Asbestos bulk sample analysis summary, 225 Liberty Street, 2001-2002

NYC 9/11 Public Portal Document

GPS Environmental Consultants, Inc.

A GPS NYC Asbestos Investigator collected fourteen bulk samples of gross debris on September 19, 2001 from representative locations within the building to assess the amount of asbestos contamination resulting from the event. Analyses indicated that asbestos containing materials were detected in bulk samples collected from the debris. Based upon these results and in an effort to protect the health and safety of people involved in the cleanup project and to obtain a building acceptable for re-occupancy, a licensed asbestos abatement contractor, using certified asbestos handlers was employed by Merrill Lynch to clean the entire building using asbestos specific procedures.

The cleanup project was divided into three phases with the first phase, Phase I, beginning on September 24, 2001. The final phase, Phase III, was completed and final air sampling collection completed on January 21, 2002.

Phase I cleanup operations were performed by Pinnacle Environmental Corporation throughout the building in conformance with acceptable asbestos work practices.

Phase II fine cleaning operations were performed by BMS Castrophe utilizing asbestos abatement handlers for cleaning operations.

The HVAC duct system was separately assessed for asbestos and lead contamination by Tri Dim Corporation on October 19, 2001. Samples were collected from the HVAC duct system on the C levels, 3rd and 9`" floors and analyzed for asbestos and lead content. No asbestos or lead was detected in the areas tested, although visual inspection indicated that the system was contaminated with fine particles. The particulate content was above the NADCA Standard Level of Cleanliness in 29 of 33 areas tested. A HVAC duct cleaning company was employed by Merrill Lynch to clean the HVAC system from the C levels through the 22°d floor. HVAC cleaning was performed by KASCO using certified asbestos workers. The cleaning procedures are outlined in section 3.0. A separate closeout report was issued by Kasco.

3.0 Abatement and Cleanup Activities

A NYC Investigator collected 14 bulk samples from representative floors on the east side of the facility where windows were broken and bulk/gross debris was observed. The samples were analyzed using the PLM, (polarized light Microscopy) analytical technique. Three Samples on three separate floors had results of asbestos present in amounts greater than 1%. Based on these results all bulk/gross material was treated as asbestos containing material, (ACM). The east side of facility from the street level through floor 22 was most heavily damaged with many broken windows and large amounts of debris. Floor 23 and above exhibited much less damage having fewer broken windows.

Merrill Lynch, World Financial Center, South Tower, 225 Liberty Street, Neiv York, NY Page 2

NYC-WTC 000097298