EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part 1: Work Plan — Decontamination/Deconstruction 133-135 Greenwich Street and 21-23 Thames Street Airtek Project 05-0701— Rev 4 September 29, 2005

3. The collected water run-off shall be pumped to 55-gallon drums. Aliquots from each drum of wash water will be collected. The aliquots will be composited to be analyzed for Full TCLP and RCRA characteristics. In addition, any testing required by NYC DEP sewer discharge requirements will be conducted. If the water is not regulated under RCRA, and meets the criteria set forth by NYC DEP, it will be filtered through a 5 micron filter prior to disposal to the NYC sewer system per NYC Title 15, Part 1-82 (b) 1. If testing indicates the water is regulated under RCRA, it will be handled, package, stored and disposed in strict accordance with its categorization.

7.2 Part II - Soft Strip:

The Soft-Strip will be conducted in negative air full-containment as an asbestos project according to the asbestos rules and NYC DEP Variance for the project. Each building will be contained as one work area. Stairwells will not be contained and/or cleared separately. As noted in Section 6.0 "Clearance Criteria," each building will have its clearance samples run simultaneously. Dust suppression will be conducted according to the stringent rules and regulations governing asbestos projects. Exterior isolation barriers will be installed per the NYC DEP Variance.

All interior materials, including moveable objects, will be subject to abatement and removal, and will be bagged and disposed of as ACM waste at a minimum. Certain stainless steel kitchen fixtures and other impermeable materials may be decontaminated by HEPA-vacuum and wet wiping. Efficacy of this decontamination will be determined by the Environmental Consultant as described in the Waste Management Plan (Submittal Part IV). All ceiling systems (plaster, tiles, sheetrock, etc.), wall systems (plaster, wall board, etc.), and floor systems, (tiles, carpet, etc.) will be removed and bagged for disposal as ACM waste at a minimum. Waste characterization testing as described in the WMP (submittal Part IV) will be used to make final waste determinations. Remaining structural members will be wet-wiped, HEPA vacuumed, and encapsulated with a penetrating encapsulant. All interstitial spaces (i.e., chases, stud walls, etc.) will be accessed, wet-wiped, HEPA-vacuumed, and encapsulated. Operable windows will be articulated, wet wiped, HEPA-vacuumed, and encapsulated.

7.3 Part III - In Place ACM:

In-place ACM has been identified as follows:

133-135 Greenwich Street:

a. Roof Flashing — 35sf b. Bulkhead Tar —10sf

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NYC-WTC 000134138