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EPA review letter, 133-135 Greenwich Street

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US EPA Region 2 letter dated November 15, 2005, confirming completion of environmental review for abatement plans at 133-135 Greenwich Street.

NYC-WTC_000134132–000134414
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NYC 9/11 Public Portal Document 6. Provisions shall be made to ensure a safe and adequate air supply to affected.building(s). All vents, skylights, air intakes, windows and doors opening onto the roof, and all other openings are to be sealed with 2 layers of 6-mil plastic or fitted with HEPA-filters where appropriate. NOTE: In lieu of sealing vents, air intakes, etc., with 2 layers of plastic or HEPA-filters, temporary extensions may be installed to a height of 10 feet to ensure adequate air exchange. Drains may be equipped with 5 micron filtering systems in lieu of being sealed.

FOAM PROCEDURES FOR ACRM REMOVAL

7. Prior to actual removal the built-up roofing shall be blanketed and wetted with a minimum 1" coating of the acceptable foam or viscous liquid which shall be maintained for the duration of the removal until the material is bagged. The foam or viscous liquid shall be confined to the work area.

8. Manual methods of removal are recommended; however, if hand-held power tools are used to drill, cut into, or - otherwise disturb the asbestos-containing roofing material, the power tools shall be equipped with HEPA-filtered local exhaust ventilation and operated to prevent potential fiber release.

9. Portable HEPA-vacuum machines shall be available during abatement.

10. Clean-up procedures shall involve removal and bagging of a) the asbestos containing roofing material (ACRM) b) visible accumulations of asbestos containing waste c) all excess foam or similar visous liquid d) all debris, and shall be followed by a thorough wet cleaning.

11. All tools shall be wet cleaned and HEPA-vacuumed, and then removed from the work area upon completion.

12. The work area shall be allowed to dry completely before the visual inspection is conducted. This inspection, to be performed by the independent third party air monitoring firm/consultant, shall confirm the absence in the work area of a) ACM or ACW bags or debris, b) excess foam or other viscous liquid.

NOTE: If the work area fails visual inspection, it shall undergo another wet cleaning and/or HEPA vacuuming until it passes the visual inspection.

13. When the visual inspection is successful, all plastic may be removed.

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I. Daily continuous air sampling inside the work area and, also, in all spaces where egress from the work area is through the structure itself, shall be conducted in accordance with sections 1-41(a), 1-41(b) and 1-42 of Title 15, Chapter 1, Rules of the City of New York. 2. If any air sample(s) within the work area exceed 0.01 f/cc or the background level, whichever is greater, then work shall stop and methods shall be altered to reduce airborne fiber concentrations to the aforementioned level. 3. Clearance air monitoring is not required. 4. Personal air monitoring data shall be submitted to the Department within one week after the completion of the project, if requested.

A copy of the approval, the corresponding notification, and this procedure shall be posted conspicuously at the entrance to the work area.

NOTE: A conservative approach has been used in the design of this protocol to provide as much relief as possible while maintaining adequate measures to safeguard health and safety.

The Department of Environmental Protection will consider additional variances in conjunction with this application.

TRU/JM 6/98 -2-

NYC-WTC 000134228

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NYC-WTC_000134228Source: NYC Law Department, mirrored locally

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