NYC-WTC_000231976

NYC 9/11 Public Portal Document

Section 2 - Ambient Air Monitoring Program Revision No.: 0 130 Liberty Street Deconstruction Plan Date: September 7, 2005 Lower Manhattan Development Corporation

1.0 INTRODUCTION 1.1 Project Background and Evolution

This document entitled Ambient Air Monitoring Program for the 130 Liberty^ Street Deconstruction Project (Plan) represents a revised and combined air monitoring plan incorporating the following two prior plans: (i) the Draft Plan provided as Section 2 of the Draft Deconstruction Plan issued by Contractor on December 10, 2004 and (ii) the companion plan prepared by TRC Environmental Corporation (TRC) entitled Proposed Enhanced Exterior Air Monitoring Approach and Conceptual Design 130 Liberty Street (October 8 2004). Both of these documents were issued by the Lower Manhattan Development Corporation (LMDC) in December 2004 for review and comment by federal, state, and local regulators and the general public. At the time of release, readers of the two companion plans were advised by LMDC that, due to their independent development, there were redundancies and a good deal of overlap in the two plans. For this reason, LMDC intended to revise the two programs to ensure that the Contractor’s and property owner’s monitoring programs were complementary and contained the necessary overlap to serve Quality Assurance/Quality Control purposes.

The December 2004 plans were submitted to regulatory agencies for review. Written responses from the United States Environmental Protection Agency (USEPA), the New York State Department of Environmental Conservation (NYSDEC), and the New York State Department of Labor (NYSDOL) addressing the December 2004 plans were provided to LMDC on January 31, 2005. Thereafter, on June 13, 2005 a revised Air Monitoring Plan was submitted to the applicable regulatory agencies addressing the agencies’ January 31,2005 responses.

Under cover of a letter from USEPA dated July 26, 2005, the regulators provided additional responses concerning the Air Monitoring Plan. These July 26, 2005 responses have also been addressed and incorporated into this Plan.

Additionally, subsequent to release of the December 2004 air monitoring plans, an approved monitoring plan for the deconstruction of 4 Albany Street was issued. This plan, entitled Specifications for Community Environmental Monitoring During Abatement and Demolition of 4 Albany Street (December 22, 2004), was approved for use by many of the same regulatory agencies reviewing the deconstruction of 130 Liberty. Accordingly, and at the direction of the regulators, the Plan adopts many of the features of the 4 Albany Street monitoring program. Most notably, the Plan adopts the two tiered system of action levels approved for use at 4 Albany Street.

Once approved, the Plan will be implemented and administered by the LMDC Environmental Consultant during Phase I and Phase II of the deconstruction of the 130 Liberty Street property. This Plan does not provide all of the details of the quality assurance/quality control measures that will be implemented by LMDC. Instead, these measures are addressed in a Quality Assurance Project Plan (QAPP) that is being submitted contemporaneously herewith and is incorporated herein by this reference. Compliance with the QAPP is a required component of this Plan.

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NYC-WTC_000231979