EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part III — Health & Safety Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— Rev 3, August 29, 2005

The Owner contracted with Airtek Environmental Corp. to conduct Asbestos Surveys and General Building Characterization for the 133-135 Greenwich/21-23 Thames Street buildings. Due to the proximity of these buildings to the WTC, and the extensive environmental tests carried out at the adjacent 130 Liberty Street (Deutsche Bank) Building, it is assumed for the purpose of this HASP that similar potentially contaminated WTC dust is present at this site. The settled dust in and on the Building may contain elevated levels of five COPCs designated by the United States Environmental Protection Agency (USEPA) as being associated with the WTC dust (asbestos, dioxin, lead, polycyclic aromatic hydrocarbons [PAHs], and crystalline silica) as well as other contaminants suspected of being present in the Buildings including polychlorinated biphenyls (PCBs) and heavy metals (antimony, barium, beryllium, cadmium, chromium, copper, manganese, mercury, nickel and zinc).

The Owner has retained Airtek Environmental Corp. to conduct Environmental Investigations of the buildings for additional unidentified asbestos containing building materials (ACBM). These environmental reports are included as Attachment 2 to this HASP.

The requirements outlined within this Health and Safety Plan are based upon the data collected to date. As additional information is obtained during the course of the Abatement and Demolition activities, these requirements will be amended if necessary to protect workers or the public.

1.2 SITE DESCRIPTION

The Property is currently developed for a combination of commercial and multi-family residential use. The Property includes a vacant two-story commercial building that was constructed on the northwestern portion of the Property circa 1980. The building was most recently occupied by a pizza shop, a coffee shop, a Japanese restaurant, an Indian restaurant, a shoe repair shop, and second floor professional (doctors') offices. The Property also includes a vacant five-story building that was constructed on the southeastern portion of the Property prior to 1894. This building includes two ground floor tenant spaces most recently occupied by a sandwich shop, a Western Union office, and approximately eight residential units.

The Property is located within the urban commercial downtown Financial District of Manhattan, New York City, immediately south of the former World Trade Center site and adjacent to the vacant Deutsche Bank Building. The Property is bounded to the west by Greenwich Street, to the north by a four story mixed-use (commercial/residential) building, to the east by Finance and Economics High School, and to the south by Thames Street.

13 PURPOSE

This document presents the safety procedures and practices to be followed during all Abatement Phase site activities to ensure the safe completion of tasks. The procedures and practices herein are designed to prevent occupational injuries and exposures to chemical, physical and biological hazards to workers at the Site. The procedures are presented to ensure compliance with all applicable government agencies and regulations, including, but not limited to requirements and protocols established by: the Occupational Safety and Health Administration (OSHA); the

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NYC-WTC 000134372