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

NYC 9/11 Public Portal Document

Part TV- Waste Management Plan 133-1 ' n' wiehStreer21-23 Thames Street Airtek Project 05-0701 —August 10, 2005

concern that they might be hazardous waste due to the inherent composition of the component, subcomponent or waste stream (e.g., light ballasts which may contain PCBs, items coated with lead-based paint).

Non-Porous Deconstruction Waste may be managed by either of two options. The Abatement Subcontractor may choose to clean the non- porous surfaces in accordance with procedures outlined in the Asbestos and COPC Abatement Plan of the Work Plan. The resulting cleaned material will not be sampled unless it is painted; in that instance, sampling will be performed as described in Section 7.0 of this Plan. Alternatively, based on field conditions and decisions regarding the use of its labor force, the Abatement Subcontractor may choose to not clean the surfaces and instead manage those uncleaned non-porous materials as asbestos waste at a minimum or otherwise, if required, as determined by the RCRA characteristics sampling.

4.3 Miscellaneous Materials

Due to the small scale, simple use, and relative antiquity of the buildings and their systems, additional miscellaneous regulated and/or hazardous waste is anticipated to be very limited in nature and scope. The Environmental Consultant will conduct daily inspections of the abatement work area to identify suspect components for segregation and testing and/or other determination.

Any material classified as "unknown" during the project will require sample collection and analysis for full RCRA characteristics in accordance with 40 CFR Part 261 (as described in Section 4.1.3 of this Plan) and will be disposed of based upon the results of that sampling and the nature of the waste. If the material is classified as RCRA hazardous waste, additional sampling may be required for "total" concentrations of specific contaminants to determine whether the waste may be land filled or is "land banned"; the contaminants to be analyzed for will depend on the specific waste classification of the waste.

4.4 Structure and Facade

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 Structure & Facade of the building would also not be hazardous. Random confirmatory sampling of the various deconstruction waste categories will be conducted to confirm the status of the structure and facade as C&D waste.

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NYC-WTC 000135130