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NYC Law Department letter regarding EPA draft report excerpts, July

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Correspondence from NYC Corporation Counsel providing comments on excerpts of a draft EPA evaluation report regarding the WTC response.

NYC-WTC_000146129–000146748

Folder label: “EPA OIG LAW

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NYC 9/11 Public Portal Document

_10/29/2001 ..15: f>4 l''A.A. I J.U4 too~-'

4. Workers will be medically qualified to wear respirators and personal protective equipment. Jn addition, wodcers will be licensed by New Yode City. for asbestos abatement worlc..

S. Personal air monitoring will comply with federal OSHA asbestos standards during this phase of the operation. Workers will be infonned of the test results as requUcc1 by OSHA standatds regarding access to employee exposure infonnatiQJl. 6. Asbestos waming signs will be posted 10 prevent eney intO the office spaces by unauthorized persons.

7. A double airlock will be constnicted at the enmmce to the law office and the entire office will be kept under negative pressure using air filtration devices.

8. Workers will remove their outer protective clothing in the second decontamination chamber before exiting and placing the co1]1'aminated ~in a p~~ ~ Conversely, work~~ don th~ protective . lt t • clothing and respirator m the ball before entering intO the mlocks. . '-~, filtration device filters the outdoor air and blows uncontaminated tm6ugb · the airlocks mto the work area.> Rrrti'~u °'/ 9. Before beginning the decontamination process, smoke tubes 1 '1Sffl"19 1 ') 2001 test the airflow into the chambers. -\ : /\ I 10. Aggressive air monitoring will be done to ensure.the deco and cleaning areas are still below the AHERA criteria of 70 asbest · ~,area5 ·:~~_. _, :,; _A<' <.:.' .·· -· b . • · ,. \ "\: Cu

structures per cubic centimeter of air after the initial phase of operation:· · ; · .; 1 Constant daily air monitoring will be petformed inside the containment to ensure airborne concentrations of asbestos fibers remain within normal limits.

11. The windows will be taped and sealed to prevent any outside con1Bmi.oation ·infiltrating into the wotkspace. The windows will iemained taped and sealed until ~erior of buildiq is cleaned.

12. A representative number of.all of the items cleaned will be tested using micro vacuum samples to verify cleanliness. Random samples will be collected rather than collecting a sample from each item. The number of surface samples should be iepresentative of the number and type of items being cleaned. Any item above the suggested ASTM DS?SS-95 criteria of 100 structures of asbestos fibem will be cleaned and tested again. The porous materials, which cannot be cleaned, should be discarded as asbestos containing waste.

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NYC-WTC_000146299

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NYC-WTC_000146299Source: NYC Law Department, mirrored locally

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