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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

Response to Comments on

Part I Revised Work Plan for Abatement and Demolition of 133-135 Greenwich Street and 21-23 Thames Street Re-submitted August 11, 2005

General Comments

1. The pages of the Revised Work Plan for Abatement and Demolition still need to be numbered and the Table of Contents should reference the page that a specific section can be found.

Pages are numbered, and Contents references section page numbers.

2. The Plan remains unclear about whether Airtek addressed EPA's comment #12 on the Revised Work Plan For Abatement and Demolition since there was no response to this comment: "Will the stairwells be cleared and sampled separately from containment area/floor clearance activities? Please explain how this will be done."

Please see Section 7.2 paragraph 1.

3. It does not appear that Airtek revised the Waste Sampling and Management Plan to include EPA's comment #30 on the Revised Work Plan For Abatement and Demolition: "Revise this subsection to include a requirement to retain records of hazardous waste determinations and hazardous waste manifests for a period of at least three years." Revise the Waste Sampling and Management Plan to state this fact.

See Section 8.4 paragraph 2 of Work Plan and Section 12 of Waste Plan

Section 3.5, USEPA Notification

4. The reference to the USEPA notification is actually NESHAP not AHERA. Please revise this section accordingly.

Done.

5. Add the following language to this section "...that greater than 100 kg of Hazardous Waste is generated in any one month from this site..."

Done

Section 7.1, Part I - Exterior Cleaning.-

-1-

NYC-WTC 000134342

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NYC-WTC_000134342Source: NYC Law Department, mirrored locally

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