NYC Law Department letter regarding EPA draft report excerpts, July

NYC 9/11 Public Portal Document

The demolition of all WTC complex buildings to ground level was completed by late December 2001. WTC 4 and WTC 5 were brought down using a weight suspended by a cable.bv wreeking balls. Section 27-1039d of the New York City Building Code This method of bringing down a building required approval of the Department of Buildings to use this method of demolition. The Department was consulted and he concurred in the use of this method.had been outlawed-in New York for over two decades, but an exception was granted under the special circumstances that existed-after the terrorist attack.- WTC 6 was brought down using mechanical grapplers and cutting shears. A photo of a grappler is attached at Appendix .with “special remote cutting shears.”

Both NYCDDC and OSHA-offioials told us that tThe WTC site was under continuous dust suppression.(If this is not acceptable then we suggest as an alternative “EPA officials were at the site and observed that the site was under continuous dust suppression.”) In addition to the general dust suppression activities on the haulways, the daily incident plan detailed areas of the WTC site where work was to take place and focused dust suppression activities would be needed. QSHA officials told us that this dust suppression was very successful, and that two minutes after demolition you could see across the space where the buildings had been. They Although QSHA officials further stated that it would I have been too dangerous to send abatement contractors into WTC 4, WTC 5, or WTC 6 to remove asbestos-containing material before demolition, there was no need to do this as there was no asbestos-containing material above ground in these buildings.T

Treatment of Asbestos-Containing Materials

Both NYCDDC and EPA officials told us that when asbestos-containing material (e.g., pipe wrapping, steel insulation) was encountered during the removal, it was tested and treated in accordance with asbestos abatement procedures. According to the NYCDDC official, the majority of the asbestos-containing material was encountered when removing the remnants of the basement levels of WTC 6, below the slurry wall.

EPA Situation Reports confirmed the NYCDDC official’s statement about asbestos abatements at the site. The reports recorded instances where asbestos was foimd during debris removal and asbestos abatements performed. For example, the EPA May 23, 2002, situation report noted that:

Twelve (12) bulk asbestos samples were taken in the Bl, B2, B3, levels of (WTC) Building 6. The samples were taken from sprayed on insulation at the request ofNYC DOI. Of the twelve samples, nine (9)

NYC-WTC_000146038