NYC 9/11 Public Portal Document
.NAY-20-2002 21:37 U.S. EPftzDEPP
212 6373772 P.03Z11
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COMMENTS Of U.S REFRESENTATIYS .12RROLD NADLER (NY-08)
EPA SCOPE OF WORK
WORLD TRADE CENTER BUILDING REMEDIATION
Ashestos Ptoiect ?ZQnitQT tod Air Sampling Cet Et s''”
A. Introduction
• The term ‘‘apartment” in the final sentence too restrictive. The term “dwelling ’ should
be used to clarify that the Scope of Work applies to all units, such as condoouniums,
co-ops, private homes, etc.
B. Qualiticatioos
Project Monitors should not simply be people widx a NYS Asbestos Project Monitor
certificate. There should also be EPA employees on site, such as On*Sccne
Coordinators or Project Managers, and they must document all actions taken at the
response site.
C. Specifications
< The Scope of Work implies that Project Monitors will receive information, from the
EPA Hotline, schedule appointments, and ensure that cleaa-up activities comply with
the Scope of Work. However, Project Monitors will not actually be on-site during
clean-up activities. Only Air Monitoring tochnicians are required to be on-sixe. The
Scope of Worit makes no mention of anyone from EPA or OSHA being preseut at the
site. There must be federal personnel on-site to ensure that all activities comply with
die Scope of Work. Compliance must not be confirmed via second-hand infermatioc-
Federal personnel at the response scene must enforce it. Tn accordance with OSHA
Regulation 29 CPR1926. there mist be a ‘'compstent person” present at the site to
eawure the appropriate handling of material, hazards and to ensure worker safety and
health.
• The EPA must ensure that tire Hotline is staffed will) people who can communicate
with all members of the public, including tenants of Chinatown, members of ths
Spanish-speaking community, tod all other residents who speak English as a second
language.
« 3(e) says that "ihc project manager shall advise the occupant or his/her authorized
representative on the ^vantages and disadvantages regarding the use of the
equipment... [aggressive air testing).” What are the advantages and disadvantages that
will be presented to the occupant? Who qualities as an "authorized representative" of
NYC-VVTC_000144753
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