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
OCR status: ok · source: pdftotext
NYC 9/11 Public Portal Document
Comments on
Part III Health and Safety Plan for 133-135 Greenwich/21-23 Thames Street Abatement Phase Decontamination Project Re-submitted August 11, 2005 General Comment:
1. Airtek states in its response to EPA comment #1 that the documents have been edited for consistency with regard to the terminology being used for the phases. However, the HASP still discusses a "Phase P" in numerous sections when it appears that Airtek has taken the approach to breakdown the project into an Abatement Phase and a Demolition Phase. Change "Phase I" to "Abatement Phase" in the HASP and any of the other submittals with regards to this project.
Done.
Section 1.0: Introduction
Page 4, Section 1.0, Second Paragraph
2. The Introduction Section now discusses five activities to be conducted as part of the Abatement Phase of the Demolition Project, but still does not mention what activities will be conducted as part of the Demolition Phase. The Demolition Phase activities still need to be summarized in the Introduction Section.
Demolition Phase task categories have been added to the Introduction, and to Table 2.1.
Page 4, Section 1.0, Third Paragraph
3. The HASP still indicates that activities to be undertaken as part of the Conventional Demolition Phase Deconstruction activities will be addressed in a separate HASP. When does Airtek plan to submit the separate HASP? Again, this separate HASP should be incorporated into the final submission to the regulators pertaining to this demolition project prior to the commencement of any work at the site.
HASP has been amended to reflect both abatement and demolition phases of this project.
Page 30, Section 2.11.1 Container Labels
4. This section now states that portable containers filled during a shift require no labeling until the shift is over (provided the container will be used on the next shift). Recommend that labels be used on all portable containers in order to avoid chemical materials being
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NYC-WTC 000134350
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