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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

asbestos waste." Airtek does not propose to conduct any dust sampling of non-porous deconstruction waste for waste classification. Airtek should explain how it plans to determine the waste classification of this waste stream and discuss the representability of the proposed sampling number in this section.

Surface wipe sampling of non porous unpainted materials will be conducted and submittedfor TCLP metals analysis. See Revised Section 7.0.

51. Airtek does not discuss how cleaned, unpainted, non-porous deconstruction waste will be managed and disposed. Revise this section to, address this concern.

Statement added.

Section 8. Page 14:

52. Airtek has not provided any design specifications for the "enclosed, locked area" for the storage of waste material nor the location of this storage area on-site. Airtek needs to provide this information to the regulatory agencies for their review and acceptance prior to beginning the project.

Waste storage, except for ACM storage permitted by NYC Title 15, will not be permitted on site. Section has been edited.

53. Add the following to the second to last sentence of this section: "...within the storage area, posted signs, labeled accumulation start dates, labeled description of the waste, aisle space, proper segregation of incompatible and or/ignitable waste, etc. will be inspected."

See response to comment #52.

Section 8.1. Pase 15:

54. Airtek should add the following italicized wording to the first sentence of the first paragraph, "Hazardous waste will be placed in containers made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored so that the ability of the container to contain the waste is not impaired (e.g., USDOT..."

See response to comment #52.

55. The last sentence of the first paragraph should be revised to read, "Containers will be inspected at least weekly to identify any leaks, and/or deterioration caused by erosion or other factors, and to ensure containers are not over-packed."

See response to comment #52.

-22-

NYC-WTC 000134363

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NYC-WTC_000134363Source: NYC Law Department, mirrored locally

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