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

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

For each of the structural and façade material categories noted at the site, 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.

7.0 Non-porous (cleanable) Waste

For cleaned (wet-wiped/HEPA-vacuumed) non-porous deconstruction waste, samples will not be collected unless the non-porous components are painted and to be disposed of. Cleaned painted scrap metals that are recycled are exempt from the below described waste characterization sampling and analysis. For non-porous components that are painted, one composite sample made up of a minimum of four grab samples of each distinct painted non-porous building component (based on paint color, building component type and zone in which the component is located) will be collected for RCRA lead, chromium and cadmium analysis. Each grab sample will be collected as a core sample (i.e., both painted surface and building component matrix) and sent to the lab under COC for analysis.

Likewise, cleaned, painted, non-porous deconstruction waste with TCLP lead, chromium and cadmium results of less than applicable standards would also be classified, managed and recycled/disposed of as non-hazardous C&D debris.

Cleaned, painted, non-porous deconstruction waste with TCLP lead, chromium and cadmium results greater than applicable standards would be classified, managed and disposed of as hazardous waste with the toxicity characteristic of lead, chromium and/or cadmium.

Non-cleaned, non-porous deconstruction waste will be disposed of as asbestos waste at a minimum for the reasons indicated previously. Should results of the settled dust classification sampling indicate that the dust results exceed the regulatory threshold for one or more RCRA characteristics, the waste will be managed as both a RCRA waste of the appropriate waste code as well as asbestos waste.

8.0 Storage

For the most part, waste will be live-loaded from the site. If necessary, an enclosed, locked area will be maintained on site for the storage of waste material prior to off-site disposal. Waste streams will be separated and stored as described below. The waste storage area will be enclosed and located away from the point of waste generation. Incompatible wastes will not be stored next to each other. Containers or incompatible wastes will be segregated. All containers in the waste storage area will have proper labeling, which included information such as waste type and accumulation start date. Weekly inspections will be conducted to confirm that containers are properly stored. The condition of each individual container, any secondary containment within the storage area, and posted signs will be inspected. Each inspection will be documented on a weekly inspection log to demonstrate compliance.

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NYC-WTC 000135140