NYC 9/11 Public Portal Document
HUDSON RIVER MANAGEMENT LLC
40 HARRISON STREET, NEW YORK, N. Y. 10013 • (212) 962-3530 • Fax (212) 571-5663
January 8, 2003
New York City Department of Environmental Protection
59-17 Junction Boulevard
Flushing, NY 11312
Attn. Arlene Anderson Re: Independence Plaza North (IPN)
310 Greenwich Street, Carpet Removal
Dear Ms. Anderson:
As you knov., in October 2001, II'N Management contracted with Commercial Lab
Enterprises to conduct air tests for the presence of asbestos in our public corridors and to
use the TEM protocol to analyze the samples. One floor, the 32nd floor corridor at the 310
Greenwich Street building, initially showed the presence of asbestos on 10.19.01. The area
was HEPA vacuumed and the walls washed down. Subsequent re-testing and TEM analysis
conducted on 10.24.01 revealed that there was no airborne asbestos in the corridor. Copies of
the complete test results were sent to your Agency, the NYC Department of Health and the
Independence Plaza North Tenant Association (IPNTA).
In August 2002, the IPNTA contracted with its own testing firm to conduct asbestos testing
and analysis of the 32nd floor carpet. The results, which were sent to Commissioner Ward of
your Agency on 12.15.02 (courtesy copy enclosed), indicated the presence of 1.3 million
asbestos structures per square centimeter in the carpet (not airborne).
Although the DEP is completely responsible for the proper cleaning and testing of the
building's common areas, Management is concerned about the huge discrepancy between
our tests and analysis results (utilizing TEM technology), and the IPNTA tests/analysis,
using the ultrasonification methodology.
Acccordingh-, Management respectfully requests that the DEP test and analyze the airborne
particles in the 32nd floor hallway prior to removing the corridor carpet. If your tests indicate
the presence of asbestos in excess of the permissible level, please confirm that the carpet will
be removed in accordance with DEP's protocols for ACM.
V ry truly yours,
Deborah Dolan
Manager
Enc.
C:c': Harold Cohn, Darane Street Associates•
Harvey Cohn, Hudson River .11anagement.LLC
Diane Lapson, 1P\TA Environmental Committee
Patricia Dillon, 11W
, 7A Environmental Committee
Kathryn E. Freed IP\TA Environmental Committer
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