NYCDOH and NYSDOH comments on WTC cleaning SOWs, Aug 2002

NYC 9/11 Public Portal Document

TO: Michael Gilsenan NYC DEP

FROM: Nancy Jeffery (NYC DOHMH) Robert Chinery (NYSDOH)

DATE: August 2, 2002

SUBJECT: Comments on SOWs for: WTC Indoor Dust Cleaning Program Cleaning and Monitoring Contracts

We have reviewed the draft July 30, 2002 scope of work for the two contracts and have the following comments. Comment 3 specifically addresses the proposed procedures for addressing mold issues:

Monitoring Contract Scope of Work

1. Introduction (page 1) 2"‘’ Paragraph, last sentence, should be modified to reflect the fact that in some of the residences/buildings, dust wipe samples will also be collected. Currently, the sentence states that contractors will follow-up with asbestos and asbestos air sampling only. 2. Deliverable 7 c. vi. (page 4) states that the project manager will advise EPA of other circumstances that may require deviation from the specified cleaning and monitoring procedures. The question we raise is related to what will be the incentives for the project monitor or cleaning contractor to look for non­ routine reservoirs of potential WTC-related dust and debris? For example, it’s not clear whether the cleaning contractor would be paid a flat fee per residence/building or whether there would be incentives to search out other possible dust reservoirs in the buildings. 3. Deliverable 8 (page 5), last sentence states that cleaning will not proceed in areas where mold is observed until potential hazards are evaluated and addressed if necessary. The sentence is very broad and is not clear who would make sure the mold issues are addressed. As addressing long-standing mold issues can take a very long time, we suggest that the project manager should notify EPA and contact DOHMH if visible mold conditions exist so they can be evaluated. The project managers should also be provided a copy of and be familiar with the DOH’s Mold Assessment and Remediation Guidelines so that common bathroom mold conditions do not stop the important clean-up work fi-om proceeding. 4. Deliverable 9 (page 5), the word “paint” is missing from the 3"* sentence. 5. Deliverable 10 (page 5), 1” sentence states that HVAC systems will be evaluated to determine if these systems have been impacted by dust or debris

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