Letter re: EPA/DEP WTC dust cleanup at 114 Liberty Street,

NYC 9/11 Public Portal Document

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Liberty St. cleaning study.’ The microvacuum method, ASTM Method 5755 is only suitable for freshly deposited dust layers that have not be touched by wet wiping, washing, etc. This is because water and detergents will temporarily bind residual dust-bome contaminants to the surface so that they will not be picked up by the diy vacuuming technique used in the ASTM microvacuum method. As discussed in my 12/19/01 memorandum,’ wipe testing has been demonstrated to pick up 4 times or more asbestos from smooth surfaces compared to microvacuum sampling.

EPA/NYCDEP failed to abate visible dust at 114 Liberty St. On 8/4/03, EPA/NYCDEP jointly wrote to FEMA to defend the adequacy of its cleaning efforts at 114 Liberty St. This defense was in response to your inquiry on behalf of the residents at this address. EPA/NYCDEP stated the following: The U.S. Environmental Protection Agency (EPA) and the NYC.Department of Environmental Protection (DEP) are in receipt of the analytical test results supplied to the Federal Emergency Management Agency (FEMA) by residents of 114 Liberty Street via Congressman Jerrold Nadler’s office.... As explain^ below we believe that the extensive data collected by DEP and its contractors to clear this building are valid.

DEP developed the scope of work ... sampling was done for the contaminants of potential concern following EPA protocols established specifically for EPA's WTC Residential Confirmation Cleaning Study. The analytical results were compared to health-based benchmarks established by EPA’s Interagency Indoor Air Task Force. The contaminants of potential concern included; asbestos, lead, dioxin, PAHs (Poly Aromatic Hydrocarbons), fibrous glass and crystalline silica.

The clean-up started on March 6,2003 and was completed on March 29,2003. The test results were reviewed and indicated that all the primary clearance levels were achieved.

As discussed in greater detail below, EPA/NYCDEP did not clean up 114 Liberty St. according to the EPA specifications in regard to either visible dust, asbestos, or silica.

EPA/NYCPEP left clearly visible dust in readily accessible areas

EPA was incorrect in its 4/24/03 letter asserting that the clean-up at 114 Liberty St. met the requirements: This is to confirm, the Department of Environmental Protection has completed the clean­ up activities as per the clean up and monitoring specifications and access agreements for 114 Liberty St.

The EPA Statement of Work requires the contractor to re-clean if there is any visible dust: * After the removal of debris, all surfaces will be cleaned in accordance with the procedures specified in Scope A. After all surfaces have been cleaned, a second

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