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Region 2 Enforcement & Compliance Assurance Division Air Compliance Branch CAA Inspection Report Inspection Date: Facility Name: Facility Address: ICIS ID #: EPA Lead Inspector: EPA Asst. Inspector: Facility Contact: Facility Contact: 3/14/2025 Gouverneur Gardens 305 Madison St, New York, NY 10002 3601664213 Christopher Collins Victor Tu Qasim Lezama, qlezama@prestigemgt.com Mo Diop, mad@dbiprojects.com I. Background Gouverneur Gardens Housing Corporation ("Gouverneur Gardens") according to its website, is a Mitchell-Lama Co-Op that "was built in the early 1960's for the benefit of New Yorkers with low to middle incomes." The CoOp consists of six buildings. On May 14, 2024, the EPA inspected 605 Water Street ("Building #4") at the Gouverneur Gardens Co-Op. At that time, the emergency cleanup of 30 apartments was completed, however, the cleanup of the janitor closets had not begun. On May 14, 2024, EPA Inspectors noted that some apartment walls remained open with exposed piping and insulation. Outside the building, EPA Inspectors also found dry asbestos containing pipe insulation in a waste container. On May 30, 2024, EPA Inspectors conducted another brief inspection followed by a meeting with DBI and Prestige to explain the asbestos sampling results of the waste container, and to discuss the NESHAP regulations. II. Pertinent Regulatory Requirements 40 CFR Part 61 Subpart M - Asbestos NESHAPs III. Summary of Onsite Observations On March 14, 2025, Victor Tu and Christopher Collins ("EPA Inspectors") conducted an inspection based on a complaint about on-going abatement work in an apartment at 605 Water Street (Building #4). At 10:22 AM, EPA Inspectors arrived at the management office for Gouverneur Gardens (located at 305 Madison St, New York, NY 10002). EPA Inspectors presented their credentials and explained the scope of the inspection, which was to observe asbestos abatement activities being conducted at Building #4. EPA Inspectors Gouverneur Gardens - 3601664213 1 3/14/2025 were accompanied by Donny Figueroa, the superintendent of Building #4. When EPA Inspectors arrived at Building #4, they met with Cesar Tello (Certified Asbestos Supervisor) and Alfonso Serrano (Certified Asbestos Worker) from Advanced DRI (the asbestos abatement company, "DRI"), and Kwasi A. Serrano (Certified Asbestos Air Monitor) from Amiantos (the air monitoring company, "Amiantos"). Inspectors took photos of their identification cards. At the time of arrival, both companies were preparing for an asbestos abatement job. Amiantos had established three air monitors for work: one at the air lock (the controlled entrance to the containment area), the decon (the decontamination chamber where workers clean equipment and remove protective gear), and the exhaust (where filtered air is discharged from the containment area). Six additional monitors were set up to measure background levels. EPA Inspectors examined the area where abatement work will be conducted. The abatement would be performed in the wall behind the bathroom. EPA Inspectors observed the back of the (see Figure 1) and the asbestos insulation on the pipes (see Figure 2). There was also an adjacent closet where asbestos insulation was scheduled for abatement (see Figures 3 and 4). Gouverneur Gardens - 3601664213 2 3/14/2025 Figure 1: Back of the decon. Note the resident's belongings behind. Figure 2: Cavity where asbestos abatement will occur, in the wall behind the bathroom. Note the insulation on the right of the cavity, in the middle of the photo. Gouverneur Gardens - 3601664213 3 3/14/2025 Figure 3: Second pipe insulation planned for abatement, in the closet next to the cavity from Figure 2. Figure 4: Outside of the closet noted in Figure 3. EPA Inspectors inquired about the waste bags for the abatement. DRI showed EPA Inspectors the black bags that would be used for disposal (see Figure 5). Gouverneur Gardens - 3601664213 4 3/14/2025 Figure 5: Black asbestos waste bag. EPA Inspectors also inquired about the waste labels for the bags. The DRI supervisor searched for the labels, and subsequently went to retrieve them from his vehicle (see Figure 6). Gouverneur Gardens - 3601664213 5 3/14/2025 Figure 6: Pre-generated labels for ACWM bag. Multiple labels are printed on standard printing paper. These labels were observed to be on printer paper. DRI stated that they used spray on adhesive to attach the information to the bags. DRI also explained that