114 LIBERTY 2 OF 2

NYC 9/11 Public Portal Document

Ambient Group's comments regarding the "Cleaning Procedures for 114 Liberty Street", as prepared by the NYC DEP, and the "Specifications for the Cleaning of the HVAC Systems", as prepared by EMTEQUE Corporation for the NYC DEP.

A. GENERAL CLEANING PROCEDURES:

1. The specifications essentially only address the asbestos contamination and do not provide any direction as to how to abate any contaminants, which may require special cleaning procedures (i.e., PCBs or dioxins).

2. The specifications allow the contractor to do superficial cleaning of certain items, such as built-in furniture, kitchen stoves, refrigerators, dishwashers, etc., thereby ignoring those contaminants that settled behind, under or inside these items.

3. The specifications, for the most part, do not address how to remove the dust and contaminants, which have settled into the small gaps between the floorboards. It also does not address the dust and contaminants that have settled into the interstitial spaces between the walls.

4. The specifications are extremely vague on how the dust and contaminants above the suspended ceilings (which act as return air plenums for the HVAC units) will be cleaned, though it does state that the ceiling shall not be damaged. How, then, can the space above the ceiling be cleaned? The specifications also state that care must be taken not to disturb the fireproofing (which is located in the return air plenum). Is there any data to suggest that no dust or contaminants are present on the surface of the fireproofing? If not, how is the contractor supposed to clean the fireproofing if they are not allowed to disturb it?

5. The clearance criteria are not clearly spelled out and appear to be focused mainly on airborne concentrations of (presumably) asbestos. The specification also mentions wipe sampling for metals, but does not stipulate which metals or what are considered "acceptable" levels. They make mention of clearance criteria as established by the USEPA for this clean-up activity. However, based on our review of the documents in question, Ambient Group feels that the logic applied in determining what contaminants to test for was inherently flawed. According to the EPA, they only focused on those contaminants that had been found in air samples collected around Ground Zero, and basically ignored sampling results from settled dust samples that indicated other contaminants were also present. This is somewhat like being on a golf course and saying there isn't a Canadian geese problem because you don't see any flying in the air above you, even though there is a huge flock of geese grazing in the fairway right in front of you! In addition, by only focusing on airborne concentrations they are ignoring the possibility of either dermal (skin) absorption of certain contaminants, or hand-to-mouth transfer of contaminants, a factor which is crucially important when you are dealing with an environment where children are likely to be living in on a daily basis.

NYC-WTC 000155440