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EPA work plan review, 133-135 and 21-23 buildings, August 2005

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EPA Region 2 letter regarding revised environmental work plan submission for two buildings including asbestos, health, and safety assessment components.

NYC-WTC_000134871–000135144
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NYC 9/11 Public Portal Document

Part III — Health & Safety Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— Rev 1, August 11, 2005

The work to be conducted at 133-135 Greenwich/21-23 Thames Street comprises construction activities and, as such, falls under Title 29 of the Code of Federal Regulations, Part 1926 (29 CFR 1926), the OSHA Construction Standard.

An evaluation of the anticipated general work activities was performed (discussed later in this section) that included a Hazard Analysis for each general task/activity to identify associated hazardous conditions, appropriate employee protection methods and PPE requirements. The evaluation of potential site conditions and activity hazards is an ongoing process and shall continue throughout the duration of the project.

Potential hazards during the Abatement Phase effort include the following:

• Physical — Excessive noise; inclement weather; heat stress; cold stress; manual lifting; slips and falls; structural integrity; working at elevation; electrical safety; heavy equipment operation; and other general construction hazards.

• Chemical — Asbestos, silica, PAHs, dioxins, man-made vitreous fibers (MMVF), antimony, cadmium, nickel, lead, barium, chromium, zinc, manganese, copper, beryllium, PCBs, mercury, copper, zinc, cristobalite and quartz.

• Biological — Mold; rodents; insects.

• Radiological — None anticipated.

2.2.2 Task Hazard Analysis

The scope of work for the 133-135 Greenwich/21-23 Thames Street project consists of three general tasks, as follows:

• Task 1: Environmental Consultant monitoring including work area air sampling during Phase I activities; clearance air sampling when cleaning of each floor is completed; and waste characterization sampling.

Task 2: Maintain temporary services including water risers, fire protection systems building communication system, GFCI protected electrical systems

Task 3: General area cleanup of WTC dust and debris, which shall be treated as asbestos (at a minimum) and which may contain other COPCs; removal and disposal of installed porous and certain non-porous building materials and components contaminated by WTC dust and debris; cleaning and salvage of certain installed non-porous building equipment and components contaminated by WTC dust and debris; removal of ACBM primarily within the Building interior; and cleaning of the exterior surfaces of the buildings.

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NYC-WTC 000134991

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NYC-WTC_000134991Source: NYC Law Department, mirrored locally

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