Firm Description: Haley & Aldrich of New York

Qualified Environmental Professional (QEP) Oversight: Haley & Aldrich of New York serves as the primary environmental consultant and designated Qualified Environmental Professional (QEP) for the remediation of the 300-302 West 128th Street site. Their technical leadership is foundational to the Remedial Action Work Plan (RAWP), ensuring that all investigation and cleanup activities meet the rigorous standards of the New York State Brownfield Cleanup Program (BCP).
Remedial Engineer (RE) Certification: The firm provides the Remedial Engineer of record, a New York State Licensed Professional Engineer (PE). This individual is legally responsible for certifying the Final Engineering Report (FER), verifying that the remedial actions were conducted in strict accordance with the NYSDEC-approved plans. Their role involves meticulous oversight of the 15-foot mass excavation and the installation of engineering controls like the 20-mil vapor barrier.
Historical Site Investigation Leadership: Haley & Aldrich conducted the comprehensive Remedial Investigation (RI) that defined the site's environmental profile. They identified elevated levels of Semi-Volatile Organic Compounds (SVOCs) and metals, specifically lead and mercury, in the site's historic fill. This data was critical in delineating the "hot spots" that require hazardous waste management under RCRA protocols.
Regulatory Liaison and Reporting Authority: As the consultant for the Volunteer (West 128th Street Owner LLC), Haley & Aldrich manages all technical communications with the New York State Department of Environmental Conservation (NYSDEC) and the New York State Department of Health (NYSDOH). Their responsibilities include the preparation of Daily and Monthly Progress Reports, as well as the management of the document repository for public transparency.
Health and Safety Stewardship: The firm is responsible for the implementation of the Site-Specific Health and Safety Plan (HASP) and the Community Air Monitoring Plan (CAMP). Their field technicians utilize photoionization detectors (PIDs) and particulate meters to monitor air quality in real-time at the site boundaries, ensuring that excavation activities do not impact the surrounding Harlem residential community.
Engineering Control Design and Inspection: Haley & Aldrich designed and will inspect the installation of the Engineering Controls (ECs) required for the site. This includes the composite cover system, consisting of the building foundation and slab, and the sub-slab vapor barrier. Their inspections ensure that the barrier system is sealed at all penetrations and transitions to mitigate soil vapor intrusion risk.
Quality Assurance Project Plan (QAPP) Management: The firm enforces a robust QAPP to maintain the integrity of all environmental data. This includes standardized sampling protocols for soil endpoints and groundwater, laboratory coordination with ELAP-certified facilities, and the production of Data Usability Summary Reports (DUSRs) to confirm the defensibility of the remedial results.
Waste Classification and Tracking: Haley & Aldrich provides specialized expertise in waste characterization for the 13,000+ tons of fill to be excavated. They coordinate with disposal facilities to manage non-hazardous and hazardous waste streams (such as the D008 lead-contaminated soil), ensuring every load is properly manifested and tracked from the site to its final destination.
Hydrogeological Analysis for Dewatering: Leveraging their internal geology and hydrogeology teams, the firm calculated the dewatering requirements for excavations extending below the water table (approx. 10.5 to 12.5 feet bgs). This analysis informed the design of the temporary groundwater treatment system required to meet NYCDEP discharge limits.
Long-Term Site Management Planning: Haley & Aldrich is responsible for authoring the Site Management Plan (SMP) if Track 2 is not fully achieved. This document will outline the long-term monitoring, inspection, and maintenance requirements for the engineering controls, ensuring the property remains safe for its future residents and commercial tenants.

