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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 1.0 BACKGROUND: Airtek Environmental Corp. has conducted an asbestos survey for the presence of Asbestos- Containing Materials (ACM) at the following building(s): Address: 133-135 Greenwich Street AKA 25-29 Thames Street (2-Story)

Borough: Manhattan

The Investigator responsible for this project was: Moyna Ali: NYC Asbestos Investigator #97088 Expires: 03/12/06 NYS Asbestos Inspector #AH 89-01641 Expires: 03/06

Site Visit(s): 5/26/05 & 5/27/05 Report Date: 5/31/05 Revision Date: N/A

Field Procedures and Analysis Methodology:

Guidelines used for the inspection were established by the Environmental Protection Agency (EPA) in the Guidance for Controlling Asbestos Containing Materials in Buildings, Office of Pesticides and Toxic Substances, DOC #560/5-85-024 and 40 CFR Part 763, Asbestos Hazard Emergency Response Act (AHERA).

Field information was organized as per the AHERA concept of Homogeneous Area (HA). A HA is defined as a suspect material of similar age, appearance, function and texture. Each material was grouped together as a specific HA, sampled and then assessed for condition.

Bulk samples of suspect ACM were analyzed by Polarized Light Microscopy (PLM) with dispersion staining, as described in 40 CFR Part 763 and the National Emissions Standard for Hazardous Air Pollutants (NESHAPS).

The New York State Department of Health has recently revised the PLM Stratified Point Counting Method. The new method, "Polarized Light Microscopy Methods for Identifying and Quantitating Asbestos in Bulk Samples" can be found as item 198.1 in the ELAP Certification manual.

The State of New York ELAP has determined that analysis of Non-friable, Organically Bound Materials (NOB) are not reliably performed by PLM. Therefore, if PLM analysis of a NOB yields a negative result, it must be further confirmed by Transmission Electron Microscopy (TEM).

All samples were initially analyzed by PLM. Samples which produced a negative PLM result and which are classified as a NOB were then re-analyzed utilizing the TEM methodology.

2.0 SCOPE OF WORK:

The following areas which may be affected by the proposed demolition were inspected for ACM: 1. Interior & exterior of the building The inspection was characterized by a close visual inspection of all accessible areas. Suspect materials were sampled and inventoried for quantity, condition and friability. Materials examined included: 1. Ceiling Tiles

NYC-WTC 000135035

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NYC-WTC_000135035Source: NYC Law Department, mirrored locally

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