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

asbestos-containing wastes at a minimum. Sampling representability will be as described in section 6.2.

6.3.5 Fuel

No Fuel Storage is known to exist at the site. Heat for both buildings was generated by natural gas from the street. Kitchen equipment was fuelled by the same gas system, and by electricity. Two Phase I Environmental Site Assessments were conducted for the site. Neither assessment identified fuel sources or suspected fuel sources.

6.3.6 Fire Extinguishers

In the case of both charged and discharged fire extinguishers, the manufacturer of the fire extinguisher will be contacted for the proper discharge and disposal method. Alternately, local fire department(s) may be contacted to determine if they would like to acquire the charged fire extinguishers in volunteer or community training exercises. If the above approaches prove impractical, fire extinguishers shall be depressurized in accordance with manufacture's recommendations and all regulatory requirements. Contained media shall be collect upon depressurization, characterized, and recycled or disposed, if and as required. Empty extinguisher bodies shall be rendered inoperable by cutting in half or puncturing, then recycling as scrap metal or disposing as municipal solid waste. If fire extinguishers are found, the Environmental Consultant will make a determination.

6.4 Structure & Façade

Sampling of the structure and facade materials will be conducted to confirm the waste status of the structure and facade prior to commencement of the demolition phase. For each of the structural and facade material categories noted at the site, five confirmatory waste samples will be collected and composited for analysis (one analysis per material, per building). Samples will be collected from various locations and functional spaces within each building. Sample representability will be as described in Section 6.2. Results will be available prior to the commencement of the demolition phase.

7.0 Non-porous (cleanable) Waste

For cleaned (wet-wiped/HEPA-vacuumed) non-porous deconstruction waste, TCLP Metals samples will not be collected unless the non-porous components are painted and to be disposed of (i.e., not recycled). Cleaned painted scrap metals that are recycled are exempt from the below described waste characterization sampling and analysis. For non- porous components that are painted, one composite sample made up of a minimum of

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NYC-WTC 000134328