all materials would be disposed off as Asbestos Containing Waste Material (ACWM) including the plastic sheets. When asked about the waste disposal process, DRI explained that the bags containing the ACWM would be left in the decon area until a transporter company would be called for pickup. EPA Inspectors did not see any other openings in the apartment other than the one that was being worked on. DRI showed the EPA Inspectors the Tyvek suits and filters that were available for their workers. EPA Inspectors confirmed that there appeared to be enough for the job. While outside in the hallway, EPA Inspectors observed asbestos notices were posted in English, Spanish, and Chinese on the hallway bulletin Board (Figures 7 and 8). Gouverneur Gardens - 3601664213 6 3/14/2025 Figure 7: Notification posted to inform residents of the asbestos abatement that is the subject of this inspection (in English and Spanish). Figure 8: Notification posted to inform residents of the asbestos abatement that is the subject of this inspection (in Chinese). Older notifications for work that was performed in the Janitor Closet/Slop Sinks were also posted. EPA Inspectors observed a notice of the current abatement project posted adjacent to the elevator. The same notice was posted inside the elevators. According to DRI, these notices were also posted on every floor. EPA Inspectors requested records of all air monitoring data that were conducted during the abatement of all eight apartments involved in this current project and the cleanup/abatement performed at the Janitor Closet/Slop Sinks. Mr. Le Maitre of Amiantos agreed to provide the requested data. EPA Inspectors reviewed the on-site work logs for Amiantos and DRI, and per the representative's request, signed in on the logbook. EPA Inspectors then left the work area for lunch and told the DRI representative that they will return later to observe the complete setup. EPA Inspectors photographed all the asbestos work-related documents posted at the front of the building. They also observed and photographed the waste container where EPA inspectors found ACM during the first inspections. EPA Inspectors returned from lunch and met with Qasim Lezama, General Manager for Prestige ("Prestige"). EPA Inspectors provided a debrief of observations from the first portion of the inspection and noted that there were clear improvements since the previous inspections. They explained how complaints had been received, particularly regarding the current abatement work. Gouverneur Gardens - 3601664213 7 3/14/2025 Mr. Lezama explained that despite Prestige and DBIs' (the project manager, "DBI") attempts to explain and provide information, residents continue to complain. Prestige stated that they communicated via email, posted notices, and held in-person meetings to provide the necessary information about the work to the residents. EPA Inspectors requested copies of correspondences sent to residents. When asked about planned renovations at the facility, Prestige indicated that this abatement work is the final step towards lifting the stop work order. After the stop work order is lifted, they would close the walls and end the portion of the project intended for this building. It was mentioned that there was sufficient budget for another building, but those plans were uncertain. EPA Inspectors requested to see the Janitor Closet/Slop Sinks in Building #4 because access to the rooms were not provided in the morning. Mr. Lezama contacted the Superintendent about it and granted access to EPA Inspectors. EPA Inspectors returned to Building #4 to examine the Janitor Closet/Slop Sinks. A maintenance worker informed EPA Inspectors on arrival that he had left the Janitor Closet/Slop Sink doors open on all the floors. Starting on the fifth floor, EPA Inspectors found the Janitor Closet/Slop Sink door locked and closed. On the fourth floor, the door to the Janitor Closet/Slop Sink was unlocked. EPA inspector opened the door and saw some debris scattered on the floor, and a plastic sheet covering the hole in the wall of the Janitor Closet/Slop Sink (Figures 9 and 10). The debris appears to be sheetrock and not the corrugated asbestos insulation. Gouverneur Gardens - 3601664213 8 3/14/2025 Figure 9: Plastic sheet observed covering the cavity where asbestos abatement was done previously. Janitor Closet/Slop Sink, fourth floor. Figure 10: Debris on floor in Janitor Closet/Slop Sink, fourth Floor. EPA Inspectors photographed the pipes behind the