EPA program revisions and coordination memo, July 2003

NYC 9/11 Public Portal Document

An NYCPDC official told us that they had been advised by the Port Authority that as for the two towers, one tower was built without asbestos and the second tower had been built with asbestos fire-proofing up to approximately the floor. Further, the Port Authority had advised that it had initiated a program following the 1993 bombing to remove asbestos related materials where present.had removed accessible asbestos-containing material from the WTC buildings prior to September 11. In addition. City officials were advised by the Port Authority and General Services Administration that -Tthere was no asbestos containing-material in the above ground portions of WTC Buildings 4, 5 and 6. However, asbestos-containing material was found in the garage structure area at the WTC sitcz. City officials told us that the City’s Asbestos Control Program rules did not apply because of the emer; situation.- While EPA and New York State asbestos NESHAP regulations require that a notification be filed even in emergency situations.r-NJ^notification of a NESHAP demolition and removal operation was not filed for the WT€-demolition and removal of WTC buildings 4, 5 and 6 because City officials were advised by the property owner and one of the larger tenants, which happened to be a Federal agency, that there was no asbestos in the above ground structures. . Although this-technical requirement-was not metin any event, throughout the WTC site,, proper planning was taken in the removal of asbestos-containing material and as set forth below- proper procedures were followed in removing any asbestos-containing material, which were below grade, and to minimize exposure to asbestos-containing material- Health and safety meetings were held every day to plan to deal with, among other things, removal of asbestos-containing material. A number of City, State, and Federal agencies, including OSHA, DEC, FEMA, EPA, USACE, and PEP, as well as the construction managers and Bechtel participated in these meetings.These meetings were a collaborative effort among a number of Cit-y-^ State and Federal agencies, including the-fiP-A. All participantsagencies, including EPA, -contributed their expertise and collaboratively played a role in the decision making at these meetings. These meetings discussed among other things concerning removal of asbestos-containing materiah and the adequate wetting down of the material. Procedures for removal of tlie material were continuously revised considering the location and nature of the material and any other issues affecting removal. Also, in this regard, a site safety plan w-as created to address issues such as the removal of asbestos-containing material. All agencies, including the EPA reviewed this plan and had input into the final version of the plan. As set forth below proper procedures including measures to insure adequate wetting down of asbestos-containing material were taken.Citv ©ffieiak4old-us-thaf-the-Gity^s-Asbestes-Ge«trol-4h=egFaHH=«les-did-«et^ply beeause-eTthe-emergeney-situatioft^^WtheFraNYGDDG-effieial-teld-us-that-the Pert-T^utherityTtad^^effloved-aeeessible-asbestes-eontaifHftg-mateFial-ftem-the buildings prior to September 11. Gonsequently; in his view asbestes-was not a primary concern in the demolition.

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