1. Harbor Point Baltimore, MD An Air Monitoring Odyssey

2. Background How we got involved with a $1.8 billion (yup, BILLION) dollar redevelopment project How we found out when ambient air monitoring is not ambient air monitoring How we figured out a way to prevail! Lessons learned

3. The Story Our journey began when we were alerted by Dave Krask, MDE in Sept. 2013. A RCRA site (formerly Allied Signal Baltimore Works— for chromium processing production, now Honeywell) located at the Inner Harbor in Baltimore was slated for redevelopment. Honeywell was under a consent decree which required EPA and MDE approval for any redevelopment. A previously approved air monitoring plan required the establishment of action levels for particulates and hexavalent chromium.

4. The Story Results from the preconstruction air monitoring was submitted for review. Results for hexavalent chromium (Cr+6) was as high as 23 nanograms/cubic meter, whereas the national average was 5 nanograms/cubic meter from the School Air Toxics study. 23 ng/m3 equates to a >>1E-04 lifetime cancer risk (5 ng/m3 is 1E-06 lifetime cancer risk) Potentially, we had a big problem facing us.

5. The Situation Investment for project is $1.8 billion, with the city issuing $107 million in bonds Highly political Developer wanted construction to commence in November 2013 Community concerns Many players MDE: RCRA and Air Monitoring EPA: LCD and APD The Developer Contractors

6. Preconstruction Monitoring Plan Initial Submission and Results

7. 12 Monitors, rotating 7 monitors at any one week

8. Offsite monitors

9. When is Ambient Air Monitoring not Ambient Air Monitoring? Report submitted Inexplicable wide ranges of Cr+6 measurements at a variety of locations Onsite: <0.7 to 8.1 ng/m3 Offsite: <0.7 to 23.0 ng/m3 High concentrations of Cr+6 were measured but we could not determine any existing sources Attempted to establish a relationship between Total PM/PM10 with Cr+6 Indicated QA/QC procedures were not followed consistently (instruments not calibrated, data not qualified, incorrect field sheets, etc.)

10. When is Ambient Air Monitoring not Ambient Air Monitoring? We found the following: Developer used OSHA industrial standards (OSHA ID 215), essentially personal monitoring method, to measure Cr+6 Monitoring equipment was foreign to us; even so, some monitors were not sited properly from an ambient air POV Developer was linking total PM with Cr+6 to generate a Background Threshold Value*/Action Level QAPP and Laboratory Analytical Methods lacked accuracy and consistency *BTV: Statistically derived confidence bounds, 95 percent Upper Prediction Limit

11. The Response We worked with our colleagues in R3 Land and Chemicals Division and MDE air monitoring and RCRA Required/Determined ASTM Standard D7614-12 for Cr+6 (formerly EPA modified CARB 039) Total PM cannot be used as a surrogate for Cr+6 Extensive changes to QA/QC protocols Third party data validation Changes to monitoring sites: reduced number of offsite and onsite monitors, dropped PM10 monitoring

13. Preconstruction Air Monitoring Results: Round 2 2 nd round of pre-construction monitoring—15 days Much of the Cr+6 onsite results were non-detects or ranged from 0.02-0.03 ng/m3 The highest offsite result was 0.15 ng/m3 QA/QC protocols and measures were followed based on laboratory and data validation reports EPA/MDE approved plans, construction to commence May 2014

14. Lessons Learned We were able to apply our skillsets to a completely new endeavor We learned how to work with differing perspectives on air quality Established and forged relationships between programs Communication was essential--both internal and external It’s good to have a united front

15. Next Steps Construction begins in May 2014 We plan to make site visits to observe construction monitoring in the next several months