EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part IV- Waste Management Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— Rev 1, September 16, 2005

Commercial/Residential Lessee Items Transient Resident Items

2.4 Structure & Façade

At completion of the Abatement Phase only the wooden framing and exterior masonry & metal facade materials of the buildings will remain. The interior materials will have been spray-encapsulated, and the exteriors will have been low-pressure washed.

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 Waste Characterization Background Data

Illustrative data and the limited site data available are useful for overall project planning, but this data is not intended to substitute actual waste stream sampling to be conducted by the Environmental Consultant.

3.1 Illustrative Data — 130 Liberty Street

The TRC Preliminary Waste Characterization Study conducted at 130 Liberty Street, 50 feet from the subject site, indicated the following: "Fourteen representative composite bulk dust (six samples) and anticipated waste stream/building material (eight) samples were collected on various floors of the Building and analyzed for Resource Conservation and Recovery Act (RCRA) Characteristics and full Toxicity Characteristic Leaching Procedure (TCLP) analysis. Results of the 14 samples were compared to criteria provided in 40 CFR Part 261 sections 21 through 24 and Environmental Protection Agency Publication SW 846 Chapter 7. None of the 14 samples collected exceed the criteria provided in 40 CFR Part 261 sections 21 through 23 or SW 846 Chapter 7. None of the eight building material samples exceeded the Maximum Concentration of Contamination for the Toxicity Characteristics provided in 40 CFR section 261.24. One of the six composite bulk dust samples, collected in a mechanical room on the 40th floor, exhibited levels of cadmium that exceeded 40 CFR section 261.24. This sample exceeded the cadmium maximum concentration of 1.0 mg/L with a result of 6.2 mg/L. (Additional sampling will be conducted to determine whether specific equipment or surface coatings in the 40th Floor mechanical room contributed to the cadmium levels.)."

3.2 Site Data

Although dust available for sampling at the subject site is very limited (Obvious WTC Dust impact was noted only in the kitchen of the second floor of the 133- 135 Greenwich Street Building), dust sampling and TCLP analysis was conducted on one sample composited from samples collected in three areas of the above- referenced kitchen. Compositing of the samples was required in order to meet the total mass requirements of the analytical method.

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NYC-WTC 000134319