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

fee occupant? Aggressive air testing should he mandated and not dependent on presentations wade by indi ’{duals on site. 3Q) states all information must be maintained on a software program acceptable to fee U.S. EPA. All information in this database must also be accessible to fee public and elected officials [G2TF, CAO}. Tire Sampling Procedures state feat project reports, including sign-off sheets, must be forwarded to the U.S. EPA andNYCDEP. These project reports and si^vofTsheets must also be forwarded to fee occupants, and made available to fee public and elected officials lGZTF, CAG]. In addition to air sampling, an equal number of wicrovac samples should be taken i following the procedures of ASTX 5755-95 and analyzed using transmission Electron Microscopy (TEM). Scope of Work A The procedures under Scope of Work A apply to the elean-up of “minimal dust accumulations. The term ‘'minimal dust” is only defined as a "light costing." Neither of these terms are legal definitions. Tt will be solely up to the EPA coordinator to determine if a site has minimal dust and apply Scope of Work A, However, fee EPa coordinator must only be given information regarding fee presence of debris. The Scope of Work does not say feat the EPA eeordinater will actually have to be present on site, and perform fee visual inspection. There are also oonecres wife some of fee specific procedures in Scope of Work A: Procedure P3 states that individuals perfpnnirg clean up activities are not required to wear psfBonal protective equipment or reqjjrators. This is unacceptable. AB workers rousT wear <j^„*** personal protective equipment «td 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 feat air condition units will be pulled into fee interior space and cleaned.^Qdw Will this be done before or after fee rest of the apartineni is remediated? The removal of the air v conditioners may disburse hazardous mbstances and increase exposure to those present It may Uir also not be possible to folly clean air conditioners. Any removal of air condition units must be done in a manner feat contains hazardous substances feat may be present The air conditioners should be removed, bagged, sealed, disposed of as hazardous waste, and replaced by a government agency or charity organization. Procedure #S states feat additional olean-up procedures shall be performed where visible dust is observed. What are these additional clean-up procedures'? It also states feat air sampling shall be performed after fee area is free of dust accmulations. Ab previously stated, wipe-samples should be performed in addition to air sampling. 9 Procedure #6 states feat fee results of personal air monitoring shall be shared immediately wife c!^ • OSHA, fee employer, fee workers or their representan ves. The results should also be made available to fee occupant and all other people present at fee sits when fee monitoring was conducted.

NYC-WTC_000144754