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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

56. Airtek should add the following sentence to the end of the first paragraph, "While being accumulated on-site, each container shall be labeled or marked clearly with the words, "Hazardous Waste".

Added to Section 8.1.

57. Re-write the last paragraph as follows: "Hazardous waste may be accumulated in the waste storage area without a storage permit for a maximum of 90 days from the accumulation start date. If the generator status should change from large quantity generator to small quantity generator, then a maximum of 13,200 pounds of hazardous waste may be accumulated in the waste storage area without a storage permit for a maximum of 180 days from the accumulation start date."

See response to comment #52.

58. Airtek should add language on its requirements for handling incompatible waste, such as, but not limited to, indicating that hazardous waste will not be placed in an unwashed container that previously held an incompatible waste, indicating how a storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby will be separated from the other materials or protected from them by means of a dike, berm, wall, or other device. Revise the plan accordingly.

See section 8.1

59. Since Airtek has not provided any specifications for the waste storage area, it is unclear how and where ignitable or reactive waste will be stored within the storage area. Such waste must be located at least 15 meters (50 feet) from a facility's property line. Specifications on the waste storage area and the location of ignitable and/or reactive waste within the waste storage area will need to be identified and provided to the regulators for review.

See response to comment #52.

Section 10.0, Page 16:

60. Airtek states that the proposed abatement subcontractor's Proposed Waste Removal and Transportation Procedures are currently under review and that the approved procedures will be appended to this plan. Airtek should provide this information to the regulatory agencies for their review and acceptance prior to beginning the project.

The referenced language was included erroneously. ACM waste haulage and disposal information is included in the NYC DEPfilingsfor the abatement phase. Other disposal information can only be generated once waste characterization is conducted, asfacilities will change dependent on the classification of waste. Routing will be subject to LMCCC directives.

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NYC-WTC 000134364

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