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

The resulting cleaned material will not be sampled unless it is painted; in that instance, sampling will be performed as described in Section 7.0 of this Plan. Alternatively, based on field conditions and decisions regarding the use of its labor force, the Abatement Subcontractor may choose to not clean the surfaces and instead manage those uncleaned non-porous materials as asbestos waste at a minimum or otherwise, if required, as determined by the RCRA characteristics sampling.

4.3 Miscellaneous Materials

Due to the small scale and simple use (commercial/residential) of the buildings and their systems, additional miscellaneous regulated and/or hazardous waste is anticipated to be very limited in nature and scope. The Environmental Consultant will conduct daily inspections of the abatement work area to identify suspect components for segregation and testing and/or other determination.

Any material classified as "unknown" during the project will require sample collection and analysis for full RCRA characteristics in accordance with 40 CFR Part 261 (as described in Section 4.1.3 of this Plan) and will be disposed of based upon the results of that sampling and the nature of the waste. If the material is classified as RCRA hazardous waste, additional sampling may be required for "total" concentrations of specific contaminants to determine whether the waste may be land filled or is restricted from land disposal pursuant to 40 C.F.R. Part 268; the contaminants to be analyzed for will depend on the specific waste classification of the waste.

4.4 Structure and Facade

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 Structure & Facade of the building 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 the status of the structure and facade prior to commencement of the demolition phase.

For materials requiring sampling, a representative sampling strategy will be used as detailed in section 6.0, and composite samples representative of the final 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

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NYC-WTC 000134321