This blog post summarizes what regulations apply to remediation sites in New York, and what air monitoring equipment can help you comply.
BROWNFIELD CLEANUP IN NEW YORK CITY
As New York City’s need for space grows, existing stock of land must be used more effectively. Brownfield cleanup and redevelopment represents one of the best opportunities to engage communities and reclaim land for development in many cities. In 2018, the Mayor’s Office of Environmental Remediation (MOER) announced 1000×21, the most aggressive land cleanup and revitalization goal of any city in the world. This OneNYC initiative seeks to remediate and redevelop 1,000 lots in NYC by the end of the de Blasio administration in 2021.
Remediation air quality challenges
Any time a remediation or construction project involves earth-moving, it has the potential to release particulate(dust) and volatile organic compounds (VOCs) contaminants that exist below the surface. VOCs will readily transition to the gaseous, breathable phase, when exposed to air. Particulate emissions must be controlled to prevent impacts to the respiratory system. Negative impacts range from mild lung irritation to chronic lung disease.
Regulations to protect the community
To protect workers and the surrounding community, construction and demolition projects that involve excavation need to follow a stringent Community Air Monitoring Plan (CAMP), as specified by the New York State Department of Health (NYSDOH). If the excavation activities are occurring on a remediation or cleanup site, additional requirements are outlined in a guidance document known as DER-10. NYSDOH and DER-10 specifically apply to sites in New York. However, agencies and authorities in other states may also recognize these guidelines. They have been known to apply or refer to them for projects in their designated territories.
WHAT IS DER-10?
In 2010, the New York State Department of Environmental Conservation (NYSDEC) issued Division of Environmental Remediation (DER)-10 Technical Guidance for Site Investigation and Remediation, known as DER-10. This is the source document the NYSDEC refer to for authority to oversee remediation projects. It was designed to help parties and consultants (environmental and engineering) in developing and implementing investigation and remediation projects at contaminated sites.
DER-10 extensively (over 225 pages) describes the A to Z requirements for remedial site investigations, cleanups, post-cleanup monitoring and site closure. It presents detailed technical guidance for each of the investigative and remedial steps undertaken at contaminated sites. DER-10 covers procedures for assessing the environmental conditions at the site, including air monitoring during remediation activities.
WHAT IS CAMP?
Appendix 1A of the DER-10 outlines requirements for the implementation of a CAMP. This air monitoring plan is prescribed by NYSDOH. It involves direct-reading air monitoring instruments placed at defined locations around the perimeter of a remediation, construction or demolition site.
A CAMP requires real-time air monitoring for total VOCs (also referred to as total organic vapors) and PM10(particulate matter 10 micrometers or less in diameter) at downwind and upwind locations relative to each designated work area when certain activities are in progress at contaminated sites. The CAMP is not intended for use in establishing action levels for worker respiratory protection. Rather, it is intended to protect the downwind community from potential airborne contaminants released as a direct result of investigative and remedial work activities. The downwind community includes off-site receptors such as residences, businesses, and on-site workers not directly involved with the subject work activities. The specified CAMP action levels require increased monitoring, corrective actions to abate emissions, and/or work shutdown. Additionally, CAMP helps to confirm that work activities did not spread contamination off-site through the air.
VOC AND PARTICULATE MONITORING
Basic requirements of a CAMP call for real-time air monitoring for VOCs and/or particulate levels at the perimeter of the exclusion zone, or work area. Sites known to be contaminated with heavy metals alone may only require particulate monitoring. If radiological contamination is a concern, additional monitoring requirements may be necessary in consultation with NYSDEC and NYSDOH. The table below summarizes Monitoring Action Levels for total VOC and particulate monitoring.
CAMP AIR MONITORING EQUIPMENT
Since the introduction of DER-10 in 2010, sensor-based technologies have reduced the cost of air monitoring and increased efficiency of the implementation of CAMP. Real-time air monitoring solutions are available to fit the budget and complexity requirements of every project. Below is a sampling of equipment options:
ENTRY LEVEL – BASIC ENVIRONMENTAL DUST MONITORING KIT
Assembled kits, like this Basic Environmental Dust Monitoring Kit from Raeco Rents, are portable and suited to short-term or temporary CAMP. The ensemble includes an off-the-shelf dust monitor, handheld PID monitor for total VOCs, and a cloud-based telemetry system mounted in an environmental enclosure.
ULTIMATE FLEXIBILITY – ALL-IN-ONE AIR QUALITY MONITOR
All-in-one air quality monitors, like the AQS1 and the Dust Sentry from Aeroqual, are highly flexible and defensible, as well as good allrounders for short or long-term CAMP. In addition to the primary particulate fraction PM10, these monitors can also measure PM2.5, PM1 and Total PM. They can also be configured for monitoring total VOCs and NO2emissions from remediation and construction sites. A robust light-scattering Nephelometer with sharp cut cyclone is integrated with a PID-based VOC analyzer module (or GSE-based NO2 gas module), Cloud telemetry platform, air quality software, and optional plug-and-play weather and noise sensors. Trigger alerts are programmable for SMS and email notifications, or can be used to activate an external VOC canister sample collection for speciated analysis according to EPA Method TO-15.
THE ROLLS ROYCE – GC-BASED PERIMETER AIR MONITORING STATION
Perimeter air monitoring stations, like the AirLogics Classic 2, contain analytical, climatic, and communications instrumentation. This equipment includes: a gas chromatograph (GC) to measure specific VOCs, a respirable particulate meter to measure dust levels, shelter heaters and air conditioners, and a radio-based data acquisition system. These systems were originally developed for use in the cleanup of former manufactured gas plant (MGP) sites.
DER-10 guidelines require daily measurement of wind speed and direction, temperature, barometric pressure, and relative humidity, to establish background weather conditions. Wind direction data is used to position the air monitoring equipment in appropriate upwind and downwind locations.
The evaluation of weather conditions is also necessary for proper fugitive dust control. When extreme wind conditions make dust control ineffective, remedial actions may need to be suspended. There may be situations that require fugitive dust suppression and particulate monitoring requirements with more stringent action levels.
Under some circumstances, the contaminant concentration and/or toxicity may require additional monitoring to protect site personnel and the community. Additional integrated sampling and chemical analysis of the dust may be required. This must be evaluated when a Health and Safety Plan (HASP), is developed. Appropriate suppression and monitoring requirements are established for the protection of people’s health and the environment.
All recorded monitoring data is downloaded and field logged daily, including Action Limit Reports (if any) and daily CAMP monitoring location plans. Records are required to be maintained onsite for NYSDEC and NYSDOH to review. A description of the CAMP-related activities is also included in a monthly progress report submitted to the NYSDEC. The overall report submitted to the NYSDEC should include all CAMP monitoring records. If site works are stopped due to inability to control fugitive emissions to below the action limit, the NYSDEC is to be notified within twenty-four hours of the work stoppage.
For a real-life example of air monitoring at a remediation site, you can read our blog about the pilot cleanup of the Gowanus Canal, NY.
WHAT CAMP SOLUTIONS DOES AEROQUAL OFFER?
Aeroqual’s Dust Sentry and AQS 1 are flexible air monitoring platforms used by air quality professionals and environmental/geotechnical consultants, for community air monitoring plans on remediation sites. We help environmental consultants deliver defensible data on projects by providing cost-effective and reliable instrumentation. For insights on the latest air monitoring trends at construction sites please read our blog about measuring NO2 and multiple PM fractions.