wall cover (Figure 11). There was no more asbestos pipe insulation behind the covering. Gouverneur Gardens - 3601664213 9 3/14/2025 Figure 11: Pipe in wall cavity after asbestos abatement. Janitor Closet/Slop Sink, fourth floor. On the third floor, inspectors did not observe a lot of debris on the floor. No insulation was visible behind the cardboard cover (Figures 12 and 13). Gouverneur Gardens - 3601664213 10 3/14/2025 Figure 12: Third floor Janitor Closet/Slop Sink. Note the lack of debris on the floor. Figure 13: Cardboard cover for wall cavity in Janitor Closet/Slop Sink on the third floor. The cover had fallen prior to EPA Inspectors arriving to observe. Note the pipes in the cavity are free of insulation. On the second floor, Inspectors observed a paper like material on the top left-hand corner of the open wall in the back of the Janitor Closet/Slop Sink area (Figure 14). Gouverneur Gardens - 3601664213 11 3/14/2025 Figure 14: Pipe in second floor Janitor Closet/Slop Sink. Annotated is the paper material observed by EPA Inspectors. EPA Inspectors went back to the apartment where preparation for ongoing abatement work was occuring. EPA Inspectors examined the setup. (See figure 15, 16, and 17). The enclosure and the ventilation appeared to be correctly setup, and the HEPA filter appeared to be operational at the time of the inspection. Gouverneur Gardens - 3601664213 12 3/14/2025 Figure 15: Outside edge of work area, and exhaust piping. Figure 16: Exhaust piping leading to open air outside of the apartment. Gouverneur Gardens - 3601664213 13 3/14/2025 Figure 17: Air scrubber used in asbestos abatement. Air scrubber is used to filter out particulates before exhausting outside. Figure 18: Back (exit) of the decon area. EPA Inspectors inquired about the paper-like material photographed in Photo #62. The DRI representative explained that it was non-asbestos paper material wrapping the pipe in the area between the two floors. DRI removed a piece of paper and stated that EPA Inspectors are welcome to test the material to confirm it was not asbestos. EPA Inspectors took this piece of paper like material and placed it in a bag (Sample #1, "GG-001") at 1:51 PM. Gouverneur Gardens - 3601664213 14 3/14/2025 Figure 19: Sample GG001, paper material observed in Figure 14. The inspection concluded at approximately 1:54 PM. IV. Photo Log PHOT O # 01 TIM E 10:36 AM PHOTO DESCRIPTION State of New York - Department of Labor Asbestos Certificate Cesar Tello Supervisor Gouverneur Gardens - 3601664213 15 3/14/2025 02 10:37 AM 03 10:41 AM 04 10:44 AM State of New York - Department of Labor Asbestos Certificate Alfonso Serrano Worker State of New York - Department of Labor Asbestos Certificate Kwasi A Le Maitre Air Monitor Air Monitor and Decon. Decon is labeled Danger Asbestos and Caution. In the background there are the personal effects of the residents. Gouverneur Gardens - 3601664213 16 3/14/2025 05 10:50 AM Temporary barrier pulled back to reveal pipe insulation that is to be removed during the abatement that is the subject of this inspection. Located on the other side of the bathroom wall, in the hallway. Gouverneur Gardens - 3601664213 17 3/14/2025 06 10:52 AM Additional asbestos abatement to be removed. Located to the left of Photo #05, near the closet. Gouverneur Gardens - 3601664213 18 3/14/2025 07 10:52 AM Closet and site noted in Photo #06. 08 10:54 AM Black asbestos waste bag. This one of the bags that will be used for the waste in this project. Gouverneur Gardens - 3601664213 19 3/14/2025 09 10:55 AM 10 10:59 AM 11 11:15 AM Repeat photo of #09, without flash. Pre-generated labels for asbestos waste bag. Printed on standard printer paper, non- adhesive. Courtesy notification to inform all residents at 605 Water Street that abatement work is scheduled for 3/14/25 (date of this inspection) inside unit 2F (location EPA observed). In English and Spanish. Posted on 2nd floor in hallway. Gouverneur Gardens - 3601664213 20 3/14/2025 12 11:17 AM Asbestos Abatement Notice ACP 13 For Janitor Closet/Slop Sink project, started 7/22/24. This asbestos abatement project was already finished by the time of this inspection. Posted on 2nd floor in hallway. Gouverneur Gardens - 3601664213 21 3/14/2025 13 11:17 AM Asbestos Abatement Notice ACP 13 (Photo #12), Page 2. Gouverneur Gardens - 3601664213 22 3/14/2025 14 11:18 AM Asbestos Abatement Notice ACP 13 (Photo #12), Page 3. Gouverneur Gardens - 3601664213 23 3/14/2025 15 11:18 AM Asbestos Abatement