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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

Analyses conducted to support to support waste characterization will be performed according to the following methodologies. Where more than one method is identified, each analytical method is valid per the regulations. All allowable methods are included in this plan to allow for flexibility in selecting an analytical laboratory(ies).

5.1 Ignitability

The characteristic of ignitability carries the RCRA waste code of D001, and may be analyzed for using American Society of Testing Materials (ASTM) method D- 93-79 or D-93-80 or D-3278-78.

5.2 Corrosivity

The characteristic of corrosivity carries the RCRA waste code of D002, and may be analyzed using Method 9045C as set forth in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication §W-846. SW-846 method 9040 (whether B or C) is for aqueous wastes and multiphase waste where the aqueous phase constitutes at least 20% of the total volume of the waste; 9045C is for soils and waste samples where the waste may be solids, sludges, or non-aqueous liquids. The aqueous phase must be less than 20% of the total volume of the waste.

5.3 Reactivity

The characteristic of reactivity carries the RCRA waste code of D003, and may be analyzed using the analytical methods outlined in sections 7.3.3.2 or 7.3.4.2 of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. The referenced sections are from SW-846 Chapter Seven: Characteristics Introduction and Regulatory Definitions. They are specifically for Reactivity. Chapter Seven was revised to reflect the withdrawal of the reactive cyanide and sulfide guidance in sections 7.3.3 ("Interim Guidance for Reactive Cyanide") and 7.3.4 ("Interim Guidance for Reactive Sulfide"), and to replace certain characteristic explanatory text with referrals to the regulations themselves. This change can be found in the Proposed Update IIIB to SW-846.

5.4 Toxicity

The characteristics of toxicity carry the RCRA waste codes of D004 through D043. Each waste code identifies the specific chemical component for which the waste is classified as toxic. The samples to be analyzed for the characteristic of toxicity must be prepared using the Toxicity Characteristic Leaching Procedures (TCLP) per Method 1311 in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. The analytical method applied to the resulting leachate depends on the type of chemical being analyzed for, as follows:

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