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

Results of the sample have been compared to criteria provided in 40 CFR Part 261 sections 21 through 24 and Environmental Protection Agency Publication SW 846 Chapter 7. The sample does not exceed the criteria provided in 40 CFR Part 261 sections 21 through 23 or SW 846 Chapter 7.

Given the limited nature of the sampling, no broad conclusions on waste characterization can be drawn from these results.

4.0 Waste Characterization Strategy

Waste generated during the project will be characterized, managed, transported and disposed of in compliance with this Waste Management Plan and applicable regulations.

4.1 Contaminants

Full-building asbestos surveys have been conducted. In-place ACBM has 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.

WTC Dust is assumed to exist at the site.

4.2 Deconstruction Waste

Dust sampling for hazardous waste characteristics has been performed in advance of sampling of materials impacted by dust. It is anticipated that the dust classification sampling will indicate that the dust is not a characteristic hazardous waste, and then by extension, any non-hazardous materials potentially impacted by dust (i.e., the Deconstruction Waste listed in subsection 2.2 above) would also not be hazardous. Due to the limited nature of the preliminary sampling, confirmatory sampling of the various deconstruction waste categories will be conducted to confirm this prior to commencement of any site work.

Those materials would then not be sampled for Resource Conservation and Recovery Act (RCRA) characteristics unless there is an independent concern that they might be hazardous waste due to the inherent composition of the component, subcomponent or waste stream (e.g., light ballasts which may contain PCBs, items coated with lead-based paint).

Porous deconstruction waste will be disposed of according to the results of waste characterization sampling, and as ACM at a minimum.

Non-Porous Deconstruction Waste may be managed by either of two options. The Abatement Subcontractor may choose to clean the non- porous surfaces in accordance with procedures outlined in the Work Plan.

NYC-WTC 000134320

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NYC-WTC_000134320Source: NYC Law Department, mirrored locally

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