EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part I: Work Plan — Decontamination/Deconstruction 133-135 Greenwich Street and 21-23 Thames Street Airtek Project 05-0701— Rev 4 September 29, 2005

1.0 General

The Copper Group, Inc. (Owner) has engaged Airtek Environmental Corp. (Airtek) to prepare the following project plan in support of the de-construction of the buildings located at 133-135 Greenwich Street and 21-23 Thames Street, New York, NY. This plan is in response to a request by the WTC Regulators for a documented approach to the project.

Though they sustained little physical damage, the buildings at 133-135 Greenwich Street and 21-23 Thames Street were impacted by fallout from the events of September 11, 2001. It is the Owner's intent to conduct abatement of in-place asbestos, and to effect a decontamination of the interior of the building so that conventional demolition activities can be completed.

2.0 Related Submittals

2.1 Community Air Monitoring Plan

Prior to initiation of any decontamination/deconstruction operations, an Environmental Community Air Monitoring Plan (ECAMP) developed by an Airtek CIH, and approved by the USEPA will be established and operational. The Program will consist of daily air monitoring at three points on the perimeter of the project site. Monitoring will be conducted in accordance with the attached Environmental Air Monitoring Specification, Community Monitoring will continue until building demolition is complete. The ECAMP is included as Part II of the submittal Package.

2.2 Health & Safety Plan

A Certified Industrial Hygienist (CIH) from Airtek has developed a site-specific HASP to be applied to all site decontamination operations. The HASP details requirements for access/egress and requirements for Personal Protective Equipment for workers at the site. The HASP is included as Part III of the submittal package.

2.3 Waste Management Plan

A Certified Industrial Hygienist (CIH) from Airtek has developed a site-specific Waste Management Plan (WMP) to be applied to all waste operations for the site. The WMP provides details on how, and by whom, waste determinations and categorizations will be made, and provides detail on sampling and analysis protocols. The WMP is included as Part N of the submittal package.

2.4 Quality Assurance Project Plan (QAPP)

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NYC-WTC 000134134