EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

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. Revise this section to address this concern.

Section has been revised.

27. 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.

This is detailed in section 6.0.

Section 4.4. Pase 8:

28. The third paragraph states that on-site storage of deconstruction waste for waste classification will not be required and that removed materials will be placed into applicable disposal containers/vehicles for off-site shipment. This paragraph appears to contradict Section 8 (Storage) which states that "if necessary, an enclosed, locked area will be maintained on site for the storage of waste material prior to off-site disposal." The Waste Sampling and Management Plan needs to clarify whether on-site storage will or will not be occurring, what will be stored in the storage area, the timing and location of sampling of waste streams prior to final off-site disposal, etc. The plan needs to be revised to make these matters clear. Further, a figure showing the location of the waste storage area and how waste streams will be segregated and stored in the waste storage area needs to be clearly defined on the figure.

No acceptable space exists at the site for on-site storage of hazardous waste. Section 8 has been edited.

29. The fourth paragraph needs to be revised to read, "If greater than 100 kg/month of hazardous waste is generated during the deconstruction process..."

Edited as noted.

Section 5.2. Pate 9:

30. Re-write this paragraph, to be consistent with the current version of SW-846, to state the following: "The characteristic of corrosivity carries the RCRA waste code of D002, and may be analyzed using Method 9045D or 9040C as set forth in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. SW- 846 method 9040 C is for aqueous wastes and multiphase waste where the aqueous phase constitutes at least 20% of the total volume of the waste; 9045D is for soils and waste samples where the waste may be solids, sludges, or non-aqueous liquids. The aqueous

-17-

NYC-WTC 000134358