NYC 9/11 Public Portal Document
DRAFT EXCERPTS FROM SECTION 4:
FOR REVIEW & DISCUSSION PURPOSES ONLY
Asbestos Work Practices Used in the WTC Complex Demolition
The New York State Department of Environmental Conservation is delegated
responsibility for implementing all Federal regulations under the NESHAP program.
NYCDEP is responsible for the asbestos abatement program in New York City. Even
though authority to run the program in New York was delegated to the State and local
agencies, EPA retains the authority to oversee agency performance and to enforce
NESHAP regulations as appropriate.
The NESHAP emergency requirement - - wetting damaged buildings before demolition
and continuous wetting of the debris after demolition - - appeared to have been
followed. However, implementation of work practices to reduce asbestos emissions
during transport of asbestos-containing debris appeared to be inconsistent. The
following sections describe work practices employed to reduce asbestos emissions.
Arrangements for Demolition and Debris Removal
The New York City Department of Design and Construction (NYCDDC) was
responsible for demolition and debris removal at the site. NYCDDC retained four
construction companies to perform the demolition and debris removal. In addition,
wetting and misting operations at the site were arranged by one of the four companies.
According to New York City officials, because of the unprecedented nature of the
disaster and the work to be performed, formal written contracts with detailed
statements of the work to be performed were not prepared. Instead, daily meetings
were held to plan the day’s activities and address any special work practices that may
be required to reduce possible emissions of asbestos.
Written NESHAP Notifications Not Prepared
EPA and New York State asbestos NESHAP regulations require that a notification be
filed even in emergency situations. The notification process provides an opportunity for
government officials to discuss and determine the preferred work practices to be used
in demolition and renovation operations. Notification of a NESHAP demolition and
removal operation was not filed for the WTC. City officials stated that a written
notification was not filed for WTC buildings 4, 5, and 6 because they were advised by
the property owners that there was no asbestos-containing material in the above ground
structures. NYCDDC officials told us that they were advised by the Port Authority that
subsequent to
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