NYC 9/11 Public Portal Document
4
Liberty St. cleaning studyThe microvacuum method, ASTM Method 5755 is only suitable for
fi-eshly 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 dry 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 resuite 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/NYCDEP 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
NYC-WTC_000155267
OCR can misread numbers and units. Confirm readings against the page image before using them.