Interim Final WTC 

Residential Confirmation 

Cleaning Study 

Volume 1

110 Liberty St.

New York, NY

U.S Environmental Protection Agency, Region 2

New York City Response and Recovery Operations

290 Broadway

New York, NY 10007-1866

May 2003
Acknowledgments 

The United States Environmental Protection Agency (EPA) is grateful for the generous 

contribution of Mr. David M. Baldwin of Liberty Street Associates, LLC for his generosity in 

providing 110 Liberty Street as the study building. 

This project was designed by EPA with the support of the Indoor Air Work Group of EPA’s 

Interagency Indoor Air Task Force. The efforts of the task force were essential to successful 

implementation of the study. The work group organizations directly involved in the development 

of the project included: the Federal Emergency Management Agency; the New York City 

Department of Environmental Protection; the New York City Department of Health and Mental 

Hygiene; The City of New York Mayor’s Office of Environmental Coordination; the New York 

City Office of Emergency Management; the New York State Department of Health and Mental 

Hygiene; the Agency for Toxic Substances and Disease Registry; the Occupational Safety and 

Health Administration; EPA’s Office of Solid Waste and Emergency Response, and EPA Region 

2. 

Note:

This interim final report is a working document that will be subject to further agency and thirdparty review. EPA intends to excerpt, and possibly expand, portions of this report for inclusion 

in manuscripts that will be submitted to scientific journals for review and consideration for 

publishing.

- i -
1

Table of Contents 

Acknowledgments......................................................................................................................... -i- 

 

Executive Summary ........................................................................................................................ 1 

1. Introduction ............................................................................................................................... 4 

 1.1 Background/Objectives .............................................................................................. 4 

 1.2 Identification of Contaminants of Potential Concern (COPC)................................... 5 

 1.3 Development of Clearance Criteria for Lead ............................................................. 6 

 1.4 The Project Team ....................................................................................................... 7 

 1.5 Cleaning Methods ...................................................................................................... 7

 1.6 The Work Plan ........................................................................................................... 9 

 1.7 Project Documentation............................................................................................... 9 

2. Cleaning Activities................................................................................................................... 10 

 2.1 Building Logistics .................................................................................................... 10 

 2.2 Personal Air Sampling, Personal Protective Equipment and Safety Risks .............. 13 

 2.3 Equipment ................................................................................................................ 13 

 2.4 Cleaning Methods .................................................................................................... 16 

 2.5 Mobilization ............................................................................................................. 17 

 2.6 Cleaning of Residential Units .................................................................................. 17 

 2.7 Cleaning of Commercial Units, Common Areas and Basement.............................. 19 

 2.8 Cleaning of Non-Study Commercial Units .............................................................. 21 

 2.9 Cleaning of Building Exterior/Roof......................................................................... 22 

 2.10 Summary of Cleaning Activity................................................................................. 23 

 2.11 Difficulties Encountered and Resolutions................................................................ 24 

3. Sampling Activities................................................................................................................. 27 

 3.1 Baseline Sampling.................................................................................................... 27

 3.2 Pre-Cleanup Sampling.............................................................................................. 27 

 3.3 Sampling During Cleaning....................................................................................... 28 

 3.4 Post-Cleanup Sampling............................................................................................ 28 

 3.5 Sampling Supplies and Equipment .......................................................................... 29 

 3.6 Sample Analysis and Management .......................................................................... 31 

 3.7 Analytical Data......................................................................................................... 32 

 3.8 Difficulties Encountered and Resolutions................................................................ 32 

 3.9 Modifications to the Study ....................................................................................... 33 

 3.10 Supplemental Sampling Activities........................................................................... 34 

 3.11 Mercury Vapor Using Lumex® Analyzer................................................................. 34 

4. Analytical Results.................................................................................................................... 35 

 
2

5. Discussion ............................................................................................................................. 103 

 5.1 Data Sets................................................................................................................. 103 

 5.2 Extent of Contamination ........................................................................................ 104 

 5.3 Location of Units.................................................................................................... 108 

 5.4 Comparison to Health-Based Benchmarks............................................................. 108 

 5.5 Cleaning Effectiveness........................................................................................... 108 

 5.6 Multiple Cleaning Events....................................................................................... 111 

 5.7 Sampling Methods.................................................................................................. 113 

 5.8 Air Disturbance ...................................................................................................... 115 

 5.9 Filter Overloading .................................................................................................. 116

 5.10 HVAC System........................................................................................................ 117 

 5.11 Observations........................................................................................................... 118 

 5.12 Complexities .......................................................................................................... 119 

6. Summary ............................................................................................................................... 120 
1

Executive Summary 

The United States Environmental Protection Agency (EPA) responded to the September 11, 2001 

attack on the World Trade Center (WTC) in conjunction with the President's declaration of a 

national disaster. The Federal Emergency Management Agency (FEMA), the federal government 

office coordinating disaster response, issued mission assignments to EPA related to: 

 

• cleaning dust and debris from the streets of lower Manhattan 

• assessing the ambient environment through analysis of air and dust samples 

• providing washing stations for decontamination of personnel and equipment involved in 

dust and debris removal operations, and 

• disposing of hazardous materials found at the WTC response and recovery site. 

Residents of lower Manhattan expressed concerns about the safety and reliability of cleaning 

methods utilized to remove dust and debris from residential unit interiors and building exteriors. 

Traditional FEMA support programs were available; however, residents requested additional 

assurance. To address concerns about the extent of indoor impact of dust and debris, as well as 

concerns regarding fire-related particle deposition, EPA Administrator Christine Todd Whitman 

formed an Interagency Indoor Air Task Force. The task force included representatives from the 

following agencies: EPA, FEMA, the New York City Department of Health and Mental Hygiene 

(NYCDOHMH), the New York City Department of Environmental Protection (NYCDEP), the 

New York City Office of Emergency Management, the New York City Mayor’s Office of 

Environmental Coordination, the New York State Health Department, the New York State 

Department of Environmental Conservation, the Occupational Safety and Health Administration 

(OSHA), and the Agency for Toxic Substances and Disease Registry (ATSDR). The 

multidisciplinary, interagency group focused on issues of concern to residents and developed 

coordinated strategies to address the concerns. 

In May 2002, EPA, FEMA and New York City (NYC) announced a voluntary cleanup program 

for residential units in lower Manhattan. This program would run parallel to and simultaneously 

with several other efforts, in order to reassure residents regarding the potential risks from 

exposure to residual WTC dust and debris, and to provide residents with the opportunity to have 

WTC residual material removed from their units as expeditiously as possible. Funded by FEMA 

through interagency agreements with EPA and NYC, these efforts include: 

• identification of Contaminants of Potential Concern (COPC) 

• a background study of the COPC in upper Manhattan (Background Study) 

• inspection and cleaning of building exteriors in lower Manhattan 

• Indoor Air Residential Assistance-WTC Dust Cleanup Program (WTC Dust Cleanup 

Program) 

• cleaning of unoccupied, uncleaned residential buildings, and 

• study of cleaning techniques in an unoccupied building adjacent to the WTC site that was 

directly impacted by the WTC collapse (WTC Residential Confirmation Cleaning Study). 

This report presents the results of the WTC Residential Confirmation Cleaning Study (study) 

conducted by EPA. 
 2

Background

Following the attack on the World Trade Center, residential living spaces in the immediate 

vicinity of ground zero were impacted by dust and debris. Samples of dust and debris collected 

by EPA from the streets of lower Manhattan contained asbestos at levels greater than one percent 

of sample mass in approximately 35 percent of the 160 samples taken between September 11, 

2001 and October 10, 2001. A study of residential unit interiors proximal to the WTC site was 

funded by FEMA, and implemented by ATSDR and NYCDOHMH with EPA support. This 

study concluded that although air sampling indicated that asbestos in air benchmarks had not 

been exceeded, residual material in the dust was attributable to the WTC attack and collapse. 

Preliminary results of this study were provided early in 2002. Final results were issued in 

September 2002.1

 

Shortly after the disaster, NYCDOHMH, EPA and others provided the residents of lower 

Manhattan with recommendations on cleaning methods through the media, fact sheets and 

community meetings. These recommendations were based on previously established cleaning 

procedures that were proven to be effective in removing layered particulate matter and debris 

with minimal dust generation. 

Objectives

In an effort to provide additional information to the public on cleaning methods that may be 

effective in reducing contaminants from dust generated by the WTC collapse and recovery 

efforts, EPA, in concert with FEMA and NYC, commenced a study of a building on Liberty 

Street, just south of the WTC site, that had been heavily impacted by the collapse of the twin 

towers. The purpose of the study was to confirm the adequacy of various cleaning and 

vacuuming methods used by residents and professional cleaning companies, in the aftermath of 

the attack, to clean dust and debris from residential living areas. 

Project Implementation

EPA and its contractors commenced the WTC Residential Confirmation Cleaning Study on June 

14, 2002. The study addressed cleaning of a complex mixture of contaminants, including 

construction debris and fire-related compounds. EPA was unaware of a precedent for an indoor 

environmental cleanup with such a diverse set of parameters; however, time pressures did not 

allow for conducting extensive research on potential cleaning techniques in a controlled setting. 

The real-time need to determine the effectiveness of the cleaning methods being used by 

residents, and being employed in the WTC Dust Cleanup Program, drove the decision to field 

test the effectiveness of the standard dust removal methods in a heavily impacted, unoccupied 

building. 

Eleven cleaning methods were selected for testing and assigned to residential units within the 

building according to the levels of observed dust. An attempt was made to test each method in 

units with both significant and minimal levels of dust. 

Multiple endpoints were used in the study to ensure that the complexity of the dust was 

comprehensively considered. Analytical results were compared to health-based benchmarks for 

pre-selected COPC to determine if the cleaning was successful in achieving these values. The 

 1

New York City Department of Health and Mental Hygiene/Agency for Toxic Substances and Disease 

Registry (NYCDOHMH). (2002). Final Report of the Public Health Investigation to Assess Potential Exposures to 

Airborne and Settled Dust in Residential Areas of Lower Manhattan. 
 3

COPC included: asbestos, lead, dioxin, polycyclic aromatic hydrocarbons (PAH), fibrous glass 

and crystalline silica (alpha-quartz, cristobalite, tridymite.) 

The study used a combination of data sets to determine the extent of contamination, the 

effectiveness of cleaning methods, and the differences of sampling and analytical methods. 

 

A summary of the significant conclusions of the study are provided below. These include 

observations about the extent of WTC-related contamination within the building and the 

effectiveness of the cleaning methods tested in the study. 

 

Conclusions Regarding Contamination of the Building: 

• The study found that the observation of WTC dust is an indicator that WTC contaminants 

may be present and that the amount of WTC dust correlates with the level of 

contamination. 

• The study found that concentrations of some contaminants in the WTC dust were 

elevated above health-based benchmarks. 

Conclusions Regarding Cleaning Effectiveness: 

• The study demonstrated that the use of a standard cleaning method of vacuuming and wet 

wiping significantly reduced levels of WTC-related contamination with each cleaning 

event and was successful in reducing concentrations to levels below health-based 

benchmarks. 

• The study found that one to three cleanings were necessary to reduce contamination levels 

to below health-based benchmarks, and the number of cleanings required generally 

correlated with the levels of contamination initially identified in the units. 

• The study found that standard Heating, Ventilation and Air Conditioning (HVAC) 

cleaning methods reduced the concentrations of WTC contaminants in HVAC systems. 

• The study found that conducting asbestos air sampling was a conservative method for 

determining if additional cleaning was needed. 

The study successfully demonstrated that standard cleaning practices are effective in removing 

the complex mixture of WTC dust, thereby reducing individual exposure to WTC-related 

contaminants. Therefore, EPA’s recommendation continues to be that individuals concerned 

about the presence of WTC dust use HEPA vacuums and wet wiping to remove the dust from 

their dwellings. Depending on the amount of dust deposited, repeated cleanings may be 

necessary. 
 4

1. Introduction

In an effort to provide information to the public on cleaning methods that would be effective in 

removing dust and contaminants generated by the WTC collapse and recovery efforts, EPA, in 

concert with FEMA and NYC, began a study of a building that had been impacted. The building 

was located on Liberty Street, just south of the WTC site. On June 14, 2002, EPA and its 

contractors commenced the WTC Residential Confirmation Cleaning Study to confirm the 

adequacy of various cleaning and vacuuming methods that may have been used by the residents 

of lower Manhattan and professional cleaning companies to clean dust and debris from 

residential living areas. 

1.1 Background/Objectives 

Shortly after the collapse of the WTC, NYCDOHMH, EPA and others provided the residents of 

lower Manhattan with recommendations on cleaning methods through the media, fact sheets and 

community meetings. These recommendations were based on previously established cleaning 

procedures that were proven to be effective in removing layered particulate matter and debris, 

with minimal dust generation. The WTC Residential Confirmation Cleaning Study was 

conducted to provide the residents with additional information. The effectiveness of the cleaning 

methods tested in the study was evaluated through the collection and analysis of pre-cleanup and 

post-cleanup samples, and comparison of the resulting analytical data to health-based screening 

levels for the COPC. Table 1.0 presents the primary clearance criteria used to determine 

cleaning effectiveness. 

The study’s COPC included: asbestos in air by phase contrast microscopy equivalent (PCMe) 2, 

lead in air and settled dust, dioxin in air and settled dust, PAH in air and settled dust, fibrous 

glass and man made vitreous fibers (MMVF) in air, and alpha-quartz in air. More detail on the 

selection of these compounds is included in Section 1.2. 

In addition to evaluating data for the COPC in their respective media identified above, data was 

also evaluated for COPC that were analyzed using alternate analytical methods [e.g., asbestos in 

air using PCM and transmission electron microscopy (TEM) Asbestos Hazard Emergency 

Response Act (AHERA), COPC in other media (e.g., asbestos, MMVF, and alpha-quartz in 

settled dust), compounds that were included as part of the crystalline silica analytical analysis 

(e.g., cristobalite, tridymite, calcite, and gypsum in air and wipe samples]. The results from these 

additional analyses were primarily used to evaluate the cleaning methods as there were no healthbased benchmarks for comparison. The exception would be the asbestos in air PCM and TEM 

AHERA results, which in addition to being used to evaluate the cleaning methods, were also 

compared to their respective regulatory criteria.3

 These regulatory criteria are referred to as 

 2

The asbestos air samples were collected according to NIOSH 7400 (PCM). The sample filters were 

analyzed using a modified AHERA method. Although the total TEM (AHERA) fiber count was recorded, a separate 

PCM-equivalent (PCMe) count was recorded by modifying the AHERA method to count only fibers greater than 5 

μm (micrometer). It is this modified-AHERA PCMe fiber count that was the basis of the asbestos test results and 

clearance criterion.

3

The regulatory clearance criterion for TEM AHERA was 70 S/cm2, converted to 0.022 S/cc, based on a 

volume of 1200 cc. The regulatory criterion for PCM AHERA was 0.01 f/cc based on a volume of 1200 cc. 
 5

secondary numeric criteria. Cleaning continued in the residential units and commercial spaces 

until primary clearance criteria were achieved. Some areas required three cleaning events. 

This report provides information on the type of cleaning and sampling methods that were used, 

the results of the analytical analyses performed, and the conclusions that were made based on the 

information collected. 

1.2 Identification of Contaminants of Potential Concern (COPC)

Under the auspices of the Interagency Indoor Air Task Force working group, a committee was 

formed to identify contaminants of potential concern (COPC) and associated health-based 

clearance criteria for the lower Manhattan clean-up program. Among other purposes, this 

initiative was intended to inform the selection of contaminants to monitor in the WTC 

Residential Confirmation Cleaning Study and Background Study and to provide a measure of 

cleaning effectiveness by establishing health-based clean-up goals for indoor air and settled dust. 

A draft of the COPC/Benchmarks Report prepared by EPA was peer reviewed on October 21-22, 

2002. The final report is currently being completed. As such, the COPC identified for inclusion 

in the study reflect those contaminants cited in the peer review draft of the COPC/Benchmarks 

Report.4

 

 

The development of the COPC report began with an assessment of the indoor environment by 

reviewing historical information on hazardous substances that have been associated with building 

fires and collapses. Many compounds, including combustion byproducts such as dioxins and 

PAH were identified, along with building materials such as asbestos and fibrous glass. Ambient 

air, indoor air, and indoor/outdoor bulk dust monitoring data were also reviewed. Data sources 

included EPA's ambient air and bulk dust/debris monitoring program (www.epa.gov/wtc), 

OSHA's air/dust monitoring data, and the NYCDOHMH/ATSDR indoor air pilot program. A 

concerted effort was also made to identify and review additional sources of WTC-related data 

from other governmental agencies (e.g., U.S. Geological Survey, NYC Department of Education) 

academic institutions, environmental organizations, and the private sector. 

A semi-quantitative screening process was performed on the collected sampling data referenced 

above. Based on frequency of detection, concentration, and inherent toxicity, contaminants that 

exceeded health-based screening levels for ambient air were identified. Dioxin and PAH were 

added to the COPC list by this process. In addition, building constituents with carcinogenic 

effects (asbestos) or irritant effects (fibrous glass, alpha-quartz) that were consistently and 

significantly found in bulk debris and indoor dust samples were identified as COPC.5

 Finally, 

lead was included based on a comparison of sampling data with existing regulatory standards. 

Collectively, the resulting group of contaminants (asbestos, lead, dioxin, PAH, fibrous glass and 

alpha-quartz) are called "contaminants of potential concern" or COPC in this report. 

 4

U.S. Environmental Protection Agency. (September, 2002). World Trade Center Indoor Air Assessment: 

Selecting Contaminants of Concern and Setting Health-Based Benchmarks. A draft report. Peer review has been 

completed; final publication pending. Customarily referred to as the COPC/Benchmarks Report. 

5

NYCDOHMH, 2002. 
 6

1.3 Development of Clearance Criteria for Lead

At the time the study was initiated, COPC benchmarks were established for all contaminants 

except lead. Initially, the clearance criterion used for lead was 0.1 μg/m3, which was based on 

an estimated national background concentration. Risk-based clearance criteria for lead in indoor 

air provide a means to evaluate the effectiveness of the WTC residential cleaning program. 

Information on background concentrations of lead in indoor air also informs attainment of 

cleanup objectives. Background information has been obtained from historical information on 

ambient air lead concentrations in urban environments, and will be further refined with data from 

a site-specific background study being conducted as part of the WTC Dust Cleanup Program. 

Table 1.0

Primary Clearance Criteria Used to Determine Reoccupancy6

Compound Air Settled Dust

Asbestos 0.0009 S/cc N/A 

Polycyclic Aromatic Hydrocarbons (PAH) 0.2 μg/m3 300 μg/m2

Dioxin/Furan 0.001 ng/m3 4 ng/m2

Lead 1 μg/m3

 

25 μg/ft2 

(micro vacuum comparison 

value 25 μg/ft2) 

Fibrous Glass (Man-made Vitreous Fibers) 10 S/L N/A 

Alpha-quartz (0.001 mg/m3 - 0.004 mg/m3 based on 

analytical methods) 

0.004 mg/m3

 

N/A 

 

EPA’s risk assessment methodology for lead has been advanced through use of a biokinetic 

model7 that incorporates a biomarker of exposure/effect (blood lead) and multimedia exposure 

modeling. Through use of this model EPA identifies a goal of reducing environmental lead 

exposure so that 95 percent of childhood blood lead levels are below 10 μg/dl. This goal is 

accomplished when the airborne lead concentration is set at 1 μg/m3

, and input values for all 

other sources of environmental lead exposure (e.g., water, soil, dust, diet) are set at background 

concentrations. 

 6

 U.S. Environmental Protection Agency. (September, 2002). World Trade Center Indoor Air Assessment: 

Selecting Contaminants of Concern and Setting Health-Based Benchmarks. Values have been excerpted from this 

draft report. 

7

U.S. Environmental Protection Agency. (February, 1994). Guidance Manual for the Integrated Exposure 

Uptake Biokinetic Model for Lead in Children. (OSWER EPA/540/R/93/081). 
 7

1.4 The Project Team 

The study was designed, implemented and managed by EPA staff with the assistance of EPA’s 

contractors: WRS Infrastructure and Environment, Inc. (WRS) and Weston Solutions, Inc. 

(Weston). 

EPA's project team consisted of three individuals from the Region 2 Removal Action Branch 

detailed to the region’s New York City Response and Recovery Operations (NYCRRO). The 

individuals included a Section Chief and two On-Scene Coordinators (OSCs) who were 

responsible for overall management and oversight of the contractors assigned to the project. All 

communication regarding site work activities, work scheduling, difficulties encountered, 

deviations from the work plan or sampling plan, and project progress were addressed by the 

OSCs on a daily basis. 

The WRS project team consisted of fourteen individuals: the response manager, the site health 

and safety officer, the project coordinator/field accountant, the foreman, and seven laborers who 

were supported by the program manager, the alternate program/contracts manager, and the 

corporate health and safety manager. WRS provided equipment and services associated with the 

cleaning operations. 

The Weston project team consisted of eight individuals: the project manager, two sample 

technicians, two technical writers, one technical artist and two data validators who were 

supported by the program manager and assistant program manager. Weston provided 

deliverables and services associated with the sampling operations. 

1.5 Cleaning Methods 

The Residential Confirmation Cleaning Study called for the testing of eleven cleaning methods. 

These ranged from basic vacuuming with standard household equipment, to wet vacuuming of 

carpets, to the use of commercial quality vacuums equipped with High Efficiency Particulate Air 

(HEPA) filters, to wet wiping with water only or soap and water, to cleaning of HVAC systems. 

The study focused primarily on cleaning methods used to clean residential living areas. 

However, two commercial units were included in the study. Cleaning of the commercial units 

was necessary to avoid the redistribution of dust from uncleaned areas to clean areas, because the 

commercial units were located on the same floor of the building as the apartments. These units 

also provided an opportunity to gain experience relative to the cleaning of heating, ventilation, 

and air conditioning units that may have been impacted by the WTC collapse. Cleaning of the 

commercial units was a condition of the access agreement agreed to with the building owner. 

 

At the time of the WTC attack, these two commercial units had been used as a Chiropractor's 

Office and a retail Mattress Store. To complete the remainder of the building, three additional 

commercial units, including two restaurants (Lemongrass Grill and The Food Exchange) and a 

Barber Shop were cleaned. 
 8

EPA applied up to two cleaning methods in each of thirteen residential units, and up to five 

cleaning methods in each of two commercial units. The eleven cleaning methods tested are 

presented below: 

1. Residential quality upright vacuums and shop vacuums. 

2. Residential quality upright vacuums and shop vacuums with the addition of an Air 

Filtration Device (AFD). 

3. HEPA-filtered upright and shop vacuums. 

4. HEPA-filtered upright and shop vacuums with the addition of an AFD. 

5. Industrial quality HEPA-filtered vacuums. 

6. Industrial quality HEPA-filtered vacuums with the addition of an AFD. 

(This cleaning method was used in both residential and commercial units.) 

7. Wet wiping of all horizontal and/or vertical surfaces with soap and water. 

8. Carpet cleaning. 

9. Standard cleaning procedures used by professional duct cleaning companies for the 

cleaning of air conditioning (A/C) systems, ducts and related equipment. 

10. Use of water only for wet wipe of horizontal and/or vertical surfaces. 

11. Scope A cleaning procedures developed by EPA and New York City for the cleaning of 

 units in lower Manhattan. 

Determination of which cleaning method would be studied in each rental unit was based on the 

apparent level of impact that unit had endured as a result of the WTC collapse. EPA developed a 

set of four tests to evaluate cleaning methods in the rental units. The tests were assigned based 

upon readily observable impact by WTC dust, and prescribed six of the eleven cleaning methods 

to be used to respond to each level of impact. Up to five different cleaning tests were tested in 

each residential and commercial unit. Factors related to level of impact included directional 

exposure to ground zero and location of the unit in the building. 

At project commencement, a visual assessment of the level of impact each rental unit had 

sustained was performed. This assessment was utilized to assign each rental unit to an applicable 

cleaning test. The assignment process was modified to ensure that each of the cleaning methods 

was applied (tested) in units that had experienced both low and high levels of observable impact. 

The effectiveness of the cleaning methods was evaluated through the collection and analysis of 

pre-cleanup and post-cleanup samples, and through comparison of the resulting analytical data to 

the COPC, to determine if the cleaning method achieved health-based screening levels. The 

COPC evaluated in this study were: asbestos in air by PCMe, lead in air and settled dust, dioxin 

in air and settled dust, PAH in air and settled dust, fibrous glass (MMVF) in air, and alpha-quartz 

in air. 

Data was also evaluated from other compounds that do not have health-based benchmarks 

established in EPA’s COPC/Benchmark Report. These included asbestos in air by PCM and 

TEM AHERA, asbestos in settled dust, calcite in air and settled dust, gypsum in air and settled 

dust, cristobalite in air and settled dust, tridymite in air and settled dust, fibrous glass (MMVF) in 

settled dust by wipe sampling, alpha-quartz in settled dust by wipe sampling and total settled dust. 

After the initial cleaning of each unit, the OSC reviewed the established cleanup criteria, reviewed 

the analytical results, and provided direction as to which units required additional cleaning. In the 

event that it was determined that a unit did not achieve the primary clearance criteria, it was 
9

cleaned a second time using the same method as the original test. The unit was then tested again 

for the COPC that did not meet the health-based benchmark during the first test. If the unit failed 

to achieve the cleanup criteria again, it was cleaned with the strongest equipment (commercial 

quality vacuum with HEPA filter and an AFD). Midway through the project, the clearance 

criterion for lead was revised to use a health-based benchmark rather than a background level 

benchmark. This eliminated the need for re-cleaning some units, because the revised criterion 

indicated lead levels were lower than the newly established benchmark. For the most part, the 

health-based benchmarks were achieved after the first or second cleaning was completed. 

However, two units required three cleanings. 

Air samples were collected to monitor for employee exposure during cleaning operations. 

Results are presented in Attachment A, Personal Monitoring Data. 

1.6 The Work Plan 

Specific procedures that were followed to perform the study, and a summary of all changes that 

were made to the work plan during the course of the study, are presented in Attachment B, The 

Work Plan and Changes to the Work Plan. 

1.7 Project Documentation 

At project commencement, digital photographs of all building interiors and building contents 

were taken. An inventory of personal belongings was developed. Photo documentation of the 

condition of each unit was compiled prior to each activity in the unit. Contents, conditions and 

specific areas of interest were digitally recorded. Photo documentation continued during initial 

sampling tasks. A record of equipment, materials, procedures and areas sampled was also 

maintained. Crews working in each unit were photographed. Procedures, equipment, and 

conditions were recorded during cleaning operations. All photographs were digitally recorded 

and are available upon request from EPA. 
10

2. Cleaning Activities

 

2.1 Building Logistics 

The study was conducted in a building supporting both residential and commercial use at the 

southern edge of ground zero. Located at 110 Liberty Street, New York, NY, the building is 

situated between Liberty and Cedar Streets. Accessible from both Liberty and Cedar Streets, it 

has a co-address of 113-117 Cedar Street. The location of the building in relation to ground zero 

is presented in Attachment C, Site Map. The building contains thirteen residential apartments 

and five commercial units, as well as common areas. It is five stories high. Prior to the WTC 

attack, all of the residential units were occupied, and the commercial units accommodated 

operating businesses. The configuration of the building interior is presented in Attachment D,

Floor Plans. 

The Residential Apartments

The thirteen residential apartments range in size from 655 square feet to 1,335 square feet. The 

dwellings have an open floor plan design. Each provides a kitchen, a bathroom, and bedrooms, 

as well as a utility closet containing a water heater and a furnace. 

The Commercial Units

The five commercial units range in size from 716 square feet to 2,451 square feet. Two of these, 

both located on the second floor, were cleaned as part of the study: 

 

• Chiropractor's Office 

• Mattress Store 

The remaining three commercial units were not part of the study, but were cleaned at the 

conclusion of the study, to complete the remainder of the building and to satisfy a condition of 

access for EPA to conduct the study: 

• Lemongrass Grill 

• The Food Exchange 

• Barber Shop 

The Lemongrass Grill has dining room facilities located on the first floor. Its preparation 

facilities are located in the basement. The Food Exchange is located on the first floor. Its 

preparation facilities are also in the basement. The Barber Shop is entirely situated in the 

basement. 

The Common Areas

Common areas include an elevator, stairwells and hallways. There is a trash compactor room 

and a utility room on floors two through five. A common laundry room is located on the second 

floor. The basement contains an elevator shaft and motor room, a trash compactor room, a fire 

equipment room, the Barber Shop and preparation and storage areas for The Food Exchange and 

Lemongrass Grill. 

Air Conditioning Systems

All of the residential and commercial units included in the study were heated by hot water 
 11

baseboard systems. In most cases, window-mounted air conditioners were in place to cool the 

residential units. Types of air conditioning systems present in the building are identified in 

Table 2.0. 

Table 2.0 

Air Conditioning Systems by Unit

Unit System 

Residential Apartments 5A, 5C, 5D

 

Ductless A/C unit, with remote 

condenser/compressor unit 

Residential Apartments 2A, 2B, 3B, 3C, 3D, 

4A, 4B, 4C, 4D 

Window/wall mounted units 

Baldwin Realty Company (3A) Ductless A/C with remote 

condenser/compressor unit 

Chiropractor’s Office Air handling unit with remote 

condenser/compressor unit (Atrium) 

Mattress Store Air handling unit with remote 

condenser/compressor unit (Atrium) 

Lemongrass Grill HVAC self contained system, makeup air 

system with hood, 2 ductless air systems with 

remote compressor/condenser units (Atrium) 

The Food Exchange Two air handling units with remote cooling 

tower (Atrium) 

Barber Shop Ductless A/C unit with remote 

condenser/compressor unit 

Building Condition 

Both Cedar Street and Liberty Street were closed to traffic after the WTC attack. Tenants were 

not permitted to enter the building. EPA, other governmental officials, and the building owner 

had been the only individuals authorized to enter the building since September 11, 2001. 

Presently, the residential spaces of the building are being re-occupied. The NYC Building 

Department inspected the building for structural integrity prior to EPA mobilization to the site. 

The building interior had been professionally cleaned by the building owner, Liberty Street 

Associates, LLC, shortly after the collapse of the WTC. Those cleaning activities focused on the 

removal of gross dust and debris. Floors, walls and ceilings were cleaned using HEPA vacuums, 

AFDs and wet wiping using soap and water. Personal items, such as furniture, clothing, 

electronics and kitchenware were not cleaned. The cleaning began on October 29, 2001 and was 

completed on November 11, 2001. The cleaning performed during this period was limited to the 

residential units, the common areas, the basement, the roof, and the Baldwin Realty Company 
 12

office. None of the other commercial spaces had been cleaned. 

Although the cleaning discussed above took place prior to implementation of the study, there had 

been significant redeposition of dust that had become airborne during the removal of the WTCrelated debris. At project assignment, the Chiropractor's Office and the Mattress Store were 

covered with inches of dust. The New York City Fire Department vacuumed dust from these 

units just prior to commencement of the study, as part of the recovery operation. Prior to 

cleaning, each unit was inspected and photographed to document its condition and contents. 

Bulk dust samples were collected. 

 

At the onset of the project, the condition of the units varied. Some units evidenced significant 

impact, while other units evidenced minimal impact by dust and debris related to the WTC 

incident. The units facing Liberty Street contained a larger quantity of dust than those facing 

Cedar Street. All of the residential and commercial units contained dust generated and 

redeposited by the work effort at ground zero. The amount of dust appeared to be dependent on 

the location of the unit with respect to its orientation to ground zero, and the degree of damage it 

had sustained during and after the collapse. 

During the initial cleaning, the doors and broken windows facing Liberty Street had been secured 

with plywood. However, they were not secured in a manner that would sufficiently seal them to 

prevent the entry of dust being generated during debris removal operations. Likewise, skylights 

located on the top floors of the building had been damaged and offered a pathway for dust to 

migrate into the building. These conditions existed during most of the WTC recovery effort. 

Building Contents

All of the residential rental units contained personal possessions. Some units were fully 

furnished, containing numerous personal possessions. Others contained few furnishings and/or 

personal possessions. The commercial units contained property customarily found in those types 

of business establishments. For example, the Mattress Store contained a display of twenty-five 

box springs and mattresses. The restaurants contained dining room tables, chairs, food 

preparation equipment, and food. 

Prior to commencement of cleaning operations, each tenant was contacted for the purpose of 

scheduling an appointment to determine the tenant’s wishes relative to disposition of their 

belongings. At the appointment, residents were suited with hooded, powered air-purifying 

respirators (PAPR), which pull ambient air through a filter. The residents were advised of the 

applicable aspects of the Health and Safety Plan, including dust and respiratory hazards. (The 

Health and Safety Plan is discussed in Section 2.2 below.) The residents then accompanied EPA 

into the apartments to review contents and to discuss the planned disposition of personal 

property. 

Residents were advised that retention of porous items was not recommended due to the 

difficulties associated with cleaning and testing. Residents were given the option of having their 

possessions: cleaned on the spot so the resident could immediately take possession, cleaned later 

and left in the apartment, or disposed of by EPA. 
 13

2.2 Personal Air Sampling, Personal Protective Equipment and Safety Risks

Personal air sampling was conducted for the workers that were participating in cleaning 

activities. Air sampling conformed to the site specific Air Surveillance Plan which is included in 

Section 8.0 of the Site Health and Safety Plan. The Site Health and Safety Officer conducted 

daily air sampling of employee exposure to three contaminants: asbestos, alpha-quartz and lead. 

On only one occasion during the study was the permissible level for alpha-quartz exceeded. 

Comprehensive information relative to health and safety is provided in Attachment E, Health and 

Safety Plan, Changes and Issues. 

Personal Protective Equipment

The study was conducted using the following levels of protection: 

• Level D+: This level of protection requires employees to wear safety glasses, disposable 

coveralls (Tyvek), disposable head coverings, disposable undergarments, disposable 

gloves, disposable boot covers, steel-toed boots, and hearing protection (if applicable). 

 

• Level C: This level of protection requires employees to supplement the above with an air 

purifying respirator (half face or full face PAPR) equipped with P100 cartridges. 

 

Safety Risks

At project onset, all units and common areas were inspected to assess building condition and to 

identify safety risks such as: gas, oil, and water leaks; perishable foods; rodent/insect 

infestations; damaged floors, walls, stairways, and elevators. All safety risks identified were 

eliminated prior to commencement of cleaning activities. The safety risks identified included 

electrical concerns, necessary building repairs, building access concerns, and rodent infestation. 

Additional details relative to safety risks are provided in Attachment E, Health and Safety Plan, 

Changes and Issues. 

 

2.3 Equipment 

EPA selected equipment similar or identical to the equipment observed in use by residents of 

lower Manhattan after the attack on the WTC, and tested use of this equipment in performing the 

cleaning of residential apartments at the project site. A commercially produced vacuum 

manufactured by NilfiskTM Advance Vacuum Systems was selected to provide industrial strength 

vacuuming technology, because many management companies who cleaned residential and 

commercial spaces in lower Manhattan purchased NilfiskTM equipment. Furthermore, confidence 

in the strength of the equipment had been evidenced in that it had been used by companies to 

clean federal buildings of anthrax prior to the study. 

In the aftermath of the WTC attack, vacuums were made available to the general public by the 

American Red Cross, and a vacuum reimbursement program was established by New York State 

in conjunction with FEMA. The vacuums made available to the public included vacuums with 

HEPA-filtration made by Eureka, Hoover and Mastercraft. Shop vacuums produced under 

the Ridgid brand and Craftsman brand were also observed in use by residents of lower 

Manhattan in the wake of the attack. High efficiency particulate air (HEPA) filters are capable of 

trapping and retaining at least 99.97 percent of all mono-dispersed particles of 0.3 micrometers in 
 14

diameter. The study tested cleaning using vacuums with and without HEPA filtration. 

An Air Filtration Device (AFD) is a local exhaust system with HEPA filtration that is capable of 

creating and maintaining a negative pressure differential between the outside and the inside of the 

work area. The AFD functions as a stand-alone piece of equipment in a room. During the study, 

the AFD was used as an air-polishing device, to capture dust particles that became airborne as a 

result of disturbances caused by the cleaning activities. The study tested cleaning with and 

without use of AFDs. 

Shop vacuums are easy to maneuver and are designed to pick up dust, shavings and debris. 

Upright vacuums are designed for use on horizontal surfaces such as floors. For purposes of the 

study: 

• The Eureka and Hoover upright vacuums were purchased both as devices with HEPA 

filtration and as devices with standard bag filtration. 

• The Ridgid and Craftsman shop vacuums were interchangeable. (Both can be changed 

from a standard cartridge filter to a HEPA-rated cartridge.) 

Wet vacuums are designed to clean horizontal porous surfaces with soap and water (shampoo). 

The wet vacuum used in the study was an upright model, providing a suction head lift of 103 

inches of water. Suction head is the measure of the suction capacity of a wet vacuum pump. In 

this case the wet vacuum pump is capable of lifting water 103 inches. 

Table 3.0 identifies equipment manufacturer and model used in the study. However, there was 

no intent of the study to compare manufacturers or the relationships between any particular 

devices. The objective of the cleanup was to confirm the effectiveness of cleaning of individual 

spaces using different equipment. 

Table 3.0

 Equipment Manufacturer and Model

Make Model

NilfiskTM CFM127 

Hoover (HEPA) U6459-900 

Hoover U5046-930 

Craftsman 113.170250 

Eureka (HEPA) S4170 

Eureka 7618 

Ridgid WD17351 

Carpet Express C4 (wet vac) 

ACSI (AFD) 400/600 

ForceAir 2,000 EC (AFD) 1000/2000 
 15

Field Observations of Equipment Used 

Upright vacuums are designed for use on horizontal surfaces such as floors. These use rotating 

devices to collect dust, and do not provide direct suction force. Brush attachments were used on 

the horizontal surfaces that could be reached. The hose attachments were limited according to 

their length and hose type. Plastic hose was not as resilient as rubber or cloth-covered hose. 

Attachments such as the crevice tools were used with ease because of their small profile. These 

were made of plastic; therefore, they were not a concern around potential electrical sources. The 

vacuums were noisy in the areas being cleaned due to the unfurnished state of the units, and 

accordingly, the enhanced acoustics. 

Shop vacuums are designed to provide easy unload of bulk debris. This type of vacuum typically 

provides a suction head lift of 48-51 inches of water. The shop vacuums were easy to maneuver 

even when pulled by the hose. They were also noisy in the unfurnished rooms. The hoses and 

attachments were larger in diameter than those of the upright vacuums. Crevice tools were larger 

than some spots to be cleaned. Cartridges loaded quickly with the fine dust being suctioned. Use 

of tube extensions and extra hose lengths facilitated the cleaning of vertical walls and ceilings. 

The cartridge filters required vacuuming to be cleaned of caked dust. Once this was completed, 

the suction increased dramatically. 

Commercial quality vacuums are designed for heavy use. This type of vacuum typically provides 

a suction head lift of 82-93 inches of water. Certain accessories were specially designed for 

specific applications and required some understanding of their operational adjustments. The 

added instrumentation facilitated monitoring the operation of the equipment. Fine dust clogged 

the primary filter cloth easily when used in extreme conditions; however, the HEPA filter when 

checked visually appeared free of dust. Only the cloth filter required vacuuming. The NilfiskTM

vacuum has a duel motor drive, providing an intense suction allowing for better lift of trapped 

material than that obtained by off-the-shelf equipment. Each NilfiskTM vacuum arrived with a 20 

amp rated plug that did not conform to the receptacles in the building. The appropriate plug ends 

were procured and installed. At 92.6 pounds, the vacuum can be handled by one person who 

maneuvers it in a manner similar to the maneuver of a shopping cart. However, two people are 

required to ascend stairs with the vacuum. 

Wet vacuums are designed to clean horizontal porous surfaces with soap and water (shampoo). 

The wet vacuums used in the study were an upright model, providing a suction head lift of 103 

inches of water. This vacuum was easy for one person to use. The vacuum required hot water to 

work properly. The hot water had to be hand carried to the site in five-gallon buckets because 

hot water was not available. The vacuum could spray water or soap individually or both soap 

and water at the same time. It uniformly sprayed soap and water on the carpet. The soap and 

water was allowed to penetrate the carpet, and was then suctioned off of the carpet. This 

spraying capability facilitated the removal of dirt, dust, and debris from the surface. 

Use of Swiffer brand cloths was discontinued quickly because of the small coverage area 

provided. The cloth quickly loaded with dust and dried out. It then streaked the surfaces being 

cleaned. Both wet and dry types of Swiffer cloths were used with the same result. Windex 

brand cleaner and water was used as a replacement for the Swiffer cloth. 

Use of water without soap on horizontal surfaces resulted in smearing and re-deposit of the dirt. 
 16

Water and ammonia-based cleaner (Windex) did not smear. No difference in the cleanliness of 

the carpets based on use of water or soap and water was observed visually. 

 

2.4 Cleaning Methods 

Eleven tests were developed to evaluate eleven different cleaning methods that may have been 

used to clean residential and commercial spaces. To evaluate the equipment under comparable 

and varying conditions, tests were performed using similar equipment to clean areas that had 

both significant and minimal dust. Every attempt was made to evaluate each test on two spaces. 

An outline of the tests and prescribed cleaning methods follows: 

Test 1 (A, B)

A. Cleaning was conducted using residential quality upright vacuums and shop vacuums that 

are available from Hoover, Eureka, Ridgid and Craftsman, as well as wet wiping. 

B. Cleaning was conducted with the vacuums used in Test A, with the addition of an AFD, 

as well as wet wiping. 

Test 2 (A, B)

A. Cleaning was conducted in up to two units using HEPA-filtered upright vacuums and 

HEPA-filtered shop vacuums available from Hoover, Eureka, Ridgid, and Craftsman, 

as well as wet wiping. 

B. Cleaning was conducted with the vacuums used in Test A, with the addition of an AFD, 

as well as wet wiping. 

Test 3 (A, B)

A. Cleaning was conducted in up to two units using commercial quality HEPA-filtered 

vacuums manufactured by Nilfisk TM Advance Vacuum Systems, as well as wet wiping. 

B. Cleaning was conducted in up to two units with the vacuums used in Test A, with the 

addition of an AFD, as well as wet wiping. 

Test 4 (A, B ,C, D, E)

A. Cleaning was conducted in commercial units and common areas using commercial 

quality HEPA-filtered vacuums manufactured by Nilfisk Advance Vacuum Systems8

. 

An AFD was used. Debris that could not be vacuumed was manually removed and 

disposed. 

B. (Wet Wiping.) Additional cleaning of wall surface areas was conducted to remove any 

residues that may not have been removed by vacuuming. Wiping of the walls with a 

damp soapy cloth was performed to remove residual dust that may have adhered to the 

walls from the force of the collapse. Wet wiping of walls was performed in the 

Chiropractor’s Office, the Mattress Store, Unit 3C, and Unit 3B. 

C. (Wet Vacuum.) Wall-to-wall carpeting was present in the Chiropractor’s Office, and the 

Mattress Store. The Chiropractor’s Office was wet-vacuumed using hot water; the 

Mattress Store was wet-vacuumed using hot water and carpet shampoo. 

D. (HVAC Cleaning.) HVAC systems are located in the Chiropractor's Office, the Mattress 

 8

Test method 4A is the same as test method 3B. Both test methods use the same cleaning equipment. Test 

method 4A was used in commercial units; test method 3B was used in residential units.
 17

Store, Lemongrass Grill, and The Food Exchange. These systems were cleaned by 

professional duct cleaning companies using standard cleaning procedures. 

E. (Wet Wiping.) Wet wiping was accomplished using water only on horizontal and vertical 

surfaces. This cleaning procedure was applied in the Chiropractor’s Office (bathroom tile 

floor and desktop), the Mattress Store (vinyl tile floor and window ledge), and the Barber 

Shop (vertical and horizontal surfaces). 

Modified Scope A – Lower Manhattan Cleaning Procedure

Added as an amendment to the original work plan, this cleaning method mirrored the procedure 

that EPA and NYC are implementing as part of the Indoor Air Residential Assistance-WTC Dust 

Cleanup Program, with the exception of the cleaning of personal belongings. This procedure is 

presented in Attachment F, Scope A - Lower Manhattan Cleaning Procedure. 

2.5 Mobilization 

Site activities began on June 17, 2002. Activities included mobilizing equipment and supplies, 

establishing a temporary office, identifying emergency support services and contacting vendors 

to arrange for specialized services and delivery of bulk items. Consolidated Edison was 

contacted and installed a shunt from the main trunk line to the building to provide electricity. 

Mobilization was completed by June 21, 2002. On June 24, 2002, WRS laborers arrived at the 

study building to begin work. Work continued through the third week of October 2002. 

Prior to commencement of the study, bulk samples were collected from three units in the 

building. Samples were collected from units that contained excessive amounts of dust, in an 

attempt to characterize the asbestos concentration in dust from worst case locations in the 

building. Samples were collected from the Chiropractor's Office, the Mattress Store and 

residential Unit 5C. Analysis of the samples indicated that less than one percent asbestos was 

present. Therefore, NYC asbestos licensing and certification regulations did not apply to the 

project. The federal OSHA asbestos standard (29 CFR 1926.1101) did apply to the project. At 

EPA direction, WRS assigned a team of asbestos-trained personnel to the project. Two licensed 

supervisors and two licensed workers were part of the operations team. All field operations 

personnel had completed all applicable training. 

2.6 Cleaning of Residential Units

 

The cleaning of each of the thirteen residential units was accomplished using the vacuum 

equipment type prescribed by the designated test, as presented in Attachment H, Synopsis of 

Cleaning Methods by Building Area and Fact Sheets. Management of waste was accomplished 

as the cleaning activities occurred. The sequence of procedures followed in each residential unit 

was the same. 

Security. The first cleaning activity in each unit related to the securing of potential access points 

from air infiltration, such as wall and window mounted air conditioning units. It was necessary to 

clean the access points as they were secured, to ensure that use of the access points after cleaning 

activities would not result in re-contamination. In order to limit unauthorized access to the 

building and to protect equipment and supplies during daytime work hours, previously damaged 

windows were secured and the entrance door to the building was continuously monitored. At the 
 18

end of the work day, the entrance door on the Cedar Street side of the building was locked. 

Where glass windows had been blown out, the temporary wood panels that had been installed for 

site security purposes were removed and reinstalled to afford complete closure. Intact windows 

were opened, and the jambs, sashes, and sills were cleaned thoroughly. The windows were then 

closed. In windows where an air conditioning unit was present, the air conditioning unit was 

removed from the window. The temporary protection on the exterior of the window was 

removed. The window cabinet that had housed the air conditioning unit was vacuumed, then 

covered with plastic to prevent air filtration. The air conditioning unit was vacuumed to remove 

loose dust, wrapped in plastic, and disposed. Wall mounted air conditioning units were removed 

from the wall, and sealed in plastic. The wall cabinet that had housed the air conditioning unit 

was vacuumed, then covered with plastic to prevent air infiltration. The air conditioning unit was 

vacuumed to remove loose dust, wrapped in plastic, and disposed. Disposal of the air 

conditioning units and installation of new self-contained ductless systems was performed by the 

building owner following completion of the study. 

Waste Management. At the onset of the project, due to limited space outside the building, it was 

necessary to line the hallways with plastic and to temporarily locate the items to be disposed, 

including personal possessions, until a roll-off container could be procured. As cleaning 

progressed, waste was accumulated and staged in the common areas by the elevator until a 

sufficient quantity was gathered to fill a roll-off container. The waste was wrapped in plastic to 

avoid cross-contamination of the hallways leading to the roll-off container. The removed 

materials were hand-carried through the hallways and down the stairwell to the roll-off container 

located outdoors, because the elevator was not functioning. 

Vacuuming. Vacuuming commenced at the entrance doorway of the unit. Working from the 

ceiling to the floor, toward the furthest area of the unit, all surfaces were vacuumed of loose dust 

and debris. Walls, ceilings, doors, pipes, ledges, closets, cabinets, shelving, trim, fixtures, and 

electrical outlets were vacuumed as they were encountered. Upon reaching the furthest point in 

the unit, the direction of cleaning was reversed and the same cleaning procedures were followed 

while returning to the point of origin at the entrance doorway. This procedure accomplished the 

cleaning of each unit twice using the designated cleaning method. 

Wet Wiping. Wet wiping was performed on all horizontal surfaces to remove dust. The WRS 

cleaning crew applied wet wiping to all horizontal surfaces, including the floor, as they 

progressed from the furthest point of the interior of the unit back to the door. Wet wiping was 

the last activity performed in the unit. 

Cleaning Air Conditioning Units. As noted in Section 2.1 above, two types of air conditioning 

systems were used in the residential living spaces: window/wall mounted air conditioners, and 

ceiling-mounted ductless air conditioners with remote condenser/compressor units. Bathroom 

fans also presented airflow routes that needed to be cleaned. Ceiling-mounted air conditioners 

were cleaned using HEPA-filtered equipment. The grills were removed to provide access to the 

interior. The condenser and compressor units on the roof were visually inspected and found to be 

clean. Removal of the ceiling cover to access the bathroom fan assemblies was necessary. The 

fan and motor were vacuumed; the fan housing was wet wiped. The interior of the exhaust duct 

was vacuumed to the first foot. The unit was reassembled and covered with poly sheeting. 
 19

Baseboard heating components, including the hydronic finned radiation systems, were cleaned. 

The protective covers were removed to expose the heating elements. The fins were then 

vacuumed and brushed simultaneously to remove dust. The space located under the heating 

element was vacuumed. The protective covers were reattached. 

Cleaning of Refrigerators, Dishwashers and Stoves (including exhaust fans). Prior to cleaning 

refrigerators, the appliance was unplugged and checked for food contents. If present, food was 

removed, bagged and disposed. The coils, underbody, compressor compartment, and back of 

each refrigerator was cleaned. Dust from the cooling coils was cleaned by elevating the 

appliance and simultaneously using vacuums and specialized brushes. Upon completing these 

activities the floor area where the refrigerator had been located was cleaned. Prior to cleaning, 

each stove unit was disconnected from its electric receptacle and gas line. Old exhaust fan lights 

and filters were removed and replaced. The first foot of the exhaust duct was vacuumed. The 

stove hood was vacuumed. Prior to cleaning dishwashers, the toe plate was removed and dust 

was vacuumed from under the appliance. After cleaning, all appliances were staged on plastic 

for subsequent removal by the owner, who had decided to replace them. 

Pre-Cleaning and Post-Cleaning Sampling. Pre-cleaning and post-cleaning sampling was 

performed to measure levels of COPC. Sampling data was reviewed and a decision regarding the 

need for additional cleaning was made. Wipe samples were collected from solid surfaces, both 

vertical and horizontal. A micro vacuum technique was used on sofas, mattresses, and porous 

materials. All sampling was conducted in accordance with the Quality Assurance Project Plan 

(QAPP) contained within Attachment G, Sampling and Analysis Plan. 

2.7 Cleaning of Commercial Units, Common Areas and Basement 

The cleaning of each commercial unit was accomplished using the vacuum equipment type 

prescribed by the designated test, as presented in Attachment H, Synopsis of Cleaning by 

Building Area and Fact Sheets. Management of waste was accomplished as the cleaning 

activities occurred. The sequence of procedures for vacuuming, wet wiping, waste management, 

and pre-cleaning and post-cleaning sampling mirrored the procedures used in the residential 

units. Cleaning of the HVAC systems and carpets presented the only significant differences from 

the procedures used to clean the residential units. A discussion of the procedures used to clean 

the HVAC systems and carpets in the commercial units and the procedures used to clean the 

common areas and the basement follows. 

HVAC Systems

The Chiropractor’s Office is located in the north end of the building at the Liberty Street address. 

It contains four patient rooms and an administrative section with a waiting room and a half bath 

facility. The air conditioning system in the unit is suspended from the third floor deck above a 

suspended acoustical tiled ceiling, located in the south end of the office space. It utilizes a 

common closed return to convey air to the blower cabinet. The supply trunk runs northward, 

supplying air to the balance of the rental space through supply diffuser grills. The system's 

condenser/compressor unit is located on the building's atrium roof area at the second floor 

elevation. 

 

The Mattress Store is located in the north end of the building at the Liberty Street address. Space 
 20

design is open throughout the unit, with a half bath, utility closet, and coat closet located in the 

south end of the room. The A/C system air handler is suspended under the third floor deck, 

above the suspended acoustical tiled ceiling. The system has two closed return air grills, a 

blower cabinet, and a supply trunk with a four way directional supply grill. The system's 

condenser/compressor unit is located in the building's atrium roof area at the second floor 

elevation. 

The procedures used to clean the Chiropractor’s Office and Mattress Store were identical. They 

mirrored the procedures used by HVAC cleaning companies when responding to ordinary HVAC 

cleaning requisitions. The following cleaning activities were conducted, in the following order: 

1. A clean plastic barrier was installed on the floor surface, three feet to either side of the 

suspended HVAC system, from the return intake to the furthest supply grill. 

2. Access points were selected at the return and supply sides of the duct system. A HEPAfiltered vacuum collection system was installed at the end of the supply run to collect 

internal dust. 

3. A rotating brush system was used to dislodge dust in the direction of the vacuum 

collection system. 

4. Degreasing agents were used on the HVAC internal coil units and cleaned. Supply grills 

were cleaned in a similar fashion. 

5. A biocide agent was applied to the duct's internal components and allowed to dry. 

6. An encapsulant was applied to the internal surfaces in order to ensure that residual dust 

was sealed in. 

7. The work area was cleaned of all equipment and plastic protection. 

8. The system was visually inspected at the air handling unit access panels for view of 

internal components. The duct work was visually inspected for dust in the return and in 

the supply lines. 

Carpet Cleaning (study)

Two methods were utilized to clean the carpets in the Chiropractor's Office and the Mattress 

Store: 1) Nilfisk vacuum with HEPA filtration, and 2) wet vacuuming. Carpets were wetvacuumed in the Chiropractor's Office and in the Mattress Store, using standard carpet 

shampooing equipment available to the public at rental stores. The carpets were cleaned twice, 

sampled, and disposed as porous material. Initially, the carpets were cleaned running in the 

direction of the room from front to back (Liberty Street to Cedar Street). The carpets were then 

cleaned again, in a direction crossing the room from side to side. 

Warm water only was used in the Chiropractor's Office. Soap (carpet shampoo) and warm water 

were used in the Mattress Store. Seven-in-One brand professional carpet shampoo, 

manufactured by Kent Investment Corporation, was diluted at two ounces per gallon of water. 

This dilution achieved 1,400-2,000 square feet of cleaning coverage. 

Common Areas (study)

The common areas were the first areas of the building cleaned, in order to provide a dust-free 

area for Level D entry through the common spaces, and to provide a safe location for equipment 

storage. All foyers, stairways, and halls were vacuumed using commercial quality HEPA 

vacuums. All horizontal and vertical surfaces in the common areas were wet wiped where 
 21

possible. The common areas were re-cleaned as necessary due to traffic. 

Stairwells were cleaned commencing at the Cedar Street doorway vestibule starting in the 

stairwell at the ground entrance and proceeding to the rooftop access door. The stairwells were 

then re-cleaned, following the same route back. The ceilings, walls, handrails, balusters, treads, 

risers, fire protection equipment, lighting, and trim were cleaned. 

The hallways of each floor were accessed through fire doors at the stairwell platform for each 

floor. Access to each floor remained closed until each stair well had been cleaned from bottom 

to top, and from top to bottom. The hallways were cleaned in the same manner as the stairwells, 

except that not all of the hallway walls were wet wiped. The second floor hallway floor was 

covered with vinyl tile. It was wet wiped. However, the third and fourth floor walls were made 

of plywood. Wallpaper originally applied to the wall surfaces had been removed, leaving a rough 

paste finish that was not conducive to wet wiping. 

Each hallway contained a utility room with a wall-enclosed trash chute that led to the basement 

of the building. Some items were discovered in the utility closets. Boxes that were unopened 

were vacuumed and left in place. Other items were packaged for disposal. The utility areas did 

not seem to be impacted by WTC dust. 

An elevator accessing each floor was located on the Cedar Street side of the building. It was not 

operational for the first two months of the project. Eventual repair of the elevator by others 

allowed access to the inner compartment. The elevator cab and the exterior top of the cab were 

vacuumed. 

Basement (study)

The basement of the building is comprised of separate rooms: a trash compactor room, a motor 

room associated with the elevator shaft, a common access area from the street, and a fire 

protection equipment room. The brick walls of the basement were encrusted with mud, 

indicating a high water level at some time in the building's history. These rooms were cleaned 

using commercial HEPA equipment. Loose debris related to stone and mortar deterioration was 

vacuumed from the walls and ledges of the base of the elevator shaft. Small rocks, paper, debris, 

and rodent carcasses were removed. 

 

2.8 Cleaning of Non-Study Commercial Units 

As discussed in Section 2.1, three commercial units were cleaned at the conclusion of the study, 

although they were not part of the study: Lemongrass Grill, the Food Exchange and the Barber 

Shop. These units were cleaned using cleaning methods as presented in Attachment H, Synopsis 

of Cleaning Methods by Building Area and Facts Sheets. 

 

The sequence of procedures for vacuuming, wet wiping, waste management, and pre-cleaning 

and post-cleaning sampling mirrored the procedures used in the residential units. Management 

of waste was accomplished as the cleaning activities occurred. Disposal of debris was handled in 

the same manner as in the residential units. Cleaning of the HVAC systems presented the only 

significant difference from the cleaning procedures used in the residential units. A discussion of 

the procedures used to clean the HVAC systems follows. 
 22

Lemongrass Grill occupies 2,351 square feet of space. It utilizes a self-contained re-circulating 

HVAC system, with no outdoor supply air, that is suspended above the floor in the south end of 

the restaurant. Return air enters the unit through a grill located in the front side of the unit. The 

air-handling unit is accessible through access doors on either side of the unit. The unit is 

enclosed with one-half-inch sheet rock. A supply trunk runs northward through the restaurant 

with three supply branches. A second source of duct is located adjacent to an exhaust hood for 

the cooking equipment. This system is separate from the HVAC and supplies makeup air to the 

hood area. Ambient air is drawn in from a grill above street level to a blower inside the building 

that leads to a supply trunk. Four supply grills are adjacent to the food exhaust hood. 

The Food Exchange is a restaurant that occupies 2,324 square feet of space, running from Cedar 

Street at the South end through to Liberty Street on the north end. Two side-by-side air handlers 

that share the supply air duct system are supported above a decorative tinned acoustical ceiling. 

