114 LIBERTY 2 OF 2

NYC 9/11 Public Portal Document

6. The "clearance criteria" called for would be laughable, were one not to consider the situation it is being applied to by the authors. There is, in fact, no clearance criterion whatsoever, other than someone inspecting the ductwork and deeming it "visually" clean. As stated previously, how can it be assured that contaminants, which cannot normally be seen by the naked eye, have been removed without some kind of sampling and analysis? Simply stated, one cannot and to imply otherwise, particularly in this situation, should be considered criminal.

In conclusion, there are numerous deficiencies, omissions and assumptions made by both the NYC DEP and EMTEQUE in their specifications which simply do not address the situation and conditions that we know exist at 114 Liberty Street. Massive amounts of contaminated dust and debris entered and permeated virtually the entire building, yet these specifications only deal with cleaning that dust which is readily visible and easily accessible. In addition, in our opinion the "clearance" criteria (where it is even stated) that they will be using to deem the project complete and the building ready for re- occupancy, fails to take into account that children will be living in this building, and some of the unique and close-up modes of exposure that are often associated with children, but not with adults (i.e., crawling on the floor, constant hand-to-mouth contact, etc.) In some cases, especially with regards to the cleaning of the HVAC systems, they are apparently relying solely on whether or not the areas are visually clean. In other cases, they are apparently ignoring the fact that other potentially hazardous and toxic contaminants have been found (i.e., PCBs and dioxins) and do not even set any type of clearance criteria for these compounds, much the less mention testing for them. Therefore, based upon our review of the documents provided to us, we would strongly recommend that you do not rely upon any cleaning processes that may be performed as part of this proposed project to be complete and suggest that the building is acceptable for re-occupancy as a residential setting.

Sincerely Signed for Ambient Group, Inc. by:

John P. Springston, CIH, CSP Director of Field Operations

NYC-WTC 000155442