Regulatory Submittal Part I(R)
EPA Comments to Remediation Work Plan
Dated: January 17, 2007
GENERAL COMMENTS:
1. With regard to the reference to the disposal of brick and mortar as conventional
construction and demolition (C&D) waste throughout the plan, those references should be
revised to state that if no residual WTC dust is identified by visual observation and if
waste characterization results collected during the Pilot Program do not exceed
RCRA/TSCA limits, brick and mortar removed subsequent to the Pilot Program, in nongash areas, will be handled and disposed of as conventional C&D waste.
It is the intent of the work plan design that brick and mortar will be removed during the
deconstruction operations. The procedure for the removal of brick and mortar will
detailed in Part I(D) – Deconstruction Operations to be submitted under separate cover.
Additionally, please refer to the response the the below General Comment No. 4 for
information regarding procedures to be implemented should suspect WTC dust be
identified on brick and mortar.
2. Airtek should clarify in the Remediation Work Plan if the definitions for porous and
nonporous items, non-fixed items, and exposed building components discussed in Section
6.1.1 for developing the clean zone apply to the definition for porous and non-porous
items, nonfixed items, and exposed building components to be disposed on the other
floors/roofs of the building, as discussed in later sections.
The following statement has been added to Section 6.0
“Please note that all items and components defined as porous or non-porous, non-fixed
and exposed are the same for all work, on all levels of the Building under the remediation
operation.”
3. In Airtek's response to comments, Airtek states that any comments received from MTA
and LMCCC will be incorporated into the plan and will be submitted for approvals before
the commencement of "remediation operations" work. The regulators would need to
review the plans again prior to commencement of work if revisions are made based on
comments
received from LMCCC and MTA.
All changes to the Work Plan will be provided to the Regulators for review. Any changes
to the Work Plan subsequent to regulatory approval will be submitted in the form of
amendments. No work will begin on an amendment until regulatory review and approval
granted for that amendment.
4. Please clarify if the results of the scaffold attachment inspections will be applied to
work procedure planning for the removal of any non-gash area fascia brick during the
remediation phase or will all of the non-gash area fascia brick removal be handled during
the deconstruction phase of the project. The remediation phase work plan should be
amended and reviewed and accepted by the regulators if the non-gash area fascia brick
will be handled and removed during the remediation phase.
The following language has been added to Section 6.19. Please note that the title of
Section 6.19 has been revised for clarity to address additional materials to be removed
during deconstruction operations. The new title of Section 6.19 is: Spandrel Mastic,
Kneewall, Brick & Mortar Removal
“Results of visual inspection of all scaffold attachment façade openings will be applied to
work procedure planning. Gash Area and Non-Gash-Area brick requiring
environmentally-controlled handling & removal will be subject to Remediation Phase
removal. Exact scope, procedure and sequence for this work will be developed by the
owner’s environmental consultant based on the field conditions and results of the
inspections. A detailed amendment to the Remediation Work plan will be developed on
completion of the inspections and design review of the conditions noted. This amendment
will be submitted for review and approval by the Regulators.
If visual inspection determines that Gash Area and Non-Gash Area brick and mortar are
not impacted by ACM or suspect WTC dust then these materials will be disposed of as
conventional construction and demolition (C&D) waste.”
5. How will Gaylord boxes be sealed? Will an entire Gaylord box be wrapped in poly on
the outside? If so, how many layers? This should be clarified in any sections that discuss
the usage of Gaylord boxes.
The following language has been added to Sections 6.1.3 & 6.9:
“All Gaylord boxes will be encapsulated prior to being delivered to the Site. The purpose
of encapsulating boxes is to render their exterior surfaces cleanable so that they may be
decontaminated upon removal from remediation work areas. Prior to use, each Gaylord
box will be made leak tight by lining the interior with either fitted plastic inserts or two
layers of poly. Gaylord boxes will be sealed by securing fitted lids into place on each box
with duct tape.”
Please note that the exteriors of gaylord boxes will not be wrapped in poly.
6. The Remediation Work Plan should describe the "aggressive clearance air sampling"
and "aggressive air sampling" procedures/techniques.
The following criteria has been added to Sections 6.1.7 and 6.20
“Aggressive Sampling Techniques
The following aggressive sampling techniques will be utilized for clearance of every
work area:
Pre-Sampling Agitation: Before starting the air sampling pumps, the exhaust of
forced air equipment (i.e., leaf blowers) will be directed at all walls, ceilings
floors, ledges, and other surfaces in the room(s). This will continue for at least
five (5) minutes per 1000 sf of floor space.
Ongoing Agitation: At least a 20-inch fan will be placed in the center of each
room. One fan per 10,000 cubic feet of room space will be used. The fan will be
operated on slow speed and pointed toward the ceiling.
Begin Sampling: The sampling pumps will then be turned on.
End Sampling: When the sampling has been completed, the sampling pumps will
be turned off first, followed by the fan(s).”
SPECIFIC COMMENTS:
Section 3.5: USEPA Notification
7. It does not appear that the sample notification stated to be Attachment III, was
submitted. Please confirm that all the attachments have been included.
EPA notification has been submitted. A stamped copy of most recent amendment is
attached.
Section 4.5: Elevator Service & Section 6.2 (Upper Level Access)
8. Please provide more details on the portable hoist, the level of PPE used by those
installing and using the hoist, and the purpose of its use.
