup. Although not considered engineering controls, an impervious site cap and a waterproofing membrane/vapor barrier will be installed throughout the footprint of the site. The site cap consists on concrete slabs, sidewalks and foundation. The waterproofing membrane/vapor barrier will extend beneath the basement foundation and behind foundation sidewalls of the new building as a part of development.


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3.2 Threshold Criteria

Protection of Public Health and the Environment

This criterion is an evaluation of the remedy’s ability to protect public health and the environment, and an assessment of how risks posed through each existing or potential pathway of exposure are eliminated, reduced or controlled through removal, treatment, and implementation of ECs/ICs. Protection of public health and the environment must be achieved for all approved remedial actions.

The Track 1 remedy would be protective of human health and the environment by removing contaminated soil and fill exceeding Track 1 Unrestricted Use SCOs to bedrock, thus eliminating potential for direct contact with contaminated soil/fill once construction is complete and eliminating the risk of contaminant leaching into groundwater. The construction measure to excavate existing overburden material to the bedrock surface and install a waterproofing/ vapor barrier membrane would mitigate potential future risk from soil vapor intrusion. Additionally, the groundwater table is within bedrock, which limits the potential for vapor intrusion into the new building.

For the Track 1 remedy, potential exposure to contaminated soil during construction would be minimized by implementing a CHASP, Soil/Materials Management Plan (SMMP) and Community Air Monitoring Plan (CAMP). Potential contact with contaminated groundwater would be prevented as limited quantities of perched groundwater were encountered above the bedrock and its use is prohibited by city laws and regulations. Potential future migration of soil vapor into the new building would be prevented by installing a waterproofing membrane/vapor barrier beneath the building’s basement slab and continuing the vapor barrier around foundation walls. The CHASP is provided as Appendix D.

3.3 Balancing Criteria

Compliance with SCGs

This evaluation criterion assesses the ability of the alternative to achieve applicable standards, criteria and guidance.

The Track 1 remedy would achieve compliance with the remedial goals, chemical-specific SCGs and RAOs for soil through removal of soil to achieve Track 1 SCOs and Protection of Groundwater SCOs. As part of construction (not a remedial engineering control), a waterproofing/vapor barrier system (with a minimum thickness of 20 mils) will be installed per manufacturer’s specifications beneath the concrete building slab and along the subsurface walls.

Health and safety measures contained in the CHASP and CAMP that comply with the applicable SCGs shall be implemented during site redevelopment under this RAWP. For the Track 1 remedy, attention on means and methods employed during the remedial action would ensure that handling and management of contaminated material would be in compliance with the SMMP and RAWP. These measures are designed to protect on-site workers and the surrounding community from exposure to site-related contaminants.


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Short-term effectiveness and impacts

This evaluation criterion assesses the effects of the Track 1 remedy during the construction and implementation phase until remedial action objectives are met. Under this criterion, the Track 1 remedy is evaluated with respect to its effects on public health and the environment during implementation of the remedial action, including protection of the community, environmental impacts, time until remedial response objectives are achieved, and protection of workers during remedial actions.

The Track 1 remedy requires excavation of fill and native material to the top of the bedrock surface. The most significant short-term adverse impacts and risks to the community, beyond standard construction practices, would be the potential complications involved with excavation of contaminated soil/ fill overburden material to bedrock. The Track 1 remedy would result in short-term dust generation impacts associated with excavation, handling, load out of materials, and truck traffic. Truck traffic will be routed on the most direct course using major thoroughfares where possible and flaggers will be used to protect pedestrians at site entrances and exits. Focused attention to means and methods during the remedial action during the removal action and support of excavation, including community air monitoring and appropriate truck routing, would minimize or negate the overall impact of these activities.

The Track 1 remedy would employ appropriate measures to prevent short term impacts, including a CAMP and an SMMP, during all on-site soil disturbance activities and would minimize the release of contaminants into the environment. The Track 1 remedy provides short-term effectiveness in protecting the surrounding community by decreasing the risk of contact with on-site contaminants. Construction workers operating under appropriate management procedures and a CHASP would be protected from on-site contaminants (personal protective equipment would be worn consistent with the documented risks within the respective work zones).

Long-term effectiveness and permanence

This evaluation criterion addresses the results of a remedial action in terms of its permanence and quantity/nature of waste or residual contamination remaining at the site after response objectives have been met, such as:

Permanence of the Track 1 remedy;

Magnitude of remaining contamination; and

Adequacy of controls including: 1) the adequacy and suitability of ECs/ICs that may be used to manage contaminants; 2) assessment of containment systems and ICs that are designed to eliminate exposures to contaminants; and 3) long-term reliability of ECs.

The Track 1 remedy would achieve long-term effectiveness and permanence related to on-site contamination by permanently removing all impacted soil/fill above Track 1 Unrestricted Use SCOs. Removal of on-site contaminant sources will prevent groundwater contamination. Installation of a waterproofing/vapor barrier membrane and site-wide composite cover as a construction measure and excavation of existing overburden material to the bedrock surface would prevent potential future migration of soil vapors into the new building.


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The Track 1 remedy would result in removal of soil contamination exceeding their respective SCOs, which provides an effective and permanent remedy over the long-term with respect to a remedy for contaminated soil, which will prevent any migration to groundwater. Therefore, the long-term effectiveness of this remedy will eliminate risks and satisfy the objectives of this criterion.

Reduction of toxicity, mobility, or volume of contaminated material

This evaluation criterion assesses the Track 1 remedy’s use of remedial technologies that permanently and significantly reduce toxicity, mobility, or volume of contaminants. The following is the hierarchy of source removal and control measures that are to be used to remediate a site, ranked from most preferable to least preferable: removal and/or treatment, containment, elimination of exposure and treatment of source at the point of exposure. It is preferred to use treatment or removal to eliminate contaminants at a site, reduce the total mass of toxic contaminants, cause irreversible reduction in contaminants mobility, or reduce of total volume of contaminated media.

The Track 1 remedy provides the maximum reduction of toxicity, mobility, and volume of contaminated material through the removal of soil/fill exceeding Track 1 Unrestricted Use SCOs to bedrock.

Implementability

This evaluation criterion addresses the technical and administrative feasibility of implementing the Track 1 remedy and the availability of various services and materials required during its implementation. This includes the technical feasibility of construction and operation, reliability of the selected technology, ease of undertaking remedial action, monitoring considerations, administrative feasibility (e.g. obtaining permits for remedial activities), and availability of services and materials.

