EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Mr Rajappan Radhakrishnan - NYC DEP 21-23 Thames Street variance Request Airtek Project 05.0701- Revised September 29,2005

Section 1-91 No negative air Section 1-102(b) Not to fully saturate ACRM with amended water Section 1-112(d) & 1-112(e) No l ot & 2"d settling period and no 2"d & 3" cleaning

We proposed to use Attachment FR - Procedures for use of Foam or Similar Viscous Liquid in Removal of Asbestos Containing Roofing (ACRM) In New York City. In addition to the conditions set forth In Attachment FR Section E-6 arrangements have been made to seal openings at High School of Economics & Finance — Refer to Work Plan for details.

In-place ACM has been identified as follows:

Main Roof: 1. Roof Membrane — 350 sf 2. Roof Flashing —150 sf 3. Bulkhead Tar — 25 sf

18t Floor Roof: 1. Roof Membrane — 100 sf 2. Roof Flashing — 46 sf

We are requesting a variance from the following subsections for the coping stone caulk:

Section 1-41(c) During abatement air sampling inside the work area Section 1-41(d) No post abatement clearance air monitoring Section 1-106(b) To use partial tents

1. Coping Stone Caulk —1 sf

We proposed to use Attachment IC — ACM caulking material from the top of the parapet wall(s) on the roof.

We are requesting a variance from the following subsections for the exterior window caulk:

Section 1-41(c) During abatement air sampling inside the work area Section 1-41(d) No post abatement clearance air monitoring Section 1-106(b) To use partial tents

1. Window Caulk —10 sf (210 If)

We proposed to use Attachment EC — ACM caulking materials from building facades.

These materials will be abated last in the decontamination sequence. For detailed Information on the asbestos survey conducted, please refer to the Airtek Asbestos Survey Report dated May 31, 2005 (Attached).

Utilities - General:

Utility service is currently cut off to the building. All electricity and water required for the work will be drawn from sources outside the building.

Project Monitoring:

NYC-WTC 000134158