The following language has been added to Section 4.5:
“The purpose of the hoist is to provide additional means of controlled veritcal transport
for materials, equipment and removed items and/or waste.
The portable hoist to be installed is a Scaffold Monorail System. It is mounted on a seven
foot (7’) long pipe scaffold frame for support during operation. The portable hoist weighs
one hundred ten pounds (110 lbs). Dimensions of the portable hoist are forty-seven and a
half inches (47.5”) wide and seventy-six inches (76”) long. The distance the portable
hoist overhangs the scaffold mount is by forty-two inches (42”). The weight capacity of
the portable hoist is one thousand pounds (1,000 lbs).
The portable hoist will be installed and operated by personnel utilizing the same level of
PPE to be utilized during the remediation operations and detailed below in Section 6.0.”
Section 5.4: Visual Inspection
9. Recommend adding "for the owner" at the end of the last sentence of the last bullet
item: "This procedure shall be followed by all parties who hold authority over the release
of work areas for the owner."
This addition has been made to Section 5.4 of the Work Plan.
Section 6.1.1: Non-Fixed Items
10. The second sentence of this section states the following: "All non-porous items,
including furniture and construction materials will be transported to the wash room of the
waste decontamination facility." What type of furniture and construction material is being
considered to be "non-porous items"? Materials, such as, but not limited to, wood,
upholstered furniture, etc. would be considered to be porous materials and would need to
be disposed of as asbestos waste at a minimum, and depending on any final waste
characterization results conducted or to be corducted.
Below is the list of non-fixed items considered to be non-porous that is included in
Section 6.1.1:
• Metal Furniture (chairs, filing cabinets, desks)
• Plastic Items
• Unused Non-Porous Construction Materials (duct work, metal
items, piping, rebar)
It is acknowledged that unfinished wood items and upholstered furniture are porous and
uncleanable.
Section 6.1.1: Non-Fixed Items
11. It is recommended that the definition of "conventional waste" be revised to read as
follows: "Conventional waste shall refer to any non-asbestos containing non-porous
material that is free of any dust or debris."
This definition has been revised as requested.
12. Recommend revising the following sentence in the first paragraph of this section to
read as follows: `Below is a list of non-fixed items that are non-porous and that are
suitable to be cleaned and disposed of as conventional waste".
This revision has been made as requested.
13. Reference is made to the "First Floor remediation" in a few locations of this section
Please clarify in this section if this pertains to the "First Floor Clean Zone" remediation
or the entire first floor remediation that is being done at different stages of the
remediation phase.
All references to First Floor remediation in Section 6.1 – Establishment of the Clean
Zone refer to the First Floor Clean Zone. These references have been revised for
consistency to state First Floor Clean Zone in all instances that pertain to the Clean Zone
and not to other areas of the First Floor.
Section 6.1.2 (Now Section 6.1.3) : Exposed Building Components
14. The second and third bullet items should be clarified if there are any wood doors
and/or wood radiator covers in the building since these items should be considered
porous materials and should be handled and disposed of as asbestos waste at a minimum,
and depending on any final waste characterization results that may have been or may be
conducted for that waste stream. This comment also applies to the reference to doors in
sections 6.1.3 and 6.8.
The following items have been added to the list of materials in Section 6.1.3 & 6.1.4 to
be disposed as asbestos waste at a minimum and depending on any final waste
characterization results:
•
Any wood doors and/or wood radiator covers
The following item has been added to the list of materials in Section 6.8 considered
shreddable and to be disposed as asbestos waste at a minimum and depending on any
final waste characterization results:
•
Any wood
15. Please see comment below under, "Regulatory Submittal Part IV(R), Remediation
Phase, Waste Sampling and Management Plan," with regard to ballasts. Such comment
applies to this section as well.
The following language has been added to Section 6.1.3:
“An inspection and inventory of existing light ballasts is ongoing, and testing as
appropriate is being conducted. The procedure for handling, packaging and storing of
light ballasts will be developed by the Owner’s Environmental Consultant based on the
results of the inspection and testing.”
Section 6.1.6: Cleaning and Clearance of the First Floor Clean Zone
16. This section discusses a visual inspection by the environmental consultant prior to the
conduct of aggressive air sampling. This section should be revised to state that the
regulators will conduct a visual inspection after the environmental consultant determines
that a specific work area is ready for a final visual inspection by the regulators prior to
the conduct of any aggressive air sampling. The environmental consultant should give the
regulators at least a minimum of twenty-four hours notice before the regulators are
expected to conduct the final visual inspection.
The following language has been added to Section 6.1.6:
“At the end of this settling period, the Owner’s Environmental Consultant and PAL
superintendent will perform a visual inspection of the First Floor Clean Zone work area.
The Owner’s Environmental Consultant will make a determination as to whether or not
the area passes visual inspection. Once the work area has passed the OEC visual
inspection, an OEC representative will contact the regulators to schedule a regulatory
visual inspection of the work area. Twenty-four hour notice shall be provided to the
regulators prior to the date of inspection. After the area has passed regulatory visual
inspection, aggressive clearance air sampling will be performed by the Owner’s
Environmental Consultant.”
Section 6.1.7: Cleaning and Clearance of Stairwell C
17. This section states the following: "When decontaminated floors have been cleared the
entrances into Stairwell C will be unsealed to provide clean access to clean areas." How
are personnel accessing these clean areas if these areas will be above the floors that still
need to be abated? What is the purpose?
