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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

four grab samples of each distinct painted non-porous building component (based on paint color, building component type and zone in which the component is located) will be collected for TCLP RCRA metals analysis. Each grab sample will be collected as a core sample (i.e., both painted surface and building component matrix) and sent to the lab under COC for analysis.

Likewise, cleaned, painted, non-porous deconstruction waste with TCLP RCRA metals results of less than applicable standards would also be classified, managed and recycled/disposed of as non-hazardous C&D debris.

Cleaned, painted, non-porous deconstruction waste with TCLP RCRA metals results greater than applicable standards would be classified, managed and disposed of as hazardous waste with the toxicity characteristic of the exceeded RCRA Characteristic.

Cleaned, unpainted, non-porous deconstruction waste will be visually inspected by the Environmental Consultant, and may be recycled and/or disposed as C&D waste if TCLP metals analyses of surface dust wipes meet RCRA criteria for disposal. The Environmental Consultant will make determinations on representativity of waste sampling based on the quantity and nature of such wastes encountered. In general, the protocols followed for representavity other site waste sampling, and as described in Section 6.0 will be followed.

Non-cleaned, non-porous deconstruction waste will be disposed of as asbestos waste at a minimum for the reasons indicated previously. Should results of the settled dust classification sampling indicate that the dust results exceed the regulatory threshold for one or more RCRA characteristics, the waste will be managed as both a RCRA waste of the appropriate waste code as well as asbestos waste.

8.0 Waste Packaging

Due to space restrictions (i.e., requirement that a waste storage facility be located 15 meters (50 feet) from a property line), waste will be not be stored on the site. Incompatible waste streams will be segregated and handled as separate operations at separate times. All containers on site will have proper labeling, which includes information such as waste type and accumulation date.

8.1 Hazardous Waste

Hazardous waste will be placed in containers (e.g., USDOT approved drums, bags, roll-off containers) and transferred to the waste decon for immediate off-site disposal. While being accumulated on-site, each container shall be labeled or marked clearly with the words, "Hazardous Waste". Containers will be inspected to ensure containers are not over packed or leaking. Hazardous waste will not be placed in an unwashed container that previously held an incompatible waste. Any disposal container holding a hazardous waste that is incompatible with any waste or other materials contained nearby will be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.

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NYC-WTC 000134329

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NYC-WTC_000134329Source: NYC Law Department, mirrored locally

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