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

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 a New York State Environmental Laboratory Approval Program (ELAP) certified (6 NYCRR Section 370.1(f)) and qualified laboratory for waste classification analysis (e.g., TCLP and RCRA characteristics) to determine appropriate 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 the National Environmental Laboratory Accreditation Program (NELAP) for the analytical parameters being analyzed, so there is assurance that the laboratory has passed a nationally recognized quality assurance program that includes audits, analysis of blind performance samples to check data quality and meeting certain minimum technical standards for the qualifications of testing personnel.

Upon receipt of analytical results, determination of waste classification and identification of disposal facilities, the Environmental Consultant will identify applicable regulatory requirements for waste handling, worker training and protection (e.g., specific training/certifications, personal protection equipment [PPE]), packaging (e.g., type of packaging, marking, labeling), transporting (e.g., placarding, shipping papers), waste routing and disposing of these wastes. Since waste classification samples will be collected from in-place materials, on-site storage of deconstruction wastes for waste classification will not be required. Rather, all removed materials will be placed into their applicable disposal containers/vehicles for off-site shipment. All potentially hazardous waste will be managed as hazardous waste until analytics prove otherwise.

If greater than 100 kg/month of hazardous waste 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.

5.0 Analytical Methodologies

Analyses conducted to support waste characterization will be performed according to the following methodologies. Where more than one method is identified, each analytical method is valid per the regulations. All allowable methods are included in this plan to allow for flexibility in selecting an analytical laboratory(ies).

NYC-WTC 000134322