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

Consultant shall include monitoring for visible emissions as detailed in the Environmental Monitoring Specification.

2.2 HEALTH AND SAFETY HAZARD ANALYSIS AND RISK ASSESSMENT

2.2.1 Preliminary Evaluation

The work to be conducted at 133-135 Greenwich/21-23 Thames Street comprises construction activities and, as such, falls under Title 29 of the Code of Federal Regulations, Part 1926 (29 CFR 1926), the OSHA Construction Standard.

An evaluation of the anticipated general work activities was performed (discussed later in this section) that included a Hazard Analysis for each general task/activity to identify associated hazardous conditions, appropriate employee protection methods and PPE requirements. The evaluation of potential site conditions and activity hazards is an ongoing process and shall continue throughout the duration of the project.

Potential hazards during the Abatement Phase effort include the following:

• Physical — Excessive noise; inclement weather; heat stress; cold stress; manual lifting; slips and falls; structural integrity; working at elevation; electrical safety; heavy equipment operation; and other general construction hazards.

• Chemical — Asbestos, silica, PAHs, dioxins, man-made vitreous fibers (MMVF), antimony, cadmium, nickel, lead, barium, chromium, zinc, manganese, copper, beryllium, PCBs, mercury, copper, zinc, cristobalite and quartz.

• Biological — Mold; rodents; insects.

• Radiological — None anticipated.

2.2.2 Task Hazard Analysis

The scope of work for the 133-135 Greenwich/21-23 Thames Street project consists of five (5) general tasks, as follows:

Task 1: Environmental Consultant monitoring including work area air sampling during preparation decontamination and demolition activities; clearance air sampling upon completion of asbestos and COPC abatement and removal activities; and waste characterization sampling.

Task 2: Maintain temporary services including water, fire protection and GFCI protected electrical.

Task 3: Preparation for and general area cleanup of WTC dust and debris, which as stated by the regulators must be treated as asbestos (at a minimum) and which may contain other COPCs;

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NYC-WTC 000134377