The supply duct system splits mid-building and runs approximately fifty feet in two opposite 

directions. A water cooling tower is located outside the building on the building atrium. The air 

handlers use a common air return with no makeup air being drawn from outside the building. 

Access to the duct work on the north side of the building must be through the access grill 

openings, because the ceiling is enclosed in sheet rock. Access to the duct work on the south 

side is through a suspended ceiling. The ceiling tiles in the area of the duct work and the 

insulation wrapping the duct work were removed prior to cleaning the ducts. The space from the 

suspended ceiling to the upper deck, including the grid work, was vacuumed. An isolation wall 

was fabricated to bar the north side from the south side. 

The services of an HVAC consultant were secured to develop site-specific cleaning procedures 

for the Lemongrass Grill and the Food Exchange, and to stipulate necessary controls, protective 

measures, and standards for the cleaning and sampling confirmation process. These procedures 

are provided in Attachment I, HVAC Cleaning Procedures. 

 

The Barber Shop is situated below grade. The unit contains a ductless A/C system with a remote 

condenser/compressor unit. The condenser/compressor unit is located above the entrance door 

that accesses Liberty Street. The air handling system and the condenser/compressor unit was 

cleaned in an effort to remove accumulated residual dust and debris so that the units could be 

handled for disposal by the building owner. 

2.9 Cleaning of Building Exterior/Roof

Cleaning of the building exterior and the rooftop was accomplished and monitored by the 

NYCDEP. NYCDEP hired an asbestos abatement contractor to accomplish this task. Cleaning 

of the building exterior was initiated at approximately the same time that cleaning of the interior 

of the building began. NYCDEP subcontractors were required to vacuum and wash the building 

exterior twice over a two-day period before acceptable results were achieved. 

The building has two roof elevations: An atrium roof at the second floor level, and a roof at the 

fifth floor level. Four residential compressor/condenser units are situated on the fifth floor roof. 

These service ductless air conditioning units in the residential apartments. Prior to the study, 

these units were cleaned by outside contractors. Three commercial compressor/condenser units 

are situated on the atrium roof of the building. These units service the Chiropractor's Office, the 
 23

Mattress Store and the Lemongrass Grill. These three units were cleaned as part of the study. 

The Food Exchange air conditioning system utilizes a water-cooling tower located on the atrium 

roof that was also cleaned. 

2.10 Summary of Cleaning Activity 

Table 4.0 presents an overview of the tests used to clean residential and common areas of the 

building as well as a description of that area. A full description of the cleaning activities in each 

area can be found in Attachment H, Synopsis of Cleaning Methods by Building Area and Fact 

Sheets. 

Table 4.0 

 Summary of Cleaning Activity 

Unit/Area Equipment Used Cleaning 

Method

Wet Wipe 

 

First 

Cleaning 

Second 

Cleaning

Third 

Cleaning

2A Ridgid shop vacuum and 

Hoover upright, AFD 

Test 1B Horizontal 

Surfaces 

soap/water Asbestos/ 

overload

Cleared for 

COPC 

2B Industrial HEPA vacuum Test 3A Horizontal 

Surfaces 

soap/water Cleared for 

COPC 

2nd Floor 

Common 

Area 

Industrial HEPA vacuum, 

AFD 

Test 4A Horizontal & 

Vertical 

Surfaces 

soap/water Cleared for 

COPC 

3A Craftsman shop vacuum 

and Eureka upright, 

w/HEPA and AFD 

Test 2B Horizontal 

Surfaces 

soap/water Cleared for 

COPC 

3B Industrial HEPA vacuum, 

AFD 

Scope A Horizontal & 

Vertical 

Surfaces 

soap/water Asbestos/ 

overload and 

lead (wipe) 

exceedence

Cleared for 

COPC 

Craftsman shop vacuum 

and Eureka upright 

3C Test 1A 

Industrial HEPA vacuum, 

AFD 

Test 3B 

(1A)(1A) 

(3B) 

Horizontal & 

Vertical 

Surfaces 

soap/water Asbestos/ 

overload and 

lead (micro 

vacuum) 

exceedence 

Asbestos/ 

overload and 

MMVF (air) 

exceedance

Cleared for 

COPC 

3D Ridgid shop vacuum and 

Hoover upright 

Test 1A Horizontal 

Surfaces 

soap/water Asbestos/ 

overload

Cleared for 

COPC 

3rd Floor 

Common 

Area 

Industrial HEPA vacuum, 

AFD 

Test 4A Horizontal & 

Vertical 

Surfaces 

soap/water Cleared for 

COPC 

4A Craftsman shop vacuum 

and Eureka upright, 

HEPA 

Test 2A Horizontal 

Surfaces 

soap/water Asbestos/ 

overload and 

alpha-quartz 

(air) 

exceedence

Cleared for 

COPC 

4B Ridgid shop vacuum and 

Hoover upright, HEPA 

and AFD 

Test 2B Horizontal 

Surfaces 

soap/water Cleared for 

COPC 

4C Craftsman shop vacuum 

and Eureka upright 

Test 1A Horizontal 

Surfaces 

soap/water Cleared for 

COPC 
 24

Table 4.0 

 Summary of Cleaning Activity 

Unit/Area Equipment Used Cleaning 

Method

Wet Wipe 

 

First 

Cleaning 

Second 

Cleaning

Third 

Cleaning

4D Ridgid shop vacuum and 

Eureka upright, HEPA 

Test 2A Horizontal 

Surfaces 

soap/water Lead (wipe) 

exceedance

Cleared for 

COPC 

4th Floor 

Common 

Area 

Industrial HEPA vacuum, 

AFD 

Test 4A Horizontal & 

Vertical 

Surfaces 

soap/water Cleared for 

COPC 

5A Industrial HEPA vacuum, 

AFD 

Test 3B Horizontal 

Surfaces 

soap/water Lead (wipe) 

exceedance

Cleared for 

COPC 

5C Industrial HEPA vacuum Test 3A 

Industrial HEPA vacuum, 

AFD 

Test 3B 

(3A)(3A)(3B)

Horizontal 

Surfaces 

soap/water Asbestos/ 

overload and 

MMVF (air) 

exceedance

Asbestos/ 

overload and 

MMVF (air) 

exceedance

Cleared for 

COPC 

(asbestos: 

modifiedaggressive 

sampling)9

5D Industrial HEPA vacuum , 

AFD 

Test 3B Horizontal 

Surfaces 

soap/water Cleared for 

COPC 

5th Floor 

Common 

Area 

Industrial HEPA vacuum, 

AFD 

Test 4A Horizontal & 

Vertical 

Surfaces 

soap/water Asbestos/ 

overload

Cleared for 

COPC 

Cedar St. 

Stairwell 

Industrial HEPA vacuum, 

AFD 

Test 4A,4B Horizontal & 

Vertical 

Surfaces 

soap/water Cleared for 

COPC 

Elevator 

Shaft 

Basement 

Area 

Industrial HEPA vacuum, 

AFD 

Test 4A No Wet Wipe Cleared for 

COPC 

Liberty St. 

Stairwell 

Industrial HEPA vacuum, 

AFD 

Test 4A,4B Horizontal & 

Vertical 

Surfaces 

soap/water Alphaquartz (air) 

exceedance

Cleared for 

COPC10 

 

9

 Asbestos air clearance criterion was met using modified aggressive air sampling protocol; however, the clearance criterion was not 

met using aggressive air sampling. 10Silica analytical methods were note received until after project completion. However, a single elevated sample result in a low

occupancy area of the building was not considered to be a health hazard. Therefore, no further cleaning was conducted. 

2.11 Difficulties Encountered and Resolutions 

A discussion of the difficulties encountered during the cleaning portion of the study, along with a 

discussion of how they were resolved is presented below. 

Site Conditions 

Rummaging. Site debris, abandoned possessions, and construction related waste materials were 

wrapped in plastic sheeting, and carried to a staged roll-off container. When filled to capacity, the 
 25

containers were transported off site for disposal, and replaced with empty containers. It was 

discovered that people were rummaging through the contents of the roll-off containers after 

personnel left the site for the day. To deter this activity, it was necessary to monitor the debris 

box at night. The staff of the cleaning contractor was utilized to provide security. Shift hours 

were adjusted to add two-hour increments of coverage by crew members until midnight. This 

eliminated the rummaging. 

Elevator. The elevator was out of service from project commencement until late August. 

Therefore, it was necessary to manually carry individual items down the stairways of many floors 

for disposal in the roll-off container. Many unanticipated labor hours were dedicated to hand 

carrying the disposable items. 

Hot Water. The building was without gas service; therefore, hot water was unavailable. Hot 

water was only used for the shampooing of carpets. Hot water was obtained from a local 

delicatessen and manually transported in five-gallon buckets as needed. Cold water was used to 

clean the remainder of the facility. 

Electric Service. EPA contacted Consolidated Edison directly to install a shunt from the main 

trunk line to the building to provide electricity by the mobilization date. 

Office Space. The location and the condition of the building did not allow for office space. Nor 

was there sufficient space proximal to the site to set up an office trailer. Therefore, office space 

to accommodate copying and administration was established in a hotel several blocks away. 

Because the building was without telephone service, in order to enable continuous 

communication, personnel carried cell phones at all times. 

Spoiled Food. At project commencement, information obtained by others indicated that all 

foodstuffs in the building were removed shortly after September 11, 2001. However, a walk-in 

box in the Lemongrass Grill contained perishable food that had been overlooked. Large 

quantities of fish and shrimp were discovered that had been spoiling for nine months. The odor 

was noxious. Additionally a previously undiscovered chest freezer was filled with spoiled food 

including fish, shrimp, beef and miscellaneous food items that required removal. Approximately 

200 pounds of spoiled food was collected, double bagged and disposed of utilizing a NYC 

Sanitation Truck. Water from melted ice and rotting food debris at the bottom of the freezer was 

removed and the area was sanitized. Similarly, the refrigerators in the apartments were to have 

been emptied of all solid contents by others shortly after the World Trade Center attack. 

However, residual foods remained. These spoils were also removed and disposed. The building 

owner subsequently disposed of all kitchen appliances, including the refrigerators. 

Rodents. Dead rats and mice were prevalent in the basement areas, in the elevator shaft, and in 

some rental units. Rodent droppings were evident on floor surfaces throughout these areas. The 

remains of rodents were collected, bagged and deposited in the roll-off containers. Live rats were 

encountered in the Lemongrass Grill and the Food Exchange. The assistance of the building 

owner was sought to hire an exterminator. 

Coordination

Tenant Response. Residents did not consistently appear at the scheduled time for appointments 
26

to address disposition of personal belongings. This caused slight delays to cleaning efforts. It 

was necessary to adjust the cleaning schedules to minimize the delays. 

Parking. Although an arrangement had been made with the Office of Emergency Management 

(OEM) for EPA and its subcontractors to park vehicles on Cedar Street, the NYC Police 

Department ticketed vehicles without regard to established verbal agreements. Time expended to 

respond to tickets was significant. Communications with the OEM were helpful at times. 

Building Contractor Coordination. The Baldwin Realty Company, the resident management 

company of the building owner, had not performed any repairs on the building since September 

11, 2001, because the entire area had been off limits to the public. Shortly after the study began, 

the management company’s repair and maintenance contractors commenced activities including: 

replacement of windows, doors, sashes, and suspended ceilings; repair of the elevator; and 

removal of refrigerators and stoves. EPA and its contractors were required to closely coordinate 

activities with these contractors to avoid interference with the study, and to ensure that areas 

were cleaned and sampled before the contractors commenced their work. At onset of the project, 

meetings were scheduled to discuss activities and to provide a schedule of cleaning activities. 

The intent was to clean and clear areas prior to the performance of any maintenance activities. 

Prior to commencing cleaning, signs were erected and caution tape was placed around the areas 

undergoing cleaning, to avoid interference by other contractors. Unfortunately, work conducted 

by window repair and floor contractors created dirt and debris that necessitated re-cleaning of 

some units. This situation occurred between sampling events only once, in Unit 5C, between the 

collection of air samples for asbestos. 

Health and Safety Concerns 

PPE. The only health and safety concern related to PPE was fogging goggles. Fogging goggles 

caused personnel some degree of visual difficulty. The problem was solved by applying an antifogging agent to the lens of the goggles. The requirement for goggles was downgraded to a 

requirement for safety glasses when it was determined that the amount of dust produced was not 

irritating to an employee’s eyes. 

Personal Air Sampling. A very small percentage of the personal air samples for asbestos were 

overloaded with dust and could not be analyzed by the laboratory. 

Baseboard Heating Cleaning. Intensive labor was required in order to remove visible dust from 

the baseboard heating systems. 

Heat Stress. Heat exhaustion, heat cramps, and heat stroke were a major concern due to the 

extreme heat experienced during cleanup activities. The heat stress hazard was mitigated by 

mandating frequent breaks to replenish fluids and lower core body temperatures. 

Heavy Lifting. All units contained heavy objects that were moved, disposed of, or lifted to 

enable cleaning underneath. The Site Health and Safety Officer frequently instructed WRS 

employees relative to proper lifting techniques. All personnel were directed to obtain assistance 

when lifting objects over fifty pounds. The non-functioning elevator resulted in a quantity of 

heavy lifting that significantly exceeded what had been anticipated at project commencement. 
27

3. Sampling Activities

3.1 Baseline Sampling

Prior to initiating cleanup activities, bulk composite samples were collected in each of the three 

units which had sufficient dust present to collect a bulk sample. These Units included 5C, and 

the two commercial units on the second floor (Mattress Store, Chiropractor’s Office). The bulk 

samples were analyzed for alpha-quartz, MMVF, lead, PAH, dioxins/furans, and asbestos. Due 

to insufficient volume, the sample collected from Unit 5C was not analyzed for PAH or 

dioxins/furans. 

 

EPA's evaluation of the analytical data from the bulk composite sampling event was utilized in 

identifying COPC concentrations present in the settled dust, and assisted EPA in determining the 

applicability of regulatory standards and in identifying potential health and safety concerns. 

Analytical results of the bulk sampling are not included in this report. 

In addition to the collection of bulk composite samples, baseline air samples were also collected. 

These samples were collected from the breathing level (5-6 ft.) and from the main living area of 

the units which, based upon visual observations, were both the least and the most impacted by 

the WTC disaster. Samples collected from the least impacted apartments (Units 3A and 3B) 

represented a best case test and were analyzed for asbestos and MMVF. Samples collected from 

the most impacted areas (Mattress Store, Chiropractor’s Office) represented a worst case test and 

were analyzed for dioxin/furans, PAH, asbestos and MMVF. 

EPA's evaluation of the baseline air sampling event determined that the airborne concentrations 

of PAH and dioxin/furans were not a health concern; therefore, the collection of additional air 

samples of these parameters was not necessary. This decision was based on the analysis of 

baseline bulk and air PAH and dioxin/furan samples which were collected from the most 

severely impacted units. As the air samples did not contain PAH or dioxin/furans at 

concentrations above the stringent primary clearance criterion as established in the 

COPC/Benchmarks Report11, EPA determined that airborne PAH or dioxin/furans would also 

not be present in the other less impacted units. EPA's decision to eliminate PAH and 

dioxin/furan analyses for air samples was later confirmed through the collection of reference 

samples in Unit 4C. These samples were analyzed for PAH and the analytical result was found 

to be below the clearance criterion of 0.2 μg/m3

. 

3.2 Pre-Cleaning Sampling 

Prior to cleaning activities, wipe samples were collected from each of the thirteen residential units 

and the two commercial units included in the study (Chiropractor’s Office, Mattress Store). The 

wipe samples were collected from a 10 cm x 10 cm area using dedicated, disposable templates 

which were left in-place. One sample was collected from the surface of each of the following four 

non-porous locations within each unit: ceiling, wall, bare floor, and horizontal surface (e.g., 

counters, tables, dressers, window sills). All samples were analyzed for asbestos, MMVF, lead, 

PAH, dioxins/furans, and alpha-quartz. Exceptions to this were the ceiling samples which were 

 11 U.S. Environmental Protection Agency. (September, 2002). World Trade Center Indoor Air Assessment: 

Selecting Contaminants of Concern and Setting Health-Based Benchmarks. 
28

analyzed for asbestos only, and horizontal surfaces which were also analyzed for total dust. 

Generally, pre-cleaning air sampling was not conducted because of concerns that given the 

presence of significant levels of dust, using the aggressive technique might make overloading the 

filters more likely. 

Pre-cleaning sampling also included the collection of micro vacuum samples from up to six 

porous surface areas (e.g., carpets, furniture fabric) in twelve of the thirteen residential units, and 

both commercial units included in the study (Mattress Store, Chiropractor’s Office). The 

samples were collected from a 10 cm x 10 cm area using dedicated, disposable templates which 

were left in place. Each unit contained a different number of porous surface sample areas, except 

Unit 4B which did not have any porous surfaces from which to collect a sample. The micro 

vacuum samples were analyzed for lead and for asbestos (TEM). 

3.3 Sampling During Cleaning 

All sampling conducted during cleaning activities was undertaken for the purpose of 

documenting potential worker exposure to asbestos, lead and alpha-quartz. Samples were 

collected from the breathing zone (5-6 ft.) in the center of the room being cleaned. The pumps 

were run the entire length of the work day (no less than 8 hours) and were not stopped during 

breaks. As reflected in Attachment A, Personal Monitoring Data, on only one occasion during 

the study was the permissible exposure level exceeded for alpha-quartz. 

3.4 Post-Cleanup Sampling 

Post-cleaning sampling conducted was designed to determine if the cleaning methods attained 

the health-based benchmarks established in EPA's COPC/Benchmarks Report12. Following 

cleanup activities in the thirteen residential and two commercial units, post-cleanup wipe and 

micro vacuum samples were collected in the same manner as the pre-cleanup samples. 

 12 U.S. Environmental Protection Agency. (September, 2002). World Trade Center Indoor Air Assessment: 

Selecting Contaminants of Concern and Setting Health-Based Benchmarks. 

The post-cleanup samples were collected from locations adjacent to the pre-cleanup sampling 

locations whenever possible. In situations where the pre-cleanup sampling location was now 

inaccessible, a new sample was collected as close to the initial location as possible. Post-cleanup 

air samples were collected in each of the thirteen residential units and in each of the two 

commercial units included in the study. The analyses for these samples included MMVF, alphaquartz, lead, and asbestos. The building's four hallways, two stairwells, basement and elevator 

shaft were also included in this sampling event; however, the elevator shaft did not include 

alpha-quartz analysis. 

All of the aforementioned post-cleanup area air samples were collected following a minimum 

settling period of sixteen (16) hours and included the implementation of aggressive and/or 

modified-aggressive air sampling techniques. Aggressive sampling employs the use of a leaf 

blower followed by circulating fans, whereas the modified-aggressive sampling employs the 

circulating fans without the initial use of a leaf blower. Aggressive sampling was utilized because 
 29

of its past use in accordance with the Asbestos Hazard Emergency Response Act (AHERA), for 

determining the effectiveness of asbestos abatement in schools. Modified-aggressive air sampling 

was also used because it is more representative of long-term trends of typical household activity 

such as those expected within the study building. 

While there is a greater potential for overloading under aggressive sampling conditions, this test 

is representative of a worst case scenario. Modified-aggressive air sampling, however, has less 

of a potential for overloading and is typical of household activity patterns. (Difficulties 

associated with sample overloading are discussed in detail in Section 3.8 below.) 

 

Other post-cleanup sampling efforts were implemented to evaluate the efficiency of the cleaning 

of the HVAC systems within the two commercial units included in the study (Chiropractor’s 

Office, Mattress Store). Post-cleanup air samples were collected in close proximity to the HVAC 

return ducts and analyzed for asbestos, MMVF, alpha-quartz and lead. 

3.5 Sampling Supplies and Equipment

Table 5.0 specifies the supplies and equipment required and utilized to collect samples, as 

described in the QAPP.13 

Table 6.0 specifies the micro vacuum equipment and the National Air Duct Cleaners Association 

(NADCA)-recommended method for sample collection that was used. 

Table 7.0 specifies the air sampling equipment that was used. 

 13 The QAPP is presented within Attachment G. 
 30

Table 5.0 

Wipe Sampling Equipment 

Analyte Sample Media Wetting Solution Sample Jar

Asbestos 6inch x 6 inch, Super Polx 1200 

Class 10 Cleanroom Wipes 

10 ml of a 50/50 mixture of 

2-propanol and DI water 

4 oz. glass

MMVF 6 inch x 6 inch, Super Polx 1200 

Class 10 Cleanroom Wipes 

10 ml of a 50/50 mixture of 

2-propanol and DI water 

4 oz. glass 

Alpha-quartz, 

Calcite, Gypsum, 

Total Dust 

“Ghost Wipes” 

(SKC Inc., No. 225-2414) 

Distilled water 4 oz. glass 

Lead “Ghost Wipes” 

(SKC Inc., No. 225-2414) 

Distilled water 4 oz. glass 

PAH’s 3 inch x 3 inch, Cotton Gauze 2 ml of acetone Amber glass or glass jars 

wrapped in aluminum foil 

Dioxins/Furans 3 inch x 3 inch, Cotton Gauze 2 ml of acetone Amber glass or glass jars 

wrapped in aluminum foil 

 

Table 6.0

Micro Vacuum Equipment and NADCA-Recommended Method for Sample Collection14 

Analyte Sample Media Flow Rate Sample Pump

Asbestos 0.45 μm (25 mm) MCE filter 

micro vacuum cassette 

2 L/min. Diaphram pump

Lead 0.8 μm (37 mm) MCE filter 

micro vacuum cassette 

2.5 L/min. Diaphram pump

NIOSH 0500 0.8 μm (37 mm) MCE filter 

matched weight cassette 

15 L/min. 

 

Gilian® Air Con-2

 14Pump flow rates were measured at the start of each day. A primary dry cell calibrator (BIOS DC-Lite) 

was used to establish the flow rates of the diaphram pump. A Gilibrator-2 high flow wet cell calibrator was used to 

establish the flow rates of the Gilian® AirCon-2 high volume air samplers. Flow rates were recorded. 
 31

Table 7.0

Air Sampling Equipment15 

Analyte Sample 

Media

Flow 

Rate

Sample 

Period

Sample 

Pump

Notes

Asbestos 

(TEM and PCM) 

0.45 μm and 0.8μm (25 

mm) MCEF cassette 

10 

L/min. 

480 min. Gilian® 

Air Con-2 

None 

MMVF 0.45 μm and 0.8μm (25 

mm) MCEF 

cassette 

10 

L/min. 

480 min. Gilian® 

Air Con-2 

None 

Alpha-quartz, 

Calcite, Gypsum 

5 μm (37 mm) 

PVC cassette 

2.5 

L/min. 

480 min. SKC Model 

224-PCXR8 

Aluminum 

cyclone 

needed 

Lead 0.8 μm (37 mm) 

MCEF cassette 

10 

L/min. 

480 min. Gilian® 

Air Con-2 

None 

PAH’s 2 μm (37 mm) 

PTFE filter followed by 

150 mg, 8 x 110, XAD-2 

sorbent tube 

2 

L/min. 

480 min. Gilian® 

Air Con-2 

None 

Dioxins/Furans 32 mm quartz filter 

followed by polyurethane 

foam (PUF) 

15 

L/min. 

56 hour Gilian® 

Air Con-2 

One 

3.6 Sample Analysis and Management 

Laboratories Utilized and Analyses Performed

Inorganic analyses, which included MMVF, alpha-quartz, calcite, gypsum, lead, total dust, pH 

and total particulates not otherwise specified (NIOSH 0500) were performed by EMSL 

Laboratories (EMSL), at the corporate headquarters located at 107 Haddon Avenue, Westmont, 

NJ. The analyses for asbestos using PCM, PLM, and TEM were performed by EMSL 

Laboratories, 307 West 38th St., New York, NY. Organic analyses were provided by Paradigm 

Analytical, 2627 North Chase Parkway SE, Wilmington, NC. These analyses included PAH and 

Dioxins/Furans. 

 15Pump flow rates were measured before and after sample collection. Pumps were calibrated before each 

use and the flow rate was confirmed following the sample period. A primary dry cell calibrator (BIOS DC-Lite) was 

used to establish the flow rates of the SKC personal sampling pumps. A Gilibrator-2 High Flow Wet Cell Calibrator 

was used to establish the flow rates of the AirCon-2 high volume air samplers. Calibrating for alpha-quartz, calcite, 

gypsum and dioxins/furans also required separate flow chambers. Flow rates were recorded on Air Sampling Data 

Sheets. 
 32

Sample Handling and Shipment

Samples transported to EMSL were typically picked up by an EMSL courier the day after sample 

collection. A small percentage of the EMSL samples, and all of the samples transported to 

Paradigm Analytical, were shipped via Federal Express. Several samples were damaged during

shipment and are so documented in Attachment J, Reporting of Analytical Results. 

At the conclusion of each sampling event, chain of custody (COC) records were generated 

electronically using Scribe7 v2.2 software. A copy of the COC records were printed, signed, and 

shipped with the samples to the lab. The only COC records not generated in this fashion were 

those for the April 30, 2002 bulk sampling event and the personal monitoring samples collected 

by WRS. 

3.7 Analytical Data

Validation

The validation of all organic and inorganic analytical data was performed in accordance with the 

QAPP. Validation of inorganic data was performed by Weston. Validation of organic data was 

performed by EPA Region 2 personnel. 

Reporting

All analytical results were tabulated subsequent to validation and are provided in Attachment J, 

Reporting of Analytical Results. 

3.8 Difficulties Encountered and Resolutions 

Sample Overloading

Initially, many of the asbestos analyses were reported by the laboratory as overloaded. After 

consulting with the laboratory, it was determined that a reported value of overloaded did not 

mean that the sample cassette was overloaded with asbestos. Rather, the filter contained 

particulate matter that could obstruct the field of view of the laboratory analyst. 

The only resolution to the problem of sample overloading was the repeated cleaning of the units. 

It was only after the presence of settled dust was minimized through cleaning that the aggressive 

and modified-aggressive sampling techniques were able to be used to collect air samples that did 

not have overloaded filters. 

Data Reporting

Given that nearly 3,000 samples were collected and submitted for analysis during the course of the 

study, EPA’s inability to receive laboratory data in a timely manner was a major and ongoing 

problem. The greatest impact was felt in the scheduling of time and resources for the re-cleaning 

of the units. The delay in receiving data resulted in the inability to determine if re-cleaning was 

necessary, which in turn complicated the scheduling of day-to-day work and resource 

requirements. In many cases, the last minute redirection of the cleaning and sampling contractor’s 

resources was required in an effort to maintain productivity. Furthermore, many of the data 

packages were incomplete upon receipt, delaying EPA’s ability to validate the data in a timely 

manner, and resulting in delays in issuing final building clearance and the completion of this 

report. 
 33

Another issue which impacted EPA’s data reporting was the rejection of data during the validation 

process. Several wipe samples and one air sample that were analyzed for dioxin/furans were 

initially reported as rejected. Fortunately, the rejected dioxin/furans data could still be utilized to 

obtain a Toxicity Equivalent value by calculating an Estimated Maximum Possible Concentration 

(EMPC) for the dioxin/furans that were rejected. In addition to the dioxin/furans, several lead 

samples (air, wipe and micro vacuum) were rejected for lab blank, field blank or method blank 

contamination. The only other sample that was rejected was an inorganic wipe sample that was 

rejected due to a laboratory blank being out of the control range. 

The wipe sampling analytical results for alpha-quartz, calcite, gypsum, cristobalite, tridymite, 

and total dust were uncertain, thereby rendering the data unusable. 

3.9 Modifications to the Study 

Modified Aggressive Air Sampling

Both modified-aggressive and aggressive air sampling were used in determining if asbestos air 

clearance criteria could be achieved in four units. The use of modified-aggressive air sampling 

was included after repeated problems with overloaded filters were encountered and the further 

evaluation of aggressive sampling determined that conditions created by aggressive air sampling 

were not typical of household living patterns. 

Wet Wipe using Windex/Wipe with Water Only

The work plan initially called for use of soap and water to accomplish wet wiping. Windex®

brand was used because it is a commonly used cleaner believed to be readily available in most 

people’s homes. Furthermore, it is non-damaging to most surfaces, from wood to fiberglass. 

Typically, this soap does not “over-suds”. It provides an effective detergent-based protection of 

surfaces when combined with cold water. This was important, because hot water was not 

immediately available at the project site. During the project, it was determined that a wet wipe 

procedure using water only would also be evaluated. Water only was used on the desktop and in 

the bathroom of the Chiropractor’s Office, and in the entire Barber Shop. Water only was also 

used on the vinyl tiles under the carpeted area in the Mattress Showroom. 

Horizontal Wet Wipe Only/Horizontal and Vertical Wet Wipe 

The majority of the tests of cleaning methods were accomplished using horizontal wet wipe only, 

to assist in determination of whether vacuuming without wet wiping would result in acceptable 

cleaning. However, application of both horizontal and vertical wet wipe was tested in Units 3B 

and 3C. Application of both horizontal and vertical wet wiping in Unit 3B was consistent with 

the procedures called for relative to testing of Scope A - Lower Manhattan Cleaning Procedures. 

Unit 3C was selected for an additional test using both horizontal and vertical wet wiping, because 

that apartment was heavily impacted by WTC dust. The cleaning test called for the use of nonHEPA-filtered vacuums and no AFD. 

Use of Swiffer Brand Cloths

The use of Swiffer brand cloths for application of wet wipe was also evaluated. Swiffer cloths 

were utilized during the cleaning of the first residential unit 5D. 
 34

Modified Scope A - Lower Manhattan

Shortly after the study was initiated, the procedures for the WTC Dust Cleanup Program were 

developed. Once those procedures were finalized, it was decided to include a modified Scope A 

cleaning procedure developed by the WTC Dust Cleanup Program as one of the cleaning methods 

in the study. 

3.10 Supplemental Sampling Activities

Sampling of "Non-Study" Units

As noted previously, three commercial units located within the study building, but not part of the 

initial study, were also cleaned by EPA. Pre-cleanup samples collected from two of the three nonstudy commercial units (Food Exchange, Lemongrass Grill) were limited to the collection of wipe 

samples from within the HVAC system ducts. Analysis of these samples included lead, MMVF, 

alpha-quartz and asbestos. Pre-cleanup samples collected from the remaining non-study 

commercial unit (Barber Shop) included a bulk sample of insulation material which was collected 

to confirm its asbestos content. Pre-cleanup wipe samples were also collected for analysis of lead, 

dioxin and PAH. 

Post-cleanup area air samples were collected from the three non-study commercial units (Barber 

Shop, Lemongrass Grill, and The Food Exchange). The analyses for these samples included 

MMVF, asbestos, alpha-quartz, and lead. Additional air samples were collected in the 

Lemongrass Grill and The Food Exchange in close proximity to the HVAC return ducts, in order 

to evaluate the effectiveness of the HVAC cleaning method.16

Post-cleanup wipe samples were collected from the inside surfaces of the HVAC ducts within two 

of the three non-study units (Lemongrass Grill, The Food Exchange) and analyzed for asbestos, 

MMVF, alpha-quartz and lead. Additionally, samples were collected from the inside surfaces of 

the ducts within the non-study units utilizing a modified micro vacuum technique; these were 

collected in accordance with the National Air Duct Cleaners Association (NADCA) ACR 2002 

procedures referenced in Attachment I, and analyzed for Total Particulates Not Otherwise 

Regulated (PNOR) following NIOSH 0500 methodology. 

3.11 Mercury Vapor Using Lumex® Analyzer

 

On June 19, 2002, with the assistance of Dr. Clyde Johnson, Assistant Professor of Environmental 

Sciences at Medgar Evers College (City University of New York), EPA measured mercury vapor 

levels in the thirteen residential units, three commercial units, and all common areas in the study 

building. All sampling was conducted under pre-cleaned conditions utilizing a Lumex® RA-915+ 

Mercury Vapor Analyzer. Measurements were performed at the breathing zone of infants and 

adults (6 inches and 5 feet above the floor), using continuous, real-time monitoring and data 

logging of mercury levels. Further explanation of mercury sampling activities and results are 

included in Attachment K, Summary of Mercury Vapor Results Using the Lumex® Vapor 

Analyzer. 

 16See Attachment I, HVAC Cleaning Procedures. 
35

4. Analytical Results

Introduction

This section reviews analytical results by building area and comparative results. The discussion 

of analytical results by building area mirrors to a large degree Attachment H, Synopsis of Cleaning 

Methods by Building Area and Fact Sheets, adding information relative to analytical results as 

they relate to the residential or commercial unit under review. Briefly summarizing the logistics 

of each unit, the cleaning methods employed, the number of times the unit was cleaned, and 

providing a narrative description of the analytical results for that unit, the narratives follow the 

tables in Attachment J, Key for Analytical Tables and Reporting of Analytical Results. 

Attachment J provides the analytical results for each sample that was collected and analyzed. 

Results reported in units of f/cc are associated with PCM analyses and results that are reported in 

units of 5>5u/cc are associated with PCMe analyses. A key at the beginning of Attachment J 

identifies the units associated with each result. 

Analytical results are presented in alphabetical order, with details relative to samples that were 

collected before and after any cleaning event. If a compound is not present for a unit or if a 

sample type is not present for a compound, then it is not listed in the text. It is of note that in the 

case of asbestos wipe and micro vacuum samples, a certain number of structures needed to be 

detected to be reported as being detected above the detection limit. This number was in the range 

of 6-8 structures. Therefore, asbestos may be indicated as being present even though the sample 

result is reported as below the detection limit. Samples were analyzed for 23 PAH compounds. 

The PAH results are reported as toxicity equivalency factors (TEF) values. These values are the 

sum of seven of the most toxic carcinogenic PAH17, modified to reflect benzo[a]pyrene 

equivalents. The PAH analyses could potentially identify an additional 16 PAH compounds (23 

total). These additional compounds are less toxic and in general are not carcinogenic, thus they 

are not included in the TEF calculations. Fifteen (15) samples that were analyzed for PAH 

detected at least one of these additional 16 less toxic compounds. These samples, along with the 

non-TEF modified concentrations detected, are reported in Table 8.0. The values in this table 

cannot be directly compared to the primary clearance value of 300 ug/m2

 because the primary 

clearance value represents a TEF value; however, the value listed for each PAH sample in 

Attachment J reflects the value that can be compared to the primary clearance value. 

 

The dioxin results were modified using a toxicity equivalency method (TEQ), that takes into 

account the toxicity difference between the different congener groups, and the results are reported 

in 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) equivalents. The TEQ value reported in the table 

represents the estimated maximum potential concentration (EMPC). The TEQ EMPC value used 

data that indicated the presence of a congener above zero but did not meet all of the QA/QC 

reporting level criteria. This value represents the highest potential concentration of dioxin that 

may be present. 

 17These seven compounds were used to calculate the toxicity equivalence factor (TEF): benzo[a]anthracene, 

benzo[a]pyrene, benzo[b]fluoranthene, benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene, indeno[1,2,3-

cd]pyrene. 
36

Table 8.0 

 PAH Analytical Results 

Unit Number Sample 

Identification Category Matrix Analyte Final Results

Final 

Results 

Units

2A 9094-W-2A-003 PAH Wipe Fluoranthene 320 μg/m2

2A 9094-W-2A-003 PAH Wipe Phenanthrene 250 μg/m2

2A 9094-W-2A-003 PAH Wipe Pyrene 300 μg/m2

3C 9094-W-3C-003 PAH Wipe Anthracene 320 μg/m2

3C 9094-W-3C-003 PAH Wipe Benzo[a]anthracene 760 μg/m2

3C 9094-W-3C-003 PAH Wipe Benzo[e]pyrene 450 μg/m2

3C 9094-W-3C-003 PAH Wipe Benzo[a]pyrene 680 μg/m2

3C 9094-W-3C-003 PAH Wipe Benzo[b]fluoranthene 980 μg/m2

3C 9094-W-3C-003 PAH Wipe Benzo[g,h,i]perylene 520 μg/m2 *

3C 9094-W-3C-003 PAH Wipe Benzo[k]fluoranthene 330 μg/m2

3C 9094-W-3C-003 PAH Wipe Chrysene 830 μg/m2

3C 9094-W-3C-003 PAH Wipe Fluoranthene 1700 μg/m2

3C 9094-W-3C-003 PAH Wipe Indeno(1,2,3-c,d)pyrene 560 μg/m2 *

3C 9094-W-3C-003 PAH Wipe Phenanthrene 1300 μg/m2

3C 9094-W-3C-003 PAH Wipe Pyrene 1600 μg/m2

3D 9094-W-3D-003 PAH Wipe Fluoranthene 280 μg/m2

3D 9094-W-3D-003 PAH Wipe Pyrene 280 μg/m2

4C 9094-A-4C-016 PAH Air Biphenyl 0.12 μg/m3 *

4C 9094-A-4C-016 PAH Air 2,6-Dimethylnaphthalene 0.12 μg/m3 *

4C 9094-A-4C-016 PAH Air Fluorene 0.06 μg/m3 *

4C 9094-A-4C-016 PAH Air 1-Methylnaphthalene 0.18 μg/m3

4C 9094-A-4C-016 PAH Air 2-Methylnaphthalene 0.34 μg/m3

4C 9094-A-4C-016 PAH Air Naphthalene 0.46 μg/m3

4C 9094-A-4C-016 PAH Air Phenanthrene 0.12 μg/m3 *

4C 9094-A-4C-017 PAH Air Dibenzofuran 0.06 μg/m3 *

4C 9094-A-4C-017 PAH Air 2,6-Dimethylnaphthalene 0.13 μg/m3 *

4C 9094-A-4C-017 PAH Air Fluorene 0.03 μg/m3 *

4C 9094-A-4C-017 PAH Air 1-Methylnaphthalene 0.19 μg/m3

4C 9094-A-4C-017 PAH Air 2-Methylnaphthalene 0.35 μg/m3

4C 9094-A-4C-017 PAH Air Naphthalene 0.48 μg/m3

4C 9094-A-4C-017 PAH Air Phenanthrene 0.13 μg/m3 *

4C 9094-W-4C-003 PAH Wipe Fluoranthene 270 μg/m2

4D 9094-W-4D-003 PAH Wipe Benzo[a]anthracene 270 μg/m2

4D 9094-W-4D-003 PAH Wipe Benzo[b]fluoranthene 320 μg/m2

4D 9094-W-4D-003 PAH Wipe Chrysene 300 μg/m2

4D 9094-W-4D-003 PAH Wipe Fluoranthene 580 μg/m2

4D 9094-W-4D-003 PAH Wipe Phenanthrene 410 μg/m2

4D 9094-W-4D-003 PAH Wipe Pyrene 530 μg/m2

5C 9094-W-5C-003 PAH Wipe Benzo[b]fluoranthene 260 μg/m2

5C 9094-W-5C-003 PAH Wipe Fluoranthene 430 μg/m2

5C 9094-W-5C-003 PAH Wipe Phenanthrene 300 μg/m2

5C 9094-W-5C-003 PAH Wipe Pyrene 370 μg/m2

Barber Shop 9094-W-BS-013 PAH Wipe Biphenyl 380 μg/m2
37

Table 8.0 

 PAH Analytical Results 

Unit Number Sample 

Identification Category Matrix Analyte Final Results

Final 

Results 

Units

Chiropractor’s 

Office 9094-A-CHR-012 VOCs Air Acenaphthene 0.18 μg/m3

Chiropractor’s 

Office 9094-A-CHR-012 VOCs Air 2,6-Dimethylnaphthalene 0.21 μg/m3

Chiropractor’s 

Office 9094-A-CHR-012 VOCs Air 1-Methylnaphthalene 0.28 μg/m3

Chiropractor’s 

Office 9094-A-CHR-012 VOCs Air 2-Methylnaphthalene 0.58 μg/m3

Chiropractor’s 

Office 9094-A-CHR-012 VOCs Air Naphthalene 0.83 μg/m3

Chiropractor’s 

Office 9094-A-CHR-012 VOCs Air Phenanthrene 0.21 μg/m3

Chiropractor’s 

Office 9094-A-CHR-013 VOCs Air Acenaphthene 0.19 μg/m3

Chiropractor’s 

Office 9094-A-CHR-013 VOCs Air 2,6-Dimethylnaphthalene 0.22 μg/m3

Chiropractor’s 

Office 9094-A-CHR-013 VOCs Air 1-Methylnaphthalene 0.28 μg/m3

Chiropractor’s 

Office 9094-A-CHR-013 VOCs Air 2-Methylnaphthalene 0.57 μg/m3

Chiropractor’s 

Office 9094-A-CHR-013 VOCs Air Naphthalene 0.82 μg/m3

Chiropractor’s 

Office 9094-A-CHR-013 VOCs Air Phenanthrene 0.22 μg/m3

Chiropractor’s 

Office 9094-W-CHR-002 PAH Wipe Fluoranthene 190 μg/m2*

Chiropractor’s 

Office 9094-W-CHR-002 PAH Wipe Phenanthrene 160 μg/m2*

Chiropractor’s 

Office 9094-W-CHR-002 PAH Wipe Pyrene 180 μg/m2*

Chiropractor’s 

Office 9094-W-CHR-003 PAH Wipe Fluoranthene 230 μg/m2*

Chiropractor’s 

Office 9094-W-CHR-003 PAH Wipe Phenanthrene 180 μg/m2*

Chiropractor’s 

Office 9094-W-CHR-003 PAH Wipe Pyrene 230 μg/m2*

Mattress Store 9094-W-MAT-003 PAH Wipe Fluoranthene 570 μg/m2

Mattress Store 9094-W-MAT-003 PAH Wipe Phenanthrene 330 μg/m2

Mattress Store 9094-W-MAT-003 PAH Wipe Pyrene 520 μg/m2

Mattress Store 9094-W-MAT-004 PAH Wipe Fluoranthene 120 μg/m2*

Mattress Store 9094-W-MAT-004 PAH Wipe Phenanthrene 90 μg/m2

* Estimated Concentration (J) 

Table 8.0 contains the PAH analytical results that were identified as being above the detection 

limit. These values cannot be directly compared to the health-based benchmark, which is based 

on the TEF calculations. The TEF values are listed in the tables in Attachment J. 
38

At times during the project, the laboratory chose to perform analyses on samples that were neither 

requested by EPA nor specified on the Chain of Custody. This was most evident in the case of 

wipe samples that were collected for total dust. The QAPP required the collection of one precleaning and one post-cleaning sample for total dust from each unit. These samples (wipes) also 

served as the samples used for the analysis of crystalline silica (alpha-quartz, cristobalite, 

tridymite, calcite and gypsum). The crystalline silica sample was also collected pre-cleaning and 

post-cleaning; however, it was collected from three locations in the unit. Upon submitting the 

samples to the laboratory, specific direction was provided to the lab regarding which samples 

were to be analyzed for total dust. The laboratory however, chose to prepare all three samples for 

the total dust analysis rather than prepare the samples specified on the chain of custody. 

A mercury vapor investigation was conducted as part of the study. The mercury vapor 

investigation was conducted using a Lumex® analyzer18 that revealed a mean mercury vapor 

concentration of 53.6 ng/m3 (range 3 - 210 ng/m3), demonstrating that air samples within the 

building tested below EPA's Reference Concentration of 300 ng/m3. A statistical evaluation of 

the results of the mercury vapor investigation is presented in Attachment K, Summary of Mercury 

Vapor Results using the Lumex® Vapor Analyzer. 

(Note: The following section does not include data and discussion of wipe sampling results for 

alpha-quartz, calcite, gypsum, cristobalite, tridymite and total dust. The analytical results for 

these parameters were uncertain thereby rendering these data unusable.)

 

Discussion of Analytical Results by Building Area 

Unit 2A – This unit is located on the second floor. It is a 1,335 sq. ft. loft with one bedroom 

facing Cedar Street. The unit has hardwood floors. The unit presented minimal dust 

accumulation in the dwelling with the exception of the baseboard-heating units. The windows 

were not blown in. All personal items were disposed except for a couch and chairs. 

Cleaning Method – The unit was cleaned using Test 1B: use of a Ridgid shop vacuum and 

Hoover upright vacuum for vacuuming the floors and other surfaces. Neither vacuum was 

equipped with a HEPA filter. An AFD was used during the cleaning process. In addition, all 

horizontal surfaces were wet wiped. This cleaning method was used for each cleaning event. 

Cleaning Results – The unit met the primary clearance criteria listed in Table 1.0 for each 

compound after being cleaned twice. 

 

Asbestos

Before Cleaning Samples – Pre-cleaning micro vacuum and wipe samples were collected 

for asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. Three of the four micro vacuum samples detected chrysotile. All five wipe 

samples detected chrysotile, although two of the samples were below the detection limit. 

 18The instrument has a detection limit of 2 ng/m3

.
39

Post 1st Cleaning Samples – Three air, three micro vacuum, and five wipe samples were 

collected. The three air samples were analyzed using PCM, TEM AHERA, and PCMe. 

The PCM results were all below the secondary numeric criterion of 0.01 f/cc. The TEM 

AHERA and PCMe analysis could not be conducted due to overloading of particulate 

material. 

 

The results for the three micro vacuum samples indicate that asbestos was present at levels 

generally lower than those observed before cleaning. One of the samples was identified as 

non-detect, although asbestos was detected below the detection limit. 

The results for the five wipe samples that were collected indicate that asbestos was present 

in two of the five samples at lower concentrations than the pre-cleaning samples. One of 

the two samples in which asbestos was detected was below the detection limit. 

Post 2nd Cleaning Samples – Six asbestos air samples were collected after the second 

cleaning. The samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM 

results were all below the secondary numeric criterion of 0.01 f/cc and were at lower 

concentrations than after the first cleaning. The TEM AHERA results were all below the 

secondary numeric criterion of 0.022 S/cc; two of the six samples were below the 

detection limit. The PCMe results were at or below the primary clearance criterion of 

0.0009 S/cc; three of the six samples were below the detection limit. 

 Dioxin

Before Cleaning Samples – Four pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The concentrations of dioxin detected were lower than those of the precleaning samples. The TEQ concentration for each sample was below the primary 

clearance criterion of 4 ng/m2. 

Gypsum

Before Cleaning Samples – Pre-cleaning samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. Because gypsum was below the detection limit 

in all of the samples collected, no additional samples were collected for analysis of 

gypsum. 

Lead

Before Cleaning Samples – Four micro vacuum samples and four wipe samples were 

collected. Lead was detected in three of the four micro vacuum samples at concentrations 

below the comparison value of 25 μg/ft2 one sample was below the detection limit. Three 

of the four wipe samples had detectable concentrations of lead above the primary 

clearance criterion of 25 μg/ft2

, while the fourth sample was below the detection limit. 
40

Post 1st Cleaning Samples – Two air samples, three micro vacuum samples and four wipe 

samples were collected after the first cleaning. The two air samples, all three micro 

vacuum samples, and three of the four wipe samples were below the detection limit. The 

fourth wipe sample was above detection limit but below the primary clearance criterion. 

The results from the first cleaning indicate that the cleaning technique was effective in 

removing the elevated concentrations of lead observed prior to the first cleaning. Because 

the primary clearance criterion for lead was met after the first cleaning, no additional 

samples were collected for analysis of lead. 

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. This indicates that the cleaning method used 

was able to reduce the pre-cleaning concentration of alpha-quartz. Because all of the 

samples were below the detection limit after the first cleaning, no additional samples were 

collected for analysis of alpha-quartz. 

Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

calcite. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limits after the first cleaning, no additional samples were collected for analysis 

of cristobalite. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limits after the first cleaning, no additional samples were collected for analysis 

of tridymite. 

 

 MMVF

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. One of the 

four samples was below the detection limit; MMVF was detected in the other three 

samples. 
41

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results for the air samples indicate that MMVF was present; 

however, the samples were below the primary clearance criterion of 10 S/L. The results of 

the five wipe samples indicate that MMVF was still present after the first cleaning; 

however, the concentrations detected were lower than the pre-cleaning samples. There is 

not a clearance criterion for MMVF in settled dust. Since the air samples were below the 

primary clearance criterion and the MMVF in settled dust was reduced after the first 

cleaning, no additional samples were collected for analysis of MMVF. 

PAH

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. Three of the 

four samples were below the detection limit; the TEF for these samples was below the 

primary clearance criterion. PAH compounds were detected in the fourth sample; 

however, the calculated TEF was below the primary clearance criterion of 300 μg/m2

. 

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

of the samples were below the detection limit and the TEF for each sample was below the 

primary clearance criterion of 300 μg/m2

. Because all of the samples were below the 

detection limit and the primary clearance criterion after the first cleaning, no additional 

samples were collected for analysis of PAH. 

Unit 2B – This unit is located on the second floor. It is a 946 sq. ft. loft with two separate 

bedrooms facing Cedar Street. The unit has hardwood floors and no carpeting. The unit 

presented minimal dust accumulation, except around baseboard-heating elements. All windows 

were intact. All personal items except a couch were disposed of prior to cleanup. 

Cleaning Method – The unit was cleaned using Test 3A: an industrial HEPA-filtered vacuum. 

An AFD was not used. All horizontal surfaces were wet wiped. 

Cleaning Results – The unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned once. 

 Asbestos

Before Cleaning Samples – Three micro vacuum and four wipe samples were collected for 

analysis of asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. Chrysotile was detected in all three micro vacuum samples. Three of the four 

wipe samples detected chrysotile. One of the three samples also contained Anthophyllite. 

However, the result for this sample, as well as for the fourth wipe sample, was below the 

detection limit. 

Post 1st Cleaning – Test 1B – Three air, four micro vacuum, and five wipe samples were 

collected. Three air samples were analyzed using PCM, TEM AHERA, and PCMe. The 

PCM results were all below the secondary numeric criterion of 0.01 f/cc. All three TEM 

AHERA results were below the secondary numeric criterion of 0.022 S/cc. Likewise, all 

three PCMe results were below the primary clearance criterion of 0.0009 S/cc. The results 

for four micro vacuum samples indicate that asbestos was present at levels similar to, and 

in some cases higher than, those observed before cleaning. The results for the five 
42

wipe samples indicate that asbestos was present in three of the five samples. Two of the 

three samples in which asbestos was detected were below the detection limit. 

Dioxin

Before Cleaning Samples – Three pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the TEQ concentration for each sample was below the 

primary clearance criterion of 4 ng/m2. 

 

Gypsum 

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in either sample. 

Lead

Before Cleaning Samples – Three micro vacuum samples and three wipe samples were 

collected. Lead was detected in one of the three micro vacuum samples at a concentration 

below the comparison value of 25 μg/ft2. Two of the three wipe samples had detectable 

concentrations of lead; one sample was above the primary clearance criterion of 25 μg/ft2

. 

The third sample was below the detection limit. 

Post 1st Cleaning Samples – Two air samples, four micro vacuum samples and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion. The four micro vacuum samples and one of the four wipe 

samples, were below the detection limit. Three of the four wipe samples were above the 

detection limit, but below the primary clearance criterion of 25 μg/ft2. The results from 

the first cleaning indicate that the cleaning technique was effective in removing the 

elevated concentrations of lead that were observed prior to the first cleaning. 

Post 2nd Cleaning Sampling – Because the cleaning was conducted prior to the 

establishment of a risk-based cleanup level for lead in air, this unit was re-cleaned in an 

effort to meet the established primary clearance criterion. Sampling results following the 

second cleaning indicate levels below the primary clearance criterion. 

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 
43

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

calcite. 

Cristobalite 

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples and four wipe samples were collected after 

the first cleaning. All of the samples were below the detection limit. 

 

MMVF

Before Cleaning Samples – Three pre-cleaning wipe samples collected. MMVF was 

detected in all three. 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results for the three air samples indicate that MMVF was present; 

however, all samples were below the primary clearance criterion of 10 S/L. The results of 

the five wipe samples indicate that MMVF remained present in four of the five samples 

after the first cleaning, but the concentrations detected were lower than the pre-cleaning 

samples. There is not a clearance criterion for MMVF in settled dust. Because the air 

samples were substantially below the primary clearance criterion and the MMVF in settled 

dust was reduced after the first cleaning, no additional samples were collected for analysis 

of MMVF. 

PAH

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. All three 

samples were below the detection limit. The TEF for each sample was below the primary 

clearance criterion. 

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

of the samples were below the detection limit. The TEF for each sample was below the 

primary clearance criterion of 300 μg/m2

. Since all of the samples were below the 

detection limit and the primary clearance criterion after the first cleaning, no additional 

samples were collected for analysis of PAH. 

Second Floor Hallway – The second floor hallway has vinyl tiles on the floor, and walls made of 

sheet rock covered with wallpaper glue. The ceiling is also made of sheet rock, and is painted. 

Cleaning Method – This area was cleaned using Test 4A and Test 4B. Test 4A used an industrial 
44

HEPA filtered vacuum and an AFD. Test 4B was a soap and water wet wipe of the ceiling and 

floor only. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned once. 

Asbestos

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – Two post-cleaning air samples were collected. The two air 

samples were analyzed using PCM, TEM AHERA, and PCMe. The PCM results were all 

below the secondary numeric criterion of 0.01 f/cc. Similarly, the TEM AHERA results 

were all below the secondary numeric criterion of 0.022 S/cc. The PCMe results were all 

below the primary clearance criterion of 0.0009 S/cc with one of the two samples being 

below the detection limit. 

Dioxin

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – There were no post-cleaning samples collected 

Gypsum

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. 

Lead

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

two air samples were below the detection limit. 

Alpha-Quartz

Before Cleaning Samples – There were no pre-cleaning samples collected.

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Calcite

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

Cristobalite

Before Cleaning Samples – There were no pre-cleaning samples collected. 
45

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

Tridymite

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

MMVF

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

results indicate that MMVF was present in one of the samples; however, the concentration 

was below the primary clearance criterion of 10 S/L. Because the air samples were below 

the primary clearance criterion, no additional samples were collected for analysis of 

MMVF. 

PAH

Before Cleaning Samples – There were no pre-cleaning samples collected. 

Post 1st Cleaning Samples – There were no post-cleaning samples collected. 

Unit 3A – This 1,368 sq. ft. loft faces Cedar Street and is utilized as office space for the Baldwin 

Realty Company. Carpet is present on half of the floor space; the remainder is hardwood floors. 

The area is furnished with 10-12 wooden desks, files and office equipment. The unit presented 

minimal dust accumulation in the dwelling. No windows were blown in. 

Cleaning Method – This unit was cleaned using Test 2B: a Craftsman shop vacuum and a 

Eureka upright vacuum with HEPA filter. An AFD was used during the cleaning process. All 

horizontal surfaces were wet wiped. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned once. 

 Asbestos

Before Cleaning Samples – Four air, four micro vacuum and four wipe samples were 

collected for asbestos. These samples indicate that asbestos was present in the unit prior 

to cleaning. All four of the micro vacuum samples detected chrysotile. One of the four 

wipe samples detected chrysotile. The PCM results for both air samples were below the 

secondary numeric criterion, and the two PCMe air results were below the primary 

clearance criterion of 0.0009 S/cc. 

 

Post 1st Cleaning Samples – Three air, four micro vacuum and five wipe samples were 

collected for asbestos. Three asbestos air samples were analyzed for PCM, TEM AHERA, 

and PCMe. The PCM results indicate that one sample was below the secondary 
46

numeric criterion and the other two could not be analyzed due to particulate overloading of 

the filter. The TEM AHERA results were below the secondary numeric criterion for two 

samples. The third sample could not be analyzed due to particulate overloading of the 

filter. Of the three air samples analyzed using PCMe, one sample could not be analyzed 

due to overloading of particulate material. The other two samples were below the primary 

clearance criterion of 0.0009 S/cc. 

The results of the four micro vacuum samples indicate that asbestos was present at levels 

generally lower than those observed before cleaning. One of the samples was identified as 

non-detect. 

The results of the five wipe samples indicate that asbestos was present in all but one 

sample; however, two of the samples were identified as non-detect. One of the non-detect 

samples had an elevated detection limit due to the presence of non-asbestos particulate 

matter. 

 Dioxin

Before Cleaning Samples – Three pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the concentrations of dioxin were similar to the precleaning samples. The TEQ concentration for each sample was below the criterion of 4 

ng/m2. 

 

 Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected above the detection limit for either sample. 

 Lead

Before Cleaning Samples – Four micro vacuum samples and three wipe samples were 

collected. Lead was not detected in any of the micro vacuum samples. One of the wipe 

samples was below the detection limit and one wipe sample was below the primary 

clearance criterion of 25 μg/ft2

. The third wipe sample exceeded the primary clearance 

criterion at 38.9 μg/ft2

. 

Post 1st Cleaning Samples – Two air samples, four micro vacuum samples, and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion but were qualified as rejected, due to field blank 

contamination. The results of the micro vacuum and wipe samples show that, while two 

of the micro vacuum and two of the wipe samples exceeded the detection limits, all 

samples met the primary clearance criterion and the comparison values for lead after the 

first cleaning. 
47

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All 

samples were below the detection limit. 

Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All 

were below the detection limit. 

MMVF

Before Cleaning Samples – Two pre-cleaning air samples and three pre-cleaning wipe 

samples were collected. The two air samples had MMVF detected, but were below the 

primary clearance criterion. The three wipe samples had MMVF detected in 

concentrations from 57.23 S/cm2

 to 801.24 S/cm2. 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. All of the air sample results indicate that MMVF was present at levels 

below the primary clearance criterion of 10 S/L. All of the wipe sample results were 

below the detection limit of 22.89 S/cm2 . This indicates that the cleaning method was 

able to reduce the pre-cleaning concentration of MMVF. 

 PAH 

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. All three 

were below the detection limit. The TEF for each sample was below the primary clearance 

criterion. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected. All four 

were below the detection limit. The TEF for each sample was below the primary clearance 

criterion of 300 μg/m2

. 
48

Unit 3B – This unit is located on the third floor. It is a 968 sq. ft. loft with three bedrooms facing 

Cedar Street. The unit has hardwood floors. No windows were blown in and the unit presented 

minimal dust accumulation, with the exception of the baseboard heating units, which contained 

visible dust. All of the tenant’s personal items remained in the unit and were cleaned. 

Cleaning Method – This unit was cleaned using the Scope A cleaning procedures: industrial 

HEPA-filtered vacuum of all surfaces. An AFD was used. All surfaces were wet wiped. This 

cleaning method was used for each cleaning event in this unit. 

Cleaning Results – This unit met the primary clearance criteria listed in Table 1.0 for each 

compound after being cleaned twice. 

