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

5.1 Ignitability

The characteristic of ignitability carries the RCRA waste code of DOO1, and may be analyzed for using American Society of Testing Materials (ASTM) method D- 93-79 or D-93-80 or D-3278-78.

5.2 Corrosivity

The characteristic of corrosivity carries the RCRA waste code of D002, and may be analyzed using Method 9045D or 9040C as set forth in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. SW-846 method 9040 C is for aqueous wastes and multiphase waste where the aqueous phase constitutes at least 20% of the total volume of the waste; 9045D is for soils and waste samples where the waste may be solids, sludges, or non- aqueous liquids. The aqueous phase must be less than 20% of the total volume of the waste. National Association of Corrosion Engineers (NACE) Standard TM- 01-69 as standardized in SW-846 shall be utilized to evaluate corrosion rate if the suspected corrosive hazardous waste is a liquid.

5.3 Reactivity

The characteristic of reactivity carries the RCRA waste code of D003, and may be analyzed using the analytical methods outlined in sections 7.3.3.2 or 7.3.4.2 of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. The referenced sections are from SW-846 Chapter Seven: Characteristics Introduction and Regulatory Definitions. They are specifically for Reactivity. Chapter Seven was revised to reflect the withdrawal of the reactive cyanide and sulfide guidance in sections 7.3.3 ("Interim Guidance for Reactive Cyanide") and 7.3.4 ("Interim Guidance for Reactive Sulfide"), and to replace certain characteristic explanatory text with referrals to the regulations themselves. This change can be found in the Proposed Update IIIB to SW-846.

5.4 Toxicity

The characteristics of toxicity carry the RCRA waste codes of D004 through D043. Each waste code identifies the specific chemical component for which the waste is classified as toxic. The samples to be analyzed for the characteristic of toxicity must be prepared using the Toxicity Characteristic Leaching Procedures (TCLP) per Method 1311 in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. The analytical method applied to the resulting leachate depends on the type of chemical being analyzed for, as follows:

— Volatile organic compound (VOC) toxic constituents will be analyzed by Method 8260B of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. VOC toxic constituents include benzene (DO18), carbon tetrachloride (DO19),

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