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
NYC-VVTC_000144817
OCR can misread numbers and units. Confirm readings against the page image before using them.
NYC-WTC_000144817Source: NYC Law Department, mirrored locally
A project proposal outlining the timeline, methods, and justification for cleaning HVAC systems in residential units affected by World Trade Center dust.
Joint announcement of a comprehensive plan by the EPA and city partners to address indoor air quality concerns in residential units south of Canal Street.
EPA Region 2 responds to a congressional inquiry about the joint EPA-DEP program for testing and cleaning lower Manhattan homes after the WTC collapse.
Formal memorandum from the DEP Commissioner instructing building representatives on safe asbestos handling and sampling protocols following the disaster.
A project proposal outlining the timeline, methods, and justification for cleaning HVAC systems in residential units affected by World Trade Center dust.