Letter on mercury contamination spread by cleaning activities, Apr 1996

NYC 9/11 Public Portal Document

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for disposal, in accordance 40 C.F.R. Section 61.147(e) and Section 112(c) and (e) of the Clean Air Act, 42 U.S.C. 7412 and (e). b. If contractors discharge visible emissions to the outside air during the collection, any processing, packaging, transporting, or deposition of asbestos containing waste material generated at the facility, they must use one of the disposal methods specified in 40 C.F.R. Section 152(b) (1), (2), or (3), thereby violating 40 C.F.R Section 152(b) and Section 112(c) and (e) of the Act, 42 U.S.C. Section 7412(c) and (e). c. Those contractors unfit to hold a permit and who have been denied a permit in any state must not be allowed i. Full disclosure of contractor’s prior violations, enforcement history, and should be accompanied by a copy of the inspection report and any other documentation of violations. ii. 40 C.F.R. Section 61.146 requires each owner or operator of a demolition operation where there is the regulated amount of asbestos to provide the Administrator of ERA with written notification of intention to demolish or renovate, setting forth specified information, at least 10 days prior to the commencement of the operation. Timely, complete, and accurate notices of demolition operations permit ERA to conduct efficient, unannounced Inspections to ensure that work practice standards to prevent emission of asbestos are being met. Such notices are particularly Important due to the short duration of most demolition operations. In the WTC cleanup - better and more timely notice should be given d. Strict monitoring, recordkeeping and reporting requirements mustt be adopted to with the appiicabie if oniy the minimum requirements provided under appiicabie regulations are imposed comp;iiance of all relevant actors will not be assuredwill not assure compliance of a bad actor. e. The following information must be made public” The name and position of the person responsible for supervising all work involving asbestos-containing material (ACM ). ii. The name, address, telephone number and contact person of the flrm(s) which will transport any asbestos-containing waste from the site. iii. A description of the procedures and equipment to be used to prevent visible emissions of asbestos-containing material, and to decontaminate workers. iv. A description of the location and amount of asbestos containing material In the facility which will undergo renovation or demolition. V. The name of the person who determined whether asbestos- containing material was located at the site and the basis on which such determination was made. vi. Decontamination facilities must be made available, equipped, and used at each jobsite which involves removal of asbestos containing material.

NYC-WTC_000144592