Harbor Point Baltimore, MD

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 • 2nd 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