Presentation of the Draft Phase I Deconstruction Plan December 13, 2004 130 Liberty Street Deconstruction Project
Agenda • Introduction • Consultants and Contractors • Presentations • LMDC – Overview • TRC – Supplemental Testing • Gilbane – Deconstruction Plans • TRC – Proposed Enhanced Air Monitoring Program • Questions
Key Parties • Consultants/Contractors • Gilbane – Deconstruction Contractor • LVI – Asbestos/Cleaning Subcontractor • Weston – Environmental Monitoring Subcontractor • CDI – Deconstruction Subcontractor • TRC – Environmental Consultant • URS Corporation, Owner’s On-Site Representative • Ecology and Environment, Inc. – Public Outreach Consultant • Ambient Group – Exterior Air Monitoring • Kroll Associates – Integrity Monitor
Key Parties, cont. • Regulators • US Environmental Protection Agency • US Occupational Safety & Health Administration • NYS Department of Environmental Conservation • NYS Department of Labor • NYS Department of Health • NYC Department of Environmental Protection • NYC Department of Buildings • NYC Department of Sanitation • NYC Department of Health
Summary of Findings in Initial Characterization • The results of the sampling and testing revealed levels of contaminants that should be addressed in the deconstruction of the building. • Throughout the building, asbestos containing materials (ACM) were positively identified. • Detectable levels of asbestos, silica, PAHs, dioxins, PCBs, and heavy metals (including mercury) were also identified in dust above and below the suspended ceilings. • The results are consistent with the highly variable nature of WTC dust and the level of activity that has occurred within the building since September 11th.
Preparation for Deconstruction • Supplemental Testing • Development of the Deconstruction Plan • Permitting and Notification Plan
Supplemental Testing Additional testing is being conducted in previously inaccessible surfaces and interstitial spaces including: • The curtain wall, interior walls, the exterior of the building, HVAC and ductwork, vertical shafts and cell systems and raceways within the concrete slabs; • Testing for all COPC’s addressed in the initial characterization study which includes asbestos and other analytes as well as visual inspection for mold; • Preliminary waste characterization; • These results continue to inform the Phase I Deconstruction Plan and will form the basis of the Phase II Deconstruction Plan.
Supplemental Testing - Results HVAC testing is complete: • Average asbestos (1,188,236 str/cm2) and lead concentrations (611 ug/ft2) generally consistent with the concentrations identified in the Initial Building Characterization Report. • Average asbestos and lead concentrations in the interior of the HVAC ductwork system that exceed the benchmark criteria provided in the September 2002 and May 2003 USEPA WTC Indoor Environment Assessment studies; • While the USEPA residential benchmark and background concentrations relate to residential settings and are not directly applicable to a commercial deconstruction project, these studies can be used to put the results of this supplemental investigation into relative context. • These results and others as completed will be available on the LMDC website at www.renewnyc.com.
Timeline December 13, 2004 LMDC presents Regulatory Agencies and the Public with a draft Phase I Deconstruction Plan January 2005 Public Information Sessions on the Phase I Deconstruction Plan January 2005 Commencement of Phase I Deconstruction Activity
Principles of Deconstruction Plan • Protective of the health and safety of the workers and the neighboring community; • Compliant with all applicable rules and regulations; • Consistent with the findings of the “Initial Building Characterization Study Report" and supplemental testing; and • Consistent with current industry standard practices
Deconstruction Plan Phasing • Phase I • Phase IA • Phase IB • Phase II
Deconstruction Plan Phase I • Phase I: • Abatement of identified interior ACBM; • Cleaning and removal of World Trade Center (WTC) dust within the building; • “Soft strip and interior gut” of most interior non-structural materials, ( i.e. carpet, etc.); and • Erection of the tower crane on the north side and hoist on the south side of the building.
Deconstruction Plan Phase II • Phase II • Abatement of identified ACBM associated with the exterior of the structure; • Disassembly and removal of some remaining interior non-structural materials; • Removal of rooftop mechanical equipment and the remaining building envelope; and • Deconstruction of the structural components of the building.
