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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

PCBs, which would make the equipment subject to the PCB regulations. SW-846 Method 8082, Analysis of Polychlorinated Biphenyls by Gas Chromatography is specified by regulation for determining the concentration of PCBs in wastes.

Ballasts (all assumed to contain PCBs) shall be handled, packaged and labeled as required for disposal as a PCB regulated waste. All hauler, transportation and disposal facility requirements shall also conform to the requirements for this category of waste.

Shipments of PCB waste must be in properly labeled and marked containers, the waste must be shipped under a properly executed manifest and Land Disposal Restriction (LDR) form, the transporter must have a valid EPA Identification number and must have a valid New York State Part 364 transporter permit as well as the latest version of U.S. Department of Transportation's Emergency Response Guide (2004). The vehicle in which PCB wastes are being shipped must be properly placarded and marked to reflect that it is transporting PCBs and must also be marked with the New York State waste transporter permit number on its sides and rear.

Disposal facilities that accept PCB wastes must have an EPA Identification number and have received TSCA authorization from the EPA and any additional state permits for the disposal/management of PCBs applicable to the state in which the facility is located. The disposal facility must comply with all manifesting requirements specified in the regulations and must prepare a certificate of destruction and send it to the generator or the generator's agent.

6.3.2 Universal Waste

Only minor quantities of materials that could be categorized as Universal Waste are anticipated to be encountered at this site. In the event that such materials are encountered, they are addressed by this WMP.

40 CFR Part 273 and 6 NYCRR Section 374.3 establish requirements for managing universal wastes. Universal wastes are those wastes that would reasonably be expected to be classified as hazardous wastes but, due to their universal use in industrial and residential properties, regulations were created that would ensure that they were managed in a manner that prevented harm to the environment while reducing the regulatory burden on generators of these wastes.

Universal wastes include the following waste types:

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