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. 06/09 J

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 contract 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-certificaticn 7. Entire buildingsZnelghborhoods are to be cleaned completely in a systematic way to prevent cross-contamination/re-contamination. a. The abatement Is to be done street by street b. The entire building has to be done at one time. i. Allowing people to be exposed flies in the face of reason. The abatement * /orkers will bo abating In full protective gear and the proposal given to us says that there require that the occupants be In the room while cleanup Is done and will be thus exposed. (1) Occupants wilt be relocated for the duration of the abatement procedure on building c. This needs to be done i. HVACZVentilation systems must be completely cleaned (1) The building ventilation system will be set to negative pressure as perEPA regulations regarding asbestos abatements. ii. Common ereas/stairwellsZetc. Ui. Elevator shafts iv. Windows casing V. Wallpaper & Carpets that cannot be properly abated must be removed and disposed of properly vi. Rugs should be sent for proper cleaning 6. All buildings and spaces inside the zone must be abated including paries, 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 ERA that is publically accessible a. All data should be permanently avallab's tor public perusal and easily accessible without the need tor 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 anetysis. 12. Contractors a. Must ensure that the friable asbestos material remains wet until collected for disposal, in accordance 40 C.F.R, Section ei.U7(e) and Section 112(c) and (e) of the Clean Air Act 42 U.S.C. 7412 and (e). b. If contractors discharge visible emissions to the outside air during the

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