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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

- Volatile organic compound (VOC) toxic constituents will be analyzed by Method 8260B of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. VOC toxic constituents include benzene (D018), carbon tetrachloride (D019), chlorobenzene (D021), chloroform (D022), 1,4-dichlorobenzene (D027), 1,2- dichloroethane (D028), 1,1-dichloroethylene (D029), methyl ethyl ketone (D035), tetrachloroethylene (D039), trichloroethylene (D040), and vinyl chloride (D043).

- Semivolatile organic compound (SVOC) toxic constituents will be analyzed by Method 8270C of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. SVOC toxic constituents include 2,4-dinitrotoluene (D030), hexachlorobenzene (D032), hexachlorobutadiene (D033), hexachloroethane (D034), o-cresol (D023), m- cresol (D024), p-cresol (D025), cresol (D026), nitrobenzene (D036), pentachlorophenol (D037), pyridine (D038), 2,4,5-trichlorophenol (D041), and 2,4,6-trichlorophenol (D042).

- Pesticide toxic constituents will be analyzed by Method 8081A of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. Pesticide toxic constituents include chlordane (D020), endrin (D012), heptachlor and its epoxide (D031), lindane (D013), methoxychlor (D014), and toxaphene (DO15).

- Herbicide toxic constituents will be analyzed by Method 8151A of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. Herbicide toxic constituents include 2,4-D (D016) and 2,4,5-TP (also known as Silvex, D017).

- Mercury (D009) will be analyzed by Method 7470A (aqueous samples) of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846.

- Metals/inorganics other than mercury will be analyzed by Method 6010B of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846. These constituents include arsenic (D004), barium (D005), cadmium (D006), chromium (D007), lead (D008), selenium (DO10), and silver (DO1 1).

Generally, building components would not be considered as possible RCRA characteristic wastes except for the potential that exists due to impacts by WTC dust. The notable exceptions to this would be painted surfaces, which would typically be sampled for TCLP lead, cadmium and chromium analysis as well as miscellaneous materials containing hazardous components prior to WTC impact (such as transformers, ballasts, lamps, etc.).

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NYC-WTC_000135134Source: NYC Law Department, mirrored locally

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