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

NYC 9/11 Public Portal Document

7

EPA. HVAC systems cleaning, if warranted, shall be completed prior to the initiation of the cleaning of common space or residences within an affected building. In the event that the HVAC system for an entire building requires cleaning, a separate, site specific contract will be awarded by DEP for this work. If only a portion of an HVAC system requires cleaning, then the cleaning contractor will conduct the cleaning utilizing specialized labor trained and experienced in duct cleaning.

HVAC cleaning shall be conducted in accordance with National Air Duct Cleaners Association (NADCA) General Specification for the Cleaning of Commercial Heating, Ventilating and Air Conditioning Systems and the NADCA Assessment, Cleaning and Restoration Standard (ACR 2002). Verification of the effectiveness of HVAC system cleaning will be determined by the Monitoring Contractor. If dust or other contaminants are evident through visual inspection, those portions of the system where dust or other contaminants are present shall be recleaned and subjected to reinspection for cleanliness. If the cleaning contractor is not a member of the NADCA, a subcontractor that is a member may perform this portion of the work.

EPA erroneously attributed the high asbestos levels to pre-existing asbestos materials

EPA also tried to attribute the high asbestos levels found by the residents as being from previously installed asbestos containing building materials. This is also untrue. An easy inquiry on the part of EPA would have revealed that this could not be the case.

There were no other asbestos-containing materials in the upper condominium floors of the building, except for floor tiles which were sealed beneath paper, and then covered over with either wood flooring or stone or ceramic in 1998. In addition to the visible dust on the wall and ceiling supports, the asbestos-laden dust tested by the residents was clearly visible as lines of dust in and on top of the paper directly under the cracks of the floorboards. It is absurd to postulate that the dust came from the floor tiles, which were under a layer of paper under the wood. It would need to have migrated upwards through the paper and arrange itself into discrete Unes aligned with the cracks in the floor boards.

It should be noted that EPAZNYCDEP refused to remove floorboards to clean dust that sifted through the cracks. The residents had requested this, because they could see the WTC dust in the cracks of the floor boards.

The only other asbestos in the building was from the first floor pizzeria, where the asbestos could not have migrated to upper floors. EPAZNYCDEP themselves demonstrated that the asbestos from the pizzeria was a completely different type of asbestos (amosite) than that found by the residents in the upper floor condominium (chrysotile, which is associated with the WTC).

Nearby building must be demolished because of similar penetration of WTC dust

Another building a few feet away, the Deutsche Bank Building at 130 Liberty St., also has WTC dust contamination “in every crack and crevice.” They tried usual asbestos and other toxic abatement procedures, but these procedures failed. Demolition of the building is planned

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