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Harbor Point Baltimore, MD An Air Monitoring Odyssey.

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Presentation on theme: "Harbor Point Baltimore, MD An Air Monitoring Odyssey."— Presentation transcript:

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

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