The techniques, materials and equipment to implement the Track 1 remedy are readily available and have been proven effective in remediating the contaminants associated with the site. They use standard materials and services that are well established technology. The reliability of the Track 1 remedy is high. There are no special difficulties associated with the activities proposed.

Cost effectiveness

This evaluation criterion addresses the cost of the Track 1 remedy, including capital costs (e.g., labor, equipment, disposal, engineering) and site management costs (costs incurred after remedial construction is complete) necessary to ensure the continued effectiveness of a remedial action.

The remedial plan creates a cost-effective approach in that it combines the Track 1 remedial action with the redevelopment of the site, including the construction of the building foundation and subgrade structures. The remedial plan is also cost effective in that it will take into consideration the selection of the closest and most appropriate disposal facilities to reduce transportation and disposal costs during the excavation of historic fill and other soils during the redevelopment of the site.

Community Acceptance


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This evaluation criterion addresses community opinion and support for the Track 1 remedial action. Observations here will be supplemented by public comment received on the RAWP.

Based on the overall goals of the remedial program, and initial permitting associated with the proposed site development, no adverse community opinion is anticipated for the Track 1 remedy. This RAWP will be subject to a public review under the Volunteer Cleanup Program (VCP) and will provide the opportunity for detailed public input on the remedial alternatives and the selected remedy. This public comment will be considered by NYCOER prior to approval of this plan. The Citizen Participation Plan for the project is provided in Appendix E. Observations here will be supplemented by public comment received on the RAWP.

Land use

This evaluation criterion addresses the proposed use of the property. This evaluation has considered reasonably anticipated future uses of the site and takes into account: 1) current use and historical and/or recent development patterns; 2) applicable zoning laws and maps; 3) NYS Department of State’s Brownfield Opportunity Areas (BOA) pursuant to section 970-r of the general municipal law; 4) applicable land use plans; 5) proximity to real property currently used for residential use, and to commercial, industrial, agricultural, and/or recreational areas; 6) environmental justice impacts and federal or state land use designations; 7) population growth patterns and projections; 8) accessibility to existing infrastructure; 9) proximity of the site to important cultural resources and natural resources; 10) potential vulnerability of groundwater to contamination that might emanate from the site; 11) proximity to flood plains, geography and geology; and 12) current ICs applicable to the site (if any).

The current, intended, and reasonably anticipated future land use of the site and its surroundings are compatible with the selected remedy of soil remediation. The proposed future use of the site includes a 12-story commercial building with a cellar and two sub-cellar levels. The superstructure design may be revised at a later date to accommodate a taller building; however, the extent of subgrade structures is not anticipated to change significantly. Following remediation, the site will meet Track 1 Unrestricted Use SCOs, which is appropriate for its planned commercial use. The reasonably anticipated future use of the site and its surroundings will be documented by the applicant in the VCP application.

Sustainability of the Remedial Action

This criterion evaluates the overall sustainability of the Track 1 remedy and the degree to which sustainable means are employed to implement the remedial action, including those that take into consideration NYC’s sustainability goals defined in OneNYC. Sustainability goals may include: maximizing the recycling and reuse of non-virgin materials; reducing the consumption of virgin and non-renewable resources; minimizing energy consumption and greenhouse gas emissions; improving energy efficiency; and promotion of the use of native vegetation and enhancing biodiversity during landscaping associated with site development.

The Track 1 remedy is comparable with respect to the opportunity to achieve sustainable remedial action. The remedial plan will take into consideration the shortest trucking routes during off-site disposal of historic fill and other soils, which will reduce greenhouse gas emissions and conserve energy used to fuel


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trucks. The NYC Clean Soil Bank program may be utilized for reuse of native soils. To the extent practicable, energy efficient building materials, appliances, and equipment will be utilized to complete the development. A complete list of green remedial activities considered as part of the VCP is included in the Sustainability Statement, included as Appendix F.


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4.0 REMEDIAL ACTION

4.1 Summary of Proposed Remedial Action

The proposed remedial action alternative is the Track 1 remedial action. The proposed remedial action achieves protection of public health and the environment for the intended use of the property. The proposed remedial action achieves all of the remedial action objectives established for the project and addresses applicable standards, criterion, and guidance; is effective in both the short-term and long-term; reduces mobility, toxicity and volume of contaminants; is cost effective and implementable; and uses standard methods that are well established in the industry.

The proposed remedial action consists of:

1. Implementation of a Community Air Monitoring Program for particulates and VOCs

2. Selection of NYSDEC Part 375 Track 1 Unrestricted Use SCOs

3. Site mobilization involving security setup, equipment mobilization, utility mark outs and marking & staking excavation areas

4. A Waste Characterization Study was completed at the site and soil samples were collected using a methodology compatible with general disposal facility requirements based on previous experience

5. Implementation of soil erosion, pollution and sediment control measures in compliance with applicable laws and regulations

6. Excavation and removal of soil and fill exceeding Unrestricted Use (Track 1) SCOs. The proposed excavation will extend into bedrock. Existing buildings at the site will be demolished prior to implementation of the remedy. General excavation will be completed into bedrock between 35 to 45 feet to accommodate foundation components for the cellar and two sub-cellar levels with a general top of slab at el. -4.5.

About 30,000 tons of soil will be excavated and removed from this site. Excavated material is anticipated to comprise historic fill material, native sand and bedrock. Based on field observations and geotechnical borings completed by MRCE during their October 2016 geotechnical investigation, bedrock was encountered beneath the fill material or native layers at:

• 7 to 10 feet bgs in the northeast portion of the site;

• 6 to 15 feet bgs in the southeast portion of the site;

• 17.6 feet bgs in the southwest portion of the site; and

• 25.3 feet bgs in the northwest portion of the site.

In areas of the site with buildings containing cellar and sub-cellar levels, bedrock was encountered at depths between 5 and 11 feet below the slab.


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7. Excavation and removal of hazardous lead as identified in the December 9, 2016 Preliminary Waste Characterization Report - The hazardous lead will be further delineated prior to off-site disposal.

8. Screening of excavated soil/fill for indications of contamination by visual, olfactory and instrumental (i.e., monitoring with a PID) means - Excavated materials will be appropriately segregated on site to prevent comingling materials of different types and contamination

9. Management of excavated materials including temporarily stockpiling and segregating in accordance with defined material types and to prevent co-mingling of contaminated material and non-contaminated materials.

