Regulatory Submittal Part IV(R) Remediation Phase. Waste Sampling and Management Plan

Transcription

1 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Remediation and Deconstruction of Fiterman Hall 30 West Broadway New York, New York Prepared for: Dormitory Authority of the State of New York & City University of New York Prepared by: Airtek Environmental Corp. 39 West 38 th Street New York, NY Date: Revised March 7, 2008

2 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Table of Contents 1.0 General Background 1.2 Objective 1.3 Remediation Phase 1.4 Deconstruction Phase 1.5 WTC Dust Waste Characterization 2.0 Primary Material Categories Contaminated Materials and ACM/LBP Building Materials 2.2 PPE and Remediation Process Consumables 2.3 Remediation Process Liquids 2.4 Universal Waste 2.5 PCB Waste 2.6 Refrigerant-containing Equipment 2.7 Shreddable Materials 2.8 Non-porous Waste 2.9 Roofing Materials 2.10 Heavy Equipment 2.11 Unanticipated (Other) Waste 3.0 Remediation Phase Waste Characterization Previously Characterized Waste 3.2 Uncharacterized Waste 4.0 Sampling Frequencies ACM/LBP Building Materials 4.2 PPE and Remediation Process Consumables 4.3 Remediation Process Liquids 4.4 Universal/PCB Waste 4.5 Refrigerant-Containing Equipment 4.6 Shreddable Materials 4.7 Non-porous Waste 4.8 Roofing Materials 4.9 Heavy Equipment 4.10 Unanticipated (Other) Waste 5.0 Analytical Methodologies Toxicity 5.2 RCRA Characteristics 5.3 Total PCBs 5.4 NYC Sewer Discharge Parameters 6.0 Waste Packaging & Storage ACM Waste 6.2 Lead Based Paint Waste 6.3 PPE and Process Consumables 6.4 Remediation Process Liquids 6.5 Universal Waste 6.6 Refrigerant Containing Equipment 6.7 Shreddable Materials 6.8 Non-porous Materials 6.9 Roofing Materials 6.10 Heavy Equipment 6.11 Unanticipated (Other) Waste 7.0 Transportation Requirements Travel Routes Disposal Facilities Documentation 24 2

3 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Attachment A: Waste Routes Attachment B: Waste Storage Areas Attachment C: Quality Assurance Project Plan Attachment D: Previous Waste Characterization Results 3

4 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, General 1.1 Background Pei Cobb Freed & Partners, Architects, LLP (PCF-P) has engaged the Environmental Consultant, Airtek Environmental Corp. (Airtek) on behalf of the Dormitory Authority of the State of New York (DASNY) and the City University of New York (CUNY) to prepare a Waste Sampling and Management Plan (WSMP) in support of the remediation and deconstruction of Fiterman Hall, located at 30 West Broadway, New York, NY (the Building). This plan is intended to be applied to the Remediation Phase of the project, and is in response to a request by the WTC Regulators for a documented approach to the project, and is Part IV(R) of the Regulatory Submittal Package. A separate document addressing waste management during the subsequent Deconstruction Phase of the project will be developed along with the Deconstruction Phase Work Plan. 1.2 Objective The objective of the WSMP is to characterize, manage, containerize and legally transport and dispose of waste streams that will be generated as part of the Fiterman Hall Remediation and Deconstruction Project. The Building was severely impacted by fallout from the events of September 11, It is the Owner s intent to conduct remediation of WTC-related contamination and abatement of in-place asbestos (ACM) and other regulated building components so that conventional deconstruction of the Building can be completed. Waste characterization in support of this effort is an ongoing process that involves active inspection on the part of the Owner s Environmental Consultant of the work conducted and the waste generated by the Contractor. 1.3 Remediation Phase The Remediation Phase of the project includes the Scaffold Erection Operation detailed in a previous submittal, and the removal of all interior non-structural elements within the building under an environmental containment system. The remediation will be conducted so that the building can be safely deconstructed to allow for redevelopment of the Site. In general, all interior building components and fixtures and furnishings are considered to be asbestos-contaminated and will be handled, packaged, stored and disposed as ACM waste. Certain non-porous items may be cleaned and disposed of as conventional waste if they can be demonstrated to be cleanable. The Remediation Phase of the project will occur under a negative pressure containment and includes the following general categories: (a) the general area cleanup of WTC dust and debris; (b) removal and disposal of installed porous and certain non-porous building materials, furnishings and components; (c) cleaning and salvage of certain installed non-porous building equipment and components; (d) removal of building materials containing asbestos which were present in the Building prior to September 11th, 2001; (e) 4

