DEPARTMENT OF HOMELAND SECURITY SCIENCE AND TECHNOLOGY DIRECTORATE OFFICE OF MISSION AND CAPABILITY SUPPORT FINDING OF NO SIGNIFICANT IMPACT (FONSI) FOR TRACER PARTICLE AND GAS TESTING IN NEW YORK CITY MASS TRANSIT ENVIRONMENTS AND CRITICAL INFRASTRUCTURE SUMMARY:

DEPARTMENT OF HOMELAND SECURITY
SCIENCE AND TECHNOLOGY DIRECTORATE
OFFICE OF MISSION AND CAPABILITY SUPPORT
FINDING OF NO SIGNIFICANT IMPACT (FONSI)
FOR TRACER PARTICLE AND GAS TESTING IN
NEW YORK CITY MASS TRANSIT
ENVIRONMENTS AND CRITICAL INFRASTRUCTURE
SUMMARY
Pursuant to section 102(2) (c) of the National Environmental Policy Act (NEPA) of 1969 and the Council
on Environmental Quality regulations (40 CFR Parts 1500-1508) on implementing the procedural
provisions of NEPA, the Department of Homeland Security (DHS) has conducted an Environmental
Assessment (EA) on the planned releases of aerosolized particulate material and inert tracer gases at
pre-determined locations in New York City (NYC).
The Proposed Federal Action includes tests that are scheduled to start October 2021. The Proposed
Action would include the release of low concentrations of safe particulate and gas tracer materials as
part of two projects sponsored by the DHS Science and Technology Directorate and entitled “Urban
Threat Dispersion (UTD)” and the “Chemical and Bio-defense Testbed (CBT)”. The purpose of the
tests is to collect quantitative data and information on the transport and deposition of particles that
simulate the release of a biological agent in a major metropolitan area (UTD) and to evaluate the
sensor architectures for rapid detection and mitigation of a chemical-biological event in the subway
(CBT).
The Proposed Action and the No Action Alternatives have been considered in the EA, according to the
following timelines:
UTD: Particle and gas tracer releases would occur within the two-week timeframe October 17 – October 30,
2021. There would be five separate testing days scheduled within this timeframe. Test locations include the
following outdoor locations: Times Square, World Trade Center Complex, Union Square Park. Indoor
release locations include platforms at Times Square and Union Square subway stations, as well as the
Oculus transit hub.
CBT: Particle and gas tracer releases would occur on a rolling basis starting October 2021, with the specific
schedule dependent on the pace of technology installation and funding availability. Testing would occur up
to 10 days per month, with a maximum of four test events per day. The test locations include subway
platforms at Grand Central and Times Square Stations. CBT test activities would not overlap with the UTD
test window.
The proposed particle tracers contain common substances that are not hazardous, particularly in the
quantities to be released, which in all cases are below published exposure limits by the National Institute for
Occupational Safety and Health (NIOSH). Components of the particulate material to be aerosolized include
the following:
(1) Salt, this is the same as common table salt.
(2) Glycerol, an ingredient that is added to many foods including processed fruits and frostings and is
used in many personal care products, such as soap.
(3) Maltodextrin, a common additive used in food and drink products such as beer, protein shakes, and
sweeteners such as Splenda.
(4) A fluorescent brightener that is non-hazardous and found in toothpastes and laundry detergents to
make whites appear brighter.
(5) Non-coding DNA oligos that do not have any function or biological activity. DNA is ubiquitous in
byproducts like skin and hair from all organisms, and is also present in food items like fruits,
vegetables, and meats.
(6) Amorphous silica, a common food additive in spices and creamers to ensure free flow of powdered
products and absorption of moisture.
(7) Fluorescent dye and/or proteins, which are non-toxic and allow for particle detection.
(8) Alginate-based hydrogel. Alginate is commonly used as a thickening agent in the food industry.
(9) A fluorescent powder commonly used in leak testing.
The proposed gas tracers include sulfur hexafluoride as well as perfluorocarbon tracer. Sulfur hexafluoride
is a safe gas commonly used in leak testing and already present in urban backgrounds due to its use in the
electric power industry. Perfluorocarbon tracer gases are safe, inert, odorless, colorless gases that have
been used in many similar airflow studies in the past.
The tests are being planned and coordinated in partnership with stakeholders in New York and New
Jersey, including the New York Police Department, Fire Department of New York, Department of
Health and Mental Hygiene, Metropolitan Transportation Authority, Port Authority of New York and
New Jersey, NYC Office of Emergency Management, NYC Department of Parks and Recreation, New
Jersey Department of Health, and New Jersey Transit.
The outcomes of the tests and analysis will be documented in detailed Technical Reports to DHS.
The DHS-sponsored studies will deliver evidence-based, actionable information to inform planning and
decisions that may be taken by federal, state, and local authorities to enhance and protect public health
and safety in a major urban setting. The results are expected to be transferrable to other urban
centers across the nation.
ANALYSIS OF ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
The Proposed Action would involve the release of particle and gas tracers into the human environment,
potentially during operational hours in the transit system locations. As a result, thorough review of the
potential effects on human health and the environment was performed and is documented in the EA.
The information reviewed and summarized in the EA also includes available data regarding safety to
animals, environmental decay, and pre-existing usage. The findings are summarized below.
Geology, Soils, Topography and Geological Hazards
The Proposed Action would have no significant impact on New York City topography or
geology resources since activities would occur in an already-existing urban area and transit
locations with no potential to disturb existing topography or geology.
