114 LIBERTY 2 OF 2

NYC 9/11 Public Portal Document

B. HVAC CLEANING SPECIFICATIONS:

1. The specifications state that the kitchen and bathroom exhaust systems are not included in this program. If not, under which program are they addressed?

2. The specifications allow the contractor to determine appropriate methods, tools and equipment required to do this project, rather than stipulating what needs to be done, how to do it, and what to use to get it done. This is, in a word, ludicrous.

3. The Inspector Qualification requirements, for the individual who will perform the HVAC cleanliness inspection (to determine if cleaning is even required), are incredibly vague. Also, are we to rely on just a visual inspection by this "qualified" person to determine if cleaning needs to be done or not? Why is there no provision for any sampling, as most of the contaminants that are present (i.e., asbestos fibers, dioxin, etc.) typically cannot be seen by the naked eye?

4. The NADCA standards that they continually refer to only apply to the general cleaning of HVAC systems and their related ducting, due to the typical build-up and deposition of normal dust that occurs over years and years of usage. This standard has absolutely no purpose being cited here since 1) the dust deposited within the various systems had nothing to do with their normal operation, and 2) the dust deposited is far from what would be considered normal. What we are dealing with in this situation is a dust that is, in general, far smaller in diameter than what we normally find in urban settings (therefore it was distributed throughout the area much more widely and efficiently) and contains numerous contaminants that would not normally be found in urban dust (including asbestos, PCBs, dioxins, etc., etc.).

5. Upon further examination, it appears that the HVAC cleaning specification that was "developed" is, in fact, a copy of the standard specifications that were developed by NADCA, with only minor revisions made to it. It is, in no way, site specific and fails to address the unique conditions that are present at 114 Liberty Street. For instance, the cleaning specification developed by the NYC DEP calls for all work to be done as an asbestos abatement project. The HVAC cleaning specifications, however, fail to even mention that asbestos is present. The HVAC cleaning specifications also fail to note that most, if not all, of the supply air ductwork is internally lined with fiberglass - an obviously porous material which cannot simply be decontaminated via HEPA vacuum techniques. Additionally, such a cleaning method for this type of material is not even allowed under the asbestos abatement regulations, and yet this specification implies that this would be acceptable. The specification also talks about cleaning return air ducts, even though there are none in any of the apartments.

NYC-WTC 000155441