10. Removal of USTs (if present) and closure of petroleum spills in compliance with applicable local, state and federal laws and regulations

11. Transportation and off-site disposal of soil/fill material at permitted facilities in accordance with applicable laws and regulations for handling, transport, and disposal, and this plan

12. During the RI, limited quantities of perched groundwater were encountered between 9.52 and 16 feet bgs (corresponding to el 26.98 to el 18.8, respectively) and excavation will extend between 35 and 45 feet bgs. Limited or localized dewatering, if required, will be conducted in compliance with New York City Department of Environmental Protection (NYCDEP) permitting requirements, including any pretreatment required for discharge to the municipal sewer system.

13. Importation of materials to be used for backfill and cover in compliance with this plan and with applicable laws and regulations

14. Performance of all activities required for the remedial action, including acquisition of required permits and attainment of pretreated requirements, in compliance with applicable laws and regulations

18. As part of construction (not a remedial engineering control), a composite cover system will be

installed over any residual (existing) soil/fill remaining at the site following development

(excavation is anticipated to extend to bedrock). If any residual soil exceeds the SCOs, the cover

system would be considered an engineering control. The composite cover system will consist of:

a. A 12-inch concrete slab at the base of the elevator pits in the central portion of the second

sub-cellar level and along the southern perimeter of the site;

b. A 6-inch slab on grade throughout the second sub-cellar level;

c. A 12-inch slab beneath the tenant domestic water tanks in the central portion of the

second sub-cellar level; and

d. A 12-inch slab beneath the fuel oil storage tank pump rooms in the northeastern portion

of the second sub-cellar level.


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15. As part of construction (not a remedial engineering control), a waterproofing/vapor barrier system (with a minimum thickness of 20 mils) will be installed per manufacturer’s specifications beneath the concrete building slab and along subsurface building walls.

16. Submission of a Remedial Action Report (RAR) that describes remedial activities, certifies remedial requirements were achieved, and lists any deviations from this RAWP, if applicable.

4.2 Soil Cleanup Objectives and Soil/ Fill Management

Track 1 Unrestricted Use SCOs are proposed for this project and SCO’s are defined in 6 NYCRR Part 375, Table 6.8(a) Track 1 Unrestricted Use. Management of site materials, including excavation, handling and disposal, will be conducted in accordance with the SMMP in Appendix C. Discrete contaminant sources (such as hotspots and/or hazardous lead areas) identified during the remedial action will be horizontally and vertically identified by Global Positioning System (GPS) or surveyed. This information will be provided in the RAR.

4.2.1 Estimated Soil/Fill Removal Quantities

The site-wide excavation will extend about 35 to 45 feet bgs to accommodate foundation components and the cellar and two sub-cellar levels with a general top of slab at el. -4.5, and will include removing the existing site overburden to top of bedrock, in addition to bedrock excavation. About 30,000 tons of soil and fill is expected to be removed for construction of the cellar, two sub-cellars and foundation. The planned excavation is shown on Figure 5.

Excavated soil/fill will be transported off-site for disposal at an approved facility. For each disposal facility, a letter from the developer/engineer to the receiving facility requesting approval for disposal and a letter back to the developer/engineer providing approval for disposal will be submitted to NYCOER prior to any transport and disposal of soil at a facility. Facilities reviewed by the engineer to receive and dispose of site soil after approval of this RAWP will be reported promptly to the NYCOER Project Manager.

4.2.2 Waste Characterization

Soil and fill within the development cut was characterized during the preliminary waste characterization to facilitate direct loading of soil for transport and off-site disposal at receiving facilities. Soil samples were collected using a methodology compatible with general disposal facility requirements based on previous experience. While the sampling methodology will satisfy typical disposal facility requirements, some facilities may require additional testing, which will be the responsibility of the contractor. The contractor will be responsible for the layout of the waste characterization grids prior to the start of and during excavation.

4.2.3 Documentation Soil Sampling

No overburden will remain in place after foundation excavation is complete, and the proposed excavation extends into bedrock. Documentation soil samples will not be collected. If USTs are discovered and removed, documentation samples will be collected where required.


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4.2.4 Quality Assurance/Quality Control

No documentation samples are expected to be collected. As necessary, one field blank and one duplicate sample will be collected for every 20 documentation samples collected as part of a Quality Assurance/Quality Control (QA/QC) plan. One trip blank sample will be included per shipment of aqueous samples.

4.2.5 Import of Soils

Where necessary, import of soils onto the site and reuse of on-site soils will be performed in conformance with the SMMP in Appendix C and will meet the lower of 6 NYCRR Part 375 Unrestricted Use and Protection of Groundwater SCOs. Because the volume of imported soil is not yet known, the quantity cannot be estimated at this time. Any imported material will be pre-approved by the NYCOER, documented during construction, and reported in the RAR.

4.2.6 Reuse of On-site Soils

If necessary, reuse of on-site soils already on-site will be performed in conformance with the SMMP in Appendix C. Reuse soils will meet the SCOs established for this project.

4.3 Engineering Controls

The remedial action will achieve Track 1 Unrestricted Use SCOs and no ECs are required. However, the following design elements will be incorporated into the project as part of the development:

• Composite cover system

• Waterproofing/vapor barrier system

If Track 1 is not achieved, the composite concrete cover and vapor barrier/waterproofing membrane will constitute ECs that will be employed to address residual contamination remaining at the site. The ECs are described in the sections below.

4.3.1 Composite Cover System

A composite cover system will be built on the site. This composite cover system will be comprised of an approximately 6 to 12-inch thick concrete building slab. A concrete sidewalk will also be constructed on Lot 50. The composite cover is shown on the attached architectural drawings (Appendix A). In the event that a landscaped area is constructed, it will be capped with a minimum of two feet of clean fill and top soil or gravel imported from an approved facility/source.

The cover system is shown on Figure 6.

4.3.2 Waterproofing/Vapor Barrier System

A waterproofing membrane/vapor barrier (minimum 20 mils thick) will be installed between the concrete basement slab and underlying sub-grade layer, extending along the four walls of the basement structure from the base of the excavation to surface grade level. Utility and foundation penetrations and incidental


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punctures will be appropriately sealed in accordance with manufacturer’s specifications. A waterproofing/vapor barrier product has not been selected. When information on the proposed product becomes available, we will provide to the NYCOER for review and approval. The areas proposed for installation of the waterproofing/vapor barrier system is shown on Figure 7.

As-built waterproofing/vapor barrier plans will be submitted with the RAR. The RAR will include photographs of the installation process, a copy of a Professional Engineer/Registered Architect (PE/RA)-certified letter (on company letterhead) from the contractor responsible for installation oversight and field inspections, and a copy of the manufacturer’s certificate of warranty.

