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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 • • If possible, pump accumulated wash water from wash containment area into a settling tank(s) with baffie(s) to promote separation of oils, sediment/debris, and water. - As needed for reuse or discharge, pump water from discharge side of settling tank through a five (5) micron, in-line, filter. · - If possible, use electric pumps. - If generators or gas pumps are used, they should be placed in secondary containment with oil absorbent material and fire extinguisher readily available. - Removal of sedimellO from tank can.be accomplished with the use of sludge vacuum pump (e.g., vacuum truck). • If a settling tank is not used, accumulated wash water should be pumped through a non- woven filter bag that is place in a contained area adjacent to the wash/decontamination station. Filtered water should then be checked for hydrocarbon contamfoation (e.g., sheen or odor). If fueVoil contamination is identified, oil absorbent materiaVboom should be used to remove contamination and these materials disposed of properly. - As needed for reuse or discharge, pump water through a five (5) micron, in-line, filter. - Filter bag should be taken to disposal site once sediment capacity has been reached. • If wash water is not :filtered, it should only be discharged into a sanitary sewer or water tankers for transport to an approved disposal site. • If possible, debris/sediment from wash/decontamination station should be stockpiled in an adjacent contained area to allow saturated sediment/debris to drain prior to being loaded into haul trucks and transported to disposal site(s). If draining of saturated sediment/debris is not possible, trucks transporting saturated material should have dump bed liners to contain liquids during transport to disposal site(s ). 4.4 Penonal Protective Measures Personnel involved in wash/decontamination station activities will be responsible for removing accumulated dust from vehicles leaving the work area and ensuring loads are properly wet down or covered. Consequently, they will be exposed to dust, wet conditions, and debris/sediments and should use the following measures to help protect themselves against possible hazards: • Head covering • Approved respiratory protection • Face shield • Rubber gloves • Water repellent outer clothing • Rubber boots

When returning home, wash/decontamination station workers should follow the recommended protection measures described above in Section 2.3, Returning Home.

10/15/01 Pages of5 FINAL

NYC-WTC_000146527

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NYC-WTC_000146527Source: NYC Law Department, mirrored locally

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