EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Edited as noted.

Section 6.3.1, Page 11;

35. Add "and other PCB Wastes" after the title of this section.

Done.

36. If fluids potentially contaminated with PCBs are suspected at this project, a discussion on such a waste stream should be included in this section.

No electrical transformers or otherfluid PCB sources are suspected to exist at the site. As with all waste, materials encountered that are not covered in this plan will be managed appropriately under the direction of the Environmental Consultant. This is discussed in Section 6.3.

Section 6.3.3. Page 13:

37. Change "Material" to "Refrigerant-containing equipment" in the third sentence of the first paragraph.

Edited as noted.

38. Add the following to the end of the section: "After removal of refrigerant and otherwise rendering the appliance safe, recycle or dispose of the appliances as scrap metal or as municipal solid waste, respectively."

Added as noted.

Section 6.3.4, Page 13:

39. Airtek states that studies were conducted by the building owner's team which indicated that the miscellaneous bagged accumulated waste were primarily clothing and used food containers. What did this "study" actually entail? Were all miscellaneous bagged accumulated waste visually inspected? If not, it is recommended that 100% of the miscellaneous bagged accumulated waste should be visually inspected.

All bags were inspected during the 9-15-05 re-inspection. No materials were noted that fall outside the categories of "Commercial/Residential Lessee Items," or "Transient Residential Items."

40. Airtek states that miscellaneous bagged accumulated waste will be disposed of as asbestos-containing wastes. It may be inappropriate to claim that miscellaneous bagged accumulated waste will be disposed of as asbestos waste. This waste stream may also

-19-

NYC-WTC 000134360