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EPA review letter, 133-135 Greenwich Street

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US EPA Region 2 letter dated November 15, 2005, confirming completion of environmental review for abatement plans at 133-135 Greenwich Street.

NYC-WTC_000134132–000134414
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NYC 9/11 Public Portal Document

Part III — Health & Safety Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— Rev 3, August 29, 2005

2.2.4 Chemical Hazards

A chemical hazard that may be encountered during this project is asbestos. Based upon the most recent pre-demolition asbestos survey conducted by Airtek environmental Corp., approximately 50 linear feet of friable, and 400 square feet of non-friable asbestos-containing material has been identified. In addition, WTC dust with assumed varying concentrations of COPCs, has been identified during visual inspection of the site. Therefore, the Contractor shall ensure that all site employees receive the required training concerning asbestos as well as all applicable Hazard Communication training.

In addition, personnel who have the potential to disturb ACBM shall be trained concerning the procedures to be used and requirements for notifications in accordance with federal, state and local regulations. Personnel who handle ACBM on this job shall have the required documented training and certificates. Each employee involved in abatement activities must have completed City of New York asbestos training, shall be a certified asbestos worker and/or supervisor by the City of New York, and shall be certified asbestos handler and/or supervisor by the New York State Department of Labor. Additionally, personnel who will conduct cleaning and abatement activities must have additionally received the required 40-hour training as outlined by 29 CFR 1910.120(a) (i) (HAZWOPER requirement) and appropriate annual refresher training as required. This HAZWOPER training requirement may be removed, should sampling indicate training requirement downgrade is appropriate. Training, medical and license documentation for each Subcontractor employee shall be verified by the CSO prior to start of work by the Subcontractor.

2.2.4.1 Additional Identified Chemicals

Other chemicals identified as potential contaminants that may be encountered during the initial site cleaning activities are PAHs, dioxins, antimony, cadmium, nickel, barium, chromium, lead, zinc, manganese, copper, beryllium, PCBs, mercury, copper, zinc, cristobalite and quartz.

Environmental sampling in the neighboring buildings has verified the presence of these chemical contaminants in WTC dust in concentrations exceeding USEPA's Residential Cleanup Criteria.

Additional chemical hazards generated from deconstruction activities would be lead, cadmium, and chromium from coated surfaces. Subcontractors shall perform personnel monitoring for all COPCs as required by OSHA. In addition, Subcontractors must provide applicable OSHA training for the identified hazards. Documentation of this training must be provided by the Subcontractor.

Precautions to be taken during the removal of miscellaneous hazardous materials (bulbs, ballasts, batteries, mercury-containing thermostats, etc) are found in Table 2-1, Task 3. Respiratory protection, as identified within Table 2-1, represents the minimum level of protection for all identified tasks.

There may also be hazardous chemicals brought on-site and used in the deconstruction. The requirements of the OSHA Hazard Coxmunications Standard (29 CFR 1910.1200) shall apply.

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NYC-WTC 000134286

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NYC-WTC_000134286Source: NYC Law Department, mirrored locally

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