EPA Region 2 correspondence cover sheet, October 2001

NYC 9/11 Public Portal Document

MflY-20-2002 21S38 U.S. EPA/DEPP 212 6373772 P.04/11

the occupant? Aggressive air testing should be mandated and not dependent on presentations made by individuals on site. « 3(j) slates aS’ information must be maintained on a software program acceptable to the U S. EPA. AU infenaaiion x this database must also be accessible to the public and elected officials [GZTF, CAO]. Tlw Sampling Procedures state that project reports, including sign-uff sheets, must be forwarded to the U.S. EPA andNYCDEIft These project reports and sigivofTsheets must also be forw arded to the occupants, and made available to the public and elected officials lGZTF, CAG], In addition to air sampling, an equal mjmber of microvac sample? should be taken following the procedures of ASTM 3755-95 ar.d analyzed using Tran emission Electron •Mieroscopy (TEM)

The procedures under Scope of Work A apply lo the clean-up of “minimal dust accumulations.” The term “niuumal dust” is only dcfor.ed as a “fight coating. ” Neither of these terms are legal definitions. It will be solely dp to the EPA coordirator to determine if a site has miciraa’ dust and apply Scope of Work A. However, the EPA coordinator must only bs given information regaidng the presence of debris. The Scope of Work does not say that the EPA eeordinator will actually have to be present on site, and perform the visual inspsetion There are also cooccros wifo some of the specific procedures in Scope of Work A

Procedure »3 states that individuals performing clean up activities are not required to wear personal protective equipment cr rsspirators This is unacceptable All workers must wear personal protective equipment and respirators. The heal± and safety of those performing the work, as well as these present al the site, must be protected, and all response actions must comply with all applicable government regulations.

ProcediiT e * A provides that air condition units will be pulled into foe interior space and cleaned Will this be done before or after rhe rest of the aparer.etii is remediated? The rrmovi; of the air conditioners may disburse hazirdotis subsranccs and increase exposure to those present. It may also not be p jssible to fully clean air conditioners Any removal of air condition rmit! must be done in a manner that contains hazardous substances that may be present. The air conditioners should be removed, bagged, sealed, disposed of as hazxdous waste, and replaced by a government agency or chanty organization.

Procedure Ji'S states that additional e’ean-up procedures shall l>e performed 'vbere visible dust is observed. What are these additional cleas-up procedures? It c’so states that air sampling shall be perfoTOcd after the area is ftee of dust accum ulations. As previously stated, wipe-samples should be performed in addition to air sampling.

Proced'jxe #6 states that ths results of personal air morn'onng shall be shared immediate!y with OSH-A, the employer, the workers or their representatives. The resuliS should dso be made available to the occupant and all other people present at the site when the roon tonng was conducted.

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