Fax cover sheet regarding Independence Plaza environmental data, Oct 2002

NYC 9/11 Public Portal Document

PH I IPNTA - Environmental Committee 40 Harrison Street I Pll i New York. NY 10013 (212) 473-5900 (work)' (212) 777-0337 (fax) December 15.2002

Christopher O. Ward, Commissioner New York City Department of Environmental Protection 59-17 Junction Blvd. Flushing. NY 11313

Dear Commissioner Ward:

I am writing on behalf of the Independence Plaza Tenant Association, representing more than 4000 tenants of Independence Plaza North (IPN), located on Greenwich Street between Duane and North Moore Streets.

As you are no doubt aware, IPN was severely Impacted by the dust cloud caused by the destruction of the World Trade Center on September 11, 2001. Our homes and, indeed, our entire neighborhood, continued for over eight months to be subjected to airborne dust created by the debris-removal operation on Pier 26, which Is virtually adjacent to our complex.

We have been trying to get the responsible government agencies to do an environmental cleanup of our buildings for more than a year. In all that time, neither DEP nor any other agency was willing to test our buildings for contaminants.

Therefore, out of concern for the health and well-being of IPN tenants, the Tenant Association hired MVA, Inc. laboratory to test a piece of carpet from the hallway of one of our towers, at 310 Greenwich Street, for asbestos, using the ultrasonication method that Dr. Millette developed for the EPA. We are enclosing herewith a copy of the results of the ultrasonication test, which show an extremely high level of asbestos (1.3 million asbestos structures per square centimeter). Given this test result, plus our massive 8-month exposure to WTC dust, it is reasonable to assume that all of the hallway carpeting in IPN contains asbestos.

Recently, DEP ordered IPN’s landlord to have testing done of the mastic tha t affixes the carpeting to the cement floor. Asbestos experts have advised us that, since carpet mastic is a non-friable material. EPA's ultrasonication test will not show any asbestos coming from carpet mastic. The test will only detect asbestos which comes from dust contamination of the carpet. Therefore, the results of the recent mastic testing have no relevance to the enclosed results of the carpet ultrasonication test, ordered by the IPN tenant association.

Therefore, we hereby request that further testing be done on the IPN carpet ng itself. Air testing should be supplemented with other testing methods - namely ultrasonication or mlcrovac - that would more accurately reflect the potential for asbestos contamination of the IPN complex. Such testing must be sufficient to demonstrate the need (or lack thereof) for asbestos abatement of the hallways of IPN buildings.

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