5 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 packaging of asbestos and other regulated waste including, but not limited to, light bulbs, lighting ballasts, mercury-containing thermostats, etc. at generation points and (f) movement of containers to the decontamination unit and movement of decontaminated containers to waste loading areas. 1.4 Deconstruction Phase The Deconstruction Phase of the project includes the structural deconstruction of the building after environmental clearance inspections and clearance testing have released the structure for conventional deconstruction. The term conventional deconstruction is defined for the purposes of this document as deconstruction conducted without the use of the special engineering controls typical of environmental remediation projects. The term conventional waste is defined for the purposes of this document as waste that is not environmentally regulated (i.e., construction and demolition C&D waste, recyclable waste). A separate WSMP will be developed to address waste management during the Deconstruction Phase. 1.5 WTC Dust Waste Characterization As detailed in the Preliminary Regulatory Submittal for the Fiterman Hall project, dated January 10, 2006, waste characterization sampling and analysis of dust throughout the structure was conducted. The purpose of this testing was to assess the potential impact of WTC dust incursion on the waste classification of conventional building materials and contents. For purposes of this document, the terms conventional building materials and conventional contents refer to items within the building that would not be classified as suspect ACM/LBP, suspect hazardous waste, suspect Resource Conservation and Recovery Act (RCRA)-regulated waste, or suspect PCBregulated waste. As an example, sheetrock and wood desks would be considered respectively as conventional building materials and conventional contents. As a converse examples, window caulk and older pipe elbows would not be considered conventional materials due to the potential PCB content of the window caulk, and the potential asbestos content of the pipe elbows. The results of the dust characterization study indicate that the dust throughout the structure is not hazardous waste, RCRA-regulated waste or PCB-regulated waste. Therefore, conventional building materials and conventional contents are not suspected to be regulated just by their contact with the WTC dust. As such, no further waste characterization of these conventional material classes will be conducted. Not withstanding these results, all interior building components are assumed to be contaminated with asbestos and will be treated as ACMcontaminated as detailed in this document. Certain non-porous items may be cleaned and disposed of as conventional waste if they can be demonstrated to be cleanable. 5

6 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Further waste determinations, as necessary, will be made by the Owner s Environmental Consultant as described in this document and the associated Quality Assurance Project Plan (QAPP). The Contractor or its authorized representative will ensure proper handling and disposal activities as described in this Plan. 2.0 Primary Material Categories This WSMP has been developed to address the handling, packaging, storage, transport and disposal of all waste materials generated by the Remediation Phase of the project. Anticipated waste streams for the project are listed below: 2.1 Contaminated Materials and ACM/LBP Building Materials Interior Surface Dust Asbestos-containing Building Materials (ACBM) Lead-Painted Components (LBP) Sprayed-on Fireproofing All interior non-structural building components and furnishings 2.2 PPE and Remediation Process Consumables Personal Protective Equipment (suits/filters/gloves/booties) Abatement Materials (rags, bags, poly sheeting) HEPA Vacuum Bags/Negative Air Filters Miscellaneous Contaminated Disposables 2.3 Remediation Process Liquids Cleaning Process Liquids Decontamination Unit Liquids 2.4 Universal Wastes (40 CFR Part 273 and 6 NYCRR Section 374.3) 2.5 PCB Waste Fluorescent Light Bulbs (Mercury) Switches and Thermostats (Mercury) Fluorescent Light Ballasts 2.6 Refrigerant-containing Equipment HVAC Equipment 6

7 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Refrigerators 2.7 Shreddable Materials Sheetrock Duct Work Ceiling Tile Wood Non-Asbestos Floor Tile Metal Studs Black Iron Porcelain Ceiling Grid No waste categorized under any other regulated waste category (universal waste, hazardous waste, et. al.) will be processed through the shredder. Likewise, no asbestos-containing building materials (manufactured building materials with asbestos content of greater than 1% by weight) will be processed through the shredder. 2.8 Non-Porous Waste Duct Work Ceiling Grid Electrical Conduit Doors Piping 2.9 Roofing Materials Stone Ballast Ballast Fines Roof Membrane ACM Roof Membrane (14 th Floor North) Cooling Tower 2.10 Heavy Equipment Generator Air Handlers Chillers Cooling Tower Elevator Cars Motors 7

8 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, Unanticipated Waste Materials Materials, if any, encountered during the work that are suspect regulated waste and have not been previously categorized for waste handling and disposal will be identified, quantified, and characterized by the Owner s Environmental Consultant. Representative testing will be conducted as discussed in Section 4.0 below. Solid materials will be tested for RCRA/PCB compliance, liquids intended for filtration and disposal to the NYC Sewer will be tested for RCRA/PCB compliance and also for NYCDEP sewer discharge parameters. The classification of building components will be an ongoing effort and will be conducted by the Owner s Environmental Consultant in accordance with applicable New York City, New York State and federal laws, rules and regulations. This Plan is intended as a working document to be used during ongoing operations at the Site, and will be updated as necessary as new information becomes available. 3.0 Remediation Phase Waste Characterization Waste testing conducted to date is discussed below. In brief, dust collected from throughout the structure, PPE and process consumables used throughout the structure, and cleaning process and decon shower water were tested. None of the results exceeded levels at which the tested materials would be classified as RCRA or PCB regulated waste and the water tested also met NYC Sewer discharge criteria. As a result, conventional building materials and contents of similar WTC impact would not be sampled for RCRA/PCB parameters unless there is an independent concern that they might be so regulated due to the inherent composition of the component, subcomponent or waste stream. Representative light ballasts were collected from the building and tested for PCBs in their potting material. A significant percentage of the ballasts tested positive for PCBs. As a result, all ballasts in the building will be assumed to contain PCBs and will be handled, packaged, stored, transported and disposed of as PCB waste. 3.1 Previously Characterized Waste Dust Preliminary testing of WTC dust within the building was conducted to identify areas of the building where concentrations of RCRA regulated contaminants within WTC dust may exist. Dust was collected with HEPA vacuums from at least five distinct areas of each floor of the building. As the sampling team moved down through the building, a geographic zone was selected for each floor (east, north, south, west, center, or throughout), and sampling as concentrated in that zone. The purpose of this bias was to allow geographic trends to be identified for further investigation in the event of detections and/or exceedances of RCRA/TSCA criteria. Samples 8

