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
OCR can misread numbers and units. Confirm readings against the page image before using them.