Letter regarding asbestos sampling at 106 Fulton Street, Feb 2002

NYC 9/11 Public Portal Document

CORPORATION Occupational Health, Safety & Environmental Consultants

February 25, 2002 Mr. R. Radhakrishnan, P.E. New York City Department of Environmental Protection Director, Asbestos Control Program 59-16 Junction Boulevard Corona, NY 11368-5107 Via Fax: 718.595.4422

Re: Pace University Property 106 Fulton Street, NY, NY

Dear Mr. Radhakrishnan,

Thank you for taking the time to talk with me on February 19, 2002 regarding your letter of February 17, 2002 (attached) that was issued to our client, Pace University. As I mentioned, the 106 Fulton Street building has been unoccupied since before September 11, 2001.

In response to your February 17th letter and in accordance with our conversation of February 19th, on February 19`t' a Colden Corporation NYC licensed asbestos investigator conducted a visual review of the exterior of 106 Fulton Street and collected ten bulk samples of dust from exterior surfaces. Samples were analyzed by Scientific Laboratories using Polarized Light Microscopy (PLM). Scientific Laboratories is an AIHA accredited and ELAP certified laboratory. A summary of the surfaces sampled and corresponding analytical results are presented below.

Sample ID Surface sampled Asbestos content in dust # 106-1 Roof — NW corner on parapet wall <1 % # 106-2 13°' floor exterior window ledge <1 % # 106-3 8 floor exterior window ledge <1 % # 106-4 8 floor exterior window ledge <1 % # 106-5 2" floor exterior window ledge <1 % # 106-6 Top of exterior construction elevator car <1 % # 106-7 15th floor exterior construction bridge <1 % # 106-8 10 floor exterior construction bridge <1 % # 106-9 7 floor exterior construction bridge <1 % # 106-10 4 floor exterior construction bridge <1 %

All sample analysis results are less than one-percent asbestos. Laboratory reports, chain of custody records and field data sheets in support of this data are attached.

It is our understanding that the City requires the building owner to remove accumulations of dust from exterior building surfaces. And, that asbestos handler licenses are not required for cleaning non-ACM dust, including dust reported to contain less than one-percent or trace asbestos as detected under PLM.

Robert Morris Building • 100 North 17th Street, 9th Floor • Philadelphia, PA 19103 Tel 215 496 9237 • Fax 215 496 9280 • Toll Free 800 586 5580 • www.colden.com

PT NYC-WTC 000104596