WTC document preservation notice, NYC Law Department

NYC 9/11 Public Portal Document

mY-20-2002 21:46 U.S. EPA/DEPP 212 6373772 P.06Z09

D.S,A. Services to preform dangerous asbestos abatement at the Gansevoort Street Plant despite the fact the owner of D.S.A, having been disbarred by the NYS DOL for committing willful violations. (b) NYC DOH was ready to rehire Clarke Mosquito Control despite the $1 million OSHA fine and centrad provision that forbade re-contract in face of such labor violations (6) They abrogated their right to have any role due to the fact their reliance completely on landlord self-certification 7. Entire buildings/neighbortioods arete be cleaned completely in a systematic way to prevent cross»contamlnation/re-contamlnation. a. The abatement is to be done street by street b. The entire building has to be done at one time. Allewir\g people to be exposed flies in the face of reason. The abatement * /orkers will bo abating in foil protective gear and the proposal f;.ven to us says that there require that the occupants be In the room while cleanup is done and will be thus exposed. (1) Occupants will be relocated for the duration of the abatement procedure on building C. Thia needs to be done I. HVAC/Ventilaflon systems must be completely cleaned (1) The building ventilation system will be set to negative pressure as perEPA regulations regarding asbestos abatements. il. Common areas/stairwells/etc. Hi. Elevator shafts iv. Windows casing V, Wallpaper & Carpets that cannot be properly abated must be removed and disposed of properly vl. Rugs should be sent for proper cleaning 8. All buildings and spaces inside the zone must be abated including parks, schools, commercial spaces/offices. religious institutions, hospitals, city-owned buildings, etc. 9. Testing should be done in real-time & reported via a publicly accessible web site done by EPA that is publically accessible a. All data should be permanently available for public perusal and easily accessible without the need for FOIA. 10. The most stringent safety/health regulations should be applied. 11. Observation by video; independent authorized observers must be allowed access to abatement sites, videos must be sent to review teams for analysis. 12. Contractors a. Must ensure that uie friable asbestos material remains wet until collected for disposal, in accordance 40 C.F.R. Section 61.147(e) and Section 112(c) and (e) of the Clean Air Act. 42 U.S.C. 7412 and (e). b. If oontractors discharge visible emissions to the outside air during the

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