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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

etc. All wastes will be shipped using properly permitted vehicles operated by drivers with Commercial Drivers Licenses (CDLs) and Hazardous Materials endorsements. All hazardous waste will be shipped using transporters with RCRA identification numbers. The actual modes of transportation to be utilized will be determined following the identification of all anticipated waste streams and will take into account the location and distance to the selected disposal facility as well as cost considerations. All off-site shipments of waste will adhere to the site-specific transportation requirements. As required by NYSDEC (6 NYCRR Part 364) all hazardous and asbestos wastes will be transported using Part 364 permitted haulers.

10.0 Travel Routes

Travel route(s) will be determined following discussion with the appropriate regulatory agencies (e.g., New York City Department of Transportation), and the Lower Manhattan Construction Command Center (LMCCC). The selected waste transporter(s) will follow the designated travel routes. These routes cannot be determined until EPA approval of the project, as the timing and routing are interdependent on other project occurring in the area.

11.0 Disposal Facilities

Waste recycling/disposal facilities will be selected based on several factors including waste types, facility acceptance criteria, regulatory compliance history, etc. Only those facilities that have valid federal/state/local permits to accept the waste type proposed for recycling/disposal at the facility will be used.

12.0 Documentation

All applicable local, state and federal documentation and record keeping requirements/guidelines will be followed. Documentation for hazardous waste disposal includes hazardous waste determination documentation including all analytical results, Hazardous Waste Manifesting, EPA Generator ID, EPA transporter ID, EPA ID for waste disposal facility and waste storage locations and capacities. Also documented will be emergency notification and operating procedures, organizational chart, unexpected waste procedures, contractor involvement list and copies of the regulatory requirement certifications of transporters, disposal facilities, etc. Specific regulatory documentation may change depending on the types and amounts of waste to be generated. The Contractor shall be responsible for document management.

All documentation noted under this Section shall be retained for a period of not less than three years after the completion of the project.

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NYC-WTC 000134331

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NYC-WTC_000134331Source: NYC Law Department, mirrored locally

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