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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

All waste materials will be transported in accordance with applicable local, state and federal DOT regulations including, but not limited to, bills of lading, manifests, placards, etc. All wastes will be shipped using properly permitted vehicles operated by drivers with Commercial Drivers Licenses (CDLs) and Hazardous Materials endorsements. All hazardous waste will be shipped using transporters with RCRA identification numbers. The actual modes of transportation to be utilized will be determined following the identification of all anticipated waste streams and will take into account the location and distance to the selected disposal facility as well as cost considerations. All off-site shipments of waste will adhere to the site-specific transportation requirements. As required by NYSDEC (6 NYCRR Part 364) all hazardous and asbestos wastes will be transported using Part 364 permitted haulers. All haulers will be required to submit for approval and follow a Spill Contingency Plan.

10.0 Travel Routes

Travel route(s) will be determined following discussion with the appropriate regulatory agencies (e.g., New York City Department of Transportation), and the Lower Manhattan Construction Command Center (LMCCC). The selected waste transporter(s) will follow the designated travel routes. The Abatement Subcontractor has submitted to the Contractor for acceptance waste removal and transportation procedures, which are currently under review. Upon approval of the proposed Abatement Subcontractor's Proposed Waste Removal and Transportation Procedures, the approved procedures will be appended to this plan and incorporated by reference. All waste travel routes will be consistent with the approved procedures.

11.0 Disposal Requirements

Waste recycling/disposal facilities will be selected based on several factors including waste types, facility acceptance criteria, regulatory compliance history, etc. Only those facilities that have valid federal/state/local permits to accept the waste type proposed for recycling/disposal at the facility will be used.

12.0 Documentation All applicable local, state and federal documentation and record keeping requirements/guidelines will be followed. Documentation for hazardous waste disposal includes Hazardous Waste Manifesting, EPA Generator ID, EPA transporter ID, EPA ID for waste disposal facility and waste storage locations and capacities. Also documented will be emergency notification and operating procedures, worker training records (HAZWOPER, Asbestos, etc.), organizational chart, unexpected waste procedures, contractor involvement list and copies of the regulatory requirement certifications of transporters, disposal facilities, etc. Specific regulatory documentation may change depending on the types and amounts of waste to be generated. The Contractor shall be responsible for document management.

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NYC-WTC 000135144

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NYC-WTC_000135144Source: NYC Law Department, mirrored locally

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