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NYS Department of Labor fax cover sheet, Feb 2006

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Fax cover sheet from the New York State Department of Labor dated February 24, 2006.

NYC-WTC_000095859–000095866

Folder label: “30 West Broadway

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NYC 9/11 Public Portal Document

02/24/2006 14:29 518-457-1301 NYS LABOR-ENG. SVCES PAGE 03/07

NYS peprrtme' t of Labor

(Workforce Linda Angeilo, Commieaionor George E. Pataki, Governor _ew York _ Put us to work for' you

ers to allow for removals and o Is the gash area now enclosed with is enclosed? ~ cleaning still necessary? £ not, what portion~g specified to address asbestos project o What is the scopc of work and procedures within the gash area? Limited removals, cleanup and required visual inspections work plan, but full details of information is provided within section 6.3.1 of the be followed for temporary existing conditions and site-specific procedures to must be included. hardwall barrier and containment construction at the gash area (ICR 56) on January 11, 2006. The Department adopted amended Industrial Code Rule 56 revised reports and work plans to Please modify all references to ICR 56 within subsequent be consistent with current requirements. the majority of the asbestos Within the work plan, no detailed procedures were included for once selected, the project tasks. Instead, references were included which indicated that project procedures within asbestos abatement contractor would determine actual asbestos site-specific variance decisions yet to be obtained. This approach is not advisable, as all specifics regarding implementation of the asbestos project should be established by the asbestos project designer prior to the bidding of the project; so all bidders know what will be required to complete the asbestos project. The role of the project designer is to "plan the scope, timing, phasing sand remediation methods to be utilized on any asbestos project". For an asbestos project that includes asbestos contamination cleanup, and specifically WTC dust/residue cleanup, establishment of the required asbestos project procedures within the work plan is essential, to reduce potential asbestos project procedural problems throughout the course of the asbestos project. If procedures must be specified that aren't consistent with ICR 56 requirements, a site- specific variance must be obtained by the project designer as an agent for the owner, and the procedures and conditions contained within the site-specific variance decision must be incorporated into the work plan specified asbestos project procedures. All asbestos project design submittals, including variance petitions, must be submitted to DASNY internal asbestos project design personnel for appropriate review and approval, prior to submission to the Department. The Department will not review any site-specific variance petition, or revised work plan asbestos project procedures, without DASNY's prior approval of the submission.

Specific Comments

PRELIMINARY FACADE CHARACTERIZATION REPORT

• 3.4 ASBESTOS-CONTAINING 1v1ATERIAL(ACM)INSPECTION AND TESTING "Figure F-I Section View for flashing location" was referenced within this section, but not apparent within the report. Also, ACM interior vapor barrier and ACM lintel flashing located below the windows between brick fascia and facade structural components were Phone: (518) 457-1536 Fax: (518) 457-1301 W. Averell Harriman State Office Campus, Bldg. 12, Room 154. Albany, NY 12240

www.tabor.state.ny.us

NYC-WTC 000095862

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NYC-WTC_000095862Source: NYC Law Department, mirrored locally

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