EPA memorandum regarding asbestos reservoir, June 2002

NYC 9/11 Public Portal Document

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TABLE 1. Hudson St carpet: levels of asbestos found using EPA’s ultrasonication test method Data from the New York Environmental Law and Justice Project?' Samples taken on May 29, 2002

Building has no forced air heating and cooling that would redistribute asbestos asbestos structures from common areas to apartments, or from apartment to apartment. per square centimeter (s/cm^)

Carpet from roof, no special cleaning since 9/11. No visible dust on carpet. 624,717 Indoor-outdoor carpeting on deck on roof.

Carpet from 1 floor hall, no special cleaning since 9/11. Sample taken 4 to 5 645,200 feet from front door. No visible dust or discoloration for different areas of carpet (such as higher dirt levels in high traffic center of carpet).

Carpet from V’floor hall by bicycle rack, no special cleaning since 9/11. No 329,427 visible dust or difference in discoloration between carpet areas.

Carpet from 10® floor hall, no special cleaning since 9/1. No visible dust or 65,202 difference in discoloration between carpet areas.

Carpet from inside 9“’ floor apartment, mat which had been HEPA vacuumed. less than 15,788 (Does not moan that HEPA vacuuming removed asbestos. Probably not that contaminated to begin with, since windows not open, not facing WTC, and no central forced air in building to re-distribute asbestos.)

The EPA tested dust lying on the street 2 blocks south of this building, and found asbestos on September 11.'^ The asbestos was less than 1% using the polarized light microscopy (PLM) method, but definitely present in the dust. EPA did not test any outdoor sites closer to the building, or immediately to the north. The PLM method used by EPA was a major problem in determining the actual levels of asbestos. If EPA had used TEM tests instead, the asbestos levels could have been many times over 1% near the Hudson St. apartment building.'^

The asbestos levels in the carpet at the Hudson St. address, more than 8 months after 9/11, can be compared to carpet that was known to be more heavily contaminated. A building near Ground Zero''* had a dust layer over 1 inches thick on surfaces, including carpet. The first abatement only involved dry HEPA vacuuming of the carpet. This carpet was tested after HEPA vacuuming by the ASTM 5755 microvacuum method and found to have over 300,000 s/cm^. If the EPA ultrasonication method had been used, the level for the previously HEPA vacuumed carpet could have been as high as 30 million s/cm^. Thus, the levels in the carpet at the Hudson St. building are probably not be as high as carpets that had thick layers of WTC dust. However, the carpet levels in the Hudson St. building are highly significant, as can be seen from a later section in this memo on comparing dust levels and health risks.

I would be highly interested in any carpet ultrasonication test results from New York City, and any other related tests such as ASTM microvacuum analyses of the same carpet. The exact address of the building, names of occupants, etc. are not necessary.

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