9 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 (including the HEPA vacuum bag used to collect the samples, were submitted for full TCLP, total PCB and RCRA characteristic analyses. Based on observation of site conditions and the number of samples taken, the sampling conducted is considered to be representative of the site dust loading conditions. Results are included in Attachment D. Note on RCRA Ignitability: Review of the dust characterization results will reveal that some of the dust samples are characterized as Ignitable by the laboratory. Under RCRA, ignitability is a characteristic assigned to liquids with a low flashpoint that could ignite during handling, transport or disposal creating a hazardous situation. In this particular case, the samples were noted as ignitable due to the paper components of the HEPA vacuum-cleaner bag used to collect the samples. Under RCRA hazardous waste definitions, these materials are not characterized as Ignitable PPE and Process Consumables PPE and process consumables (plastic, filters, etc.) used throughout the building during the characterization phase have been subject to waste characterization testing. None of the PPE or process consumables analyzed to date have tested above the applicable regulatory limits Cleaning Liquids Decontamination Unit wash water and all other water collected during the cleaning operations that supported the characterization phase was drummed and tested for RCRA/PCB waste characterization parameters and for NYCDEP Sewer discharge parameters. None of the cleaning/decon water analyzed to date has tested above the RCRA/PCB limits or the NYC Sewer Discharge Limits Caulking Materials In addition to testing for asbestos content, caulking materials were sampled and analyzed for total PCBs. None of the caulking materials tested over the 50 ppm limit for PCB content Roofing Materials Although the roof ballast on the building was cleaned as a part of the NYC DEP Exterior Cleaning Program, the materials were re-tested for waste characterization. Ballast stone was moved and ballast fines were collected from each roof and roof setback. As the ballast fines tested below the RCRA/PCB limits in all cases, the ballast stone and roof membranes are not considered suspect RCRA/PCB waste. Due to the potential for recontamination over the time since the NYC DEP cleaning, the roofing 9

10 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 materials are considered ACM-contaminated. ACM testing of roof materials indicates that the north section of the 14 th floor setback roof is ACM, and it will be treated as such per Part I(R), and disposed as such per Part IV(R). Likewise, the cooling tower fill is considered to be ACMcontaminated and will be treated as such. Due to the fact that the physical damage to the building included certain areas of roof on the fifth, 14 th and 15 th floors, it was decided by the Owner s Environmental Consultant to assume that some contamination of roof components such as roof membrane and insulation was possible. It was decided that the wet removal of all roofing system components down to the roof slab would be advisable at the gash area edge of the roofs. It was decided based on site inspection that these removals to a distance of ten feet from the roof edge at the gash area would be sufficient to ensure the abatement of all suspect WTC-contamination that might have infiltrated the edge of the roofing system. The roofing materials in these areas were tested for their integral asbestos content, and are non-asbestos. Upon completion of roofing removal from the demarcated area in all gash area roof levels, an additional visual inspection by the OEC Asbestos Project Monitor will be conducted at the edge of the roofing that remains. This inspection will be conducted and documented in a similar manner to the scaffold tie-in inspections conducted during the Scaffold Erection Operation. If it is determined that WTC dust/debris exists at any of the subject locations, additional abatement by wet methods will be conducted of an additional demarcated area out to a distance to be determined in consultation with the Regulators Shreddable Waste All waste processed through the shredder is assumed to be ACM waste and will be handled, packaged, stored, transported and disposed as such Light Ballasts All light ballasts within the building will be assumed to contain PCBs and will be cleaned for WTC dust and packaged for disposal as PCB waste Façade Brick and Mortar During the Scaffold Erection Operation Pilot Program, brick and brick mortar samples were collected for testing for waste characterization parameters. These materials were observed to be visually clean of WTC dust, and test results confirm their status as conventional (C&D) waste. Results of this testing are included in Attachment D. 10

11 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, Uncharacterized Waste Any uncharacterized material suspected to be hazardous waste or other RCRA/PCB regulated waste will be tested and evaluated based on its composition. For materials requiring sampling, a representative sampling strategy will be used as detailed in Section 4.0, and composite samples representative of the suspect waste streams will be collected. The locations and frequency of samples to be combined into composite samples shall be determined by the Environmental Consultant such that a representative sample of the waste type has been obtained. All sampling personnel shall be familiar with sample collection and waste storage protocols and shall have been trained appropriately per the Health and Safety Plan. The waste classification samples will be sent to laboratories accredited by the NYS Department of Health under the ELAP Program, certified under 6 NYCRR Section 370.1(f), and qualified for waste classification analysis (e.g., TCLP, total PCBs and RCRA characteristics). Testing will determine waste classification and handling requirements (40 CFR Section ). Liquid to be filtered to the NYC Sewer will also be tested for NYC Sewer Discharge Criteria. Other sampling and laboratory analysis may be required by the disposal facility prior to waste acceptance. The laboratory subcontracted to perform the analysis will also be certified through NYSDOH ELAP for the analytical parameters being analyzed. All potentially hazardous waste will be managed as hazardous waste until analytics prove otherwise. If greater than 100 kg/month of hazardous waste is generated during the deconstruction process, Contractor will comply with, among other things, 6 NYCRR Part 373, Subpart 373-3, section (b). If results of waste characterization sampling and analysis dictate that waste material must be managed and disposed of as both an asbestos and another regulated waste (i.e., hazardous, RCRA-regulated, or PCB-regulated waste) both asbestos and hazardous/rcra/pcb waste management and disposal requirements as applicable will be met. If there are conflicts between the requirements for asbestos and another regulated hazardous waste that preclude compliance with both, then the hazardous waste requirements will dictate specific management and disposal requirements. If 50 ppm or more PCBs are detected in any waste stream the materials will be classified as both federal Toxic Substances Control Act (TSCA) waste and New York State hazardous waste. 4.0 Sampling Frequencies 4.1 ACM Building Materials 11

