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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

8.1 Hazardous Waste

Hazardous waste will be placed in containers (e.g., USDOT approved drums, bags, roll-off containers) and transferred to the waste storage area prior to off-site disposal. Drums will be closed at all times during storage, except when waste is added or removed. Drums will be stored in manner to prevent ruptures or leaks in the waste storage area. Containers will be inspected to ensure containers are not over packed or leaking.

Hazardous waste may be kept in the waste storage area for up to 90 days from the accumulation start date. If the generator status should change from large quantity generator to small quantity generator, then up to 13,200 pounds of waste may be stored in the waste storage area for up to 180 days from the accumulation start.

8.2 Universal Waste

Universal waste will be treated according to hazardous waste regulations. See 8.1 above.

8.3 Asbestos Waste

Waste containing asbestos will be wet down to prevent visible emissions of asbestos dust into the air. The asbestos waste will be sealed while wet in a leak- tight container. A supply of leak tight containers will be kept in the waste storage area to provide adequate repackaging if a break in the container should occur. Storage area shall be maintained under a negative pressure ventilation system. Daily inspections of the waste storage area shall be required.

Storage of asbestos waste will not exceed 50 cubic yards. Authorization from the New York City Department of Sanitation (NYCDOS) and additional requirements, per code, will be required if accumulation of asbestos is anticipated to be greater than 50 cubic yards. Containers holding asbestos waste will be inspected daily to ensure no visible emissions of asbestos dust in the air or breaks in the container.

8.4 PCB Waste

Non-leaking waste PCB waste will be placed in containers and maintained in the waste storage area prior to disposal. Any leaking PCB articles or containers will be transferred to properly marked, non-leaking containers or an over-pack containers. Leaking waste PCB articles and equipment that cannot be transferred to a non-leaking container or over pack container will be placed in a containment pad with sorbent material and tarp. PCB bulk product waste, including fluorescent light ballasts, may be kept in the waste storage area up to 180 days.

9.0 Transportation Requirements

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NYC-WTC 000135142

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NYC-WTC_000135142Source: NYC Law Department, mirrored locally

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