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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 W- Waste Management Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— Rev 1, September 16, 2005

8.2 Universal Waste

Universal waste will be treated as a separate operation at a separate time according to hazardous waste regulations. See 8.1 above.

Q:3) Asbestos Waste

Waste containing asbestos will be wet down to prevent visible emissions of asbestos dust into the air. The asbestos waste will be sealed while wet in a leak- tight container. A supply of leak tight containers will be kept in the waste storage area to provide adequate repackaging if a break in the container should occur. Storage area shall be maintained under a negative pressure ventilation system. Daily inspections of the waste storage area shall be required. R Q ~, ; c'-cI 5l "-s e -Xvcv- p Storage of asbestos waste will not exceed 50 cubic yards. Authorization from the New York City Department of Sanitation (NYCDOS) and additional requirements, per code, will be required if accumulation of asbestos is anticipated to be greater than 50 cubic yards. Containers holding asbestos waste will be inspected daily to ensure no visible emissions of asbestos dust in the air or breaks in the container.

8.4 Exterior Wash Water

Wash water collected per the Work Plan shall be pumped to new, clean 55-gallon drums. Aliquots from each drum of wash water will be collected. For each day of work, the aliquots will be composited into one sample to be analyzed for Full TCLP and RCRA characteristics. If the water is not regulated under RCRA, it will be filtered through a 5 micron filter prior to disposal to the NYC sewer system per NYC Title 15, Part 1-82 (b) 1. If testing indicates the water is regulated under RCRA, it will be handled, packaged and disposed of in strict accordance with its categorization. Until its determination as hazardous waste, it will be stored in the ACM waste decontamination unit as permitted by NYC DEP Title 15. All filtration media and PPE associated with this operation will be handled as ACM waste pending HazWaste determination.

8.5 PCB Waste

Non-leaking waste PCB waste will be packaged in suitable containers and immediately loaded for disposal off site. Any leaking PCB articles or containers will be transferred to properly marked, non-leaking containers or an over-pack container.

9.0 Transportation Requirements

All waste materials will be transported in accordance with applicable local, state and federal DOT regulations including, but not limited to, bills of lading, manifests, placards,

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NYC-WTC 000134330

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NYC-WTC_000134330Source: NYC Law Department, mirrored locally

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