12 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Prior, extensive ACM surveys and testing have been conducted on the building. Any additional Suspect-ACM materials encountered during the work will be sampled by the Owner s Environmental Consultant according to Asbestos Emergency Response Act (AHERA) protocols and analyzed by a laboratory accredited under the NYSDOH ELAP program and the US Dept. of Commerce NVLAP program. 4.2 PPE and Remediation Process Consumables Dust throughout the building has been tested and confirmed to be below RCRA/TSCA limits. PPE and remediation process consumables from throughout the building were sampled during the Characterization Phase and have been tested and confirmed to be below RCRA/TSCA limits. Further testing of these materials is not planned. If conditions are noted during the Remediation and Deconstruction Phases that indicate a site condition or waste source that is determined by the Owner s Environmental to be as yet uncharacterized, further testing may be conducted. In that event, representative samples will be tested for waste characterization per Section 5.0. One composite sample comprised of at least five grab samples will be collected at the personal decon in the case of PPE used for a suspect operation, and one composite sample comprised of at least five grab samples will be collected at the waste decon in case of rags, and/or other cleaning materials used for that operation. 4.3 Remediation Process Liquids Characterization Phase remediation process liquids from throughout the interior of the building and the decontamination unit shower water were tested and confirmed to be below RCRA/TSCA limits and determined to meet NYC Sewer Discharge Criteria. Further testing of remediation process liquids originating from within the building is not planned. Remediation process liquids determined to be of an uncharacterized source (i.e., exterior wash liquids, roof ballast liquids, and any other remediation process liquids determined by the Owner s Environmental Consultant to be from an uncharacterized source) will be captured, drummed, and stored in the secure waste storage facility with secondary containment until analytical testing is complete. Liquids intended for filtration and disposal to the NYC Sewer will be tested for RCRA/TSCA compliance and also for NYCDEP sewer discharge parameters. If the contractor chooses to dispose of some of the drummed liquids as opposed to filtering to the NYC sewer, the RCRA/TSCA testing would be conducted, but the NYC Sewer discharge testing would not be conducted on those liquids. Aliquots will be collected from each drum of every set of five drums of water and composited into one sample. If fewer than five drums are available, one aliquot from each subject container will be collected for compositing. 12

13 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 A dewatering permit is only required by the NYC DEP for quantities exceeding 10,000 gallons. It is not anticipated that this project will produce that quantity of waste water. 4.4 Universal Waste/PCB Waste Universal waste as defined by 40 CFR Part 273 and 6 NYCRR Section is anticipated to be generated by the Remediation Phase. These materials (fluorescent bulbs, thermostats, etc.) will be assumed to be Universal Waste, will be cleaned of surface dust by HEPA vacuuming and wet wiping and will be drummed for disposal as Universal Waste. Fluorescent light ballasts will all be assumed to be PCB-containing waste after testing indicated that a significant percentage of ballasts within the building contained PCBs. Any other mechanical/electrical equipment suspected of containing PCBs, other than Universal Waste discussed above, will be investigated and tested for total PCB content. Each suspect PCB source will be tested individually for total PCBs per section 5.0. Given that the majority of the mechanical/electrical equipment in the building was newly installed in 2001, it is unlikely that further equipment containing PCB compounds will be identified, 4.5 Refrigerant-Containing Equipment Refrigerant-Containing Equipment will have been purged of refrigerant during the SEO operations. The equipment itself is considered ACM contaminated. No further testing is planned. 4.6 Shreddable Waste Most interior non-structural building components, including those listed in Section 2.6 will be processed through an industrial grade shedding machine as detailed in Regulatory Submittal Part I(R) Remediation Work Plan. All shreddable waste will be assumed to be ACM waste and will not be tested further. 4.7 Non-Porous Waste Non-Porous Deconstruction Waste may be managed by either of two options. The Abatement Subcontractor may choose to clean the non-porous surfaces in accordance with procedures outlined in the Part I(R) - Work Plan. The resulting cleaned material will not be sampled unless it is painted; in that instance, sampling will be performed as described below. Alternatively, based on field conditions and decisions regarding the use of its labor force, the Abatement Subcontractor may choose to not clean the surfaces and instead manage those uncleaned non-porous materials as asbestos waste at a minimum or otherwise, if painted, as determined by the RCRA characteristics sampling. 13

14 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 For cleaned (wet-wiped/hepa-vacuumed) non-porous deconstruction waste, TCLP RCRA Metals samples will not be collected unless the non-porous components are painted and to be disposed of (i.e., not recycled). Cleaned unpainted 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 TCLP RCRA Metals 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 chain-of-custody procedures for analysis. Cleaned, painted, non-porous deconstruction waste with TCLP RCRA Metals 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 RCRA Metals results greater than applicable standards would be classified, managed and disposed of as hazardous waste with the toxicity characteristic of the exceeded RCRA Characteristic. Cleaned, unpainted, non-porous deconstruction waste will be visually inspected by the Environmental Consultant in general accordance with the procedures outlined in ASTM Guideline E 1368: Standard Practice for Visual Inspection of Asbestos Abatement Projects, and may be recycled and/or disposed as C&D waste. 4.8 Roofing Materials Ballast stone was moved and ballast fines were collected from each roof and roof setback. As the ballast fines tested below the RCRA/PCB limits in all cases, the ballast stone and roof membranes are not considered suspect RCRA/PCB waste. The materials are considered ACM-contaminated and no further testing will be conducted. 4.9 Heavy Equipment Heavy equipment is considered ACM-contaminated as are all other interior components. No further testing will be conducted Unanticipated (Other) Waste Materials, if any, encountered during the work that have not been previously categorized for waste handling and disposal will be identified, quantified, and characterized by the Owner s Environmental Consultant as detailed in Section 14