Asbestos

Before Cleaning Samples – Two air, three micro vacuum and four wipe samples were 

collected for asbestos. These samples indicate that asbestos was present in the unit prior 

to cleaning. The two air samples that were collected were analyzed using PCM and 

PCMe. One PCM result was below the secondary numeric criterion of 0.01 f/cc. The 

other PCM result was above the secondary numeric criterion. The PCMe results indicate 

that both samples were below the detection limit and below the primary clearance criterion 

of 0.0009 S/cc. Two of the three micro vacuum samples detected chrysotile. The third 

sample was below the detection limit. Three of the four wipe samples were below the 

detection limit. The fourth one detected chrysotile at a concentration slightly above the 

detection limit. 

Post 1st Cleaning – Three air, three micro vacuum and five wipe samples were collected to 

evaluate if additional cleaning events were necessary. The three air samples that were 

collected indicated that all three PCM results were below the secondary numeric criterion 

of 0.01 f/cc and that the TEM AHERA and PCMe analyses could not be conducted due to 

overloading of particulate material. Due to inconclusive PCMe results, a second cleaning 

was conducted. 

The results for the three micro vacuum samples indicate that asbestos was present at levels 

similar to those observed before cleaning. 

The results for the five wipe samples that were collected indicate that asbestos was present 

in all five of the samples at slightly higher concentrations than the pre-cleaning samples. 

One of the five samples in which asbestos was detected was below the detection limit. 

Post 2nd Cleaning – Three asbestos air samples were collected after the second cleaning. 

The samples were analyzed for PCM, TEM AHERA, and PCMe. Two of the three PCM 

results were below the detection limit; all three were below the secondary numeric 

criterion of 0.01 f/cc. All three TEM AHERA results were below the detection limit and 

below the secondary numeric criterion of 0.022 S/cc. All three PCMe results were below 

the detection limit and below the primary clearance criterion of 0.0009 S/cc. All of the air 

asbestos results after the second cleaning were at lower concentrations than the precleaning samples and the samples collected after the first cleaning. This indicates that the 

cleaning techniques used were efficient at removing asbestos to levels that were below 
49

detection limits and below the primary clearance and secondary numeric criteria. 

Dioxin

Before Cleaning Samples – Four pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that there was dioxin present; however, the TEQ 

concentration for each sample was below the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the concentrations of dioxin detected were similar to 

the pre-cleaning samples and that the TEQ concentrations for each sample were well 

below the primary clearance criterion of 4 ng/m2. Because the dioxin samples were below 

the primary clearance criterion for all of the samples collected, no additional samples were 

collected for analysis of dioxin. 

Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. Because gypsum was below the detection limits 

for all of the samples collected, no additional samples were collected for analysis of 

gypsum. 

Lead

Before Cleaning Samples – Three micro vacuum samples and four wipe samples were 

collected. The results indicate that all three micro vacuum samples were below the 

detection limit and at concentrations below the comparison value of 25 μg/ft2. Two of the 

four wipe samples had detectable concentrations of lead; however, they were below the 

primary clearance criterion of 25 μg/ft2. The third sample was below the detection limit. 

The fourth sample was lost at the laboratory and was not analyzed. 

Post 1st Cleaning Samples – Two air samples, three micro vacuum samples and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion of 1.0 μg/m3

. All three micro vacuum samples and one of the 

four wipe samples were below the detection limit. Two wipe samples were below the 

primary clearance criterion and the fourth wipe sample was above the primary clearance 

criterion. Due to the one lead sample being above the primary clearance criterion, as well 

as the asbestos samples that exceeded the primary clearance criterion, this unit was 

cleaned a second time. 

Post 2nd Cleaning Samples – Two lead wipe samples were collected after the second 

cleaning in the area where the post-first cleaning lead exceedance occurred. One of the 

samples was received broken at the laboratory and was not analyzed. The other sample 

was below the detection limit and below the primary clearance criterion. The results from 

the second cleaning indicate that the cleaning technique was effective in removing the 

elevated concentration of lead that was observed after the first cleaning. 
50

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

two air samples were below the detection limit. Because the samples were below the 

detection limits after the first cleaning, no additional samples were collected for analysis 

of alpha-quartz. 

Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

calcite. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

cristobalite. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

tridymite. 

MMVF

Before Cleaning Samples – Two pre-cleaning air samples and three pre-cleaning wipe 

samples were collected. One of the two air samples was above the primary clearance 

criterion of 10 S/L and the other air sample was above the detection limit. The results for 

all three of the wipe samples indicate that MMVF was above the detection limit. This 

indicates that MMVF was present in the unit prior to cleaning. 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results for the three air samples indicate that MMVF was present; 

however, all three were below the primary clearance criterion of 10 S/L. The results of the 

five wipe samples indicate that three of the five samples were below the detection limit 

and the remaining two samples were at the detection limit. Although MMVF was still 

present after the first cleaning, the concentrations detected were much lower than the precleaning samples. There is not a clearance criterion for MMVF in settled dust. Because 

the air samples were below the primary clearance criterion and the MMVF in settled dust 
51

was reduced after the first cleaning, no additional samples were collected for analysis of 

MMVF. 

PAH

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. All four 

samples were below the detection limit. The TEF for each sample was below the primary 

clearance criterion. 

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

of the samples were below the detection limit. The TEF for each sample was below the 

primary clearance criterion of 300 μg/m2. Because all of the samples were below the 

detection limit and the primary clearance criterion after the first cleaning, no additional 

samples were collected for analysis of PAH. 

Unit 3C – This unit is located on the third floor. It is a 655 sq. ft. loft with two bedrooms facing 

the WTC site. The unit has hardwood floors with no carpet. The unit presented significant 

accumulation of dust in the dwelling. The windows were blown in. The majority of personal 

items were disposed of prior to cleaning. 

Cleaning Method – This unit was cleaned using Test 1A: a Craftsman shop vacuum and a 

Eureka upright vacuum with no HEPA filter. An AFD was not used. This method was used 

for the first two cleaning events. For the third cleaning event the method was changed to Test 

3B: an industrial HEPA filtered vacuum and an AFD. All horizontal and vertical surfaces were 

wet wiped in conjunction with each method. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned three times. 

 Asbestos

Before Cleaning Samples – Four micro vacuum and four wipe samples were collected for 

asbestos. These samples indicate that asbestos was present in the unit prior to cleaning. 

All four of the micro vacuum samples detected chrysotile. Three of the four wipe samples 

detected chrysotile; one also detected amosite. The fourth wipe sample was below the 

detection limit. 

 

Post 1st Cleaning Samples – Three air, four micro vacuum, and five wipe samples were 

collected for asbestos. The PCM and PCMe analyses could not be conducted due to 

overloading of particulate matter on the filters. 

The results of the four micro vacuum samples indicate that asbestos was present at levels 

higher than those observed before cleaning. 

 

Two of the five wipe samples were below the detection limit, although one of these 

samples did detect chrysotile. Results of the remaining three samples were above the 

detection limit and similar to or lower than the pre-cleaning samples. 
52

Post 2nd Cleaning – Four air samples were collected for asbestos. The samples could not 

be analyzed due to overloading of particulate matter on the filters. Therefore, a third 

cleaning was conducted using a more aggressive cleaning method: a commercial HEPA 

vacuum and an AFD. 

Post 3rd Cleaning – Six air samples were collected for asbestos after the third cleaning. 

The samples were analyzed for PCM, TEM AHERA, and PCMe. The results of the PCM 

analysis indicate that three of the six samples were below the detection limit. The 

remaining three samples were above the detection limit but below the secondary numeric 

criterion of 0.01 f/cc. The TEM AHERA results indicate that all six samples were below 

the detection limit. The PCMe results also indicate that all six samples were below the 

detection limit. This suggests that the cleaning techniques used for the third cleaning were 

effective at reducing the particulate matter to levels that permitted valid air samples to be 

collected and analyzed, with the results indicating that all six samples were below the 

primary clearance criterion of 0.0009 S/cc. 

Dioxin

Before Cleaning Samples – Three pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present and that the TEQ concentration for 

one of the three samples was above the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples – Four post-cleaning samples were collected and analyzed for 

dioxin. The results indicate that dioxin was present; however, the TEQ concentrations 

were below the primary clearance criterion of 4 ng/m2

. This indicates that the cleaning 

techniques used were effective at reducing the pre-cleaning concentrations of dioxin. 

 Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected above the detection limit in the air samples. 

 Lead

Before Cleaning Samples – Four micro vacuum samples and three wipe samples were 

collected. Lead was detected in all four micro vacuum samples at concentrations above 

the comparison value. Two of the three wipe samples detected concentrations above the 

primary clearance criterion of 25 μg/ft2

. The micro vacuum samples exceeded the 

comparison value in a range of 39.4 μg/ft2

 to 135 μg/ft2, and the two wipe samples 

exceeded the primary clearance criterion at 48.7 μg/ft2 and 750 μg/ft2. This indicates that 

lead was present prior to cleaning. 

Post 1st Cleaning Samples – Two air samples, four micro vacuum samples, and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion. The results of the micro vacuum and wipe samples show that 

all but one micro vacuum sample (26.9 μg/ft2

) met the comparison value or primary 

clearance criterion for lead. 
53

Post 2nd Cleaning Samples – Two air samples were collected after the second cleaning. 

Both samples detected concentrations below the primary clearance criterion. 

 Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All 

samples were below the detection limit. 

 Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

calcite. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Since all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

cristobalite. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Since all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

tridymite. 

MMVF

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. The three 

wipe samples detected MMVF in concentrations from 343.39 S/L to 744.01 S/L. This 

indicates that MMVF was present prior to cleaning. 

 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. All of the air sample results indicate that MMVF was present at levels 

below the primary clearance criterion of 10 S/L. All of the wipe sample results were 

above the detection limit and at concentrations similar or lower than the pre-cleaning 

samples. 

Post 2nd Cleaning – Five air samples were collected after the second cleaning. Four of the 

five samples were below the primary clearance criterion of 10 S/L. However, one sample 

exceeded the primary clearance criterion at 91.796 S/L. This value was further evaluated 
54

and determined to be invalid due to an equipment malfunction which resulted in the 

collection of a volume of air significantly lower than the other four samples. It should be 

noted that the other four post-2nd cleaning air samples, and the three post-1st cleaning air 

samples were below the applicable health-based benchmark. 

PAH 

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. Two of the 

three samples were below the detection limit. The calculated TEF for these two samples 

was below the primary clearance criterion. Twelve PAH compounds were detected in the 

third sample. The calculated TEF for this sample exceeded the TEF of 300 μg/m2 with a 

value of 1,046.6 μg/m2

. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected. All four 

samples were below the detection limit. The TEF for each sample was below the primary 

clearance criterion of 300 μg/m2. This indicates that the cleaning techniques used were 

effective in reducing the PAH pre-cleaning concentrations. 

Unit 3D – This unit is located on the third floor. It is a 968 sq. ft. loft with three bedrooms, 

facing the WTC site. The unit has hardwood floors with no carpet. This unit presented a 

significant accumulation of dust in the dwelling. Its windows were blown in. The majority of 

personal items, with the exception of three pieces of hardwood furniture, were disposed of prior 

to cleaning. 

Cleaning Method – This unit was cleaned using Test 1A: a Ridgid shop vacuum and a Hoover 

upright without a HEPA filter. AFDs were not used during cleaning. All horizontal surfaces 

were wet wiped. This cleaning method was used for each cleaning event. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned twice. 

 Asbestos

Before Cleaning Samples – Three micro vacuum and five wipe samples were collected for 

asbestos. These samples indicate that asbestos was present in the unit before cleaning. All 

three of the micro vacuum samples detected chrysotile, and four of the five wipe samples 

detected chrysotile. The remaining sample was below the detection limit. 

 

Post 1st Cleaning Samples – Three micro vacuum, five wipe samples and three air samples 

were collected for asbestos. 

All three of the air samples, which were analyzed using PCM, TEM AHERA, and PCMe, 

could not be analyzed due to overloading of particulate material. Due to this situation, a 

second cleaning was conducted. 

The results of the three micro vacuum samples indicate that asbestos was present at levels 

lower than those observed before cleaning. One of the samples was below the detection 

limit. 
55

The results of the five wipe samples indicate that asbestos was present in all of the 

samples, but generally at lower concentrations than those observed before cleaning. 

Post 2nd Cleaning Samples – Four post-cleaning air samples were collected for asbestos. 

These samples were analyzed using PCM, TEM AHERA, and PCMe. The results of the 

PCM analysis were below the secondary numeric criterion of 0.01 f/cc. One sample was 

below the detection limit. The TEM AHERA results were all below the detection limit. 

The PCMe results were also all below the primary clearance criterion of 0.0009 S/cc. This 

indicates that the cleaning techniques were effective at reducing the particulate matter, 

which allowed valid air samples to be collected and analyzed. 

 Dioxin

Before Cleaning Samples – Four pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2

. 

 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2 and were detected at 

lower concentrations than in the pre-cleaning samples. This indicates that the cleaning 

techniques were effective in reducing dioxin concentrations. 

Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected above the detection limit of 0.008 mg/m3 in the air samples. 

Lead

Before Cleaning Samples – Three micro vacuum samples and four wipe samples were 

collected. One of the three micro vacuum samples was above the comparison value. The 

other two results were below the detection limit. The results indicate lead was present in 

two of the four wipe samples at concentrations above the primary clearance criterion of 25 

μg/ft2

. The micro vacuum samples exceeded the comparison value at 50.7 μg/ft2 and the 

two wipe samples exceeded the primary clearance criterion at 112 μg/ft2

 and 201 μg/ft2. 

Post 1st Cleaning Samples – Two air samples, three micro vacuum samples, and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion but were qualified as rejected due to field blank contamination. 

The results of the micro vacuum and wipe samples show that while one of the micro 

vacuum (qualified as rejected) and two of the wipes samples exceeded the detection limit, 

all samples met the comparison value and the primary clearance criterion for lead after the 

first cleaning. Therefore, additional samples were not collected for analysis of lead. 

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 
56

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All 

samples were below the detection limit. 

 Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

calcite. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

cristobalite. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

tridymite. 

 MMVF

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. The four wipe 

samples had MMVF detected in concentrations from 228.93 S/cm2 to 1259.09 S/cm2. 

This indicates that MMVF was present prior to cleaning. 

 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. All of the air sample results indicate that MMVF was present but at 

levels below the primary clearance criterion of 10 S/L. All of the wipe sample results 

were at or below the detection limit of 22.89 S/cm2 . This indicates that the cleaning 

method was able to reduce the pre-cleaning concentration of MMVF. 

 PAH 

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. Three of the 

four samples were below the detection limit and below the primary clearance criterion. 

The fourth sample had two PAH compounds detected; the calculated TEF was below the 

primary clearance criterion. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected. All four 

samples were below the detection limit, and each sample was below the primary clearance 

criterion of 300 μg/m2

. 
57

Third Floor Hallway – The third floor hallway is an area with plywood floors, and walls made 

of sheet rock covered with wallpaper glue. The ceiling is also made of sheet rock, and is painted. 

Cleaning Method – This area was cleaned using Test 4A and Test 4B. Test 4A used industrial 

HEPA-filtered vacuums and an AFD, while Test 4B consisted of a soap and water wet wipe of 

the ceiling only. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned once. 

 Asbestos 

Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – Two post-cleaning air samples were collected. The two air 

 samples were analyzed using PCM, TEM AHERA, and PCMe. The PCM result were all 

 below the secondary numeric criterion of 0.01 f/cc. Similarly, the TEM AHERA results 

 were all below the secondary numeric criterion of 0.022 S/cc. The PCMe results were 

 all below the primary clearance criterion of 0.0009 S/cc with both samples being below 

 the detection limit. 

 Dioxin

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were no samples collected after cleaning. 

 Gypsum

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were two air samples collected after the first cleaning. 

 Gypsum was not detected in any sample. 

 Lead

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There was one air sample collected after the first cleaning. 

 The air sample was below the detection limit. Since the primary clearance criterion was 

 met for lead after the first cleaning, no additional lead samples were collected. 

 Alpha-Quartz

 Before Cleaning Samples – There were no samples collected before cleaning.

 Post 1st Cleaning Samples – There were two air samples collected after the first cleaning. 

 All of the samples were below the detection limit. Because all of the samples were 

 below the detection limit after the first cleaning, no additional samples were collected 

 for analysis of alpha-quartz. 
58

 Calcite

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

 Both were below the detection limit. 

 Cristobalite

Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were two air samples collected after the first cleaning. 

 Both were below the detection limit. 

 Tridymite

Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

 Both were below the detection limit. 

 MMVF

Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

 results indicate that MMVF was present in both samples; however, the concentrations 

 were below the primary clearance criterion of 10 S/L. Because the air samples were 

 below the primary clearance criterion, no additional samples were collected for MMVF. 

 PAH

Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were no samples collected after cleaning. 

Unit 4A – This unit is located on the fourth floor. It is a 1,368 sq. ft. open loft facing Cedar 

Street. No windows were blown in and there was minimal dust accumulation in the dwelling 

with the exception of the baseboard heating units, which contained visible dust. The unit has 

hardwood floors. All of the tenant’s personal items were removed prior to the cleanup. 

Cleaning Method – This unit was cleaned using Test 2A: a Craftsman shop vacuum and 

Eureka upright vacuum with a HEPA filter for vacuuming the floors and other surfaces. There 

were no AFDs used during the cleaning process. In addition, all horizontal surfaces were wet 

wiped. This cleaning method was used for each cleaning event. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned twice. 

 Asbestos

Before Cleaning Samples – Three micro vacuum and four wipe samples were collected 
59

for asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. All three micro vacuum samples detected chrysotile above the detection 

limit. Three of the four wipe samples were below the detection limit; however, chrysotile 

was detected in two of these samples. The fourth wipe sample was above the detection 

limit. 

Post 1st Cleaning – Three air samples, three micro vacuum samples, and five wipe samples 

were collected. The three air samples were analyzed using PCM, TEM AHERA, and 

PCMe. The PCM, TEM AHERA and PCMe analyses could not be conducted due to 

overloading of particulate material. Due to inconclusive asbestos air results, a second 

cleaning was conducted. 

The results for the three micro vacuum samples indicate that asbestos was present at levels 

similar to or higher than those observed before cleaning. One of the samples was 

identified as non-detect, although asbestos was present below the detection limit. 

The results for the five wipe samples that were collected indicate that asbestos was present 

in all five samples, although two samples were below the detection limit. The 

concentrations observed were similar to or higher than the pre-cleaning samples. 

Post 2nd Cleaning – Three asbestos air samples were collected after the second cleaning. 

The samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM results could 

not be obtained due to the filter being overloaded with particulate material. The TEM 

AHERA results for each sample were below the detection limit and below the secondary 

numeric criterion of 0.022 S/cc. The PCMe results were all below the primary clearance 

criterion of 0.0009 S/cc, with all three of the samples below the detection limit. This 

indicates that the cleaning techniques used were able to reduce the particulate matter in the 

unit after the second cleaning, which permitted samples to be analyzed. The results of the 

analysis indicated that asbestos concentrations were below the primary clearance criterion 

of 0.0009 S/cc. 

Dioxin

Before Cleaning Samples – Three pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the TEQ concentration for each sample was below the 

primary clearance criterion of 4 ng/m2

. 

Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. 

Post 2nd Cleaning Samples – Two air samples were collected after the second cleaning. 
60

Gypsum was not detected in any sample. 

Lead

Before Cleaning Samples – Three micro vacuum samples and three wipe samples were 

collected. The results indicate that all three of the micro vacuum samples were below the 

comparison value of 25 μg/ft2 and below the detection limit. The three wipe samples 

contained detectable concentrations of lead; however, all of the concentrations were below 

the primary clearance criterion of 25 μg/ft2

. 

Post 1st Cleaning Samples – Two air samples, three micro vacuum samples and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion of 1.0 μg/m3. Two of the three micro vacuum samples were 

below the detection limit. The third micro vacuum sample was slightly above the 

detection limit, but below the comparison value. Three of the four wipe samples were 

below the detection limit. The fourth sample was above the detection limit but below the 

primary clearance criterion. Since the primary clearance criterion was met for lead after 

the first cleaning, no additional samples were collected for analysis of lead. 

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. One 

of the two air samples detected alpha-quartz at a concentration above the detection limit, at 

0.008 mg/m3

. The detection also was above the primary clearance criterion of 0.004 

mg/m3

. The other air sample was below the detection limit. Since one air sample 

exceeded the primary clearance criterion, additional air samples for alpha-quartz were 

collected. 

Post 2nd Cleaning Samples – Two air samples were collected after the second cleaning. 

The results showed that both samples were below the detection limit. This indicates that 

the second cleaning was able to reduce the alpha-quartz concentration in air to below the 

detection limit. 

Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Post 2nd Cleaning Samples – Two air samples were collected after the second cleaning. 

The results indicate that both samples were below the detection limit. 

Cristobalite

Before Cleaning Samples –Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 
61

Post 2nd Cleaning Samples – Two air samples were collected after the second cleaning. 

The results indicate that both samples were below the detection limit. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Post 2nd Cleaning Samples – Two air samples were collected after the second cleaning. 

The results indicate that both samples were below the detection limit. 

MMVF

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. All three 

sample results indicate that MMVF was present above the detection limit. 

 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results for the three air samples indicate that MMVF was present; 

however, both samples were below the primary clearance criterion of 10 S/L. The results 

of the five wipe samples indicate that four of the samples were below the detection limit 

and one sample was at the detection limit. The MMVF concentrations after the first 

cleaning were lower than those in the pre-cleaning samples. There is not a clearance 

criterion for MMVF in settled dust. Since the air samples were below the primary 

clearance criterion and the MMVF in settled dust was greatly reduced after the first 

cleaning, no additional samples were collected for analysis of MMVF. 

PAH

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. All three 

samples were below the detection limit and the TEF for each sample was below the 

primary clearance criterion. 

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

of the samples were below the detection limit. The TEF for each sample was below the 

primary clearance criterion of 300 μg/m2

. Since all of the samples were below the 

detection limit and the primary clearance criterion after the first cleaning, no additional 

samples were collected for analysis of PAH. 

Unit 4B – This unit is located on the fourth floor. It is a 968 sq. ft. loft with four bedrooms facing 

Cedar Street. No windows were blown in and there was minimal dust accumulation in the 

dwelling with the exception of the baseboard heating units, which contained visible dust. The unit 

has hardwood floors and all of the tenant’s personal items were cleaned and sealed in bags prior to 

the cleanup. 

Cleaning Method – This unit was cleaned using Test 2B. a Ridgid shop vacuum and Hoover

upright vacuum with a HEPA filter for vacuuming the floors and other surfaces. An AFD was 

used during the cleaning process. In addition, all horizontal surfaces were wet wiped. This 
62

cleaning method was used for each cleaning event. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned once. 

 Asbestos

Before Cleaning Samples – Pre-cleaning wipe samples were collected for asbestos. The 

results for these samples indicate that asbestos was present in the unit prior to cleaning. 

Two of the five wipe samples were below the detection limit, although one of these 

samples had chrysotile detected. The remaining three samples had chrysotile detected 

above the detection limit. 

Post 1st Cleaning – Three air and five wipe samples were collected. The three air samples 

were analyzed using PCM and PCMe. The PCM results were all below the secondary 

numeric criterion of 0.01 f/cc. The PCMe results for each sample were below the primary 

clearance criterion of 0.0009 S/cc and were reported as below the detection limit. 

The results for the five wipe samples that were collected indicate that asbestos was present 

in two of the five samples; however one of these samples was below the detection limit. 

The remaining three samples were below the detection limit. 

 Dioxin

Before Cleaning Samples – Four pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that there was dioxin present; however, the TEQ 

concentration for each sample was below the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the TEQ concentration for each sample was below the 

primary clearance criterion of 4 ng/m2

. 

 

 Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. 

 Lead

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. The results 

indicate that lead was detected in three of the four wipe samples with two samples 

exceeding the primary clearance criterion of 25 μg/ft2

. One sample was slightly over the 

primary clearance criterion with a result of 30 μg/ft2

, while the second was twice the 

primary clearance criterion with a result of 50 μg/ft2

. 

Post 1st Cleaning Samples – Two air samples and four wipe samples were collected after 

the first cleaning. The two air samples were above the detection limit but below the 

primary clearance criterion of 1.0 μg/m3

. Three of the four wipe samples were below the 

detection limit. The fourth wipe sample was above the detection limit but below the 
63

primary clearance criterion. Since the primary clearance criterion was met for lead after 

the first cleaning, no additional cleaning was necessary. 

Post 2nd Cleaning Sampling – Because the cleaning was conducted prior to the 

establishment of a risk based cleanup level for lead in air, this unit was re-cleaned in an 

effort to meet the initially established clearance criterion . Sampling results following the 

second cleaning indicated levels below the primary clearance criterion. 

 Alpha-Quartz

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Calcite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Cristobalite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 MMVF

Before Cleaning Samples – Four pre-cleaning wipe samples collected. All four samples 

had MMVF detected above the detection limit. 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results for the three air samples indicate that MMVF was present; 

however, both samples were below the primary clearance criterion of 10 S/L. The results 

of the five wipe samples indicate that MMVF was still present after the first cleaning; 

however, the concentrations detected were generally lower than the pre-cleaning samples. 

There is not a clearance criterion for MMVF in settled dust. 

 PAH 

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. All four 

samples were below the detection limit and the TEF for each sample was below the 

primary clearance criterion. 
64

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

of the samples were below the detection limit and the TEF for each sample was below the 

primary clearance criterion of 300 μg/m2. Because all of the samples were below the 

detection limit and the primary clearance criterion after the first cleaning, no additional 

samples were collected for analysis of PAH. 

Unit 4C – This unit is located on the fourth floor. It is a 655 sq. ft. open loft that faces the WTC 

site. The windows were blown in and there was significant dust accumulation in the dwelling. 

The unit has hardwood floors and no carpet. All personal possessions to be retained by the tenant 

were vacuumed and bagged. 

Cleaning Method – This unit was cleaned using Test 1A: a Craftsman shop vacuum and a 

Eureka upright vacuum for vacuuming the floors and other surfaces. No HEPA or AFD was 

used during the cleaning process. In addition, all horizontal surfaces were wet wiped. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned once. 

Supplemental Sampling Activities – The air samples collected for PAH analysis were taken for 

reference purposes only. These samples are discussed in the PAH section below. 

 Asbestos

Before Cleaning Samples – Pre-cleaning micro vacuum and wipe samples were collected 

for asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. All four of the micro vacuum samples detected chrysotile, and one of the four 

micro vacuum samples detected amosite. Three of the four wipe samples detected 

chrysotile; however, one of these samples was below the detection limit. The fourth wipe 

sample did not detect chrysotile and was below the detection limit. 

 

Post 1st Cleaning Samples – Three air samples, three micro vacuum samples, and five 

wipe samples were collected for asbestos. The samples were analyzed using PCM, TEM 

AHERA, and PCMe. The PCM analysis could not be conducted due to overloading of 

particulate material. The TEM AHERA results were above the detection limit but were 

below the secondary numeric criterion of 0.022 S/cc. Two of the three air samples 

analyzed using PCMe were below the primary clearance criterion of 0.0009 S/cc. The 

third air sample detected chrysotile and was present at the primary clearance criterion of 

0.0009 S/cc. Since the primary primary clearance criterion was met, no additional 

cleaning was required. 

The results of the three micro vacuum samples indicate that asbestos was present at levels 

lower than those observed before cleaning. 

The results of the five wipe samples indicate that asbestos was present above the detection 

level in one of the five samples. The concentrations were lower than in the pre-cleaning 

concentrations. 
65

Dioxin

Before Cleaning Samples – Three pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that there was dioxin present; however, the TEQ 

concentration for each sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the TEQ concentration for each sample was below the 

criterion of 4 ng/m2

 and were detected at lower concentrations than in the pre-cleaning 

samples. 

 

 Gypsum

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected above the detection limit in these samples. 

 Lead

Before Cleaning Samples – Four micro vacuum samples and three wipe samples were 

collected. The results indicate that all four micro vacuum samples exceeded the 

comparison value. Two of the three wipe samples exceeded the primary clearance 

criterion of 25 μg/ft2. The third wipe sample was below the detection limit. The micro 

vacuum samples ranged in concentration from 69.8 μg/ft2 to 83.7 μg/ft2, and the wipe 

samples ranged from non-detect to 181 μg/ft2

. 

Post 1st Cleaning Samples – Two air samples, three micro vacuum samples, and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion of 1.0 μg/m3

. The results of the micro vacuum and wipe 

samples show that all samples met the comparison value or primary clearance criterion for 

lead after the first cleaning; however, three of the four wipe samples were qualified as 

rejected due to field blank contamination, and one wipe sample was not analyzed because 

it was not received at the laboratory. 

Post 2nd Cleaning Samples – While the study was underway, there was a revision from a 

background clearance criterion for lead in air of 0.1 μg/m3

 to a health-based clearance 

criterion for lead in air of 1.0 μg/m3

. The initial results were compared to the background 

clearance criterion which resulted in a decision to re-clean the dwelling and resample for 

lead in air. This also occurred in four other units and although these units were cleaned a 

second time and samples were collected after the second cleaning, the revised lead-in-air 

criterion actually negated the need for the second cleaning and sampling events. One air 

sample was collected and analyzed for lead. The result for this sample indicates that the 

concentration was below the primary clearance criterion of 1.0 μg/m3

. 

 Alpha-Quartz

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 
66

Calcite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Cristobalite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 MMVF

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. The three 

wipe samples contained MMVF detected at concentrations from 57.23 S/cm2 to 1030.17 

S/cm2. This indicates that MMVF was present prior to cleaning. 

 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. All of the air sample results indicate that MMVF was present, but at 

concentrations below the primary clearance criterion of 10 S/L. The wipe sample results 

were detected in concentrations ranging from 57.23 S/cm2 to 343.39 S/cm2 which were 

similar to or lower than the pre-cleaning samples. 

 PAH 

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. Two of the 

three samples were below the detection limit; the TEF for each sample was below the 

primary clearance criterion. PAH compound was detected in the third sample; however 

the calculated TEF was below the primary clearance criterion of 300 μg/m2. 

Post 1st Cleaning Samples – Two post-cleaning air samples and four post-cleaning wipe 

samples were collected. Both air samples had seven PAH compounds detected; however, 

the calculated TEFs for these samples were below the primary clearance criterion of 0.2 

μg/m3

. All wipe samples were below the detection limit and the TEF for each sample was 

below the primary clearance criterion of 300 μg/m2. 

Unit 4D – This unit is on the fourth floor. It is a 968 sq. ft. open loft facing the WTC site. The 

unit had windows blown in and presented a significant accumulation of dust. The dwelling has 

hardwood floors with no carpet. All personal possessions to be retained by the tenant were 

vacuumed and bagged. 
67

Cleaning Method – This unit was cleaned using Test 2A: a Ridgid shop vacuum and a Eureka

upright vacuum with a HEPA filter. No AFDs were used. All horizontal surfaces were wetwiped. This cleaning method was used for each cleaning event. 

Cleaning Results – This unit met the clearance listed in Table 1.0 for each compound after being 

cleaned twice. 

 Asbestos

Before Cleaning Samples – Six micro vacuum and five wipe samples were collected for 

asbestos. These samples indicate that asbestos was present in the unit prior to cleaning. 

All six of the micro vacuum samples detected chrysotile above the detection limit. Two of 

the five wipe samples were below the detection limit, although one detected chrysotile. 

The remaining three samples were above the detection limit. 

Post 1st Cleaning Samples – Three air, six micro vacuum samples and five wipe samples 

were collected for asbestos. The samples were analyzed using PCM, TEM AHERA, and 

PCMe. The results for the PCM analysis indicate that two of the three samples were 

below the secondary numeric criterion of 0.01 f/cc. The third slightly exceeded this value 

with a concentration of 0.02 f/cc. The TEM AHERA results indicate that all three samples 

were below the secondary numeric criterion of 0.022 S/cc. The PCMe results indicate that 

two of the three air samples were below the primary clearance criterion of 0.0009 S/cc. 

The third sample detected chrysotile and was at the primary clearance criterion of 0.0009 

S/cc. 

The results of the six micro vacuum samples indicate that asbestos was present at levels 

lower than those observed before cleaning. 

The results of the five wipe samples indicate that asbestos was present in all of the 

samples at concentrations similar to or lower than those observed before cleaning. 

Dioxin

Before Cleaning Samples – Four pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that there was dioxin present at concentrations lower than 

those observed in the pre-cleaning samples. In addition, the TEQ concentration for each 

sample was below the primary clearance criterion of 4 ng/m2

. This indicates that the 

cleaning techniques were effective at reducing dioxin concentrations. 

Gypsum

Before Cleaning Samples - Pre-cleaning air samples were not collected. 

 

Post 1st Cleaning Samples - Two air samples were collected after the first cleaning. 

Gypsum was not detected above the detection limit of 0.016 mg/m3 for these samples. 
68

Lead

Before Cleaning Samples – Six micro vacuum samples and four wipe samples were 

collected. The results indicate that lead was detected in all six of the micro vacuum 

samples at concentrations above the comparison value of 25 μg/ft2

, ranging from 26.2 

μg/ft2 to 83.5 μg/ft2. One of the four wipe samples exceeded the primary clearance 

criterion of 25 μg/ft2

 with a concentration of 169 μg/ft2. 

Post 1st Cleaning Samples – Two air samples, six micro vacuum samples, and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion but were qualified as rejected due to lab blank contamination. 

The results of the micro vacuum and wipe samples show that all but one wipe sample (66 

μg/ft2

) met the comparison value or primary clearance criterion for lead. 

Post 2nd Cleaning Samples – One air sample and one wipe sample were collected after the 

second cleaning. Both sample results were below their respective clearance criterion. 

 Alpha-Quartz

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All 

samples were below the detection limit. 

 

 Calcite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Since all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

calcite. 

 Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

cristobalite. 

 Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. Because all of the samples were below the 

detection limit after the first cleaning, no additional samples were collected for analysis of 

tridymite. 
69

MMVF

Before Cleaning Samples – Four wipe samples were collected. MMVF was detected in 

the wipe samples in concentrations from 286.16 S/cm2 to 2174.79 S/cm2. 

 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. All of the air sample results indicate that MMVF was present, but at 

levels below the primary clearance criterion of 10 S/L. All of the wipe sample results 

were in the range of 57.23 S/cm2

 to 572.31 S/cm2, which is lower than the pre-cleaning 

range. This indicates that the cleaning techniques were effective at reducing MMVF 

concentrations. 

 

 PAH 

Before Cleaning Samples – Four wipe samples were collected. Three of the four samples 

were below the detection limit with TEF values below the primary clearance criterion. 

The fourth sample had six PAH compounds detected; the calculated TEF slightly exceeded 

the primary clearance criterion of 300 μg/m2

 with a value of 325.8 μg/m2. 

Post 1st Cleaning Samples – Four wipe samples were collected. All four samples were 

below the detection limit, and the TEF for each sample was below the primary clearance 

criterion of 300 μg/m3. 

Fourth Floor Hallway – The fourth floor hallway is an area with plywood floors and walls made 

of sheet rock covered with wallpaper glue. The ceiling is also made of sheet rock, and is painted. 

Cleaning Method – This area was cleaned using Test 4A and Test 4B. Test 4A used an industrial 

HEPA-filtered vacuum and an AFD, while Test 4B consisted of a soap and water wet wipe of only 

the ceiling. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned once. 

 

 Asbestos

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One sample was collected after cleaning. The air sample was 

analyzed using PCM, TEM AHERA, and PCMe. The PCM result was below the 

secondary numeric criterion of 0.01 f/cc. Similarly, the TEM AHERA result was below 

the secondary numeric criterion of 0.022 S/cc. The PCMe result was below the primary 

clearance criterion of 0.0009 S/cc with the sample being below the detection limit. 

 Dioxin

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were no post- cleaning samples collected. 

 
70

Gypsum

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. Gypsum 

was not detected. 

 Lead

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The air 

sample was below the primary clearance criterion of 1.0 μg/m3

. 

 Alpha-Quartz

 Before Cleaning Samples – There were no samples collected before cleaning.

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. 

 Calcite

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. 

Cristobalite

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. 

Tridymite

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. 

MMVF

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

results indicate that MMVF was present in the sample; however, the concentration was 

below the primary clearance criterion of 10 S/L. 

PAH

Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – There were no samples collected. 
71

Unit 5A – This unit is on the fifth floor. It is a 1,404 sq. ft. loft facing Cedar Street with one 

bedroom. The unit has hardwood floors and no carpet. One window had been blown in. The 

dwelling presented minimal accumulation of dust, except for baseboard-heating units. Numerous 

items were cleaned, then bagged. 

Cleaning Method – This unit was cleaned using Test 3B: an Industrial HEPA-filtered vacuum. 

An AFD was used during cleaning. In addition, all horizontal surfaces were wet wiped. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound after 

being cleaned twice. 

 Asbestos

Before Cleaning Samples – Seven micro vacuum and four wipe samples were collected for 

analysis of asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. Chrysotile was detected in six of the seven micro vacuum samples and all four 

of the wipe samples; however, chrysotile was present below the detection limit in two of 

the four wipe samples. 

Post 1st Cleaning – Three air samples, seven micro vacuum samples, and five wipe 

samples were collected. The three air samples were analyzed using PCM and PCMe. The 

PCM results were all below the secondary numeric criterion of 0.01 f/cc. All three PCMe 

analyses were at or below the primary criterion of 0.0009 S/cc. 

The results for the seven micro vacuum samples indicate that asbestos results varied and 

were present at levels higher and lower than before cleaning. 

The results for the five wipe samples showed that asbestos was present in one sample; 

however, all samples were below the detection limit. The results indicate that the cleaning 

techniques used were effective in reducing the asbestos concentrations observed prior to 

cleaning. 

Dioxin

Before Cleaning Samples – Three wipe samples were collected and analyzed for dioxin. 

The results indicate that dioxin was present; however, the TEQ concentration for each 

sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples – Four wipe samples were collected and analyzed for dioxin. 

The results indicate that the TEQ concentration for each sample was below the primary 

clearance criterion of 4 ng/m2

. 

Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. 
72

Lead

Before Cleaning Samples – Seven micro vacuum samples and three wipe samples were 

collected. Lead was detected in one of the seven micro vacuum samples at concentrations 

below the comparison value of 25 μg/ft2

. All three wipe samples had detectable 

concentrations of lead, two of which were above the primary clearance criterion of 25 

μg/ft2

. 

Post 1st Cleaning Samples – Two air samples, seven micro vacuum samples and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion of 1.0 μg/m3

. All seven micro vacuum samples were below the 

comparison value. Two of the four wipe samples exceeded the primary clearance 

criterion, therefore, additional cleaning was necessary. 

Post 2nd Cleaning Sampling – Three wipe samples were collected following the second 

cleaning. The results of all three samples were below the primary clearance criterion. In 

two of the samples, lead was not detected. The sampling results following the second 

cleaning indicate that the primary clearance criterion was met. 

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

 Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. All of 

the samples were below the detection limit. 

MMVF

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. MMVF was 

detected in all three of the samples. 
73

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results of the three air samples indicate that MMVF was present; 

however, all samples were below the primary clearance criterion of 10 S/L. The results of 

the five wipe samples indicate that MMVF continued to be present in all of five of the 

samples after the first cleaning; however, the concentrations detected were lower than in 

the pre-cleaning samples. This indicates that the cleaning techniques were effective at 

reducing the pre-cleaning concentrations of MMVF. 

PAH

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. All three 

samples were below the detection limit. The TEF for each sample was below the primary 

clearance criterion. 

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

were below the detection limit and the TEF for each sample was below the primary 

clearance criterion of 300 μg/m2

. Since all of the samples were below the detection limit 

and the primary clearance criterion after the first cleaning, no additional samples were 

collected for analysis of PAH. 

Unit 5C – This unit is located on the fifth floor. It is a 968 sq. ft. loft with three separate 

bedrooms facing the WTC. The unit has hardwood floors. Windows were blown in. There was 

significant accumulation of dust in the dwelling. All of the tenant’s personal items were removed 

prior to cleaning. 

Cleaning Method – This unit was cleaned twice using Test 3A: an industrial HEPA-filtered 

vacuum for vacuuming the floors and other surfaces. An AFD was not used during the cleaning 

process. All horizontal surfaces were wet wiped. This cleaning method was used for the first two 

cleaning events. The third cleaning event used Test 3B, which is similar to Test 3A described 

above; however, AFDs were used during the third cleaning. 

Cleaning Results – With the exception of asbestos, this unit met the clearance criteria listed in 

Table 1.0 for each compound after being cleaned three times. 

 Asbestos

Before Cleaning Samples – Three micro vacuum and four wipe samples were collected for 

analysis of asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. All three micro vacuum samples, as well as all four wipe samples, detected 

chrysotile above the detection limit. 

Post 1st Cleaning – Three air samples, three micro vacuum samples, and five wipe samples 

were collected. The three air samples were analyzed using PCM and PCMe. The PCM 

results indicate that two of the samples were below the secondary numeric criterion of 0.01 

f/cc. The third slightly exceeded the primary clearance criterion with a result of 0.015 f/cc. 

The PCMe analysis could not be conducted due to overloading of particulate material. 

Due to inconclusive PCMe results, a second cleaning was conducted. 
74

The results for two of the three micro vacuum samples indicate that asbestos was present 

at levels similar to those observed before cleaning. The third micro vacuum sample was 

reported as being below the detection limit. 

The results for the five wipe samples indicate that two of the five samples were below the 

detection limit, although one of these samples had chrysotile detected. The remaining 

three samples had chrysotile detected at concentrations above the detection limit. Unlike 

the micro vacuum samples, the results of the wipe samples collected after the first cleaning 

were lower than the pre-cleaning concentrations. This indicates that the cleaning 

techniques used were able to reduce the concentrations of asbestos in settled dust. 

Post 2nd Cleaning – Five asbestos air samples were collected after the second cleaning. 

The samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM, TEM 

AHERA, and PCMe results could not be obtained due to the filters being overloaded with 

particulate material. Due to inconclusive PCMe results, a third cleaning was conducted. 

Post 3rd Cleaning – Four asbestos air samples were collected after the third cleaning. The 

samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM results indicate 

that one sample was below the detection limit and the other three were at the detection 

limit. All PCM results were below the secondary numeric criterion of 0.01 f/cc. The 

TEM AHERA results had chrysotile detected above the detection limit; however, all four 

results were below the secondary numeric criterion of 0.022 S/cc. The PCMe results 

indicate that two of the samples which were collected under a modified-aggressive 

sampling methodology, were below or at the detection limit. The remaining two samples, 

collected under an aggressive sampling methodology, were slightly above the primary 

clearance criterion of 0.0009 S/cc with results of 0.0015 S/cc and 0.0016 S/cc. The results 

obtained from the samples collected with the modified-aggressive sampling were used as 

evidence of meeting the primary clearance criterion. 

 Dioxin

Before Cleaning Samples – Three pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that the TEQ concentration for each sample was below the 

primary clearance criterion of 4 ng/m2

. Since dioxin was below the detection limit for all 

of the samples collected, there were no additional dioxin samples collected. 

 Gypsum

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. 

Gypsum was not detected in any sample. 

 Lead

Before Cleaning Samples – Three micro vacuum samples and three wipe samples were 
75

collected. Lead was detected in all three micro vacuum samples at concentrations above 

(approximately four to six times) the comparison value of 25 μg/ft2. Two of the three 

wipe samples had detectable concentrations of lead above the primary clearance criterion 

of 25 μg/ft2

, while the third was below the primary clearance criterion. 

Post 1st Cleaning Samples – Two air samples, three micro vacuum samples and four wipe 

samples were collected after the first cleaning. The two air samples were below the 

primary clearance criterion of 1.0 μg/m3

. However, at the time the results were received, 

the primary clearance criterion that was being used for comparison was the background 

clearance criterion of 0.1 μg/m3

, not the health-based clearance criterion of 1.0 μg/m3

which was developed during the execution of this project. Therefore, additional air 

samples were collected after the second cleaning. 

All three micro vacuum samples were below the detection limit. This indicates that the 

cleaning techniques used were able to reduce the elevated pre-cleaning lead concentrations 

that were observed in the settled dust in the areas where the samples were collected. 

The results of three of the four wipe samples were below the primary clearance criterion 

(one sample was broken and not analyzed). The results from the first cleaning indicate 

that the cleaning technique was effective in removing the elevated concentrations of lead 

that were observed prior to the first cleaning. Since the primary clearance criterion was 

met for lead after the first cleaning, no additional samples were collected for the analysis 

of lead, with the exception of the air samples discussed above. 

Post 2nd Cleaning – Two air samples were collected after the second cleaning. The results 

of both indicate that the samples were below the primary clearance criterion of 

1.0 μg/m3

. Since the primary clearance criterion was met for lead after the first cleaning, 

no additional samples were collected. 

 Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

 Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

samples were below the detection limit. 

 Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

samples were below the detection limit. 
76

Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. One 

was below the detection limit and one was slightly above the detection limit. 

 MMVF

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. All three 

samples were above the detection limit. 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. The results indicate that MMVF was present in all three, with two 

samples being above the primary clearance criterion of 10 S/L. The third was below the 

primary clearance criterion. The results of the five wipe samples indicate that MMVF was 

still present after the first cleaning at concentrations similar to or higher than the precleaning samples. There is not a clearance criterion for MMVF in settled dust; however, 

since two of the air samples were above the primary clearance criterion, additional air 

samples were collected for analysis of MMVF. 

Post 2nd Cleaning – Five air samples were collected after the third cleaning. The results 

indicate that the two of the five samples were above the primary clearance criterion. Due 

to this situation, additional air samples were collected after the third cleaning. 

Post 3rd Cleaning – Two air samples were collected after the second cleaning. The results 

indicate that both samples were below the primary clearance criterion and below the 

detection limit. 

 PAH

Before Cleaning Samples – Three pre-cleaning wipe samples were collected. Two of the 

three samples were below the detection limit; the TEF for these samples was below the 

primary clearance criterion. The third sample had four PAH compounds detected; the 

calculated TEF was 303.5 μg/m2, which is slightly above the primary clearance criterion of 

300 μg/m2

. 

Post 1st Cleaning Samples – Four wipe samples were collected after the first cleaning. All 

were below the detection limit. The TEF for each sample was below the primary clearance 

criterion of 300 μg/m2

. Since all of the samples were below the detection limit and the 

primary clearance criterion after the first cleaning, no additional samples were collected 

for analysis of PAH. 

Unit 5D – This unit is on the fifth floor. It is a 1,024 sq. ft. open loft facing the World Trade 

Center site. This unit had windows that were blown in, which resulted in significant dust 

accumulation. The dwelling has hardwood floors with no carpet. All personal items were 

removed prior to cleaning. 

Cleaning Method – This unit was cleaned using Test 3B: an industrial HEPA-filtered vacuum and 
77

an AFD. All horizontal surfaces were wet wiped. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned one time. 

 Asbestos

Before Cleaning Samples – Two micro vacuum and five wipe samples were collected for 

analysis of asbestos. These samples indicate that asbestos was present in the unit prior to 

cleaning. The two micro vacuum samples detected chrysotile above the detection limit. 

Three of the five wipe samples were below the detection limit, although four of the five 

wipe samples detected either chrysotile or amosite. 

 

Post 1st Cleaning Samples – Three air, two micro vacuum and five wipe samples were 

collected for asbestos. The samples were analyzed for PCM and PCMe. The PCM results 

indicate all three air samples were below the secondary numeric criterion of 0.01 f/cc. 

The PCMe results indicate that all three of the samples were below the primary clearance 

criterion of 0.0009 S/cc. 

The results of the two micro vacuum samples indicate that asbestos was present at levels 

somewhat similar to those observed before cleaning. 

The results of the five wipe samples indicate that asbestos was below the concentrations 

observed in the pre-cleaning samples and was below the detection limit for all samples. 

 

 Dioxin

Before Cleaning Samples – Four wipe samples were collected and analyzed for dioxin. 

The results indicate that dioxin was not present and that the TEQ concentration for all 

samples was below the primary clearance criterion of 4 ng/m2

. 

 

Post 1st Cleaning Samples – Four post-cleaning wipe samples were collected and 

analyzed for dioxin. The results indicate that there was dioxin present; however, the TEQ 

concentration was below the primary clearance criterion of 4 ng/m2

 and similar to precleanup concentrations. 

 Gypsum

Before Cleaning Samples - Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples - Two air samples were collected after the first cleaning. 

Gypsum was not detected above the detection limit of 0.016 mg/m3 in the air samples. 

 Lead

Before Cleaning Samples - Two micro vacuum samples and four wipe samples were 

collected. Lead was detected in both micro vacuum samples and two of the four wipe 

samples at concentrations above the comparison value or primary clearance criterion of 

25 μg/ft2

. The micro vacuum samples exceeded the comparison value, ranging from 27.1 

μg/ft2 to 49.1 μg/ft2, and the two wipe samples exceeded the primary clearance criterion, 

ranging from 25.3 μg/ft2

 and 32.1 μg/ft2. 
78

Post 1st Cleaning Samples (Test 3B) – Two air samples, two micro vacuum samples, and 

four wipe samples were collected after the first cleaning. The two air samples were 

below the primary clearance criterion of 1.0 μg/m3. The results of the micro vacuum and 

wipe samples show that all samples met the comparison value or primary clearance 

criterion for lead. 

Alpha-Quartz

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

Calcite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

Cristobalite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

Tridymite

Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

MMVF

Before Cleaning Samples – Four wipe samples were collected. The four wipe samples 

evidenced MMVF above the detection limit, which indicates that MMVF was present 

prior to cleaning. 

Post 1st Cleaning Samples – Three air samples and five wipe samples were collected after 

the first cleaning. All of the air sample results indicate that MMVF was present, but at 

levels below the primary clearance criterion of 10 S/L. All of the wipe sample results 

were in the range of 114.46 S/cm2

 to 228.93 S/cm2. This indicates that the cleaning 

method was able to reduce the pre-cleaning concentration of MMVF. 

PAH 

Before Cleaning Samples – Four wipe samples were collected. All four samples were 

below the detection limit, and the TEF of 300 μg/m2

. 

Post 1st Cleaning Samples – Four wipe samples were collected. All four samples were 

below the detection limit; the TEF value was below the primary clearance criterion of 
79

300 μg/m2. 

Fifth Floor Hallway – The fifth floor hallway is an area with plywood floors and walls made of 

sheet rock covered with wallpaper glue. The ceiling is also made of sheet rock, and is painted. 

Cleaning Method – This area was cleaned twice using Test 4A and Test 4B. Test 4A used an 

industrial HEPA-filtered vacuum and an AFD, while Test 4B consisted of a soap and water wet 

wipe of only the ceiling. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned twice. 

Asbestos

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected. The air samples were 

analyzed using PCM. The PCM results were below the secondary numeric criterion of 

0.01 f/cc. The samples could not be analyzed for PCMe, due to overloading of particulate 

matter on the filters. 

Post 2nd Cleaning Samples – Two air samples were collected. The air samples were 

analyzed using TEM AHERA, and PCMe. The samples could not be analyzed for PCM, 

due to overloading of particulate matter on the filters. The TEM AHERA results were 

below the secondary numeric criterion of 0.022 S/cc, with the samples being below the 

detection limit. Similarly, the PCMe results were below the primary clearance criterion 

of 0.0009 S/cc with the samples likewise below the detection limit. 

Dioxin

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – There were no post-first cleaning samples collected. 

Post 2nd Cleaning Samples – There were no post-second cleaning samples collected. 

Gypsum

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. 

Gypsum was not detected. Since gypsum was below the detection for the sample 

collected, no additional gypsum samples were collected. 

Lead

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The air 

sample was below the primary clearance criterion of 1.0 μg/m3

. Since the primary 
80

clearance criterion was met for lead after the first cleaning, no additional lead samples 

were collected. 

Alpha-Quartz

Before Cleaning Samples – There were no samples collected before cleaning.

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. Because the sample was below the detection limit 

after the first cleaning, no additional samples were collected for analysis of alpha-quartz. 

Calcite

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. Because the sample was below the detection limit 

after the first cleaning, no additional samples were collected for analysis of calcite. 

Cristobalite

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning; the 

sample was below the detection limit. Because the sample was below the detection limit 

after the first cleaning, no additional samples were collected for analysis of cristobalite. 

Tridymite

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – One air sample was collected after the first cleaning. The 

sample was below the detection limit. Since the sample was below the detection limit 

after the first cleaning, no additional samples were collected for tridymite. 

MMVF

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

results indicate that MMVF was present in both samples; however, the concentrations 

were below the primary clearance criterion of 10 S/L. Because the air samples were 

below the primary clearance criterion, no additional samples were collected for MMVF. 

PAH

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – There were no post-first cleaning samples collected. 

Post 2nd Cleaning Samples – There were no post-second cleaning samples collected. 
81

Barber Shop – The Barber Shop is located below grade to Liberty Street. This 1,268 sq. ft. open 

space faces the WTC site. The front door of the business was blown inward. Significant amounts 

of dust and debris were deposited down into the staircase into the rental space. Floor areas are 

covered with ceramic tiles. The ceiling is a suspended system composed of fibrous tiles. A void 

space is above the suspended ceiling, The void space accommodates flexible A/C ducts, 

electrical conduit and lights. All structural support members above the ceiling are encapsulated 

with a non-asbestos insulating material. Equipment including chairs, wash sinks, counters and 

hair care displays were located in the shop. The head space above the entrance door houses a 

condenser/compressor unit that was heavily impacted with WTC-related dust and debris. Ceiling 

tiles, flexible duct, chairs, display shelving, and hair care merchandise were disposed of prior to 

cleaning. Ancillary rooms that extend under Liberty Street are adjacent to the shop space. These 

rooms have earthen floors and are believed to be associated with utility companies. They were 

not cleaned. 

 Cleaning Method – This unit was cleaned using Test 4A and Test 4E. Test 4A consisted of use 

of an industrial HEPA vacuum to vacuum floors and other surfaces. An AFD was used during 

the cleaning process. Test 4E consisted of use of water to wet wipe all horizontal and vertical 

surfaces. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned once. 

Supplemental Sampling Activities – One bulk sample of insulation material was collected to 

determine its asbestos content, in order to address applicable health and safety concerns. 

Asbestos was not detected in the sample. 

 Asbestos

Before Cleaning Samples – Other than the bulk sample mentioned in the previous section, 

no other pre-cleanup samples were collected. 

 

Post 1st Cleaning Samples – Three air samples were collected for asbestos. The samples 

were analyzed using PCM, TEM AHERA, and PCMe. The PCM results indicate that all 

three samples were below the detection limit and below the secondary numeric criterion 

of 0.01 f/cc. The TEM AHERA results indicate that all three samples were below the 

detection limit and below the secondary numeric criterion of 0.022 S/cc. The PCMe 

results also indicate that all three samples were below the detection limit and were below 

the primary clearance criterion of 0.0009 S/cc. 

Dioxin

Before Cleaning Samples – Four pre-cleaning wipe samples were collected and analyzed 

for dioxin. The results indicate that dioxin was present; however, the TEQ concentration 

for each sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples – Four wipe samples were collected and analyzed for dioxin. 

The results indicate that the concentrations of dioxin detected were slightly lower than the 

pre-cleaning samples. The TEQ concentration for each sample was below the criterion of 

4 ng/m2

. 
82

Lead

Before Cleaning Samples – Four pre-cleaning wipe samples were collected. Three of the 

four samples were above the detection limit. The fourth sample was below the detection 

limit. Two were above the primary clearance criterion of 25 μg/ft2

. Two of the samples 

were qualified as rejected due to field blank contamination. 

Post 1st Cleaning Samples – Two air samples and four wipe samples were collected after 

the first cleaning. All of the air and wipe samples were below the detection limit and met 

the primary air and wipe clearance criteria for lead after the first cleaning. 

 MMVF

Before Cleaning Samples – No pre-cleaning samples were collected for MMVF. 

 

Post 1st Cleaning Samples – Three air samples were collected after the first cleaning. 

MMVF was detected in two of three samples, but at levels below the primary clearance 

criterion of 10 S/L. 

 

PAH 

Before Cleaning Samples – Four wipe samples were collected. All of the samples were 

below the detection limit. The TEF for each sample was below the primary clearance 

criterion. One PAH compound was detected in the fourth sample; however, the TEF was 

below the primary clearance criterion of 300 μg/m2. 

Post 1st Cleaning Samples – Four wipe samples were collected. All four samples were 

below the detection limit. The TEF for each sample was below the primary clearance 

criterion of 300 μg/m2. 

Cedar Street Staircase – This area consisted of wood steps/landings, sheet rock walls and 

ceiling. Flooring was covered with vinyl tiles; walls and ceilings were covered with gloss paint. 

Cleaning Method – This area was cleaned using Test 4A and Test 4B. Test 4A utilized a 

commercial HEPA-filtered vacuum and an AFD. Test 4B consisted of soap and water wet wipe 

of all horizontal and vertical surfaces. 

 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned once. 

Asbestos

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected. The air samples were 

analyzed using PCM, TEM AHERA, and PCMe. The PCM results were below the 

secondary numeric criterion of 0.01 f/cc. The TEM AHERA results indicate that 

chrysotile was present, but both samples were below the secondary numeric criterion of 

0.022 S/cc. The PCMe results indicate that one sample was below the detection limit and 

the other had chrysotile present, but at a concentration below the primary clearance 
83

criterion of 0.0009 S/cc. 

 Gypsum

 Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – Two air samples were collected. Gypsum was not detected 

in either sample. 

 Lead

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Lead 

was not detected in either sample. The results were below the primary clearance criterion 

of 1.0 μg/m3

. Because the primary clearance criterion was met for lead after the first 

cleaning, no additional lead samples were collected. 

 Alpha-Quartz

 Before Cleaning Samples – There were no samples collected before cleaning.

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

samples were below the detection limit. 

 Calcite

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

 Cristobalite

 Before Cleaning Samples – There were no air samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

 Tridymite

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

were below the detection limit. 

 MMVF

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

results indicate that MMVF was only present in one sample. Both samples were below 

the primary clearance criterion of 10 S/L. 
84

Chiropractor’s Office – This is a 716 sq. ft. office space with four examination rooms facing 

the World Trade Center site. All front windows were blown in. Significant amounts of dust 

were present on all horizontal and vertical surfaces. Floor areas were covered with wall-to-wall 

carpeting. The suspended ceiling was covered with fibrous tiles. There was a two-foot high void 

space above the ceiling. The space above the suspended ceiling contained the HVAC system and 

wood floor joist system for the third floor apartments. This area contained WTC-related and 

non-WTC- related dust. The space was extremely difficult to clean due to the presence of 

electrical wires, recessed lighting fixtures, sprinkler systems, and the dry, friable nature of the 

wood support system. Ceiling tiles, flexible ventilation ducts and office equipment were 

disposed of prior to cleaning. 

