DEP draft response regarding trade center cleanup, Oct 2004

NYC 9/11 Public Portal Document

‘ Gilsenan,.Michael From: Maldonado, Jane Sent: Friday, October 08, 2004 3:00 PM To: Gilsenan, Michael Subject: 130 Liberty Street Letter

October , 2004

ADDRESSEE

Dear

This letter reiterates the New York City Department of Environmental Protection’s (NYC DEP) position regarding dust clean-up issues related to 130 Liberty Street. The Department has stated numerous times to interested parties that USEPA’s WTC Clean-up Program protocolslbe used tor remediation purposes in tRTs case. Our position is based on the following;

As part of EPAFs WTC Clean-up Program, DEP was responsible for the project management of interior clean­ up activities atjun-cleaned, unoccupied buildings impacted by the collapse of the World Trade Center. The Scope of Work for this project was developed by the EPA and its Federal, State and City partners. The cleaning contractor was required to be in compliance with all applicable laws and regulations including, but not limited to, regulations issued by the USEPA, the United States Department of Labor Occupational Safety and Health Administration (OSHA), the New York State Department of Labor (NYS DOL), and the NYCDEP.

NYS DOL licensed asbestos contractors performed the cleaning activities and an independent monitoring contractor monitored the work, performed final visual inspections, and performed asbestos air sampling when the cleaning was completed, on all NYCDEP clean-up activities.

Also, as part of EPA’s WTC Clean-up Program, the NYC DEP contracted and oversaw an exterior clean up program at buildings impacted by the collapse. The Department performed visual inspections at the buildings and targeted areas that required clean up. In the absence of homogeneous debris and a discernable distribution pattern, the Department determined that all WTC debris would be treated as asbestos-containing material (ACM).

The NYC DEw Asbestos Control Program (ACP) provided guidance to building owners within a few days of the UlTQ collapse. Thefdocument was based on the ACP Rules and Regulations for assessment and clean-up activities and the interpretation thereof, and was distributed by mail and through site visits. This document remains in effect and summarizes the Department’s position regarding complian^.*^

la ndditinn-tn'thn hnnkgrnund inTnmintifiWTfgni-djfi^^bp U/TC ntnnn.fip artivitiPg Aie A«ihnQ4w>-nii1nr. require that asbestos-containing materials be removed prior to the demolition of any structure. Demolition activities cannot in any way compromise ACM abatement. The abatement procedures prior to a demolition project require the installation of decontamination enclosure systems, installation of isolation barriers, pre-cleaning, etc. by certified asbestos workers. Debris within the work area^whether ACM or not, must be cleaned up. Objects that can be pre-cleaned must be cleaned using HEPA-filtered vacuum equipment and/or wet cleaning.

Based on our experience at buildings impacted by the collapse of the WTC and the requirements set forth in the asbesto.s rules, the Department recommends the cleaning of WTC debris from all surfaces as part of the 1

NYC-WTC_000152063