15 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, Based on the type, quantity and location of any unanticipated materials, the Owner s Environmental Consultant will develop a representative sampling protocol. If a sampling protocol needs to be developed, it will be provided to the regulators for review and approval prior to final disposal of the unanticipated waste streams. 5.0 Analytical Methodologies Analyses conducted to support waste characterization will be performed according to the following methodologies. Where more than one method is identified, each analytical method is valid per the regulations. 5.1 Toxicity Method 1311 in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846 as follows: Volatile organic compounds (VOCs) - Method 8260B of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW VOC toxic constituents include benzene (D018), carbon tetrachloride (D019), chlorobenzene (D021), chloroform (D022), 1,4-dichlorobenzene (D027), 1,2-dichloroethane (D028), 1,1-dichloroethylene (D029), methyl ethyl ketone (D035), tetrachloroethylene (D039), trichloroethylene (D040), and vinyl chloride (D043). Semivolatile organic compounds (SVOCs) - Method 8270C of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846. SVOC toxic constituents include 2,4-dinitrotoluene (D030), hexachlorobenzene (D032), hexachlorobutadiene (D033), hexachloroethane (D034), o-cresol (D023), m-cresol (D024), p-cresol (D025), cresol (D026), nitrobenzene (D036), pentachlorophenol (D037), pyridine (D038), 2,4,5-trichlorophenol (D041), and 2,4,6-trichlorophenol (D042). Pesticide toxic constituents - Method 8081A of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW Pesticide toxic constituents include chlordane (D020), endrin (D012), heptachlor and its epoxide (D031), lindane (D013), methoxychlor (D014), and toxaphene (D015). Herbicide toxic constituents - Method 8151A of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW Herbicide toxic constituents include 2,4-D (D016) and 2,4,5-TP (also known as Silvex, D017). 15

16 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Mercury (D009) - Method 7470A (aqueous samples) of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW Metals/inorganics other than mercury - Method 6010B, or Method 6020 of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846. These constituents include arsenic (D004), barium (D005), cadmium (D006), chromium (D007), lead (D008), selenium (D010), and silver (D011). 5.2 RCRA Characteristics Ignitability American Society of Testing Materials (ASTM) method D or D or D Corrosivity Method 9045D or 9040C as set forth in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846. National Association of Corrosion Engineers (NACE) Standard TM as standardized in SW-846 shall be utilized to evaluate corrosion rate if the suspected corrosive hazardous waste is a liquid Reactivity or of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW Total PCBs SW-846 Method 8082, Analysis of Polychlorinated Biphenyls by Gas Chromatography is specified by regulation for determining the concentration of PCBs in wastes. 5.4 NYC Sewer Discharge Parameters For any project liquids intended for filtration and disposal to the NYC Sewer, the following testing methodologies will apply: EPA Method 624: SW C/8082: SW /8270C: SW 846/8151: SW /6010: Volatiles NYCDEP Target list PCBs TCLP Base/Neutral/Acids TCLP Herbicides TCLP RCRA Metals 16

17 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 SW /7470: SW /8081: SW /8260: EPA Method 200.7: SW A: EPA 245.1: SW : SW EPA 1664a: EPA 150.1: EPA 420.1/2: TCLP Mercury TCLP Pesticides TCLP Volatiles Cadmium, Copper, Lead, Nickel and Zinc Hexavalent Chromium Mercury Reactivity-Cyanide and Sulfide Flashpoint Non-polar Material ph Total phenols 6.0 Waste Packaging and Storage Locked waste storage areas will be established outside of the building to accommodate both categorized waste awaiting transport, and suspect waste awaiting analyses (see Attachment B for waste storage facility location and configuration). The waste storage facility will be located in an accessible area to allow for regulatory inspection without entering containment. Storage areas will be plasticized, segregated, and any liquid storage will have secondary containment. An inspection will be conducted to identify any NYC Sewer access points proximate to the waste storage facility. Any access points will be sealed. Incompatible waste streams will be segregated, and waste labeling and signage will be in strict accordance with regulations. Within the storage area, posted signs, labeled accumulation start dates, labeled description of the waste, aisle space, proper segregation of incompatible and or/ignitable waste, etc. will be inspected on a daily basis by the Environmental Consultant. Statutory waste volume and holding times shall not be exceeded. All containers on site will have proper labeling, which includes information such as waste type and accumulation date. 6.1 Asbestos Waste Waste containing asbestos, containerized and labeled per NYS ICR 56 may be stored in an area maintained under a negative pressure ventilation system. ACM packaging and waste decontamination procedures will be in accordance with NYS Industrial Code Rule 56. Containers holding asbestos waste will be inspected daily to ensure no visible emissions of asbestos dust in the air or breaks in the container. Storage of asbestos waste will exceed 50 cubic yards. A 100-yard sealed waste trailer will be housed in the regulated waste loading dock until filled for transport. Notification of the 100-yard storage plan will be made to the New York City Department of Sanitation (NYCDOS) in writing. The written notification will include details on the amount to be stored, and the location. 17