4.4 Institutional Controls

A Track 1 remedial action is proposed and Institutional Controls are not required. If a Track 1 remedial action is not achieved, ICs will be incorporated in this remedial action to manage residual soil/fill and other media and render the Site protective of public health and the environment. These ICs define the program to operate, maintain, inspect and certify the performance of ECs and ICs on this property. Institutional Controls would be implemented in accordance with a Site Management Plan (SMP) included in the final RAR. If Track 1 SCOs are not achieved, potential ICs for this remedial action include:

Continued registration with a Hazardous Materials E-Designation – The property will continue to be registered with an E-Designation at the DOB. This RAWP includes a description of all ECs and ICs and summarizes the requirements of the SMP, which will note that the property owner and property owner’s successors and assigns must comply with the approved SMP.

Submittal of a SMP in the RAR for approval by NYCOER that provides procedures for appropriate operation, maintenance, inspection, and certification of ECs and ICs. The SMP will require that the property owner and property owner’s successors and assigns submit to NYCOER a periodic written statement that certifies: 1) controls employed at the site are unchanged from the previous certification or that any changes to the controls were approved by NYCOER; and, 2) nothing has occurred that impairs the ability of the controls to protect public health and environment or that constitute a violation or failure to comply with the SMP. This certification shall be submitted at a frequency to be determine by NYCOER in the SMP and will comply with RCNY §43-1407(l)(3). NYCOER retains the right to enter the site in order to evaluate the continued maintenance of any controls.

Vegetable gardens and farming on the site are prohibited when in contact with residual soil and fill.

Use of groundwater underlying the site is prohibited without treatment rendering it safe for its intended use.

The site will be used for commercial use and will not be used for a higher level of use (i.e., residential) without prior approval by NYCOER.


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4.4.1 Site Management Plan

Site management is not required for Track 1 remedial actions. However, if Track 1 SCOs are not achieved, site management will be the last phase of remediation and begins with the approval of the RAR and issuance of the Notice of Completion (NOC) for the remedial action. The SMP describes appropriate methods and procedures to ensure implementation of all EC/ICs that are required by this RAWP. The SMP is submitted as part of the RAR but will be written in a manner that allows its use as an independent document. Site management continues until terminated in writing by NYCOER. The property owner is responsible to ensure that all site management responsibilities defined in the SMP are implemented.

If required, the SMP will provide a detailed description of the procedures required to manage residual soil/fill left in place following completion of the remedial action in accordance with the Voluntary Cleanup Agreement with NYCOER. This includes a plan for: 1) implementation of EC/ICs; 2) implementation of monitoring programs; 3) operation and maintenance of ECs; 4) inspection and certification of ECs; and 5) reporting.

Site management activities, reporting and EC/IC certification will be scheduled by NYCOER on a periodic basis to be established in the SMP and will be subject to review and modification by NYCOER. The SMP will be based on a calendar year and certification reports will be due for submission to NYCOER by July 31 of the year following the reporting period.

4.5 Qualitative Human Health Exposure Assessment

The objective of the qualitative exposure assessment is to identify potential receptors and pathways for human exposure to the COC that are present at, or migrating from, the site. An exposure pathway describes the route that the COC takes to travel from the source to the receptor. An identified pathway indicates that the potential for exposure exists; it does not imply that exposures actually occur.

Data and information reported in the RIR are sufficient to complete a Qualitative Human Health Exposure Assessment (QHHEA). As part of the VCP process, a QHHEA was performed to determine whether the site poses an existing or future health hazard to the site’s exposed or potentially exposed population. The sampling data from the RI were evaluated to determine whether there is any health risk under current and future conditions by characterizing the exposure setting, identifying exposure pathways, and evaluating contaminant fate and transport. This QHHEA was prepared in accordance with Appendix 3B and Section 3.3 (b) 8 of the NYSDEC Draft Division of Environmental Remediation (DER)-10 Technical Guidance for Site Investigation and Remediation.

Known and Potential Contaminant Sources

Known and potential sources were identified during previous investigations at the site and include the AOCs that were evaluated during the RI. The AOCs for the site are summarized below:

1. AOC 1 – Documented Contaminated Historic Fill Material


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Previous reports document the presence of historic fill at the site, and laboratory analyses of soil samples collected from the historical fill material confirmed the presence of SVOCs and metals at concentrations above 6 NYCRR Part 375 Unrestricted Use SCOs.

2. AOC 2 – Historical Site Use

Historical site use included a leather factory, engraving supply shop, paper bailing, lard oil refinery, coal yard, glass company, cutting company, metal and manufacturing company, auto parts company, chemist facility, elevator company and a furniture finishing and assembly warehouse. Potential contaminants, including solvents, petroleum products, SVOCs, metals and PCBs were likely used during historical site operations. Spills or leaks of these contaminants may have impacted the subsurface soil, soil vapor and groundwater.

3. AOC 3 – Petroleum Bulk Storage on Site

Historical fuel oil and gasoline storage was reported on site Lots 29, 30, 39, 45 and 46. A CO dated October 15, 1947 identified a gasoline tank as approved for installation by the NYFD in Lot 30. COs dated January 14, 1948 and August 7, 1951 indicate NYFD approval of fuel oil installation in Lots 29 and 39. One 10,000-gallon #6 fuel oil tank was observed in a vault beneath the 33rd Street sidewalk along Lot 46. One 1,080-gallon #2 fuel tank was observed in the Lot 45 building basement. The 1,080-gallon tank is encased in concrete, with the exception of a portion of the top that is chipped away. One 1,000-gallon tank was observed in the basement of Lot 29.

4. AOC 4 – Historic Use at Adjoining Properties

524 West 36th Street, which is located approximately 350 feet north (cross-gradient) of the site, includes a ten-year history of gasoline tank overfills. Groundwater monitoring is on-going at the property, and groundwater contamination was observed to be present within the bedrock zone. The former BP Service Station, located across Tenth Avenue to the northeast of the site, contains multiple (LTANKS and NY Spills listings. Elevated petroleum-related VOCs (e.g., BTEX) and MTBE were detected in groundwater. LNAPL was detected in one of the wells at the property. A stipulation list to conduct cleanup and removal of petroleum discharges in reference to the spill was signed and returned to NYSDEC on August 23, 2004. Site-wide remedial excavations and groundwater remediation were conducted between 2006 and 2008 as part of redevelopment of the property. Remediation of the groundwater within the underlying bedrock was completed to the extent feasible in 2013 and the spill was closed. During redevelopment of 440 Tenth Avenue (immediately north of the former BP Service Station), a new spill (NYSDEC Spill No. 1309801) was reported due to elevated VOC soil vapor concentrations. The property at 509 West 34th Street, which adjoins the site to the north, is listed in the BCP program as Site No. C231094.


