NYC 9/11 Public Portal Document
Regulatory Submittal Pan IV- Waste Sampling & Management Plan
Fiterman Hall 30 West Broadway, New York, New York
Airtek Project 05-0867 — January I0, 2006
impacted by dust (i.e., the Deconstruction Waste listed in subsection 2.3
above) will be assumed to be non-hazardous for handling and disposal
purposes.
This assumption will be applied to all deconstruction waste that is not
suspected to be hazardous waste based on its original (pre-9/1 1)
composition.
• Where analytical results indicate that dust in a portion of the building is
classified as a particular category of regulated waste, then dust-impacted
materials in that portion of the building will be likewise classified until
and unless testing indicates otherwise.
Any material suspected to be hazardous waste or other RCRA —regulated
waste will be tested and evaluated based on its composition.
For materials requiring sampling, a representative sampling strategy will be used
as detailed in Section 4.0, and composite samples representative of the suspect
waste streams will be collected. The locations and frequency of samples to be
combined into composite samples shall be determined by the Environmental
Consultant such that a representative sample of the waste type has been obtained.
All sampling personnel shall be familiar with sample collection and waste storage
protocols and shall have undergone Hazard Communication training in
accordance with 29 CFR Section 1910.1200 as well as being trained appropriately
per the Health and Safety Plan.
The waste classification samples will be sent to laboratories accredited by the
NYS Department of Health under the NELAC Program, certified under 6
NYCRR Section 370.1(f), and qualified for waste classification analysis (e.g.,
TCLP and RCRA characteristics). Testing will determine waste classification and
handling requirements (40 CFR Section 262.11). Other sampling and laboratory
analysis may be required by the disposal facility prior to waste acceptance. The
laboratory subcontracted to perform the analysis will be also be certified through
NELAC for the analytical parameters being analyzed.
All potentially hazardous waste will be managed as: hazardous waste until
analytics prove otherwise. If greater than 100 kg/month of hazardous waste is
generated during the deconstruction process, Contractor will comply with, among
other things, 6 NYCRR Part 373, Subpart 373-3, section 373-3.3(b).
If results of waste characterization sampling and analysis dictate that waste
material must be managed and disposed of as both an asbestos and a hazardous
waste, both asbestos and hazardous waste management and disposal requirements
will be met. If there are conflicts between the requirements for asbestos and
hazardous waste that preclude compliance with both, then the hazardous waste
requirements will dictate specific management and disposal requirements.
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