Further review of remediation operations has determined that it will be necessary to
perform the cleaning and clearance of Stairwell C before commencing the removals,
cleaning and clearance in the First Floor Clean Zone in order to accommodate the
installation of electrical requirements in Stairwell C.
In order to maintain continuity, it will be necessary to change the numbering of the SubSections of Section 6.1 to move the Cleaning of Stairwell C to the beginning. The
Cleaning and Clearance of Stairwell C will now be Section 6.1.1. All other Sub-Sections
of Section 6.1 will follow sequentially behind Section 6.1.1 in the order they were
written in the original Part I(R) – Remediation Operations Work Plan with the exception
of new sections added in response to regulator comments. For example a comment
regarding sub-section 6.1.4 will be responded to in sub-section 6.1.5. In this example,
6.1.4 and 6.1.5 are the same sub-section only now they are numbered differently in
response to the revised sequencing.
Below is the revised Sub-Section regarding the cleaning and clearance of Stairwell C:
Section 6.1.1 Cleaning and Clearance of Stairwell C
The construction of Stairwell C is of the following materials:
•
•
Painted Masonry Block Walls
Concrete Floor Landings
•
•
•
•
•
•
•
Concrete Deck
Steel Stairs
Steel Handrails
Stand Pipe
Light Fixtures
Light Bulbs
Electrical Conduit
Prior to the cleaning and clearance of the First Floor Clean Zone, PAL will commence the
cleaning and clearance of Stairwell C. It is necessary to clear the Stairwell C at the beginning
of the remediation operations in order to install electric panels for the remediation work on
the upper floors of the Building. All electrical power to the Stairwell C will be shutdown
prior to the commencement of Cleaning and Clearance activities. A worker and waste
decontamination facility will be constructed exterior to the Building on the ground level on
the South Side in the Gash Area. NYS DOL and NYC DEP certified asbestos handlers will
construct an access tunnel from the decontamination facility into the Building via the Gash
Area. The tunnel shall be constructed of hard wood. Prior to constructing the tunnel, the
wood panels will be encapsulated in order to render the surfaces cleanable. The tunnel will
meet the Stairwell C at the south side of the First Floor landing. The existing painted
sheetrock wall into the Stairwell C will be demolished by NYS DOL and NYC DEP certified
asbestos handlers in order to create and opening from the south side. The access tunnel will
be fully connected to this opening so that there is no air transfer into the tunnel from the First
Floor. In order to connect the tunnel to the opening into Stairwell C it will also be necessary
to demolish a masonry block wall that is in the path of the tunnel. Prior to commencing the
demolition of the painted sheetrock and masonry block walls, the surfaces will be wetted
down with amended water to control dust. Please note that it is not possible to fully saturate
painted sheetrock or masonry block as these materials do not absorb water. The painted
sheetrock and masonry block walls will not be fully saturated with water during demolition.
Water will be used to as a means of dust control at all times during the removal the painted
sheetrock and masonry block walls to connect the access tunnel to Stairwell C. The painted
sheetrock and masonry block walls will be demolished using a combination of manual and
mechanical means Debris generated from the painted sheetrock and masonry block walls will
be handled and disposed of as asbestos waste. All openings and penetrations into Stairwell C,
including the doorway onto each floor will be sealed with two (2) layers of poly. Four (4) air
changes with negative pressure differential of point zero two inch (0.02”) water column will
be established within the Stairwell C and the attached access tunnel. Make up air will be
drawn from the decontamination unit. Negative air units will be installed in the stairwell on
the Fifteenth Floor and vented onto the main roof level via the existing doorway. All light
bulbs and fixtures will be detached. Light bulbs and fixtures will be handled and disposed of
as universal waste. All interior surfaces of the stairwell and the attached access tunnel will be
HEPA vacuumed and wet wiped to remove any residual dust and debris. All used cleaning
materials generated during the remediation in the C Stairwell and access tunnel will be
double bagged, properly labeled, processed through the waste decontamination facility and
disposed of as asbestos waste. Please note that there are no asbestos containing materials
present within Stairwell C. Wall, ceiling and floor surfaces will remain in place within the
Stairwell C once remediation activities have been completed. After cleaning activities are
completed one twelve hour settling/drying period will then be observed in order to allow all
surfaces to dry. At the end of this settling period, the Owner’s Environmental Consultant and
PAL superintendent will perform a visual inspection of the C Stairwell work area. After the
area has passed visual inspection by the Owner’s Environmental Consultant, the regulators
will be contacted to perform a regulatory visual inspection. Twenty-four (24) hour notice will
be provided prior to the regulatory visual inspection. After the Stairwell C work area has
passed regulatory visual inspection, aggressive clearance air sampling will be performed by
the Owner’s Environmental Consultant. Sampling will be performed as follows: 5 TEM air
samples (1 sample for every 3 floors) and 5 Metals air samples (1 sample for every 3 floors)
will be run for the entire stairwell. Sample locations will be evenly distributed vertically
through the stairwell. Clearance testing for all work areas will be consistent with the work
area Clearance Criteria noted in section 6.21.
Once successful clearance is achieved the modified full containment in the C Stairwell will
remain in place in order to prevent recontamination from yet-to-be-cleaned areas. After
decontaminated floors have been cleared the entrances into Stairwell C will be unsealed to
provide clean access to clean areas. After the Stairwell C has been cleared GFCI equipped
electrical panels will be installed on each floor level within the stairwell by licensed
electricians. Power will be run from the electrical closets that abut the south side of the
Stairwell C wall on Floors 2 through 15.
