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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

16. Remove "Regulated" before "Contaminants".

Done.

17. The first sentence of the second paragraph states that the dust at the site has been sampled and tested for RCRA characteristics. If Airtek is referring to the one composite sample taken from the kitchen, then it is not appropriate for Airtek to state that the waste characterization for the building components at the site has been completed since assumptions about all of the building components in both buildings should not be made based on one analytical sampling result taken from one room of one floor of the buildings. This section should be re-written to address these concerns.

Paragraph 2 has been re-written.

18. The last sentence of the second paragraph states that sample results are documented in Attachment I. There is no Attachment I included with the Waste Sampling and Management Plan and no sampling results provided. Include this information.

Attachment 1 has been added.

Section 4.2, Page 6:

19. The first paragraph states that, "dust sampling for hazardous waste characteristics has been performed in advance of sampling of materials impacted by dust." We are only aware of two samples taken by Airtek: one composite sample taken of dust in the kitchen and a second sample taken of the caulking. If additional analytical sampling results have been generated, those sample results should be included as an attachment to the Waste Sampling and Management Plan and referenced in the Table of Contents. If analytical sampling results have been generated, why does Airtek makes assumptions about these results. The actual analytical sampling results should be discussed if the samples have already been collected and analyzed, as stated in this section.

Section 4.2 has been edited.

20. Define "random confirmatory sampling" with respect to sampling representability in the first paragraph. Airtek should provide specific details on the locations of the various samples, and the rationale for their locations. Simply stating that "random confirmatory sampling" will be conducted is a broad generalization that does not provide any indication on the number of samples that will be gathered from each building component per floor and/or waste storage area, and the locations at which the samples will be collected.

Term has been edited to read "confirmatory sampling. "Sampling details are specified in Section 6.0. 21. Airtek states in the first paragraph that if "the dust is not a characteristic hazardous waste, and then by extension, any non-hazardous materials potentially impacted by dust (i.e., the Deconstruction Waste listed in subsection 2.2 above) would also not be

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NYC-WTC 000134356

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NYC-WTC_000134356Source: NYC Law Department, mirrored locally

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