Phase I Plan Components • Section 1: Waste Management Plan: • Classifies waste streams that will be generated; • Section 2: Ambient Air Sampling Program: • Methodology to monitor for contaminants of concern at monitoring locations around the perimeter of the 130 Liberty Street Building; • Section 3: Emergency Action Plan • Provides the initial response steps and identifies roles and responsibilities of LMDC and Gilbane during an emergency situation to protect the health and safety of onsite workers and the surrounding community; • Section 4: Safety Plan: (To be provided at a later date) • Provides the safety procedures for Gilbane, as well as each subcontractor including CDI, LVI, and Weston;
Phase I Plan Components Cont. • Section 5: Health and Safety Plan: • Presents practices and procedures all will follow during the deconstruction of the 130 Liberty Street Building; • Section 6: Asbestos Abatement Plan: • Comprises Phase IA of the deconstruction process and details activities necessary to carry out the abatement of ACBM and the cleaning and removal of dust; • Section 7: Soft Strip/Interior Gut Plan: • Comprises Phase IB of the deconstruction process and details deconstruction, removal, and disposal of interior, non-structural materials not removed during Phase IA.
Deconstruction Plan Phase IA • Phase IA • Activities will be undertaken from the top of the building down; • Abatement of interior Asbestos Containing Building Materials (ACBM); • Dust cleaning and removal; and • Removal of building components needed to complete the dust cleaning and asbestos abatement.
Means and Methods for Phase IA • Enclose all work areas and establish negative air pressure to ensure potential contaminants remain in the building. • Licensed abatement subcontractors will perform limited soft strip to create an open work area, followed by the removal of asbestos containing building materials (ACBM). • Thorough cleaning to remove any fibers that may have been released during the abatement of ACBM, and to remove the settled WTC dust. • Prior to any work, all vertical connections between floors will be sealed properly in order to prevent dust from reentering spaces/floors already cleaned and cleared. • Vertical connections (stairwells and shafts) will be cleaned last once all floors of the building have been cleaned.
Asbestos Abatement • Establish negative pressure; • Open work area; • Remove ACBMs; • Clean area and dust; • Encapsulate fireproofing; • Visual inspection; and • Final air clearance.
Deconstruction Plan Phase IB • Phase IB • “Soft strip and interior gut” • Removal of interior gypsum wall board partitions, sprayed-on fireproofing, bathroom fixtures, integral shelving and components; and • Removal of remaining small scale mechanical, electrical and plumbing components.
Means and Methods for Phase IB • Phase IB soft-strip/interior gut operations shall start at the top of the building and proceed downward. A minimum buffer zone of one floor shall be maintained between Phase IA and Phase IB work at all times. • The interior soft strip/interior gut work will be done on two floors at a time using diesel-powered equipment compliant with environmental and safety regulations/standards including, but not limited to the Coordinated Construction Act for Lower Manhattan. • Water will be used to provide dust control on each floor during this phase of the work. • Deconstruction debris shall be chuted from upper floors past lower floors on which Phase IA activities are occurring.
Tower Crane and Hoist • Necessary for material and personnel movement during Phase I. • Tower Crane will be located at the northwest corner. • Hoist will be located at the mid-south side on Albany Street. • Pre-cleaning as necessary will be done at attachment points.
Protective Measures Waste Sampling –(Section 1) • Classify the waste streams that will be generated as part of the deconstruction project and identify proper handling, packaging, labeling, transportation, and disposal methods. • Utilize existing data to determine sampling program; • Collect additional samples of materials in place; • Sampling results to determine personnel, handling, movement, packaging, transport and disposal requirements. • Any determined hazardous waste will be properly segregated; • Hazardous waste will not be chuted; and • Containers will be secured at all times when not being loaded and be clearly labeled.
Protective Measures Cont. Air Monitoring-(Section 2) Four levels of monitoring established: • Personnel air monitoring • Inside building/proximate work activities • Outside building within site boundaries • Outside site boundaries in immediate surrounding community
Protective Measures Cont. Air Monitoring-(Section 2) Section 2 of the Deconstruction Plan outlines level four of the program: • Utilizing meteorological instrumentation to record wind speed, wind direction and other pertinent conditions; • Conducting real-time monitoring for potential off-site migration of emissions using continuous direct read ambient air monitors; and • Conducting integrated air sampling for the following target compounds: Particulates as Total Suspended Particulates (TSP), metals as TSP, asbestos, silica, mercury, PAH's (polyaromatic hydrocarbons) Dioxins & Furans (D/Fs), and PCBs.