18. This section states the following: `Wall, ceiling and floor surfaces will remain in
place within the C Stairwell once remediation activities have been completed." Please
clarify what materials the wall, ceiling, and floor surfaces consist of within the stairwell.
Please clarify if there are any porous materials within the stairwell that should be
removed during the "remediation" activities as opposed to the "deconstruction" phase.
The following list of the stairwell construction materials/surfaces existing in Stairwell C:
•
•
•
•
•
•
•
•
•
Painted Masonry Block Walls
Concrete Floor Landings
Concrete Deck
Steel Stairs
Steel Handrails
Stand Pipe
Light Fixtures
Light Bulbs
Electrical Conduit
Please note that all painted masonry wall surfaces will be cleaned by HEPA vacuuming
and wet wiping during the Cleaning and Clearance of Stairwell C.
19. This section discusses a visual inspection by the environmental consultant prior to the
conduct of aggressive air sampling. This section should be revised to state that the
regulators will conduct a visual inspection after the environmental consultant determines
that a specific work area is ready for a final visual inspection by the regulators prior to
the conduct of any aggressive air sampling. The environmental consultant should give the
regulators at least a minimum of twenty-four hours notice before the regulators are
expected to conduct the final visual inspection.
The following language has been added to Section 6.1.7:
“Once the work area has passed the OEC visual inspection, an OEC representative will
contact the regulators to schedule a regulatory visual inspection of the work area.
Twenty-four hour notice shall be provided to the regulators prior to the date of
inspection. After the area has passed regulatory visual inspection, aggressive clearance
air sampling will be performed by the Owner’s Environmental Consultant.”
Section 6.1.8: First Floor Clean Zone and C Stairwell Clearance Criteria
20. This section discusses a visual inspection by the environmental consultant prior to the
conduct of aggressive air sampling. This section should be revised to state that the
regulators will conduct a visual inspection after the environmental consultant determines
that a specific work area is ready for a final visual inspection by the regulators prior to
the conduct of any aggressive air sampling. The environmental consultant should give the
regulators at least a minimum of twenty-four hours notice before the regulators are
expected to conduct the final visual inspection. This comment also applies to Sections
6.20 (Final Cleaning and Clearance) and 6.21 (Work Area Clearance Criteria).
The following language has been added to Section 6.1.8:
“At the end of this settling period, the Owner’s Environmental Consultant and PAL
superintendent will perform a visual inspection of the First Floor Clean Zone and C
Stairwell work areas. The Owner’s Environmental Consultant will make a determination
as to whether or not the area passes visual inspection. Once the work area has passed the
OEC visual inspection, an OEC representative will contact the regulators to schedule a
regulatory visual inspection of the work area. Twenty-four hour notice shall be provided
to the regulators prior to the date of inspection. After the area has passed regulatory
visual inspection, aggressive clearance air sampling will be performed by the Owner’s
Environmental Consultant.”
21. How do you plan to conduct final aggressive air sampling and final clearance of the
stairwell? How many samples will be taken for the stairwell? This section should be
revised to address these questions.
The following criteria has been added to Sections 6.1.7 and 6.20:
“Aggressive Sampling Techniques
The following aggressive sampling techniques will be utilized for clearance of every
work area:
Pre-Sampling Agitation: Before starting the air sampling pumps, the exhaust of
forced air equipment (i.e., leaf blowers) will be directed at all walls, ceilings
floors, ledges, and other surfaces in the room(s). This will continue for at least
five (5) minutes per 1000 sf of floor space.
Ongoing Agitation: At least a 20-inch fan will be placed in the center of each
room. One fan per 10,000 cubic feet of room space will be used. The fan will be
operated on slow speed and pointed toward the ceiling.
Begin Sampling: The sampling pumps will then be turned on.
End Sampling: When the sampling has been completed, the sampling pumps will
be turned off first, followed by the fan(s).”
22. Please clarify that the clearance criteria levels specified in this section will apply to
the stairwells in addition to the floors being abated and cleared.
Please refer to revised Section 6.1.1 Cleaning and Clearance of Stairwell C
After the cleaned stairwell passes visual inspection by the Owner’s Environmental
Consultant, and the Regualtors, 5 TEM air samples (1 sample for every 3 floors) and 5
Metals air samples (1 sample for every 3 floors) will be run for the entire stairwell.
Sample locations will be evenly distributed vertically through the stairwell. Clearance
testing for all work areas will be consistent with the work area Clearance Criteria noted in
section 6.21.