Notice ACP 13 (Photo #12), Page 4. Gouverneur Gardens - 3601664213 24 3/14/2025 16 11:19 AM Courtesy notification to inform all residents at 605 Water Street that abatement work is scheduled for 3/14/25 (date of this inspection) inside unit 2F (location EPA observed). In Chinese. Gouverneur Gardens - 3601664213 25 3/14/2025 17 11:19 AM Notice of Asbestos Abatement for Janitor Closet/Slop Sinks. Posted outside of the elevator on the second floor. Gouverneur Gardens - 3601664213 26 3/14/2025 18 11:34 AM Notice explaining to contractors that construction materials should only be transported in the designated elevators. Posted inside of the elevator. Gouverneur Gardens - 3601664213 27 3/14/2025 19 11:35 AM Asbestos Project Amendment Form (ACP 8). Amendment for ACP7 filed 1/7/25. Abatement Procedure listed as Emergency Cleanup, Tent. Posted on first floor. Page 1 Gouverneur Gardens - 3601664213 28 3/14/2025 20 11:35 AM Asbestos Project Amendment Form (ACP 8). Amendment for ACP7 filed 1/7/25. For the project that is the subject of this inspection, amendment for Floor 16 and Floor 2 work. Page 2 Gouverneur Gardens - 3601664213 29 3/14/2025 21 11:36 AM Building Owner's Letter of Authorization ACP7. Authorization for Advanced DRI to file asbestos project notifications. Authorization for Air Monitor Amiantos to conduct air monitoring. Posted on first floor. 22 11:36 AM Gouverneur Gardens - 3601664213 30 Asbestos Work Permit for Janitor Closet/Slop Sink project. Permit issuance date 7/22/24. Posted on first floor. Page 1 3/14/2025 23 11:36 AM 24 11:36 AM Asbestos Work Permit for Janitor Closet/Slop Sink project. Permit issuance date 7/22/24. Posted on first floor. Page 2. Asbestos Work Permit for Janitor Closet/Slop Sink project. Permit issuance date 7/22/24. Posted on first floor. Page 3. Gouverneur Gardens - 3601664213 31 3/14/2025 25 11:37 AM Asbestos Project Notification (ACP 7) for 8 apartments. Project start date 1/27/25. Posted on first floor. Page 1. Gouverneur Gardens - 3601664213 32 3/14/2025 26 11:37 AM Asbestos Project Notification (ACP 7) for 8 apartments. Project start date 1/27/25. Posted on first floor. Page 2 Gouverneur Gardens - 3601664213 33 3/14/2025 27 11:38 AM Asbestos Project Notification (ACP 7) for 8 apartments. Project start date 1/27/25 Posted on first floor. Page 3 Gouverneur Gardens - 3601664213 34 3/14/2025 28 11:38 AM Asbestos Project Notification (ACP 7) for 8 apartments. Project start date 1/27/25 Posted on first floor. Page 4 Gouverneur Gardens - 3601664213 35 3/14/2025 29 11:39 AM Left Column: Notice that apartments will be inspected by Amiantos for asbestos sampling. Amiantos Survey Protocol in English, Spanish, and Chinese. Right Column: Project Management Update stating that DEP has authorized the closing of the walls in 605 water street. Similar documents in Spanish and Chinese. Posted on first floor. Gouverneur Gardens - 3601664213 36 3/14/2025 30 11:41 AM Courtesy notification to inform all residents at 605 Water Street that abatement work is scheduled for 3/14/25 (date of this inspection) inside unit 2F (location EPA observed). In English. Posted on first floor. Gouverneur Gardens - 3601664213 37 3/14/2025 31 11:49 AM Asbestos Project Notification (ACP7) for Janitor Closet/Slop Sink asbestos abatement. Start date 5/7/24. Page 1. Posted on first floor. Gouverneur Gardens - 3601664213 38 3/14/2025 32 11:49 AM Asbestos Project Notification (ACP7) for Janitor Closet/Slop Sink asbestos abatement. Start date 5/7/24. Page 2. Posted on first floor. Gouverneur Gardens - 3601664213 39 3/14/2025 33 11:49 AM Asbestos Project Notification (ACP7) for Janitor Closet/Slop Sink asbestos abatement. Start date 5/7/24. Page 3. Posted on first floor. Gouverneur Gardens - 3601664213 40 3/14/2025 34 11:49 AM Asbestos Project Notification (ACP7) for Janitor Closet/Slop Sink asbestos abatement. Start date 5/7/24. Page 4. Posted on first floor. Gouverneur Gardens - 3601664213 41 3/14/2025 35 11:50 AM Asbestos Project Notification (ACP7) for Janitor Closet/Slop Sink asbestos abatement. Start date 5/7/24. Page 5. Posted on first floor. Gouverneur Gardens - 3601664213 42 3/14/2025 36 11:50 AM Asbestos Project Notification (ACP7) for Janitor Closet/Slop Sink asbestos abatement. Start date 5/7/24. Page 6. Posted on first floor. Gouverneur Gardens - 3601664213 43 3/14/2025 37 11:54 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 1. Posted on first floor. Gouverneur Gardens - 3601664213 44 3/14/2025 38 11:54 