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

Other chemicals identified as potential contaminants that may be encountered during the initial site cleaning activities are PAHs, dioxins, antimony, cadmium, nickel, barium, chromium, lead, zinc, manganese, copper, beryllium, PCBs, mercury, copper, zinc, cristobalite and quartz.

Environmental sampling in the neighboring 130 Liberty Street Building has verified the presence of these chemical contaminants in WTC dust in concentrations exceeding USEPA's Residential Cleanup Criteria.

Additional chemical hazards generated from deconstruction activities would be lead, cadmium, and chromium from coated surfaces. Subcontractors shall perform personnel monitoring for all COPCs as required by OSHA. In addition, Subcontractors must provide applicable OSHA training for the identified hazards. Documentation of this training must be provided by the Subcontractor.

Precautions to be taken during the removal of miscellaneous hazardous materials (bulbs, ballasts, batteries, mercury-containing thermostats, etc) are found in Table 2-1, Task 3. Respiratory protection, as identified within Table 2-1, represents the minimum level of protection for all identified tasks.

There may also be hazardous chemicals brought on-site and used in the deconstruction. The requirements of the OSHA Hazard Communications Standard (29 CFR 1910.1200) shall apply. Section 2.8 provides information concerning the management of hazardous chemicals on-site and the site Hazard Communication Program.

2.2.5 Biological Hazards

Biological concerns in the work area are primarily, insects, rodents, and mold/fungi.

2.2.5.1 Insects

The presence of insects shall be addressed by personnel as the insects are encountered. When a stinging or poisonous insect, such as a bee or spider, is identified, personnel should exercise caution to avoid being bitten or stung for example by using tools to move material. In the event that a person is stung or bitten, the incident shall be reported to the Site Manager for the Subcontractor who shall report the incident to the CSO. The Site Manager for the Subcontractor shall initiate actions to manage and address the bite or sting. Personnel who are allergic to insect bites and stings should identify their allergy to their employer.

2.2.5.2 Rodents

In the event that rodents or animal pests are identified or observed on-site, the Subcontractor Manager should report the incident to the Contractor CSO. The Contractor shall be responsible for evaluating the condition and implementing steps to eliminate rodents on the site.

2.2.5.3 Mold/Fungi

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NYC-WTC_000135004Source: NYC Law Department, mirrored locally

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