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

4.0 Sampling Frequencies

4.1 Contaminants

A full-building asbestos survey has been conducted. In-place Asbestos- Containing Building Materials (ACBM) have been identified, located and included in the Project Plan. No further characterization will be conducted unless site conditions reveal additional suspect materials not addressed in the ACBM surveys. Lead paint testing has detected only a small quantity (<100sf) of lead paint in the Building. Again, as remediation and deconstruction reveal materials heretofore uncharacterized, testing will be conducted as appropriate.

WTC dust characterization will be conducted throughout the facility in accordance with an organized sampling protocol approved by EPA, and established to ensure representativeness of sample results. On a floor-by- floor basis (16 floors), five grab samples of dust will be collected for compositing at the laboratory. These 16 samples will be analyzed in accordance with the analytical methodologies detailed in Section 5.0 (full TCLP, RCRA characteristics, total PCBs). The results of these analyses will be applied to waste sampling and management decisions for the other primary waste categories on a spatial basis relative to the source location of the applicable representative sample. Where analyses indicate that the dust exceeds RCRA criteria for any one RCRA characteristic, materials potentially impacted by the dust will be assumed to exceed that specific RCRA characteristic unless testing proves otherwise.

Details of the representative composite sampling to be conducted in response to the results of the dust characterization will be the subject of a revised WSMP to be submitted upon completion of the dust characterization study.

4.2 PPE and Remediation Process Consumables

RCRA characterization testing will be conducted on composite samples of spent filters, filter media, personal protective equipment (PPE), and other project consumables. A minimum of three grab samples will be collected at random from 10% of the packages (bags/drums) of this class of material. Grab samples from every five packages sampled will be composited for analysis. These materials will be packaged and disposed of as asbestos waste at a minimum unless hazardous waste characterization testing indicates that the material must be managed as a hazardous waste as well as an asbestos waste. Used PPE and Remediation Process Consumables will be packaged, handled and stored per the results of the dust characterization study pending RCRA hazardous waste characterization of composited samples. Locations of work that produced

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