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 10, 2006

2.7 Non-Porous (Cleanable) Waste

Certain non-porous deconstruction waste such as unpainted scrap metals may be cleaned and classified, managed, and recycled/disposed of as non- hazardous C&D debris. Cleaned, painted, non-porous deconstruction waste with waste characterization greater than applicable standards would be classified, managed and disposed of as hazardous waste with the toxicity characteristic of the exceeded Resource Conservation and Recovery Act (RCRA) characteristic. Non-cleaned, non-porous deconstruction waste will be disposed of as asbestos waste at a minimum, and in accordance with the determinations of the dust characterization study that is discussed in Section 4.1.

2.8 Structure & Façade

At completion of the Remediation Phase only the steel, concrete and glass structural components and exterior masonry & metal facade materials of the buildings will remain. The interior materials will have been decontaminated as a part of the Remediation Phase, and focused cleaning of exterior facade components will have been conducted. The exceptions to this are specific non-friable asbestos-containing components of the facade that will be abated and managed per a site-specific variance from the NYS Department of Labor (NYS DOL), and disposed as ACM waste at a minimum.

The classification of building components and contents will be an ongoing effort and will be conducted by the Environmental Consultant in accordance with applicable New York City, New York State and federal laws, rules, and regulations. This Plan is intended as a working document to be used during ongoing operations at the Site, and will be updated as necessary as new information becomes available.

3.0 Overall Waste Characterization Stratewy

As was proposed at 130 Liberty Street by the Lower Manhattan Development Corp. (LMDC), samples of WTC dust will be collected throughout the 30 West Broadway structure and analyzed for Full TCLP, RCRA Characteristics and Total PCBs. Sample site selection will be designed to be representative of the various conditions noted throughout the structure. Representativeness of the sampling plan is discussed in Section 4.0. Results of these samples will be compared to the criteria provided in 40 CFR Part 261 sections 21 through 24 and Environmental Protection Agency Publication SW 846 Chapter 7. The results of these comparisons will inform further waste characterization sampling activities as follows:

• Where dust classification sampling indicates that the dust is not a characteristic hazardous waste, any non-hazardous materials potentially

NYC-WTC 000095839