Section 6.3: Shredder Installation
23. This section discusses shoring the floor underneath the "First Floor Shredder Zone"
using lolly columns and steel beams to be installed on the basement level. What type of
personnel will be conducting this activity and what type of pre-cleaning of the area will
be conducted to establish a clean zone to facilitate the installation of the shoring? Please
clarify in this section
The following language has been added to Section 6.3:
“All shredder shoring installation activities will be monitored by an NYS DOL certified
project monitor. The required shoring will be performed by scaffold/shoring installation
personnel who have valid asbestos awareness certification and are equipped with
remediation operations abatement work area PPE. A personal decontamination unit will
be installed at the entrance to the Basement Level from First Floor Clean Zone to be used
for shredder shoring related personal decontamination activities. The primary waste
decontamination unit will be used for the decontamination of waste generated during the
shredder shoring installation. Refer to the Attachment V - Logistics Plan entitled
“Configuration of First Floor for Basement Remediation” to see the layout of the
decontamination units for the shredder shoring installation. Shoring to be installed will be
made of steel. The exact location and layout of shoring will be determined by the
engineer of record for the shredder installation. NYS DOL and NYC DEP certified
asbestos handlers equipped with abatement work area PPE will perform pre-cleaning of
the surfaces at each location where the shoring will be installed. Pre-cleaning activities to
be performed will include HEPA vacuuming and wet-wiping. In addition, depending on
the exact location of the shoring, minor removals of raised flooring, ceiling tiles, and/or
ceiling grid may be necessary prior to installation. Any waste generated will be
containerized, decontaminated and stored in the First Floor Clean Zone waste storage
facility for disposal as asbestos waste at a minimum, and in accordance with any waste
characterization testing deemed necessary by the Owner's Environmental Consultant.
Limited ACM removal (i.e. VAT) if necessary, will be performed at shoring installation
areas only at this time. Should limited abatement be necessary, NYS DOL and NYC DEP
certified asbestos handlers will wet down the ACM with amended water and remove it by
manual means. Any asbestos waste generated will be containerized, properly labeled,
decontaminated and stored in the existing First Floor Clean Zone waste storage facility
for disposal as asbestos waste at a minimum, or in accordance with any waste
characterization testing deemed necessary by the Owner's Environmental Consultant.
Any ACM abated areas will be cleaned by HEPA vacuuming and wet-wiping. After these
surfaces are cleaned, they will encapsulated. After pre-cleaning and removals are
complete, the installation areas will be visually inspected by the Owner's Environmental
Consultant. The visual inspection will be performed by the NYS DOL certified project
monitor. The project monitor will verify that the installation areas have been properly
cleaned and are free of bulk debris, dust and/or residue. If limited ACM abatement is
performed, the project monitor will also visually inpsect all abated areas. Once the
installation areas have passed OEC visual inspection, the steel shoring will be installed
based on the engineer of record for the scaffolding specifications by shoring installation
personnel equipped with abatement work area PPE. Shoring installation personnel with
asbestos awareness certification will be instructed that disturbance of ACM is prohibited
during the installation procedure. The shoring will be installed in, and remain in, noncleaned areas until the Final Cleaning and Clearance of the Remediation Operations
reaches the Basement Level where the shredder shoring is installed.”
The following language has been added to Section 6.20:
“Shoring in the Basement to support the shredder and the scaffolding on the 5th & 14th
Floor Setback Roofs be decontaminated by HEPA vacuuming and wet-wiping Any
adjustable shoring for the shredder will be dismantled so that the individual sections can
be decontaminated. The surfaces where shredder shoring had been installed will be
cleaned by HEPA vacuuming and wet-wiping. After cleaning, the shoring beneath the
Setback Roof Levels will remain in place since the scaffold must remain in place for the
deconstruction. As the deconstruction activities proceed down the Building, the
scaffolding will be taken down level by level by deconstruction personnel. Once the
deconstruction activities reach a Setback Roof Level and the exterior scaffolding on that
Roof Level has been removed, the deconstruction personnel will remove the shoring
beneath the affected level.”
24. Based on discussions with NYSDOL, it is recommended that the word "may" be
replaced with `shall" in the following sentence of the last paragraph of this section:
'Manufactured items with asbestos content of one percent or greater may not be subject to
shredding."
Language has been changed in the work plan to comply with this request.
25. What type of dust control devices will be installed on the shredder? Please clarify in
this section.
The following language revision has been added to Section 6.3:
“The shredder will be equipped with a wet misting system for dust control. The misting
system consists of a plastic attachment for a water hose. The attachment spreads water
from the hose in an even and repetitive manner across the shredder loading hopper. The
misting system shall be running continuously at all times while the shredder is being
operated. The shredder area will be placed under negative pressure as part of the
containment of the upper levels.”
“The contractor will install negative pressure ventilation equipment, as demonstrated by
calculations, to provide eight (8) air volume changes per hour in the Shredder Zone.
Please note that the shredder zone is part of the one containment work area where air
volume will be changed four (4) times per hour in accordance with ICR 56. A manometer
shall be installed in the shredder zone to document pressure differential in this area.”
Section 6.4: Establishment of Secondary Loading Dock
26. Please explain in this section how the loading dock area will be cleaned.
The loading dock area is a part of the First Floor Clean Zone and will be cleaned during
the cleaning and clearance of the First Floor Clean Zone.
The following text has been added to Section 6.4:
“The secondary loading dock area is included within the First Floor Clean Zone and will
have been cleaned with the rest of the First Floor Clean Zone, passed visual inspections
and final clearance prior to the establishment of the Secondary Loading Dock.”
Section 6.5: Establishment of Interior Containment (Second Floor through Fifteenth
Floor)
27. Why were intake bays proposed as opposed to negative air machines to bring in air?
How will filters be changed?
Negative air machines are going to be used to pull make up air into the Building through
the air intake bays. The intake bays will be equipped with hinged flaps. When the
negative air machines are activated, the negative pressure will pull the flap inward and
draw make up air from the outside environment into the work area.
The intake flaps will be HEPA filter equipped to prevent air from interior work areas
from communicating with the outside environment in the event of a negative pressure
failure.