Cleaning Method – This unit was the subject of separate tests to evaluate five different cleaning 

techniques as described below: 

 Test 4A: Industrial HEPA-filtered vacuums and AFD. 

 Test 4B: Wet wipe all walls. 

 Test 4C: Hot water wet vacuum 

 Test 4D: A/C Duct Cleaning 

Test 4E: Water only wet-wipe of the bathroom floor and desktop. 

 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after the Test 4E cleaning event except for the lead wipe collected from the bathroom floor. 

 

Supplemental Sampling Activities – Prior to initiating pre-cleaning sampling activities as 

described below, EPA collected a bulk composite sample from the Chiropractor’s Office. The 

analytical data obtained from the bulk composite was utilized in identifying COPC 

concentrations present in settled dust, determining the applicability of regulatory standards, and 

identifying potential health and safety concerns. The Chiropractor’s Office was selected, based 

upon visual observation, as being representative of a “worst case scenario” in the study building. 

 Asbestos

Before Cleaning Samples – Two air samples, four micro vacuum samples, and five wipe 

samples were collected for asbestos. The air samples were analyzed for PCM and PCMe. 

The PCM results indicate that one sample was above the secondary numeric criterion of 

0.01 f/cc and one was below this value. The PCMe results were both below the detection 

limit and below the primary clearance criterion of 0.0009 S/cc. All four of the micro 

vacuum samples contained chrysotile above the detection limit. All five wipe samples 

were also above the detection limit, with chrysotile being detected in all five samples and 

amosite in two of the five samples. 

 

Post 1st Cleaning Samples (Test 4A) – Three air, four micro vacuum, and five wipe 

samples were collected for asbestos. The air samples were analyzed for PCM and PCMe; 

however, none of the analyses could be completed due to overloading of particulate 

material. 

The results of the four micro vacuum samples indicate that asbestos was present at levels 

lower than those observed before cleaning. 
85

Asbestos was present in all five wipe samples at lower concentrations than those 

observed before cleaning. One of the five samples was identified as being below the 

detection limit. 

Post 1st Cleaning Samples (Test 4B) – Three air samples and five wipe samples were 

collected for asbestos. The air samples were analyzed for PCM, TEM AHERA, and 

PCMe. The PCM results indicate that one sample could not be analyzed due to 

particulate overloading; two were above the secondary numeric criterion of 0.01 f/cc. 

The TEM AHERA results indicate that two samples could not be analyzed due to 

particulate overloading; one sample was above the secondary numeric criterion of 0.022 

S/cc. The PCMe results indicate that two of the samples could not be analyzed due to 

particulate overloading; one was above the primary clearance criterion of 0.0009 S/cc. 

The results of the five wipe samples indicate that asbestos was present in all five samples 

at lower concentrations than those observed before cleaning. 

Post 1st Cleaning Samples (Test 4C) – Five air samples and four micro vacuum samples 

were collected for asbestos. The air samples were analyzed for PCM, TEM AHERA, and 

PCMe. The PCM analysis could not be conducted due to overloading of the filter with 

particulate matter. The TEM AHERA results indicate that three of the five samples could 

not be analyzed due to overloading of the filters with particulate material. The remaining 

two samples were below the secondary numeric criterion of 0.022 S/cc. The PCMe 

results indicate that three of the five air samples analyzed could not be analyzed due to 

overloading of particulate matter. The remaining two PCMe results indicate that one 

sample was below the primary clearance criterion and one sample exceeded the primary 

clearance criterion of 0.0009 S/cc at 0.0033 S/cc. 

The results of the four micro vacuum samples indicate that asbestos was present in all 

five samples at lower concentrations than those observed before cleaning, but at similar 

concentrations to those after Test 4A cleaning. 

Post 1st Cleaning Samples (Test 4D) – Three air samples were collected for asbestos. The 

samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM results indicate 

that all three samples were below the secondary numeric criterion of 0.01 f/cc. The TEM 

AHERA results indicate that all three samples were below the detection limit and below 

the secondary numeric criterion of 0.022 S/cc. The PCMe results were all below the 

detection limit and were below the primary clearance criterion of 0.0009 S/cc. 

 Dioxin

Before Cleaning Samples – One air sample and four wipe samples were collected and 

analyzed for dioxin. The results indicate that there was dioxin present; however, the TEQ 

concentration for each sample was below the primary clearance criterion of 4 ng/m2

. 

Post 1st Cleaning Samples (Test 4A) – Four wipe samples were collected and analyzed for 

dioxin. The TEQ concentration for each sample was below the primary clearance 

criterion of 4 ng/m2

. 

Post 1st Cleaning Samples (Test 4B) – Four wipe samples were collected and analyzed for 
86

dioxin. The concentrations of dioxin were similar to the pre-cleaning samples. The TEQ 

concentration for each sample was below the criterion of 4 ng/m2.

Post 1st Cleaning Samples (Test 4E) – Three wipe samples were collected and analyzed 

for dioxin. The concentrations of dioxin were slightly lower than the pre-cleaning 

samples. The TEQ concentration for each sample was below the criterion of 4 ng/m2

. 

 

 Gypsum

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected. Gypsum was not 

detected in the air samples above the detection limit range of 0.008 mg/m3 to 0.017 

mg/m3

. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Gypsum was 

detected in air at concentrations of 0.011 mg/m3 and 0.014 mg/m3. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Gypsum was 

detected in air above the detection limit with the results of 0.009 mg/m3 to 0.012 mg/m3. 

 Lead

Before Cleaning Samples – Four micro vacuum samples and four wipe samples were 

collected. Lead was detected in all of the micro vacuum samples and wipe samples. 

Three of the four micro vacuum results exceeded the comparison value of 25 μg/ft2

, 

ranging from 28.2 μg/ft2

 to181 μg/ft2. Wipe sample concentrations exceeded the primary 

clearance criterion of 25 μg/ft2

 in all of the samples, ranging in concentrations from 74.7 

μg/ft2 to 433 μg/ft2. 

Post 1st Cleaning Samples (Test 4A) – Two air samples, four micro vacuum samples, and 

four wipe samples were collected after the first cleaning. The two air samples were 

below the primary clearance criterion of 1.0 μg/m3

. The results of the micro vacuum and 

wipe samples show that, while all of the micro vacuum and two of the wipes samples 

were below the comparison value or primary clearance criterion. The remaining two 

wipe samples exceeded the primary clearance criterion with concentrations of 64.5 μg/ft2

and 146 μg/ft2

. 

Post 1st Cleaning Samples (Test 4B) – Two air samples and four wipe samples were 

collected. The two air samples were below the primary clearance criterion of 1.0 μg/m3

. 

Two of the four wipe samples exceeded the primary clearance criterion at concentrations 

of 147 μg/ft2 and 556 μg/ft2. 

Post 1st Cleaning Samples (Test 4C) – Two air samples and four micro vacuum samples 

were collected. The two air samples both exceeded the primary clearance criterion at 

1.89 μg/m3

 and 2.56 μg/m3. All four micro vacuum samples were below the comparison 

value of 25 μg/ft2. 
87

Post Cleaning Samples (Test 4D) – Two air samples were collected. Both were below the 

detection limit of 0.052 μg/m3 and the primary clearance criterion of 1.0 μg/m3. 

Post 1st Cleaning Samples (Test 4E) – Three wipe samples were collected. Two of the 

three samples were below their respective primary clearance criterion. The third sample 

exceeded the primary clearance criterion of 25 μg/ft2

 at a concentration of 954 μg/ft2. 

 Alpha-Quartz

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected after the first 

cleaning. Samples were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Samples were 

below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 Calcite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected after the first 

cleaning. Samples were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Samples were 

below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 Cristobalite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected after the first 

cleaning. Both samples were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Both samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected after the first 
88

cleaning. Both samples were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Both samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 MMVF

Before Cleaning Samples – Two air samples and four wipe samples were collected. 

MMVF was present in both air samples, but below the primary clearance criterion of 10 

S/L. The four wipe samples had detectable concentrations of MMVF. 

 

Post 1st Cleaning Samples (Test 4A) – Three air samples and five wipe samples were 

collected after the first cleaning. All of the air sample results indicate that MMVF was 

present at levels below the primary clearance criterion of 10 S/L. All of the wipe sample 

results indicate that MMVF was present at concentrations below pre-cleaning samples. 

Post 1st Cleaning Samples (Test 4B) – Three air samples and five wipe samples were 

collected after the first cleaning. Two of the three air samples exceeded the primary 

clearance criterion of 10 S/L at 17.579 S/L and 60.606 S/L. All of the wipe samples were 

below the concentrations detected during pre-cleaning sampling and were similar to the 

concentrations after Test 4A. 

Post 1st Cleaning Samples (Test 4C) – Five air samples were collected after the first 

cleaning. All of the air samples indicate that MMVF was present at levels below the 

primary clearance criterion of 10 S/L. 

Post 1st Cleaning Samples (Test 4D) – Three air samples were collected after cleaning. 

All of the air samples indicate that MMVF was present at levels below the primary 

clearance criterion of 10 S/L. 

 

 PAH 

Before Cleaning Samples – Two air samples and four wipe samples were collected. The 

two air samples both detected six PAH compounds; however, the calculated TEFs were 

below the primary clearance criterion of 0.2 μg/m3. Two of the four wipe samples also 

detected three PAH compounds; however, the calculated TEFs were below the primary 

clearance criterion of 300 μg/m2

. The remaining two samples were below the detection 

limit. The TEF for each sample was below the primary clearance criterion. 

Post 1st Cleaning Samples (Test 4A) – Four wipe samples were collected. All four 

samples were below the detection limit. The TEF for each sample was below the primary 

clearance criterion of 300 μg/m2

. 

Post 1st Cleaning Samples (Test 4B) – Four wipe samples were collected. All four 

samples were below the detection limit. The TEF for each sample was below the primary 

clearance criterion of 300 μg/m2

. 
89

Post 1st Cleaning Samples (Test 4E) – Three post-cleaning wipe samples were collected. 

All three samples were below the detection limit. The TEF for each sample was below 

the primary clearance criterion of 300 μg/m2. 

Elevator Shaft/Compactor Room – This area consisted of an elevator shaft with a soil floor and 

an adjacent compactor room with a concrete floor. Construction was of cinder block walls and 

exposed floor joists. 

Cleaning Method – This area was cleaned using Test 4A. Test 4A consisted of use of an 

industrial HEPA-filtered vacuum and an AFD. No wet wiping was performed. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned once. 

Asbestos

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Three air samples were collected. The three air samples 

were analyzed using PCM, TEM AHERA, and PCMe. The three PCM results were all 

below the secondary numeric criterion of 0.01 f/cc. Two of the three results were below 

the detection limit. Similarly, the TEM AHERA results were all below the secondary 

numeric criterion of 0.022 S/cc. All three of the samples were also below the detection 

limit. The PCMe results were all below the primary clearance criterion of 0.0009 S/cc, 

with all three of the samples below the detection limit. 

Lead

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. The 

two air samples were below the detection limit. 

MMVF

Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples – Three air samples were collected after the first cleaning. 

MMVF was present in each of the three samples; however, the concentrations were below 

the primary clearance criterion of 10 S/L. 

The Food Exchange – This unit is a 5,000 sq. ft. restaurant occupying three floors. The first 

floor is at street level with entrances from both Liberty and Cedar Streets. This floor was used for 

food service and customer dining. The lower level (basement) was used for food preparation and 

storage. The third level (sub-basement) was used for storage of restaurant equipment. Ceramic 

tile covers the floor area in both the dining room and the basement. The floor of the sub-basement 

is packed soil. All exterior windows had been blown inward depositing significant amounts of 

dust on all surface areas of the first floor. Minimal dust was present in the basement. The first 
90

floor ceiling by the Liberty Street entrance is made of gypsum board. The ceiling on the Cedar 

Street entrance consists of suspended acoustical tile covered with decorative tin facing. Above the 

suspended ceiling is a two-foot void space that houses the HVAC system for the establishment. 

The basement ceiling is a suspended fibrous tile ceiling. The void space above both suspended 

ceilings and the gypsum ceiling contained both WTC-related and non-WTC- related dust. 

Asbestos pipe insulation was present in the void space of the basement. Grills, refrigerators, 

tables and chairs were present on the first floor. The basement contains walk-in refrigerators, 

preparation tables, stoves, dishwashing areas and dry goods storage. Prior to cleaning, all open 

and bulk stored food, fibrous ceiling tiles in the basement, and wrap insulation that had 

surrounded the HVAC systems were disposed. 

Cleaning Method – This unit was cleaned using Test 4A and Test 4D. Test 4A consisted of use 

of an industrial HEPA-filtered vacuum and an AFD. All horizontal surfaces were wet wiped. 

Test 4D consisted of cleaning of the HVAC system by a subcontractor utilizing standard industry 

cleaning techniques. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned once. 

 Asbestos

Before Cleaning Samples – One wipe sample and one bulk sample were collected from 

the HVAC system. The wipe sample concentration was below the detection limit, 

however the detection limit was much higher than the other wipe sample detection limit 

(approximately 300,000 vs. 3,000). The bulk sample was analyzed by PLM and asbestos 

was not detected. 

Post 1st Cleaning Samples (Test 4A) – Eight air samples were collected for asbestos. The 

air samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM results 

indicate that six of the samples were below the detection limit and all eight samples were 

below the secondary numeric criterion of 0.01 f/cc. The TEM AHERA results indicate 

that seven of the samples were below the detection limit and all eight samples were below 

the numeric criterion of 0.022 S/cc. The PCMe results indicate that all eight of the air 

samples were below the detection limit and below the primary clearance criterion of 

0.0009 S/cc. 

Post 1st Cleaning, HVAC System – Three air and two wipe samples were collected. The 

air samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM results 

indicate that all of the samples were below the secondary numeric criterion of 0.01 f/cc. 

The TEM AHERA results indicate that two of the samples were below the detection limit 

and the third was at the detection limit with all three being below the secondary numeric 

criterion of 0.022 S/cc. The PCMe results indicate that two of the samples were below 

the detection limit and the third was at the detection limit with all three being below the 

primary clearance criterion of 0.0009 S/cc. 

 Gypsum

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples, HVAC System – One air sample was collected after the first 
91

cleaning. Gypsum was not detected above the detection limit of 0.008 mg/m3 in the air 

sample. 

 Lead (HVAC)

Before Cleaning Samples – One wipe sample was collected from the HVAC system. 

Lead was detected above the primary clearance criterion of 25 μg/ft2

 at 1310 μg/ft2. 

Post 1st Cleaning Samples, HVAC System – Two air samples and two wipe samples were 

collected after the first cleaning. The two air samples were below the detection level and 

primary clearance criterion of 1.0 μg/m3

. Lead concentrations exceeded the primary 

clearance criterion at 136 μg/ft2

 and 183 μg/ft2. The post-cleaning lead exceedances were 

attributed to the composition of the HVAC construction material. 

Post 1st Cleaning Samples (Test 4A) – Five air samples were collected. All were below 

the detection level. 

 Alpha-Quartz (HVAC)

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples, HVAC System – One air sample was collected after the first 

cleaning. The air sample was below the detection limit. 

 

 Calcite (HVAC)

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples, HVAC System – One air sample was collected. The air sample 

was below the detection limit. 

 Cristobalite (HVAC)

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples, HVAC System – One air sample was collected after the first 

cleaning. The air sample was below the detection limit. 

 Tridymite (HVAC)

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples, HVAC System – One air sample was collected. The air sample 

was below the detection limit. 

 MMVF (HVAC)

Before Cleaning Samples – One sample was collected. The wipe sample had an MMVF 

concentration of 11732.44 S/cm2

. 

Post 1st Cleaning Samples, HVAC System – Three air samples and two wipe samples were 

collected. All of the air and wipe sample results indicate that MMVF concentrations were 

below the detection limit and that the air samples were below the primary clearance 
92

criterion of 10 S/L. This indicates that the cleaning method was able to reduce the precleaning concentration of MMVF in the HVAC system. 

Post 1st Cleaning Samples (Test 4A) – Eight air samples were collected. All sample 

concentrations were below the primary clearance criterion of 10 S/L. Six of the eight 

samples were below the detection limit. 

 Total Dust

 Before Cleaning Samples – There were no samples collected before cleaning. 

Post 1st Cleaning Samples, HVAC System – The results for the micro vacuum sample 

indicated that dust was present below the clearance criteria of 0.5 mg/cm2

. This value is 

lower than the clearance criteria set by NADCA. 

Lemongrass Grill – This unit is 3,500 square feet in area with two floors. All exterior windows 

facing the WTC were blown inward depositing significant amounts of dust on all surfaces of the 

first floor. Minimal dust was present in the basement. The first floor is at street level with 

entrances from both Liberty and Cedar Streets. The lower level (basement) was used for food 

preparation and storage. Gypsum ceilings and hardwood floors are present throughout the dining 

area. Wood floor joists and sub-floor from the first floor constitute the basement ceiling. The 

dining area is decorated with Thai accents consisting of bamboo and thatch. 

Grills, ovens, refrigerators, tables, chairs and a bar are on the first floor. The basement contains a 

walk-in refrigerator, freezers, preparation table, dishwasher, and dry goods storage. The floor of 

the basement is concrete. The establishment’s HVAC system is suspended from the ceiling of 

the first floor. 

Prior to cleaning, all tables, chairs, containerized food and accent decorations were disposed. 

Restaurant equipment including woks, utensils, pots, pans, and flatware were vacuumed and 

washed. 

Cleaning Method – This unit was cleaned using Test 4A and Test 4D. Test 4A consisted of use 

of an industrial HEPA-filtered vacuum and an AFD. Test 4D consisted of professional cleaning 

of the HVAC system using standard industry techniques. All horizontal surfaces were wet 

wiped. This cleaning method was used for each cleaning event. The HVAC system was also 

cleaned and tested. 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after being cleaned twice. The HVAC met the clearance criteria after being cleaned once. 

 Asbestos

HVAC Cleaning Results – One wipe sample and one bulk sample were collected from the 

HVAC system. The wipe sample concentration was below the detection limit, however 

the detection limit was much higher than the other wipe sample detection limit 

(approximately 12,000 vs. 3,000). The bulk sample was analyzed by PLM and found to 

be less than one percent asbestos. 
93

Post 1st Cleaning – Five air samples were collected from the first floor and one air sample 

was collected from the basement. The samples were analyzed for PCM, TEM AHERA, 

and PCMe. The PCM, TEM AHERA and PCMe analyses of the five samples collected 

from the first floor could not be conducted due to overloading of particulate material. 

The sample collected from the basement met the primary clearance criterion and 

secondary numeric criterion. 

Post 2nd Cleaning – Seven air samples were collected after the second cleaning. The 

samples were analyzed for PCM, TEM AHERA, and PCMe. The PCM results were all 

below the secondary numeric criterion of 0.01 f/cc. Five of the samples were below the 

detection limit. The TEM AHERA results were all below the secondary numeric 

criterion of 0.022 S/cc, with six of the seven samples below the detection limit. The 

PCMe results were all below the primary clearance criterion of 0.0009 S/cc, with six of 

the seven samples below the detection limit. The seventh sample was at the detection 

limit of 0.0005 S/cc. This indicates that the cleaning techniques were effective at 

removing particulate matter after the first cleaning, which allowed valid asbestos air 

samples to be collected. The results indicate that the unit met the primary clearance and 

secondary numeric criteria. 

HVAC System – Four air samples and two wipe samples were collected after the HVAC 

system was cleaned. The air samples were analyzed for PCM, TEM AHERA, and PCMe. 

The PCM results were all below the secondary numeric criterion of 0.01 f/cc. The TEM 

AHERA results indicate that two samples were below the detection limit and that two 

samples were equal to the detection limit of 0.0005 S/cc. The PCMe results indicate that 

all four samples were below the detection limit of 0.0005 S/cc. 

The results for the two asbestos wipe samples indicate that both samples were below the 

detection limit. The detection limit (12,100 S/cm2

) was higher than the detection limit 

(approximately 3,000 S/cm2

) for most other wipe samples on this project. 

 Dioxin

 Before Cleaning Samples – There were no samples collected and analyzed for dioxin. 

 Post 1st Cleaning Samples – There were no samples collected and analyzed for dioxin. 

 HVAC System – There were no samples collected and analyzed for dioxin. 

 Gypsum

 Before Cleaning Samples – Pre-cleaning air samples were not collected. . 

Post 1st Cleaning Samples – There were no samples collected after the first cleaning for 

gypsum. 

HVAC System – One air sample was collected for gypsum. This sample was below the 

detection limit. 
94

Lead (HVAC)

Before Cleaning Samples – One wipe sample was collected. Lead was detected at a 

concentration above the primary clearance criterion of 25 μg/ft2 with a value of 10700 

μg/ft2

. 

Post 1st Cleaning Samples – Four air samples were collected. All four samples were 

below the primary clearance criterion of 1.0 μg/m3

. One of these samples was collected 

from the basement. 

 

HVAC System – Three air samples and two wipe samples were collected after the HVAC 

system was cleaned. The air sample results indicate that all three air samples were below 

the detection limit. The two wipe sample results indicated that lead was still present at 

25.9 μg/ft2 and 166 μg/ft2. Both of these results were above the primary clearance 

criterion. Post cleaning lead exceedances were attributed to the composition of the 

HVAC construction material. 

 Alpha-Quartz (HVAC)

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 Post 1st Cleaning Samples – There were no samples collected after the first cleaning. 

HVAC System – One air sample was collected. The air sample was below the detection 

limit. 

 Calcite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 

 Post 1st Cleaning Samples – There were no samples collected after the first cleaning. 

HVAC System – One air sample was collected after the HVAC system was cleaned. This 

sample was below the detection limit. 

 Cristobalite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 Post 1st Cleaning Samples – There were no samples collected after the first cleaning. 

HVAC System – One air sample was collected after the HVAC system was cleaned. This 

sample was below the detection limit. 

 Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 Post 1st Cleaning Samples – There were no samples collected after the first cleaning. 

 HVAC System – One air sample was collected after the HVAC system was cleaned. This 

 sample was below the detection limit. 
95

MMVF

Before Cleaning Samples – One wipe sample was collected. The sample was below the 

detection limit. 

Post 1st Cleaning Samples – Five air samples were collected after the first cleaning. 

MMVF was below the detection limit. 

HVAC System – Four air and two wipe samples were collected after the HVAC system 

was cleaned. The results for all air and wipe samples indicate that MMVF was below the 

detection limit and that the air samples were below the primary clearance criteria of 10 

S/L. 

Post 2nd Cleaning Samples – One air sample was collected after the second cleaning. The 

result was below the detection limit. 

 PAH

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were no samples collected after the first cleaning. 

 Total Dust

 Before Cleaning Samples – There were no samples collected before cleaning. 

 Post 1st Cleaning Samples – There were no samples collected after the first cleaning. 

HVAC System – One micro vacuum sample was collected. The results for the micro 

vacuum sample indicate that dust was present below the clearance criterion of 0.50 

mg/cm2. This value is lower than the clearance criterion set by NADCA. 

Liberty Street Staircase – The stairwell consisted of cast concrete steps/landings, sheet rock 

walls and ceiling. All surfaces were covered with gloss paint. 

Cleaning Method – This area was cleaned using Test 4A and Test 4B. Test 4A consisted of use 

of an industrial HEPA-filtered vacuum and an AFD. Test 4B consisted of soap and water wet 

wipe of all horizontal and vertical surfaces. 

Cleaning Results – This area did not meet the primary clearance criterion for alpha-quartz listed 

in Table 1.0. Due to a delay in receiving analytical results, this exceedance was not identified 

until after the close of the study. However, the only elevated sampling result for airborne alphaquartz was obtained from the Liberty Street staircase. This result is inconsistent with the other 

53 samples taken throughout apartments and common spaces in the building. Those results were 

all reported to be below the detection limit. Consequently, the presence of a single elevated 

sample result in a low occupancy area of the building is not indicative of a health hazard. 

 

 Asbestos 

 Before Cleaning Samples – There were no samples collected. 
96

Post 1st Cleaning Samples – Two air samples were collected for asbestos. These samples 

were analyzed for PCM, TEM AHERA, and PCMe. The PCM results were all below the 

secondary numeric criterion of 0.01 f/cc. The TEM AHERA results indicate that one was 

below the detection limit and one was at the detection limit. Both samples were below 

the secondary numeric criterion of 0.022 S/cc. The PCMe results indicate that one was 

below the detection limit and one was at the detection limit. Both samples were below 

the primary clearance criterion of 0.0009 S/cc. 

 Gypsum

 Before Cleaning Samples – There were no samples collected. 

 Post 1st Cleaning Samples – Two air samples were collected. Gypsum was not detected. 

 Lead

 Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – Two air samples were collected for lead. Lead was not 

detected in either sample. 

 

 Alpha-Quartz

 Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. One 

sample exceeded the primary clearance criterion of .004 mg/m3. Alpha-quartz was not 

detected in the remaining sample. 

 Calcite

Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

samples were below the detection limit. 

 Cristobalite

Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

samples were below the detection limit. 

 Tridymite

Before Cleaning Samples – There were no samples collected. 

Post 1st Cleaning Samples – Two air samples were collected after the first cleaning. Both 

samples were below the detection limit. 

 MMVF

 Before Cleaning Samples – There were no samples collected. 
97

Post 1st Cleaning Samples – Two air samples were collected. The results for both 

samples were below the primary clearance criterion of 10 S/L. 

Mattress Store – This is a 968 sq. ft. open space facing the World Trade Center site. All front 

windows were blown in. Significant amounts of dust were present on all horizontal surfaces. 

Floor areas were covered with wall-to-wall carpeting. Approximately 25 display mattresses and 

box springs were present. Ceiling tiles, mattresses, office equipment and flexible ventilation 

ducts were removed and disposed of prior to cleaning. The space above the suspended ceiling 

exhibited the same characteristics as in the Chiropractor’s Office. 

Cleaning Method – This unit was the subject of separate tests to evaluate five different cleaning 

techniques as described below: 

 Test 4A: Industrial HEPA-filtered vacuums and AFD 

 Test 4B: Wet wipe all walls 

 Test 4C: Hot water carpet shampoo 

 Test 4D: A/C duct cleaning 

Test 4E: Cleaning of vinyl floor tile and wet wipe of window ledge using water 

only 

Cleaning Results – This unit met the clearance criteria listed in Table 1.0 for each compound 

after the Test 4E cleaning event except for one lead wipe which was collected from a window 

ledge. 

Supplemental Sampling Activities – Prior to initiating pre-cleaning sampling activities as 

described below, EPA collected a bulk composite sample from the Mattress Store. The 

analytical data obtained from the bulk composite was utilized in identifying COPC 

concentrations present in settled dust, determining the applicability of regulatory standards, and 

identifying potential health and safety concerns. The Mattress Store was selected, based upon 

visual observation, as being representative of a “worst case scenario” in the study building. 

 Asbestos

Before Cleaning Samples – Four air, seven micro vacuum, and three wipe samples were 

collected for asbestos. The air samples were analyzed for PCM and PCMe. The PCM 

results indicate that two of the samples were above and two of the samples were below 

the secondary numeric criterion of 0.01 f/cc. The PCMe results indicate that two of the 

samples could not be analyzed due to overloading of particulate material. The remaining 

two samples were below the detection limit and below the primary clearance criterion of 

0.0009 S/cc. All seven of the micro vacuum samples and all three of the wipe samples 

detected chrysotile. 

Post 1st Cleaning Samples (Test 4A) – Three air samples, seven micro vacuum samples 

and four wipe samples were collected for asbestos. The air samples were analyzed for 

PCM, TEM AHERA, and PCMe. The PCM results indicate that all three samples were 

below the secondary numeric criterion of 0.01 f/cc. The TEM AHERA results indicate 

that two of the samples could not be analyzed due to overloading of particulate material. 

The remaining sample was below the secondary numeric criterion of 0.0022 S/cc. The 

PCMe results indicate that two of the samples could not be analyzed due to overloading of 
98

particulate material. The remaining sample was below the primary clearance criterion of 

0.0009 S/cc. The results of the seven micro vacuum samples indicate that asbestos was 

present at concentrations lower than those observed before cleaning. The results of the 

wipe samples indicate that asbestos was present in all four samples at higher 

concentrations than those observed before cleaning. 

Post 1st Cleaning Samples (Test 4B) – Three air samples and four wipe samples were 

collected for asbestos. The three air samples were analyzed using PCM, TEM AHERA, 

and PCMe. The PCM results indicate that two samples could not be analyzed due to 

overloading of particulate material and one sample was above the secondary numeric 

criterion of 0.01 f/cc. The TEM AHERA and PCMe analyses could not be analyzed due 

to overloading of particulate matter. 

Asbestos was present in three of the four wipe samples at higher concentrations than 

those observed before cleaning, but similar to the Test 4A samples. One sample was 

recorded as below the detection limit; however, the detection limit was greater than 

normal due to the presence of particulate material. 

Post 1st Cleaning Samples (Test 4C) – Five air and seven micro vacuum samples were 

collected. Five air samples were analyzed using PCM, TEM AHERA, and PCMe. The 

PCM results indicate that all five samples were below the secondary numeric criterion of 

0.01 f/cc. The TEM AHERA results indicate that all five samples were below the 

secondary numeric criterion of 0.022 S/cc. The PCMe results indicate that all five 

samples were above the primary clearance criterion of 0.0009 S/cc. The results of the 

seven micro vacuum samples indicate that asbestos was present in concentrations above 

the detection level in four of the seven samples. However, post-cleanup sample 

concentrations were lower than those observed before cleaning and after Test 4A 

cleaning. 

Post 1st Cleaning Samples (Test 4D) – Three air samples were collected and analyzed 

using PCM, TEM AHERA, and PCMe. The PCM results indicate that all three samples 

were below the detection limit and below the secondary numeric criterion of 0.01 f/cc. 

The TEM AHERA results indicate that all three samples were below the detection limit 

and below the secondary numeric criterion of 0.022 S/cc. The PCMe results indicate that 

all three samples were below the detection limit and below the primary clearance criterion 

of 0.0009 S/cc. 

 Dioxin

Before Cleaning Samples – Two air samples and three wipe samples were collected and 

analyzed for dioxin. The results indicate that dioxin was present; however, the TEQ 

concentration for each sample was below the primary clearance criterion of 0.001 ng/m3

for air and 4 ng/m2 for settled dust. 

Post 1st Cleaning Samples (Test 4A) – Four wipe samples were collected and analyzed for 

dioxin. The concentrations of dioxin were similar to the pre-cleaning samples. The TEQ 

concentration for each sample was below the primary clearance criterion of 4 ng/m2. 

Post 1st Cleaning Samples (Test 4B) – Four post-cleaning wipe samples were collected 
99

and analyzed for dioxin. The concentrations of dioxin were slightly higher than the precleaning samples. The TEQ concentration for each sample was below the primary 

clearance criterion of 4 ng/m2

. 

 

Post 1st Cleaning Samples (Test 4E) – Two post-cleaning wipe samples and two prewater wipe samples were collected and analyzed for dioxin. The results indicate that the 

concentrations of dioxin were similar to the pre-cleaning samples. TEQ concentrations 

were below the primary clearance criterion of 4 ng/m2

. 

 

 Gypsum

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected. Gypsum was not 

detected in the air samples above the detection limit. 

Post 1st Cleaning Samples, (Test 4B) – Two air samples were collected. Gypsum was not 

detected in the air samples above the detection limit. 

 

Post 1st Cleaning Samples, (Test 4C) – Two air samples were collected. Gypsum was not 

detected in the air samples above the detection limit. 

 Lead

Before Cleaning Samples – Seven micro vacuum samples and three wipe samples were 

collected. All seven micro vacuum samples were below the comparison value of 25 

μg/ft2. Two of the three wipe samples were above the primary clearance criterion of 25 

μg/ft2

. The third was below the detection limit. Concentrations of lead in the two wipe 

samples, which exceeded the primary clearance criterion of 25 μg/ft2, were 38.9 μg/ft2

and 77 μg/ft2. 

Post 1st Cleaning Samples (Test 4A) – Two air samples, seven micro vacuum samples, 

and four wipe samples were collected after the first cleaning. The two air samples were 

below the primary clearance criterion of 1.0 μg/m3

. Five of the seven micro vacuum 

samples were below the detection limit. All seven samples were below the comparison 

value. Two of the four wipe samples exceeded the primary clearance criterion with 

concentrations of 42.2 μg/ft2

 and 43.9 μg/ft2. Of the remaining two samples, one was 

below the primary clearance criterion and both were below the detection limit and below 

the primary clearance criterion. 

Post 1st Cleaning Samples (Test 4B) – Two air samples and four wipe samples were 

collected. The two air samples were below the primary clearance criterion of 1.0 μg/m3. 

Two of the four wipe samples exceeded the primary clearance criterion with 

concentrations of 91.5 μg/ft2

 and 79.3 μg/ft2. Of the remaining two, one was below the 

primary clearance criterion and the other was below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples and seven micro vacuum samples 

were collected. The two air samples were below the primary clearance criterion of 1.0 

μg/m3

. All seven micro vacuum samples were below the comparison value of 25 μg/ft2. 
100

Six were below the detection limit. 

Post 1st Cleaning Samples (Test 4D) – Two air samples were collected, both with results 

below the 0.051 μg/m3

 detection limit as well as the primary clearance criterion of 1.0 

μg/m3. 

Post Cleaning Samples (Test 4E) – Three wipe samples were collected. The glass jars 

containing two of the samples were broken at the laboratory; however, the laboratory was 

able to analyze these samples. The samples were below the primary clearance criterion of 

25 μg/ft2

. The third sample exceeded the primary clearance criterion at a concentration of 

38.2 μg/ft2

. Re-cleaning and testing at this location was not performed since this sample 

was collected on a window sill which was later painted by the property owner. 

 Alpha-Quartz

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – There were two air samples collected after the first 

cleaning. Both air samples were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Both samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 

 Calcite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected. Both air samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Both samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 Cristobalite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected after the first 

cleaning. Both air samples were below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Both samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 
101

the detection limit. 

 Tridymite

 Before Cleaning Samples – Pre-cleaning air samples were not collected. 

Post 1st Cleaning Samples (Test 4A) – Two air samples were collected. Both air samples 

were below the detection limit. . 

Post 1st Cleaning Samples (Test 4B) – Two air samples were collected. Both samples 

were below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Two air samples were collected. Both were below 

the detection limit. 

 MMVF

Before Cleaning Samples – Four air samples and three wipe samples were collected. All 

four air samples were above the detection limit. MMVF was detected above the primary 

clearance criterion of 10 S/L in two of the four air samples. The three wipe samples had 

detectable concentrations of MMVF. 

 

Post 1st Cleaning Samples (Test 4A) – Three air samples and four wipe samples were 

collected. MMVF was present in all, but at concentrations below the primary clearance 

criterion of 10 S/L. All of the wipe sample results were below the concentrations 

detected during pre-cleaning sampling, with one below the detection limit. 

Post 1st Cleaning Samples (Test 4B) – Three air samples and four wipe samples were 

collected after the first cleaning. All three of the air samples were below the primary 

clearance criterion of 10 S/L. All of the wipe samples were below the concentrations 

detected during pre-cleaning sampling, with one below the detection limit. 

Post 1st Cleaning Samples (Test 4C) – Five air samples were collected after the first 

cleaning. MMVF was present in all, but at concentrations below the primary clearance 

criterion of 10 S/L. 

Post 1st Cleaning Samples (Test 4D) – Three air samples were collected after cleaning. 

All were below the detection limit and below the primary clearance criterion of 10 S/L. 

 

 PAH 

Before Cleaning Samples – One air sample and three wipe samples were collected. The 

air sample was below the detection limit. The TEF was below the primary clearance 

criterion of 0.2 μg/m3

. Two of the three wipe samples had PAH compounds detected. 

One sample detected three PAH compounds and the other detected two PAH compounds. 

The calculated TEFs for these two samples, as well as the third sample, were below the 

primary clearance criterion of 300 μg/m2

. 

Post 1st Cleaning Samples (Test 4A) – Four post-cleaning wipe samples were collected. 

All four were below the detection limit; the TEF for each sample was below the primary 
102

clearance criterion of 300 μg/m2. 

Post 1st Cleaning Samples (Test 4B) – Four post-cleaning wipe samples were collected. 

All four samples were below the detection limit; the TEF for each sample was below the 

primary clearance criterion of 300 μg/m2

. 

Post 1st Cleaning Samples (Test 4E) – Two wipe samples were collected. Both were 

below the detection limit; the TEF for each was below the primary clearance criterion of 

300 μg/m2. 
103

5. Discussion 

This project was an essential element of EPA's efforts in responding to concerns raised by 

residents of lower Manhattan regarding the presence of WTC dust in their homes. EPA 

endeavored to confirm that the cleaning methods that individuals were using, and that 

representatives of health and environmental agencies had recommended, were effective in 

removing the dust generated by the unprecedented disaster. 

Concurrent with this study, EPA conducted the Indoor Air Residential Assistance-WTC Dust 

Cleanup Program, cleaning residential spaces for residents of lower Manhattan who expressed 

interest. It was imperative to complete this study as quickly as possible to determine if the 

routine cleaning procedures being employed in the WTC Dust Cleanup Program required 

modification. 

The study addressed cleaning of a complex mixture of contaminants, including construction 

debris and fire-related compounds. As noted in the Executive Summary, EPA was unaware of a 

precedent for an indoor environmental cleanup with such a diverse set of parameters. However, 

time pressure did not allow for conducting extensive research on potential cleaning techniques in 

a controlled setting. The urgent and real-time need to determine the effectiveness of the cleaning 

methods being used by residents and being employed in the WTC Dust Cleanup Program drove 

the decision to field test the effectiveness of the standard dust removal methods in a heavilyimpacted unoccupied building. 

Multiple endpoints were used in the study to ensure that the complexity of the dust was 

comprehensively considered. Sampling for a variety of compounds was conducted before and 

after cleaning. Clearance was determined by the removal of contaminants to the health-based 

benchmarks established in the COPC/Benchmark Report. 

The study used a combination of data sets to determine the extent of contamination, the 

effectiveness of the cleaning methods, and the differences across various sampling and analytical 

methods. 

5.1 Data Sets 

Many different samples from multiple media for specific compounds were collected over the 

course of the study which resulted in a variety of data sets being generated. Different data sets 

were used to evaluate the objectives listed above. Multiple data sets were used for determining 

the extent of contamination before any cleaning events occurred and for evaluating the 

effectiveness of various cleaning methods. 

The most informative data sets included results from asbestos wipe sampling, lead wipe and micro 

vacuum sampling and MMVF wipe sampling events conducted before and after first cleaning of 

the residential units. The majority of results for other compounds for which wipe samples were 

collected before and after first cleaning (e.g., dioxin, PAH) were below the detection limits for both 

sampling events. Therefore, these data sets did not provide a useful basis for determining the 

extent of contamination prior to cleaning or for evaluating the effectiveness of the cleaning 

methods. Pre-cleaning air sampling was not conducted because of concerns that the presence of 

significant levels of dust accumulation might make overloading of filters more likely using the 
104

aggressive technique. 

The results from the two commercial units included as part of the study could not be used to 

evaluate existing contamination or overall cleaning efficiency, in as much as the cleaning and 

sampling process that was used in the commercial units differed from the cleaning and sampling 

process that was used in the residential units. The non-study commercial units were sampled 

only for post-cleaning clearance confirmation. 

It should be noted that samples were collected for alpha-quartz, calcite, gypsum, tridymite, 

crystobalite and total dust. However, data for these parameters are not included in this document 

due to uncertainties in the analytical results. Another data set, asbestos micro vacuum samples, 

was also not included for evaluating the extent of contamination or cleaning efficiency because 

the results were extremely variable and did not present consistent trends, as did other data. A 

work group of the Interagency Indoor Air Task Force debated the inclusion of asbestos micro 

vacuuming in this study as a result of concerns that the results would not be relevant because, as 

stated in the ASTM - Standard Test Method for Micro Vacuum Sampling and Indirect Analysis 

of Dust by Transmission Electron Microscopy for Asbestos Structure Number Concentrations: 

"...the collection efficiency of this technique is unknown and will vary among substrates.”19 

This uncertainty, combined with the high degree of uncertainty in predicting airborne asbestos 

levels based on the amount in settled dust20 and the variable nature of the asbestos micro vacuum 

results, limited the use of this data set. Despite these concerns and the quantitative limitations of 

the method, micro vacuuming was used in an effort to assess the presence of asbestos. 

The data sets that did not provide adequate information for determining the extent of existing 

contamination and the efficiency of cleaning methods, were useful, in combination with the other 

data sets, to address variances in the use of different sampling and analytical methods, and the 

use of different equipment. 

5.2 Extent of Contamination 

This study was designed to establish the effectiveness of a variety of cleaning methods in 

removing dust and associated materials related to the WTC collapse. In order to evaluate 

different cleaning methods, the degree of contamination prior to cleaning needed to be assessed. 

This was accomplished by visually observing the amount of dust in an apartment and by 

collecting samples prior to cleaning events. 

Qualitative visual observations of the quantities of WTC dust that had been deposited into each 

 19American Society for Testing and Materials. (1995). Standard Test Method for Microvacuum Sampling 

and Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos Structure Number Concentrations. 

(ASTM Publication No. D576-95.) West Conshohocken, PA. 

20The uncertainty of predicting airborne asbestos levels based on settled dust was recently reiterated by a 

panel of experts that peer reviewed an EPA report that proposed a health-based benchmark for asbestos in settled 

dust based on utilizing a K factor approach. Specifically, the peer review panel (www.tera.org) stated: 

"The panel did not endorse the asbestos settled dust benchmark because the only relevant exposure pathway for 

asbestos is inhalation and the K-factor methodology is, at this time, inadequate for predicting inhalation exposure from 

asbestos surface loading measurements." 
105

apartment were recorded in the initial phase of the study, prior to cleaning. Six apartments were 

identified as having accumulated a significant amount of dust. The remaining seven apartments 

were identified as having a minimal amount of dust accumulation. All of the apartments 

characterized as containing a significant amount of dust presented windows that had been blown 

in during the collapse of the WTC. The visual observations were used in an attempt to distribute 

the cleaning methods evenly, based on the amount of dust present. 

Once the analytical results were available, it was possible to quantitatively determine differences 

that existed in the amount of contamination that was present in the apartments prior to cleaning. 

As indicated above, the pre-cleaning results for asbestos wipe sampling, lead wipe and micro 

vacuum sampling, and MMVF wipe sampling results from the residential units provided the 

most complete data set for determining the existing contamination in apartments prior to 

cleaning. These four data sets were used to establish differences in contamination between 

apartments prior to cleaning. 

The results for each data set identified above were averaged by unit, then ranked from the highest 

concentration t the lowest concentration, which resulted in each unit having four rankings (one 

for each data set). These rankings are presented in Table 9.0. 

The range of the highest concentration to the lowest concentration for each compound or sample 

type spanned an order of magnitude. One apartment, 4B, did not contain any porous surfaces that 

could be sampled, therefore there were no micro vacuum samples collected. This prohibited this 

unit from being included in the ranking. 

Once the units were assigned a ranking for each data set, the rankings for each unit were summed 

to create a variable called "sum of ranks". This information is presented in Table 10.0. The sum 

of ranks has a theoretical range of 4-48, while the observed range in this evaluation was 13-45. 

This indicates that there was generally an even distribution within the theoretical range, with the 

exception of the lower end of the range, as there were no units which ranked less than 13. 

Therefore, the visual observations of dust generally corresponded with levels of contamination 

found in the dust. The results of the ranking evaluation indicates that there was a difference in 

the degree of an average contamination for these compounds between units prior to the cleaning 

events. 

1. 

The study found that there was a pre-cleaning difference 

in the levels of contamination among the units in the building.
106

Table 9.0 

Ranking of Residential Units for Four Contaminants based on Level of Contamination Before 

Cleaning 21 

Ranking by Asbestos Wipe Results Ranking by MMVF Wipe Results

Unit Rank 

Asbestos 

Wipe 

Lead 

Wipe

Lead 

Microvac

MMVF 

Wipe Unit Rank 

Asbestos 

Wipe

Lead 

Wipe

Lead 

Microvac

MMVF 

Wipe 

5A 1 65,290 732 2 799 2B 1 28,092 40 3 4,731 

3D 2 60,623 81 20 601 3B 2 2,566 9 5 1,259 

5C 3 35,021 129 177 687 4D 3 8,861 52 61 830 

3C 4 34,030 268 72 477 5A 4 65,290 732 2 799 

2B 5 28,092 40 3 4,731 2A 5 16,607 34 6 787 

2A 6 16,607 34 6 787 5C 6 35,021 129 177 687 

4C 7 14,242 88 75 477 3D 7 60,623 81 20 601 

5D 8 9,651 17 38 441 3A 8 2,962 19 5 515 

4D 9 8,861 52 61 830 3C 9 34,030 268 72 477 

3A 10 2,962 19 5 515 4C 10 14,242 88 75 477 

3B 11 2,566 9 5 1,259 5D 11 9,651 17 38 441 

4A 12 2,368 12 5 401 4A 12 2,368 12 5 401 

4B 7,911 25 n/a 501 4B 7,911 25 n/a 501 

Ranking by Lead Wipe Result Ranking by Lead Microvac Result

Unit Rank 

Asbestos 

Wipe

Lead 

Wipe 

Lead 

Microvac

MMVF 

Wipe Unit Rank 

Asbestos 

Wipe

Lead 

Wipe

Lead 

Microvac 

MMVF

Wipe

5A 1 65,290 732 2 799 5C 1 35,021 129 177 687 

3C 2 34,030 268 72 477 4C 2 14,242 88 75 477 

5C 3 35,021 129 177 687 3C 3 34,030 268 72 477 

4C 4 14,242 88 75 477 4D 4 8,861 52 61 830 

3D 5 60,623 81 20 601 5D 5 9,651 17 38 441 

4D 6 8,861 52 61 830 3D 6 60,623 81 20 601 

2B 7 28,092 40 3 4,731 2A 7 16,607 34 6 787 

2A 8 16,607 34 6 787 3A 8 2,962 19 5 515 

3A 9 2,962 19 5 515 3B 9 2,566 9 5 1,259 

5D 10 9,651 17 38 441 4A 10 2,368 12 5 401 

4A 11 2,368 12 5 401 2B 11 28,092 40 3 4,731 

3B 12 2,566 9 5 1,259 5A 12 65,290 732 2 799 

4B 7,911 25 n/a 501 4B 7,911 25 N/A 501 

 

 21The results for each compound and/or sample type were averaged by unit and then ranked from the 

highest concentration to the lowest concentration. The values presented in the tables represent the average 

concentration detected per unit. The average concentration calculation included samples that were identified as 

below the detection limit. These samples were assigned a value equal to the detection limit. The sample size for 

each unit was generally either four or five samples. Unit 4B was not included in the rankings because no micro 

vacuum samples were collected for lead before cleaning.
107

Table 10.0

Ranking of Residential Units by 

Pre-Cleaning Average Concentrations of Contaminants22 

Unit 

Number

Observable 

Dust

Cleaning 

Test

Times 

Cleaned

Presence of 

Belongings23

Asbestos 

Wipe

Lead 

Wipe

Lead 

Microvac

MMVF 

Wipe

Sum of 

Ranks 

 Rank Rank Rank Rank

5C significant 3A,3A,3B 3 No, 1 couch 3 3 1 6 13 

5A minimal 3B,3B 2 No, 1 couch 1 1 12 4 18 

3C significant 1A,1A,3B 3 No, 1 couch 4 2 3 9 18 

3D significant 1A,1A 2 no, 1 couch & 

chair 

2 5 6 7 20 

4D significant 2A,2A 2 no, 1 chair & 

ottoman 

9 6 4 3 22 

4C significant 1A 1 no, 1 couch 7 4 2 10 23 

2B minimal 3A 1 no, 1 couch 5 7 11 1 24 

2A minimal 1B,1B 2 no, 1 couch & 

chair 

6 8 7 5 26 

5D significant 3B 1 no, 1 couch 8 10 5 11 34 

3B minimal Scope A 2 Yes 11 12 9 2 34 

3A minimal 2B 1 yes, carpet 10 9 8 8 35 

4A minimal 2A,2A 2 no, 1 couch 12 11 10 12 45 

 

Cleaning Equipment: 

1A Basic w/o AFD 

2A Intermediate w/HEPA w/o AFD 

3A Advanced w/o AFD 

1B Basic w/AFD 

2B Intermediate w/HEPA w/AFD 

3B Advanced w/AFD 

The visual classification of dust in the apartments was also compared to the ranking for each 

apartment. There was general agreement between the visual observations and the analytical 

results in that five of the six units that were classified as having significant dust accumulation 

ranked in the top six places. This indicates that visual observations of dust is an indicator that 

contaminants associated with WTC-related dust may be present. 

 22Each contaminant per sampling type was ranked based upon the average concentration per unit with the 

highest average concentration receiving a rank of 1 and the remaining values continued in ascending order up to 12. 

The ranking for each combination was then summed for each unit to determine which unit had the highest overall 

concentration of contaminants. The sum of the rankings for each compound per unit indicates that 5C contained the 

highest concentrations of contaminants prior to cleaning. Note that the lower the sum of ranks, the higher the 

concentration of total contaminants. 

Unit 4B is not included in the list of rankings because there were no lead micro vacuum samples collected in this 

unit. As a point of reference, the sum of the ranks for 4B for the asbestos, lead, and MMVF wipe samples totals 27. 

This indicates that this unit would have placed in the bottom-tier of the rankings.

23In units where personal belongings were retained, the items were cleaned and bagged, simulating a 

situation where no belongings were present. 
108

5.3 Location of Units 

Based upon the visual observations of dust and the ranking of individual apartments for precleaning analytical results, it was noted that the apartments facing the WTC site corresponded 

with a higher average level of contamination within the unit for lead, asbestos and MMVF. 

Specifically, the units facing Liberty Street (units with C and D designations) which were in the 

direct path of the WTC collapse generally showed the greatest degree of contamination. This 

indicates that buildings, or portions of buildings, that had significant amounts of dust deposited 

from the WTC site may have had a greater amount of contamination than buildings that did not 

have significant amounts of dust deposited. 

5.4 Comparison to Health-Based Benchmarks 

The pre-cleaning analytical results for all of the data sets listed above were also evaluated to 

determine if the concentration of contaminants in the dust were elevated above health-based 

benchmarks. For this evaluation, the health-based benchmarks presented in Table 1.0 were used 

for comparison to the pre-cleaning and post-cleaning sampling results. Based on pre-cleaning 

data, there were ten residential units and five commercial units that exceeded a health-based 

benchmark for either lead, dioxin, PAH, or some combination of the three compounds. Based on 

post-cleaning data, an additional three residential units and one common area exceeded a healthbased benchmark for either asbestos, lead, MMVF, or alpha-quartz, or a combination of these 

compounds. 

Cumulatively, nineteen sites inside the building or 76 percent exceeded a health-based 

benchmark for one or more contaminants associated with the WTC collapse. This indicates that 

some contaminant concentrations exceeded health-based benchmarks. 

3. 

The study found that the portions of the building with 

higher levels of deposited WTC dust had higher levels of 

contamination.

4. 

The study found that concentrations of some contaminants 

in the WTC dust were elevated above health-based 

benchmarks.

2. 

The study found that the observation of WTC dust 

is an indicator that WTC contaminants may be present 

and that the amount of WTC dust correlates with 

 the level of contamination.
109

5.5 Cleaning Effectiveness 

Cleaning effectiveness was determined using two endpoints. One endpoint was the reduction in 

contaminant concentration between the pre-cleaning and post-cleaning event concentrations in 

each unit. The other endpoint was the ability to meet health-based benchmarks. The evaluation 

of both endpoints proved that cleaning indoor environments using standard cleaning techniques 

(vacuuming and wet wiping techniques) succeeded in reducing contaminant concentrations 

below health-based benchmarks. This is evidenced by the fact that all residential units, 

commercial units, and common areas had marked reductions in contaminant concentrations 

between cleaning events. In addition, all of the residential units, commercial units, and common 

areas exhibited concentrations that were below health-based benchmarks at the conclusion of the 

study. 

The comparison of pre-cleaning and post-first cleaning concentrations for asbestos wipe and air 

samples, lead wipe and micro vacuum samples, MMVF wipe samples, and asbestos air samples 

from post-second and third cleaning events is presented in Table 11.l. This table shows the 

average concentration of the pre-cleaning samples in comparison with post-cleaning events, with 

the difference presented in the last column on the right. Exceedances of COPC by cleaning event 

are presented in Table 11.2. Note: Due to the quantity of information presented, Table 11.1 and 

Table 11.2 are presented at the conclusion of this discussion. 

The aggregate removal efficiencies for the nine apartments that were identified as being the most 

heavily contaminated, based on pre-cleaning results, are presented in Figure 1.0. This figure 

shows that with the exception of two apartments, there was a net decrease for each contaminant 

regardless of sampling media or test methods. Asbestos wipe samples for one apartment and 

MMVF wipe samples for another apartment were the two exceptions. The reason for this is 

unknown. 

As indicated in Section 2.4, a total of eleven cleaning methods were tested in the study. These 

eleven methods were distributed among 25 spaces, although one of the methods, 4A, was used in 

all of the common spaces and commercial spaces. Because the different test methods that were 

evaluated were similar in nature, and the number of apartments that were available for testing the 

methods was limited, all of the test methods were identified as being able to reduce contaminant 

concentrations and no specific test method was identified as being more effective. Therefore, the 

central theme of these methods, specifically vacuuming and using wet wiping techniques, was 

demonstrated to be effective for reducing contaminant concentrations. 

 5. 

The study demonstrated that use of a standard cleaning 

method of vacuuming and wet wiping significantly reduced 

levels of WTC-related contamination with each cleaning 

event and was successful in reducing concentrations to 

levels below health-based benchmarks. 
110

Figure 1.0 Contaminant Removal Efficiency After the First Cleaning Attempt of Units Identified 

Through Pre-Cleaning Measurements as Most Contaminated (2A, 2B, 3C, 3D, 4C, 4D, 5A, and 5C). 

-300%-200%-100%

0%

100%200%300%400%

3C - Method 1A

3D - Method 1A

4C - Method 1A

2A - Method 1B

4D - Method 2A

2B - Method 3A

5C - Method 3A

5A - Method 3B

Residential Unit & Cleaning Method - Grouped by Cleaning Method Type 

Aggregate of Removal Efficiencies

Asbestos WipeLead MicrovacLead WipeMMVF Wipe
111

5.6 Multiple Cleaning Events 

The results indicate that meeting health-based benchmarks is achievable using the methods 

identified above, although they also indicate that multiple cleaning events (from one to three 

times) may be needed to achieve these benchmarks. The incremental increase in the number of 

residential units that met the health-based benchmarks is presented in Table 12.0. The data 

shows that dioxin and PAH met the health-based benchmarks after the first cleaning for each unit 

and that the majority of the units (92 percent) met the health-based benchmarks for MMVF and 

alpha-quartz after the first cleaning. The number of cleaning events required to meet all of the 

health-based benchmarks for each unit are presented in Table 4.0. This table illustrates that 

multiple cleaning events may be needed to meet the health-based benchmarks for each 

compound. 

Table 12.0

Number of Units Meeting Health-Based Benchmarks 

by Cleaning Event 

Compound Pre-Cleaning First 

Cleaning 

Second 

Cleaning 

Third 

Cleaning 

Asbestos N/A24 5/13 (38%) 6/8 (75%) 2/2 (100%) 

Lead 3/13 (23%) 9/13 (69%) 4/4 (100%) 

MMVF N/A 12/13/ (92%) 0/2 (0%) 2/2 (100%) 

Alphaquartz N/A 12/13 (92%) 1/1 (100%) 

Dioxin 12/13 (92%) 13/13 (100%) 

PAH 10/13 (77%) 13/13 (100% 

An analysis was also conducted to examine if the degree of pre-cleaning contamination affected 

the number of cleaning events required to meet the health-based benchmarks. Table 13.0 below 

presents the results of this analysis. The sum of ranks for each apartment from Table 9.0 were 

grouped and the average number of cleaning events for each grouping was calculated. Since 

there were no definitive natural breaks in the sum of ranks, three separate groupings were chosen. 

One was based on a numeric grouping, in which the sum of ranks were assigned to four groups 

(10-19, 20-29, 30-39, and 40 and above). 

The results suggest that there is a decreasing trend in the number of cleaning events required. 

The second grouping used the mid-point to create two groups (0-23 and 24-48). This grouping 

also indicates a decreasing trend in the average number of cleaning events required. The third 

grouping divided the data into an equal number of units. Although this grouping suggests a 

decreasing trend for most of the groupings, the decreased trend did not continue for the last set of 

 

24N/A signifies that samples were not collected before cleaning. 
112

data. Overall, it appears that there may be a decreasing trend in the average number of cleaning 

events required to meet the clearance criteria based upon the degree of pre-cleaning 

contamination. 

Table 13.0 

Residential Units that are More Heavily Contaminated (Lower Sum of Ranks) 

Required More Cleaning Events to Achieve the Clearance Criteria25

Unit 

Number 

Observable 

Dust 

Cleaning 

Test 

Times 

Cleaned 

Sum of 

Ranks 

Numeric 

Grouping 

Mid-point 

Grouping 

Equal 

Number 

Grouping 

5C significant 3A,3A,3B 3 13 

5A minimal 3B,3B 2 18 

3C significant 1A,1A,3B 3 18 

2.7 2.7 

3D significant 1A,1A 2 20 

4D significant 2A,2A 2 22 

4C significant 1A 1 23 

2.2 

1.7 

2B minimal 3A 1 24 

2A minimal 1B,1B 2 26 

1.6 

5D significant 3B 1 34 

1.3 

3B minimal Scope A 2 34 

3A minimal 2B 1 35 

1.3 

4A minimal 2A,2A 2 45 N/A 

1.5 

1.7 

It should be noted that there were two units in which the test was changed for the third cleaning 

event. Unit 3C was cleaned twice using Test 1A. Test 3B was used for the third cleaning to 

achieve the health-based benchmarks. Unit 5C was cleaned twice using Test 3A. Test 3B was 

used for the third cleaning to achieve the health-based benchmarks. It is unclear if the change in 

the method, the additional cleaning event, or a combination of the two, was responsible for 

meeting the health-based benchmark. 

