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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

The results of RCRA characteristic analyses, the classification of the material based on historical information, as well as the material's status as presumptively asbestos-contaminated, will be used as the basis for the Waste Profile for the particular waste stream.

6.0 Sampling Frequencies

6.1 Regulated Contaminants

The limited ACBMs at the site have been identified and located. The Limited WTC Dust at the site has been sampled to the degree possible.

6.2 Deconstruction Waste

For each of the Deconstruction Waste Materials listed in section 2.2 above, five confirmatory waste samples will be collected and composited for analysis (one analysis per material). Results will be available prior to the commencement of site work.

6.3 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. The Environmental Consultant will make determinations as to the appropriate testing required to characterize any materials encountered.

In general, the following will apply:

6.3.1 Light Ballasts:

During deconstruction activities, as ballasts are removed from lighting fixtures, the Abatement Subcontractor shall clean the surfaces of dust and containerize ballasts for disposal as PCB waste. All ballasts, including those labeled "No PCB" will be containerized for disposal as PCB waste due to the presence of potting material. For potentially PCB-containing equipment other than ballasts, PCB samples may be required to determine whether the dielectric fluid contains more than 50 parts per million. (ppm) PCBs, which would make the equipment subject to the PCB regulations. SW-846 Method 8082, Analysis of Polychlorinated Biphenyls by Gas Chromatography is specified by regulation for determining the concentration of PCBs in wastes.

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NYC-WTC 000135136

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NYC-WTC_000135136Source: NYC Law Department, mirrored locally

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