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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 IV- Waste Management Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— August 10, 2005

Publication SW 846 Chapter 7. It is anticipated that the sample will not exceed the criteria provided in 40 CFR Part 261 sections 21 through 23 or SW 846 Chapter 7.

3.3 Preliminary Conclusion

Based on the above corollary data from 130 Liberty Street, waste disposal information from the recent deconstruction of 4 Albany Street, and the confirming results from WTC Dust samples collected at the subject site, it is anticipated that all waste noted in subsection 2.1 and 2.2 above will be disposed of as ACM O c -- Waste. In the case of stainless steel kitchen fixtures, equipment and other impermeable materials it may be possible to decontaminate and dispose as C&D/recyclable waste. Miscellaneous waste noted in subsection 2.3 above will be characterized, handled, transported and disposed according to waste characterization conducted by the Environmental Consultant.

4.0 Waste Characterization Strategy

Waste generated during the project will be characterized, managed, transported and disposed of in compliance with this Waste Management Plan and applicable regulations.

4.1 Regulated Contaminants

Full-building asbestos surveys have been conducted. In-place ACBM has been identified, located and included in the Project Plan. No further characterization will be conducted unless site conditions reveal additional suspect materials not addressed in the ACBM surveys.

The limited WTC Dust that exists at the site has been sampled and tested for RCRA characteristics. Results are discussed above, and the documentation is included in Attachment I.

4.2 Deconstruction Waste

Dust sampling for hazardous waste characteristics has been performed in advance of sampling of materials impacted by dust. It is anticipated that the dust classification sampling will indicate that the dust is not a characteristic hazardous waste, and then by extension, any non-hazardous materials potentially impacted by dust (i.e., the Deconstruction Waste listed in subsection 2.2 above) would also not be hazardous. Random confirmatory sampling of the various deconstruction waste categories will be conducted to confirm this prior to commencement of any site work, as was done at 130 Liberty Street.

Those materials would then not be sampled for Resource Conservation and Recovery Act (RCRA) characteristics unless there is an independent

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NYC-WTC 000135129

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