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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