EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part IV- Waste Management Plan 133-135 Greenwich Streetl21-23 Thames Street Airtek Project 05-0701— Rev 1, September 16, 2005

6.0 Sampling Frequencies and Disposal

6.1 Contaminants

The limited ACBMs at the site have been identified and located. Limited WTC Dust sampling has been conducted. Where further WTC dust can be identified, further sampling will be conducted to support waste classification prior to removals off-site. Detailed information on sampling locations will be documented. A detailed sampling scheme cannot be developed until further dust is encountered. Where possible, each floor of each building will represented within any composite sample.

6.2 Deconstruction Waste

For each of the Deconstruction Waste Materials listed in section 2.2 above, a minimum of five confirmatory waste samples will be collected from different locations and functional spaces in each building (a minimum of five samples per building, with each floor of each building represented. Each building's samples will be composited for analysis (one analysis per material, per building). Where it is deemed appropriate by the Environmental Consultant, more samples may be collected and analyzed. Results will be available prior to the commencement of site removals.

6.3 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. The Environmental Consultant will make determinations as to the appropriate testing required to characterize any materials encountered. Where possible, each floor of each building will represented within any composite sample of miscellanoues waste, and the minimum of five grab samples to composited will be observed.

In general, the following will apply:

6.3.1 Light Ballasts and other PCB Wastes:

During deconstruction activities, as ballasts are removed from lighting fixtures, the Abatement Subcontractor shall clean the surfaces of dust and containerize ballasts for disposal as PCB waste. All ballasts, including those labeled "No PCB" will be containerized for disposal as PCB waste due to the presence of potting material. For potentially PCB-containing equipment other than ballasts, PCB samples may be required to determine whether the dielectric fluid contains more than 50 parts per million (ppm)

NYC-WTC 000134325