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Based on the evaluation of the AOCs and the results of the RIR and preliminary waste characterization, the COCs are:

Soil:

SVOCs including benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene were detected above Restricted Commercial Use SCOs.

Metals including barium, copper, lead, and mercury were detected above Restricted Commercial Use SCOs. Atypically high concentrations of lead and mercury were identified in the RI and preliminary waste characterization. In addition, hazardous lead was identified in the northeast portion of Lot 39, and requires further horizontal and vertical delineation prior to off-site disposal.

Groundwater:

Metals including antimony, iron, selenium, magnesium, manganese and sodium were detected at a concentration exceeding their corresponding TOGS Ambient Water Quality Standards and SGV.

Soil Vapor:

The results for PCE and TCE in soil vapor samples indicate a range of suggested action from monitoring through mitigation per the NYSDOH decision matrices.


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Nature, Extent, Fate and Transport of Contaminants

Soil and Fill Material:

The information compiled during the RI and previous investigations has confirmed the presence of historic fill throughout the site from a-grade surface to depths of:






In areas of the site with buildings containing cellar and sub-cellar levels, historic fill was observed immediately below existing slabs to depths of 0.8 to 2.8 feet below the slab. Fill material generally consisted of light to dark brown, fine to medium sand with trace gravel and silt, and varying quantities of glass, brick fragments, concrete, wood, slag, and coal ash. Dark staining was observed in boring EB-17 between 1 and 1.5 feet bgs (northwest portion of the site). Odors and PID readings were not encountered in any of the borings. Laboratory analytical results from the RI identified several SVOCs and metals at concentrations exceeding Restricted Commercial Use SCOs detected in samples collected from historic fill.

A native sand layer consisting of brown fine sand with trace medium sand, gravel and silt was observed from 10 to 18 feet bgs in the eastern portion of the site and from 15 to 24 feet bgs in the northwestern portion of the site.

Groundwater:

Groundwater samples collected during the RI identified dissolved metals concentrations exceeding TOGS Ambient Water Quality Standards and SGVs. Metals concentrations are distributed throughout groundwater at the site. These metals are representative of regional groundwater quality and are not indicative of a contaminant release.

Soil Vapor:

Soil vapor samples collected during the RI identified VOCs. Soil vapor contaminants of concern include TCE (max. 156 µg/m3) and PCE (max. 60.2 µg/m3). The source of the detected VOCs may relate to shallow localized impacts or an off-site source.

Receptor Populations

On-Site Receptors:

Lots 46, 45, and 30 of the site are currently vacant, Lot 30 is currently occupied by a commercial tenant and Lots 29, 32, and 39 are currently used for construction-related activities including storage areas, training centers, and real estate showrooms. Access to the site buildings is restricted by 24-hour security, locked doors/ gates and perimeter fencing along parking lot areas. On-site receptors are limited to tenants


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occupying the building in Lot 30, construction personnel, trespassers, site representatives, personnel performing subsurface investigations and visitors granted access to the property. Prior to implementation of the remedy, the existing buildings on site will be vacated and demolished. During construction, potential on-site receptors include construction workers, site representatives, and visitors. Under proposed future conditions, potential on-site receptors include commercial tenants and visitors.

Off-Site Receptors:

Potential off-site receptors within a 400-foot radius of the site include: adult and child residents; pedestrians; commercial and construction workers; and passerby based on the following:

Commercial Businesses – The Hudson Yards 7 Line Subway Station is located to the west. Commercial-use developments are located to the north, east and southeast beyond Tenth Avenue. Commercial use is planned for portions of the Hudson Yards Eastern Rail Yard redevelopment (south of the site).

Residential Buildings – Mixed-use residential buildings are located approximately 300 feet north and northeast of the site along Tenth Avenue and West 35th Street.

Building Construction/ Renovation – There are active construction sites to the northeast beyond Tenth Avenue and to the south (Hudson Yards Eastern Rail Yard redevelopment).

Pedestrians and Cyclists – Pedestrian traffic (including cyclists) is currently possible on West 34th Street to the north, Tenth Avenue to the east, and Hudson Boulevard to the west. The Hudson Park and Boulevard is located west of the site. Future construction includes expansion of Hudson Park and Boulevard to the west and southwest, and on-site pedestrian walkways.

Potential Routes of Exposure

Three potential primary routes exist by which chemicals can enter the body: ingestion, inhalation, and dermal absorption. Exposure can occur based on the following potential media:

Ingestion of contaminated groundwater or fill/ soil;

Inhalation of contaminated vapors or particulates; and

Dermal absorption of contaminants in groundwater or fill/ soil.

Potential Exposure Points

Current Conditions:

The potential for exposure to surficial historic fill is limited under current conditions because the site footprint is covered with an impervious cover (i.e. concrete foundations and asphalt parking areas) and site access is restricted by 24-hour security, locked doors/ gates and perimeter fences. Groundwater is not exposed at the site, and because the site is served by the public water supply (from reservoirs in upstate New York) and groundwater use for potable supply is prohibited, there is no potential for exposure to groundwater contaminants. On-site structures include seven multi-story buildings and associated parking


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areas, of which four have cellar and sub-cellar areas. No cracks or openings in the foundation were identified during site reconnaissance.

Construction/Remedial Conditions:

During the remedial action, construction workers will come in direct contact with soil and limited quantities of perched groundwater. Site construction workers could potentially ingest, inhale or have dermal contact with any exposed soil, fill or groundwater. Similarly, off-site receptors could be exposed to dust and vapors from excavation activities.

Proposed Future Conditions:

Under future remediated conditions, all soil will be excavated to the bedrock surface, eliminating sources of contamination. A waterproofing membrane/vapor barrier will prevent exposure to potential soil vapor. A ventilated parking garage will also be constructed in the second sub-cellar level. The site is served by a public water supply, and groundwater is not used at the site for potable supply. There are no plausible off-site pathways for oral, inhalation, or dermal exposure to contaminants derived from the site.

Overall Human Health Exposure Assessment

This assessment takes into consideration the reasonably anticipated use of the site, which includes commercial use, site cap, no anticipated landscaped areas on residual site soil, and subsurface waterproofing. Potential post-construction use of groundwater is not considered an option because groundwater in NYC is not used as a potable water source. There are no complete exposure pathways (i.e., source, route to exposure, receptor population) for the current condition or for the post-construction condition. Under current conditions, on-site exposure is limited by preventing access to the site and limiting site activity. After the remedial action is complete, there will be no remaining exposure pathways to identified contaminants. The waterproofing membrane/vapor barrier will prevent the potential for vapor intrusion.