The following language has been added to Section 6.5:
“The contractor supervisor will regularly inspect the filters on the flap mechanism and
change them as needed.”
Section 6.6: Simultaneous Work Procedures
28. With work being performed on several floors within the building simultaneously, will
there be enough showers in the decon to support the amount of workers in the building?
Please clarify in this section
The Contractor will provide sufficient showers to support all certified abatement
personnel working in the building in compliance with all applicable regulations.
The following statement has been added to Section 6.6:
“Sufficient shower facilities will be provided for all abatement personnel performing the
remediation operations.”
Section 6.7.1: Shreddable Material
29. Which "non-fixed items" are planned to be shredded from floors two through fifteen?
Please clarify in this section
The following list of non-fixed items to be shredded has been added to Section 6.7.1:
Non-fixed items comprised of any of the following material may be processed through
the shredder
•
•
•
•
•
•
Wood
Metal
Upholstered
Plastic
Glass
Any other non-ACM material determined to be uncleanable by the Owner’s
Environmental Consultant.
30. How will Gaylord boxes be removed from the floors and loaded onto the trucks?
Please clarify in this section.
The following language has been added to Section 6.7.1
“Individual Gaylord boxes will be transported in the building and loaded onto trucks
utilizing pallet jacks. If it is necessary to move Gaylord boxes between floors, the
elevator cars shall be used. Pallet jacks will be used inside of the work area and in the
First Floor Clean Zone. Workers inside the work area will load a full, sealed Gaylord box
onto a pallet jack. The pallet jack will then be moved via the elevators to the Primary
Waste Decontamination Facility on the First Floor. Gaylord boxes will be loaded into the
wash room of the Decon and fully decontaminated. After decontamination, the Gaylord
box will be transported into the clean room of the Decon and moved off of the pallet jack.
Workers with pallet jacks in the First Floor Clean Zone will enter the Decon clean room
from the Clean Zone and load the decontaminated Gaylord box onto the pallet jack. The
box will then be transported out of the Decon, into the First Floor Clean Zone waste
storage facility or asbestos waste trailer in the Primary Loading Dock. Pallet jacks used
inside of the work area are made of a cleanable, metal material. All pallet jacks will be
full cleaned and decontaminated before being removed from the work area.”
Section 6.7.2: Non-Shreddable Material
31. Which "non-fixed items" are planned to be cleaned that are not capable of being
shredded from floors two through fifteen? Please clarify in this section.
Further review of the work plan has determined that the title of Section 6.7.2 must be
revised for clarity. The new title for this section is Section 6.7.2 Non-Porous, Cleanable
Material
The reason for this clarification is that it is not necessarily the case that items planned to
be cleaned are not shreddable. In situations where it is more practical to decontaminate
non-porous, cleanable items, such items will be cleaned. In situations where it is more
practical to shred non-porous, cleanable items, such items will be shredded and disposed
as ACM waste.
The following list of items that apply to this clarification:
• Metal Furniture (chairs, filing cabinets, desks)
• Unused Non-Porous Construction Materials (duct work, metal
items, piping, rebar)
• Any other non-porous, non-ACM material determined to be cleanable by the Owner’s
Environmental Consultant.
.
Additionally, a new Sub-Section has been added under Section 6.7. This new SubSection is Section 6.7.3 Porous Items for Disposal. Below is the text of this Section:
Section 6.7.3 Porous Items for Disposal
Any porous items encountered that are not practical to shred or to manually dismantle
will be wrapped in two layers of six-mil poly, properly labeled, processed through the
waste decontamination facility and loaded into the asbestos waste trailer parked in the
existing loading dock for disposal of as asbestos waste. The wrapping of these items will
take place on the floor on which they are found. They will be wrapped prior to
transportation to the Primary Waste Decontamination Facility via the elevators and/or
construction hoist.
32. Are there any non-porous "non- fixed items" that are not capable of being shredded
and that are not capable of being cleaned from floors two through fifteen (e.g., hand
tools, power tools)? This section should clarify what these items are and how they will be
handled, stored, and disposed from floors two through fifteen.
It is not anticipated that any non-porous, non-fixed items that are not capable of being
shredded and not capable of being cleaned will be encountered during the project. Please
note that hand tools and power tools, if they are not capable of being cleaned, can be
shredded, or wrapped for disposal as ACM waste.
The following language has been added to Section 6.7.2:
“If any non-porous, non-fixed items that are not capable of being shredded and not
capable of being cleaned are discovered in the Building, they will be wrapped in 2 layers
of poly for disposal as asbestos waste as a minimum, or accordng to waste
characterization analysis.”
33. "and incapable of being cleaned" should be stricken from the first sentence of the last
paragraph of this section since all porous items should be handled and disposed of as
asbestos waste at a minimum and based on any final representative hazardous waste
characterization sampling that has been or will be conducted for that waste stream.
This language has been deleted as requested.
Section 6.8: Exposed Building Components (Floors Two through Fifteen)
34. Which "exposed building components" will be considered "shreddable building
components" and which will not be considered `khreddable building components"?
Please clarify in this section
The following list of Shreddable Building Components has been added to Section 6.8:
•
•
•
•
Any Metal (Duct Work, Supports, Hangers)
Any Plastic
Any Wood
Wiring
It is not anticipated that any exposed building components that are not capable of being
shredded will be encountered.
