Permit application Part IV, management plan Jan 2006

NYC 9/11 Public Portal Document

Regulatory Submittal Part IV- Waste Sampling & Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project 05-0867 — January l0, 2006

hazardous waste and DOT regulations. The Remediation Contractor will be required to identify and apply the specific regulatory programs applicable to specific waste types.

The Environmental Consultant will conduct daily inspections of the abatement work area to identify suspect components for segregation and testing and/or other determination.

Any material classified as "unknown" during the project will require sample collection and analysis for full RCRA characteristics in accordance with 40 CFR Part 261 and will be disposed of based upon the results of that sampling and the nature of the waste. If the material is classified as RCRA hazardous waste, additional sampling may be required for "total" concentrations of specific contaminants to determine whether the waste may be land filled or is restricted from land disposal pursuant to 40 C.F.R. Part 268; the contaminants to be analyzed for will depend on the specific waste classification of the waste.

If additional categories of waste that are suspected to have different waste characteristics than those sampled are observed during the work, these materials will be sampled for waste characterization prior to removal. Materials similar in composition and WTC impact to those sampled would not be sampled for Resource Conservation and Recovery Act (RCRA) characteristics unless there is an independent concern that they might be hazardous waste due to the inherent composition of the component, subcomponent or waste stream.

4.7 Non-Porous (Cleanable) Waste

Non-Porous Deconstruction Waste may be managed by either of two options. The Remediation Contractor may choose to clean (HEPA vacuum and wet-wipe) the non-porous surfaces in accordance with procedures outlined in Section 6.3.5 of Regulatory Submittal Part I- Work Plan. The resulting cleaned material would be subject to visual inspection by the Environmental Consultant, but will not be sampled unless it is painted; in which case, representative sampling for TCLP Metals will be performed. Alternatively, based on field conditions and decisions regarding the use of its labor force, the Remediation Contractor may choose not to clean the surfaces and instead manage those uncleaned non-porous materials as asbestos waste at a minimum and as required by the determinations of the dust characterization study. In either case, the methods of cleaning packaging, transport and disposal of these wastes shall be in strict accordance with applicable regulations and the site-specific Health & Safety Plan, and shall be equally protective of site workers and the environment.

10

NYC-WTC 000095843