 25Using the rankings presented in Table 10.0, a semi-quantitative evaluation was made to determine if there 

was a difference in the number of cleaning events needed to meet the clearance criteria based on the measured 

concentrations of pre-cleaning contamination. The average number of cleaning events required to meet the clearance 

criteria was calculated using several different groupings of the sum of ranks. The first set of calculations used 

numeric breakpoints of 10-19, 20-29, 30-39, and >40. This grouping indicates a decreasing trend in the average 

number of cleaning events required. The second set of groupings used the mid-point 23.5. This grouping also 

indicates a decreasing trend in the average number of cleaning events required. The third grouping divided the data 

into an equal number of units. Although this grouping suggests a decreasing trend for most of the groupings, the 

decreased trend did not continue for the last set of data. Overall, it appears that there may be a decreasing trend in 

the average number of cleaning events required to meet the clearance criteria based upon the degree of pre-cleaning 

contamination. 

6. 

The study found that two to three cleanings were necessary 

to reduce contamination levels to below health-based 

benchmarks, and that the number of cleanings generally 

correlated with the levels of contamination initially found in 

the units. 
113

5.7 Sampling Methods 

Several types of sampling methods (air, micro vacuum, and wipe samples) were used in this 

study to determine the contaminant concentrations before and after cleaning events. An 

assessment was made to determine if one of these sampling methods could be used as a 

surrogate, which would allow only one type of sample for one compound to be used to assess if 

an indoor space required additional cleaning. As the amount of contamination present after a 

cleaning event was the most important factor for determining if a surrogate test could be used, 

only the post-cleaning data was used for this particular assessment. 

The post-cleaning data that was collected indicated that it was necessary to conduct eleven 

additional cleaning events (9 second cleaning events and 2 third cleaning events) due to either a 

health-based benchmark being exceeded or samples that could not be analyzed. As presented in 

Table 14.0, air samples collected for asbestos and analyzed using PCMe accounted for the 

majority (82 percent) of the additional cleaning events. These additional cleaning events were 

conducted because the filters were overloaded with particulate matter and could not be analyzed. 

In comparison: 

lead would have resulted in a total of four additional cleaning events (36 percent), although 

three were based on wipe samples and one was based on a micro vacuum sample; 

MMVF air samples resulted in three additional cleaning events (27 percent); 

silica resulted in one additional cleaning even t(nine percent); and 

PAH and dioxin wipe samples results in zero additional cleaning events. 

This indicates that the testing methodology associated with PCMe asbestos air sampling is very 

sensitive to particulate matter and that an indoor environment needs to be relatively clean of 

particulate matter to achieve valid PCMe results. Based on the compounds and testing methods 

chosen, the data suggests that using asbestos air samples as an indicator for additional cleaning is 

the most sensitive of the testing methods, as it results in the largest percentage of additional 

cleaning events. In addition, it is conservative in nature because the asbestos air sampling with 

PCMe analysis may indicate that additional cleaning events need to be conducted even if no 

contamination is present above health-based benchmarks, simply because of excess particulate 

matter. For example, there were five instances where the sampling results for the other 

compounds indicated that the unit met the health-based benchmarks, which would indicate that 

no additional cleaning was necessary; however, because the asbestos air samples could not be 

analyzed due to the filters being overloaded with particulate material, the unit was cleaned again. 
114

Table 14.0

Number of Additional Cleaning Events Required based on Sampling Method26

Compound Sampling Method(s) Number of Additional 

Cleaning Events 

Percentage 

Total Air, Micro vacuum and Wipe 11 100% 

Asbestos Air via PCMe 9 82% 

Lead Wipe 3 27% 

Lead Micro vacuum 1 9% 

MMVF Air 3 27% 

Silica Air 1 9% 

PAH Wipe 0 0% 

Dioxin Wipe 0 0% 

Table 14.0 indicates the number of additional cleaning events that were required based on the 

results from the post-cleaning event samples for the residential units by compound and 

sampling method. The data indicates that using asbestos air sampling with PCMe analysis 

accounted for the most number of additional cleaning events. Overall, the data suggest that the 

use of asbestos air sampling as a surrogate testing method is generally a conservative 

methodology to use to determine if further cleaning is warranted. 

 26The percentages listed in the right-hand column sum to greater than 100% because several of the units had 

more than one compound above a health-based benchmark after a cleaning event. 

7. 

The study found that conducting asbestos in air 

sampling after cleaning could be used as a surrogate 

method for determining if future cleaning was needed. 
115

5.8 Air Disturbance 

The asbestos air samples were collected using two types of air disturbance prior to sampling. 

Either an aggressive technique, using a leaf blower and oscillating fans to disturb the air, or a 

modified-aggressive technique, using only oscillating fans to disturb the air was used. In several 

instances both methods were used in the same apartment to evaluate if there was a difference in 

the analytical results. Both the aggressive and modified-aggressive techniques are expected to 

create air disturbance over an eight-hour sampling period that represents either a worst-case or 

high-end (respectively) air movement in an indoor environment, which would provide a 

conservative estimate of the airborne asbestos concentration. 

Table 15.0 

Comparison of Airborne Asbestos Samples Collected Using Modified-Aggressive and 

Aggressive Air Disturbance Methods27

Modified-Aggressive Air Disturbance Aggressive Air Disturbance 

Unit Sample ID Result Units Sample ID Result Units 

9094-A-2A-25 0.0004 S>5μ/cc 9094-A-2A-28 < 0.0005 S>5μ/cc 

2A 9094-A-2A-26 0.0004 S> 5μ/cc 9094-A-2A-29 < 0.0005 S> 5μ/cc 

9094-A-2A-27 0.0004 S> 5μ/cc 9094-A-2A-30 < 0.0005 S> 5μ/cc 

9094-A-3B-39 < 0.0005 S> 5μ/cc 

3B 9094-A-3B-40 < 0.0005 S> 5μ/cc 

9094-A-3B-41 < 0.0005 S> 5μ/cc 

9094-A-3C-32 < 0.0005 S> 5μ/cc 9094A-3C-35 < 0.0005 S> 5μ/cc 

3C 9094-A-3C-33 < 0.0005 S> 5μ/cc 9094-A-3C-36 < 0.0005 S> 5μ/cc 

9094-A-3C-34 < 0.0005 S> 5μ/cc 9094-A-3C-37 < 0.0005 S> 5μ/cc 

3D 9094-A-3D-23 < 0.0005 S> 5μ/cc 90-94-A-3D-33 < 0.0005 S> 5μ/cc 

9094-A-3D-24 < 0.0005 S> 5μ/cc 9094-A-3D-34 < 0.0005 S> 5μ/cc 

5C 9094-A-5C-31 0.0004 S> 5μ/cc 9094-A-5C-33 0.0016 S> 5μ/cc 

9094-A-5C-32 < 0.004 S> 5μ/cc 9094-A-5C-34 0.0015 S> 5μ/cc 

Number Below 

Detection Limit 9/13 8/10 

Percent Below 

Detection Limit 69.2% 80.0% 

Average 0.00045 0.00071 

In apartments where both methods were used, the modified-aggressive technique was used first 

and air samples were collected. Several days later, the aggressive technique was used and 

additional air samples were collected with no cleaning events occurring between sampling events. 

 27Samples below the detection limit were assigned a value equal to the detection limit. Comparison of 

asbestos air samples that were collected using modified-aggressive and aggressive air disturbance. The samples 

collected using modified-aggressive air disturbance (i.e., box fans) were collected several days prior to the samples 

collected using aggressive air disturbance (i.e., leaf blower and box fans). The comparison does not show any 

trends, as the percentage of samples below the detection limit was higher for the aggressive air disturbance while the 

average asbestos concentration was nominally lower for the modified-aggressive air disturbance. 
116

As shown in Table 15.0, the comparison of these results suggest that no conclusive difference 

could be observed. 

Overall, the samples collected using the aggressive technique had a slightly higher percentage of 

samples below the detection limit (80 percent vs. 69 percent) than the samples collected with the 

modified-aggressive technique, while the samples collected using the modified-aggressive 

technique had a lower average concentration (0.00045 S/cc) than the samples collected using the 

aggressive technique (0.00071 S/cc). 

5.9 Filter Overloading 

As mentioned above, there were many instances where the filters from the asbestos air samples 

were overloaded with particulate material and could not be analyzed, which resulted in invalid 

asbestos air results and required additional cleaning events. During the study, the use of an air 

filtration device was added to the cleaning method for the third cleaning in an attempt to reduce 

the airborne particulate matter as both previous air sampling events resulted in overloaded filters. 

This occurred twice. In both cases, there was no overloading of the filters and valid asbestos air 

results were received. This prompted an evaluation to determine if there was a noticeable 

reduction in overloading filters with particulate matter when an AFD was used during the 

cleaning event. The data for all of the units in the building were used to see if there was a 

difference in the percentage of units with at least one overloaded filter when an AFD was used. 

Table 16.0 presents a comparison of the percentage of units, including residential, common 

spaces, and commercial spaces, with asbestos air samples that could not be analyzed due to the 

filter being overloaded with particulate matter, and indicates whether or not an AFD was used. 

The data suggest that using an AFD during cleaning may offer a slight advantage for reducing the 

potential for overloading a filter with particulate matter. 

8. 

The study did not find a measurable difference in the use 

of modified or aggressive air disturbance technique. 

9. 

The study found that the use of an Air Filtration Device 

during cleaning offered a slight advantage to reducing 

the potential for filter overloading. 
117

Table 16.0 

The Use of an Air Filtration Device Reduces the Occurrence of 

Overloaded Air Sample Filters 

AFD Used Number of Units with or without 

AFDs for the First cleaning 

Number of Units with 

One or More Overloads 

Percentage of Units 

with Overloads 

Yes 18 7 38.9% 

No 7 4 57.1% 

AFD Used Number of Units with or without AFDs 

for the Second Cleaning 

Number of Units with at 

Least One Overload 

Percentage of Units with 

Overloads 

Yes 5 0 0.05 

No 5 2 40.0% 

AFD Used Number of Units with or without AFDs 

for the Third Cleaning 

Number of units w/at Least 

One Overload 

Percentage of Units with 

Overloads 

Yes 2 0 0.0% 

No 0 0 N/A 

5.10 HVAC System 

The HVAC system was cleaned in two of the commercial units. The system was cleaned by 

professionals using equipment and techniques common to the industry that included HEPAfiltered vacuums, air whips, air washing and soap and water washes. Wipe samples were 

collected prior to cleaning and after cleaning for comparison. The results indicate that overall 

there was a reduction of an order of magnitude for the compounds which were detected. In The 

Food Exchange, lead was reduced from 1,310 μg/m3

 to 159 μg/m3 (average), MMVF was 

reduced from 11,732 S/cm2

 to<57.3 S/cm2. In the Lemongrass Grill, there was a reduction in 

lead concentrations from 10,700 μg/m3

 to 95.95 μg/m3 (average). This indicates that standard 

HVAC cleaning methods and equipment reduced the concentrations of WTC-related 

contaminants by an order of magnitude. 

10. 

The study found that standard HVAC cleaning methods 

reduced the concentrations of WTC-related 

contaminants. 
118

5.11 Observations 

5.11.1 Review of Personal Monitoring Data 

 

In addition to evaluating the efficiency of various cleaning methods, the study assessed the 

potential for exposure to workers during the actual cleaning procedures. This was accomplished 

through the collection of personal monitoring data (approximately 500 samples) while cleaning 

was taking place. These samples, which measured airborne levels of asbestos, lead and silica, 

provide insight, although limited by the scope of the pilot program, into the potential exposures 

incurred by residents during cleaning activities. 

All air samples (103) that were analyzed by phase contrast microscopy (PCM) were below the 

Occupational Health and Safety Administration’s (OSHA) Permissible Exposure Limit (PEL) for 

asbestos of 0.1 f/cc. The PEL represents a time-weighted average over a 40 hour work week, and 

is intended to protect workers from adverse health effects. Although PCM analysis is the 

required analytical procedure for compliance with OSHA PEL for asbestos, EPA conducted an 

additional analysis of samples using transmission electron microscopy (TEM) for all samples that 

were greater than 1/10 the OSHA PEL (64 samples). This follow up analysis by the more 

powerful transmission electron microscope determined that very little of the fibrous material 

identified by PCM was actually asbestos. PCM cannot distinguish asbestos from other nonasbestos fibers (e.g., fibrous glass), whereas TEM has that ability. 

Personal air monitoring results (44 samples) for lead were all below the OSHA PEL of 50 μg/m3. 

The PEL represents a time-weighted average over a 40 hour work week, and is intended to 

protect workers from adverse health effects. No individual sample exceeded 1 μg/m3

. 

Personal air monitoring results (97 samples) for crystalline silica (quartz) were, with one 

exception, below the OSHA PEL of 100 μg/m3

. The PEL represents a time-weighted average 

over a 40 hour work week, and is intended to protect workers from adverse health effects. The 

quartz concentration in the sample that exceeded the PEL was 108 μg/m3. Only 19 of the 96 

samples were above the approximate detection limit of 5 μg/m3

. 

Asbestos, lead and crystalline silica (quartz) are substances that have been identified as WTC 

contaminants of potential concern in the indoor environment. The personal monitoring data 

obtained during the study, within the range of contamination found in the building’s apartments, 

that the use of personal protective equipment (e.g., respirator, gloves) during cleaning activities 

(vacuuming, wet wiping) was not necessary. 

5.11.2 Final Observations 

EPA’s position remains that individuals concerned about the presence of WTC-related dust 

should use HEPA vacuums and wet wiping to remove the dust from their dwelling spaces. 

Depending on the amount of dust deposited, repeated cleanings may be necessary. 
119

5.12 Complexities

The interpretation of results from this study is complicated by several factors. This was a noncontrolled, field study. The WTC dust material is not homogeneous; in EPA’s ambient WTC 

settled dust bulk sampling only 35 percent of the samples contained greater than one percent 

asbestos. The number of completely or partially uncleaned buildings available and willing to 

participate in the study was very limited. Thus, in the selected building, units varied in the 

amount of baseline contamination, and results of baseline testing were not available prior to the 

assignment and initiation of the first set of cleaning protocols. Therefore, some cleaning 

methods (Scope A, 1B and 2B) were only tested on units with lower levels of contamination. 

Therefore, it is difficult to draw conclusions about the ability of these methods to remove heavy 

contamination. It was not possible to make every comparison between methods and the level of 

contamination. In addition, a large number of cleaning methods were tested, given the number of 

units available for pilot cleaning. This limited the number of times each method could be tested, 

and makes the overall results more susceptible to fluctuations due to extreme data points that 

may represent rare, unusual conditions. Variation in the types of sampling conducted pre- and 

post-cleaning events make it difficult to compare certain indices of contamination to different 

cleaning methods. 
120

6. Summary

This complex study was able to identify a cleaning method that is able to reduce levels of the 

multiple contaminants that are associated with WTC-related dust and able to reduce those 

contaminants below health-based benchmarks. The specific cleaning method includes 

vacuuming porous and hard surfaces and wet wiping hard surfaces. The results also indicate that 

the cleaning method may need to be repeated several times, especially in heavily impacted 

apartments, to bring concentrations below health-based benchmarks. In addition, the results from 

this study indicate that using asbestos air sampling to determine if additional cleaning is 

necessary is an approach that should generally determine if an area has been cleaned effectively. 

The data also indicates that buildings that had significant amounts of WTC-related dust are likely 

to have had more contamination than those buildings that did not have significant amounts of 

dust deposited. 

In conclusion, this study shows that while there were impacts to the indoor environment in this 

building from the collapse of the WTC, these types of impacts can be mitigated if the cleaning 

method identified is followed, perhaps several times, and should result in an indoor environment 

that is similar to those found prior to the collapse. 
Table 11.1 

 Comparison of Cleaning Results by Cleaning Event 
PCME Asbestos Air Samples - Pre 2nd Cleaning, Post 2nd Cleaning, and Post 3rd Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

2A-2nd 9094-A-2A-010 Pre 2nd cleaning overload S>5u/cc 2A 9094-A-2A-028 Test 1B - Post 2nd cleaning < 0.000500 S>5u/cc

2A-2nd 9094-A-2A-011 Pre 2nd cleaning overload S>5u/cc 2A 9094-A-2A-029 Test 1B - Post 2nd cleaning < 0.000500 S>5u/cc

2A-2nd 9094-A-2A-012 Pre 2nd cleaning overload S>5u/cc 2A 9094-A-2A-030 Test 1B - Post 2nd cleaning < 0.000500 S>5u/cc

2A Test 1B - Post 2nd cleaning

2A Test 1B - Post 2nd cleaning

Average Average 0.000500

3B-2nd 9094-A-3B-011 Pre 2nd cleaning overload S>5u/cc 3B 9094-A-3B-039 Scope A - Post 2nd cleaning < 0.000500 S>5u/cc

3B-2nd 9094-A-3B-012 Pre 2nd cleaning overload S>5u/cc 3B 9094-A-3B-040 Scope A - Post 2nd cleaning < 0.000500 S>5u/cc

3B-2nd 9094-A-3B-013 Pre 2nd cleaning overload S>5u/cc 3B 9094-A-3B-041 Scope A - Post 2nd cleaning < 0.000500 S>5u/cc

3B-2nd 9094-A-3B-026 Pre 2nd cleaning < 0.000900 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-027 Pre 2nd cleaning 0.001100 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-028 Pre 2nd cleaning < 0.000500 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-029 Pre 2nd cleaning 0.000500 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-030 Pre 2nd cleaning < 0.000500 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-031 Pre 2nd cleaning 0.001500 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-032 Pre 2nd cleaning 0.001100 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-033 Pre 2nd cleaning 0.000900 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-034 Pre 2nd cleaning < 0.000500 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-035 Pre 2nd cleaning 0.001000 S>5u/cc 3B Scope A - Post 2nd cleaning

3B-2nd 9094-A-3B-036 Pre 2nd cleaning < 0.000900 S>5u/cc 3B Scope A - Post 2nd cleaning

3B Scope A - Post 2nd cleaning

Average 0.000855 Average 0.000500

.

3C-2nd 9094-A-3C-009 Pre 2nd cleaning overload S>5u/cc 3C 9094-A-3C-025 Test 1A - Post 2nd cleaning overload S>5u/cc

3C-2nd 9094-A-3C-010 Pre 2nd cleaning overload S>5u/cc 3C 9094-A-3C-026 Test 1A - Post 2nd cleaning overload S>5u/cc

3C-2nd 9094-A-3C-011 Pre 2nd cleaning overload S>5u/cc 3C 9094-A-3C-027 Test 1A - Post 2nd cleaning overload S>5u/cc

3C 9094-A-3C-028 Test 1A - Post 2nd cleaning overload S>5u/cc

3C 9094-A-3C-029 Test 1A - Post 2nd cleaning overload S>5u/cc

Average Average

3C-3rd 9094-A-3C-025 Post 2nd cleaning - Test 1A overload S>5u/cc 3C 9094-A-3C-032 Test 3B - Post 3rd cleaning < 0.0005 S>5u/cc

3C-3rd 9094-A-3C-026 Post 2nd cleaning - Test 1A overload S>5u/cc 3C 9094-A-3C-033 Test 3B - Post 3rd cleaning < 0.0005 S>5u/cc

3C-3rd 9094-A-3C-027 Post 2nd cleaning - Test 1A overload S>5u/cc 3C 9094-A-3C-034 Test 3B - Post 3rd cleaning < 0.0005 S>5u/cc

3C-3rd 9094-A-3C-028 Post 2nd cleaning - Test 1A overload S>5u/cc 3C 9094-A-3C-035 Test 3B - Post 3rd cleaning < 0.0005 S>5u/cc

3C-3rd 9094-A-3C-029 Post 2nd cleaning - Test 1A overload S>5u/cc 3C 9094-A-3C-036 Test 3B - Post 3rd cleaning < 0.0005 S>5u/cc

3C 9094-A-3C-037 Test 3B - Post 3rd cleaning < 0.0005 S>5u/cc

Average Average 0.000500

3D-2nd 9094-A-3D-008 Pre 2nd cleaning overload S>5u/cc 3D 9094-A-3D-023 Test 1A - Post 2nd cleaning < 0.0005 S>5u/cc

3D-2nd 9094-A-3D-009 Pre 2nd cleaning overload S>5u/cc 3D 9094-A-3D-024 Test 1A - Post 2nd cleaning < 0.0004 S>5u/cc

3D-2nd 9094-A-3D-010 Pre 2nd cleaning overload S>5u/cc 3D 9094-A-3D-025 Test 1A - Post 2nd cleaning < 0.0005 S>5u/cc

3D 9094-A-3D-026 Test 1A - Post 2nd cleaning < 0.0005 S>5u/cc

Average Average 0.000475

4A-2nd 9094-A-4A-008 Pre 2nd cleaning overload S>5u/cc 4A 9094-A-4A-023 Test 2A - Post 2nd cleaning < 0.0009 S>5u/cc

4A-2nd 9094-A-4A-009 Pre 2nd cleaning overload S>5u/cc 4A 9094-A-4A-024 Test 2A - Post 2nd cleaning < 0.0008 S>5u/cc

4A-2nd 9094-A-4A-010 Pre 2nd cleaning overload S>5u/cc 4A 9094-A-4A-025 Test 2A - Post 2nd cleaning < 0.0009 S>5u/cc

Average Average 0.000867

5C-2nd 9094-A-5C-009 Pre 2nd cleaning overload S>5u/cc 5C 9094-A-5C-024 Test 3A - Post 2nd cleaning overload S>5u/cc

Table 11.1
PCME Asbestos Air Samples - Pre 2nd Cleaning, Post 2nd Cleaning, and Post 3rd Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

Table 11.1

5C-2nd 9094-A-5C-010 Pre 2nd cleaning overload S>5u/cc 5C 9094-A-5C-025 Test 3A - Post 2nd cleaning overload S>5u/cc

5C-2nd 9094-A-5C-011 Pre 2nd cleaning overload S>5u/cc 5C 9094-A-5C-026 Test 3A - Post 2nd cleaning overload S>5u/cc

5C 9094-A-5C-027 Test 3A - Post 2nd cleaning overload S>5u/cc

5C 9094-A-5C-028 Test 3A - Post 2nd cleaning overload S>5u/cc

Average Average

5C-3rd 9094-A-5C-024 Post 2nd cleaning - Test 3A overload S>5u/cc 5C 9094-A-5C-031 Test 3B - Post 3rd cleaning 0.0004 S>5u/cc

5C-3rd 9094-A-5C-025 Post 2nd cleaning - Test 3A overload S>5u/cc 5C 9094-A-5C-032 Test 3B - Post 3rd cleaning < 0.0004 S>5u/cc

5C-3rd 9094-A-5C-026 Post 2nd cleaning - Test 3A overload S>5u/cc 5C 9094-A-5C-033 Test 3B - Post 3rd cleaning 0.0016 S>5u/cc

5C-3rd 9094-A-5C-027 Post 2nd cleaning - Test 3A overload S>5u/cc 5C 9094-A-5C-034 Test 3B - Post 3rd cleaning 0.0015 S>5u/cc

5C-3rd 9094-A-5C-028 Post 2nd cleaning - Test 3A overload S>5u/cc 5C

Average Average 0.000975
Lead Wipe Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

2A 9094-W-2A-002 Before cleaning < 4.65 ug/ft2 2A 9094-W-2A-018 Post 1st cleaning - Test 1B < 4.65 ug/ft2

2A 9094-W-2A-003 Before cleaning 49.40 ug/ft2 2A 9094-W-2A-019 Post 1st cleaning - Test 1B 11.30 ug/ft2

2A 9094-W-2A-004 Before cleaning 35.40 ug/ft2 2A 9094-W-2A-020 Post 1st cleaning - Test 1B < 4.65 ug/ft2

2A 9094-W-2A-005 Before cleaning 44.60 ug/ft2 2A 9094-W-2A-021 Post 1st cleaning - Test 1B < 4.65 ug/ft2

Average 33.51 Average 6.31 27

2B 9094-W-2B-002 Before cleaning < 4.65 ug/ft2 2B 9094-W-2B-016 Post 1st cleaning - Test 3A < 4.65 ug/ft2

2B 9094-W-2B-003 Before cleaning 97.00 ug/ft2 2B 9094-W-2B-017 Post 1st cleaning - Test 3A 9.90 ug/ft2

2B 9094-W-2B-004 Before cleaning 17.50 ug/ft2 2B 9094-W-2B-018 Post 1st cleaning - Test 3A 18.70 ug/ft2

2B 9094-W-2B-019 Post 1st cleaning - Test 3A 7.41 ug/ft2

Average 39.72 Average 10.17 30

3A 9094-W-3A-002 Before cleaning < 4.65 ug/ft2 3A 9094-W-3A-018 Post 1st cleaning - Test 2B < 4.65 ug/ft2

3A 9094-W-3A-003 Before cleaning 38.90 ug/ft2 3A 9094-W-3A-019 Post 1st cleaning - Test 2B 10.50 ug/ft2

3A 9094-W-3A-004 Before cleaning 12.00 ug/ft2 3A 9094-W-3A-020 Post 1st cleaning - Test 2B 9.29 ug/ft2

3A 9094-W-3A-021 Post 1st cleaning - Test 2B < 4.65 ug/ft2

Average 18.52 Average 7.27 11

3B 9094-W-3B-002 Before cleaning < 4.65 ug/ft2 3B 9094-W-3B-019 Post 1st cleaning - Scope A < 4.65 ug/ft2

3B 9094-W-3B-003 Before cleaning 11.50 ug/ft2 3B 9094-W-3B-020 Post 1st cleaning - Scope A 51.60 ug/ft2

3B 9094-W-3B-004 Before cleaning 9.65 ug/ft2 3B 9094-W-3B-021 Post 1st cleaning - Scope A 10.90 ug/ft2

3B 9094-W-3B-005 Before cleaning LOST ug/ft2 3B 9094-W-3B-022 Post 1st cleaning - Scope A 7.27 ug/ft2

Average 8.60 Average 18.61 -10

.

3C 9094-W-3C-002 Before cleaning < 4.65 ug/ft2 3C 9094-W-3C-017 Post 1st cleaning - Test 1A 5.02 ug/ft2

3C 9094-W-3C-003 Before cleaning 750.00 ug/ft2 3C 9094-W-3C-018 Post 1st cleaning - Test 1A 8.03 ug/ft2

3C 9094-W-3C-004 Before cleaning 48.70 ug/ft2 3C 9094-W-3C-019 Post 1st cleaning - Test 1A 6.01 ug/ft2

3C 9094-W-3C-020 Post 1st cleaning - Test 1A < 4.65 ug/ft2

Average 267.78 Average 5.93 262

3D 9094-W-3D-002 Before cleaning < 4.65 ug/ft2 3D 9094-W-3D-016 Post 1st cleaning - Test 1A 8.22 ug/ft2

3D 9094-W-3D-003 Before cleaning 201.00 ug/ft2 3D 9094-W-3D-017 Post 1st cleaning - Test 1A 9.80 ug/ft2

3D 9094-W-3D-004 Before cleaning 112.00 ug/ft2 3D 9094-W-3D-018 Post 1st cleaning - Test 1A < 4.65 ug/ft2

3D 9094-W-3D-005 Before cleaning < 4.65 ug/ft2 3D 9094-W-3D-019 Post 1st cleaning - Test 1A < 4.65 ug/ft2

Average 80.58 Average 6.83 74

4A 9094-W-4A-002 Before cleaning 5.66 ug/ft2 4A 9094-W-4A-016 Post 1st cleaning - Test 2A < 4.65 ug/ft2

4A 9094-W-4A-003 Before cleaning 21.50 ug/ft2 4A 9094-W-4A-017 Post 1st cleaning - Test 2A 10.70 ug/ft2

4A 9094-W-4A-004 Before cleaning 9.41 ug/ft2 4A 9094-W-4A-018 Post 1st cleaning - Test 2A < 4.65 ug/ft2

4A 9094-W-4A-019 Post 1st cleaning - Test 2A < 4.65 ug/ft2

Average 12.19 Average 6.16 6

4B 9094-W-4B-002 Before cleaning < 4.65 ug/ft2 4B 9094-W-4B-014 Post 1st cleaning - Test 2B < 4.65 ug/ft2

Table 11.1
Lead Wipe Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

Table 11.1

4B 9094-W-4B-003 Before cleaning 50.00 ug/ft2 4B 9094-W-4B-015 Post 1st cleaning - Test 2B 6.68 ug/ft2

4B 9094-W-4B-004 Before cleaning 14.00 ug/ft2 4B 9094-W-4B-016 Post 1st cleaning - Test 2B < 4.65 ug/ft2

4B 9094-W-4B-005 Before cleaning 30.00 ug/ft2 4B 9094-W-4B-017 Post 1st cleaning - Test 2B < 4.65 ug/ft2

4B

Average 24.66 Average 5.16 20

4C 9094-W-4C-002 Before cleaning < 4.65 ug/ft2 4C 9094-W-4C-019 Post 1st cleaning - Test 1A LOST ug/ft2

4C 9094-W-4C-003 Before cleaning 181.00 ug/ft2 4C 9094-W-4C-020 Post 1st cleaning - Test 1A 14.90 ug/ft2 (Validation = R).

4C 9094-W-4C-004 Before cleaning 77.50 ug/ft2 4C 9094-W-4C-021 Post 1st cleaning - Test 1A 8.28 ug/ft2 (Validation = R).

4C 9094-W-4C-022 Post 1st cleaning - Test 1A 7.81 ug/ft2 (Validation = R).

Average 87.72 Average 10.33 77

4D 9094-W-4D-002 Before cleaning < 4.65 ug/ft2 4D 9094-W-4D-020 Post 1st cleaning - Test 2A 20.40 ug/ft2 (Validation = R).

4D 9094-W-4D-003 Before cleaning 169.00 ug/ft2 4D 9094-W-4D-021 Post 1st cleaning - Test 2A 66.00 ug/ft2 (Validation = R).

4D 9094-W-4D-004 Before cleaning 17.40 ug/ft2 4D 9094-W-4D-022 Post 1st cleaning - Test 2A 10.60 ug/ft2 (Validation = R).

4D 9094-W-4D-005 Before cleaning 17.10 ug/ft2 4D 9094-W-4D-023 Post 1st cleaning - Test 2A 15.60 ug/ft2 (Validation = R).

Average 52.04 Average 28.15 24

5A 9094-W-5A-002 Before cleaning 4.79 ug/ft2 5A 9094-W-5A-020 Post 1st cleaning - Test 3B < 4.65 ug/ft2

5A 9094-W-5A-003 Before cleaning 191.00 ug/ft2 5A 9094-W-5A-021 Post 1st cleaning - Test 3B 43.50 ug/ft2

5A 9094-W-5A-004 Before cleaning 2000.00 ug/ft2 5A 9094-W-5A-022 Post 1st cleaning - Test 3B 10.50 ug/ft2

5A 9094-W-5A-023 Post 1st cleaning - Test 3B 39.70 ug/ft2

Average 731.93 Average 24.59 707

5C 9094-W-5C-002 Before cleaning 6.95 ug/ft2 5C 9094-W-5C-017 Post 1st cleaning - Test 3A Broken ug/m2

5C 9094-W-5C-003 Before cleaning 336.00 ug/ft2 5C 9094-W-5C-018 Post 1st cleaning - Test 3A 10.30 ug/ft2

5C 9094-W-5C-004 Before cleaning 43.60 ug/ft2 5C 9094-W-5C-019 Post 1st cleaning - Test 3A 7.69 ug/ft2

5C 9094-W-5C-020 Post 1st cleaning - Test 3A 6.86 ug/ft2

Average 128.85 Average 8.28 121

5D 9094-W-5D-002 Before cleaning 7.35 ug/ft2 5D 9094-W-5D-016 Post 1st cleaning - Test 3B < 4.65 ug/ft2

5D 9094-W-5D-003 Before cleaning 4.68 ug/ft2 5D 9094-W-5D-017 Post 1st cleaning - Test 3B 12.80 ug/ft2

5D 9094-W-5D-004 Before cleaning 25.30 ug/ft2 5D 9094-W-5D-018 Post 1st cleaning - Test 3B < 4.65 ug/ft2

5D 9094-W-5D-005 Before cleaning 32.10 ug/ft2 5D 9094-W-5D-019 Post 1st cleaning - Test 3B < 4.65 ug/ft2

Average 17.36 Average 6.69 11
Lead Micro Vacuum Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

2A 9094-M-2A-006 Before cleaning 4.03 ug/ft2 2A 9094-M-2A-022 Post 1st cleaning - Test 1B < 2.32 ug/ft2

2A 9094-M-2A-007 Before cleaning 14.40 ug/ft2 2A 9094-M-2A-023 Post 1st cleaning - Test 1B < 2.32 ug/ft2

2A 9094-M-2A-008 Before cleaning 3.89 ug/ft2 2A 9094-M-2A-024 Post 1st cleaning - Test 1B < 2.32 ug/ft2

2A 9094-M-2A-009 Before cleaning < 2.32 ug/ft2

Average 6.16 Average 2.32 4

2B 9094-M-2B-005 Before cleaning < 2.32 ug/ft2 2B 9094-M-2B-020 Post 1st cleaning - Test 3A < 2.32 ug/ft2

2B 9094-M-2B-006 Before cleaning 4.54 ug/ft2 2B 9094-M-2B-021 Post 1st cleaning - Test 3A < 2.32 ug/ft2

2B 9094-M-2B-007 Before cleaning < 2.32 ug/ft2 2B 9094-M-2B-022 Post 1st cleaning - Test 3A < 2.32 ug/ft2

2B 9094-M-2B-023 Post 1st cleaning - Test 3A < 2.32 ug/ft2

Average 3.06 Average 2.32 1

3A 9094-M-3A-006 Before cleaning < 4.65 ug/ft2 3A 9094-M-3A-022 Post 1st cleaning - Test 2B 4.85 ug/ft2

3A 9094-M-3A-007 Before cleaning < 4.65 ug/ft2 3A 9094-M-3A-023 Post 1st cleaning - Test 2B < 2.32 ug/ft2

3A 9094-M-3A-008 Before cleaning < 4.65 ug/ft2 3A 9094-M-3A-024 Post 1st cleaning - Test 2B 4.39 ug/ft2

3A 9094-M-3A-009 Before cleaning < 4.65 ug/ft2 3A 9094-M-3A-025 Post 1st cleaning - Test 2B < 2.32 ug/ft2

Average 4.65 Average 3.47 1

3B 9094-M-3B-006 Before cleaning < 4.65 ug/ft2 3B 9094-M-3B-023 Post 1st cleaning - Scope A < 2.32 ug/ft2

3B 9094-M-3B-007 Before cleaning < 4.65 ug/ft2 3B 9094-M-3B-024 Post 1st cleaning - Scope A < 2.32 ug/ft2

3B 9094-M-3B-008 Before cleaning < 4.65 ug/ft2 3B 9094-M-3B-025 Post 1st cleaning - Scope A < 2.32 ug/ft2

Average 4.65 Average 2.32 2

.

3C 9094-M-3C-005 Before cleaning 68.40 ug/ft2 3C 9094-M-3C-021 Post 1st cleaning - Test 1A 6.32 ug/ft2

3C 9094-M-3C-006 Before cleaning 135.00 ug/ft2 3C 9094-M-3C-022 Post 1st cleaning - Test 1A 9.66 ug/ft2

3C 9094-M-3C-007 Before cleaning 43.30 ug/ft2 3C 9094-M-3C-023 Post 1st cleaning - Test 1A 26.90 ug/ft2

3C 9094-M-3C-008 Before cleaning 39.40 ug/ft2 3C 9094-M-3C-024 Post 1st cleaning - Test 1A 6.47 ug/ft2

3C Post 1st cleaning - Test 1A

Average 71.53 Average 12.34 59

3D 9094-M-3D-005 Before cleaning 50.70 ug/ft2 3D 9094-M-3D-020 Post 1st cleaning - Test 1A < 2.32 ug/ft2

3D 9094-M-3D-006 Before cleaning < 4.65 ug/ft2 3D 9094-M-3D-021 Post 1st cleaning - Test 1A 5.71 ug/ft2 (Validation = R).

3D 9094-M-3D-007 Before cleaning < 4.65 ug/ft2 3D 9094-M-3D-022 Post 1st cleaning - Test 1A < 2.32 ug/ft2

Average 20.00 Average 3.45 17

4A 9094-M-4A-005 Before cleaning < 4.65 ug/ft2 4A 9094-M-4A-020 Post 1st cleaning - Test 2A < 2.32 ug/ft2

4A 9094-M-4A-006 Before cleaning < 4.65 ug/ft2 4A 9094-M-4A-021 Post 1st cleaning - Test 2A < 2.32 ug/ft2

4A 9094-M-4A-007 Before cleaning < 4.65 ug/ft2 4A 9094-M-4A-022 Post 1st cleaning - Test 2A 2.58 ug/ft2

Average 4.65 Average 2.41 2

4B Before cleaning 4B Post 1st cleaning - Test 2B

Table 11.1 
Lead Micro Vacuum Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

Table 11.1 

4B Before cleaning 4B Post 1st cleaning - Test 2B

4B Before cleaning 4B Post 1st cleaning - Test 2B

4B Before cleaning 4B Post 1st cleaning - Test 2B

4B Before cleaning 4B Post 1st cleaning - Test 2B

Average none Average none

4C 9094-M-4C-005 Before cleaning 76.10 ug/ft2 4C 9094-M-4C-023 Post 1st cleaning - Test 1A < 2.32 ug/ft2

4C 9094-M-4C-006 Before cleaning 83.70 ug/ft2 4C 9094-M-4C-024 Post 1st cleaning - Test 1A < 2.32 ug/ft2

4C 9094-M-4C-007 Before cleaning 69.80 ug/ft2 4C 9094-M-4C-025 Post 1st cleaning - Test 1A < 2.32 ug/ft2

4C 9094-M-4C-008 Before cleaning 70.80 ug/ft2

Average 75.10 Average 2.32 73

4D 9094-M-4D-006 Before cleaning 83.50 ug/ft2 4D 9094-M-4D-024 Post 1st cleaning - Test 2A 2.40 ug/ft2

4D 9094-M-4D-007 Before cleaning 66.00 ug/ft2 4D 9094-M-4D-025 Post 1st cleaning - Test 2A < 2.32 ug/ft2

4D 9094-M-4D-008 Before cleaning 26.20 ug/ft2 4D 9094-M-4D-026 Post 1st cleaning - Test 2A < 2.32 ug/ft2

4D 9094-M-4D-009 Before cleaning 39.90 ug/ft2 4D 9094-M-4D-027 Post 1st cleaning - Test 2A < 2.32 ug/ft2

4D 9094-M-4D-010 Before cleaning 78.20 ug/ft2 4D 9094-M-4D-028 Post 1st cleaning - Test 2A < 2.32 ug/ft2

4D 9094-M-4D-011 Before cleaning 72.10 ug/ft2 4D 9094-M-4D-029 Post 1st cleaning - Test 2A < 2.32 ug/ft2

Average 60.98 Average 2.33 59

5A 9094-M-5A-005 Before cleaning < 2.23 ug/ft2 5A 9094-M-5A-024 Post 1st cleaning - Test 3B 2.60 ug/ft2 G.F. AA

5A 9094-M-5A-006 Before cleaning < 2.23 ug/ft2 5A 9094-M-5A-025 Post 1st cleaning - Test 3B 4.15 ug/ft2 G.F. AA

5A 9094-M-5A-007 Before cleaning < 2.23 ug/ft2 5A 9094-M-5A-026 Post 1st cleaning - Test 3B 2.60 ug/ft2 G.F. AA

5A 9094-M-5A-008 Before cleaning < 2.23 ug/ft2 5A 9094-M-5A-027 Post 1st cleaning - Test 3B 0.78 ug/ft2 G.F. AA

5A 9094-M-5A-009 Before cleaning < 2.23 ug/ft2 5A 9094-M-5A-028 Post 1st cleaning - Test 3B 0.98 ug/ft2 G.F. AA

5A 9094-M-5A-010 Before cleaning 3.46 ug/ft2 5A 9094-M-5A-029 Post 1st cleaning - Test 3B 1.02 ug/ft2 G.F. AA

9094-M-5A-011 < 2.23 ug/ft2 5A 9094-M-5A-030 Post 1st cleaning - Test 3B 5.27 ug/ft2 G.F. AA

Average 2.44 Average 2.49 0

5C 9094-M-5C-005 Before cleaning 104.00 ug/ft2 5C 9094-M-5C-021 Post 1st cleaning - Test 3A < 2.32 ug/ft2

5C 9094-M-5C-006 Before cleaning 293.00 ug/ft2 5C 9094-M-5C-022 Post 1st cleaning - Test 3A < 2.32 ug/ft2

5C 9094-M-5C-007 Before cleaning 133.00 ug/ft2 5C 9094-M-5C-023 Post 1st cleaning - Test 3A < 2.32 ug/ft2

Average 176.67 Average 2.32 174

5D 9094-M-5D-006 Before cleaning 27.10 ug/ft2 5D 9094-M-5D-020 Post 1st cleaning - Test 3B < 2.32 ug/ft2

5D 9094-M-5D-007 Before cleaning 49.10 ug/ft2 5D 9094-M-5D-021 Post 1st cleaning - Test 3B < 2.32 ug/ft2

Average 38.10 Average 2.32 36
Asbestos Wipe Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

2A 9094-W-2A-001 Before cleaning < 2,366 S/cm2 2A 9094-W-2A-017 Post 1st cleaning - Test 1B < 1,183 S/cm2

2A 9094-W-2A-002 Before cleaning < 2,366 S/cm2 2A 9094-W-2A-018 Post 1st cleaning - Test 1B < 1,183 S/cm2

2A 9094-W-2A-003 Before cleaning 56,192 S/cm2 2A 9094-W-2A-019 Post 1st cleaning - Test 1B 4,397 S/cm2

2A 9094-W-2A-004 Before cleaning 18,945 S/cm2 2A 9094-W-2A-020 Post 1st cleaning - Test 1B < 2,366 S/cm2

2A 9094-W-2A-005 Before cleaning 3,166 S/cm2 2A 9094-W-2A-021 Post 1st cleaning - Test 1B < 1,183 S/cm2

Average 16,607 Average 2,063 14,544

2B 9094-W-2B-001 Before cleaning < 2,366 S/cm2 2B 9094-W-2B-015 Post 1st cleaning - Test 3A < 5,916 S/cm2

2B 9094-W-2B-002 Before cleaning < 2,366 S/cm2 2B 9094-W-2B-016 Post 1st cleaning - Test 3A < 5,916 S/cm2

2B 9094-W-2B-003 Before cleaning 102,096 S/cm2 2B 9094-W-2B-017 Post 1st cleaning - Test 3A < 5,916 S/cm2

2B 9094-W-2B-004 Before cleaning 5,540 S/cm2 2B 9094-W-2B-018 Post 1st cleaning - Test 3A < 5,916 S/cm2

2B 9094-W-2B-019 Post 1st cleaning - Test 3A 5,936 S/cm2

Average 28,092 Average 5,920 22,172

3A 9094-W-3A-001 Before cleaning < 2,366 S/cm2 3A 9094-W-3A-017 Post 1st cleaning - Test 2B 15,037 S/cm2

3A 9094-W-3A-002 Before cleaning < 2,366 S/cm2 3A 9094-W-3A-018 Post 1st cleaning - Test 2B < 11,832 S/cm2

3A 9094-W-3A-003 Before cleaning < 2,366 S/cm2 3A 9094-W-3A-019 Post 1st cleaning - Test 2B 3,957 S/cm2

3A 9094-W-3A-004 Before cleaning 4,749 S/cm2 3A 9094-W-3A-020 Post 1st cleaning - Test 2B 3,166 S/cm2

3A 9094-W-3A-021 Post 1st cleaning - Test 2B < 2,366 S/cm2

Average 2,962 Average 7,272 -4,310

3B 9094-W-3B-001 Before cleaning < 2,366 S/cm2 3B 9094-W-3B-018 Post 1st cleaning - Scope A 742 S/cm2

3B 9094-W-3B-002 Before cleaning < 2,366 S/cm2 3B 9094-W-3B-019 Post 1st cleaning - Scope A < 740 S/cm2

3B 9094-W-3B-003 Before cleaning 3,166 S/cm2 3B 9094-W-3B-020 Post 1st cleaning - Scope A 4,699 S/cm2

3B 9094-W-3B-004 Before cleaning < 2,366 S/cm2 3B 9094-W-3B-021 Post 1st cleaning - Scope A 3,957 S/cm2

3B 9094-W-3B-022 Post 1st cleaning - Scope A 2,473 S/cm2

Average 2,566 Average 2,522 44

.

3C 9094-W-3C-001 Before cleaning < 2,366 S/cm2 3C 9094-W-3C-016 Post 1st cleaning - Test 1A < 2,366 S/cm2

3C 9094-W-3C-002 Before cleaning 2,374 S/cm2 3C 9094-W-3C-017 Post 1st cleaning - Test 1A 12,663 S/cm2

3C 9094-W-3C-003 Before cleaning 55,401 S/cm2 3C 9094-W-3C-018 Post 1st cleaning - Test 1A 77,561 S/cm2

3C 9094-W-3C-004 Before cleaning 75,979 S/cm2 3C 9094-W-3C-019 Post 1st cleaning - Test 1A < 2,366 S/cm2

3C 9094-W-3C-020 Post 1st cleaning - Test 1A 13,454 S/cm2

Average 34,030 Average 21,682 12,348

3D 9094-W-3D-001 Before cleaning 4,749 S/cm2 3D 9094-W-3D-015 Post 1st cleaning - Test 1A 14,246 S/cm2

3D 9094-W-3D-002 Before cleaning < 2,366 S/cm2 3D 9094-W-3D-016 Post 1st cleaning - Test 1A 3,957 S/cm2

3D 9094-W-3D-003 Before cleaning 172,534 S/cm2 3D 9094-W-3D-017 Post 1st cleaning - Test 1A 10,289 S/cm2

3D 9094-W-3D-004 Before cleaning 118,716 S/cm2 3D 9094-W-3D-018 Post 1st cleaning - Test 1A 10,289 S/cm2

3D 9094-W-3D-005 Before cleaning 4,749 S/cm2 3D 9094-W-3D-019 Post 1st cleaning - Test 1A 10,289 S/cm2

Average 60,623 Average 9,814 50,809

4A 9094-W-4A-001 Before cleaning < 2,366 S/cm2 4A 9094-W-4A-015 Post 1st cleaning - Test 2A 1,979 S/cm2

4A 9094-W-4A-002 Before cleaning < 2,366 S/cm2 4A 9094-W-4A-016 Post 1st cleaning - Test 2A 1,583 S/cm2

4A 9094-W-4A-003 Before cleaning 2,374 S/cm2 4A 9094-W-4A-017 Post 1st cleaning - Test 2A < 1,183 S/cm2

4A 9094-W-4A-004 Before cleaning < 2,366 S/cm2 4A 9094-W-4A-018 Post 1st cleaning - Test 2A 6,331 S/cm2

4A 9094-W-4A-019 Post 1st cleaning - Test 2A < 1,183 S/cm2

Average 2,368 Average 2,452 -83

Table 11.1
Asbestos Wipe Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

Table 11.1

4B 9094-W-4B-001 Before cleaning < 2,366 S/cm2 4B 9094-W-4B-013 Post 1st cleaning - Test 2B < 2,366 S/cm2

4B 9094-W-4B-002 Before cleaning < 2,366 S/cm2 4B 9094-W-4B-014 Post 1st cleaning - Test 2B < 2,366 S/cm2

4B 9094-W-4B-003 Before cleaning 18,203 S/cm2 4B 9094-W-4B-015 Post 1st cleaning - Test 2B 4,749 S/cm2

4B 9094-W-4B-004 Before cleaning 13,454 S/cm2 4B 9094-W-4B-016 Post 1st cleaning - Test 2B < 2,366 S/cm2

4B 9094-W-4B-005 Before cleaning 3,166 S/cm2 4B 9094-W-4B-017 Post 1st cleaning - Test 2B < 2,366 S/cm2

Average 7,911 Average 2,843 5,068

4C 9094-W-4C-001 Before cleaning < 2,366 S/cm2 4C 9094-W-4C-018 Post 1st cleaning - Test 1A < 2,366 S/cm2

4C 9094-W-4C-002 Before cleaning < 2,366 S/cm2 4C 9094-W-4C-019 Post 1st cleaning - Test 1A < 2,366 S/cm2

4C 9094-W-4C-003 Before cleaning 49,069 S/cm2 4C 9094-W-4C-020 Post 1st cleaning - Test 1A 3,166 S/cm2

4C 9094-W-4C-004 Before cleaning 3,166 S/cm2 4C 9094-W-4C-021 Post 1st cleaning - Test 1A < 2,366 S/cm2

4C 9094-W-4C-022 Post 1st cleaning - Test 1A < 2,366 S/cm2

Average 14,242 Average 2,526 11,716

4D 9094-W-4D-001 Before cleaning < 2,366 S/cm2 4D 9094-W-4D-019 Post 1st cleaning - Test 2A 2,374 S/cm2

4D 9094-W-4D-002 Before cleaning < 2,366 S/cm2 4D 9094-W-4D-020 Post 1st cleaning - Test 2A < 2,366 S/cm2

4D 9094-W-4D-003 Before cleaning 34,032 S/cm2 4D 9094-W-4D-021 Post 1st cleaning - Test 2A 26,118 S/cm2

4D 9094-W-4D-004 Before cleaning 2,374 S/cm2 4D 9094-W-4D-022 Post 1st cleaning - Test 2A 43,529 S/cm2

4D 9094-W-4D-005 Before cleaning 3,166 S/cm2 4D 9094-W-4D-023 Post 1st cleaning - Test 2A 18,995 S/cm2

Average 8,861 Average 18,676 -9,815

5A 9094-W-5A-001 Before cleaning < 2,366 S/cm2 5A 9094-W-5A-019 Post 1st cleaning - Test 3B < 2,366 S/cm2

5A 9094-W-5A-002 Before cleaning < 2,366 S/cm2 5A 9094-W-5A-020 Post 1st cleaning - Test 3B < 2,366 S/cm2

5A 9094-W-5A-003 Before cleaning 233,475 S/cm2 5A 9094-W-5A-021 Post 1st cleaning - Test 3B < 2,366 S/cm2

5A 9094-W-5A-004 Before cleaning 22,952 S/cm2 5A 9094-W-5A-022 Post 1st cleaning - Test 3B < 2,366 S/cm2

5A 9094-W-5A-023 Post 1st cleaning - Test 3B < 2,366 S/cm2

Average 65,290 Average 2,366 62,923

5C 9094-W-5C-001 Before cleaning 9,497 S/cm2 5C 9094-W-5C-016 Post 1st cleaning - Test 3A 2,374 S/cm2

5C 9094-W-5C-002 Before cleaning 3,166 S/cm2 5C 9094-W-5C-017 Post 1st cleaning - Test 3A < 2,366 S/cm2

5C 9094-W-5C-003 Before cleaning 97,347 S/cm2 5C 9094-W-5C-018 Post 1st cleaning - Test 3A < 2,366 S/cm2

5C 9094-W-5C-004 Before cleaning 30,075 S/cm2 5C 9094-W-5C-019 Post 1st cleaning - Test 3A 3,166 S/cm2

5C 9094-W-5C-020 Post 1st cleaning - Test 3A 3,166 S/cm2

Average 35,021 Average 2,688 32,333

5D 9094-W-5D-001 Before cleaning < 2,366 S/cm2 5D 9094-W-5D-015 Post 1st cleaning - Test 3B < 5,916 S/cm2

5D 9094-W-5D-002 Before cleaning < 2,366 S/cm2 5D 9094-W-5D-016 Post 1st cleaning - Test 3B < 5,916 S/cm2

5D 9094-W-5D-003 Before cleaning < 2,366 S/cm2 5D 9094-W-5D-017 Post 1st cleaning - Test 3B < 5,916 S/cm2

5D 9094-W-5D-004 Before cleaning 4,749 S/cm2 5D 9094-W-5D-018 Post 1st cleaning - Test 3B < 5,916 S/cm2

5D 9094-W-5D-005 Before cleaning 36,406 S/cm2 5D 9094-W-5D-019 Post 1st cleaning - Test 3B < 5,916 S/cm2

Average 9,651 Average 5,916 3,735
MMVF Wipe Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

2A 9094-W-2A-002 Before cleaning < 57.23 mmvf_S/c 2A 9094-W-2A-017 Post 1st cleaning - Test 1B 57.23 mmvf_S/c

2A 9094-W-2A-003 Before cleaning 629.55 mmvf_S/c 2A 9094-W-2A-018 Post 1st cleaning - Test 1B 114.46 mmvf_S/c

2A 9094-W-2A-004 Before cleaning 2117.56 mmvf_S/c 2A 9094-W-2A-019 Post 1st cleaning - Test 1B 171.69 mmvf_S/c

2A 9094-W-2A-005 Before cleaning 343.39 mmvf_S/c 2A 9094-W-2A-020 Post 1st cleaning - Test 1B 57.23 mmvf_S/c

2A 9094-W-2A-021 Post 1st cleaning - Test 1B 114.46 mmvf_S/c

Average 786.93 Average 103.01 684

2B 9094-W-2B-002 Before cleaning 629.55 mmvf_S/c 2B 9094-W-2B-015 Post 1st cleaning - Test 3A < 57.23 mmvf_S/c

2B 9094-W-2B-003 Before cleaning 13163.22 mmvf_S/c 2B 9094-W-2B-016 Post 1st cleaning - Test 3A 114.46 mmvf_S/c

2B 9094-W-2B-004 Before cleaning 400.62 mmvf_S/c 2B 9094-W-2B-017 Post 1st cleaning - Test 3A 228.93 mmvf_S/c

2B 9094-W-2B-018 Post 1st cleaning - Test 3A 171.69 mmvf_S/c

2B 9094-W-2B-019 Post 1st cleaning - Test 3A 171.69 mmvf_S/c

Average 4731.13 Average 148.80 4,582

3A 9094-W-3A-002 Before cleaning 57.23 mmvf_S/c 3A 9094-W-3A-017 Post 1st cleaning - Test 2B < 22.89 mmvf_S/c

3A 9094-W-3A-003 Before cleaning 801.24 mmvf_S/c 3A 9094-W-3A-018 Post 1st cleaning - Test 2B < 22.89 mmvf_S/c

3A 9094-W-3A-004 Before cleaning 686.78 mmvf_S/c 3A 9094-W-3A-019 Post 1st cleaning - Test 2B < 22.89 mmvf_S/c

3A 9094-W-3A-020 Post 1st cleaning - Test 2B < 22.89 mmvf_S/c

3A 9094-W-3A-021 Post 1st cleaning - Test 2B < 22.89 mmvf_S/c

Average 515.08 Average 22.89 492

3B 9094-W-3B-002 Before cleaning 744.01 mmvf_S/c 3B 9094-W-3B-018 Post 1st cleaning - Scope A 57.23 mmvf_S/c

3B 9094-W-3B-003 Before cleaning 2289.26 mmvf_S/c 3B 9094-W-3B-019 Post 1st cleaning - Scope A < 57.23 mmvf_S/c

3B 9094-W-3B-004 Before cleaning 744.01 mmvf_S/c 3B 9094-W-3B-020 Post 1st cleaning - Scope A < 57.23 mmvf_S/c

3B 9094-W-3B-021 Post 1st cleaning - Scope A 57.23 mmvf_S/c

3B 9094-W-3B-022 Post 1st cleaning - Scope A < 57.23 mmvf_S/c

Average 1259.09 Average 57.23 1,202

.

