Contamination Control Engineering, Inc.

Our staff performed an integral role in the WTC Disaster Recovery Project.  Due to our staff's unique experience of working for various City of New York Inspector General offices and its familiarity with our work, we were afforded the opportunity of providing the City of New York, Department of Investigation (NYC-DOI) with site-wide, environmental integrity monitoring services during the WTC Disaster Recovery Project.  

 

Due to the magnitude of the project, the site was sub-divided into four (4) quadrants. Each quadrant was managed by a separate construction management (CM) firm to which four (4) separate Integrity Monitor (IM), Independent Private Sector Inspector General (IPSIG) investigative firms were assigned.  The environmental segment of the IM program encompassed all four (4) quadrants and their immediate perimeters.  Our firm was chosen to perform this work in all four (4) quadrants (site-wide), as a result of past experience and a proven track record of integrity, forensic background, cost effectiveness, industrial hygiene competence and environmental knowledge.  

 

Our firm had personnel stationed at the “Ground Zero” site for seven (7) months for the on-site field investigation work.  Our field work activities included field inspections of: contractor and consultant compliance with Federal, State, Local regulatory requirements; contractor and consultant work activities with respect to industrial hygiene compliance; time and material observations for establishment of actual labor and material utilized for comparison with invoices submitted by the contractors and consultants; identification of potential improprieties leading to  fraud investigations; and providing periodic updates on the overall performance on the project.  

In the early 1990s, at the direction of the SCA Office of the Inspector General, in coordination with Senior Management of the SCA, I&EH established and implemented an internal Integrity Monitoring and Operations Support Program (OSP).  As part of the OSP, CCE was tasked with; conducting the assessment of operations systems; identification of actual, potential and perceived risks; development of risk mitigation strategies; assisting with mitigation of risks; and oversight of implemented risk mitigations strategies.  As part of these efforts, CCE was often engaged in various special assignments, many of which were sensitive and confidential in nature.  Further, CCE was tasked with assisting the I&EH with developing and implementing internal and external Quality Assurance program focused on the environmental work being performed by SCA I&EH industrial hygiene personnel and outside consultants and contractors.

 

The OSP is broad, diverse and continually evolving to complement daily operations and is designed to meet current and anticipated future demands. During the course of the dynamic, day-to-day responsibilities, the OSP augments and reinforces various aspects of the ever-demanding facility operations with the intent of maintaining, analyzing and improving I&EH operations relative to consultant and contractor compliance. OSP efforts were designed to monitor internal management procedures and staff supervised activities to develop and implement policies that maximize efficiency and minimize waste while maintaining program integrity.

 

The program's objectives also included QA initiatives, efficiency management, liability control measures through operational procedures, technical and operational support, in-house staff training, program monitoring, cost analysis and assistance with various specialized aspects of the operations.

In May of 2011 our staff completed its 4 1/2-year term assignment on the reconstruction of the WTC.   This engagement entailed a multi-dimensional review of all environmental aspects of the work including: the identification and assessment of potential project integrity risks; the development of risk mitigation strategies; the oversight of risk mitigation program; the evaluation of program compliance; and consultation and routine reporting of same to the Client through collaborative meetings with the IPSIG IM project Team.  

 

At the inception of the project, in collaboration with Thacher Associates, LLC, our staff was tasked with the development of comprehensive analysis of potential environmental risks associated with the scheduled work for the reconstruction of the World Trade Center site.  In this capacity, we reviewed existing Federal, City and Lower Manhattan Developmental Corporation's (LMDC’s) agreements as well as the applicable Port Authority policies, contracts, etc.  We also interviewed key personnel and developed an environmental project integrity risk matrix.  From the assessment and the risk matrix, a risk mitigation strategy and monitoring program was developed, and implemented throughout our tenure on the project.  Specifically, the assignment was to review and analyze all aspects of policies, procedures and deliverables for the work, including the work of the construction management firms, consultants, general contractors and their sub-contractors and vendors, as well as the programs developed in conjunction with and for the Port Authority of New York and New Jersey.  As a part of the Thacher Team, we worked for and reported to the PANYNJ Office of the Inspector General.  

 

A significant element of the program was the review and comments related to the development of the site specific Soil Management Plan (SMP).   The SMP included site soil assessment and classification; delineation of materials and excavation by sector, procedures for loading and transporting the materials; procedures for dust suppression/control; procedures for sediment control and wash operations; procedures for disposal (including vetting of various disposal sites and review of disposal site controls), manifesting and tracking of approximately one million tons of soil.  

 

Another significant element of the program included evaluating and monitoring project compliance policies related to Environmental Performance Commitments (EPC’s).  These EPCs were negotiated and agreed upon by all parties as part of the Environmental Impact Statement (EIS) process.  The EPC’s included Air Quality (dust control, low sulfur fuel and the mandated diesel particulate filter); noise and vibration control; cultural and historic resources protection; sustainable environmental design; construction waste water and storm water management; and hazardous materials management. 

CCE was contracted by NYCHA to provide expert Consultation Services to assist in Program Management of Lead Based Paint issues regarding Construction Plans, Master Specifications, Protocols, Standard Operating Procedures and Processing, including prioritization of remediation efforts, request for Pre-Qualifications for procurement including lead-based paint and other hazardous building material remediation (i.e., mold, etc.), Operating Program enhancements - constructing program plans, specifications, protocols, standard operating procedures and processes, program implementation, Documentation Control, and Quality Assurance organizational structure.

 

For this engagement, fortified by more than 30 years of multifaceted experience in performing services identical in scope, size, and complexity, CCE assembled a team of environmental, regulatory, contractual, analytical and risk mitigation experts, with extensive background and proven history, tailored to the expressed Contract requirements.   

 

Upon engagement, CCE was directed to immediately procure a team of analysts to process the approximately 30,000 reports from NYCHA’s early versions (“Legacy”) of LBP inspection records.  Within two (2) weeks, the ~30,000 count of documents slated for CCE’s analysis was reduced to ~20,000 documents, through internal investigation and reconciliation.  Subsequently, while the operational systems were being built, CCE was directed to analyze and report on the approximately 20,000 remaining vintage (“Legacy”) documents submitted by vendors in strict compliance with vendors’ Contracts, regulatory framework, industry standards, HPD and NYCHA’s policies and procedures.  To that end, CCE; 

1. Reviewed and analyzed vendors’ Contract requirements 

2. Developed a list of requirements in consideration of regulatory framework, HPD requirements and NYCHA policies and procedures

3. Built a Standard Operations Procedure focused on reports review 

4. Developed a standardized reports review checklist

5. Managed Analysts the review protocol and reporting

6. Developed tracking mechanisms with statistical analysis of findings

7. Developed reporting format to NYCHA, based on Client needs and preferences 

Once the Legacy portion of the Program analysis was nearing completion, at NYCHA’s request, CCE assisted with moving the Legacy program to NYCHA’s internal SharePoint system. Subsequently the LBP Program shifted to non-legacy XRF program analysis, and continued using the SharePoint system, for which CCE provided analysts and direct CCE’s analysts’ supervision only, in coordination with NYCHA’s internal global systems management.  

 

As a result of the Healthy Homes engagement, in addition to reconciliation of the more than 30,0000 reports, CCE has developed for NYCHA templates, checklists, specifications and SOPs.  CCE has also engaged with NYCHA vendors regarding the aforementioned documents and QA of same.  Finally, CCE has prepared programs for quality oversight for the Healthy Homes environmental program, including QA field inspections.