EPA draft letter to FEMA regarding 114 Liberty, July 2003

NYC 9/11 Public Portal Document

Mr. Walter Melnick Federal Emergency Management Agency Federal Recovery Office 80 Centre Street, 3"** Floor New York, NY 10013 Dear Mr. Melnick, The US Environmental Protection Agency (EPA) and NYC Department of Environmental Protection (DEP) are in receipt of the analytical test results supplied to the Federal Emergency Management Agency (FEMA) by residents of 114 Liberty Street via Congressman Jerrold Nadler’s office. These samples were collected and analyzed in April 2003 and the data was received by FEMA on June 24 and EPA on June 25, 2003. As explained below we believe that the extensive data collected by DEP and its contractors to clear this building are still valid. As part of the EPA, FEMA and DEP voluntary clean-up program for residential units in lower Manhattan, DEP was responsible for the clean-up of World Trade Center (WTC) dust and debris from unoccupied, uncleaned residential buildings; one of which was 114 Liberty Street. EPA collaborated with DEP on this part of the program. DEP developed the scope of work following the guidelines set forth in Title 15 Chapter 1 of RCNY (Asbestos Control Program). Copies of this scope of work were distributed to EPA, the building management and the residents. In addition, sampling was done for contaminants of potential concern following EPA protocols established specifically for WTC clean-ups. 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. In April of 2003, DEP sent the Board of Directors a letter informing them that the clean-up activities had been completed as per the clean-up and monitoring specifications, as well as the access agreements for 114 Liberty Street. Attached to the letter were copies of correspondence from EPA regarding the clearance levels for contaminants of possible concern and enclosures summarizing the analytical results. Included in the letter was reaffirmation of DEP’s Asbestos Control Program’s staff observations whereby pre-existing building materials were identified as having suspect asbestos-containing material (ACM). Those materials included thermal system insulation, surfacing material and vinyl asbestos tiles. Copies of DEP’s April 24, 2003 and EPA’s April 18,2003 letters are attached for your perusal. The following provides the results of our review of the above-described data submitted to you by the residents of 114 Liberty Street:

Asbestos Data Based on the results that were received, it appears that eleven wipe samples and sixteen microvacuum samples were collected by Ambient Group Inc. and analyzed by EMSL Analytical Inc. for asbestos. An additional wipe sample and two microvacuum samples were submitted as blanks. A summary of the results is presented below.

NYC-WTC_000163169