3C 9094-W-3C-002 Before cleaning 343.39 mmvf_S/c 3C 9094-W-3C-016 Post 1st cleaning - Test 1A 57.23 mmvf_S/c

3C 9094-W-3C-003 Before cleaning 744.01 mmvf_S/c 3C 9094-W-3C-017 Post 1st cleaning - Test 1A 171.69 mmvf_S/c

3C 9094-W-3C-004 Before cleaning 343.39 mmvf_S/c 3C 9094-W-3C-018 Post 1st cleaning - Test 1A 400.62 mmvf_S/c

3C 9094-W-3C-019 Post 1st cleaning - Test 1A 114.46 mmvf_S/c

3C 9094-W-3C-020 Post 1st cleaning - Test 1A 114.46 mmvf_S/c

Average 476.93 Average 171.69 305

3D 9094-W-3D-002 Before cleaning 228.93 mmvf_S/c 3D 9094-W-3D-015 Post 1st cleaning - Test 1A < 22.89 mmvf_S/c

3D 9094-W-3D-003 Before cleaning 572.31 mmvf_S/c 3D 9094-W-3D-016 Post 1st cleaning - Test 1A 22.89 mmvf_S/c

3D 9094-W-3D-004 Before cleaning 1259.09 mmvf_S/c 3D 9094-W-3D-017 Post 1st cleaning - Test 1A < 22.89 mmvf_S/c

3D 9094-W-3D-005 Before cleaning 343.39 mmvf_S/c 3D 9094-W-3D-018 Post 1st cleaning - Test 1A < 22.89 mmvf_S/c

3D 9094-W-3D-019 Post 1st cleaning - Test 1A < 22.89 mmvf_S/c

Average 600.93 Average 22.89 578

4A 9094-W-4A-002 Before cleaning 400.62 mmvf_S/c 4A 9094-W-4A-015 Post 1st cleaning - Test 2A < 22.89 mmvf_S/c

4A 9094-W-4A-003 Before cleaning 629.55 mmvf_S/c 4A 9094-W-4A-016 Post 1st cleaning - Test 2A < 22.89 mmvf_S/c

4A 9094-W-4A-004 Before cleaning 171.69 mmvf_S/c 4A 9094-W-4A-017 Post 1st cleaning - Test 2A 22.89 mmvf_S/c

4A 4A 9094-W-4A-018 Post 1st cleaning - Test 2A < 22.89 mmvf_S/c

4A 9094-W-4A-019 Post 1st cleaning - Test 2A < 22.89 mmvf_S/c

Average 400.62 Average 22.89 378

Table 11.1
MMVF Wipe Samples - Before Cleaning and Post 1st Cleaning Results

Unit Number Sample_Id Cleaning Type Sign Result Units Unit Number Sample_Id Cleaning Type Sign Result Units Difference

Table 11.1

4B 9094-W-4B-002 Before cleaning 286.16 mmvf_S/c 4B 9094-W-4B-013 Post 1st cleaning - Test 2B 286.16 mmvf_S/c

4B 9094-W-4B-003 Before cleaning 629.55 mmvf_S/c 4B 9094-W-4B-014 Post 1st cleaning - Test 2B 228.93 mmvf_S/c

4B 9094-W-4B-004 Before cleaning 400.62 mmvf_S/c 4B 9094-W-4B-015 Post 1st cleaning - Test 2B 400.62 mmvf_S/c

4B 9094-W-4B-005 Before cleaning 686.78 mmvf_S/c 4B 9094-W-4B-016 Post 1st cleaning - Test 2B 171.69 mmvf_S/c

4B 9094-W-4B-017 Post 1st cleaning - Test 2B 57.23 mmvf_S/c

Average 500.78 Average 228.93 272

4C 9094-W-4C-002 Before cleaning 57.23 mmvf_S/c 4C 9094-W-4C-018 Post 1st cleaning - Test 1A 57.23 mmvf_S/c

4C 9094-W-4C-003 Before cleaning 1030.17 mmvf_S/c 4C 9094-W-4C-019 Post 1st cleaning - Test 1A 228.93 mmvf_S/c

4C 9094-W-4C-004 Before cleaning 343.39 mmvf_S/c 4C 9094-W-4C-020 Post 1st cleaning - Test 1A 343.39 mmvf_S/c

4C 9094-W-4C-021 Post 1st cleaning - Test 1A 114.46 mmvf_S/c

4C 9094-W-4C-022 Post 1st cleaning - Test 1A 228.93 mmvf_S/c

Average 476.93 Average 194.59 282

4D 9094-W-4D-002 Before cleaning 400.62 mmvf_S/c 4D 9094-W-4D-019 Post 1st cleaning - Test 2A 57.23 mmvf_S/c

4D 9094-W-4D-003 Before cleaning 2174.79 mmvf_S/c 4D 9094-W-4D-020 Post 1st cleaning - Test 2A 171.69 mmvf_S/c

4D 9094-W-4D-004 Before cleaning 286.16 mmvf_S/c 4D 9094-W-4D-021 Post 1st cleaning - Test 2A 572.31 mmvf_S/c

4D 9094-W-4D-005 Before cleaning 457.85 mmvf_S/c 4D 9094-W-4D-022 Post 1st cleaning - Test 2A 228.93 mmvf_S/c

4D 9094-W-4D-023 Post 1st cleaning - Test 2A 228.93 mmvf_S/c

Average 829.86 Average 251.82 578

5A 9094-W-5A-002 Before cleaning 297.60 mmvf_S/c 5A 9094-W-5A-019 Post 1st cleaning - Test 3B 286.16 mmvf_S/c

5A 9094-W-5A-003 Before cleaning 1308.15 mmvf_S/c 5A 9094-W-5A-020 Post 1st cleaning - Test 3B 57.23 mmvf_S/c

5A 9094-W-5A-004 Before cleaning 792.45 mmvf_S/c 5A 9094-W-5A-021 Post 1st cleaning - Test 3B 114.46 mmvf_S/c

5A 9094-W-5A-022 Post 1st cleaning - Test 3B 57.23 mmvf_S/c

5A 9094-W-5A-023 Post 1st cleaning - Test 3B 114.46 mmvf_S/c

Average 799.40 Average 125.91 673

5C 9094-W-5C-002 Before cleaning 457.85 mmvf_S/c 5C 9094-W-5C-016 Post 1st cleaning - Test 3A 1774.17 mmvf_S/c

5C 9094-W-5C-003 Before cleaning 457.85 mmvf_S/c 5C 9094-W-5C-017 Post 1st cleaning - Test 3A 744.01 mmvf_S/c

5C 9094-W-5C-004 Before cleaning 1144.63 mmvf_S/c 5C 9094-W-5C-018 Post 1st cleaning - Test 3A 4211.37 mmvf_S/c

5C 9094-W-5C-019 Post 1st cleaning - Test 3A 2758.14 mmvf_S/c

5C 9094-W-5C-020 Post 1st cleaning - Test 3A 1316.32 mmvf_S/c

Average 686.78 Average 2160.80 -1,474

5D 9094-W-5D-002 Before cleaning 251.82 mmvf_S/c 5D 9094-W-5D-015 Post 1st cleaning - Test 3B 171.69 mmvf_S/c

5D 9094-W-5D-003 Before cleaning 206.03 mmvf_S/c 5D 9094-W-5D-016 Post 1st cleaning - Test 3B 228.93 mmvf_S/c

5D 9094-W-5D-004 Before cleaning 712.21 mmvf_S/c 5D 9094-W-5D-017 Post 1st cleaning - Test 3B 171.69 mmvf_S/c

5D 9094-W-5D-005 Before cleaning 595.21 mmvf_S/c 5D 9094-W-5D-018 Post 1st cleaning - Test 3B 114.46 mmvf_S/c

5D 9094-W-5D-019 Post 1st cleaning - Test 3B 228.93 mmvf_S/c

Average 441.32 Average 183.14 258
Table 11.2 

Exceedances of COPC by Cleaning Event
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Second Floor Hallway: Test 4A

 Cleanup Criteria Post - First Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 5C: Test 3A, 3B

 Cleanup Criteria Pre-Cleaning Post-First Cleaning Post-Second Cleaning Post-Third Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2 303.5

Asbestos 0.0009 f/cc n/a OL OL 0.0016

OL OL 0.0015

OL OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 336 104 SB 

43.6 293

133

MMVF 0.01 f/cc n/a 13.399 16.598

19.25 12.621

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac

SB = Sample broken
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 5A: Test 3B

 Cleanup Criteria Pre-Cleaning Post-First Cleaning Post - Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 191 43.5 

2000 39.7

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a LT 0.007

OL = Overloading of particulates

MV = Microvac

LT = Concentration is less than the specified level of detection
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 4D: Test 2A

 Cleanup Criteria Pre-Cleaning Post - First Cleaning Post - Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2 325.8

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 169 83.5 0.146 R 20.4 R

66 0.137 R 66 R

26.2 10.6 R

39.9 15.6 R

78.2

72.1

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac

R = Result rejected
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 4C: Test 1A

 Cleanup Criteria Pre-Cleaning Post - First Cleaning Post - Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 181 76.1 NOT ANALYZED

77.5 83.7 14.9 R

69.8 8.28 R

70.8 7.81 R

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac

R = Result rejected
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 4B: Test 2B

 Cleanup Criteria Pre-Cleaning Post - First Cleaning Post - Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 50

30

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 4A: Test 2A

 Cleanup Criteria Pre-Cleaning Post - First Cleaning Post - Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a 0.008

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 3D: Test 1A

 Cleanup Criteria Pre-Cleaning Post-First Cleaning Post-Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 201 50.7 0.074 R 5.71 R 

112 0.126 R

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac

R = Result rejected
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 3C: Test 1A, 3B

 Cleanup Criteria Pre-Cleaning Post-First Cleaning Post-Second Cleaning Post-Third Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2 6.2

PAH 0.2 ug/m3 300 ug/m2 1046.6

Asbestos 0.0009 f/cc n/a OL OL

OL OL

OL OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 750 68.4 26.9 

48.7 135

43.3

39.4

MMVF 0.01 f/cc n/a 91.796

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 3B: Scope A

 Cleanup Criteria Pre-Cleaning Post-First Cleaning Post-Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 SAMPLE LOST 51.6 SB

MMVF 0.01 f/cc n/a 14.78

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac

SB = Sample broken
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 3, Unit 3A: Test 2B

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 38.9 0.116 R 

0.131 R

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac

R = Result rejected
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 2B: Test 3A 

 Cleanup Criteria Pre-Cleaning Post - First Cleaning Post - Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 97

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

UD = Uneven distribution of material

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 2A: Test 1B

 Cleanup Criteria Pre-Cleaning Post - First Cleaning Post - Second Cleaning Post - Third Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 49.4

44.6

35.4

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Mattress Store: Test A (Industrial HEPA filtered vacuums, AFD)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2 LT 2.7

Asbestos 0.0009 f/cc n/a OL OL

OL OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 38.9 43.9

77 42.2

MMVF 0.01 f/cc n/a 11.716

92.184

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac

LT = Concentration is less than the specified level of detection
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Mattress Store: Test B (Wet wipe all walls)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2 2.7

Asbestos 0.0009 f/cc n/a OL OL

OL OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 38.9 91.5

77 79.3

MMVF 0.01 f/cc n/a 11.716

92.184

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Mattress Store: Test C (Hot water carpet shampoo)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2 2.7

Asbestos 0.0009 f/cc n/a OL 0.0025

OL 0.0016

0.0025

0.0016

0.0016

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 38.9

77

MMVF 0.01 f/cc n/a 11.716

92.184

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Mattress Store: Test D (A/C duct cleaning)

 Pre-Cleaning Post - First Cleaning

COPC Wipe MV Air Wipe MV Air Wipe MV

Dioxin 4 ng/m2

PAH 300 ug/m2 2.7

Asbestos n/a OL

OL

Lead 25 ug/ft2 25 ug/ft2 38.9

77

MMVF n/a 11.716

92.184

Silica n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Mattress Store: Test E 

(Cleaning of vinyl floor tile and window ledge wet wipe using water only)

 Cleanup Criteria Pre-Cleaning Pre-Water Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Wipe Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2 2.7

Asbestos 0.0009 f/cc n/a OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 38.9 38.2

77

MMVF 0.01 f/cc n/a 11.716

92.184

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Liberty Street Staircase: Test 4A, 4B

 Cleanup Criteria Post - First Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a 22

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Lemongrass Grill: Test 4A

 Cleanup Criteria Pre-Cleaning Post-First Cleaning Post-Second Cleaning Post-Encap.

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

OL

OL

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 10700 J 25.9 R 

166

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac

R = Result rejected

J = Estimated concentration
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Lemongrass Grill Basement

 Cleanup Criteria Post-First Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

The Food Exchange: Test 4A

 Cleanup Criteria Pre-Cleaning Post - First CleaningPost-Encap.

COPC Air Wipe MV Air Wipe MV Air Wipe MV Air WipeMV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 1310 136 

183

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

The Food Exchange Basement

 Cleanup Criteria Post-First Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Elevator Shaft/Compactor Room: Test 4A

 Cleanup Criteria Post - First Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a 

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Chiropractor's Office: Test A (Industrial HEPA filtered vacuums, AFD)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a UD

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 433 28.2 146

346 181 J 64.5

116 69.3 J 

74.7

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a LT 8

UD = Uneven distribution of material

OL = Overloading of particulates

MV = Microvac

J = Estimated concentration

LT = Concentration is less than the specified level of detection
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Chiropractor's Office: Test B (Wet Wipe all walls)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

0.039

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 433 28.2 147

346 181 556

116 69.3

74.7

MMVF 0.01 f/cc n/a 17.579

60.606

Silica 4 ug/m3 n/a

OL = Overloading of particulates

M.V. = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Chiropractor's Office: Test C (Hot water wet vacuum)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

0.0033

OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 433 28.2 1.89

346 181 2.56

116 69.3

74.7

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Chiropractor's Office: Test D (A/C duct cleaning)

 Cleanup Criteria Pre-Cleaning Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 433 28.2

346 181

116 69.3

74.7

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Chiropractor's Office: Test E 

(Cleaning of bathroom floor and desk top wet wipe using water only)

 Cleanup Criteria Pre-Cleaning Pre-Water Post - First Cleaning

COPC Air Wipe MV Air Wipe MV Wipe Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 433 28.2 147 ug/ft2 (Tile) 954 (Tile)

346 181 556 ug/ft2 (Desk)

116 69.3

74.7

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Cedar Street Staircase: Test 4A, 4B

 Cleanup Criteria Post - First Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a 

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Barber Shop: Test 4A, 4E 

 Cleanup Criteria Pre-Water Wipe Post-Water Wipe

COPC Air Wipe MV Air Wipe Air Wipe

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 12.1 R

25.9 R

42.9

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac

R = Result rejected
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Fifth Floor Hallway: Test 4A

 Cleanup Criteria Post-First Cleaning Post-Second Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a OL

OL

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

OL = Overloading of particulates

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Fourth Floor Hallway: Test 4A

 Cleanup Criteria Post-Cleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Third Floor Hallway: Test 4A

 Cleanup Criteria Post - FirstCleaning

COPC Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Table 11.2

Contaminants of Potential Concern (COPC) Exceedance By Event

Unit 5D: Test 3B

 Cleanup Criteria Pre-Cleaning Post-First Cleaning

COPC Air Wipe MV Air Wipe MV Air Wipe MV

Dioxin 0.001 ng/m3 4 ng/m2

PAH 0.2 ug/m3 300 ug/m2

Asbestos 0.0009 f/cc n/a

Lead 1 ug/m3 25 ug/ft2 25 ug/ft2 25.3 27.1

32.1 49.1

MMVF 0.01 f/cc n/a

Silica 4 ug/m3 n/a

MV = Microvac
Attachment A 

 Personal Monitoring Data
 Personal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

 Method NIOSH 7400 (PCM); NIOSH 7402 (TEM). Flow Rate 2.0 L/min, Minimum Sample Volume 400 L)

ocation Sample Number Location 

PCM TEM PEL 0.1f/cc (PCM) PCM TEM

ommon-JN 0.024 <.003 APS-9094-A-070802-BA 5A 0.013 <.002

C 0.022 <.003 APS-9094-A-070802-FB BLANK < N/A

LANK < N/A APS-9094-A-070802-LB LOT BLANK < N/A

OT BLANK < N/A APS-9094-A-070902-JB 4B 0.003 <.003

ommon-BA 0.012 <.003 APS-9094-A-070902-JN 5A 0.002 <.002

ommon 0.013 <.003 APS-9094-A-070902-FB BLANK < N/A

LANK < N/A APS-9094-A-070902-LB LOT BLANK < N/A

OT BLANK < N/A APS-9094-A-071002-GR 4B 0.022 0.007

D 0.008 **** APS-9094-A-071002-SC 5A 0.031 <.003C 0.015 <.002 APS-9094-A-071002-FB BLANK < N/A

LANK < N/A APS-9094-A-071002-LB LOT BLANK < N/A

OT BLANK < N/A APS-9094-A-071102-JB 3C 0.022 <.002

D/2B 0.012 <.002 APS-9094-A-071102-BA 3D 0.079 <.008

C 0.016 <.002 APS-9094-A-071102-FB BLANK <  

LANK < N/A APS-9094-A-071102-LB LOT BLANK < ** **

OT BLANK < N/A APS-9094-A-071202-GR 3C 0.006  C overloaded APS-9094-A-071202-JN 3D/MATRESS 0.006 ** **

B 0.006 *** APS-9094-A-071202-FB BLANK <  

LANK < ** * APS-9094-A-071202-LB LOT BLANK < ****

OT BLANK < *** APS-9094-A-071302-RH 4A/MATRESS 0.038 <.011

B/4C 0.007 *** APS-9094-A-071302-SC 4D/4A/CHIRO 0.057 <.012

D 0.005 *** APS-9094-A-071302-FB BLANK < N/A

LANK < *** APS-9094-A-071302-LB LOT BLANK < N/A

OT BLANK < *** APS-9094-A-071502-GR 3A 0.018 <.002

D 0.051 <.003 APS-9094-A-071502-BA 2A 0.021 <.002

C 0.027 <.003 APS-9094-A-071502-FB BLANK N/A N/A

OT BLANK N/A N/A APS-9094-A-071502-LB LOT BLANK N/A N/A

C 0.018 <.002 APS-9094-A-071602-JB 3A 0.011 <.002

D/5A 0.016 <.002 APS-9094-A-071602-JN 2A 0.014 <.002

LANK < N/A APS-9094-A-071602-FB BLANK N/A N/A

OT BLANK < N/A APS-9094-A-071602-LB LOT BLANK N/A N/A

C 0.01 <.004 APS-9094-A-071702-GR 3A 0.004  

LANK < N/A APS-9094-A-071702-SC MATRESS 0.023 <.003

OT BLANK < N/A APS-9094-A-071702-FB BLANK < N/A

C/4B 0.013 <.002

ASBESTOS (f/cc) ASBESTOS (f/cc)

C reoccupancy standard (.01 f/cc ) so TEM was not run.

his method assumes the limit of dectection is 7 f/mm2 

1
 Personal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

 Method NIOSH 7400 (PCM); NIOSH 7402 (TEM). Flow Rate 2.0 L/min, Minimum Sample Volume 400 L)

ocation Sample Number Location 

PCM TEM PEL 0.1f/cc (PCM) PCM TEM

OT BLANK < N/A APS-9094-A-072602-LB LOT BLANK < ** **

A/4A 0.009 *** APS-9094-A-072702-JN 3C 0.039 <.005

ATRESS 0.037 <.003 APS-9094-A-072702-FB BLANK < N/A

LANK N/A *** APS-9094-A-072902-JB THAI 0.039 <.004

OT BLANK N/A *** APS-9094-A-072902-SC 3C 0.039 overloaded

HIRO OVERLOADED 0.053 APS-9094-A-072902-FB BLANK < N/A

ATRESS 0.013 <.002 APS-9094-A-072902-LB LOT BLANK < N/A

LANK < N/A APS-9094-A-073002-BA THAI 0.005  

OT BLANK < N/A APS-9094-A-073002-SC CHIRO/CA 0.006 ** **

ATRESS 0.017 <.002 APS-9094-A-073002-FB BLANK <  

HIRO OVERLOADED >.004 APS-9094-A-073002-LB LOT BLANK < ** **

A 0.011 <.007 APS-9094-A-073102-JN MATRESS 0.009  

LANK < ** * APS-9094-A-073102-GR THAI 0.022 ****

OT BLANK < *** APS-9094-A-073102-FB BLANK < N/A

HIRO 0.019 <.002 APS-9094-A-073102-LB LOT BLANK < N/A

ATRESS 0.012 <.002 APS-9094-A-080102-SC CHIRO 0.009  

A 0.009 ** * APS-9094-A-080102-BA THAI 0.007 ****

LANK < N/A APS-9094-A-080102-FB BLANK <  

OT BLANK < N/A APS-9094-A-080102-LB LOT BLANK < ** **D 0.016 <.002 APS-9094-A-080202-GR THAI <.002  

A/THAI/3B 0.021 <.002 APS-9094-A-080202-JN MATRESS/CA <.002 ** **

LANK < N/A APS-9094-A-080202-FB BLANK <  

OT BLANK < N/A APS-9094-A-080202-LB LOT BLANK < ** **

HIRO 0.048 <.008 APS-9094-A-080302-SC MATRESS 0.004  

C/CA 0.049 <.006 APS-9094-A-080302-BA CA 0.006 ** **

LANK < N/A APS-9094-A-080302-FB BLANK <  

OT BLANK < N/A APS-9094-A-080302-LB LOT BLANK < ** **

A/5C 0.034 <.002 APS-9094-A-080502-GR THAI 0.004  

B 0.021 <.004 APS-9094-A-080502-JN THAI 0.005 ** **

LANK < N/A APS-9094-A-080502-FB BLANK <  

OT BLANK < N/A APS-9094-A-080502-LB LOT BLANK < ** **

B 0.004 *** APS-9094-A-080602-JN THAI 0.002  

 Liberty 0.004 ** * APS-9094-A-080602-FB BLANK < ****

C/THAI 0.007 *** APS-9094-A-080702-BA THAI 0.002  

LANK < ** * APS-9094-A-080702-FB BLANK < ****

ASBESTOS (f/cc) ASBESTOS (f/cc)

C reoccupancy standard (.01 f/cc ) so TEM was not run.

his method assumes the limit of dectection is 7 f/mm2 

2
 Personal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

 Method NIOSH 7400 (PCM); NIOSH 7402 (TEM). Flow Rate 2.0 L/min, Minimum Sample Volume 400 L)

ocation Sample Number Location 

PCM TEM PEL 0.1f/cc (PCM) PCM TEM

HAI 0.007 *** APS-9094-A-090402-SC FOOD X 0.004 N/A

LANK < *** APS-9094-A-090402-FB BLANK < N/A

HAI 0.006 *** APS-9094-A-090502-JN FOOD X <.003 N/A

LANK < *** APS-9094-A-090502-FB BLANK < N/A

B 0.016 <.003 APS-9094-A-090602-SC 5TH CA 0.019 <.005

LANK < N/A APS-9094-A-090602-FB BLANK < N/A

TH CA 0.007 *** APS-9094-A-090902-JN 3D 0.011 <.003

LANK < *** APS-9094-A-090902-SC 4A 0.018 N/A

OOD X 0.022 <.003 APS-9094-A-090902-FB BLANK < N/A

LANK < N/A APS-9094-A-091002-JN 2A 0.005 N/A

OOD X 0.008 *** APS-9094-A-091002-SC 5C 0.007 N/A

LANK < *** APS-9094-A-091002-FB BLANK < N/A

OOD X 0.038 <.003 APS-9094-A-091202-SC MATTRESS/CHIRO 0.011 <.002

LANK < *** APS-9094-A-091202-JN 3C 0.005 <.002

OOD X 0.02 APS-9094-A-091302-JN BARBER 0.131 <.008

LANK < *** APS-9094-A-091602-JN BARBER overloaded 0.007

OOD X 0.009 *** APS-9094-A-091602-SC FOOD X 0.008 N/A

LANK < *** APS-9094-A-091602-FB BLANK < N/A

OOD X 0.014 <.002 APS-9094-A-091702-JN BARBER overloaded 0.003

LANK < N/A APS-9094-A-091702-SC FOOD X 0.015 <.003

OOD X <.005 *** APS-9094-A-091702-FB BLANK < N/A

LANK < N/A APS-9094-A-091802-SC THAI 0.017 0.002

OOD X 0.022 <.003 APS-9094-A-091802-JN BARBER 0.033 <.002

LANK < N/A APS-9094-A-091802-FB BLANK < N/A

OOD X 0.02 <.002 APS-9094-A-091902-SC FOOD X 0.006 <.002

LANK < N/A APS-9094-A-091902-JN 5C/BARBER 0.025 <.002

OOD X 0.007 *** APS-9094-A-091902-FB BLANK < N/A

LANK < N/A APS-9094-A-092402-SC N-STRS/3RD FL 0.019 <.002

OOD X 0.028 <.006 APS-9094-A-092402-JN BARBER 0.011 <.002

LANK < N/A APS-9094-A-092402-FB BLANK < N/A

OOD X 0.028 <0.003 APS-9094-A-092502-SC S-STRS/2ND FL 0.007 N/A

LANK < N/A APS-9094-A-092502-FB BLANK < N/A

ASBESTOS (f/cc) ASBESTOS (f/cc)

C reoccupancy standard (.01 f/cc ) so TEM was not run.

his method assumes the limit of dectection is 7 f/mm2 

3
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7300, Flow Rate 2.0 L/min PEL 50 ug/m3

)

Location LEAD (ug/m3

) Sample Number Location LEAD (ug/m3

)

Common-JN <.269 LPS-9094-A-070802-FB BLANK <.250

5C 0.909 LPS-9094-A-070802-LB LOT BLANK 0.268

BLANK <.25 LPS-9094-A-070902-JB 4B <.169

LOT BLANK <.25 LPS-9094-A-070902-JN 5A 0.433

Common-BA <.233 LPS-9094-A-070902-FB BLANK <.250

Common <.347 LPS-9094-A-070902-LB LOT BLANK <.250

BLANK <.25 LPS-9094-A-071002-GR 4B 1.68

LOT BLANK <.25 LPS-9094-A-071002-SC 5A 0.272

5D <.238 LPS-9094-A-071002-FB BLANK 0.3285C <.0213 LPS-9094-A-071002-LB LOT BLANK 0.267

BLANK <.25 LPS-9094-A-071102-BA 3D 0.234

LOT BLANK <.25 LPS-9094-A-071102-JB 3C 0.245

5D/2B <.202 LPS-9094-A-071102-FB BLANK <.250

5C <.202 LPS-9094-A-071102-LB LOT BLANK <.250

BLANK <.25 LPS-9094-A-071202-GR 3C <.242

LOT BLANK <.25 LPS-9094-A-071202-JN 3D/MATRESS <.2585C <.211 LPS-9094-A-071202-FB BLANK <.25

2B <.273 LPS-9094-A-071202-LB LOT BLANK <.25

BLANK <.250 LPS-9094-A-071302-SC Chiro/4D/4A <.0395

LOT BLANK <.250 LPS-9094-A-071302-RH 4A/MATRESS <.0418

BLANK <.250 LPS-9094-A-071302-FB BLANK <.25

LOT BLANK <.250 LPS-9094-A-071302-LB LOT BLANK <.25

2B/4C <.210 LPS-9094-A-071502-GR 3A <.209

4D 0.387 LPS-9094-A-071502-BA 2A <.0214

4C <.255 LPS-9094-A-071502-FB BLANK <.25

BLANK <.25 LPS-9094-A-071502-LB LOT BLANK <.25

LOT BLANK <.25 LPS-9094-A-071602-JB 3A <.225

4C <.207 LPS-9094-A-071602-JN 2A <.227

4D/5A <.205 LPS-9094-A-071602-FB BLANK <.25

BLANK <.250 LPS-9094-A-071602-LB LOT BLANK <.25

LOT BLANK <.250 LPS-9094-A-071702-SC MATRESS 0.2774C <.269 LPS-9094-A-071702-GR 3A <.216

BLANK <.250 LPS-9094-A-071702-FB BLANK <.250

LOT BLANK <.250 LPS-9094-A-071702-LB LOT BLANK <.250

4C/4B 0.244 LPS-9094-A-071802-JN MATRESS 0.2775A 0.36 LPS-9094-A-071802-JB 3A/4A <.208

1
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7300, Flow Rate 2.0 L/min PEL 50 ug/m3

)

Location LEAD (ug/m3

) Sample Number Location LEAD (ug/m3

)

BLANK <.250 LPS-9094-A-072202-FB BLANK <.250

LOT BLANK <.250 LPS-9094-A-072202-LB LOT BLANK <.250

MATRESS <.206 LPS-9094-A-072302-SC 3D <.272CHIRO 0.312 LPS-9094-A-072302-NF CA/THAI/3B 0.272

BLANK <.250 LPS-9094-A-072302-FB BLANK <.250

LOT BLANK <.250 LPS-9094-A-072302-LB LOT BLANK <.250

CHIRO 0.765 LPS-9094-A-072402-NF CHIRO 0.328

BLANK <.250 LPS-9094-A-072402-JN 4C/CA <.218

LOT BLANK <.250 LPS-9094-A-072402-FB BLANK <.250

CHIRO <.224 LPS-9094-A-072402-LB LOT BLANK <.250

2
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

ation 

(mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3)

0.1 0.05 0.05 5 5 5

mmon-JN 0.027 0.029 0.317 0.337 0.09 0.096 0.31 0.033 0.058 0.062 0.034 0.036

0.099 0.108 0.359 0.393 <.02 <.022 <.02 <.022 <.02 <.022 <.02 <.022

NK <.005 N/A <.020 N/A <..020 N/A N/A N/A <.02 N/A <.02 N/A

 BLANK 0.013 N/A 0.395 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

mmon-BA 0.011 0.016 0.047 0.067 <.02 <.029 <.02 <.014 <.02 0.014 <.02 <.014

mmon <.01 <.009 0.035 0.031 <.02 <.018 <.02 <.009 <.02 <.009 <.02 <.014

NK <.01 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK 0.007 N/A 0.109 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.043 <.20 <.017 <.02 <.017 <.02 <.017 <.02 <.017 <.02 <.017

0.011 0.009 0.209 0.179 0.104 0.089 0.023 0.02 0.021 0.018 0.02 0.017

NK <.005 N/A 0.021 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A 0.021 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

2B <.005 <.004 <.02 <.016 <.02 <.016 <.02 <.016 <.02 <.016 <.02 <.016

0.005 0.004 0.095 0.078 0.029 0.024 <.02 <.016 <.02 <.016 <.02 <.016

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.003 <.02 <.01329 <.02 <.01329 <.02 <.013 <.02 <.013 <.02 <.013

0.016 0.012 <.02 <.01490 <.02 <.01490 0.045 0.034 <.02 <.015 <.02 <.015

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

4C 0.012 0.008 <.02 <.01412 <.02 <.01412 <.02 <.014 <.02 <..014 <.02 <.014

<.005 <.003 <.02 <.01338 <.02 <.01338 <.02 <.013 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.004 0.034 0.028 0.032 0.027 <.02 <.017 <.02 <.017 <.02 <.017

<.005 <.004 <.02 <.017 <.02 <.017 <.02 <.017 <.02 <.017 <.02 <.017

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.006 0.004 0.025 0.016 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013

5A <.005 <.003 0.029 0.018 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.007 <.02 <.027 <.02 <.027 <.02 <.027 <.02 <.027 <.02 <.027

SILICA

Quartz Cristobalite ** Tridymite Gypsum Calcite Portlandite

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

1
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

ation 

(mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3)

0.1 0.05 0.05 5 5 5

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

4B <.005 <.003 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

<.005 <.003 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK 0.011 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

0.032 0.022 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

<.005 <.003 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

NK 0.1 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK 0.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.020 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

<.050 <.032 <.02 <.013 <.02 <.013 <.02 <.014 <.02 <.013 <.02 <.013

NK <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

0.013 0.009 <.02 <.014 <.02 <.014 0.018 0.012 <.02 <.014 <.02 <.0140.007 0.005 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.004 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

MATRESS <.005 <.003 <.02 <.013 <.02 <.013 0.013 0.009 <.013 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

MATRESS <.005 <.006 <.02 <.022 <.02 <.022 0.012 0.013 <.02 <.022 <.02 <.022

4A <.005 <.005 <.02 <.022 <.02 <.022 <.02 <.022 <.02 <.022 <.02 <.022

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.003 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013

0.009 0.006 <.02 <.014 <.02 <.014 0.012 <.014 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

<.005 <.004 <.02 <.014 <.02 <.014 <.02 N/A <.02 N/A <.02 N/A

<.005 <.004 <.02 <.014 <.02 <.014 <.02 N/A <.02 N/A <.02 N/A

Quartz Cristobalite ** Tridymite Portlandite Gypsum Calcite

SILICA

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

2
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

ation 

(mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3)

0.1 0.05 0.05 5 5 5

NK <.005 N/A <.02 N/A <.02 N/A <.02 <.014 <.02 <.014 <.02 <.014

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 <.014 <.02 <.014 <.02 <.014

<.005 <.003 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

TRESS <.005 <.004 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

4A 0.03 0.02 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014 <.02 <.014

TRESS 0.005 0.004 <.02 <.016 <.02 <.016 <.02 <.014 <.02 <.016 <.02 <.015

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

RO <.005 <.004 <.02 <.017 <.02 <.017 0.024 0.02 <.02 <.017 <.02 <.017

TRESS <.005 <.003 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

TRESS <.005 <.003 <.02 <.013 <.02 <.013 0.018 0.012 <.02 <.013 <.02 <.013

RO <.005 <.003 <.02 <.014 <.02 <.014 0.023 0.016 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

RO <.005 <.004 <.02 <.014 <.02 <.014 0.014 0.01 <.02 <.014 <.02 <.014

TRESS <.005 <.004 <.02 <.014 <.02 <.014 0.01 0.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

<.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

THAI/3B <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

RO <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

CA <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

5C <.005 <.003 <.02 <.003 <.02 <.013 0.011 0.007 <.02 <.013 <.02 <.013

<.005 <.003 <.02 <.003 <.02 <.014 <.01 0.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 <as <.02 N/A

Portlandite

SILICA

Quartz Cristobalite ** Tridymite Gypsum Calcite

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

3
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

ation 

(mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3)

0.1 0.05 0.05 5 5 5

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 <as <.02 N/A

THAI <.005 <.003 <.02 <.013 <.02 <.013 <.01 <.007 <.02 <.013 <.02 <.013

<.005 <.003 <.02 <.013 <.02 <.013 <.01 <.007 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

<.005 <.008 <.02 <.032 <.02 <.032 <.01 <.016 <.02 <.032 <.02 <.032

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I <.005 <.003 <.020 <.013 <.02 <.013 <0.10 <.007 <.02 <.013 <.02 <.013

<.005 <.003 <.020 <.014 <.02 <.014 0.013 0.009 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.010 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.010 N/A <.02 N/A <.02 N/A

I <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

RO/CA <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

TRESS <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

I <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

RO 0.011 0.008 <.02 <.014 <.02 <.014 <.01 <.007 0.027 0.019 <.02 <.014

I <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I <.005 <.004 <.02 <.014 <.02 <.014 <.01 <0.07 <.02 <.014 <.02 <.014

TRESS/CA <.005 <.004 <.02 <.014 <.02 <.014 <.01 <0.07 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

TRESS <.005 <.006 <.02 <.023 <.02 <.023 <.01 <.011 <.02 <.023 <.02 <.023

<.005 <.006 <.02 <.023 <.02 <.023 <.01 <.011 <.02 <.023 <.02 <.023

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I 0.011 0.008 <.02 <.015 <.02 <.015 <.01 <.007 <.02 <.015 <.02 <.015

I <.005 <.0004 <.02 <.015 <.02 <.015 <.01 <.007 <.02 <.015 <.02 <.015

Calcite Portlandite

SILICA

Quartz Cristobalite ** Tridymite Gypsum

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

4
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

ation 

(mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3)

0.1 0.05 0.05 5 5 5

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I <.005 <.002 <.02 <.008 <.02 <.008 <.01 <.004 <.02 <.008 <.02 <.008

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I <.005 <.002 <.02 <.008 <.02 <.008 <.01 <.004 <.02 <.008 <.02 <.008

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

I <.005 <.007 <.02 <.027 <.02 <.027 <.01 <.027 <.02 <.014 <.02 <.027

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

<.005 <.005 <.02 <.02 <.02 <.02 <.01 <.01 <.02 <.02 <.02 0.01

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

CA <.005 <.015 <.02 <.015 <.02 <.015 <.02 <.015 <.02 <.015 <.02 <.015

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

OD X <.005 <.004 <.02 <.017 <.02 <.017 <.01 <.009 <.02 <.017 <.02 <.017

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.004 <.02 <.018 <.02 <.018 <.01 <.009 <.02 <.018 <.02 <AS

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <AS <.02 <AS <.02 <AS <.01 <.009 <.02 <.018 <.02 <.018

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.017 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.004 <.02 <.014 <.02 <.014 <.01 N/A <.02 N/A <.02 N/A

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.007 <.02 <.027 <.02 <.027 <.01 <.013 <.02 <.027 <.02 <.027

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.004 <.02 <.017 <.02 <.017 <.01 0.009 <.02 <.017 <.02 <.017

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.003 <.02 <.013 <.02 <.013 <.01 <.007 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.003 <.02 <.014 <.02 <.014 <.02 <.007 <.02 <.014 <.02 <.014

SILICA

Quartz Gypsum Calcite Cristobalite ** Tridymite Portlandite

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

5
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

ation 

(mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3)

0.1 0.05 0.05 5 5 5

NK <.005 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A <.02 N/A

OD X <.005 <.009 <.02 <.035 <.02 <.035 <.01 <.018 <.02 <.035 <.02 <.035

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X 0.006 0.005 <.02 <.017 <.02 <.015 <.01 <.008 <.02 <.017 <.02 <.017

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.003 <.02 <.013 <.02 <.013 0.01 0.007 <.02 <.013 <.02 <.013

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

 CA <.005 <.008 <.02 <.032 <.02 <.032 <.01 <.016 <.02 <.032 <.02 <.032

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.2 N/A

0.007 0.008 <.02 <.023 <.02 <.023 0.035 0.039 0.071 0.08 <.02 <.023

NK 0.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

RBER <.005 <.012 <.02 <.047 <.02 <.047 0.01 0.023 <.02 <.047 <.02 <.047

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

RBER 0.005 0.004 <.02 <.017 <.02 <.017 0.024 0.02 <.02 <.017 <.02 <.017

OD X <.005 <.004 <.02 <.017 <.02 <.017 <.01 <.009 <.02 <.017 <.02 <.017

NK <.005 N/A <.02 N/A <.02 N/A 0.024 0.02 <.02 N/A <.02 N/A

 BLANK <.005 N/A <.02 N/A <.02 N/A <.01 <.009 <.02 N/A <.02 N/A

RBER 0.008 0.006 <.02 <.015 <.02 <.015 <.01 <.007 <.02 <.015 <.02 <.015

OD X 0.005 0.004 <.02 <.015 <.02 <.015 <.01 <.007 <.02 <.015 <.02 <.015

NK <.005 N/A <.02 N/A <.02 N/A N/A N/A <.02 N/A <.02 N/A

RBER <.005 <.004 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

OD X <.005 <.003 <.02 <.014 <.02 <.014 <.01 <.007 <.02 <.014 <.02 <.014

NK <.005 N/A <.02 N/A <.02 N/A <.01 N/A <.02 N/A <.02 N/A

TRS/3RD FL <.005 <.003 <.02 <.014 <.02 <.014 <.01 <AS <.02 <.014 <.02 <.014

RBER 0.005 0.003 <.020 <.013 <.02 <.013 <.01 <AS <.02 <.013 <.02 <.013

NK <.005 N/A <.020 N/A <.02 N/A <.010 N/A <.02 N/A <.02 N/A

SILICA

Quartz Cristobalite ** Tridymite Gypsum Calcite Portlandite

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

6
ersonal Air Sampling Results for the WTC Residential Confirmation Cleaning Study

(Analytical Method NIOSH 7500, Flow Rate 2.5 L/min, Required Volume 400 to 1,000 L)

alite and Tridymite

 Limit for quartz (0.1 mg/m3) was arrived by using 100 in the denominator of the formula specified for quartz

e Z-3. The cristobalite and tridymite PELs (0.05 mg/m3) were arrived at by halving the quartz value as

1000 Table Z-3

ues of Cristobalite in EPA WTC Samples

been using the tertiary peak (non-overlapping with other five phases) for Cristobalite for estimating this phase if it is 

s

e samples do show a strong diffraction peak in the angular region 30.2-32.4 degree 2-theta. However, there are ese peaks may be due to some other phase, not Cristobalite.Three spectra from the project # 040208995

 a strong peak and the true position for cristobalite superimposed. Clearly, the peaks in these samples are very mu

espect to the true position. For comparison purposes, a similar spectra taken on a 50 ug cristobalite standard is als

o

g a disclaimer, that Cristobalite has not been confirmed in these samples and that estimates are only tentative.

he NYC reoccupancy standard (.01 f/cc). Therefore, TEM was not run.

 is equivalent to the Analytical Sensitivity which is calculated from the lowest reproducible concentration of silica detectable by the instrument.

7
Attachment B 

The Work Plan and Changes to the Work Plan 
Residential Confirmation Cleaning Study

Work Plan

Prepared for and by:

The United States Environmental Protection Agency 

2890 Woodbridge Avenue 

Edison, New Jersey 08837 

May 30, 2002
1 

1. INTRODUCTION

The United States Environmental Protection Agency (EPA) has been tasked to evaluate the 

effectiveness of various cleaning procedures that may have been utilized in cleaning residential 

living spaces located in the immediate vicinity of ground zero that are contaminated with dust 

and debris from the World Trade Center (WTC) attack. The study will involve implementing 

various vacuuming and cleaning techniques in separate apartments to determine their 

effectiveness. Comprehensive sampling for Contaminants of Potential Concern (COPC) will be 

conducted throughout the study to determine which method of cleaning is most effective at dust 

control. The building located at 110 Liberty Street has been selected for the study. The location 

of the building in relation to ground zero is shown on Figure 1.0. 

1.1 BACKGROUND INFORMATION

The building at 110 Liberty Street is five stories with twelve (12) residential and six commercial 

spaces and has been unoccupied since September 11, 2001. It is owned by Liberty Street 

Associates LLC (David M. Baldwin Realty Company, Inc). The building is situated between 

Liberty and Cedar Steets and has a co-address of 113-117 Cedar Street. The collapse of the WTC 

severly impacted all spaces in the building with deposition of dust and debris. Windows of 

residential and commercial spaces facing the WTC were blown out as were the sky lights located 

in the ceilings of the three, fifth floor dwellings. The building was professionally cleaned shortly 

after the collapse of the WTC. The cleanup was limited to all residential spaces, the basement 

and the roof. None of the commercial spaces, except for unit 3A were cleaned. Two of the 

commercial spaces (Unit 1 and Unit 2) are presently covered with inches of dust. All of the 

residential rental spaces contain dust of various degrees due to redeposition of dust generated 

from the work effort at ground zero. 

The rental spaces range in size from 1,000 to 1,300 square feet. The residential spaces are of 

open design and include a kitchen, bathroom and sleeping area. Commercial spaces identified as 

Unit 1, Unit 2 and Dwelling 3A were used as a chiropractors office, a retail mattress showroom 

and offices of Baldwin Realty, respectively. Each space is heated by an individual hot water 

base board system. Window or roof mounted air conditioners are present in the residential space, 

central systems are present in the commercial space (Unit 1 and Unit 2). Rental spaces are 

accessible from Liberty or Cedar Streets through common hallways, floors are accessible via an 

elevator and stairs. The building is presently without electricity and service is not expected to be 

restored until mid June. Each floor has a trash compactor room and a utility room. A laundry 

room is located on the second floor. The basement contains the building trash compactor, 

elevator shaft, electric meter rooms, preparation and storage areas for the Chinese restaurant, and 

a hair salon. 

The study will be conducted on twelve (12) residential and three commercial spaces. The two 

restaurants and hair salon are not part of the study but will be cleaned by EPA at the completion 

of the study. 
2 

2. PROPOSED PLANS AND PROJECT OBJECTIVES

EPA will evaluate eight cleaning techniques during the study. Fifteen (15) separate units will be 

identified and evaluated based on the following criteria: exposure to ground zero, type of interior 

decorating and the location of the unit in the building. Cleaning techniques will be specific to 

each unit and will consist of basic vacuuming with standard household equipment to use of 

advanced commercial quality equipment. Wet wiping of horizontal surfaces will be performed in 

each unit. The use of wet vacuums for cleaning carpets will also be investigated. 

Comprehensive sampling for COPC will be conducted prior to, during and after the cleanup. 

Laboratory data will be evaluated by EPA to determine the efficiency and effectiveness of each 

cleanup technique as well as possible exposures to individuals performing the task. 

The Cleanup Plan details the tasks and procedures to be used during the cleaning of specific 

units. Tasks will be identified and protocols will be detailed for building assessments, setup of 

support/decontamination zones, vacuuming/washing and disposal. 

The Sampling and Analysis Plan (SAP) presents the detailed procedures and methods for 

sampling and analysis of bulk, surface and airborne dusts. Sampling will be performed during all 

phases of the cleanup. A Quality Assurance Project Plan (QAPP) is included in the Sampling and 

Analysis Plan to ensure that the sampling and analysis are conducted in conformance with EPA 

Quality Assurance/Quality Control (QA/QC) objectives. 

 

The Health and Safety Plan (HASP) provides the minimum safety requirements that will be 

implemented during the activities conducted under the Cleanup and Sampling Plans. The Health 

and Safety Plan satisfies the requirements of 29 CFR 1910.120. 

 

3. CLEANUP PLAN

This Cleanup Plan describes the procedures and protocols to be implemented for the following 

tasks: 

i) support areas, security 

ii) building and apartment access and assessment; 

iii) photo documentation, and inventories of existing conditions; 

iv) cleaning of common areas, building exteriors, elevator shafts and heating systems; 

v) decontamination areas; 

vi) procedures for interior cleaning; 

vii) procedures for containment and disposal of cleanup wastes. 

The sampling program to be implemented is summarized in Section 4. Specific details of 

sampling activities/protocols/methods performed during the Cleanup are presented in the 

Sampling and Analysis Plan and associated QAPP. All activities performed under the Cleanup 

Plan will be performed in accordance with the health and safety protocols presented in the Health 

and Safety Plan. 
3 

1. Support Facilities: 

 

This project will require office space large enough to support numerous activities including 

public relations, public availability, technical support, communications, data collection and 

presentation, contractor support and EPA management. Portable trailers cannot be used in the 

area due to space constraints, therefore office space in the immediate vicinity of the cleanup will 

be rented for the duration of the study. Security needs will be determined for support areas and 

the study building. 

2. Building Access and Assessment: 

Prior to entering the building, EPA will obtain a signed access agreement with the building 

owner(s) and prior tenant(s). These documents will be prepared by EPA attorneys and signed 

copies will be kept on file. Once access is obtained the entire building and each apartment will 

be inspected for safety concerns including: gas/oil/water leaks, perishable foods, rodent/insect 

infestations, individual or common heating/cooling systems, damaged floors/walls/roofs, 

common areas, stair ways and elevators. All safety concerns will be noted/evaluated and repaired 

(if necessary) prior to beginning the cleanup. 

3. Photo Documentation and Inventories: 

Photo documentation of all building interiors will be conducted and catalogued in an index. The 

building owner and tenant will be requested to accompany EPA during this event. Inventories of 

personnel belongings will be developed and owners will be permitted to remove valuables. 

This documentation is for the benefit of all parties involved. Measurements of the apartment 

and details of the interior decorating (furniture/carpets etc.) will be obtained to develop a floor 

plan of the living space. The floor plan will be utilized to locate and document sample locations 

while the cleanup is progressing. Bulk samples of dust will be obtained (if possible) for 

laboratory analysis and subsequent evaluation. 

 

4. Cleaning of Common Areas: 

EPA will clean building exterior areas (if necessary) prior to beginning interior work. The work 

will be performed by a subcontractor utilizing vacuum trucks equipped with HEPA filtration. 

All foyers, stair ways, hall ways, elevators/shafts, and common heating systems will be 

vacuumed using commercial quality HEPA-filtered vacuums. Cleaning of common areas will 

begin at the building entrance and proceed to the upper level then return down to the entrance. 

Plastic curtains will be installed at the interface of clean and non - clean areas to prevent re - 

deposition of dust due to drafting. If HVAC systems are present, subcontractors specializing in 

cleaning these units may be utilized. All ventilation ducts will be covered with plastic to 

minimize recontamination with dust. Wet washing of walls, and ceilings will be performed if 

dust cannot be removed by vacuuming. The goal of this activity is to provide a dust free area to 

allow level “D” entry through the common spaces and for construction of equipment storage and 

decontamination areas. Decontamination areas be will temporary structures built of wood and 

plastic sheeting to be utilized to don and doff protective equipment when entering or exiting the 

work areas. 
4 

5. Interior Cleaning: 

EPA will evaluate eight cleaning techniques on fifteen (15) rental spaces. Each cleaning 

technique will be tested on two rental units. The eight cleanup techniques will vary through use 

of different vacuuming systems. Sampling of dust before, during, and after the cleanup will be 

performed to evaluate the effectiveness of each cleanup technique and worker exposure. 

General cleaning procedures which will be employed for all units are as follows: Bulk 

accumulations of dust and debris (if present) will be manually removed using shovels and 

commercial quality HEPA-filtered vacuums. All horizontal and vertical surfaces will be 

vacuumed beginning with the ceilings and working down along the walls to the floor. Windows, 

electrical outlets, sills, heating/cooling units will be vacuumed as they are encountered. Filters 

will be replaced on cooling units. After cleaning, A/C units will be sealed with plastic sheeting. 

Central HVAC intake/discharge registers will be covered with plastic. Horizontal and vertical 

solid surfaces including floors, appliances, table tops, cabinets (interior/exterior) as well as flat 

ware, and accent items will be washed with soap and water (if appropriate). Books, files, 

magazine, porous accent items will be vacuumed and stored in boxes then covered with plastic 

bags. Items such as clothes, shoes, drapes/curtains, will be HEPA vacuumed (if necessary) and 

stored in plastic bags for washing/dry-cleaning by the tenant. Carpets and furniture will be dry 

vacuumed until visibly clean. The tenant will be invited to monitor the cleanup if desired. EPA 

will furnish protective equipment to tenant(s) during the cleanup. No items will be discarded 

unless authorized by the tenant. If necessary, work schedules will be modified to accommodate 

the tenant. 

Detailed cleaning procedures and sequencing of work are included as Attachment A. 

Four scenarios have been developed to evaluate eight cleanup techniques. Each scenario 

contains two parts for testing two different cleaning procedures. Each scenario is discussed 

below: 

Scenario 1: 

(Selection Criteria): Accumulation of dust on horizontal surfaces should be limited to a dusting. 

This scenario may represent a typical apartment which was impacted but not totally encompassed 

in dust. 

Test A (Equipment Selection) Cleaning will be conducted in two units using basic residential 

quality upright vacuums and shop vacuums which are available from Hoover®, Eureka®, 

Rigid® and Craftsman®. 

Test B (Equipment Selection) Cleaning will be conducted in two units with basic vacuums as 

used in Test A but with the addition of an air filtration device (AFD). The AFD produces a 

negative pressure differential which will serve to capture dust particles through HEPA filtration 

that become airborne as a result of the cleaning activities. 

 
5 

Scenario 2:

(Selection Criteria) Same or similar to Scenario 1. 

Test A (Equipment Selection) Cleaning will be conducted in two units using HEPA-filtered 

upright vacuums and HEPA-filtered shop vacuums which are available from Hoover®, Eureka®, 

Rigid® and Craftsman® companies. The upright vacuums from Hoover® and Eureka® were 

provided to residents of lower Manhattan, by FEMA and the American Red Cross for cleaning of 

their occupied space. 

Test B (Equipment Selection) Cleaning will be conducted in two units using the same vacuums 

in Test A but with the addition of an AFD. 

Scenario 3: 

(Selection Criteria): Same or similar to Scenario 1. 

Test A (Equipment Selection) Cleaning will be conducted in two units using commercial quality 

HEPA-filtered vacuums. These vacuums will be purchased from Nilfisk-AdvanceTM Vacuum 

Systems. Vacuums of this type were used by management companies for cleaning 

residential/commercial spaces in lower Manhattan after the WTC attack. 

Test B (Equipment Selection) Cleaning will be conducted in two units using the same vacuums 

in Test A but with the addition of a AFD. 

Scenario 4:

(Selection Criteria) Units have a direct exposure to ground zero. Windows were blown out as a 

result of the WTC collapse. Accumulation of dust on horizontal surfaces measures in inches. 

This scenario represents a severely impacted space with heavy accumulations of dust and debris. 

The two commercial spaces (Units 1 and Unit 2) in the building fit this criteria. Both spaces 

have wall to wall carpeting and acoustical ceiling tiles. 

Test A (Equipment Selection) Cleaning will be conducted in both units using NilfiskTM HEPAfiltered vacuums. Debris that cannot be vacuumed will be manually removed and disposed of. 

Due to the excessive amount of dust, a minimum of two AFDs will be used to control airborne 

dust. Cleaning will continue until all visible dust has been removed. 

Test B (Wet Wiping) Additional cleaning of wall surface areas will be conducted to remove any 

dust residues that may not have been removed by vacuuming. Wiping of the walls with a damp 

soapy cloth will be performed to remove residual dust that may have adhered to the walls from 

the force of the collapse. 

Test C (Carpet Shampooing) Wall to wall carpeting in both units will be shampooed or steam 

cleaned using commercial duty equipment. 

Scenarios 1, 2 and 3 will be each be tested on four units. Scenario 4 will be tested on the two 

commercial spaces. Additional evaluation of wet wiping methods will be conducted on the 15th 

 (Dwelling) that has not been proposed for evaluation under the previously proposed scenarios. 
6 

Samples will be collected prior to, during and after cleanup in accordance with the SAP to 

determine the effectiveness of the cleaning. If sample results do not attain cleanup objectives for 

a specific scenario, the unit will be re-cleaned using the same equipment and re-sampled. If after 

a second cleaning the results are unsatisfactory the unit will be cleaned using a method proven 

successful. 

6. Disposal of Waste Generated in Cleanup: 

Dust/debris, used protective equipment, clogged vacuum filters, expendables and items discarded 

by the tenant will be double bagged in 6ml plastic bags and deposited in a roll off container 

placed out side the building. The roll off container will be transported off site when full and 

replaced with another roll-off container. Water used for hand washing and equipment washing 

will be disposed into the sanitary sewer. 

4. PROJECT SAMPLING

EPA will perform comprehensive sampling before, during and after the cleanup to evaluate the 

effectiveness of the work and possible worker exposure. Samples of dust collected by wipe, 

micro vac, and personnel pump sampling techniques will be obtained from porous and nonporous 

surfaces as well as from workers. Prior to the start of work, bulk samples will be collected (if 

possible) from each unit. If bulk samples cannot be collected, samples will be obtained using 

wipe or micro - vac techniques. Samples will be collected from the locations, and analyzed for 

the parameters shown on the tables included as Attachment B. Specific sampling protocols, 

methods as well as sample management, data validation and reporting are detailed in the SAP. 

 

5. REPORT PREPARATION

Upon completion of the study a summary report will be prepared discussing the work performed 

under each scenario. The report will present a synopsis of the work, detailing conditions of the 

units prior to, during and after the cleanup, duration of the cleanup, problems encountered during 

cleanup and sampling, sample locations, laboratory data summary tables, and QA/QC 

documentation. This information will be presented to EPA for evaluation and recommendation. 

 

 
7 

 

Figure 1.0

8 

Attachment A
9 

Residential Confirmation Cleaning Study 

Sequence of Activities and Detailed Cleaning Procedures

1. Obtain Access from Owner(s) & Tenants(s): 

i. Meet with owner/tenants to explain the pilot and goals. 

ii. Arrange for owner/tenants to enter rental space to identify items to be discarded or removed 

 (clothes, rugs, furniture) This entry will be after hallways are cleaned and tenants are provided 

proper PPE. 

 

2. Photo Documentation of Rental Space: 

i. EPA will video and photograph all rental and common spaces before the cleanup begins. 

(drawers, cabinets, and closets will be opened and areas of damage will be noted) 

ii Inventories of all belongings will be logged and entered into an EPA database. 

iii Heating and air conditioning systems will be identified and photographed.. 

iv The interior space will be detailed on a scaled floor plan. Furniture, carpets, beds will be 

 identified, sample locations will be marked. 

3. Exterior Cleaning: 

NYC is responsible for cleaning roof tops and building exteriors that are covered with dust. Dust 

will be removed by vacuum and wetted then brushed into bags. 

4. Cleaning of Common Spaces: 

EPA will initiate the cleanup by vacuuming all common spaces. This includes hallways, utility 

rooms, laundry rooms, compactor rooms, elevators and elevator shafts. Work will begin from the 

entrance to the top floors. Windows and screens will be cleaned first. Vacuuming will begin at 

the ceiling and continue down the walls to the floor. Work will continue to the next floor via 

stair ways. Utility rooms, compactor rooms and laundry rooms, will be vacuumed as encountered 

starting from the ceiling working down to the floor. Appliances will be moved to permit 

complete cleaning. Dryer vents and filters will be replaced or cleaned. When the top hallway is 

completed vacuuming will continue floor by floor to the building entrance following the same 

procedures as during the initial cleaning. Isolation barriers will be installed at the stairwell of 

each floor to minimized recontamination caused by drafting. This barrier will also isolate the 

common spaces for clearance sampling. Following receipt of acceptable clearance sample 

results, the floor of the common spaces (hallway) will be covered with construction paper (red 

rosin), and will be used as storage areas for equipment and supplies, and as passage areas for 

(level D) workers and visitors. 

5. Cleaning of Interior (Residential) Spaces: 

EPA will begin cleaning interior spaces beginning at the entrance door of the rental space. 

Workers will vacuum the foyer areas and construct an isolation barrier to separate this area from 

the rest of the rental space. The contained foyer area will be considered a clean space for 

donning PPE. Exteriors of windows/screens will be cleaned first. Interior areas will be cleaned 

as encountered. Items identified by the tenant(s) for disposal will be consolidated and bagged. 

Personnel belongings (shoes, clothes, linens etc.) will be vacuumed then bagged for 

washing/cleaning by the tenant. Vacuuming will begin at the ceiling and continue down the 
10 

walls to the floor, working toward the far end of the rental space. Window sills, electrical 

outlets, mouldings, baseboard heating elements and horizontal surfaces will be vacuumed as 

encountered. Carpets will be vacuumed 2 times using an agitator bar after removal of gross dust.. 

 Fabric covered furniture will be vacuumed 2 times using a stiff brush attachment after removal 

of gross dust. Fabric window dressings will be vacuumed 2 times. Window air conditioners will 

be vacuumed externally then dismantled to be vacuumed internally. Central HVAC 

intake/discharge registers (if present) will be removed/cleaned to permit interior duct cleaning 

then replaced and covered with plastic. Appliances such as refrigerators and stoves will be 

moved to vacuum dust from floor footprint area. Spoiled food (if present in the refrigerator) will 

be removed at this time. Refrigerator cooling tubes will brushed and vacuumed. Closet and 

dresser interiors will be vacuumed. Upon reaching the far end of the rental space vacuuming will 

continue by reversing the process detailed above. Vacuuming will continue to the entrance area. 

At this time horizontal surfaces will be wet wiped, solid floors will be moped, flatware and solid 

objects, will be washed. Flatware, solid objects (electrical equipment, exercise equipment, etc. ) 

will be packaged in boxes and/or covered with plastic. Work will continue to the isolation barrier 

where all cleaning equipment will be vacuumed and/or washed for use on the next rental space.. 

 

6. Cleaning of Interior (Commercial) Spaces: 

Two commercial spaces are present in the building, both are grossly contaminated with inches of 

dust and debris. Both spaces are carpeted and have central air conditioning systems with the 

exchanger located above tiled ceilings. Entrance to the spaces is via a hallway from Cedar Street 

and a stairwell from Liberty Street. The heavy accumulation of dust in these spaces requires 

special considerations. The units will be isolated from both entrance ways by plastic barriers. 

Vacuum motors and canisters will operate from outside the isolation area. Vacuuming will be 

accomplished by snaking hoses into the contaminated areas. This procedure will minimize 

entraining dust into the air. Due to the accumulation of dust, negative air machines will be 

utilized to manage air born dust. The front windows are presently covered with plywood. 

Plywood will be removed and window openings will be vacuumed to remove dust and residual 

debris. Upon completion, plywood and plastic will be installed until the building owner installs 

permanent windows. Following complete removal of accumulated dust, vacuums will be 

brought into the space and cleaning will proceed as detailed in the procedures for residential 

space. 

7. Specialized Cleaning Procedures 

a. Window Mounted Air Conditioners. 

