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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

improperly mixed with hazardous materials and/or substances and/or waste and/or with incompatible materials.

This section has been amended to require proper labeling on all containers.

Section 2.2.2: Task Hazard Analysis: Page 11:

5. This section now states, "the scope of work for the 133-135 Greenwich/21-23 Thames Street project consists of three general tasks". There are other tasks to be performed as part of this project besides the three tasks discussed in the Abatement Phase HASP (e.g., air monitoring during the demolition phase) that should be included in the HASP for the Demolition Phase that Airtek still has not submitted. The three tasks discussed in this HASP pertain to the Abatement Phase, and thus, this sentence should be re-written to indicate this fact.

Task Hazard Analysis has been revised to include demolition phase activities.

Section 2.5.3: Level B PPE: Page 21:

6. Airtek's response to EPA comment #16 states that no concrete chute will be used. However, reference is still made to the installation of a cement chute. Revise this section to remove the reference to a cement chute.

Reference removed.

Page 29, Section 2.10: Page 29. Section 2.10.2; & Page 32, Section 2.12:

7. Airtek's response to EPA comment #18 indicates that "HASP AM" had been changed to "CSO". However, three sections still discuss a "HASP AM". The role of the "HASP AM" has not been described in the HASP. Revise the HASP to define what this acronym stands for and to describe his/her role or change to "CSO" as was done in Section 2.2.4.

Changed to CSO.

Section 2.3, Page 19 & Section 2.7, Page 24:

8. These sections still discuss torching operations even though Airtek's response to EPA comment # 20 indicates that torching will not be conducted. If torching will not be conducted, remove any reference to torching operations in the HASP.

References removed.

Section 2.6: Safety Equipment: Page 22:

9. The HASP indicates that the communication and alarm system will be located in the contamination reduction zone (CRZ). Where in the CRZ will this system be located?

NYC-WTC 000134351

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NYC-WTC_000134351Source: NYC Law Department, mirrored locally

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