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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

chlorobenzene (D021), chloroform (D022), 1,4-dichlorobenzene (D027), 1,2- dichloroethane (D028), 1,1-dichloroethylene (D029), methyl ethyl ketone (D035), tetrachloroethylene (D039), trichloroethylene (D040), and vinyl chloride (D043).

- Semivolatile organic compound (SVOC) toxic constituents will be analyzed by Method 8270C of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. SVOC toxic constituents include 2,4-dinitrotoluene (D030), hexachlorobenzene (D032), hexachlorobutadiene (D033), hexachloroethane (D034), o-cresol (D023), m- cresol (D024), p-cresol (D025), cresol (D026), nitrobenzene (D036), pentachlorophenol (D037), pyridine (D038), 2,4,5-trichlorophenol (D041), and 2,4,6-trichlorophenol (D042).

toxic constituents will be analyzed by Method 8081A of "Test "e:o or Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. Pesticide toxic constituents include chlordane (D020), endrin (D012), heptachlor and its epoxide (D031), lindane (D013), methoxychlor (DO14), and toxaphene (D015).

LHerblic/ideoxic constituents will be analyzed by Method 8151A of "Test Evaluating Solid Waste, Physical/Chemical Methods," EPA W-846. Herbicide toxic constituents include 2,4-D (D016) and 2,4,5-TP (also known as Silvex, D017).

- Mercury (D009) will be analyzed by Method 7470A (aqueous samples) of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846.

- Metals/inorganics other than mercury will be analyzed by Method 6010B of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. These constituents include arsenic (D004), barium (D005), cadmium (D006), chromium (D007), lead (D008), selenium (DO10), and silver (DO11).

Generally, building components would not be considered as possible RCRA characteristic wastes except for the potential that exists due to impacts by WTC dust. The notable exceptions to this would be painted surfaces (which would typically be sampled for TCLP RCRA Metals), as well as miscellaneous materials containing hazardous components prior to WTC impact (such as transformers, ballasts, lamps, etc.).

The results of RCRA characteristic analyses, the classification of the material based on historical information, as well as the material's status as presumptively asbestos-contaminated, will be used as the basis for the Waste Profile for the particular waste stream.

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NYC-WTC 000134324

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NYC-WTC_000134324Source: NYC Law Department, mirrored locally

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