EPA memo re: asbestos assessment and Superfund advantages, Jan 2002

NYC 9/11 Public Portal Document

Upholsteredfurniture, drapes, vents and ducts not addressed by NYC recommendations

The NYC DOH recommendations also do not address the problem of upholstered furniture, which is almost impossible to effectively clean. Draperies are another problem, often too large for washing in madiines, and some must be dry cleaned. Therefore, cross-contamination will occur if these drapes are sent to commercial facilities for cleaning.

The NYC DOH also does not address the problem of contaminated duct work, or air conditioners or other contaminated equipment, like the insides of computers which use cooling fans.

Any EPA recommendation of professional asbestos abatement not enforceable

EPA officials have claimed they recommended professional asbestos abatement for buildings “unless they only had a light dusting.”^’ Even if EPA has issued such guidance^ it will not result in effective asbestos removal, because EPA has no legal authority to enforce the use of certified asbestos abatement contractors. The EPA has stated that it is using the AHERA statute as the authority or standard for cleanup after the WTC disaster. This statute only requires schools to use certified asbestos abatement professionals. For the owners of buildings, the only requirement is that if the owner does choose to have an asbestos inspection, then a certified professional must be used. It does not require that any advice or action resulting from that inspection be followed. The owners of many buildings have not been hiring certified asbestos abatement profesaonals, even when they were heavily contaminated.^®

For tenants, the AHERA has no effect whatsoever. Many, if not most, tenants have been cleaning their own apartments.^’

High cost of professional abatement probibitive to most, preventing effective cleanup

Because professional asbestos abatement is expensive, tenants have chosen to perform their own cleanups or hire unqualified persons. For a 2 bedroom apartment, the cost of professional abatement is $5000; for a 2 bedroom apartment, the cost is around $10,000. That would not include the costs of replacement of any carpeting, upholstered furniture, or draperies that cannot be effectively cleaned.

Recently, Bonnie Bellow of the EPA Region 2 press office claimed that tenants do not have to pay for their cleanups; that all they have to do is apply to the Federal Emergency Management

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