There is a potential complete, unacceptable exposure pathway that requires mitigation during implementation of the remedy. The potentially exposed receptors during remedy implementation are workers on the site and the public adjacent to the site. Unacceptable exposure pathways will be mitigated or eliminated by proper implementation of the SMMP, dust controls, CHASP and CAMP. The CHASP specifies appropriate monitoring and controls required to mitigate/eliminate the pathway between sources and site workers. The CAMP specifies appropriate monitoring and controls required to mitigate/eliminate the pathway between sources and the adjacent public.


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5.0 REMEDIAL ACTION MANAGEMENT

5.1 Project Organization and Oversight

Principal Langan personnel who will participate in implementing this RAWP during construction include Jason Hayes, Joseph Good, and Emily Snead. The PE for this project is Jason Hayes.

5.2 Site Security

Site access will be controlled by construction fencing and gated entrances. Access will be limited to construction workers, project team members, and approved visitors.

5.3 Work Hours

The hours for operation will comply with the New York Department of Buildings (NYCDOB) construction code requirements or according to specific variances issued by that agency. The anticipated hours of operation will be conveyed to the NYCOER during the pre-construction meeting.

5.4 Construction Health and Safety Plan

The CHASP is included in Appendix D. The Langan Site Safety Coordinator will be Bill Bohrer and the Langan Site Safety Officer will be Emily Snead. Remedial work performed under this RAWP will be in full compliance with applicable health and safety laws and regulations, including site and OSHA worker safety requirements and Hazardous Waste Operations and Emergency Response (HAZWOPER) requirements. Confined space entry, if any, will comply with OSHA requirements and industry standards and will address potential risks. The parties performing the remedial construction will work in compliance with the CHASP and applicable laws and regulations. The CHASP pertains to remedial and invasive work performed at the site until the issuance of the Notice of Satisfaction.

All Langan field personnel involved in remedial activities will participate in training required under 29 Code of Federal Regulations (CFR) 1910.120, including 40-hour hazardous waste operator training and annual 8-hour refresher training. The Site Safety Officer will be responsible for maintaining training records.

Personnel entering any exclusion zone will be trained in the provisions of the CHASP and will comply with all requirements of 29 CFR 1910.120. Site-specific training will be provided to field personnel. Additional safety training may be added depending on the tasks performed. Emergency telephone numbers will be posted at the site before any remedial work begins. A safety meeting will be conducted before each shift begins. Topics to be discussed include task hazards and protective measures (physical, chemical, environmental); emergency procedures; personal protective equipment (PPE) levels and other relevant safety topics. Meetings will be documented in a log book or specific form.

An emergency contact sheet with names and phone numbers is included in the CHASP. That document will define the specific project contacts for use in case of emergency.


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5.5 Community Air Monitoring Plan

Real-time air monitoring for VOCs and particulate levels at the perimeter of the exclusion zone or work area will be performed. Continuous monitoring will be performed for all ground intrusive activities and during the handling of contaminated or potentially contaminated media. Ground intrusive activities include, but are not limited to, soil/waste excavation and handling, test pit excavation or trenching, and the installation of soil borings or monitoring wells.

Periodic monitoring for VOCs will be performed during non-intrusive activities such as the collection of soil and sediment samples or the collection of groundwater samples from existing monitoring wells. Periodic monitoring during sample collection, for instance, will consist of taking a reading upon arrival at a sample location, monitoring while opening a well cap or overturning soil, monitoring during well bailing/purging, and taking a reading prior to leaving a sample location. Depending upon the proximity of potentially exposed individuals, continuous monitoring may be performed during sampling activities. Examples of such situations include groundwater sampling at wells on the curb of a busy urban street, in the midst of a public park, or adjacent to a school or residence. Exceedances of action levels observed during performance of the CAMP will be reported to the NYCOER Project Manager and included in the Daily Report.

5.5.1 VOC Monitoring, Response Levels, and Actions

VOCs will be monitored at the upwind and downwind perimeter of the immediate work area or exclusion zone on a continuous basis during invasive work. Monitoring will be performed using equipment appropriate to measure the types of contaminants known or suspected to be present. The equipment will be calibrated daily at the start of each work shift. The equipment will be capable of calculating 15-minute running average concentrations, which will be compared to the levels specified below:

If the ambient air concentration of total organic vapors at the downwind perimeter of the work area or exclusion zone exceeds 5 parts per million (ppm) above background for the 15-minute average, work activities will be temporarily halted and monitoring continued. If the total organic vapor level readily decreases (per instantaneous readings) below 5 ppm over background, work activities will resume with continued monitoring.

If total organic vapor levels at the downwind perimeter of the work area or exclusion zone persist at levels in excess of 5 ppm over background but less than 25 ppm, work activities will be halted, the source of vapors identified, corrective actions taken to abate emissions, and monitoring continued. After these steps, work activities will resume provided that the total organic vapor level 200 feet downwind of the exclusion zone or half the distance to the nearest potential receptor or residential/commercial structure, whichever is less - but in no case less than 20 feet, is below 5 ppm over background for the 15-minute average.

If the organic vapor level is above 25 ppm at the perimeter of the work area, activities will be shutdown.


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All 15-minute readings must be recorded and be available for NYCOER personnel to review. Instantaneous readings, if any, used for decision purposes will also be recorded.

5.5.2 Particulate Monitoring, Response Levels, and Actions

Particulate concentrations will be monitored continuously at the upwind and downwind perimeters of the work area or exclusion zone at temporary particulate monitoring stations. The particulate monitoring will be performed using real-time monitoring equipment capable of measuring particulate matter less than 10 micrometers in size (PM-10) and capable of integrating over a period of 15 minutes (or less) for comparison to the airborne particulate action level. In addition, fugitive dust migration should be visually assessed during all work activities. The action levels and procedures to be followed are specified below:

If the downwind PM-10 particulate level is 100 micrograms per cubic meter (µg/m3) greater than background (upwind perimeter) for the 15-minute period or if airborne dust is observed leaving the work area, then dust suppression techniques will be employed. Work will continue with dust suppression techniques provided that downwind PM-10 particulate levels do not exceed 150 µg/m3 above the upwind level and provided that no visible dust is migrating from the work area.