18 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, Lead Based Paint Waste Within the building there are three areas where lead based paint remains: a bumper pole located in the loading dock area, a white ceramic sink in the center of the basement mechanical equipment room and a red plaster section of a building column on the east side of the fourth floor. In the existing loading dock there is one lead painted bumper pole present. This lead abatement will be performed in immediately following the completion of asbestos abatement activities in the First Floor Clean Zone. NYS DOL and NYC DEP certified asbestos handlers who also hold valid US EPA Lead Certification will remove the paint from the pole utilizing chemical means. Workers will utilize proper PPE for the duration of lead paint abatement activities. Peel-Away chemical will be applied to the painted surface. Adequate time will be allowed for the chemical application to loosen the painted surface. Once prepared, the loosened lead paint will be scraped from the surface of the pole. Removed paint chips will be containerized in large drums designed to transport lead waste. The drum will be properly labeled, processed through the waste decontamination facility and moved to the existing exterior waste storage facility. Lead waste will be transported by a properly licensed hauler and disposed of at a properly licensed disposal facility. Workers will utilize proper PPE for the duration of lead removal activities. In the Basement Level there is one porcelain sink that contains lead. On the 4 th Floor there is one lead painted column. The entire sink will be removed and disposed of as lead containing material. The lead paint will be removed from the column and disposed of as lead containing waste. This lead removal will be performed during the asbestos abatement activities on the Basement Level and the 4 th Floor. A drop cloth consisting of a single layer of 6mil poly will be placed in an area adjacent to the sink in the Basement. NYS DOL and NYC DEP certified asbestos handlers who also hold valid US EPA Lead Certification will remove the sink from its mounting utilizing manual means and transport it to the Primary Waste Decontamination Facility. The exterior surfaces of the sink will be cleaned by HEPA vacuuming and wet wiping in the Primary Waste Decontamination Facility wash room. Once it has been decontaminated, the sink will be placed in a lead waste drum and transported to the exterior waste storage facility for temporary storage prior to disposal as lead waste. If sizing (breaking up of the sink) is required prior to packaging of the sink, sizing will be conducted in an environmental tent containment outside the building. Wet methods will be utilized to control dust within the tent. The lead paint on the 4 th Floor column is applied to plaster material which is assumed asbestos contaminated. The affected lead painted plaster will be removed from the 4 th Floor column during the asbestos abatement activities on the 4 th Floor. The affected lead painted plaster will be removed from the column by manual or mechanical means. Plaster debris from the lead painted column will be 18

19 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 kept separate from other waste, collected and double bagged in asbestos bags. Bags of lead painted column debris will be sealed with duct tape and placed into drums made of a durable and cleanable material. The drums will be transported to the Primary Waste Decontamination Facility and fully decontaminated. After decontamination, the drums containing lead painted plaster debris will be TCLP d for lead. The drums will then be transported to the lead chamber of the exterior waste storage facility for temporary storage. If TCLP results indicate there is lead present, the drums of lead containing plaster debris will be disposed of as lead waste. If TCLP results are negative for lead the drums of lead containing plaster debris will be disposed of as asbestos waste at a minimum or in accordance with any waste characterization results. 6.3 PPE and Remediation Process Consumables PPE and Remediation Process Consumables will be packaged, labeled and stored as ACM waste at a minimum and based on the results of any additional waste characterization deemed necessary by the Owner s Environmental Consultant as discussed in Section 4.2 above. 6.4 Remediation Process Liquids Decontamination water, wash-down liquids and any other liquid waste will be drummed, labeled and segregated from all other waste for filtration to the NYC Sewer. All liquid waste will be stored in a separate locked storage area with secondary containment sufficient to contain the total volume of stored liquid. If remediation process liquids from an uncharacterized location or source are encountered, they will be drummed, labeled and segregated from all other waste until analytical results determine the waste categorization. 6.5 Universal Waste After having been cleaned of dust with HEPA-vacuuming and wet-wiping procedures, universal waste will be handled, packaged, and stored pending transport according to all regulations governing universal wastes. The requirements for handling, packaging and storage of hazardous waste apply, and are discussed below. Universal waste will be placed in containers made of or lined with materials that will not react with, and are otherwise compatible with, the hazardous waste to be stored so that the ability of the container to contain the waste is not impaired (e.g., USDOT approved drums, bags, roll-off containers) and transferred to the waste storage area pending transport. While being accumulated on-site, each container shall be labeled or marked clearly with the words, Universal Waste. Containers will be inspected at least weekly (and more often if the area is active, as determined by the Owner s Environmental Consultant) to identify any leaks, 19

20 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 and/or deterioration caused by erosion or other factors, and to ensure containers are not over-packed. Universal waste will not be placed in an unwashed container that previously held an incompatible waste. Any disposal container holding a universal waste that is incompatible with any waste or other materials contained nearby will be separated from the other materials or protected from them by means of a dike, berm, wall, or other device. 6.6 Refrigerant-containing Equipment Refrigerant-containing equipment will have been purged in place during the SEO operations by mechanical technicians wearing PPE per the site HASP, entering the building as occasional visitors per the site-specific variance. Once purged, this equipment will be handled in accordance with Part I (R) Section Shreddable Waste Shreddable waste will be packaged in Gaylord Boxes as described in detail in Part I(R). Boxes will then be processed through the decontamination facility and will be transferred directly to the regulated waste loading dock and into a 100-yard sealed ACM waste trailer. No waste categorized under any other regulated waste category (universal waste, hazardous waste, et al) will be processed through the shredder. Likewise, no asbestos-containing building materials (manufactured building materials with asbestos content of greater than 1% by weight) will be processed through the shredder. 6.8 Non-porous Materials Non-porous materials cleaned and inspected per Part I(R) will be transferred directly to the conventional waste loading dock and live-loaded into compactor trucks for compaction and transport to a C&D waste facility. Non-cleanable and non-inspectable items will be treated as ACM at a minimum and according to any testing required as detailed in Section 4.7. Similarly, packaging and storage will be as ACM at minimum unless there reason to suspect they are RCRA or TSCA regulated waste, in which case they will be tested for waste characterization prior to their removal form the remediation work area. 6.9 Roofing Materials The first remediation procedures on this roof will be the loose stone removal and decontamination of the underlying roof membrane surface. These activities will be performed as outlined below and in Remediation Work Plan Section Once decontaminated, the non-acm surface on the west side of the 14 th Floor Set Back Roof Level will be left intact for removal during the structural deconstruction phase. 20

