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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

6. This section mentions "bagged accumulated waste". Section 6.3.4 states that miscellaneous bagged accumulated waste are primarily associated with occupancy by transient (squatting) occupants and are primarily clothing and used food containers. The Waste Sampling and Management Plan does not discuss the pre-transient occupants and commercial/retail lessees items that were in the building prior to September 11, 2001 (e.g., clothes, furniture, etc.). This section needs to be revised to include these items on the list of building components. Additionally, the characterization, management, storage, transport, and disposal of these waste streams should be incorporated into the Waste Sampling and Management Plan.

As noted above, a building re-inspection was conducted on 9/15/2005 particular attention was paid to the items referenced in this comment. Commercial/Residential lessee items have been added to Section2.3.

7. Add "and potting material" after "light ballasts."

Done.

Section 3.0. Page 5:

8. The syntax does not seem appropriate in the first sentence of this section. Nonetheless, the concentration of the contaminants of potential concern (COPCs) found within settled dust varied throughout the buildings impacted by the collapse of the World Trade Center buildings. It is not appropriate to imply that the RCRA characteristics for the buildings to be demolished as part of this project will be similar to those found in other buildings since the level of contaminants to be found in the dust, and by extension, materials impacted by the dust may not be homogeneous throughout the buildings. Recommend removing this sentence.

Removed. See Section 3.0 for replacement statement.

Section 3.1. Page 5:

9. This section (Corollary Data) discusses TRC sampling results for the 130 Liberty Street building. We do not believe Airtek can assume that the data from another building correlates to what will be found at the buildings to be demolished as part of this project for the reasons explained above. Recommend removing this section.

"Corollary " has been edited to read "illustrative, " and this data was never intended to substitute waste stream sampling.

Section 3.2, Page 5:

10. We understand that Airtek has received the analytical results from the sample taken within the kitchen. Therefore, this section should be re-written to discuss the sample

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NYC-WTC 000134354

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NYC-WTC_000134354Source: NYC Law Department, mirrored locally

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