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 3 September 16, 2005

Airtek has undertaken an asbestos survey intended to coordinate and complete previous survey work that has been conducted at the site. All previous documentation was reviewed and a site survey and bulk sampling wa`conducted. Based on this survey work, an inventory of in-place asbestos has been developed. The results of the surveys are included in Attachment I "Variance Application" to this Work Plan.

3.2 Site Survey

A thorough inspection of the subject structures and the adjacent structures has been conducted. Communicating openings, air intakes, and other potential pathways of contamination have been identified for inclusion in the decontamination design. Facility managers for the adjacent structures have been contacted so that engineering controls may be implemented to protect occupants. Of particular concern are air intakes of the school building directly to the east of the project site. These concerns are being addressed cooperatively with the Department of Education. Details on these plans are included in Attachment II "Mechanical Controls" to this work plan.

3.3 NYC DEP Variance Application

In order to execute the particular requirements of this unique project, specific relief from RCNY Title 15 will be requested by the submittal to NYC DEP of an ACP-7 form with an accompanying ACP-8 Request for Variance form for each of the two structures involved in the project. Variances to be requested will be specific to the conditions in each building, and the variance request will also include the use of Attachment DW (Waste decontamination in Personnel Decon) during the initial lobby-cleaning phase. A copy of the variance request for each building is included in Attachment I "Variance Application."

3.4 NYS DOL Notification

Due the fact that the decontamination will constitute a `Large Project" according to Industrial Code Rule #56, notification of the project will be made to the NYS Department of Labor. A copy of the DOSH-486 form is included in Attachment I.

3.5 USEPA Notification

Due the fact that the decontamination will constitute a `Large Project" according to EPA NESHAP, notification of the project will be made to the USEPA. A copy of the USEPA notification is attached. In addition, if it is determine that greater than 100 kg of Hazardous Waste is to be generated in any one month from this site, RCRA notification will be required.

4.0 Utilities - General:

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NYC-WTC 000134181