35. Please see comment below under, "Regulatory Submittal Part IV(R), Remediation
Phase, Waste Sampling and Management Plan" with regard to ballasts. Such comment
applies to this section as well.
The following text has been added to Section 6.8:
“An inspection and inventory of existing light ballasts is ongoing, and testing as
appropriate is being conducted. The procedure for handling, packaging and storing of
light ballasts will be developed by the Owner’s Environmental Consultant based on the
results of the inspection and testing.”
36. Which "exposed building components" are planned to be cleaned that are not suitable
to be shredded from floors two through fifteen? Please clarify in this section
It is not necessarily the case that items planned to be cleaned are not suitable to be
shredded. In situations where it is more practical to decontaminate cleanable items, such
items will be cleaned.
The following text has been added to Section 6.8:
“In situations where it is more practical to shred cleanable items, such items will be
shredded and disposed as ACM waste.”
37. Are there any non-porous "exposed building components" that are not suitable to be
cleaned and/or shredded from floors two through fifteen? If so, this section should clarify
what these items are and how they will be handled, stored, and disposed from floors two
through fifteen.
It is not anticipated that any non-porous exposed building components that are not
capable of being shredded and not capable of being cleaned will be encountered during
the project.
The following language has been added to Section 6.8:
“If any non-porous exposed building components that are not capable of being shredded
and not capable of being cleaned are discovered in the Building, they will be wrapped in
2 layers of poly upon detachment for disposal as asbestos waste at a minimum or in
accordance with any waste characterization results.”
38. Are there any porous "exposed building components" on floors two through fifteen
(e.g., wood doors, wood/upholstered furniture, etc.)? Wood/Upholstered "exposed
building components" should be considered porous materials and should be handled and
disposed of as asbestos waste at a minimum, with any other porous "exposed building
components", and depending on any final waste characterization results that may have
been or may be conducted for that waste stream. This section should clarify what these
items are and how they will be handled, stored, and disposed from floors two through
fifteen.
It is not anticipated that any porous exposed building components will be encountered
during the project. It is possible that porous insulation (ACM and/or non-ACM) may be
present. Please note that doors and furniture are considered to be non-fixed items.
The following language has been added to Section 6.8:
“If any porous, non-asbestos exposed building components are discovered during the
remediation operations, they will be processed through the shredder and loaded into
Gaylord boxes or wrapped in 2 layers of poly upon detachment for disposal as asbestos
waste at a minimum or in accordance with any waste characterization results. If porous,
non-asbestos insulation materials are found on non-porous exposed building components,
the insulation will be stripped off of the affected components and disposed of as asbestos
waste at a minimum or in accordance with any waste characterization results. The
affected non-porous components will then be detached and either cleaned for disposal as
conventional waste or processed through the shredder and loaded into Gaylord boxes for
disposal as asbestos waste at a minimum or in accordance with any waste
characterization results or wrapped in 2 layers of poly for disposal as asbestos waste at a
minimum or in accordance with any waste characterization results.”
39. This section states that non-shreddable material will be steam cleaned or wet washed.
However, other sections state that both methods will be used. Please clarify in this section
if both methods will be used or only one of these methods.
The following statement has been added to Section 6.8:
“Depending on the type of material, items will be either steam cleaned or wet washed
depending on which methodology proves more effective at decontaminating that
particular material.”
40. How will proper inspection of the cleaned material be conducted if it is being "liveloaded" into compactor trucks?
The following statement is included in Section 6.8:
“Once clean of all residual dust and debris, components will be inspected by the Owner’s
Environmental Consultant in the decontamination facility. After components pass OEC
visual inspection, they will be transported out of the waste decontamination facility and
live-loaded into compactor trucks docked at the Secondary Loading Dock for disposal as
conventional waste.”
The following statement has been added to Section 6.8 for clarification:
“No material shall be loaded until it has passed visual inspection by Owner’s
Environmental Consultant.”
Section 6.9: Interior Walls and Ceiling Systems (Floors Two through Fifteen)
41. The following sentence can be found in the second paragraph: `in both of the methods
for disposal of sheetrock and ceiling tile debris, metal materials will be removed in the
same manner." This statement contradicts the approach to be taken for handling the
ceiling grids later in the paragraph. Please clarify in this section or re-word or
remove the sentence.
This sentence has been struck from Section 6.9.
42. This section should be clarified to note that any porous building components and/or
materials existing behind interior walls or within ceiling systems should be handled and
disposed of as asbestos waste at a minimum, and depending on any final waste
characterization results that may have been or may be conducted for that waste stream.
This comment also applies to Section 6.1.3 and to the ventilation shaft section (i.e.,
Section 6.10).
The following clarification has been added to Section 6.9.
“Any porous building components and/or materials existing behind interior walls or
within ceiling systems will be handled and disposed of as asbestos waste at a minimum,
and depending on any final waste characterization results.”
Section 6.10: Ventilation Shaft
43. Please provide further details in this section on the basins to be used at the bottom
level of each shaft work area.
The following statement has been added to Section 6.10:
“Basins used to collect excess water will be either portable metal shower pans or will be
constructed of poly.”
Section 6.12: Gash Area Abatement Procedures
44. Please describe the scope of work and procedures to address the containment,
cleaning, removal, and visual inspections of all breached fascia brick in the gash area.
