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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 I: Work Plan — Decontamination/Deconstruction 133-135 Greenwich Street and 21-23 Thames Street Airtek Project 05-0701— Rev 2 August 10, 2005

4.0 Utilities - General:

Utility service is currently cut off to the building. All electricity and water required for the work will be drawn from sources outside the building.

5.0 Monitoring:

Community Monitoring will be conducted as detailed in submittal Part II — ECAMP.

Project Monitoring: Throughout the decontamination activities, project air monitoring will be conducted in addition to the Perimeter Monitoring described above. Project Monitoring will be conducted in strict accordance with RCNY Title 15 Chapter 1, Section 1-41 to 1-45, with the exception that all sample analyses will be by TEM. Project monitoring is detailed in submittal Part II- ECAMP.

Clearance Testing will be conducted as detailed in the "Clearance Criteria" section below, and as detailed in submittal Part II — ECAMP.

6.0 Clearance Criteria:

The site will be considered ready for the Conventional Building Demolition Phase when the buildings are visually clean of all dust, all interior surfaces have been encapsulated with a colored encapsulant, and when interior air clearance testing indicates that concentrations of the analytes listed below have been reduced to levels specified below. All visual clearance and air testing will be conducted by the environmental consultant. Where necessary a "White Glove Test" will be performed to determine visual clearance.

The buildings can be removed from containment and the abatement phase will be completed when area air measurements, performed using aggressive air sampling procedures which re-suspend residual settled dusts, are at or below each of the following airborne concentrations in every sample, respectively for the metals noted below and for asbestos. Air testing for asbestos shall be in accordance with applicable regulations and applicable permits and variances for this project. If any one sample is above any of these limits, then the abatement phase will be considered incomplete, and the effected areas shall be re-cleaned and re-tested until the airborne concentrations are at or below the levels noted for metals and asbestos.

Clearance testing for asbestos will be acceptable when all samples for a given work area meet the 70 structures per square millimeter TEM standard. Clearance testing for metals will be acceptable when all samples meet the following criteria:

Antimony 250 ug/m3 Barium 250 ug/m3 Beryllium 1.0 ug/m3 Cadmium 5.0 ug/m3 Chromium (III) 250 ug/m3

NYC-WTC 000134887

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NYC-WTC_000134887Source: NYC Law Department, mirrored locally

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