21 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 There is asbestos containing roof membrane on the north side of the Fourteenth Floor Set Back Roof. Upon the completion of loose stone removal and roof surface decontamination on this level, workers will begin the removal of the asbestos-containing roofing. A decontamination facility will be installed on the Fourteenth Floor Set Back Roof level adjacent to the section of ACM roofing membrane. Critical barriers installed during interior remediation operations on all openings within twenty feet of the Fourteenth Floor Set Back Roof will remain in place. The surface of ACM roofing membrane will be wetted down with amended water. NYS DOL and NYC DEP certified asbestos handlers will utilize manual scraping tools to perform the removal. ACM roofing material will be bagged on detachment from the roof surface. Once full, bags will be placed inside a second bag, sealed and properly labeled. The exterior of the bags will be decontaminated and removed from the area via the exterior pipe scaffolding system. Once at ground level, bags of ACM roofing will be live-loaded into asbestos waste trucks waiting at the site. The remainder of the cleaned non-acm roof will be left for removal during the Deconstruction Phase. Cooling tower fill will also be removed during the Remediation Phase. These activities will be performed as outlined below and in Remediation Work Plan Section The tower contains non-asbestos plastic fill material. A waste decontamination facility will be established in an area directly adjacent to the cooling tower unit. Panels will be removed from the tower in order to gain access to the plastic fill. The fill material will be manually loaded into asbestos waste bags, double bagged, properly labeled and disposed of as asbestos waste or in accordance with any waste characterization results since it is not possible to effectively clean. The cooling tower panels are made of metal and will be cleaned by HEPA vacuuming and wet wiping. Once cleaned the panels will be placed on the roof surface adjacent to the cooling tower and secured. The panels will be removed during the structural deconstruction phase and disposed of as conventional construction and demolition (C&D) waste. The interior and exterior surfaces of the cooling tower will be decontaminated by HEPA vacuuming and wet wiping. Once cleaned, the tower structure will be left in place, to be removed during the structural deconstruction phase with other heavy machinery and equipment. If it is not possible to effectively clean the cooling tower unit while it is intact, NYS DOL and NYC DEP certified asbestos handlers will dismantle the tower and clean all the components which will be left where the tower was located for removal during the deconstruction phase. All detached cooling tower components will be secured to the roof to prevent from being blown off prior to disposal during the deconstruction phase. Any components that cannot be cleaned will be removed from the tower, wrapped in two layers of poly, processed through the waste decontamination facility and disposed of as asbestos 21

22 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 waste or in accordance with any waste characterization results during the Remediation Phase. The edge of the roofs at the gash area will be removed during the Remediation Phase. These activities will be performed as outlined below and in Section of the Part I(R) - Remediation Work Plan. In Gash Areas on all affected roof levels, WTC impact is assumed for the edge of the roof system at the Gash only. As stated above, the rest of the roof levels are sealed and non-porous. The contractor shall observe a ten foot (10 ) demarcation from the Gash Area on all affected roof levels. Due to the fact that the physical damage to the building included certain areas of roof on the fifth, 14 th and 15th floors, it was decided by the Owner s Environmental Consultant to assume that some contamination of roof components such as roof membrane and insulation was possible. It was decided that the wet removal of all roofing system components down to the roof slab would be advisable at the gash area edge of the roofs. It was decided based on site inspection that these removals to a distance of ten feet from the roof edge at the gash area would be sufficient to ensure the abatement of all suspect WTC-contamination that might have infiltrated the edge of the roofing system. The roofing materials in these areas were tested for their integral asbestos content, and are non-asbestos. The purpose of the demarcation area is to provide a remediation zone for the assumed WTC impact based on the condition of the compromised roof areas. All ballast in the demarcation area will be cleaned in conjunction with The Office of the City Medical Examiner inspection operations on all affected roof levels. Cleaned ballast will be removed from the 10 demarcation area onto adjacent areas of the roof levels where it will remain for disposal during the deconstruction phase. All roofing membrane in the 10 demarcation area will be removed, handled and disposed as asbestos waste or in accordance with any waste characterization results. ACM roofing material will be bagged on detachment from the roof surface. Once full, bags will be placed inside a second bag, sealed and properly labeled. The exterior of the bags will be decontaminated and removed from the area via the exterior pipe scaffolding system. Once at ground level, bags of ACM roofing will be live-loaded into asbestos waste trucks waiting at the site. Upon completion of roofing removal from the demarcated area in all gash area roof levels, an additional visual inspection by the OEC Asbestos Project Monitor will be conducted at the edge of the roofing that remains. This inspection will be conducted and documented in a similar manner to the scaffold tie-in inspections conducted during the Scaffold Erection Operation. If it is determined that WTC dust/debris exists at any of the subject locations, additional abatement by wet methods will be conducted of an additional demarcated area out to a distance to be determined in consultation with the Regulators. 22