The following statement has been added to Section 6.12:
“Results of visual inspection of all scaffold attachment façade openings will be applied to
work procedure planning. Gash Area brick requiring environmetnally-controlled handling
& removal will be subject to Remediation Phase removal. Exact scope, procedure and
sequence for this work will be developed by the Owner’s Environmental Consultant
based on the field conditions and results of the inspections. A detailed amendment to the
Remediation Work plan will be developed on completion of the inspections and design
review of the conditions noted. This amendment will be submitted for review and
approval by the Regulators.
If visual inspection determines that Gash Area brick and mortar are not impacted by
ACM or suspect WTC dust then these materials will be disposed of as conventional
construction and demolition (C&D) waste.”
Section 6.13.1: Loose Stone (Ballast) Removal
45. This section states that the surface of the rubber roof membrane will be cleaned of all
residual dust and debris by HEPA vacuuming and wet wiping. Please clarify if there is a
potential for dust and debris to be located in the subsurface of the rubber roof membrane
in addition to the surface. If so, please clarify how the subsurface of the rubber roof
membrane will be cleaned and how the rubber roof membrane would be disposed.
The following revision has been made to Section 6.13:
“The surface of the roof levels at the Building have been previously cleaned by others
during WTC recovery operations. The contractor shall re-clean the ballast and surface of
the membrane in conjunction with the Office of the City Medical Examiner investigation
of those levels. After cleaning these materials will be left in place for removal during
deconstruction. With the exception of the Gash Area, the functionality of the roof levels
have not been compromised and the roof systems effectively prevent water incursion to
the building interior. The sub-surface of the roof levels, with exception to the Gash Area,
will not be cleaned as they are effectively sealed by the membrane allowing no transfer
for contaminants to migrage to the subsurface of the roofs.”
Further review of the Work Plan has determined that a new Sub-Section is required under
Section 6.13. The purpose of this Sub-Section is to address the procedures for roofing
remediation activities in the Gash Area. The new Sub-Section is titled Section 6.13.6
Gash Area Roofing. The text of this new Sub-Section is shown below:
Section 6.13.6 Gash Area Roofing
In Gash Areas on all affected roof levels, WTC impact is assumed for the edge of the roof
system at the Gash only. As stated above, the rest of the roof levels are sealed and nonporous. The contractor shall observe a ten foot (10’) demaraction from the Gash Area on
all affected roof levels. The purpose of the demarcation area is to provide a remediation
zone for the assumed WTC impact based on the condition of the compromised roof areas.
All ballast in the demaracation area will be cleaned in conjunction with The Office of the
City Medical Examiner inspection operations on all affected roof levels. Cleaned ballast
will be removed from the 10’ demarcation area onto adjacent areas of the roof levels
where it will remain for disposal during the deconstruction phase. All Gash Area roofing
membrane in the 10’ demarcation area will be removed, handled and disposed as asbestos
waste or in accordance with any waste characterization results. Gash Area roofing
material will be bagged on detachment from the roof surface. Once full, bags will be
placed inside a second bag, sealed and properly labeled. The exterior of the bags will be
decontaminated and removed from the area via the exterior pipe scaffolding system.
Once at ground level, bags of Gash Area roofing will be live-loaded into asbestos waste
trucks waiting at the site.
Section 6.18: Heavy Machinery & Equipment Removal
46. Please clarify if any of the heavy machinery and equipment noted in this section
could be dismantled under containment during the remediation phase and properly
handled and disposed during the remediation phase.
The following statement has been added to Section 6.18:
“Heavy machinery and equipment, such as elevator machines, cooling towers and water
heaters are constructed of many intricately operable components. In some cases this
machinery and equipment utilizes a lubricant such as oil or grease on operable
components. It is not believed that it is possible to fully decontaminate all components,
particularly those affected by oil, grease or other lubricants. It is the Contractor’s belief
that heavy machinery and equipment must be disposed of as absestos waste. These items
will be dismantled into sections and wrapped with two layers of poly and decontaminated
prior to disposal. Given the weight of these items, it is necessary to perform the removal
of heavy machinery and equipment during the deconstruction phase in order to utilize
rigging equipment that will be on site for deconstruction activities.”
Section 6.20: Final Cleaning & Clearance
47. Based on discussions with the NYSDOL, encapsulant should not be applied until
after the final air clearance sample results have been reviewed and accepted by the
regulators.
The following revision has been made to Section 6.20:
“Negative air ventilation units will continue to operate in all locations until successful air
clearance is achieved. Upon completion of final cleaning activities in each three floor
block, a visual inspection of the subject block of floors shall be performed by the
Owner’s Environmental Consultant in conjunction with a Contractor representative. To
review the visual inspection procedure, please refer to Section 5.4. Once a three floor
block has passed the Owner’s Environmental Consultant’s visual inspection, the
regulators will be contacted to perform regulatory visual inspection of the subject block
of floors. Twenty-four hour notice will be provided to the regulators prior to the date of
regulatory visual inspection. After the subject block of floors has passed regulatory visual
inspection, final aggressive air clearance will be run. Please refer to Section 6.21 for
clearance criteria. After successful clearance is achieved lockdown encapsulant will be
applied. After encapsulation, the modified full containment on the subject three floor
block will be broken down. This procedure will be repeated until all floors have passed
visual inspection, successful air clearance has been achieved on all floors, all floors have
been encapsulated and all critical barriers and barrier walls have been removed. Upon
completion of the final clearance of all floors the Primary Personal Decontamination
Facility and the Primary Waste Decontamination Facility will be dismantled.”