from the collapse of the WTC. How will it be determined that the dust/debris
present is WTC-related? It is not clear how the project monitor would be
able to make such a determination.
6. Deliverable 10 a (page 5) states that if an individual wants their residence
cleaned, the HVAC system dedicated to that residence will be evaluated. The
problem is that cleaning of only one area of an HVAC system may not be
sufficient if the rest of the HVAC system is impacted.
7. Deliverable 12 f (page 7) states that wipe samples for dioxin, total metals and
mercury will be conducted at 10 percent of the residences where sampling
only has been requested. Total metals and mercury are not contaminants that
have been identified as WTC-related Contaminants of Potential Concern (see
most recent version of the EPA COPC document) and we suggest that
sampling be limited to only COPC contaminants.
Cleaning Contract Scope of Work
1. Scope of Work A, 6 (page 3) states that contractor and EPA will determine if
elevator shafts contain significant WTC dust /debris. It is unclear how that
determination will be made.
2. Scope of Work A, 9 (page 5) states that HEPA air filtration devices (AFDs) will
run continuously during all cleaning activities given appropriate conditions.
Please add in that the return air should be derived from a non-impacted source
(i.e. open window), so that the devices will not be pulling in air from areas that
have not yet been cleaned (nearby residence or common space.)
We hope these comments are helpful. Please feel free to call us at: 212-788-4290
(Nancy) or 518-402-7511 (Robert).
NYC-WTC_000140583
OCR can misread numbers and units. Confirm readings against the page image before using them.
NYC-WTC_000140583Source: NYC Law Department, mirrored locally
EPA correspondence clarifying regulatory agency roles, asserting NYC Department of Health holds primary authority for mold remediation in WTC recovery.
EPA correspondence clarifying regulatory agency roles, asserting NYC Department of Health holds primary authority for mold remediation in WTC recovery.