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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

hazardous." That statement may only be accurate if Airtek is proposing a sampling scheme that will be representative of all areas in the building that have been impacted by WTC dust because 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. Further, building components specified in Section 2.3 may also be potentially impacted by dust. Revise this section to address these concerns.

Section has been edited. Representative sampling will be conducted. Sampling is detailed in section 6.0.

Section 4.2, Page 7, Last Paragraph:

22. Airtek makes reference to an "Asbestos and COPC Abatement Plan of the Work Plan". Where exactly is this located since none of the four parts of Airtek's submittal for the Abatement and Demolition project are titled this?

Section has been edited to read, "Work Plan. "

23. Airtek discusses the waste characterization strategy for non-porous deconstruction waste. Airtek should discuss the waste characterization strategy for porous deconstruction waste.

Statement has been added on porous deconstruction waste. Sampling details are in section 6.0.

Section 4.3. Page 7. Second Paragraph:

24. This section does not discuss the waste characterization strategy for the miscellaneous materials defined under Section 2.3. Add language to this section to address the waste characterization strategy.

"Miscellaneous Materials " have been further defined based on the 9-15-05 re- inspection. Waste characterization sampling is discussed in section 6.0.

25. Replace "land banned" with "restricted from land disposal pursuant to 40 C.F.R. Part 268."

Edited as noted.

Section 4.4, Page 7, First Paragraph:

26. 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 Structure & Façade of the building would also not be hazardous." That statement may only be accurate if Airtek is proposing a sampling scheme that will be representative of all areas in the building that have been impacted by WTC dust because

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NYC-WTC 000134357

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NYC-WTC_000134357Source: NYC Law Department, mirrored locally

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