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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