Scope of Services: Implementation of the Remedial Action

Pre-Remediation Mobilization and Permitting: The scope begins with the acquisition of all required municipal and state permits, including NYCDEP sewer discharge permits for dewatering and NYCDOB permits for site excavation and shoring. Haley & Aldrich will establish the site perimeter with 8-foot fencing, install stabilized construction entrances (truck wash-down pads), and establish a field command center for environmental monitoring.
Execution of the Community Air Monitoring Plan (CAMP): During all ground-intrusive activities, Haley & Aldrich will deploy a network of monitoring stations. These stations will measure VOCs using photoionization detectors (PIDs) and particulates using dust meters. Data will be recorded at 15-minute intervals and summarized in Daily Reports, with immediate notification protocols for any exceedances of the 5 ppm VOC or 150 µg/m³ particulate action levels.
Health and Safety Plan (HASP) Management: The firm will enforce the HASP for all on-site personnel. This includes mandatory safety briefings, the use of appropriate Personal Protective Equipment (PPE) based on the "Modified Level D" standard, and the designation of a Site Safety Officer (SSO) to oversee exclusion zones and decontamination procedures for equipment.
Bulk Soil Excavation for Track 2 Achievement: The primary remedy consists of excavating the entire 13,375-square-foot site footprint. Excavation will proceed to a depth of approximately 15 to 18 feet below ground surface (bgs). This mass removal is designed to eliminate all soil and historic fill exceeding the Track 2 Restricted-Residential Soil Cleanup Objectives (SCOs), targeting contaminants like Lead, Mercury, and SVOCs.
Delineation and Removal of Hazardous Lead Hot Spots: Based on the Remedial Investigation, the scope includes the targeted excavation of hazardous lead-impacted soil. One specific area (SB03) identified lead at 6,420 mg/kg; this material will be segregated and managed as D008 hazardous waste, requiring specialized TCLP testing and disposal at a RCRA-permitted facility.
Underground Storage Tank (UST) Closure and Removal: The scope provides contingency and protocol for the discovery of USTs. Any tank encountered will be registered with NYSDEC, emptied of contents, cleaned, and removed in accordance with DER-10 Section 5.5 and 6 NYCRR Part 613. Confirmatory soil samples will be taken from the tank grave to ensure no residual petroleum impact remains.
Dewatering and Groundwater Treatment: Excavation will penetrate the groundwater table, which is situated between 10.5 and 12.5 feet bgs. A temporary dewatering system—comprising sumps, pumps, and a treatment train involving settling tanks and carbon filtration—will be operated to maintain a dry work environment. Treated water will be sampled and discharged to the combined sewer system.
Endpoint Soil Sampling and Laboratory Analysis: Following mass excavation, Haley & Aldrich will collect endpoint soil samples from the bottom of the excavation at a frequency of one per 900 square feet. These samples will be analyzed for the "Full Suite" of parameters: VOCs (EPA 8260), SVOCs (EPA 8270), Pesticides (EPA 8081), PCBs (EPA 8082), Metals (EPA 6010), and PFAS/1,4-Dioxane as required by current NYSDEC guidance.
Importation of Clean Fill and Backfill Management: Any soil imported to the site for backfill or structural needs must be pre-approved by the NYSDEC. The scope requires sampling of imported material at the source to ensure it meets the Track 2 Restricted-Residential and Protection of Groundwater SCOs. Each source must be documented with an affidavit and laboratory data.
Installation of the 20-mil Vapor Barrier System: A critical engineering control involves the installation of a 20-mil vapor barrier (Stego Wrap or NYSDEC-approved equivalent) beneath the entire building slab and behind all sub-grade foundation walls. Haley & Aldrich will inspect all seams, penetrations, and overlaps to ensure a continuous seal against potential soil vapor intrusion from off-site sources.
Construction of the Composite Cover System: The new 11-story building’s concrete foundation and slab (approx. 24 inches thick) will serve as the permanent composite cover system. This physical barrier prevents human exposure to any residual contaminants that may remain at depths below the Track 2 excavation limits.
Institutional Control (IC) Implementation: The scope includes the administrative filing of an Environmental Easement. This legal instrument will be recorded with the NYC Register to restrict future land use to restricted-residential, commercial, or industrial applications and mandate the long-term maintenance of the ECs through the Site Management Plan.
Development of the Site Management Plan (SMP): If Track 2 is not fully achieved and residual contamination remains, Haley & Aldrich will author an SMP. This document provides the blueprint for future site use, including an Excavation Work Plan for future repairs, a monitoring plan for the cover system, and a schedule for Periodic Review Reports (PRRs).
Preparation and Certification of the Final Engineering Report (FER): The remedial phase concludes with the production of the FER. This voluminous document includes all waste manifests, endpoint data, "as-built" drawings of the engineering controls, and the Remedial Engineer’s formal certification that the cleanup meets all BCP requirements for the issuance of a Certificate of Completion (COC).
Reporting and Stakeholder Coordination: Throughout the project, the firm will coordinate with the NYSDEC Project Manager (currently Michael Sollecito) and NYSDOH. The scope includes the maintenance of a digital and physical document repository for public access, ensuring transparency throughout the remedial lifecycle.
Spill Response and Contingency: The scope includes a spill management protocol. In the event of a release of hazardous materials or petroleum during construction, Haley & Aldrich will coordinate with the NYSDEC Spill Hotline and implement immediate containment and cleanup measures as required by law.
Odors and Nuisance Control: During the handling of impacted soil, the scope mandates the use of odor suppressants (such as BioSolve or Rusmar foam) to prevent nuisance conditions for the neighborhood. Any complaints received from the community will be documented and addressed through modified work practices.

Technical Evaluation & Remedy Selection

DER-10 Evaluation Criteria

Overall Protection: Achievement of Track 2 SCOs.
Standards/Criteria: Compliance with Part 375-6.8(b).
Long-term Effectiveness: Removal of 13,000+ tons of fill.
Short-term Impacts: CAMP and HASP mitigation.
Implementability: Use of standard excavation/shoring.

Financial/Contractual Notes

As a technical RAWP submitted for public review, specific contract values between the Volunteer and the Consultant are excluded from the public record. Technical value is measured by the successful remediation of the property to allow for safe occupancy.

Regulatory Callouts

Track 2 Cleanup

Restricted-Residential SCOs achievement. Requires removal of soil/fill exceeding SCOs to 15 feet bgs or bedrock.

DER-10

NYSDEC Technical Guidance for Site Investigation and Remediation. The standard for all BCP technical protocols.

D008 Hazardous Waste

The EPA code for lead-contaminated material that fails TCLP testing (>5.0 mg/L), requiring RCRA management.

GAYA CAPITAL

NYSDEC SITE NO: C231151

300-302 West 128th St Brownfield Cleanup