EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part 111 — Health & Safety Plan 133-135 Greenwich Street>21-23 Thames Street Airtek Project 05-0701 —Rev 3, August 29, 2005

where material handling is performed, where hoisting equipment is located or where equipment is staged.

Decontamination Unit/Contamination Reduction Zone (CRZ) — This area shall be located subject to approval of the variance. The CRZ shall exist until the completion of Abatement Phase activities. Personnel shall be aware of and follow all site control procedures with respect to entering and exiting the CRZ, to ensure that they are not exposed to contaminants and to minimize the potential for contamination of personnel and the spread of contamination outside the Exclusion Zone (EZ). These measures include having personnel follow the proper procedures for donning and removal of PPE and washing in the CRZ. The measures also address the decontamination procedures for use when moving equipment between zones. The CRZ shall consist of an area to drop off equipment, plastic bags to dispose of protective clothing, adequate soap and water for personnel and equipment decontamination and a means of capturing wash water generated during decontamination. The CRZ shall also have a first-aid kit, fire blanket and fire extinguisher (20-lb ABC type).

Exclusion Zone (EZ) — This area extends from the side of the CRZ facing the building and includes all areas on each floor of the building. This definition of the EZ shall remain effective until Abatement Phase activity on each floor is completed. No employee shall enter the Exclusion Zone without the required training and PPE. No employee shall eat, drink, chew gum, apply cosmetics, smoke or use other tobacco products while in the Exclusion Zone. The employee must first exit the Exclusion Zone and follow decontamination procedures (Section 2.8.2.1) in the CRZ before engaging in any of the above actions. In the event that an employee in the EZ requires a replacement or his/her protective suit or respirator filters, the employee shall exit the EZ and utilize proper decontamination procedures in the CRZ, replace or repair the defective PPE, then reenter the EZ.

2.8.2 Personnel and Equipment Decontamination

When exiting the EZ, personnel shall be aware of and follow the procedures used to decontaminate personnel, equipment, and sampling containers. Subcontractors shall ensure that their employees follow proper decontamination and waste disposal procedures. Disposal of PPE and other items shall be performed in accordance with Section 3 of this HASP, with material placed in appropriately sized and labeled containers. Specific decontamination procedures are presented in the following subsections. All decontamination procedures shall be in accordance with the Entry/Exit Procedures of NYC Title 15, Chapter 1.

2.8.2.1 Personnel Decontamination Procedure

Personnel entering containment are required to follow proper decontamination procedures. All employees who leave the Exclusion Zone shall follow the decontamination process as outlined below. All employees shall remove all gross contamination and debris from disposal protective clothing and equipment by vacuuming prior to leaving the EZ. All employees must be HEPA vacuumed before entering the CRZ. Upon entering the CRZ, each employee shall remove the first layer of protective clothing and place it in the appropriate container. If the employee performs duties and

NYC-WTC 000134395