Hudson River Management LLC requests asbestos testing of carpeting at Independence Plaza before removal.
NYC-WTC_000154937–000154938Folder label: “INDEPENDENCE PLAZA”
OCR status: ok · source: pdftotext
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. Christopher O. Ward, Commissioner Re: Independence Plaza North (IPN) 310 Greenwich Street. Carpet Removal
Dear Commissioner Ward:
The undersigned represents the Managing Agent (Hudson River Management LLC) for Independence Plaza North, a residential apartment Complex located in Lower Manhattan (one block North of Chambers Street). Our Development is comprised of 1332 middle income rental units and has a population of approximately 2500 people.
In October 2001, 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 32"^ 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 Environmental Committee contracted with its own testing firm to conduct asbestos testing and analysis of the 32"’’ floor carpet. The results, which were sent to you 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).
Accordingly, Management respectfully requests that the DEP test and analyze the airborne particles in the 32"** 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.
truly you]
Deborah Dolai Manager
Eni;. Ce: DEP Dep»^' Commiss/oner Roberf C. .Ana/trvni, Jr. Coiw, Hudson R/nerMana^menf HLC IPNTyl Eninm/nnenta/ Comnn'f/ee Ar/ene Anderson, EPA
NYC-WTC_000154938
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