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

NYC 9/11 Public Portal Document

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cleaning shall be performed. This results in two full cleanings of all surfaces ... Surfaces include but are not limited to walls, floors, ceilings, ledges, trims, appliances, equipment and furnishings.

The cleaning contractor shall notify the monitoring contractor immediately upon completion of the cleaning. The Monitoring Contractor will conduct a thorough visual inspection to verify the absence of visible dust accumulations. If dust is observed the cleaning contractor will reclean as necessary at no additional cost.

[Scope A surface cleaning procedures:] Residences will be cleaned using HEPA vacuums, water extraction cleaners and wet wiping as described below. Surfaces to be cleaned include but are not limited to walls, floors, ceilings, ledges, trims, furnishings, appliances, equipment, etc.... All surfaces including but not limited to floors, walls, curtains, fabric window treatments, upholstery and other materials that are not cleaned by wet methods (wet wiping and water extraction cleaning) will be HEPA vacuumed two times.

The EPA/NYCDEP contractor did not remove all visible dust even after two cleaning events at 114 Liberty. Residents, their architect, and their environmental consultants clearly identified visible dust layers on horizontal surfaces on the galvanized steel wall framing system and ceiling support system. These surfaces were easily accessible, because as stated earlier, EPA/NYCDEP had removed the ceiling and one side of the walls for the purpose of making them accessible.

Some of these exposed, accessible wall and ceiling filming and support surfaces with visible dust were tested. The residents’ consultant demonstrated high levels of asbestos, an indication that that visible dust remained. The locations where these visible dust layers were tested were described as wall, ceiling and floor tracking, an area on the exposed column beneath a light switch, an exposed ceiling I-beam, an area on the floor in the center of a column, and a pipe shaft, all had visible dust.

Resident testing was demonstration of failure to remove visible dust The surfaces tested by file residents at 114 Liberty showed elevated levels of asbestos, most fi’om 10,000 to over I million structures per square centimeter (s/cm^). These laboratory results demonstrate the presence of significant dust after the two abatements by EPA/NYCDEP.

Newly abated hard surfaces typically show no detectable asbestos, or extremely low levels. Surfaces were also tested after the same EPA/NYCDEP contractors abated 110 Liberty St., a few feet away fi-om 114 Liberty St., and almost as severely impacted by WTC dust. The EPA 110 Liberty cleaning stud/ showed that smooth surfaces only had asbestos in the thousands of structures per square centimeter (1000 to around 5000 s/cm^ ) after only one cleaning. Since most of the units at 110 Liberty had to be re-cleaned fi-om two up to four times, the concentrations of asbestos on surfaces would have been even lower with each successive cleaning. (EPA did not provide data on the surface levels of asbestos after the additional cleanings in its report).

EPA/NYCDEP stated in their 8/4/03 letter to FEMA that wipe and microvacuum testing of surfaces after abatement served the purpose of demonstrating abatement effectiveness:

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