Vacuum exterior surfaces, remove from wall mount and relocate to isolated cleaning area. Cover 

A/C mount with plastic. Discard filters and open unit to expose interior mechanism. Vacuum 

cooling fins and interior surfaces. Replace filter, install in mount and cover interior vents with 

plastic. 

b. Roof Mounted A/C 

Units cannot be removed; therefore, cleaning will be performed with the unit in place. Remove 

and replace filters, vacuum interior, inspect exterior exchanger, replace all cleaned parts and 

cover interior vents with plastic. 
11 

c. Refrigerators 

Inspect refrigerator, remove and dispose of spoiled food. Move appliance to isolated cleaning 

area, elevate and clean dust from cooling coils using vacuums and specialized brushes. Clean 

floor area where appliance was located. 

d. Stoves 

Move appliance from location, clean floor area. Vacuum storage drawer (if present) and open 

top of stove to vacuum. Remove exhaust fan light and filters, replace with new. Vacuum first 

foot of exhaust duct if present. 

e. Dishwashers 

Remove toe plate and vacuum dust from under appliance. 

f. Bathroom Fans 

Remove protective cover and wet wipe, remove fan/motor and vacuum. Vacuum first foot of 

exhaust duct. 

g. Hydronic Finned Radiation 

Remove protective covers to expose heat elements. Finns are to be vacuumed and brushed to 

remove dust. 

h. Electronic Equipment 

Equipment is to be moved to the isolated cleaning area where dust will be removed by blowing 

air into the cooling slats while vacuuming. 

i. Non-perishable canned and bottled goods 

These items are to be wet wiped and stored in boxes covered with plastic for the tenant. 

j Carpets 

Carpets will be vacuumed twice or until visibly clean. Carpets in the commercial space will be 

shampooed after vacuuming. 
12 

Attachment B
Changes to the Work Plan
1

Changes to the Work Plan

1. WET WIPING

1.1 Wet Wipe Using Windex / Wet Wipe Using Water Only

The work plan initially called for use of soap and water to accomplish wet wiping. Windex

brand was used because it is a commonly used cleaner believed to be readily available in most 

people’s homes. Further, it is non-damaging to most surfaces, from wood to fiberglass. 

Typically, this soap does not “over-suds.” It provides an effective detergent-based protection of 

surfaces when combined with cold water. This was important, because hot water was not 

immediately available at the project site. During the project, EPA opted to also evaluate 

application of wet wipe using water only. Water only was used on the desktop in the 

Chiropractor’s Office, in the bathroom of the Chiropractor’s Office, and in the entire Barber 

Shop. Water only was also used on the vinyl tiles under the carpeted area in the Mattress Store. 

1.2 Horizontal Wet Wipe Only / Horizontal and Vertical Wet Wipe 

The majority of tests of cleaning methods were accomplished using horizontal wet wipe only, to 

assist in determination of whether vacuuming without wet wiping would result in acceptable 

cleaning. However, application of both horizontal and vertical wet wipe was tested in Units 3B 

and 3C. 

Application of both horizontal and vertical wet wiping in Unit 3B was consistent with the 

procedures called for relative to testing of Scope A, Lower Manhattan Cleaning Procedures. 

(Attachment F). 

Unit 3C was selected for additional tests of the use of both horizontal and vertical wet wiping. 

The unit was selected for the following reasons: 

• The apartment was heavily impacted by WTC dust

• The apartment was fully furnished and contained many personal belongings, and 

• he test of vacuuming method called for use of equipment without HEPA filter or AFD. 

Additionally, the resident had expressed the intention to return.

1.3 Use of Swiffer Brand Cloths

EPA opted to evaluate use of Swiffer brand cloths for application of wet wipe. Swiffer brand 

cloths were utilized during the cleaning of residential unit 5D. 

2. SCOPE A- LOWER MANHATTAN CLEANING PROCEDURES

See Attachment F. 
Attachment C 

Site Map 

Attachment D 

Floor Plans 






Attachment E 

Health and Safety Plan, Changes and Issues 
 Changes to the Health and Safety Plan
1 

1. Changes to the Health and Safety Plan 

As a result of changing conditions and new information gained in the field through analytical 

activities, changes were made to the Health and Safety Plan. The changes related to lead 

sampling, levels of protection, and use of personal protective equipment. A memorandum 

concerning detection of cristobalite interference in laboratory results was also incorporated. 

(See Attachment E).

1.1 Lead Sampling

Air sampling to characterize for exposure of personnel to lead was discontinued on July 24, 

2002, because lead in air concentrations consistently presented below the OSHA Action Limit of 

30 ug/m3. (29CFR 1926.62). 

1.2 Level of Protection

Levels of personal protective equipment (PPE) were changed to reflect exposure measurements. 

An addendum to the Health and Safety Plan was prepared to address this on September 17, 2002. 

The table below presents the PPE assignments by task, pursuant to original and the amended 

Health and Safety Plan. 

1.3 Personal Protective Equipment (PPE) By Task

Location Task Original 

PPE 

Revised 

PPE 

Exclusion 

Zone 

1. Surveying and prep of previously cleaned areas 

2. Surveying and prep of areas not previously cleaned 

3. Vacuuming with non-HEPA-filtered equipment 

4. Vacuuming with HEPA-filtered equipment in 

previously cleaned areas 

5. Wet wiping following non-HEPA vacuuming 

6. Wet wiping following HEPA vacuuming 

7. Cleaning equipment using air and vacuum 

8. Removing/ changing vacuum bags and filters 

9. Re-cleaning units w/HEPA vacuuming and 

supporting personal air sampling results 

10. Re-cleaning units w/ non-HEPA vacuuming 

11. Re-cleaning units w/HEPA vacuuming without 

supporting personal air sampling results 

Level C- 1⁄2 face 

Level C PAPR 

Level C PAPR 

Level C- 1⁄2 face 

Level C- 1⁄2 face 

Level D+ 

Level C PAPR 

Level C PAPR 

New Task 

New Task 

New Task 

Level C- 1⁄2 face 

Level C PAPR 

Level C PAPR 

Level C- 1⁄2 face 

Level C- 1⁄2 face 

Level D+ 

Level C PAPR 

Level C PAPR 

Level D+ 

Level C- 1⁄2 face 

Level C- 1⁄2 face 

1.4 Use of Goggles

Goggles were assigned for Levels D and D+ because of concerns that irritation of employee’s 

eyes might result from airborne fiberglass. Once it was determined that eye irritation was not 

occurring, safety glasses were substituted. 
 

 Health and Safety Issues
1

1. Health and Safety Issues

1.1 Electrical Concerns 

All areas of the building were inspected to ensure that no electrical concerns posed a threat to the

safety of employees. In the Food Exchange, live, loose hanging electrical wires were found. 

Electricity at the panel box was shut off and the wires in question were taped. 

1.2 Building Repairs

A damaged hand rail in the Liberty Street stairwell was reinstalled to ensure the safety of

personnel. All other repairs made prior to commencement of the work related to building access.

1.3 Building Access

The only access concern related to broken windows in the Chiropractor’s Office. In order to

prevent unauthorized access, which could potentially pose risks to both public health and to

equipment used in the study, plywood panels were installed over the broken windows. 

1.4 Rodent Infestation

In the process of inspecting to identify safety concerns, evidence of rodent infestation was

discovered (droppings). The building owner was advised of the problem and contacted an

exterminator. 

1.5 Personal Monitoring

Every morning, the Site Health and Safety Officer calibrated the personal pumps. The initial

flow, pump start time, pump serial number, date, location of pump, and sample number were

recorded. Personal pumps are typically worn by employees to collect air samples that are

representative of what the employees are experiencing while working. Given the space

constraints of the work areas and the number of parameters to be measured, the majority of

exposure measurements were made using area samples. 

Pumps for the three parameters were mounted on five-foot tripod stands, in lieu of being worn by

the employees. The Site Health and Safety officer collected media blanks at a rate of 10% of

samples. At the end of the day, the stand was disassembled and the final flow rate and finish

time were recorded. The total volume was calculated and the samples were packaged and

forwarded to EPA’s contracted laboratory. The laboratory is accredited for analysis of lead and

silica by the American Industrial Hygiene Association and by the NVLAP for asbestos. The air

samples were analyzed by the laboratory for asbestos, using one or both of the following

procedures: PCM /TEM. 

Sampling for airborne lead ceased on July 24, 2002, after consistent results of non-detectable
2

concentrations. Sampling for asbestos and silica continued throughout the project to the extent

commensurate with the task and crew size. 

1.6 Work Zones

Upon commencement of the study, the building condition was assessed for the purpose of

establishing work zones. Determination of work zones was made with consideration of

boundaries that would maximize work productivity while facilitating pre and post sampling

efforts. The demarcation of zones was accomplished to ensure the health and welfare of 

personnel and third parties. The Site Health and Safety Officer supervised the demarcation of

zones. Space at the site was extremely limited, forcing continuous re-designation of the support

zone, contamination reduction zone and the personnel decontamination area throughout the

project. At any given time, the exclusion zone consisted of the area or areas then being cleaned;

the contamination reduction zone and the personnel decontamination zone changed accordingly.

Typically, because the walls of the apartment units offered inherent boundaries, the room or area

configuration served as the delineation.

The Support Zone

As noted previously, space constraints at the site presented difficulty, resulting in ongoing redesignation of work zones. The purpose of the support zone is to provide an area for support and

communications to operations personnel. Initially, the support zone was designated as an area

outside of the building, adjacent to the entrance vestibule on Cedar Street, while office functions

were accomplished from a hotel several blocks away. The site Health and Safety Officer

conducted daily safety meetings in the outdoor area to establish project procedures and controls,

and to communicate changes. After being cleaned, the entrance vestibule was designated as part

of the support zone. A third support zone was located on the second floor after it had been

cleaned. This support zone occupied the north end of the enclosed hallway area between the

Chiropractor’s Office and the Mattress Store, and extended into apartment 2B, where an on-site

office was established. (This unit was cleaned and sampled prior to use.) The outdoor area, the

vestibule and the second floor area were all utilized as support zones until completion of the

project. 

The Exclusion Zone and The Contamination Reduction Zone

The exclusion zone was identified as the areas of the building then requiring cleaning. These areas

were designated with a unit number or a common area reference. All personnel, tools, and small

equipment passed into and out of the exclusion zone through the contamination reduction zone. The

purpose of the contamination reduction zone is to provide a defined area for reduction of any

contamination potentially sustained in the exclusion zone. The contamination reduction zone was

relocated appropriately as the exclusion zone focal area changed. 

The contamination reduction zone was initially established in the stairway landing area, near the

elevator, adjacent to the vestibule on the first floor. Personnel suited with personal protective

equipment in the vestibule. They unsuited in the area at the bottom of stairs, before re-entering

the vestibule. As the job progressed, the contamination reduction zone was located adjacent to

the areas being cleaned. 
3

The Personnel Decontamination Area 

The personnel decontamination area was located directly inside the contamination reduction

zone. In this area, personnel disrobed of personal protective wear that was subsequently bagged

and disposed. The personnel decontamination area was supplemented with other safety

precautions such as: a portable eye wash station, a first aid kit and fire extinguishers placed at

various locations through out the building. 
-001 WRS Infrastructure and Environment, Inc. i

WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

SITE-SPECIFIC HEALTH AND SAFETY PLAN

USEPA REGION II 

Emergency Response and Rapid Response Service 

WTC Pilot Cleaning Evaluation 

110 Liberty Street 

New York, NY 

Submitted to:

USEPA REGION II

Prepared by: 

WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

925 Canal Street, Suite 3701 

Bristol, PA 19007 

WRS Project Number: 501060 

Document No. 501060-001 
-001 WRS Infrastructure and Environment, Inc. 2

WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

SITE-SPECIFIC HEALTH AND SAFETY PLAN

USEPA REGION II 

Emergency Response and Rapid Response Service 

WTC Pilot Cleaning Evaluation 

New York, NY 

Submitted to:

USEPA REGION II

Prepared by: 

WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

925 Canal Street, Suite 3701 

Bristol, PA 19007 

WRS Project Number: 

Prepared by: 

 

Date: 

 Doug Nelson CIH, CHMM 

WRS Corporate Health and Safety Manager 

 

Reviewed by: 

 

Date: 

 Scott Wilhelm 

WRS Response Manager 

 

Reviewed by: 

 

Date: 

 Dan Harkay 

EPA On Scene Coordinator 
-001 WRS Infrastructure and Environment, Inc. 3

1.0 INTRODUCTION ................................................................................................ 6

1.1 PURPOSE, SCOPE AND APPLICABILITY OF THE SITE SPECIFIC HEALTH AND SAFETY PLAN .....6 

1.2 REVISIONS TO THE PLAN .................................................................................................................6 

2.0 KEY PERSONNEL AND RESPONSIBILITIES ....................................................... 7

2.1 KEY PERSONNEL ..............................................................................................................................7

2.2 RESPONSIBILITIES............................................................................................................................7 

2.2.1 RESPONSE MANAGER........................................................................................................................7 

2.2.2 SITE SAFETY AND HEALTH OFFICER (SSHO) ...................................................................................7 

2.2.3 WRS HEALTH AND SAFETY MANAGER (HSM)................................................................................8 

2.2.4 FOREMAN, OPERATORS, AND TECHNICIANS .....................................................................................8 

3.0 SITE AND PROJECT DESCRIPTION ................................................................... 9

3.1 SITE DESCRIPTION ...........................................................................................................................9 

3.2 PROJECT DESCRIPTION ...................................................................................................................9 

4.0 HAZARD ANALYSIS......................................................................................... 10

4.1 GENERAL HAZARD ANALYSIS .......................................................................................................10 

4.1.1 PHYSICAL HAZARDS........................................................................................................................11 

4.1.2 CHEMICAL HAZARDS.......................................................................................................................12 

5.0 PERSONNEL TRAIING REUIREMENTS ............................................................ 13

5.1 GENERAL ........................................................................................................................................13 

5.2 PRE-ASSIGNMENT AND ANNUAL REFRESHER TRAINING............................................................13 

5.3 PROJECT SUPERVISORS TRAINING ...............................................................................................13 

5.4 HEALTH AND SAFETY PLAN REVIEW............................................................................................13 

5.5 DAILY SAFETY MEETINGS.............................................................................................................13 

5.6 ASBESTOS TRAINING......................................................................................................................14 

5.7 LEAD TRAINING..............................................................................................................................14 

6.0 PERSONAL PROTECTIVE EQUIPMENT ............................................................ 14

6.1 SPECIFIC LEVELS OF PROTECTION PLANNED FOR THE PROJECT..............................................14 
-001 WRS Infrastructure and Environment, Inc. 4

6.2 ENSEMBLE COMPONENTS..............................................................................................................15 

6.3 APPLICATION..................................................................................................................................15 

6.4 INSPECTION ....................................................................................................................................16 

6.5 RESPIRATOR CARTRIDGE CHANGE-OUT SCHEDULE...................................................................16 

7.0 MEDICAL SURVILLANCE REQUIREMENTS ...................................................... 16

7.1 GENERAL ........................................................................................................................................16 

7.2 SITE SPECIFIC MEDICAL MONITORING........................................................................................16 

7.3 SUBSTANCE ABUSE PREVENTION..................................................................................................16 

7.4 ASBESTOS........................................................................................................................................17 

7.5 LEAD ...............................................................................................................................................17 

8.0 AIR SURVEILLANCE........................................................................................ 17

8.1 MONITORING..................................................................................................................................17 

8.2 ACTION LIMITS ..............................................................................................................................17 

8.3 AIR SAMPLING................................................................................................................................17 

9.0 SITE CONTROL MEASURES ............................................................................. 19

9.1 CONTROL ZONES............................................................................................................................19 

9.2 SITE COMMUNICATIONS PLAN......................................................................................................19 

9.3 SANITATION FACILITIES................................................................................................................19 

10.0 DECONTAMINATION PLAN............................................................................. 21

10.1 LEVELS OF DECONTAMINATION PROTECTION REQUIRED FOR ASSISTING PERSONNEL.......21 

10.2 EQUIPMENT DECONTAMINATION................................................................................................21 

10.3 PERSONNEL DECONTAMINATION................................................................................................21 

10.3.1 PROCEDURE....................................................................................................................................21 

10.3.2 EQUIPMENT ....................................................................................................................................21 

10.4 DISPOSITION OF DECONTAMINATION WASTES..........................................................................21 

11.0 EMERGENCY RESPONSE PLAN...................................................................... 22

11.1 PRE-EMERGENCY PLANNING ......................................................................................................22 

11.2 PERSONNEL ROLES AND LINES OF AUTHORITY.........................................................................22 

11.3 EMERGENCY RECOGNITION/PREVENTION.................................................................................22 

11.4 EMERGENCY EQUIPMENT/FACILITIES .......................................................................................23 

11.5 FIRE OR EXPLOSION.....................................................................................................................23 

11.6 SPILL OR LEAKS ...........................................................................................................................23 
-001 WRS Infrastructure and Environment, Inc. 5

APPENDICES 

APPENDIX A HEALTH AND SAFETY FORMS 

APPENDIX B HEAT STRESS 

APPENDIX C WRS LOCKOUT/ TAGOUT SOP 

APPENDIX D WRS FALL PROTECTION SOP 
-001 WRS Infrastructure and Environment, Inc. 6

1.0 INTRODUCTION 

1.1 Purpose, Scope and Applicability of the Site Specific Health and Safety Plan 

Purpose of this site specific Health and Safety Plan (HASP) is to identify anticipated hazards and 

the control measures to be implemented at the WTC Pilot Cleaning Evaluation in New York 

City, hereafter known as the Site. The procedures presented in this HASP are based on the best 

available information at the time of the plan's preparation, and are intended only for the activities 

described in this plan. 

The Plan applies to all WRS Infrastructure & Environment, Inc. (WRS) employees, and 

subcontractor employees. All personnel prior to entering the exclusion zone or contamination 

reduction zone (decontamination zone) must review and sign this plan. All personnel on site 

shall be informed of the site emergency response procedures and any potential fire, explosion, 

health, or safety hazards of the project tasks/operations. This HASP summarizes those hazards in 

Section 4.0 and defines hazard control measures planned for the site. 

All visitors entering the contamination reduction zone and exclusion zone at the site will be 

required to read and verify compliance with the provisions of this HASP. In addition, visitors 

will be expected to comply with relevant OSHA requirements. Visitors will be expected to 

provide their own personal protective equipment unless the USEPA specifies otherwise. In the 

event that a visitor does not adhere to the provisions of this HASP, he/she will be requested to 

leave the work area. 

The requirements and protocols cited in this plan were developed in consideration of current 

safety standards as defined by EPA/OSHA/NIOSH, health effects and standards for known 

contaminants, and procedures designed to account for the potential for exposure to unknown 

substances. Specifically, the following reference sources were consulted in developing this plan: 

• OSHA General Industry and Construction Standards. 

• EPA Standard Operating Safety Guides. 

• NIOSH/OSHA/USCG/EPA Occupational Health and Safety Guidelines. 

• NIOSH Pocket Guide to Chemical Hazards. 

• EPA Draft Work Plan 

• EPA Provided Sample Analytical Data 

1.2 Revisions to the Plan 

Revisions to this plan may be made in response to changes or unexpected conditions not 

described in this Plan. All revisions to this plan shall be documented on a Field Procedures 

Change Authorization form (Appendix A), approved by the WRS H&S Manager. 
-001 WRS Infrastructure and Environment, Inc. 7

2.0 KEY PERSONNEL AND RESPONSIBILITIES 

2.1 Key Personnel 

The following personnel have principal responsibility for the implementation , maintenance and 

oversight of health and safety measures during site activities. 

Job Function Name Phone Alternate Phone 

WRS Response Mgr. Scott Wilhelm 610-220-8481 

WRS Program Mgr. Brad Cunningham 

PE 

267-540-0048 215-796-0337 

WRS H&S Mgr. Doug Nelson 

CIH, CHMM 

770-469-6522 678-296-1267 

2.2 Responsibilities 

2.2.1 Response Manager 

The Response Manager is responsible for health and safety "performance" in the field. The Site 

Response Manager can temporarily halt work at any time if, in his/her opinion, it is necessary to 

protect the health and well being of site workers or the general public. Specific responsibilities 

of the Response Manager include: 

• Directing site activities in accordance with the HASP. 

• Being aware of and complying with all applicable federal, state, and local occupational 

health and safety regulatory requirements. 

• Ensuring that resources called for in the HASP and Work Plan/Operations Plan are on 

site and operational. 

• Verifying that all permits, supporting documentation and clearances for a given task 

(e.g., utility surveys, health and safety plan, confined space entry permits) are in place. 

• Informing the appropriate site management and safety personnel of the activities to be 

performed each day. 

• Providing technical advice during routine operations and emergencies. 

• Handling field emergency response situations that may arise. 

• Correcting unsafe acts and conditions. 

• Participating in pre-job and daily safety meetings. 

2.2.2 Site Safety and Health Officer (SSHO) 

The Site Safety and Health Officer (SSHO) has responsibility for ensuring that provisions of 

each HASP are implemented in the field by all WRS employees and subcontractor employees. 

The SSHO must be trained to implement the requirements in the site specific HASP, including 

the correct use of monitoring instruments, health and safety criteria for the site, documentation of 

monitoring results, and actions to take if site conditions change. 
-001 WRS Infrastructure and Environment, Inc. 8

The designated SSHO shall continuously evaluate the adequacy of prescribed health and safety 

procedures and levels of protection against the actual conditions encountered in the field. If an 

obvious discrepancy exists between the realized hazard(s) and the level of personal protective 

equipment (either too much or too little), the SSHO shall immediately bring the situation to the 

attention of the WRS Health and Safety Manager (HSM). With the concurrence of the HSM and 

the Response Manager, the SSHO shall take appropriate corrective action. The SSHO has final 

on-site authority for all matters specifically related to worker health and safety, and emergency 

situations that require immediate action, including the authority to temporarily cease operations. 

Additional responsibilities of the SSHO include: 

• Monitoring site activities for unsafe acts and conditions and initiating their correction. 

• Monitoring project and site activities for conformance to the site specific HASP. 

• Overseeing confined space entries and ensuring that all confined space entries are done in 

accordance with the requirements found in the WRSIE standard operating procedures 

(SOP’s) for confined space entry. 

• Performing on-site air monitoring and personal sampling as specified in the site specific 

HASP. 

• Calibration of instruments. 

• Maintenance of health and safety equipment and supplies. 

• Ensuring that all work-related injuries and illnesses are properly treated and investigated. 

• Conducting safety briefings and daily safety meetings. 

• Maintaining documentation in support of the HASP. 

• Participating in a pre-job safety briefing with project personnel to discuss anticipated hazards 

and their control measures. 

2.2.3 WRS Health and Safety Manager (HSM) 

The WRS Health and Safety Manager (HSM) shall be responsible for implementing an 

effective hazardous waste operations health and safety program. The HSM shall have the 

requisite authority to implement the procedures set forth in the WRS Health and Safety Manual 

for Hazardous Waste Site Activities, including the authority to temporarily halt work on a project 

if necessary, to protect employees' safety or health. The HSM may delegate certain duties to the 

SSHO or to other WRS personnel, but shall be ultimately responsible for the following: 

• Overseeing the employee medical surveillance program and interacting with examining 

physicians as required 

• Investigating site histories, performing site characterizations, and assessing site/task 

specific hazards. 

• Developing or assessing task specific monitoring procedures, action levels, levels of 

personal protective equipment (PPE), and health and safety requirements for the site and 

the HASP. 

• Performing periodic site inspections/audits. 

• Following to resolution all deficiencies noted during site inspections. and, 

• Resolve "level of care" conflicts that may arise during conduct of the project. 

2.2.4 Foreman, Operators, and Technicians 

All site personnel share responsibilities for health and safety. Specific duties include: 
-001 WRS Infrastructure and Environment, Inc. 9

• Conducting work in accordance with the HASP. 

• Participating in daily safety meetings/planning. 

• Prompt reporting of all incidents and potential health and safety-related problems. 

3.0 SITE AND PROJECT DESCRIPTION 

3.1 Site Description 

The Site is located at 110 Liberty Street. It is five stories with 12 residential and six commercial 

spaces. It has been unoccupied since 9/11/01. The building was severely impacted in the WTC 

collapse. Dust and debris were deposited in the building, windows were blown out, as well as 

skylights. Residential spaces, the basement and the roof of the building were professionally 

cleaned shortly after the collapse. Two of the commercial spaces have “inches” of dust and all 

residential spaces have experienced varying degrees of dust re-deposition. 

Rental spaces range in size from 1,000 to 1,300 square feet. They are open in design and consist 

of a kitchen, bathroom and sleeping area. Each space is heated by an individual hot water 

baseboard system. Window or roof mounted air conditioners are present in the residential space, 

central air systems are present in commercial spaces Unit 1 and 2. Rental spaces are accessible 

through from Liberty and Cedar Streets through common hallways. Floors are accessible via an 

elevator and stairs. Each floor has a trash compactor room and utility room. A laundry room is 

located on the 2nd floor. The basement contains the building trash compactor, elevator well, 

electric motor rooms, preparation and storage areas or the Chinese restaurant and a hair salon. 

3.2 Project Description 

The project’s objective includes evaluating the effectiveness of various cleaning procedures that 

may have been used in the residential spaces. The study will include 12 residential spaces and 3 

commercial spaces. The two restaurants ad hair salon are not a part of the study, but will be 

cleaned at the completion of the study. Eight cleaning techniques will be evaluated: 

1. Vacuuming with non-HEPA vacuums 

2. Vacuuming with non-HEPA vacuums with Negative Air Machines (NAM) 

3. Vacuuming with non-commercial HEPA vacuums 

4. Vacuuming with non-commercial HEPA vacuums with NAM 

5. Vacuuming with commercial HEPA vacuums 

6. Vacuuming with commercial HEPA vacuums with NAM 

7. Vacuuming heavy dust laden areas with commercial HEPA vacuums and 2 NAMs 

8. Vacuuming heavy dust laden areas with commercial HEPA vacuums and 2 NAMs with 

vertical surface wet wiping and carpet shampooing. 

Each cleaning technique will be evaluated on two rental units. 

Activities will include the following: 

• Mobilization to site 
-001 WRS Infrastructure and Environment, Inc. 10

• Establishing Support Area and Facilities 

• Assist with photo documentation and resident visits 

• Isolate study areas from common areas (plastic sheeting and adhesive tape) 

• Clean common areas (HEPA vacuum and wet wipe horizontal surfaces) 

Hallways, 

Building entry ways, 

Laundry rooms, 

Stairs and wells, 

Elevator well, roof mechanical room, interior and lobby, 

Trash compactor and utility rooms (5), and 

Basement 

• Clean previously cleaned areas using the techniques to be evaluated 

• Clean areas not previously cleaned using the techniques to be evaluated 

• Clean non-study areas 

• Dispose of wastes 

• Decontaminate cleaning equipment 

• Demobilization 

4.0 HAZARD ANALYSIS 

The evaluation of hazards is based upon the knowledge of project background information 

presented in Section 3, and anticipated risks posed by the specific tasks/operations to be 

performed. Section 4 presents a general description of project hazards. Section 4.2 describes the 

specific hazards associated with each task/activity, and identifies the hazard control measures to 

be implemented during completion of these tasks. 

4.1 General Hazard Analysis 

Potential/ Anticipated Hazards 

CHEMICAL YES SLIPS, TRIPS, & FALLS SAME 

LEVEL 

YES 

ASBESTOS YES SLIPS, TRIPS, & FALLS 

DIFFERENT LEVEL 

YES 

FIRE/ EXPLOSION NO HEAVY EQUIPMENT/ 

VEHICULAR TRAFFIC 

YES 

HEAT STRESS YES OVERHEAD HAZARDS YES 

MACHINERY/ 

MECHANICAL EQUIPMENT 

YES ELECTRICAL/ UTILITY 

HAZARDS 

YES 

NOISE YES CONFINED SPACE NO 
-001 WRS Infrastructure and Environment, Inc. 11

4.1.1 Physical Hazards 

Noise – vacuums produce noise exposures in excess of the permissible exposure limit (90dBA). 

Operators of these pieces of equipment must wear hearing protection (plugs). Others working in 

the same room/ area must wear hearing protection as well. 

Ambient temperatures - capable of producing either heat are expected to impact the projec. The 

WRS SOP for Heat Stress Management is included as an Appendix B. 

Motor vehicles – obey local traffic laws, use qualified drivers in insured vehicles. Seatbelt use is 

mandatory. 

Flame, Heat or Spark Producing Operations - The use of flame, heat or spark producing 

equipment (e.g., cutting or welding torches and abrasive saws) is prohibited. 

High or Elevated Work - All work near an unprotected side or edge (no handrail) which would 

allow a fall to a lower level of six feet or more will be performed using fall protection (e.g., body 

harness and lifeline). Fall protection equipment will provide continuous protection. Workers in 

aerial lift baskets will utilize full body harnesses with lanyards attached to the man basket. See 

the WRS Standard Operating Procedure for Fall Protection (Appendix D) 

. 

Electrical Safety - Ground fault protection devices (GFCI) will be provided for all electric power 

tools and extension cords. Vacuums directly (no extension cord) plugged into the building’s 

outlets are exempt from this requirement when the outlet has been tested and verified to provide 

adequate grounding. Voltage detectors may be used to facilitate electrical safety. The WRS 

Lockout/ Tagout SOP (Appendix C) will be applied specifically to cleaning the elevator, and 

generally to activities specified in the SOP 

Eye Protection - Eye protection is mandatory in all areas of the project site at all times. Eye 

protection will conform to ANSI Standard Z87. 

Head Protection – Hardhats will be worn when overhead hazards exist and when the hazard of 

an employee bumping his head on an overhead object exists. 

Floor Holes – cover floor holes in the building. 
-001 WRS Infrastructure and Environment, Inc. 12

4.1.2 Chemical Hazards 

SUBSTANCE EXPOSURE 

LIMIT 

(PEL)

IDLH 

LEVEL

HEALTH EFFECTS ROUTE OF 

ENTRY

FIRST AID By 

Route of Exposure

Polycyclic 

Aromatic 

Hydrocrbons 

(PAHs) 

0.2 mg/m3 80 

mg/m3 

Dermatitis, bronchitis, 

potential occupational 

carcinogen 

Inhalation, 

Contact 

Eye: irrigate 

immediately, Skin: 

soap wash 

promptly 

Lead 0.050 mg/m3 100 

mg/m3 

Weak, insomnia, 

gingival lead line, 

abdominal pain, 

irritated eyes 

Inhalation 

Ingestion 

Eye: irrigate 

immediately, Skin: 

soap wash 

promptly 

Crystalline 

silica 

Respirable 

10 mg/m3 ⁄ % 

SiO2 +2 

50 

mg/m3 

Cough, pain with 

breathing, wheezing, 

decreased pulmonary 

function, silicosis, 

cancer of lung 

Inhalation Eye: irrigate 

immed. 

Breath: fresh air 

Asbestos 0.1 fiber/ cc NA Asbestosis, pain with 

breathing, restricted 

pulmonary function, 

finger clubbing, lung 

cancer 

Inhalation 

Ingestion 

Contact 

Eye: irrigate 

immed. 

Breath: fresh air 

SUBSTANCE EXPOSURE 

LIMIT 

(PEL)

IDLH 

LEVEL

HEALTH EFFECTS ROUTE OF 

ENTRY

FIRST AID By 

Route of Exposure

Dioxin (1,1,2,2-

Tetrachlorodebenzo-pdioxin) 

None None Eye irritation, allergic 

dermatitis, chloracne, 

digestive disturbances, 

possible reproductive 

effects, in animals 

produces liver/ kidney 

damage, cancer 

Inhalation 

Ingestion 

Contact 

Eye: irrigate 

immed. 

Skin wash with 

soap/ water 

Breath: fresh air 

Swallow: med 

attention 

Man Made 

Vitreous 

Fibers (aka 

fiberglass and 

glass wool) 

15 mg/m3 

(total) 

5 mg/m3 

(respirable) 

None Irritation of eyes skin 

nose, throat, pain with 

breathing 

Inhalation 

Contact 

Eye: irrigate 

immed. 

Breath: fresh air 

Gypsum 

(calcium (II) 

sulfate 

dihydrate) 

15 mg/m3 

(total) 

5 mg/m3 

(respirable) 

None Irritation of eyes, skin, 

mucous membranes, 

upper respiratory 

system, coughing, 

sneezing, runny nose 

Inhalation 

Contact 

Eye: irrigate 

immed. 

Breath fresh air 
-001 WRS Infrastructure and Environment, Inc. 13

Concentrations of these materials in bulk samples collected to date include: 

• Asbestos <1% (reported as chrysotile) 

• Lead up to 300 ppm 

• MMVF up to 40% 

• Dioxin up to 0.088 ppb 

• PAHs up to 340 ppm 

• Crystalline silica (quartz) up to 10% 

• Gypsum up to 14% 

5.0 PERSONNEL TRAINING REUIREMENTS 

5.1 General 

All project personnel are trained in accordance with OSHA's 29 CFR 1910.120 Hazardous Waste 

Operations and Emergency Response Standard. At a minimum, all personnel are required to be 

trained to recognize the hazards on-project, the provisions of this HASP, and the personnel 

responsible for safety on the project.

5.2 Pre-Assignment and Annual Refresher Training 

Non required other than and orientation to the site including a walkthrough. All employees 

should have their current 8-hr annual refresher training and be medically qualified to wear a 

respirator. 

5.3 Project Supervisors Training 

Consistent with OSHA 29 CFR 1910.120 paragraph (e)(4), individuals designated as Project 

Supervisors receive an additional 8 hours of training in addition to the 40 hr certification. 

5.4 Health and Safety Plan Review 

Prior to working on the project, each person will review the HASP and will have the opportunity 

to ask questions of the Project Health and Safety Officer about the plan's contents. After 

reviewing the HASP, WRS employees and subcontractor employees will sign the HASP Review 

Sign-Off (Safety Briefing form) located in Appendix A. 

5.5 Daily Safety Meetings 

Project safety meetings will be conducted daily. The meeting will cover: 

• The work to be completed. 

• Hazards associated with the work. and, 

• Hazard control measures to be implemented. 

WRS subcontractor employees and their supervisor(s) are required to attend. 
-001 WRS Infrastructure and Environment, Inc. 14

5.6 Asbestos Training 

The clean up of the dust in this building is an unclassified task because the material does not 

contain enough asbestos (<1%) to be considered Asbestos Containing Material (ACM). 

Therefore the training requirements at 29 CFR 1926.1101(k)(9)(viii) apply. There is no 

minimum or maximum time allotted for completion of this training only a list of subjects to be 

covered. Employees performing dust removal activities will have training that meets or exceeds 

these requirements. 

5.7 Lead Training 

Lead is present in the dusts to be removed. Lead training is required at 29 CFR 1926.62 (l) when 

employee exposures exceed the Action Limit of 30 ug/m3. Because the dust removal methods 

are designed to minimize the aerosolization of the dust, and the low concentrations (< 300 ppm), 

it is not anticipated that Action Limit will be reached and lead training will therefore not be 

necessary. An exposure assessment will be used to verify this assumption. 

6.0 PERSONAL PROTECTIVE EQUIPMENT 

This section describes the specific levels of protection required for each task to be conducted at 

the project. The general requirements of the EPA designated Levels of Protection (A-D) are 

described in the WRS Health and Safety Program Manual. The level of protection to be worn by 

field personnel will be monitored by the IHSO. 

6.1 Specific Levels of Protection Planned for the Project 

PPE assignments are task specific. Table 6.1 on the following page lists task specific PPE levels. 

These levels are disqualified for use if air surveillance indicates that the upper action limit for the 

level of protection being used is exceeded. 

TABLE 6.1: LEVELS OF PROTECTION

Location Job Function/Task PPE

 

Exclusion Zone • Surveying and prep of previously cleaned 

areas 

• Surveying and prep of areas not 

previously cleaned 

• Vacuuming with Non-HEPA filtered 

equipment 

• Vacuuming with HEPA filtered 

equipment in previously cleaned areas 

• Wet wiping following non-HEPA 

vacuuming 

• Wet wiping following HEPA vacuuming 

• Cleaning equipment using air and vacuum 

• Removing/ Changing vacuum bags/ filters 

C1/2 

CPAPR 

CPAPR 

C1/2 

C1/2 

D+ 

CPAPR 

CPAPR 

Support Zone Project Management Activities 

Materials Storage 

D 
-001 WRS Infrastructure and Environment, Inc. 15

 6.2 Ensemble Components 

Level D

This is the basic work uniform and shall consist of the following items: 

 Safety glasses 

 Steel-toed boots 

 Hearing protection (as applicable) 

• Leather gloves 

Level D+

 Safety glasses 

• Disposable coverall (Tyvek or Kleengaurd) 

• Disposable head covering 

• Disposable undergarments 

• Disposable gloves 

• Disposable boot covers or reusable/ cleanable boots (e.g., PVC, latex) 

• Steel toe boots 

• Hearing protection 

• Skin Barrier Cream for preventing fiberglass dermatitis (North Brand Model 222 available 

from Lab Safety) 

Level C

• Air Purifying Respirator (1/2 mask or full face PAPR) 

• P100 Cartridges 

• Disposable coverall (Tyvek or Kleengaurd) 

• Disposable head covering 

• Disposable undergarments 

• Disposable gloves 

• Disposable boot covers or reusable/ cleanable boots (e.g., PVC, latex) 

• Steel toe boots 

• Hearing protection 

• Skin Barrier Cream for preventing fiberglass dermatitis (North Brand Model 222 available 

from Lab Safety) 

6.3 Application 

Table 6.1 details the anticipated levels of protection for different tasks. However, project 

developments may prompt changes in the levels of PPE. Proper notification of the IHSO, HSA, 

and WRS Project manager is required to ensure continued safe operations. 
-001 WRS Infrastructure and Environment, Inc. 16

NO CHANGES TO THE SPECIFIED LEVELS OF PROTECTION SHALL BE MADE 

WITHOUT THE KNOWLEDGE AND APPROVAL OF THE NORTHEAST SAFETY 

AND HEALTH ADMINISTRATOR, WRS PROJECT HEALTH AND SAFETY 

OFFICER, AND THE WRS PROJECT MANAGER.

6.4 Inspection 

Before protective equipment is worn within the project area, its user will properly inspect it. 

6.5 Respirator Cartridge Change-out Schedule 

PAPR cartridges will be changed out when flow rate indicator (a.k.a. rotameter) measures 

unacceptably low flows. APR cartridges will be changed out when breathing becomes difficult 

or daily whichever comes first. 

7.0 MEDICAL SURVILLANCE REQUIREMENTS 

7.1 General 

WRS utilizes a Medical Monitoring Program designed to determine each employee's health 

status and fitness (including the ability to utilize respiratory protection) for working at hazardous 

waste sites. All WRS personnel involved in hazardous waste project activities are required to 

undergo baseline, annual, and project specific examinations. WRS utilizes the services of 

physicians experienced in occupational medicine and the effects of toxic industrial substances. 

Medical surveillance records for WRS employees are retained for the length of employment plus 

30 years. 

7.2 Site Specific Medical Monitoring 

No site specific medical monitoring is anticipated beyond that required under the Heat Stress 

Management SOP. 

7.3 Substance Abuse Prevention 

It is the policy of WRS to provide quality products and services to its customers and to maintain 

a safe and healthy workplace by assuring a work environment free of alcohol and other drugs. 

The unlawful manufacture, distribution, dispensation, possession, use or presence in one’s 

system of a controlled substance is prohibited in the workplace. Any employee who is in 

violation of this policy will be subject to disciplinary action up to and including discharge. Help 

is available to employees who have substance abuse problems through the Employee Assistance 

Program. 

Federal law also requires that an employee of WRS notify WRS in writing of a conviction under 

a criminal drug statute for a violation occurring during the performance of work under a covered 

federal procurement. This project is covered. Such notifications must be made through the WRS 

Health and Safety Manager. 
-001 WRS Infrastructure and Environment, Inc. 17

7.4 Asbestos 

The medical surveillance program outlined under 7.1 of this Plan includes the medical 

surveillance components required by the Asbestos Standard at 29 CFR 1926.1101(m). 

7.5 Lead 

Blood lead and ZPP monitoring are required by 29 CFR 1926.62(j) when airborne exposures 

exceed the Action Level of 30 ug/m3. Because the dust removal methods are designed to 

minimize the aerosolization of the dust, and the low concentrations (< 300 ppm), it is not 

anticipated that Action Limit will be reached and blood lead/ ZPP monitoring will therefore not 

be necessary. An exposure assessment will be used to verify this assumption. 

8.0 AIR SURVEILLANCE 

This section specifies the surveillance activities that will take place during the project. 

Surveillance activities will achieve the following objectives: 

• Characterize breathing zone (BZ) concentrations of site contaminants for comparison 

with published exposure limits; 

• Determining the appropriateness of respiratory protective equipment; and, 

• Monitoring the performance of emission control activities. 

8.1 Monitoring 

The usefulness of real time monitoring of respirable dust in this work environment is unknown to 

WRS. Collecting this data alongside air sampling activities may “calibrate” future real-time 

respirable dust monitoring and the establishment of Action Limits. WRS will perform real-time 

respirable dust monitoring to instruct the crew in relative dust levels. There will be no respirable 

dust Action Limits until or unless air-sampling data is available for comparison with real-time data. 

8.2 Action Limits 

None initially. 

8.3 Air Sampling 

Personal air sampling for lead, asbestos, and silica will be performed. Samples will be collected 

from the breathing zones of employees using the following NIOSH Methods. Analysis of 

samples will be made using NIOSH analytical method as well to facilitate comparisons with 

exposure limits. 
-001 WRS Infrastructure and Environment, Inc. 18

Method Flow Rate Sample Train Media 

7300 Lead 2 liters per minute 

minimum sample volume to 

achieve detection limits 50 

liters 

37 mm cellulose ester membrane 

(0.8 micron) Closed Face 

7400 Fibers (Asbestos and 

Man Made Vitreous Fibers 

MMVF) 

2 liters per minute** 

minimum sample volume to 

achieve detection limits – 

400 liters 

25 mm cellulose ester membrane 

(pore size 0.45 – 1.2 microns) 

with conductive cowl. Open face

7500 Respirable Silica/ 

Calcite/ Gypsum* 

1.7 liters per minute** 

minimum sample volume to 

achieve detection limits – 

400 liters 

37 mm PVC membrane (pore 

size 5 micron) with 10 mm nylon 

cyclone 

* This methods requires that a bulk respirable or settled dust sample be submitted with personal 

breathing zone sample to identify interferences with detection method. 

**These methods are sensitive to filter over loading. Length of sampling period should not 

exceed 4 hours. Use multiple sample periods to represent entire shift exposure. 

Samples will be collected on individuals performing tasks representative of exposure conditions. 

Specifically the following tasks will be characterized: 

• Common area cleaning; 

• Non-HEPA vacuuming; and, 

• Cleaning of areas not previously cleaned. 

Sample pumps will be pre- and post sample period calibrated using a sample train in-line 

between the pump and calibration unit to simulate pressure drop posed by the sample train. 

Calibrations will be made with a primary calibration device (e.g., film flow calibrator or near 

frictionless piston). 

Sample results will be communicated by the SHSO to employees represented by the sample data 

within five days of receipt on the WRS Air Sampling Data Acknowledgement Form. This data is 

forwarded to the WRS H&S Manager for inclusion in the employee’s medical file. 
-001 WRS Infrastructure and Environment, Inc. 19

9.0 SITE CONTROL MEASURES 

9.1 Control Zones 

Control boundaries will be established at the site. The exclusion zone, contamination reduction 

zone (decontamination zone) and support zone will be designated. A decontamination corridor 

will separate the Support areas of the project site from exclusion zones. The corridor should be 

split down the middle with a control line. One side of the corridor is for clean entry into 

exclusion zones and the other side is for decontamination of personnel and equipment. It may be 

necessary to protect the support zone from fugitive dust by placing it under positive pressure 

with the exhaust of a Negative air machine. 

The Response Manager has been designated to coordinate access control on the work site. No 

unauthorized person shall be allowed beyond the contamination control line. During all 

activities in the exclusion zone, the implementation of a buddy system is mandatory. 

Standing orders for the exclusion zone and contamination reduction zone are presented on the 

following page. 

9.2 Site Communications Plan 

Hand signals, radios, and mobile telephones are the modes of communication to be used at the 

site. The Response Manager will review hand signals with all site personnel prior to the start of 

the project and periodically at daily safety meetings. Standard hand signals include: 

ACTION MEANING

Hands around throat - out of air/can't breathe 

Thumbs up - OK/yes 

Thumbs down - negative, no 

Hands on top of head - need assistance 

Grip partner's wrist/waist - leave area immediately 

No one will be permitted to break visual contact while in the exclusion zone or contamination 

reduction zone. The buddy system will be strictly adhered to. When working in the exclusion 

zone, personnel will not be allowed to work alone. The buddy system will be in place to provide 

aid in case of an emergency. 

A telephone will be available in the support zone. Emergency assistance telephone numbers will 

be posted by this telephone. The Project Manager is responsible for the management of 

communications during normal and emergency operations. 

9.3 Sanitation Facilities 

Sanitation facilities will be located within the support zone. They will include hand and face 

washing facilities and toilets. 
-001 WRS Infrastructure and Environment, Inc. 20

Standing orders for the exclusion zone and contamination reduction zone are as follows:

 No smoking, eating, or drinking in these zones. Eating, drinking, chewing gum or tobacco, smoking, or 

any practice that increases the probability of hand-to-mouth transfer and ingestion of any material is 

prohibited in any area designated as a contamination reduction zone or exclusion zone. 

 No horse play. 

 No matches or lighters in these zones. 

 Check-in on entrance to the contamination reduction zone. Check-out on exit from this zone. Entrance 

and exit locations shall be designated and emergency escape routes delineated. Warning signals for site 

evacuation have been established. 

 Implement the communications system. Communications using radios, hand signals, signs, or other 

means shall be maintained between work crew members at all times. Emergency communication shall 

be prearranged in case of radio failure, necessity for evacuation off site, or other reasons. 

 Maintain visual contact between exclusion zone entrants. 

 Wear the appropriate level of protection as defined in the site specific Health and Safety Plan. 

 Work will only be performed during daylight hours unless adequate lighting is available. 

 Contact with known or suspected contaminated surfaces should be avoided. Whenever possible, there 

will be no walking through puddles or discolored surfaces; kneeling on ground; or leaning, sitting or 

placing equipment on drums, containers, or the ground. 

 Prescribed drugs should not be taken by personnel where the potential for absorption, inhalation, or 

ingestion of toxic substances exists, unless specifically approved by a qualified physician. 

 All respirator wearers must be certified as being capable of wearing respiratory protection (physician's 

approval, fit tested) while performing their assigned tasks. All respirator wearers must have been fit 

tested, within the past 12 months, with the make and size respirator to be worn. No facial hair is 

allowed that would interfere with respirator fit. 

 Work areas for all operational activities shall be clearly established and clearly delineated in the site 

specific Health and Safety Plan. 

 Work areas and decontamination procedures shall be established based on expected site conditions and 

clearly delineated in the site specific Health and Safety Plan. 

Personnel and equipment in the exclusion zone(s) will be minimized, consistent with effective site operations. 
-001 WRS Infrastructure and Environment, Inc. 21

10.0 DECONTAMINATION PLAN 

Decontamination of equipment and personnel will be performed to limit the potential migration 

of contaminants outside the exclusion zone. All equipment and personnel will be 

decontaminated prior to leaving the exclusion zone. 

10.1 Levels Of Decontamination Protection Required For Assisting Personnel 

The level of protection required for personnel assisting with decontamination is one level below 

that of the person being decontaminated. The Industrial Hygiene and Safety Officer is 

responsible for monitoring decontamination procedures and determining their effectiveness. 

10.2 Equipment Decontamination 

All vacuums and Negative Air Machines will have filters and pre-filters removed and disposed of 

before demobilization. They will also be wet wiped. The Response Manager and SHSO are 

responsible for ensuring the cleanliness of equipment prior to leaving the site. Any other 

equipment not disposed of after the job will be wet wiped. 

10.3 Personnel Decontamination 

10.3.1 Procedure 

All site personnel should minimize contact with contaminants in order to reduce the need for 

extensive decontamination. Personnel decontamination will be conducted in the 

decontamination zone. Gross decontamination for PPE Levels C and D+ will include: 

1. Vacuum coverall/ boots with HEPA vacuum 

2. Remove coveralls and dispose 

3. Remove boot covers and dispose (alternate: rinse boots/ remove and 

hang for drying) 

4. Remove gloves and dispose 

5. Remove respirator 

6. Wash/rinse respirator (inside and out) and hang for drying 

7. Rinse hard hat (inside and out) 

Personal hygiene following decontamination will take place in the support zone. 

10.3.2 Equipment 

Personal decontamination equipment will consist of trashcans with liners (for disposable PPE), 

three-gallon containers (respirator wash, sanitize and rinse), water supply, and detergent. 

10.4 Disposition of Decontamination Wastes 
-001 WRS Infrastructure and Environment, Inc. 22

All equipment used for decontamination shall be decontaminated or disposed of properly. 

Aqueous liquids will be disposed according to the Site Work Plan. All disposable PPE will be 

containerized and properly disposed. 

11.0 EMERGENCY RESPONSE PLAN 

This Emergency Response Plan has been prepared to define the responsibilities, resources and 

actions necessary to respond to uncontrolled releases of contaminated materials and injury to 

personnel. 

11.1 Pre-Emergency Planning 

This Emergency Response Plan will be reviewed and revised on a regular basis (if necessary) by 

the IHSO. This will ensure that the plan is adequate and consistent with prevailing project 

conditions. 

Local emergency medical, fire, and police resources will be identified. 

11.2 Personnel Roles and Lines of Authority 

The Project manager has primary responsibility for responding to and correcting emergency 

situations. This includes taking appropriate measures to ensure the safety of project personnel 

and the public. 

The individual subcontractor organizations are responsible for assisting the Project manager in 

his/her mission within the parameters of their scope of work. 

11.3 Emergency Recognition/Prevention 

Section 4.0 identifies the chemical and physical hazards on project. Additional hazards that may 

result from project activities are listed in Table 11.1. This table also lists prevention and control 

techniques/mechanisms. Personnel will be familiar with techniques of hazard recognition from 

pre-assignment training and project specific briefings. The IHSO is responsible for ensuring that 

prevention devices or equipment are available to personnel. 

 TABLE 11.1: EMERGENCY RECOGNITION/CONTROL MEASURES

Potential Hazard Prevention/Control Location of Response Equipment 

Fire • Fire Extinguisher (15 lb. dry 

chemical) 

• Ignition source control 

• Hot Work Prohibited 

• One per floor 

Eyewash Facility • 15 Minute Drench • At Building Entrance 

Delayed Building Exit • Mark routes of exit 

• Do not block stairs/ exits 

• All stairways/ exits 
-001 WRS Infrastructure and Environment, Inc. 23

11.4 Emergency Equipment/Facilities 

• First aid kit 

• Fire extinguishers 

• Telephone 

The following safety equipment and materials will be maintained on project. 

 Safety Equipment

Number Item

1 Industrial First Aid Kit 

1 Fire Extinguisher per floor 

1 Eyewash Station 

In the event of an injury requiring more than minor first aid, or any employee reporting any sign 

or symptom of exposure to hazardous substances, immediately take the victim to a local 

emergency medical provider. In the event of life-threatening or traumatic injury, implement 

appropriate first aid and immediately call for emergency medical assistance. If the patient's 

condition is serious first aid should be administered while awaiting an ambulance or paramedics. 

When an individual(s) is being transported to a clinic or hospital for treatment, the Project 

manager, or IHSO should ensure that information on the chemical(s) the individual(s) have been 

exposed to at the project is taken. This information, which is included in Section 4.0, could also 

be given to the hospital during project set-up activities. Any vehicle used to transport 

contaminated personnel will be treated and cleaned as necessary.

11.5 Fire or Explosion 

In the event of a fire or explosion, the local Fire Department should be summoned immediately. 

Upon their arrival, the Project manager or designated alternate will advise the fire commander of 

the location, nature, and identification of the hazardous materials on project. 

The IHSO shall act as the designated project emergency coordinator and shall have final 

authority for initial response to on-project emergency situations. Upon arrival of the appropriate 

emergency response personnel, the IHSO shall defer all authority but shall remain on the scene to 

provide assistance, if necessary. At the earliest opportunity, the IHSO shall contact the Project 

manager. 

11.6 Spill or Leaks 

In the event of a spill or a leak, project personnel will: 

 Inform the Project manager immediately 

If a leak occurs containment procedures will begin if possible. Simultaneously, the source of the 

spill will be stopped if it is still releasing material Air monitoring should be conducted 

downwind. The WRS Representative will be responsible for any reporting procedures that are 

required as a result of the spill.
-001 WRS Infrastructure and Environment, Inc. 24

Figure 11-1 

Route to Hospital 

EMERGENCY TELEPHONE NUMBERS AND HOSPITAL ROUTE 

 EMERGENCY ASSISTANCE TELEPHONE LIST

EMERGENCY ASSISTANCE 

ORGANIZATION

TELEPHONE NUMBER

New York University Downtown Hospital 

170 William Street 

New York, NY 10038 212-312-5000

AMBULANCE/RESCUE SQUAD 911 

FIRE 911 

LOCAL POLICE 911 

WRS BRISTOL OFFICE 267-540-0048 

WRS H&S Manager 770-469-6522 

CHEMTREC (24 HOURS) (800) 424-9300 

U. S. COAST GUARD NATIONAL 

RESPONSE CENTER (NRC) 

(800) 424-8802 

EPA OSC Communications 732-689-0019 
-001 WRS Infrastructure and Environment, Inc. 25

APPENDIX A 

HEALTH AND SAFETY FORMS
-001 WRS Infrastructure and Environment, Inc. 26

1. Accident/Incident Report 

2. Daily Safety Meeting Form 

3. Training Attendance Record 

4. Qualitative Respirator Fit Test and Inspection Form 

5. Daily Safety Report 

6. SSHP Change Authorization 

7. SSHP Sign-Off 

8. Air Monitoring Log 

9. Quantitative Respirator Fit Test Form 
WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

INJURY/ILLNESS/INCIDENT INVESTIGATION AND REPORT (OSHA 301 Form Equivalent) 

Supervisor Complete Both Pages/Forward to Branch and WRS H&S Manager within 48 hrs./Supervisor's Manager Review for 

Completeness

-001 WRS Infrastructure and Environment, Inc. 27

Personal & Background Information 

1. Case Number

 

2. Soc. Sec. No. 3. Name (Last name, first initial) 5. Date of Birth

6. Gender

  M  F

7. Date of Hire 8. Job or Site Name 9. Job Number

11. Time of Accident 12. Time Employee 

Began Work 

13. Date of Accident 14. Date Reported 15. Number of Others 

Involved in Accident 

16. Occupation at Accident Time 17. Regular Occupation 18. Number of Others 

 Injured in Accident

19. Nature of Injuries (Bruise, Strain, etc.) 20. Injured Body Part (left index finger) 

21. Names of Others Involved in Accident 22. Names of Others Injured in Accident

23. Chemicals Involved in Accident 24. Exact Location of Accident 

 (Sketch on Back)

25. On WRS Premises?

  Yes  No

26. Activity Injured was doing at time of accident or illness (operating backhoe, unloading drums, etc.) 

--Try to Identify job in three words 

-- Use no more than 30 spaces | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 

27. What Occurred (Use single line descriptive sentences to tell the story of what occurred) 

28. Check Type of Accident (Check one) 

 a. Struck by 

 b. Struck against 

 c. Contacted by 

 d. Contact with 

 e. Trapped in 

 f. Caught on 

 g Caught between 

 h Same level fall 

 i Different level fall 

 j Strain/overexertion 

 k. Exposure 

 l. Other 

29. Accident Agent (Limit to 21 spaces)(i.e., equipment, machine, hand tool) 

 | | | | | | | | | | | | | | | | | | | | | 

30. Contact Agent (Limit to 22 spaces)(i.e., machine part or material 

contacting) 

 | | | | | | | | | | | | | | | | | | | | | 

31. UNSAFE ACTIONS - What did employee do or fail to do that 

caused or contributed to accident? (Check no more than 2, give details 

on reverse)

32. UNSAFE CONDITIONS - What condition of tools, equipment 

or job site caused or contributed to accident? (Check no more than 2, 

give details on reverse)

 a. Operating without authority 

 b. Failure to make secure 

 c. Operating unsafe speed 

 d. Failure to warn/signal 

 e. Nullified safety device 

 f. Used defective equipment 

 g. Used equipment unsafely 

 h. Used wrong tool 

 i. Failure to make inoperative 

 j. Riding hazardous equipment 

 k. Took unsafe position 

 l. Horseplay, distractive 

 m. No protective equip. worn 

 n. Unsafe job procedure 

 o. No unsafe action 

 p. Other 

 a.Inadequate guard/Safety device 

 b. Hazardous personal attire 

 c. Inadequate warning system 

 d. Fire or Explosion hazard 

 e. Unsecured against movement 

 f. Poor housekeeping 

 g. Protruding object 

 h. Close clearance/congestion 

 i. Hazardous arrange/storage 

 j. Defective tools/equipment 

 k. Atmospheric condition 

 l. Illumination/noise 

 m. Other unsafe condition 

 n. No unsafe condition 

33. What caused or influenced unsafe actions you identified 

above? (Answer only if item 32 applies. Check no more than 2)

34. What caused or influenced unsafe condition you identified 

above? (Answer only if item 33 applies. Check no more than 2)

 a. Unaware of job hazards 

 b. Inattention to hazard 

 c. Unaware of safe method 

 d. Low level job skill 

 e. Tried to gain or save time 

 f. Tried to avoid extra effort 

 g. Tried to avoid discomfort 

 h. Influence of emotions 

 i. Influence of fatigue 

 j. Influence of intoxicant/drugs 

 k. Defective vision 

 l. Influence of illness 

 m. Other personal factors 

 n. Unknown personal factors 

 a. Caused by employee 

 b. Defective from normal use 

 c. Defective via abuse/misuse 

 d. Safety inspection failure 

 e. Housekeeping/cleaning failure 

 f. Faulty design/construction 

 g. Inadequate illumination 

 h. Preventive maintenance failure 

 i. Defective tools/equipment 

 j. Exposure to corrosion 

 k. Extreme temperature 

 l. Caused by other employees 

 m. Other source cause 

 n. Unknown source cause 

35. What action has been taken (Mark X box) or is planned (Mark P box) to prevent recurrence: (Mark no more than 5)

X P

  a. Reinstruction of employee 

  b.Reprimand/warning of employees involved 

  c. Penalty discipline of employee involved 

 .Preventive instruction of others who do job 

  e. Job reassignment of employee 

  f. Improved inspection procedure 

  g. Improved cleanup procedure 

X P

  h. Action to improve enforcement 

  i. Order JSA done on job 

  j. Order JSA revision 

  k. Install safety guard against 

  l. Require protective equipment 

  m. repair/replace equipment 

  n. Improve storage/arrangement 

X P

  o. Improve design/construction 

  p. Eliminate congestion 

  q. Use safer Materials/supplies 

  r. Improve illumination/ventilation 

  s. Mandatory pre-job instructions 

  t. Correction other than above 

  u. No action required 

36. Immediate Supervisor (Last name first, first initial) 37. Employee's Signature

38. Investigated by (Names and positions) Date 39. Reviewed and approved by (Name and position) Date

Part 1. Accident Description and Direct Cause Analysis 
WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

INJURY/ILLNESS/INCIDENT INVESTIGATION AND REPORT (OSHA 301 Form Equivalent) 

Supervisor Complete Both Pages/Forward to Branch and WRS H&S Manager within 48 hrs./Supervisor's Manager Review for 

Completeness

-001 WRS Infrastructure and Environment, Inc. 28

1. What Occurred

Describe in sequence (1) relevant background information if any, (2) employee's location and position relative to immediate surroundings, (3) 

how employee was doing job, (4) what occurred that precipitated the accident, (5) the type of accident and contact agent. 

