WTC document preservation notice, NYC Law Department

NYC 9/11 Public Portal Document MAY-20-2002 21:47 U.S. EPA/DEPP 212 6373772 P.07Z09

collection, any processing, packaging, transporting, or deposition of asbestos containing waste material generated at the facility, they must use one of the disposal methods specified in 40 C.F.R. Section 162(b) (2). or (3). thereby violating 40 C.F.R Section 152(b) and Section 112(o) and (e) of the Act, 42 U.S.C. Section 7412(c) and (e). c. Those contractors unfit to hold a permit and who have been denied a permit in any state must not be allowed I. Full disclosure of contractor’s prior violations, enforcement history, and should be accompanied by a copy of the inspection report and any other documentation of violations. ii. 40 C.F.R. Section 61.146 requires each owner or operator of a demolition operation where there is the regulated amount of asbestos to provide the Administrator of ERA with written notification of intention to demolish o- renovate, setting forth specified information, at least 10 days prior to the commencement of the operation. Timely, complete, and accurate notices of demolition operations permit EPA to conduct efficient, unannounced inspections to ensure that work practice standards to prevent emission of asbestos are being met. Such notices are particularly important du© to th© short duration of most demolition operations, tn the WTC cleanup - better and more timely notice should be given d. Strict monitoring, recordkeeping and reporting requirements mustt be adopted to with the applicable If only the minimum requirements provided under applicable regulations are imposed compliance of all relevant actors will not be assuredwill not assure compliance of a bad actor. e. The following information must be made public" 1. The name and position of the person responsible for supervising all work nvolving asbestos«containing material (ACM ). ■f. The name, address, telephone number and contact person of the firm(s) which win transport any asbestos'containing waste from the site iii. A description of the procedures and equipment to be used to prevent visible emissions of asbestos-containing material, and to decontaminate workers. iv. A description of the location and amount of asbestos containing material in the facility which will undergo renovation or demolition. V. The name of the person who determined whether asbestos­ containing material was located at the site and the basis on which such determination was made. vi. Decontamination facilities must be made available, equipped, and used at each jobsite which involves removal of asbestos containing material. f. Each contract should include penalty/ liquidated damages clause I. wv>>v.(aivinfo.eom/caain/enforeerBe»?t/caadl44.html CoMftjM decree model Dept of Justice & Asbestos violator

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