Protective Measures Cont. LMDC Proposed Enhanced Exterior Air Monitoring Approach (on-line at www.renewnyc.com) • To be modified to ensure program is complementary and allows for QA/QC of Section 2 • Proposal includes: • Additional sampling locations at various elevations (i.e. ground level, rooftops and setbacks) • Co-located sampling locations for QA/QC purposes • Daily real-time monitoring component • Enhanced analyte list including COPC list • Project and public notification protocol • Continued submission of results to NYCDEP • Continued public access to air results via LMDC website
Emergency Action Plan (EAP) • Designates appropriate personnel responsible for implementation and monitoring of emergency procedures. • Applies to all contractors working on-site including employees and visitors. • Gilbane Emergency Coordinator – John Graves, licensed New York City Site Safety Manager –Liaison to the First Responder agencies throughout the duration of the project. • All prime subcontractors will identify an OSHA certified Emergency Coordinator, responsible for the performance of emergency preparedness responsibilities. • Plan will be revised as necessary during the course of the project.
Emergency Action Plan Cont. EAP includes: • Pre- Emergency Planning Activities • Prior to commencement of work, Gilbane Emergency Coordinator and the LMDC will meet with the FDNY, NYPD, OEM, and Battery Park City Certified Emergency Response Team (CERT) to discuss: • Emergency Response Activities, • Agencies roles and responsibilities, and • To confirm an understanding of the existing building conditions. • Throughout deconstruction activities the Gilbane Emergency Coordinator will conduct regular emergency preparedness meetings with on-site personnel.
Emergency Action Plan Cont. • The EAP also includes protocol for building evacuation: • Emergency Response Communication Chart • Emergency Contact Numbers for Local Authorities • Evacuation Assembly Area • Community Notification
Community Emergency Action Plan • Pre-Emergency Planning Activities • LMDC will meet with Emergency Response Agencies, local hospital, and the surrounding Community prior to commencement of work. • LMDC will notify surrounding building landlords and superintendents of deconstruction activities and EAP. • LMDC will arrange for the Gilbane Emergency Coordinator to meet with the Community as necessary.
Community Emergency Action Plan Cont. • In the event of any emergency necessitating immediate community action, LMDC will rely on the Emergency Response Agencies protocol for informing the community of necessary actions and impacts during the event. • In the event of incidents impacting the community: • LMDC will activate the phone tree that was established with area neighbor volunteers in October 2004. • LMDC will send an email update regarding particular incidents. • LMDC will post flyers in neighboring buildings identifying the actions that were taken. • LMDC will host briefings to discuss the incident and measures taken in response to the incident.
Health and Safety Plan (HASP) • Presents the safety procedures and practices to be followed during all Phase I site activities to: • Ensure safe completion of tasks • Ensure prevention of occupational injuries and exposures to chemical, physical and biological hazards to workers at the Site; and • Ensure compliance with all applicable government agencies and regulations, including requirements established by: OSHA; NIOSH; USEPA; NYSDEC; NYCDEP; NYSDOL, and the City of New York. • All on-site Contractor and Subcontractor personnel are required to strictly comply with the provisions of the HASP. • This HASP is based upon current knowledge of conditions at the Site and shall be updated as new information becomes available and/or conditions change within the Building.
Health and Safety Plan Cont. The HASP Outlines: • Engineering Controls • Personal Protective Equipment and decontamination requirements • Potential physical hazards • Chemical hazards
Coordinated Construction Act • LMDC will comply with all regulations dictated by the Coordinated Construction Act, including but not limited to: • The use of Ultra Low-Sulfur diesel fuel; • Hours of operation; and • Pre-planned truck routes
Proposed Truck Routes-Phase I • LMDC developing plan with NYC DOT, NYS DOT, Port Authority of New York and New Jersey. • Proposing the use of Washington Street for access to the loading dock and the north plaza area. • Proposing the use of Albany Street for access to the Hoist.
Next Steps • Public outreach • Submission of plan to regulators • Submission of plan amendments as required by regulators • Submission of permit applications • Approval of plan • Mobilization at site
Opportunities for Public Involvement • E-Updates • Public Information Sessions • Comment through the LMDC Website • Community Board One meetings