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 2. Posted on first floor. Gouverneur Gardens - 3601664213 45 3/14/2025 39 11:54 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 3. Posted on first floor. Gouverneur Gardens - 3601664213 46 3/14/2025 40 11:54 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 4. Posted on first floor. Gouverneur Gardens - 3601664213 47 3/14/2025 41 11:54 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 9. Posted on first floor. Gouverneur Gardens - 3601664213 48 3/14/2025 42 11:54 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 11. Posted on first floor. Gouverneur Gardens - 3601664213 49 3/14/2025 43 11:55 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 1. Posted on first floor. Gouverneur Gardens - 3601664213 50 3/14/2025 44 11:57 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 5. Posted on first floor. Gouverneur Gardens - 3601664213 51 3/14/2025 45 11:57 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 6. Posted on first floor. Gouverneur Gardens - 3601664213 52 3/14/2025 46 11:57 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 7. Posted on first floor. Gouverneur Gardens - 3601664213 53 3/14/2025 47 11:57 AM Asbestos Project Notification (ACP7) for 30 apartments. Start date 2/15/24. Page 8. Posted on first floor. Gouverneur Gardens - 3601664213 54 3/14/2025 48 11:58 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 2. Posted on first floor. Gouverneur Gardens - 3601664213 55 3/14/2025 49 11:58 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 3. Posted on first floor. Gouverneur Gardens - 3601664213 56 3/14/2025 50 11:58 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 4. Posted on first floor. Gouverneur Gardens - 3601664213 57 3/14/2025 51 11:59 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 6. Posted on first floor. Gouverneur Gardens - 3601664213 58 3/14/2025 52 11:59 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 7. Posted on first floor. Gouverneur Gardens - 3601664213 59 3/14/2025 53 11:59 AM Asbestos Abatement Notice (ACP13) for 30 apartments. Start date 2/15/24. Page 5. Posted on first floor. 54 12:04 PM Gouverneur Gardens - 3601664213 60 Waste container sampled during EPA's first inspection. Samples were found to be positive. Noted here covered up following EPA and NYC guidance. 3/14/2025 55 12:04 PM 56 1:32 PM Photo taken at a different angle for the same waste container as in Photo #55 Fourth Floor Janitor Closet/Slop Sink area. Plastic sheet covers the missing wall. Sheet ripped and hole open on the right side. Gouverneur Gardens - 3601664213 61 3/14/2025 57 1:32 PM Fourth Floor Janitor Closet/Slop Sink. Ground has debris. Gouverneur Gardens - 3601664213 62 3/14/2025 58 1:33 PM Fourth floor Janitor Closet/Slop Sink, behind sheet. Note lack of insulation. Gouverneur Gardens - 3601664213 63 3/14/2025 59 1:39 PM Third Floor Janitor Closet/Slop Sink. Wall cavity covered by cardboard. Square cut- out fallen when inspected. Inspectors could see the pipes behind, no insulation noted. Gouverneur Gardens - 3601664213 64 3/14/2025 60 1:39 PM Third floor Janitor Closet/Slop Sink. Ground lacked debris. Gouverneur Gardens - 3601664213 65 3/14/2025 61 1:42 PM Second floor Janitor Closet/Slop Sink. Wall cavity covered by cardboard. Gouverneur Gardens - 3601664213 66 3/14/2025 62 1:42 PM Second floor Janitor Closet/Slop Sink. Ground lacked debris. Gouverneur Gardens - 3601664213 67 3/14/2025 63 1:43 PM Behind second floor Janitor Closet/Slop Sink. Cardboard/paper material noted on pipe at space between floors. Gouverneur Gardens - 3601664213 68 3/14/2025 64 1:45 PM Exhaust pipe and back of work area enclosure. Gouverneur Gardens - 3601664213 69 3/14/2025 65 1:46 PM Exhaust pipe connected to exterior window. 66 1:47 PM Air scrubber for exhaust. Gouverneur Gardens - 3601664213 70 3/14/2025 67 1:47 PM Air monitor and decon exit area. Note personal effects of residents. 68 1:56 PM Sample GG-001. Sample was cardboard/paper material noted in Photo #63. Gouverneur Gardens - 3601664213 71 3/14/2025 Lead Inspector's Name: Christopher Collins CHRISTOPH CHRISTOPHER COLLINS Digitally signed by X ER COLLINS -04'00' Date: 2025.04.09 08:31:39 Lead Inspector Assisting Inspector's Name: Victor Tu Digitally signed by Tu, Tu, Victor Date: 2025.04.09 Victor X 09:23:33 -04'00' Assisting Inspector Supervisor's Name: Harish Patel HARISH X PATEL Digitally signed by HARISH PATEL Date: 2025.04.09 10:44:37 -04'00' Supervisor Gouverneur Gardens - 3601664213 72 3/14/2025