A View of the World Trade Center Site from the Hudson River.
130 Liberty Street
130 Liberty Street Variances
Variances
As an important step in responding to the January 31, 2005 Regulator Comments submitted to the LMDC on the draft Phase I Deconstruction Plan, the LMDC submitted a Request for Variance to the New York State Department of Labor (NYSDOL) on April 11, 2005. Submitting the Request for Variance to NYSDOL was an important step forward as it allowed the LMDC to finalize the revisions to the Deconstruction Plan in response to the comments received. The revised Deconstruction Plan was submitted to the regulators on June 15, 2005 for their review and approval. The LMDC currently anticipates work on Phase I activities beginning this summer.
The Request for Variance implements many of the requirements contained in the Regulator Comments. For example, as required by the Regulators, the LMDC will complete all work in Phase I in compliance with New York State Industrial Code Rule (ICR) 56. The draft Phase I Deconstruction Plan originally proposed that the cleaning and interior gut work would be performed in separate phases, Phase IA and Phase IB. However, as directed by the regulatory agencies the LMDC will now perform all cleaning and interior gut work under the same protective measures required for asbestos abatement that were previously outlined only for Phase IA.
As required by the regulators, all of Phase I will now include negative pressure containment, use of personal protective equipment, and air monitoring that will be in effect for the deconstruction project until all asbestos, including all World Trade Center dust containing asbestos and other contaminants of potential concern, are properly cleaned and removed. The Request for Variance summarizes and explains why Phase I of the Deconstruction requires modification of specified portions of ICR 56 and how alternative abatement approaches will be used to make the most of unique opportunities and to overcome logistical challenges presented by the 130 Liberty building. To view ICR 56 click here.
LMDC, its contractors and consultants are committed to compliance with applicable laws throughout the cleaning and deconstruction of the building. Accordingly, the Request for Variance complies with applicable federal, state and local law. To ensure such compliance, the proposed cleanup and abatement (i) will not expose the general public to asbestos, (ii) will minimize worker exposure to asbestos through the use of appropriate controls and personal protective equipment, (iii) will minimize adverse impacts to the community, (iv) will address the practical operational opportunities and challenges provided by the Building, and (v) will prepare the building for exterior cleaning, abatement and demolition to be conducted during Phase II.
Since the submission of the initial Request for Variance in April, 2005, official correspondence regarding that request and subsequent Variance requests has been ongoing. All documents related to Variance Requests and other permit applications and approvals are available for public review upon request.