23 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, Heavy Machinery and Equipment As detailed in Part I(R), heavy machinery and equipment such as generators, elevator motors and cooling tower components will be removed during the Deconstruction Phase because these items will require some structural demolition be performed prior to their removal. This procedure will be detailed in full in Regulatory Submittal Part I (D) Deconstruction Operations. Heavy machinery and equipment will be dismantled to the degree possible for decontamination of non-porous cleanable parts. Components that cannot be fully cleaned, and are too large and/or heavy to move without rigging will be wrapped in two layers of 6-mil plastic sheeting and left for removal and disposal as ACM waste during the Deconstruction Phase Unanticipated (Other) Waste Materials, if any, encountered during the work that have not been previously categorized for waste handling and disposal will be identified, quantified, and characterized by the Owner s Environmental Consultant as detailed in Section An area of the waste storage facility has been set aside for temporary storage of materials awaiting pending characterization results Light Ballasts (PCB Waste) All light ballasts in the building will be assumed to contain PCBs. As such, light ballasts will be cleaned of WTC dust utilizing HEPA vacuuming and wet wiping and packaged as PCB waste for proper transport and disposal. PCB waste will be stored in a separate PCB waste section of the Waste Storage area prior to transport from the site. 7.0 Transportation Requirements 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 universal 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. Shipments of PCB waste will be in properly labeled and marked containers, the waste must be shipped under a properly executed manifest and Land Disposal Restriction (LDR) form, and the transporter must have a valid EPA Identification number and a valid 23

24 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 New York State Part 364 transporter permit, as well as the latest version of U.S. Department of Transportation s Emergency Response Guide (2004). The vehicle in which PCB wastes are being shipped must be properly placarded and marked to reflect that it is transporting PCBs and must also be marked with the New York State waste transporter permit number on its sides and rear. 8.0 Travel Routes The proposed waste route for the Remediation Phase will be from the west side of the site (Greenwich Street) south on Greenwich Street, right onto Barclay Street, and right onto the West Side Highway north and/or from the east side of the site (West Broadway) south on West Broadway to Barclay Street, and right onto the West Side Highway north. Travel route(s) will be finalized 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. Proposed routes are illustrated in Attachment A. These routes cannot be finalized until EPA approval of the project, as the timing and routing are interdependent on other project occurring in the area. If any change is made to the routes proposed, this plan will be amended in writing and subject the review of the Regulators. 9.0 Disposal Facilities Waste recycling/disposal facilities will be selected based on several factors including waste types, facility acceptance criteria, regulatory compliance history, etc. Facilities to be used include: Asbestos: Minerva Enterprises 9000 Minerva Road SE, Waynesburg, OH Permit # C&D Waste: Disposal Site: Royal Rail 3700 West Side Avenue North Bergen, NJ Transporter: Liberty Carting th Street North Bergen, NJ Lead & PCBs: Disposal: Clean Earth of New Jersey 105 Jacobus Avenue Kearny, NJ EPA ID RCRA Exceedance: Republic Environmental Systems 2269 Sandstone Dr., Hatfield, PA EPA ID

25 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 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 Documentation All applicable local, state and federal documentation and record keeping requirements/guidelines will be followed. Documentation for hazardous waste disposal includes hazardous waste determination documentation including all analytical results, 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, 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. All documentation noted under this Section shall be retained for a period of not less than three years after the completion of the project. 25

26 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Attachment A: Waste Routes Waste route for the Remediation Phase will be from the west side of the site (Greenwich Street), or the east side of the site (West Broadway) south to Barclay Street, right onto Barclay Street, and then right onto West Side Highway. 26

27 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Attachment B: Waste Storage Areas 27

28 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7,

29 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Attachment C: Quality Assurance Project Plan The Quality Assurance Project Plan for waste characterization operations is included as Attachment C to the approved Regulatory Submittal Part IV(S) 29

30 Regulatory Submittal Part IV(R) Remediation Phase Waste Sampling and Management Plan Fiterman Hall 30 West Broadway, New York, New York Airtek Project Revised March 7, 2008 Attachment D: Previous Waste Sampling Data 30

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35 AIRTEK ENVIRONMENTAL CORP. 39 WEST 38TH STREET, 12TH FLOOR, NEW YORK, NY PHONE (212) FAX (212) June 15, 2007 Mr. Pat Evangelista WTC Coordinator New York City Response and Recovery Operations USEPA Region II 290 Broadway New York, NY Re: Brick and Mortar Waste Characterization Testing Results Fiterman Hall - 30 West Broadway, New York, NY Dear Mr. Evangelista, Attached please find results of samples collected per Amendment #3 to the 30 West Broadway Scaffold Erection Operation Work Plan submitted to the Regulators on June 1, Samples of brick and mortar were collected from each façade of the building (north, east, south and west) on June 7 and submitted to the laboratory for full TCLP, RCRA characteristics and Total PCBs analysis. Results indicate levels below RCRA and TSCA regulatory limits for all four samples. Brick and mortar waste generated by the scaffold erection operation that does not have spandrel mastic attached and does not exhibit WTC dust impact per the ongoing visual inspections will be handled as normal construction and demolition (C&D) waste from this point forward per the approved plan. Please contact me with any concerns or questions. Thank you for your time and consideration, Benn Lewis Vice President BL:em Encl. ENVIRONMENTAL CONSULTANTS

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