If, after implementation of dust suppression techniques, downwind PM-10 particulate levels are greater than 150 µg/m3 above the upwind level, work will be stopped and the work activities will be re-evaluated. Work will resume provided that dust suppression measures and other controls are successful in reducing the downwind PM-10 particulate concentration to within 150 µg/m3 of the upwind level and in preventing visible dust migration.

All readings will be recorded and be available for NYCOER personnel to review.

5.6 Agency Approvals

All permits or government approvals required for remediation and construction have been or will be obtained prior to the start of remediation and construction. Acceptance of this RAWP by the NYCOER does not constitute satisfaction of these requirements and will not be a substitute for any required permit.

5.7 Site Preparation

5.7.1 Pre-Construction Meeting

Prior to construction, the NYCOER will be invited to attend the preconstruction meeting at the site with all parties involved (e.g., owner, contractor, construction manager, engineer).

5.7.2 Mobilization

Mobilization will be conducted as necessary for each phase of work at the site. Mobilization includes field personnel orientation, equipment mobilization, marking/staking sampling locations and utility mark-outs. Each field team member will attend an orientation meeting to become familiar with the general operation of the site, health and safety requirements, and field procedures.


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5.7.3 Utility Marker Layouts, Easement Layouts

The presence of utilities and easements on the site will be fully investigated prior to the start of invasive work such as excavation or drilling under this plan by using, at a minimum, the One-Call System (811). Underground utilities may pose an electrocution, explosion, or other hazard during excavation or drilling activities. All invasive activities will be performed in compliance with applicable laws and regulations to assure safety. Utility companies and other responsible authorities will be contacted to locate and mark the locations, and a copy of the Markout Ticket will be retained by the contractor prior to the start of drilling, excavation or other invasive subsurface operations. Overhead utilities may also be present within the anticipated work zones. Electrical hazards associated with drilling or operating other heavy machinery in the vicinity of overhead utilities will be prevented by maintaining a safe distance between overhead power lines and drill rig masts/heavy machinery.

Proper safety and protective measures pertaining to utilities and easements, and compliance with all laws and regulations will be employed during invasive and other work contemplated under this RAWP. The integrity and safety of on-site and off-site structures will be maintained during all invasive, excavation or other remedial activity performed under the RAWP.

5.7.4 Dewatering

Limited or localized dewatering may be needed to excavate below the water table for construction of the foundation and components (e.g., pile caps, elevator pits). Dewatering for this site is anticipated to use a pumping system, settling tanks, and a treatment system prior to discharge into the NYC combined sewer system. All required permits will be obtained from the NYCDEP before discharging groundwater into the combined sewer system.

5.7.5 Equipment and Material Staging

Equipment and materials will be stored and staged in a manner that complies with applicable laws and regulations.

5.7.6 Stabilized Construction Entrance

Steps will be taken so that trucks departing the site will not track soil, fill or debris off site. Such actions may include use of cleaned asphalt or concrete roads or use of stone or other aggregate-based egress paths between the truck inspection station and the property exit. Measures will be taken to ensure that adjacent roadways will be kept clean of project related soils, fill and debris.

5.7.7 Truck Inspection Station

An outbound-truck inspection station will be set up close to the site exit. Before exiting the site, trucks will be required to stop at the truck inspection station and will be examined for evidence of contaminated soil on the undercarriage, body, and wheels. Brooms, shovels and clean water will be used to remove soil from vehicles and equipment, as necessary.


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5.7.8 Extreme Storm Preparedness and Response Contingency Plan

Damage from flooding or storm surge can include erosion of soil and stockpiled materials, damage of site structures and construction materials and equipment, and damage of support of excavation structures. Damage from wind during an extreme storm event can create unsafe or unstable structures, damage safety structures and cause downed power lines creating dangerous site conditions and loss of power. In the event of emergency conditions caused by an extreme storm event, the enrollee will undertake the following steps for site preparedness prior to the event and response after the event.

5.7.9 Storm Preparedness

Preparations in advance of an extreme storm event will include the following: containerized hazardous materials and fuels will be removed from the property; loose materials will be secured to prevent erosion and blowing by wind or water; heavy equipment such as excavators and generators will be removed from excavated areas, trenches and depressions on the property to high ground or removed from the property; an inventory of the property with photographs will be performed to establish conditions for the site and equipment prior to the event; stockpile covers for soil and fill will be secured by adding weights such as sandbags for added security and worn or ripped stockpile covers will be replaced with competent covers; stockpiled hazardous wastes will be removed from the property; stormwater management systems will be inspected and fortified, including, as necessary: clean and reposition silt fences, hay bales; clean storm sewer filters and traps; and secure and protect pumps and hosing.

5.7.10 Storm Response

At the conclusion of an extreme storm event, as soon as it is safe to access the property, a complete inspection of the property will be performed. A site inspection report will be submitted to NYCOER at the completion of site inspection and after the site security is assessed. Site conditions will be compared to the inventory of site conditions and material performed prior to the storm event and significant differences will be noted. Damage from storm conditions that result in acute public safety threats, such as downed power lines or imminent collapse of buildings, structures or equipment will be reported to public safety authorities via appropriate means such as calling 911. Petroleum spills will be reported to NYSDEC within 2 hours of identification and consistent with State regulations. Emergency and spill conditions will also be reported to NYCOER. Public safety structures, such as construction security fences will be repaired promptly to eliminate public safety threats. Debris will be collected and removed. Dewatering will be performed in compliance with existing laws and regulations and consistent with emergency notifications, if any, from proper authorities. Eroded areas of soil including unsafe slopes will be stabilized and fortified. Displaced materials will be collected and appropriately managed. Support of excavation structure will be inspected and fortified as necessary. Impacted stockpiles will be contained and damaged stockpile covers will be replaced. Stormwater control systems and structures will be inspected and maintained as necessary. If soil or fill materials are discharged off site to adjacent properties, property owners and NYCOER will be notified and corrective measure plan designed to remove and clean eroded material will be submitted to NYCOER and implemented following approval by NYCOER and granting of site access by the property owner. Impacted off-site areas may require


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characterization based on site conditions, at the discretion of NYCOER. If on-site petroleum spills are identified, a qualified environmental professional will determine the nature and extent of the spill and report to NYSDECs spill hotline at 800-457-7362 within statutory defined timelines. If the source of the spill is ongoing and can be identified, it should be stopped if this can be done safely. Potential hazards will be addressed immediately, consistent with guidance issued by NYSDEC.