Land Use and Planning
The Proposed Action would use existing transportation infrastructure. The Proposed Action
would not impact public transportation access or have appreciable effects on the city’s electric
system, potable water, sanity sewer and wastewater infrastructure, natural gas, or waste
management. Therefore, there would be no significant effects to land use or infrastructure
overall.
Public Health and Safety
The public may be exposed to very low concentrations of particulate and gas associated with
the test options. Exposures may include inhalation, ingestion, and dermal contact, as well as
potential exposure to re-aerosolized particulate material after the Proposed Project due to air
movement within subway station locations. Release quantities would be very low. Maximum
exposure concentrations for all proposed tracers would be well-below existing guidelines
established by the Occupational Safety and Health Administration, the Environmental
Protection Agency, and the American Conference of Governmental Industrial Hygienists for
exposure in occupational settings or for the health of sensitive populations. Impacts to the
overall public human health and safety from the Proposed Action would be less than significant.
Socioeconomics
The greater New York City metropolitan area is extremely diverse in land use and
demographics. No disproportionately high or adverse impacts on low-income populations,
minority populations or environmental justice communities are anticipated from the selected
particulate tracers. Therefore, there would be no significant effects to environmental justice
communities under the Proposed Action.
Air Quality
The Proposed Action would have little to no significant impact on air quality in the urban and
transit environments, which is already characterized by high particulate concentrations.
Therefore, impacts to air quality from the Proposed Action would be less than significant.
Noise
Existing noise within NYC results from ongoing construction activities, vehicular traffic, and
air traffic. None of the equipment or personnel due to the implementation of the Proposed
Action would generate loud noises that would increase existing noise levels. Therefore, the
Proposed Action would result in no significant impact to the existing noise environment.
Hydrology and Water Resources
There would be no significant impacts on water resources associated with the Proposed
Action as activities would occur in an already existing transit location and urban area.
Biological Resources
Four threatened or endangered species (piping plover, red knot, roseate tern, and seabeach
amaranth) reside within the county, but are all coastal species not anticipated to be present in
the subway system or metropolitan area. Any tracer materials that disseminate to appropriate
habitats would be expected to be at vanishingly low concentrations. While urban wildlife and
their habitat may be present in the proposed project area, no effect is anticipated on wildlife,
given the relatively low quantities and non-toxicity of the materials. Therefore, there would be
no effect on threatened and endangered species, to wildlife or special-status species from the
Proposed Action. According to the U.S. Fish and Wildlife Service’s (USFWS) Information for
Planning and Consultation, there is no critical habitat in the proposed project area. Therefore,
there would be no impact and no significant effects to areas with special designation from
implementation of the Proposed Action.
Cultural Resources
Many National Register of Historic Places (NRHP) listed properties and National Historic
Landmarks are present within NYC. Additionally, the NYC vicinity and surrounding area has
been inhabited by Native Americans for thousands of years and many sites remain which may
have cultural significance. There would be no ground disturbing activities or need to
permanently affix equipment to any structures or walls within subway stations. The temporary
nature of the Proposed Action would not result in visual or audible impacts or direct or indirect
effect to any contributing features of any historic properties or subway stations listed on the
NRHP. As such, the Proposed Action would have no effect on historic properties.
Hazardous Materials and Wastes
None of the Proposed Action materials are CERCLA, RCRA, or SPCC regulated hazardous
waste. Equipment used to release tracer materials with be properly stored before and after use,
and any sampling waste generated during the Proposed Action will be disposed of according to
applicable regulations. As a result, there would be no significant effects from the Proposed
Action due to hazardous materials and waste.
Impacts from Past, Present and Reasonably Foreseeable Actions
There are numerous projects occurring in NYC that may require environmental analysis and
public input. Due to the judicious selection of particulate tracer material, the relatively limited
quantity of materials to be released, and temporary nature of the Proposed Action, no impact
is anticipated on the resource areas discussed above, and would result in no significant
effects when considered with other recent past, ongoing, or reasonably foreseeable future
actions in the project area
DETERMINATION
Based on a detailed technical analysis presented in the EA, DHS finds that the Proposed Federal Action
will not have a significant impact on the human environment, either on individual release dates, or
cumulatively and is compliant with the existing national environmental policies and objectives as set forth
in the National Environmental Policy Act of 1969 (NEPA). Therefore, an Environmental Impact Statement
(EIS) is not required for the Proposed Federal Action.
Public input was solicited through an online posting of the EA with a 30-day period for public comment
and the publication in two New York City newspapers of a Legal Notice. Additionally, DHS has posted the
final EA document online (http://www.dhs.gov/nepa).
DATE DONALD A. BANSLEBEN, Ph.D.
PROGRAM MANAGER
OFFICE OF MISSION AND CAPABILITY SUPPORT
SCIENCE AND TECHNOLOGY DIRECTORATE
DEPARTMENT OF HOMELAND SECURITY
DATE MR. IAN ROSENBLUM
ENVIRONMENT, SAFETY, HEALTH, AND ENERGY
MANAGER
BUSINESS AND READINESS SUPPORT OFFICE
ADMINISTRATION AND SUPPORT DIVISION
OFFICE OF ENTERPRISE SERVICES
SCIENCE AND TECHNOLOGY DIRECTORATE
DEPARTMENT OF HOMELAND SECURITY
DATE DR. TERESA R. POHLMAN
DIRECTOR, SUSTAINABILITY AND ENVIRONMENTAL PROGRAMS
OFFICE OF THE CHIEF READINESS SUPPORT OFFICER
MANAGEMENT DIRECTORATE
DEPARTMENT OF HOMELAND SECURIT