WTC document preservation notice, NYC Law Department

NYC 9/11 Public Portal Document MAY-20-2002 21:38 U.S. EPA/DEPP 212 6373772 P.04/11

the occupant? Aggressive air testing should be mandated and not dependent on presentations made by indi nduals on site. 30) states all information must be maintained on a software program acceptable to the U.S. EPA. AU information in this database must also be accessible to the public and elected officials [GZTF, CAO}. The Sampling Procedures state that project reports, including sign-off sheets, must be forwarded to the U.S. HPA andNYCDEP. These project reports and si^vofT sheets roust also be forwarded to the occupants, and mi. le available to the public and elected officials [GZTF, CAG]. In addition to air sampling, an equal number of microvac samples should be 'akes 1 following the procedures of ASTM 5755-95 and analyzed using Transmission Electron Microscopy (TEM). '* Scone of Work A The procedoies under Scope of Work A apply to the clean-up of “minimal dust accumulations.” • The term “minimal dust” is only defined as a “light costing.” Neither of these teims are legal Z * - definitions. It will be solely up to the BPA coordinator to determine if a site has minirnaJ dust and apply Scope of Work A However, the £PA coordinator most only be given information ' regarding die presence of debris. The Scope of Work does not say that the EPA eoerdinator will actually have to be present on site, and perform the visual inspection. There are also concerns with 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 or respirators. This is unacceptable. All workers must wear persona! protective equipment aid respirators. The health and safety of those performing work, as well as those present at the site, must be protected, and all response actions must comply with all applicable government regulations. Procedure #4 provides that air condition units will be pulled into the interior apace and cleaned. Will this be done before or after the rest of the apartmeni is remediated? The removal of the air v conditiODers may disburse hazardous substances and increase exposure to those present It may also not be possible to fully clean air conditioners. Any removal of air condition units 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 hazardous waste, and replaced by a govemmori agency or charity organization. Procedure #5 states that additional clean-up procedures shall be performed where visible dust is observed. What are these additional clean-up procedures? It also states that air sampling shall be performed after the area is ftee of dust accumulations. As previously stated, wipe-samples should be performed in addition to air sampling. 9 Procedure #6 states that the results of personal air monitoring shall be shared immediately with • OSHA, the employer, the workers or their representanves. The result should also be made available to the occupant and all other people present at the site udxen tl t monitoring was conducted.

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