NYS Department of Labor fax cover sheet, Feb 2006

NYC 9/11 Public Portal Document

02/24/2006 14:29 518-457-1301 NYS LABOR-ENG. SLICES PAGE 06/07

NY$ Department

of Labor

6nme George E. Pataki. Govemor A ork Put us to work for you Linda Angello, Commissioner

utilized during the shredding and bagging/containerization of the shredded waste stream. In addition, no ACMremoved shall be shredded o

6.3.4 Work Areas This section indicates that the entire structure will be one work area. This approach may

be problematic, as the entire work area will be abated, then cleaned then cleared One floor couldn 't be under removal, while another floor was in the cleaning stage or clearance stage, unless work area segregation occurs per floor or group offloors. The single work area approach should be revisited before the work plan isfinalized 0 6.3.5 Removals This section includes procedures not in compliance with the current ,ICR 56. As previously indicated, ifprocedures must be specified that aren't consistent with ICR 56 requirements, a site-specific variance must be obtained by the project designer as an agentfor the owner, and the procedures and conditions contained within the sire- specific variance decision must be incorporated into the work plan specified asbestos project procedures.

• 6.4 OPERATION IV — IN PLACE ACM No information is apparent within this section regarding the ACllrl window caulking at the elevator mechanical room roofs, or the ACM window frame caulking at the first floor exterior of the building. These materials were identified within Report Attachment IV, Table I "Summary of Inspection Resultsfor Asbestos ". In addition, ACMfloor covering materials are includea but nothing is included regarding the floor covering adhesives/mastics. These materials should also be assumed and treated as ACM, unless appropriate bulk sampling and analyses adequately show the materials to be nonACM.

Regardless of the listed ACMs, as previously indicated if procedures must be specified that aren't consistent with ICR 56 requirements, a site-speck variance must be obtained by the project designer the and the procedures and conditions contained as an

agent for

owner,

within the site-speck variance decision must be incorporated into the work plan specified asbestos project procedures.

7.3

SCAFFOLDING

A "Deconstruction and Scaffold Layout Plan" was referenced within this section, but not apparent within the documents". The document detailing all appropriate procedures for this

work

must

be

included

with the

workplan.

Phone;

(518)

457-1536

Fax:

(518)

457-1301

Averell W,

State Harriman

Office

Campus, Blda_

12,

Room

154. Albanv. NY 1994n

wwwia bo r.

state. ny.

us

NYC-WTC 000095865