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NYC Law Department letter regarding EPA draft report excerpts, July

Machine-extracted title · confidence 100%

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

DUST PROTECTION AND SUPPRESSION PLAN

2.2 Leaving the Work Area: When personnel leave the work area, they should do the following to prevent spreading dust outside the work area: • Exit work area through designated routes. • Wash boots with soap and water. • If wearing disposable outer protective clothing, dispose of clothing in designated container. • Thoroughly remove dust from clothing using a HEPA vacuum. • Clean personal protective equipment (e.g., respirator, goggles). • At end of shift, replace respirator cartridges. • Wash face and hands with soapy water. · 2.3 Returning Home When workers return ''home" with clothing that has been soiled with dust, they should do the . following to prevent bringing dust into their residence: • Immediately remove clothing soiled with dust. • Place dust soiled clothing in plastic bag(s) until washing. Do not shake dust from clothing. • Launder dust soiled clothes twice and separate from other clothing. • Run machine empty through one (1) complete cycle to rinse any debris that may have been deposited before washing next load. • Dispose of plastic bag(s); do not reuse. • Wash hands with soapy water.

3. DEBRIS/DUST REMOVAL AND LOADING Search/rescue, demolition, and cleanup activities will require the removal of vast quantities of debris that could potentially spread dust within and outside the work area(s). The following dust suppression measures should be used to control the generation and spread of dust: • Minimize handling of debris/dust by avoiding, where possible, multiple handling. • Minimize the drop height of debris from equipment when dumping into haul trucks or onto ground surface. • At locations in or adjacent to rubble piles where debris is separated. by dropping and/or spreading, the rubble should be periodically wet down. • Where practical, aerial mist sprayers should be used to help control dust (e.g., when material is double handled or dumped, in rest areas, in areas where debris is sorted), and· water mist curtains should be used at the perimeter to minimize dust leaving the area. • In areas with thick dust accumulation (including streets and sidewalks), use a truck- mounted, high efficiency particulate air (HEPA) vacuum or, if not available, use standard large volume vacuum trucks. • In areas where vacuum trucks are not used, lightly wet down areas prior to initiating debris/dust removal activities with shovels or other tools/equipment. • Either wet down, or cover and secure debris/dust loads in haul trucks. Haul trucks shall not be allowed to leave the work area unless these measures have been completed. • Assign haul trucks designated routes to and from disposal site(s). • Haul truck speed in work areas should not exceed 10 mph. • Haul routes to disposal sites should be periodically wet down and/or cleaned with "street sweepers" to control dust.

10/15/01 Page3 ofS FINAL

NYC-WTC_000146525

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NYC-WTC_000146525Source: NYC Law Department, mirrored locally

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