EPA and DEP positions on HVAC containment and signage protocols

NYC 9/11 Public Portal Document

Brieflng Notes for Kathleen Callahan

HVAC issues

Containment

EPA - Wants to have containment installed for the air-handling unit during cleaning, regardless of where the unit is located.

DEP - Thinks that containment is necessary only where the system is heavily impacted with debris and should be done on a case-by-case basis following guidelines that DEP and EPA agree upon.

Signage

EPA - Feels that asbestos signage is warranted when work is ongoing. However, are checking with OSHA to verify.

DEP - Feels that a caution sign should be sufficient. Do not want to panic the public for no reason.

General Comments

DEP feels the two above issues are overkill by EPA for what the program is designed to accomplish.

Exhaust Cleaning

DEP is concerned that EPA will not get access to all apartments in cleaning an exhaust system. In addition, DEP is concerned that those vents that do not need cleaning, but will be cleaned under the current scenario, will cause undo hardship and raise anxiety levels in people. DEP has also learned that in Quad D, a camera has been used to verify presence/absence of debris. DEP is concerned that we can be criticized for not employing consistent methods of evaluation. Therefore, we propose that all Quads use a camera. This will allow for consistency throughout the program and will serve as a check for the HVAC subcontractors. We also feel that this method will allow the program to clean only areas where we find debris. This methodology will allow the program to move forward without upsetting the public needlessly.

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