Letter on mercury contamination spread by cleaning activities, Apr 1996

NYC 9/11 Public Portal Document

I EP 1110-1-11 15 JUL 92

12. ADMINISTRATIVE CONSIDERATIONS. (independent of the abatement Contractor) who is Because improper abatement may result in a hired by the Contracting Officer (CO). hazard to building occupants, careful planning and b. Contractor PreQua/ification. The most diligent implementation of a project is essential. effective means of ensuring high standards in Por asbestos projects, the standard contractual asbestos abatement is through prequalification of relationship between the Contracting Officer's potential bidders. All potential bidders must have Representative (CORI and the Contractor remains successfully completed abatement projects simitar the traditional construction overview practice. In in size and complexity to the project being bid on. addition, it is critical to foster cooperative onsite A preliminary assessment of the quality and type administration and coordination. of abatement projects the potential bidders have a. Contracting Officer's Representative (CORi. completed will be helpful in assessing their depth of experience, quality of execution, and other (II The asbestos abatement contract factors. All prequalifications should be reviewed requires the COR to take a more active role than during the bidding stage by the CO and made a the traditional construction or demolition contract part of the bid analysis. allows. According to CEGS 02080, the COR is c. Preabatement Notification to EPA/State. responsible for monitoring contract compliance, Preabatement notification is a submittal accepting the Contractor's final clearance (before requirement for the abatement. Per the revised clearance air sampling) via a thorough visual NESHAP, each owner or operator of an ACM inspection, and normal inspection of workmanship demolition and/or renovation site (covered by and materials. NESHAP) must, at least 10 working days before (21 Failure to properly control the asbestos abatement begins, provide written notice of the abatement procedure can result in contamination intention to demolish or renovate. The revised NESHAP also requires a demolition/renovation outside the work area. Because of the critical value of onsite monitoring, the COR must be notification in a format similar to figure 1. Check with the EPA region, the State, and the customer directly involved in the oversight of preabatement, abatement, and final clearance monitoring in order in order to determine who will submit the notification, the Contractor or the Government. to ensure that the Contractor's performance meets quality standards. Should a hazardous d. Overnight. situation arise (such as fiber counts exceeding (II Contract enforcement. Enforcement of established criteria or loss of containment area the contract requirements by the COR integrity), the COR will stop all work, investigate encompasses both technical and administrative the causes, and establish if a contamination event functions, including the following: has occurred, if contamination exists, work must be terminated until a sampling program is (al Processing the Contractor's submittals instituted to identify the source of contamination as listed in the Contractor's submittal register. and the need for decontamination. The extent of (bi Visual inspecting and monitoring of contamination can be determined by establishing the Contractor's work. Also, air sampling if a thorough visual inspection and air-sampling specified in the contract. strategy (phase contrast microscopy (PCM) or transmission electron microscopy (TEM)}. Work (cl Reviewing all Contractor's progress will not recommence unless air samples prove reports and abatement daily log. negative or until the affected areas have been ^di Preparing the final abatement report. decontaminated and identified deficiencies corrected. (21 Contract Submittals. The Contractor's submittal register lists those items to be (3) The COR's responsibilities described submitted to the CO (see CEGS 02080). There are above may be performed by a Contractor four submittal categories: (1) those to be

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