Community Air Monitoring Plan

Community Air Monitoring Station
Community Air Monitoring Station

Protects surrounding community by continuously monitoring the air for dust and volatile organic compounds (VOCs) during investigations, remedial activity, and future construction.

Air Monitoring Includes:

  • Real time VOC and dust monitoring using direct reading instruments;
  • Upwind and downwind monitoring locations; and,
  • CAMP action levels
    • If action levels are exceeded work practices will be re-evaluated to reduce potential migration of site impacts
    • CAMP data will be available for public review

The New York State Department of Environmental Conservation and the New York State Department of Health (DEC and DOH respectively) will approve a Community Air Monitoring Plan (CAMP) that requires continuous upwind and downwind air monitoring during all excavation, soil handling and backfilling activities. This will be implemented to ensure no additional dust, particulates or VOCs are released beyond the work zone to the environment or surrounding community during the cleanup activities. The air monitoring stations check for dust particulates and VOCs using real-time monitoring equipment. Results are compared to the airborne action level standards and will be provided to NYSDOH and NYSDEC for review. The equipment employs an audible alarm to indicate exceedance of the action level so corrective measures (such as wetting down the area) can be taken immediately. The CAMP requires no visual dust moving outside the work area, and wetting down dry materials as necessary. The air monitoring equipment is sensitive and will detect very low levels of VOCs or dust particles in the air, typically before you can see them with your eyes. If dust is observed, either by the personnel at the site, or if it is detected above action levels with the air monitoring equipment, the work will be stopped, and corrective actions will be taken. Additional controls require trucks to be covered to properly secure all excavated material during transport across the site or for disposal off-site at a permitted facility.

Potential release of contaminated dust or volatile organic compounds (VOC) vapors to the outdoor air during remedial activity is controlled by:

  • Community Air Monitoring Plan – protects the surrounding community by continuously monitoring the air for dust or VOC vapors during investigative or remedial activities; and
  • Engineering controls will be in place to minimize dust generation and prevent access to the work area. These controls include watering of excavations/soil, covering of stockpiles and other best practices to reduce migration of contaminated materials.


All New York State employees, on-site contractors and personnel associated with investigation or remedial efforts will comply with all NYS Covid-19 regulations.

For more information on the NYS Covid-19 Response:
Covid-19 Hotline: 1-888-364-3065


Exposure is physical contact with a chemical or substance. Without exposure, you cannot be harmed by a substance. There are three main routes of exposure including inhalation, direct contact, and ingestion.

One or more of these physical contacts must occur before a chemical has the potential to cause a health problem. Exposure does not necessarily mean that a health effect will occur. Access to the site is currently restricted which prevents exposure to site related impacts in soil and groundwater. Additionally, the site and surrounding community receive drinking water from a public water supply that is not affected by this contamination.

Inhalation – breathing in dust or vapors from remediation areas

This can occur via soil vapor intrusion, which is the process by which volatile chemicals move from a subsurface source into the indoor air of an overlying building. Specific to the site,

  • There are no occupied buildings on-site, therefore no current exposures; and,
  • Soil Vapor Intrusion will be evaluated for all future occupied buildings
Diagram depicting soil vapor intrusion risks

Diagram depicting soil vapor intrusion risks

Direct Contact – getting contaminated soil, groundwater, surface water or sediment on your skin or in your eyes.

Contact to Soil: Exposure can occur due to the presence of Semi-Volatile Organic Compounds (SVOCs), Volatile Organic Compounds (VOCs), or Metals:

  • Persons who enter the site could contact contaminants in the soil by walking on the site, digging or otherwise disturbing these areas
    • The site is partially fenced, gated, and has signage to restrict current access
  • Site remedy will remove or consolidate impacts and will include cover systems to prevent direct contact with remaining site impacts
    • Site cover will include at least 1 foot of soil meeting the soil cleanup objectives

Contact to Sediment and/or Surface Water: Exposure can occur due to the presence of Polychlorinated biphenyls (PCB), Metals, or Polycyclic Aromatic Hydrocarbons (PAH):

  • Persons who enter the site or use the waterways may come in contact with impacted sediment or surface water; and,
  • Site remedy will include removal of impacted sediments and restoration of the waterbody areas in the upper and lower reach of Smokes Creek, South Return Water Trench and Gateway Metroport Ship Canal.

Ingestion – eating or drinking something that has contaminated soil, groundwater, surface water or sediment on it

People are not drinking contaminated groundwater as the area is served by a public water supply that is not affected by this contamination.

Current fish advisories for Lake Erie, adjacent to the site, include:

Waterbody Fish Type Men Over 15 & Women Over 50 Women under 50 & Children Under 15 Chemicals of Concern
Lake Erie Rock bass, Yellow perch , Burbot Up to 4 meals per month Up to 4 meals per month PCBs
Carp, Channel catfish Up to 1 meal per month DON’T EAT PCBs
All other fish Up to 4 meals per month Up to 1 meal per month PCBs

*NOTE* This fish advisory is not directly related to Bethlehem Steel impacts, and there are currently no fish advisories for Smokes Creek.

Post Remedy Exposure Pathway Management

Exposure to remaining site impacts will be prevented through a Site Management Plan that outlines the required institutional and engineering controls. This includes:

  • Site Monitoring and Management of Remedial Elements:
    • Monitoring of soil, sediment, groundwater, bank soil and surface water to evaluate effectiveness of the remedy
    • Monitoring of the site cover system, Corrective Action Management Unit (CAMU) and Enhanced Groundwater Extraction systems and occupied structures
    • Required notification and approval for future activities (i.e., construction of new buildings)
  • Restrict use of the site to commercial or industrial uses, and limit groundwater or surface water use for drinking, or manufacturing/industrial processes unless there is specific approval by NYSDOH or Erie County Health Department