5.7.11 Storm Response Reporting

A site inspection report will be submitted to NYCOER at the completion of site inspection. An inspection report established by NYCOER is available on NYCOERs website (www.nyc.gov/oer) and will be used for this purpose. Site conditions will be compared to the inventory of site conditions and material performed prior to the storm event and significant differences will be noted. The site inspection report will be sent to the NYCOER project manager and will include the site name, address, tax block and lot, site primary and alternate contact name and phone number. Damage and soil release assessment will include: whether the project had stockpiles; whether stockpiles were damaged; photographs of damage and notice of plan for repair; report of whether soil from the site was eroded and whether any of the soil left the site; estimates of the volume of soil that left the site, nature of impact, and photographs; description of erosion damage; description of equipment damage; description of damage to the remedial program or the construction program, such as damage to the support of excavation; presence of on-site or off-site exposure pathways caused by the storm; presence of petroleum or other spills and status of spill reporting to NYSDEC; description of corrective actions; schedule for corrective actions. This report should be completed and submitted to NYCOER project manager with photographs within 24 hours of the time of safe entry to the property after the storm event.

5.8 Traffic Control

Drivers of trucks leaving the site with soil and fill will be instructed to proceed without stopping in the vicinity of the site to prevent neighborhood impacts. The planned route on local roads for trucks leaving the site is shown on Figure 8.

5.9 Demobilization

Demobilization will include:

As necessary, restoration of temporary access areas and areas that may have been disturbed to accommodate support areas (e.g., staging areas, decontamination areas, storage areas, temporary water management areas, and access area);

Removal of sediment from erosion control measures and truck wash and disposal of materials in accordance with applicable laws and regulations;

Equipment decontamination; and

General refuse disposal.


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Equipment will be decontaminated and demobilized at the completion of all field activities. Investigation equipment and large equipment (e.g., soil excavators) will be washed at the truck inspection station as necessary. In addition, all investigation and remediation derived waste will be appropriately disposed off-site.

5.10 Reporting and Record Keeping

5.10.1 Daily Reports

Daily reports that provide a general summary of activities for each day of active remedial work will be emailed to the NYCOER Project Manager by the end of the following day. Those reports will include:

Project number and statement of the activities and an update of progress made and locations of work performed;

Quantities of material imported and exported from the site;

Status of on-site soil/fill stockpiles;

A summary of citizen complaints, with relevant details (basis of complaint; actions taken; etc.);

A summary of CAMP results, noting if and the reason for action levels being triggered; and,

Photographs of notable site conditions and activities.

The frequency of the reporting period may be revised in consultation with the NYCOER project manager based on planned project tasks. Daily email reports are not intended to be the primary mode of communication for notification to the NYCOER of emergencies (accidents, spills), requests for changes to the RAWP or other sensitive or time critical information. However, such information will be included in the daily reports. Emergency conditions and changes to the RAWP will be communicated directly to the NYCOER project manager by personal communication. Daily reports will be included as an Appendix in the RAR.

5.10.2 Record Keeping and Photo-Documentation

Job-site records for all remedial work will be maintained. These records will be kept on site during the project and will be available for inspection by NYCOER staff. Representative photographs will be taken of the site prior to any remedial activities and during major remedial activities to illustrate remedial program elements and contaminant source areas. Photographs will be submitted at the completion of the project in the RAR in digital format (i.e., jpeg files).

5.11 Complaint Management

Citizen complaints will be promptly reported to the NYCOER. Complaints will be addressed and the outcomes reported to the NYCOER in daily reports. Notices to the NYCOER will include the nature of the complaint, the party providing the complaint, and the actions taken to resolve any problems. The Citizen Participation Plan is provided in Appendix E.


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5.12 Deviations from the Remedial Action Work Plan

Proposed changes to the RAWP will be reported to the NYCOER Project Manager, documented in daily reports and reported in the RAR. The process to be followed if there are any deviations from the RAWP will include a request for approval for the change from the NYCOER noting the following:

Reasons for deviating from the approved RAWP;

Effect of the deviations on overall remedy; and

Determination that the remedial action with the deviation(s) is protective of public health and the environment.


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6.0 REMEDIAL ACTION REPORT

A RAR will be submitted to the NYCOER following implementation of the remedial action defined in this RAWP. The RAR will document that the remedial work required under this RAWP was completed in compliance with this plan and any approved deviations thereto. The RAR will include:

Information required by this RAWP;

As-built drawings for all constructed engineering controls;

Required certifications and manifests for soil and fill disposal;

Photographic documentation for installation of the required engineering controls and of soil handling;

Account of the disposal destination of all contaminated material removed from the site - Documentation associated with disposal of all material will include transportation and disposal records, and letters approving receipt of the material;

Tabular summary of documentation soil sample results and supplemental characterization results, QA/QC results, and other sampling and chemical analysis performed as part of the remedial action;

If discovered, an account of source area locations and characteristics of associated contaminated material removed from the site (including a map showing source areas);

Account of the origin and required chemical quality testing for material imported onto the site;

Description of any changes in the remedial action from the elements provided in this RAWP and associated design documents; and

Reports and supporting material will be submitted in digital form.


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7.0 REMEDIAL ACTION REPORT CERTIFICATION

The following certification will appear in front of the Executive Summary of the RAR. The certification will include the following statements:

I reviewed this document, to which my signature and seal are affixed.

I am currently a professional engineer licensed by the State of New York. I had primary direct responsibility for implementation of the remedial program for the 50 Hudson Yards project; CEQR No. 03DCP031M, OER No. 17TMP0019M.

I certify that to the best of my knowledge the NYCOER-approved Remedial Action Work Plan dated was implemented and that all requirements in those documents have been substantively complied with. I certify that to the best of my knowledge contaminated soil, fill, liquids or other material from the property were taken to facilities licensed to accept this material in full compliance with applicable laws and regulations.


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8.0 SCHEDULE

The table below presents a schedule for the proposed remedial action and reporting. If the schedule for remediation and development activities changes, it will be updated and submitted to the NYCOER. Currently, remedial action is anticipated to start on or about October 2017.

Schedule Milestone Duration (weeks) Weeks from Remedial Action

Start

NYCOER Approval of RAWP 0 0

Fact Sheet Announcing Start of Remedy

2 2

Contractor Mobilization 4 6

Foundation Excavation and Remedial Construction

36 42

Demobilization 10 52

Submit Remedial Action Report 5 57

Documents

2017-01-04.17TMP0019M.RAPRAWP.Draft … Columbus Circle New York, New York 10023 Prepared by: Langan Engineering, Environmental, Surveying, and Landscape Architecture, D.P.C. 360 West