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EPA program revisions and coordination memo, July 2003

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Interagency memo circulating EPA revisions for NESHAP and related programs with request for legal and agency comments.

NYC-WTC_000153096–000153111
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NYC 9/11 Public Portal Document

Excerpts from Draft Report

Qualification Regarding Our Observations and Conclusions

The demolition and debris removal at the World Trade Center site presented an unprecedented situation and the standard government contract procedures that would be used in a normal situation were modified to deal with the unprecedented situation. The New York City Department of Design and Construction (NYCDDC) was responsible for demolition and debris removal at the site. NYCDDC entered into awarded four emergency oraTcontracts with four construction management companies for demolition and removal. Under the circumstances, written contracts were not executed between the City and the construction management companies.., as -wel-l-as a contract for wWetting and misting operations at the site were was subcontracted under these contracts. As stated above, the standard procedures for government eentraets-were modified to deal with the situation. A scope of work was not issued for the construction management work as there was no time for standard planning in this circumstance. Instead, meetings were held every day at 9:00 a.m. to determine the work to be done and verbal directions w'ere issued to the construction managers concerning the work to be done for the day. Another meeting was held at 5:00 p.m. to determine the progress that had been made that day and to assist in planning work for the planning the evening work (the work was performed 24 hours a day, 7 days a week). Representatives of the four construction managers, various subconsultants and subcontractors, and the staff of various federal, state, and city agencies attended these meetings. NewYork City officials would then would work with the construction managers at the site to try to insure that the work was accomplished. Another meeting was held at 5:00 p.m. to determine the progress that had- been made that day and to assist in planning work for the next day. At both meetings, minutes of the previous meeting would be provided so the meeting participants could review the tasksmgs from the previous meeting to aid in dealing with the issues for the current meeting. We contacted-an NYCDDC effieiaT«h(Hrt-demehtiem«nd-dehiTy^emeyal-eperathms-at-the-site-and4=eq«ested copies of the statements of work fdr-these contracts in order to determine what, if any, Asbestos NESHAP work practices wererequir-edrby-th&se-e^ntracts. Although we made multiple Fequests;-we were not provided with copies-ef-these statements of work. Accordingly, our review and conclusions were limited since we were unable to review these key documents.

NOTIFICATION AND PLANNING CONCERNING ASBESTOS­ CONTAINING MATERIALSA/ESHjAP NotificatfonReQuk^ment&N/^FoUowed

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NYC-WTC_000153105Source: NYC Law Department, mirrored locally

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