2. Contributing "Unsafe" Action What did the injured (or other 

person) do or fail to do that contributed directly to accident? Be 

specific. 

(Ex., Failed to use protective equipment, Failed to lock out machine) 

Don't report "Carelessness."

3. Contributing "Unsafe" Condition What defective or otherwise 

unsafe conditions of tools, equipment, machines, structures or work 

equipment contributed directly to accident? 

(Ex., Oil on floor, Broken or missing machine guard, Poor housekeeping)

 

Part 2. Corrective Action Must Be Taken

4. Required Corrections

What corrective actions will be taken to prevent recurrence of accident? See Reverse Side, Item 35, for basic correction ideas. 

(Ex., Job Safety Analysis (JSA), Training, Employee counseling, Machine Guarding)

Part 3. Witnesses: 

Part 4. Accident Location Sketch 

N



Part 5. Extent and Outcome of Injury/Illness 

Lost Time Case

- Date Lost Time Began: ___/___/___ 

- Date Lost Time Ended: ___/___/___

Restricted Duty Case

Date Restriction Began: ___/___/___ 

Date Restriction Ended: ___/___/___

Restrictions: 

____________________________________

____________________________________ 

Medical Treatment

- Name of Hospital or Clinic: 

___________________________________________________________________________________________________________________ 

- Name of Physician: 

___________________________________________________________________________________________________________________ 

Describe Treatment: 

___________________________________________________________________________________________________________________

Was employee treated in an Emergency Room? Yes No Was employee hospitalized overnight as an in-patient? Yes 

N
-001 WRS Infrastructure and Environment, Inc. 29

WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

DAILY SAFETY MEETING 

Date: __________________________ Job Name: ____________________________ 

1. Work to be completed: 

 

2. Hazards Associated with this work: 

 

3. Hazard control measures to be implemented: 

 

SAFETY TOPICS PRESENTED

Protective Clothing/Equipment: 

 

Chemical Hazards: 

 

Physical Hazards: 

 

Emergency Procedures: 

 

ATTENDEES 

 NAME PRINTED SIGNATURE

 _________________________ _________________________ 

 _________________________ _________________________ 

 _________________________ _________________________ 

 _________________________ _________________________ 

WRS INFRASTRUCTURE & 

ENVIRONMENT, INC. TRAINING ATTENDANCE RECORD 
-001 WRS Infrastructure and Environment, Inc. 30

Class Title: 

Class Content: 

Class Instructor(s): 

 

Date: 

ATTENDED BY 

 NAMES (PRINTED) SIGNATURES 

 

 

 

Instructor(s) Signature: 

 

Date(s): 

cc: Corporate File 

 Branch File 
-001 WRS Infrastructure and Environment, Inc. 31

WRS INFRASTRUCTURE & ENVIRONMENT, INC.

RESPIRATOR FIT TESTING & INSPECTION

NAME ___________________________ EMPLOYEE NO.________ DATE ____________ 

TITLE ______________________ SERVICE CENTER ____________________________ 

HOOD/ ENCLOSURE MAY NOT BE USED WITH IRIITANT SMOKE. 

IRRITANT SMOKE FIT TESTING:

No. of Squeezes Activity Reaction

 _______ Initial ___ Yes ___ No 

 _______ Head/Neck Motion ___ Yes ___ No 

 _______ Motion/Talking ___ Yes ___ No 

 _______ Motion/Deep Breathing ___ Yes ___ No 

 _______ Total Squeezes 

Seal Obtained ______ Type of Cartridge used _____________________ 

 

 Type of respirator _____________________ 

 Size of respirator _____________________ 

RESPIRATOR INSPECTION:

Head Straps ok / not ok Inhalation valves/stems/bodies ok / not ok 

Face to Mask Sealing Surface ok / not ok Canister holder gasket/ threads ok / not ok 

Exhalation valves/cover/stems/bodies ok / not ok Lens ok / not ok 

Action Taken to Correct Deficiencies: _______________________________________ 

Fit Test/ Inspection performed by:__________________________ Date ___________ 

Employee signature: __________________________ Date ___________ 
Page ___ of ___ 

WRS INFRASTRUCTURE & ENVIRONMENT, INC. 

Daily Safety Report 

Project:

Contract No.: WRS Project No.: Date:

SHSO: PM: Supervisor: 

Site Conditions (weather, temp., soil conditons, etc.):______________________________ 

____________________________________________________________________________

Task/ Personnel/ PPE Matrix 

Task/Area Personnel PPE Level 

 

Corrective Actions 

Unsafe Act/ Condition Corrective Action 

 

Signature:_____________________________________________ Date:_______________ 

 SHSO 

Attachments: 

! Air Surveillance Log ! Accident Report ! Daily Safety Meeting ! Other ! None 
WRS Infrastructure & Environment, Inc. 

H&S Plan Change Authorization 

Project Name:______________________ Date:__________________________ 

Project Number:____________________ 

Description of Change: 

Reason for Change:

Person requesting Change: Signature Date 

Approved By Signature Date 

(WRS Health and Safety Administrator) 

Attach sheets if necessary 
SAFETY BRIEFING 

Project Name:____________________________________________ Date:_________________________ 

The following personnel were present at the pre-job safety briefing and having read the Health and Safety 

Plan, are familiar with its provisions, and will abide by the procedures set forth in this plan: 

Name Signature

 

 

Printed name of Site Supervisor or Site Health and Safety Officer 

Signature Date 
WRS Infrastructure & Environment, Inc.

Health and Safety Plan Sign-off

By signing below, I am indicating that I have read and agree to comply with the contents of the Site Specific Health and Safety Plan prepared for the Project. 

Name Signature Company Date
WRS Infrastructure & Environment, Inc.

WRS Infrastructure & Environment, Inc. 

Air Monitoring Log

Project Site: Project No. Date: 

 

Level of Protection: Description of Site (e.g. weather, temp., soil conditions):

 

Instrument: Instrument 

Response: 

Location: Time: Comments: 

 

Calibration Data (e.g. type & gas concentration, instrument adjustments if any): 

Additional Notes: 

Siganature:_______________________________ Date:________________________ 

 (Health and Safety Officer)
WRS Infrastructure & Environment, Inc 

WRS Infrastructure & Environment, Inc. 

Quantitative Fit Testing Certificate 

Employee 

Name:________________________________ Date:_________________________________ 

Dept.:________________________________ 

Employee 

No.:__________________________________

Quantitative Fit Testing Device: DNI Nevada Fit Tester 3000 (Controlled Negative Pressure)

Test Parameters

Work Rate: Heavy 300 kcal/ hr. Cartridge Type: Hi (Combination)

Mask Type: Full Face or Half Face Challenge Pressure:_______________” H2O 

Manufacturer:_________________________ Breathing Rate:___________________ LPM 

Model:________________________________ Gender:_______________________________ 

Size:__________________________________ Minimum Passing Fit Factor: 500

18 Step Protocol Exercises & Tests 

Step 1: Breathing 60 seconds 

Step 10: Test Face Forward 

FF:____________ Test Q:______________ 

Step 2: Test Face Forward 

FF:____________ Test Q:______________ Step 11: Grimace 20 seconds 

Step 3: Move Head Side to Side 60 seconds Step 12: Test Face Forward 

FF:____________ Test Q:______________ 

Step 4: Test Face Left 

FF:____________ Test Q:______________ Step 13: Bend at Waist 30 seconds 

Step 5: Test Face Right 

FF:____________ Test Q:______________ 

Step 14: Test Face Forward 

FF:____________ Test Q:______________ 

Step 6: Move Head Up & Down 60 seconds Step 15: Jog in place 30 seconds 

Step 7: Test Head Up 

FF:____________ Test Q:______________ 

Step 16: Test: Face Forward 

FF:____________ Test Q:______________ 

Step 8: Test Head Down 

FF:____________ Test Q:______________ Step 17: Re-don Respirator 60 seconds 

Step 9: Reading 30 seconds 

Step 18: Test Face Forward 

FF:____________ Test Q:______________ 

Average of Fit Test Exercises 

Average % Leak:___________Test Quality:________ Equivalent Fitactor:________ 

Employee Signature:________________________________ Date:________________ 

Tester’s Signature:_________________________________ Date:_________________ 
WRS Infrastructure & Environment, Inc 

APPENDIX B 

HEAT STRESS 
WRS Heat Stress Management Standard Operating Procedure

WRS Infrastructure & Environment, Inc 

 

CONTENTS

1.0 PURPOSE

2.0 SCOPE

3.0 DEFINITIONS

4.0 RESPONSIBILITIES

5.0 PROCEDURE

6.0 REFERENCES

7.0 ATTACHMENTS

8.0 RECORD KEEPING

9.0 EQUIPMENT
WRS Heat Stress Management Standard Operating Procedure

WRS Infrastructure & Environment, Inc 

1.0 PURPOSE

The Heat Stress Management SOP is intended to describe measures which will reduce the probability of workers 

experiencing a heat related disorder. 

2.0 SCOPE

The Heat Stress Management SOP is applicable to all WRS project sites. Its implementation is mandatory when 

workers wearing impermeable personal protective equipment are exposed to ambient air temperatures above 70o

F. 

3.0 DEFINITIONS

Stress can contribute significantly to accidents or harm workers in other ways. 

The term "stress" denotes the physical (gravity, mechanical force, heat, cold, pathogens, injury) and psychological 

(fear, anxiety, crises, joy) forces that are experienced by individuals. 

They body's response to stress occurs in three stages: 

 a. Alarm Reaction - The body recognizes the stress and the pituitary-adreno-cortical system responds 

by increasing the heart rate and blood sugar level, decreasing digestive activity and dilating the 

pupils. 

 b. Adaptive Stage - The body repairs the effect of stimulation and stress symptoms disappear. 

 c. Exhaustion Stage - The body can no longer adapt to stress and the individual may develop 

emotional disturbances and cardiovascular and renal diseases. 

The most common types of stress that affect remediation personnel are heat stress and cold stress. Heat and cold 

stress can be the most serious hazards an employee encounters at hazardous waste sites. 

Heat Stress usually is a result of protective clothing decreasing natural body ventilation, although it may occur at any 

time work is being performed at elevated temperatures. 

If the body's physiological processes fail to maintain a normal body temperature because of excessive heat, a number 

of physical reactions can occur ranging from mild (such as fatigue, irritability, anxiety, and decreased concentration, 

dexterity, or movement) to fatal. Because heat stress is one of the most common and potentially serious illnesses at 

hazardous waste sites, regular monitoring and other preventative measures are vital. 

Site workers must learn to recognize and treat various forms of heat stress. 

4.0 RESPONSIBILITIES

The Project Manager/ Supervisor is responsible for directing work in accordance with this procedure when 

implementation conditions are met. The PM is also responsible for providing resources necessary for 

implementation of the procedure. 

The Site Health and Safety Officer is responsible for monitoring and facilitating employee compliance with the 

procedure. The SHSO is responsible for instructing employees in the recognition and control of heat related 

illnessess. 

5.0 PROCEDURE
WRS Heat Stress Management Standard Operating Procedure

WRS Infrastructure & Environment, Inc 

5.1 Symptom Recognition and Treatment 

A large portion of heat stress control lies in the ability of an individual to recognize heat stress symptoms in 

themselves and co-workers. Early recognition and treatment of heat stress symptoms can prevent the development of 

more serious, debilitating and even life threatening conditions. 

5.1.1 Heat Stroke

Heat stroke is an acute and dangerous reaction to heat stress caused by a failure of the heat regulating mechanisms of 

the body. The individual's temperature control system that causes sweating stops working correctly. Body 

temperature rises so high that brain damage and death will result if the person is not cooled quickly. Heat stroke 

requires medical attention. 

 a. Symptoms - Red, hot dry skin, although person may have been sweating earlier. Nausea, 

dizziness, confusion, extremely high body temperature, rapid respiratory and pulse rate, 

convulsions, unconsciousness, or coma. 

 b. Treatment - Cool the victim quickly. If the body temperature is not brought down fast, permanent 

brain damage or death will result. Soak the victim in cool, but not cold, water; sponge the body 

with cool water; or pour water on the body to reduce the temperature to a safe level (102o

F). 

Observe the victim and obtain medical help. Do not give coffee, tea, or alcoholic beverages. Do 

give fluids by mouth if victim is in and out of consciousness 

5.1.2 Heat Exhaustion

Heat exhaustion is a state of very definite weakness or exhaustion caused by the loss of fluids from the body. This 

condition is much less dangerous than heat stroke, but it nonetheless must be treated. 

 a. Symptoms - Pale, clammy moist skin, profuse perspiration and extreme weakness. Body 

temperature is normal, pulse is weak and rapid, breathing is shallow. The person may have a 

headache, may vomit, and may be dizzy. 

 b. Treatment - Remove the person to a cool, air-conditioned place, loosen clothing, place in a headlow position, and provide bed rest. Consult a physician, especially in severe cases. The normal 

thirst mechanism is not sensitive enough to ensure body fluid replacement. Have the patient drink 

one to two cups of water immediately and every 20 minutes thereafter until symptoms subside. 

Total water consumption should be about one to two gallons per day. 

5.1.3 Heat Cramps

Heat cramps are caused by perspiration that is not balanced by adequate fluid intake. Heat cramps are often the first 

sign of a condition that can lead to heat stroke. 

 a. Symptoms - Acute painful spasms of voluntary muscles: e.g., abdomen and extremities. 

 b. Treatment - Remove the victim to a cool area and loosen clothing. Have the patient drink one to 

two cups of water immediately and every 20 minutes thereafter until the symptoms subside. Total 

water consumption should be one to two gallons per day. Consult your physician. 

5.1.4 Heat Rash

Heat rash is caused by continuous exposure to heat and humid air and is aggravated by chafing cloths. The condition 

decreases the ability to tolerate heat. 
WRS Heat Stress Management Standard Operating Procedure

WRS Infrastructure & Environment, Inc 

 a. Symptoms - Mild red rash, especially in areas of body in contact with protective gear. 

 b. Treatment - Decrease the amount of time in protective gear and provide powder to help absorb 

moisture and decrease chafing. 

5.2 Heat Stress Prevention Measures 

What follows is a list of heat stress prevention measures which reduce the risk of an employee experiencing a heat 

related disorder. They are in no particular order. Successful heat stress prevention will require the implementation 

of all the control measures listed to varying degrees. No single control measure will prove to be either effective nor 

efficient for a given project site. 

5.2.1 Fluid Replacement 

 Have workers drink 16 ounces of water before beginning work, such as in the morning or after 

lunch. Provide disposable, four ounce cups and water that is maintained at 50 to 60o

F. Urge 

workers to drink one to two gallons per day. To assist employees track their own fluid 

replacement, provide individual water coolers/ containers, fill the containers each day, and check 

consumption at the end of the day. The use of paper cups and a single cooler for the entire job site 

are difficult for both supervisors and employees to track. Provide cool, preferably air-conditioned, 

area for rest breaks. Discourage the use of alcohol in nonworking hours and discourage the intake 

of coffee during working hours. Monitor for signs of heat stress. 

 Use of electrolyte containing fluids (e.g., Gatorade) is more important for unacclimatized workers 

than acclimatized workers. 

5.2.2 Acclimate Crew Members 

 Acclimatization is the process by which the body adapts to heat stress. Changes 

 include increased sweating efficiency (earlier onset of sweating, increased sweat 

 production, lower electrolyte loss) and stabilized blood circulation (less likelihood 

 of blackout, dizziness, spots, etc.) It occurs with brief (~100 minutes) daily 

 exposures to heat in 5 -7 days. Benefits of acclimatization are typically lost with 

 no heat exposure for a week or more. 

5.2.3 Reduce Heat Load (both environmental and metabolic) 

 

 Provide cooling devices to aid body cooling (i.e., Cool Vests). These devices, however, add 

weight, and their use should be balanced against worker efficiency. 

 

 Evaporative cooling is aided by clothing which wicks away perspiration from the skin. Long 

cotton underwear acts as a wick to help absorb moisture and protect the skin from direct contact 

with heat-absorbing protective clothing. However, long cotton underwear is of no use and can 

aggravate heat stress symptoms once it becomes soaked with perspiration. 

 Install mobile showers and/or hose-down facilities to reduce body temperature and cool protective 

clothing. 

 In hot weather, conduct field activities in the early morning or evening. 

 
WRS Heat Stress Management Standard Operating Procedure

WRS Infrastructure & Environment, Inc 

 Reduce metabolic heat load by designing tasks such that employee exertion is kept 

 to a minimum 

 Reduce environmental heat loads by reducing radiant heat exposure (sunshine). 

 Working in shaded areas and taking breaks in shaded areas will reduce heat loads 

 due to radiant heat. 

5.2.4 Employee Rotation 

 In hot weather, rotate shifts of workers wearing impervious clothing. On project sites with large 

crews, stagger heat stress breaks so that tasks are not completely shut down. On sites with small 

crew sizes this may not be possible due to the “buddy system” rule. 

5.2.5 Dry Clothing and Personal Hygiene 

 Good hygienic standards must be maintained by frequent changes of clothing and showering. 

Clothing should be permitted to dry during rest periods. Persons who notice skin problems should 

immediately consult medical personnel. 

5.2.6 Avoid Diuretics and Stimulants 

Avoid consuming alcoholic beverages which cause loss of body fluid water by urination. Avoid consumption of 

stimulants such some cold medicines and caffiene which increase heart rates. 

5.2.7 Heat Stress Monitoring and Work/ Rest Cycle Management 

For strenuous field activities that are part of on-going work activities in hot weather, the following procedures shall 

be used to monitor the body's physiological response to heat and to manage the work/ rest cycle. These procedures 

are to be instituted when ambient temperatures exceed 70o

F and employees are wearing impervious (i.e., does not 

allow perspiration to evaporate) clothing (e.g., Tyvek, Saranex, PE Coated Tyvek, etc., coveralls). 

 a. Measure Heart Rate (HR) - The heart rate should be measured by the radial pulse at the wrist for 

30 seconds as early as possible in the resting period. The HR at the beginning of the rest period 

should not exceed 110 beats per minute. If the HR is higher, the next work period should be 

shortened by 33%, while the length of the rest period stays the same. If the pulse rate still exceeds 

110 beats per minute at the beginning of the next rest period, the following work cycle should be 

further shortened by 33%. The procedure is continued until the rate is maintained below 110 beats 

per minute. 

 

 b. Measure Body Temperature - Body temperature should be measured orally or aurally by a clinical 

thermometer as early as possible in the resting period. The temperature (OT) at the beginning of 

the rest period should not exceed 99.6o

F, if it does, the next work period should be shortened by 

33% while the length of the rest period stays the same. If the OT exceeds 99.6o

F at the beginning 

of the next period, the following work cycle should be further shortened by 33%. The procedure is 

continued until the body temperature is maintained below 99.6o

F. Consuming fluids immediately 

prior to temperature measurement will give false, low readings. No one will continue to be 

exposed to hot conditions with an oral/ aural temperature in excess of 100.6o

F. 
WRS Heat Stress Management Standard Operating Procedure

WRS Infrastructure & Environment, Inc 

c. Rest Areas - Rest areas should be air conditioned if possible. The heart rates of workers who 

recover in air conditioned areas will be reduced faster and to lower rates than those that recover in 

non-air conditioned areas. 

 d. Manage Work/Rest Schedule - The following work/rest schedule shall be used as a guideline: 

Adjusted Temperature (oF) Active Work Time Using Impermeable Protective Gear

75 or less 50 

80 40 

85 30 

90 20 

95 10 

100 0 

To calculate the adjusted temperature: 

T (adjusted) = T (actual) + (13 X fraction sunshine) 

Measure the air temperature with a standard thermometer. Estimate the fraction of sunshine by judging what percent 

the sun is out: 100% sunshine = no cloud cover = 1.0, 50% sunshine = 50% cloud cover = 0.5, and 0% sunshine = 

full cloud cover = 0.0. 

Reduce or increase the work cycle according to the guidelines under heart rate and body temperature. 

6.0 REFERENCES

• Occupational Safety and Health and Guidance Manual for Hazardous Waste Site Activities 

• Patty’s Industrial Hygiene and Toxicology, Fourth Edition 

• OSHA Web Site http://www.osha-slc.gov/SLTC/heatstress/index.html

7.0 ATTACHMENTS

None 

8.0 RECORD KEEPING

Records which facilitate the tracking of employee fluid consumption and work/ rest cycles will be generated. 

9.0 EQUIPMENT

• Oral thermometers and hygienic slip covers or aural thermometers with hygienic slip covers 

• Thermometer to measure air temperature 

• Cool water and/ or electrolyte containing fluids (e.g., Gatorade) 

• Ice cooled vests 

• Materials to create shaded work areas 
WRS Infrastructure & Environment, Inc 

APPENDIX C 

LOCKOUT/ TAGOUT 

WRS STANDARD OPERATING PROCEDURE 
Standard Operating Procedure Page 1 of 10 

Lockout/ Tagout 1/00 Edition 

WRS Infrastructure & Environment, Inc. 

CONTENTS

1.0 PURPOSE

2.0 SCOPE

3.0 DEFINITIONS

4.0 RESPONSIBILITIES

5.0 PROCEDURE

6.0 REFERENCES

7.0 ATTACHMENTS

8.0 RECORD KEEPING

9.0 EQUIPMENT
Standard Operating Procedure Page 2 of 10 

Lockout/ Tagout 1/00 Edition 

WRS Infrastructure & Environment, Inc. 

1.0 PURPOSE 

WRS recognizes the hazards of unexpected: 

 energization 

 machine startup and/or 

 release of stored energy 

during service or maintenance activities on equipment/machines. The following Standard Operating Procedure: Control of 

Hazardous Energy - Lockout/Tagout, has been developed to provide for the isolation of all energy sources that could endanger 

employees. 

This procedure establishes minimum requirements for the lockout and/or tagout of energy isolating devices and systems. Lockout

and/or tagout shall be used to ensure that all equipment, machinery, systems and facilities are inoperable and isolated from all 

potentially hazardous energy. The Lockout/Tagout procedure shall be implemented before employees perform service or 

maintenance activities where the unexpected energization, start-up or release of stored energy could cause personal injury and/or 

damage to equipment, machinery, facilities or the environment. 

2.0 SCOPE 

A. Provisions outlined in this SOP include individual responsibilities, instructions for the implementation and removal of 

energy control procedures and employee training requirements. 

B. Employees Covered - This procedure applies to all WRS employees and sub-contractors to the same. 

C. Activities Covered 

 

 Service and maintenance activities on machines, equipment, systems and facilities during which the unexpected 

energization, start-up or release of stored energy could cause injury to employees must be conducted under the protection 

of a Lockout/Tagout SOP. 

 Operation/Production activities during which an employee must remove or bypass a guard or other safety device, or place 

his/her body into an area of machinery/equipment where work is actually performed upon the material being processed 

(point of operation) must also be conducted in accordance with a Lockout/Tagout SOP. 

D. This SOP is generic in nature and applies to the portion of scenarios described above which meet the following criteria: 

 1. The machine, equipment or facility component has no potential for stored or residual energy or re-accumulation 

of stored energy after shut down which could endanger employees; 

 2. The machine, equipment or facility component has a single energy source which can be readily identified and 

isolated; 

 3. The isolation and locking out of that energy source will completely de-energize and deactivate the machine, 

equipment or facility component; 

 4. The machine, equipment or facility component is isolated from that energy source and locked out during 

servicing, maintenance or site operations; 
Standard Operating Procedure Page 3 of 10 

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 5. A single lockout device will achieve a lock-out condition; 

 6. The lockout device is under the exclusive control of the authorized employee performing the servicing, 

maintenance or site operation; 

 7. The servicing, maintenance or site operation does not create additional hazards for other employees; and 

 8. Utilization of this procedure has resulted in no accidents involving the unexpected activation or re-energization 

of an electrical source during servicing, maintenance or site operations. 

E. Activities which do not conform to these criteria must be conducted under equipment/machinery specific lockout/tagout 

procedures. 

3.0. DEFINITIONS 

 AFFECTED EMPLOYEES - WRS employee and/or a subcontractor employee whose job includes activities such as 

operating machines or equipment on which servicing or maintenance is being performed under lockout or tagout action or 

whose job requires the employee to work in an area in which servicing or maintenance or site operations are being 

performed. 

 AUTHORIZED EMPLOYEE - An employee who locks or implements a tagout system procedure on electrical sources to 

perform the servicing or maintenance of the equipment, or site operations. An authorized employee and an affected 

employee may be the same person when the affected employee's duties also include performing maintenance, service on 

machinery/equipment or site operations which must be locked or a tagout system implemented. The authorized employee 

shall be properly trained and approved to apply and remove locks and tags. 

 BLANK - To introduce an obstruction or to replace an opening with a solid surface to prevent flow (e.g. pipeblank). 

 CAPABLE OF BEING LOCKED OUT - An energy isolating device will be considered to be capable of being locked out 

if it has a hasp or other attachment where a lock can be affixed, or has a locking mechanism built in. 

 DOUBLE ISOLATION - To isolate by closing two valves or inserting a blank within an area of two valves. 

 ENERGY ISOLATING DEVICE - A physical device which prevents the transmission or release of energy. Examples 

include, but are not limited to, restrain blocks, electrical circuit breakers, disconnect switches, slide gates, or line valves. 

Where possible, they shall provide visible indication of the position of the device. Push-buttons, selector switches, check 

valves, and other portions of the control circuit shall not be considered energy isolating devices. 

 ENERGY SOURCE - Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. 

 LOCKOUT - The placement of a lockout device on an energy isolation device, in accordance with an established 

procedure. 

 LOCKOUT DEVICE - A device that utilizes a positive means such as a lock, either key or combination type, to hold an 

energy isolating device in the safe "off" position for the purpose of protecting personnel. 

 TAGOUT - The placement of a tagout device on an energy isolation device in accordance with an established procedure. 

(See Attachment B for a suggested lockout/tagout tag.) 
Standard Operating Procedure Page 4 of 10 

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 TAGOUT DEVICE - A prominent warning device, such as a tag and a means of attachment which can be securely 

fastened to an energy isolating device in accordance with the established procedure. 

 - Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or 

accidental removal. 

 - Tagout devices' attachment means shall be of a non-reusable type, attachable by hand, self-locking, and nonreleasable, with a minimum unlocking strength of no less than fifty pounds. 

 - Tagout devices shall have the general design and basic characteristics of being at least equivalent to a onepiece, all-environment-tolerant nylon cable tie. 

 ZERO ENERGY STATE - Removal of all potential energy within the designated area of a lockout or tagout. 

4.0 RESPONSIBILITY 

Appropriate (authorized and affected) employees shall be instructed in the safety significance of the lockout/tagout procedure. 

Each new or transferred affected employee and other employees whose work operations are or may be in the area shall be 

instructed in the purpose and use of the lockout/tagout procedure. 

A. Affected Employees - shall conduct themselves in a manner which does not jeopardize the effectiveness of the 

Lockout/Tagout procedure. Assist Authorized Employees in the successful application, use and removal of the 

Lockout/Tagout SOP. 

B. Authorized Employees - shall be familiar with that particular equipment and processes that are being locked/tagged out, 

and with the means and methods to isolate the energy source. Shall conduct service, maintenance and operation activities 

covered by this SOP in strict accordance with its provisions. 

C. Industrial Hygiene and Safety Officer (IH&SO) - shall provide consultation to Operations Management on determining 

the applicability of this SOP to a particular activity. Develop equipment/machinery specific Lockout/Tagout SOPs not 

covered under this SOP. Assist Operations Management in determining the effectiveness of this SOP for a particular 

activity, conduct and/or coordinate the training of Authorized and Affected Employees. Audit and report on the 

effectiveness of the Lockout/Tagout SOP and training activities. 

D. Operations Management - shall identify, with IH&SO's assistance, activities covered under this SOP and shall inform 

Affected and Authorized employees of same. Shall identify to the IH&SO and provide access to employees in need of 

training. Shall assign work activities to Authorized and Affected Employees in accordance with this SOP. Shall identify 

to the IH&SO machinery/equipment in need of SOPs beyond the scope of this SOP and assist in their preparation. Shall 

inform outside servicing personnel or contractors of this procedure whenever they are engaged in activities covered by 

the scope of this procedure. 

5.0 PROCEDURE 

5.1 TRAINING 

Each WRS site/location shall provide training to ensure that the purpose and function of the energy control program are 

understood by employees and that the safe application, usage and removal of energy controls are acquired by the employees. 

Proper documentation with content and person's signature is required. 
Standard Operating Procedure Page 5 of 10 

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A. The training shall include the following: 

 1. Each authorized employee shall receive training in the recognition of applicable hazardous energy sources. 

 2. Each affected employee shall be instructed on the purpose and use of the energy control procedure. 

 3. All other employees whose work operations are or may be in an area where energy control procedures may be 

utilized, shall be instructed concerning the procedure. 

B. Additional training requirements when using Tagout Systems shall include the following: 

 1. Tags are warning devices and do not provide physical restraint as would be provided by a lock. 

 2. A tag shall not be removed without written approval of the authorized person responsible. 

 3. Tags must be legible and understandable by all authorized employees, affected employees, and all other 

employees whose work operations are in the area. 

 4. Tags and their means of attachment must be made of materials which will withstand the environmental 

conditions. 

C. Additional retraining shall be conducted: 

 1. Whenever there is a change in an employee's job assignment. 

 2. Based on changing job assignments, methods of control and/or whenever a periodic inspection reveals a 

deviation from the energy control procedure. 

D. Training on the use of the Energy Control Procedures shall be certified by WRS. The certification shall contain each 

employee's name, signature and date of training. 

 All WRS employees shall receive training sufficient to undertake the activities of an Authorized employee under this 

generic SOP. 

5.2 APPLICATION OF THE ENERGY CONTROL PROCEDURE 

The following steps shall be followed in the application of the lockout or tagout system. 

A. Preparation for Shutdown - Authorized and affected employees shall have knowledge of the type and magnitude of the 

energy, the hazards of the energy to be controlled, and the method or means to control the energy. 

B. Machine or Equipment Shutdown - Machines or equipment shall be turned off or shut down using point of operation 

control switches. 

C. Machine or Equipment Isolation - The energy isolating device for the machine or equipment shall be physically located 

and operated to ensure that the machine or equipment is isolated from the energy source. 
Standard Operating Procedure Page 6 of 10 

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D. Lockout or Tagout Device - The lockout or tagout device shall be affixed to each energy isolating device by authorized 

employees. The device shall be affixed in a manner that will hold the energy isolating device in a safe or off position. 

E. Full Employee Protection - When a tagout device is used on an energy isolating device which is capable of being locked 

out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the 

employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a 

lockout program. 

 Means to be considered as part of the demonstration of full employee protection shall include the implementation of 

additional safety measures such as: 

 Removal of an isolating circuit element 

 Blocking of a controlling switch 

 Opening of an extra disconnecting device 

 Removal of a valve handle. 

F. Stored Energy - All potentially hazardous stored or residual energy shall be relieved, disconnected and rendered safe. 

G. Isolation of Energy Verification - Prior to starting work on machines or equipment, the authorized employee shall verify 

(per Section entitled "Removal of Lockout or Tagout Devices") that isolation and de-energization of the machine, 

equipment or electrical source has been accomplished. 

5.3 REMOVAL OF LOCKOUT OR TAGOUT DEVICES 

Before lockout or tagout devices are removed and energy is restored, the following procedures shall be followed: 

A. Employees

 The work area shall be checked to ensure that all employees have been safely positioned or removed from the 

area. 

 All affected employees shall be notified that the lockout or tagout devices have been removed before any 

machine, equipment or electrical source is energized. 

B. The Machine or Equipment

 The work area shall be inspected to ensure that all non-essential items have been removed and the machine or 

equipment is ready for operation. 

C. Removing the Lockout or Tagout Device

 Each lockout or tagout device shall be removed by the authorized employee who applied the device. 

5.4 REMOVAL OF LOCKOUT OR TAGOUT DEVICE BY ANOTHER EMPLOYEE 

When the authorized employee who applied the lockout or tagout device is not available to remove it, the following procedure 

must be in place with specific training for such removal. 
Standard Operating Procedure Page 7 of 10 

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 Verify by visual inspection or equivalent that the authorized employee who applied the device is not at the facility. 

 Make a reasonable effort to contact and notify the authorized employee that the lockout or tagout device has been 

removed. 

 Notify that employee's supervisor. 

 Before resuming work, ensure that the authorized employee knows that the device has been removed. 

5.5 GROUP LOCKOUT OR TAGOUT 

When servicing and/or maintenance is performed by a crew, craft or other group, they shall utilize a procedure which affords the 

employees a level of protection that is equivalent to that provided by the implementation of a personal lockout device. 

Group lockout or tagout procedures shall include the following specific requirements: 

 An employee will be assigned primary responsibility as an authorized employee for a set number of employees working 

under the protection of a group lockout or tagout device. 

 This employee will maintain a roster of group members and their job assignments. 

 When more than one crew, craft, or department is involve, assignment of overall job-associated lockout or tagout control 

responsibility shall be designated to an authorized employee to coordinate affected work forces and ensure continuity of 

protection. 

 Each authorized employee shall affix a personal lockout or tagout device to the group lockbox or device, group lockout 

box, or comparable mechanism on the machine or equipment being serviced or maintained. 

5.6 OUTSIDE PERSONNEL (CONTRACTORS) 

 All outside servicing personnel (contractors) and WRS personnel shall inform each other of their respective lockout or 

tagout procedures. 

 All WRS locations and or facilities shall ensure that the employees understand and comply with the restriction and 

prohibitions of the outside contractor's energy control procedures. 
Standard Operating Procedure Page 8 of 10 

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Table I 

LOCKOUT OR TAGOUT SEQUENCE 

NOTIFY EMPLOYEES ACTION 

Site Supervisor A. Notifies all personnel affected by the lockout or tagout application and the 

reason therefore. 

SHUTDOWN PROCESS OR EQUIPMENT 

Authorized Employee A. Turns off or returns operating controls to the neutral mode using 

appropriate equipment/process shutdown procedures. 

B. Operates switches and/or valves or any other energy isolating device(s) so 

that the equipment is isolated from its energy source(s). 

PLACE LOCKOUT AND/OR TAGOUT 

Authorized employee A. Applies safety locks and tags in all cases as required to isolate all energy 

devices. The lockout or tagout must be visible and accessible to anyone 

attempting to operate the isolated device. 

VERIFY THE ABSENCE OR CONTROL OF ENERGY 

Authorized employee A. Checks or tests all systems after the lockout and tagging procedures have 

been completed to insure that total energy isolation has occurred. 

CAUTION: Return operating control to neutral or off position, after verification of 

energy isolation. 

REMOVE LOCKOUT/TAGOUT DEVICES 

Authorized Employee A. Checks the area around the machine or equipment to ensure that no one is 

exposed. 

B. Removes all tools from machines or equipment. Ensures all guards have 

been reinstalled and employees are in the clear. 

C. Ensures that all pipes that were opened for repair or draining purposes are 

closed and connected properly. 

D. Ensures that all controls are in off position or neutral position. 

E. Removes safety locks and/or tags. 

F. Operates the energy isolating devices to restore energy to the machine or 

equipment 

ADMINISTER LOCKOUT/TAGOUT DEVICES 

Site Supervisor A. Maintains a lockout or tagout log at the lock cabinet. 

B. Schedules and performs surveillances so that proper lock and tag procedure 

is being followed. 

C. Schedules and performs audits of the proper lock and tag procedure. 

5.7 PROCEDURE INVOLVING MORE THAN ONE PERSON 

Each individual working on equipment or processes shall be required to place his/her own personal lockout device or tagout 

device on the energy isolating device. 

When an energy isolating device cannot accept multiple locks or tags, a multiple lockout or tagout device (hasp) may be used. If a 

lockout is used, a single lock may be used with the key being placed in a lockout box or cabinet which allows the use of multiple 

locks to secure it. Each employee will use his/her own lock to secure the box or cabinet. 

6.0 REFERENCES

• 29 CFR 1910.147 
Standard Operating Procedure Page 9 of 10 

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• OSHA Web Page http://www.osha-slc.gov/SLTC/controlhazardousenergy/index.html

7.0 ATTACHMENTS

• Training Outline 

• Sample Tag 

8.0 RECORD KEEPING

• Employee training evets 

• Inspections of ongoing LOTO’s 

9.0 EQUIPMENT

• Lockout device (e.g., hasp) 

• Lock 
Standard Operating Procedure Page 10 of 10 

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ATTACHMENT A 

 Training Outline
 1 

 CONTROL OF HAZARDOUS ENERGY 

 LOCKOUT/TAGOUT 

Training Outline 

I. Hazard Recognition 

 A. Recognize the Scenario 

 1. Unexpected Energization 

 

 

 2. Unexpected Machine Startup 

 

 3. Release of Stored Energy 

 

 4. Our Equipment vs. Our Clients Equipment 

 

 5. Suspect Activities 

 

 B. Recognize the Energy 

 1. Electric 

 

 2. Hydraulic 

 

 3. Pneumatic 

 

 4. Mechanical 

 

 5. Thermal 

 

 6. Chemical 

 
 2 

 7. Combinations 

 

II. Hazard Control Standard Operating Procedure 

 A. Activities Covered 

 

 

 

B. Definitions 

 1. Affected Employees 

 

 2. Authorized Employees 

 

 3. Blank 

 

 4. Capable of Being Locked Out 

 

 5. Double Isolation 

 

 6. Energy Isolating Device 

 

 7. Lockout 

 

 8. Lockout Device 

 

 9. Tagout 

 

 10. Tagout Device 

 
 3 

 

 11. Zero Energy State 

 

 C. Lockout/Tagout Sequence 

 1. Notify Employees 

 

 2. Shutdown Process or Equipment 

 

 3. Place Lockout/Tagout Device 

 

 4. Verify Obsence or Control of Energy 

 

 5. Remove Lockout/Tagout Devices 

 

 D. Activities Not Covered by SOP 

 

 

 

 

 E. Removing Another Employee's Lock/Tag 

 

 

 

 

 F. Group Lockout/Tagout 

 

 

 

 

 G. Outside Personnel (Subcontractors, Clients) 

 

 

 

 
 
 

ATTACHMENT B 

Tag 

TAG OUT

NAME DATE HOUR
 

APPENDIX D 

WRS FALL PROTECTION 

STANDARD OPERATING PROCEDURE 
Standard Operating Procedure Page 1 of 15 

Fall Protection 

 

CONTENTS

1.0 PURPOSE

2.0 SCOPE

3.0 DEFINITIONS

4.0 RESPONSIBILITIES

5.0 PROCEDURE

 5.1 Training 

 5.2 Gaurdrail Systems 

 5.3 Safety Net Systems 

 5.4 Personal Fall Arrest Systems 

 5.5 Positioning Device Systems 

 5.6 Warning Line Systems 

 5.7 Controlled Access Zones 

 5.8 Safety Monitoring Systems 

 5.9 Covers 

 5.10 Protection from Falling Objects 

 5.11 Fall Protection Plans 

6.0 REFERENCES

7.0 ATTACHMENTS

8.0 RECORD KEEPING

9.0 EQUIPMENT
Standard Operating Procedure Page 2 of 15 

Fall Protection 

 

1.0 PURPOSE 

This procedure establishes minimum requirements to prevent injuries to employees from 

different level falls. It also defines minimum requirements for complying with OSHA’s Fall 

Protection Standard (29 CFR 1926 Subpart M). 

2.0 SCOPE 

This procedure applies to all WRS employees and WRS subcontractor employees exposed to the 

following workplace conditions: 

Unprotected Sides and Edges - employees on walking/working surfaces (horizontal and vertical 

surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level. 

Leading Edge Work - employees constructing a leading edge 6 feet (1.8 m) or more above lower 

levels. 

Work In Hoist Areas - employees in a hoist area shall be protected from falling 6 feet (1.8 m) or 

more to lower levels. 

Holes - employees on walking/working surfaces shall be protected from falling through holes 

(including skylights) more than 6 feet (1.8 m) above lower levels. Employees on a 

walking/working surface shall be protected from tripping in or stepping into or through holes 

(including skylights) Employees on a walking/working surface shall be protected from objects 

falling through holes (including skylights). 

Formwork and Reinforcing Steel - employees on the face of formwork or reinforcing steel shall 

be protected from falling 6 feet (1.8 m) or more to lower levels. 

Ramps Runways and Other Walkways - employees on ramps, runways, and other walkways shall 

be protected from falling 6 feet (1.8 m) or more to lower levels. 

Excavations - employees at the edge of an excavation 6 feet (1.8 m) or more in depth shall be 

protected from falling by guardrail systems, fences, or barricades when the excavations are not 

readily seen because of plant growth or other visual barrier. 

Wells, Pits and Shafts - employees at the edge of a well, pit, shaft, and similar excavation 6 feet 

(1.8 m) or more in depth shall be protected from falling. 

Work Above Dangerous Equipment - employees working less than 6 feet (1.8 m) above 

dangerous equipment shall be protected from falling into or onto the dangerous equipment 

Employees working 6 feet (1.8 m) or more above dangerous equipment shall be protected from 

fall hazards. 
Standard Operating Procedure Page 3 of 15 

Fall Protection 

 

Roof Work - employees engaged in roofing activities on low-slope roofs, with unprotected sides 

and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling. Employees 

on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall 

be protected from falling. 

Precast Concrete Erecetion - employees engaged in the erection of precast concrete members 

(including, but not limited to the erection of wall panels, columns, beams, and floor and roof 

"tees") and related operations such as grouting of precast concrete members, who are 6 feet (1.8 

m) or more above lower levels shall be protected from falling. 

Wall Openings - employees working on, at, above, or near wall openings (including those with 

chutes attached) where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more 

above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 m) 

above the walking/working surface, shall be protected from falling. 

Walking/ Working Surfaces Not Otherwise Addressed - employees on a walking/working surface 

6 feet (1.8 m) or more above lower levels shall be protected from falling 

3.0 DEFINITIONS 

Anchorage - means a secure point of attachment for lifelines, lanyards or deceleration devices. 

Body belt (safety belt) - means a strap with means both for securing it about the waist and for attaching it to a 

lanyard, lifeline, or deceleration device. 

Body harness - means straps which may be secured about the employee in a manner that will distribute the fall arrest 

forces over at least the thighs, pelvis, waist, chest and shoulders with means for attaching it to other components of a 

personal fall arrest system. 

Buckle - means any device for holding the body belt or body harness closed around the employee's body. 

Connector - means a device which is used to couple (connect) parts of the personal fall arrest system and positioning 

device systems together. It may be an independent component of the system, such as a carabiner, or it may be an 

integral component of part of the system (such as a buckle or dee-ring sewn into a body belt or body harness, or a 

snap-hook spliced or sewn to a lanyard or self-retracting lanyard). 

Controlled access zone (CAZ) - means an area in which certain work (e.g., overhand bricklaying) may take place 

without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is 

controlled. 

Dangerous equipment - means equipment (such as pickling or galvanizing tanks, degreasing units, machinery, 

electrical equipment, and other units) which, as a result of form or function, may be hazardous to employees who fall 

onto or into such equipment. 

Deceleration device - means any mechanism, such as a rope grab, rip-stitch lanyard, specially-woven lanyard, tearing 

or deforming lanyards, automatic self-retracting lifelines/lanyards, etc., which serves to dissipate a substantial 

amount of energy during a fall arrest, or otherwise limit the energy imposed on an employee during fall arrest. 

Deceleration distance - means the additional vertical distance a falling employee travels, excluding lifeline 

elongation and free fall distance, before stopping, from the point at which the deceleration device begins to operate. 
Standard Operating Procedure Page 4 of 15 

Fall Protection 

 

It is measured as the distance between the location of an employee's body belt or body harness attachment point at 

the moment of activation (at the onset of fall arrest forces) of the deceleration device during a fall, and the location 

of that attachment point after the employee comes to a full stop. 

Equivalent - means alternative designs, materials, or methods to protect against a hazard which the employer can 

demonstrate will provide an equal or greater degree of safety for employees than the methods, materials or designs 

specified in the standard. 

Failure - means load refusal, breakage, or separation of component parts. Load refusal is the point where the 

ultimate strength is exceeded. 

Free fall - means the act of falling before a personal fall arrest system begins to apply force to arrest the fall. 

Free fall distance - means the vertical displacement of the fall arrest attachment point on the employee's body belt or 

body harness between onset of the fall and just before the system begins to apply force to arrest the fall. This 

distance excludes deceleration distance, and lifeline/lanyard elongation, but includes any deceleration device slide 

distance or self-retracting lifeline/lanyard extension before they operate and fall arrest forces occur. 

Guardrail system - means a barrier erected to prevent employees from falling to lower levels. 

Hole - means a gap or void 2 inches (5.1 cm) or more in its least dimension, in a floor, roof, or other 

walking/working surface. 

Infeasible - means that it is impossible to perform the construction work using a conventional fall protection system 

(i.e., guardrail system, safety net system, or personal fall arrest system) or that it is technologically impossible to use 

any one of these systems to provide fall protection. 

Lanyard - means a flexible line of rope, wire rope, or strap which generally has a connector at each end for 

connecting the body belt or body harness to a deceleration device, lifeline, or anchorage. 

Leading edge - means the edge of a floor, roof, or formwork for a floor or other walking/working surface (such as 

the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or 

constructed. A leading edge is considered to be an "unprotected side and edge" during periods when it is not actively 

and continuously under construction. 

Lifeline - means a component consisting of a flexible line for connection to an anchorage at one end to hang 

vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), 

and which serves as a means for connecting other components of a personal fall arrest system to the anchorage. 

Low-slope roof - a roof having a slope less than or equal to 4 in 12 (vertical to horizontal). 

Lower levels - means those areas or surfaces to which an employee can fall. Such areas or surfaces include, but are 

not limited to, ground levels, floors, platforms, ramps, runways, excavations, pits, tanks, material, water, equipment, 

structures, or portions thereof. 

Mechanical equipment - means all motor or human propelled wheeled equipment used for roofing work, except 

wheelbarrows and mopcarts. 

Opening - means a gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide, in a wall or 

partition, through which employees can fall to a lower level. 

Overhand bricklaying and related work - means the process of laying bricks and masonry units such that the surface 

of the wall to be jointed is on the opposite side of the wall from the mason, requiring the mason to lean over the wall 

to complete the work. Related work includes mason tending and electrical installation incorporated into the brick 

wall during the overhand bricklaying process. 
Standard Operating Procedure Page 5 of 15 

Fall Protection 

 

Personal fall arrest system - means a system used to arrest an employee in a fall from a working level. It consists of 

an anchorage, connectors, a body belt or body harness and may include a lanyard, deceleration device, lifeline, or 

suitable combinations of these. As of January 1, 1998, the use of a body belt for fall arrest is prohibited. 

Positioning device system - means a body belt or body harness system rigged to allow an employee to be supported 

on an elevated vertical surface, such as a wall, and work with both hands free while leaning. 

Rope grab - means a deceleration device which travels on a lifeline and automatically, by friction, engages the 

lifeline and locks so as to arrest the fall of an employee. A rope grab usually employs the principle of inertial 

locking, cam/level locking, or both. 

Roof - means the exterior surface on the top of a building. This does not include floors or formwork which, because a 

building has not been completed, temporarily become the top surface of a building. 

"Roofing work" means the hoisting, storage, application, and removal of roofing materials and equipment, including 

related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck. 

Safety-monitoring system - means a safety system in which a competent person is responsible for recognizing and 

warning employees of fall hazards. 

Self-retracting lifeline/lanyard - means a deceleration device containing a drum-wound line which can be slowly 

extracted from, or retracted onto, the drum under slight tension during normal employee movement, and which, after 

onset of a fall, automatically locks the drum and arrests the fall. 

Snaphook - means a connector comprised of a hook-shaped member with a normally closed keeper, or similar 

arrangement, which may be opened to permit the hook to receive an object and, when released, automatically closes 

to retain the object. Snaphooks must be the self-closing, self-locking keeper which remains closed and locked until 

unlocked and pressed open for connection or disconnection. 

Steep roof - means a roof having a slope greater than 4 in 12 (vertical to horizontal). 

Toeboard - means a low protective barrier that will prevent the fall of materials and equipment to lower levels and 

provide protection from falls for personnel. 

Unprotected sides and edges - means any side or edge (except at entrances to points of access) of a walking/working 

surface, e.g., floor, roof, ramp, or runway where there is no wall or guardrail system at least 39 inches (1.0 m) high. 

Walking/working surface - means any surface, whether horizontal or vertical on which an employee walks or works, 

including, but not limited to, floors, roofs, ramps, bridges, runways, formwork and concrete reinforcing steel but not 

including ladders, vehicles, or trailers, on which employees must be located in order to perform their job duties. 

Warning line system - means a barrier erected on a roof to warn employees that they are approaching an unprotected 

roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, 

body belt, or safety net systems to protect employees in the area. 

Work area - means that portion of a walking/working surface where job duties are being performed. 

4.0 RESPONSIBILITY 

All WRS employees and subcontractor employees covered by this SOP are responsible for complying with its 

contents. Supervisors are responsible for implementing and enforcing the SOP and securing the resouces necessary 

to implement it. 
Standard Operating Procedure Page 6 of 15 

Fall Protection 

 

5.0 PROCEDURE 

5.1 TRAINING 

Employees with potential exposure to fall hazards shall receive training that will enable them to recognize the 

hazards of falling and implement procedures to be followed in order to minimize these hazards. 

Retraining will be performed when an employee who has already been trained does not have the understanding and 

skill required by paragraph to recognize and control fall hazards. Circumstances where retraining is required 

include, but are not limited to, situations where changes in the workplace render previous training obsolete, or 

changes in the types of fall protection systems or equipment to be used render previous training obsolete, or 

inadequacies in an employee's knowledge or use of fall protection systems or equipment indicate that the employee 

has not retained the requisite understanding or skill. 

Training shall be performed by a competent person qualified in the following areas: 

• The nature of fall hazards in the work area; 

• The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be 

used; 

• The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line 

systems, safety monitoring systems, controlled access zones, and other protection to be used; 

• The role of each employee in the safety monitoring system when this system is used; 

• The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped 

roofs; 

• The correct procedures for the handling and storage of equipment and materials and the erection of overhead 

protection; and 

• The role of employees in fall protection plans; 

• The applicable OSHA standards. 

A written certification record of employee training will be maintained. The written certification record shall contain 

the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who 

conducted the training. 

5.2 GUARDRAIL SYSTEMS 

The top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 

inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge may exceed the 

45-inch height, provided the guardrail system meets all other criteria of this paragraph. Note: When employees are 

using stilts, the top edge height of the top rail, or equivalent member, shall be increased an amount equal to the 

height of the stilts. 

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural members shall be 

installed between the top edge of the guardrail system and the walking/working surface when there is no wall or 

parapet wall at least 21 inches (53 cm) high. Midrails, when used, shall be installed at a height midway between the 

top edge of the guardrail system and the walking/working level. Screens and mesh, when used, shall extend from the 

top rail to the walking/working level and along the entire opening between top rail supports. 

Intermediate members (such as balusters), when used between posts, shall be not more than 19 inches (48 cm) apart. 

Other structural members (such as additional midrails and architectural panels) shall be installed such that there are 

no openings in the guardrail system that are more than 19 inches (.5 m) wide. 

Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied 

within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge. 
Standard Operating Procedure Page 7 of 15 

Fall Protection 

 

When the 200 pound (890 N) test load is applied in a downward direction, the top edge of the guardrail shall not 

deflect to a height less than 39 inches (1.0 m) above the walking/working level. Guardrail system components 

selected and constructed in accordance with the following specifications are deemed to meet this requirement. 

(1) For wood railings: Wood components shall be minimum 1500 lb-ft/in(2) fiber (stress grade) 

construction grade lumber; the posts shall be at least 2-inch by 4-inch (5 cm x 10 cm) lumber spaced not 

more than 8 feet (2.4 m) apart on centers; the top rail shall be at least 2-inch by 4-inch (5 cm x 10 cm) 

lumber, the intermediate rail shall be at least 1-inch by 6-inch (2.5 cm x 15 cm) lumber. All lumber 

dimensions are nominal sizes as provided by the American Softwood Lumber Standards, dated January 

1970. 

(2) For pipe railings: posts, top rails, and intermediate railings shall be at least one and one-half inches 

nominal diameter (schedule 40 pipe) with posts spaced not more than 8 feet (2.4 m) apart on centers. 

(3) For structural steel railings: posts, top rails, and intermediate rails shall be at least 2-inch by 2-inch (5 

cm x 10 cm) by 3/8-inch (1.1 cm) angles, with posts spaced not more than 8 feet (2.4 m) apart on centers. 

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members shall be 

capable of withstanding, without failure, a force of at least 150 pounds (666 N) applied in any downward or outward 

direction at any point along the midrail or other member. 

Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or lacerations, and to 

prevent snagging of clothing. The ends of all top rails and midrails shall not overhang the terminal posts, except 

where such overhang does not constitute a projection hazard. Steel banding and plastic banding shall not be used as 

top rails or midrails. Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diameter or thickness 

to prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-foot intervals 

with high-visibility material. Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected 

as frequently as necessary to ensure that it continues to meet strength requirements. 

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall be placed across 

the access opening between guardrail sections when hoisting operations are not taking place. 

When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of the hole. When 

guardrail systems are used around holes used for the passage of materials, the hole shall have not more than two 

sides provided with removable guardrail sections to allow the passage of materials. When the hole is not in use, it 

shall be closed over with a cover, or a guardrail system shall be provided along all unprotected sides or edges. When 

guardrail systems are used around holes which are used as points of access (such as ladderways), they shall be 

provided with a gate, or be so offset that a person cannot walk directly into the hole. 

Guardrail systems used on ramps and runways shall be erected along each unprotected side or edge. 

5.3 SAFETY NET SYSTEMS 

Safety nets shall be installed as close as practicable under the walking/working surface on which 

employees are working, but in no case more than 30 feet (9.1 m) below such level. When nets 

are used on bridges, the potential fall area from the walking/working surface to the net shall be 

unobstructed. 

Safety nets shall extend outward from the outermost projection of the work surface as follows: 

Vertical distance from working level to horizontal plane 

of net 

Minimum required horizontal distance of outer 

edge of net from the edge of the working 

surface 

Up to 5 feet 8 feet 
Standard Operating Procedure Page 8 of 15 

Fall Protection 

 

More than 5 feet up to 10 feet 10 feet 

More than 10 feet 13 feet 

Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface or structures 

below when subjected to an impact force equal to the drop test specified below. Safety nets and their installations 

shall be capable of absorbing an impact force equal to that produced by the drop test. 

Safety nets and safety net installations shall be drop-tested at the jobsite after initial installation and before being 

used as a fall protection system, whenever relocated, after major repair, and at 6-month intervals if left in one place. 

The drop-test shall consist of a 400 pound (180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter 

dropped into the net from the highest walking/working surface at which employees are exposed to fall hazards, but 

not from less than 42 inches (1.1 m) above that level. 

When it is unreasonable to perform the drop-test a designated competent person shall certify that the net and net 

installation is in compliance with the above listed specifications by preparing a certification record prior to the net 

being used as a fall protection system. The certification record must include an identification of the net and net 

installation for which the certification record is being prepared; the date that it was determined that the identified net 

and net installation were in compliance and the signature of the person making the determination and certification. 

The most recent certification record for each net and net installation shall be available at the jobsite for inspection. 

Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear, damage, and other 

deterioration. Defective components shall be removed from service. Safety nets shall also be inspected after any 

occurrence which could affect the integrity of the safety net system. 

Materials, scrap pieces, equipment, and tools which have fallen into the safety net shall be removed as soon as 

possible from the net and at least before the next work shift. 

The maximum size of each safety net mesh opening shall not exceed 36 square inches (230 cm) nor be longer than 6 

inches (15 cm) on any side, and the opening, measured center-to-center of mesh ropes or webbing, shall not be 

longer than 6 inches (15 cm). All mesh crossings shall be secured to prevent enlargement of the mesh opening. Each 

safety net (or section of it) shall have a border rope for webbing with a minimum breaking strength of 5,000 pounds 

(22.2 kN). Connections between safety net panels shall be as strong as integral net components and shall be spaced 

not more than 6 inches (15 cm) apart. 

5.4 PERSONAL FALL ARREST SYSTEMS 

Connectors in a fall arrest system shall be drop forged, pressed or formed steel, or made of equivalent materials. 

They shall have a corrosion-resistant finish, and all surfaces and edges shall be smooth to prevent damage to 

interfacing parts of the system. 

Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds (22.2 kN). Dee-rings and 

snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or 

taking permanent deformation. 

Snaphooks shall be the self closing, self locking type. 

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall not be engaged: 

• Directly to webbing, rope or wire rope; 

• To each other; 

• To a dee-ring to which another snaphook or other connector is attached; 

• To a horizontal lifeline; or 
Standard Operating Procedure Page 9 of 15 

Fall Protection 

 

• To any object which is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional 

disengagement could occur by the connected object being able to depress the snaphook keeper and release itself. 

On suspended scaffolds or similar work platforms with horizontal lifelines that may become vertical lifelines, the 

devices used to connect to a horizontal lifeline shall be capable of locking in both directions on the lifeline. 

Horizontal lifelines shall be designed, installed, and used, under the supervision of a qualified person, as part of a 

complete personal fall arrest system, which maintains a safety factor of at least two. 

Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds (22.2 kN). 

When vertical lifelines are used, each employee shall be attached to a separate lifeline. During the construction of 

elevator shafts, two employees may be attached to the same lifeline in the hoistway, provided both employees are 

working atop a false car that is equipped with guardrails; the strength of the lifeline is 10,000 pounds [5,000 pounds 

per employee attached] (44.4 kN); and all other criteria specified in this paragraph for lifelines have been met. 

Lifelines shall be protected against being cut or abraded. 

Self-retracting lifelines and lanyards which automatically limit free fall distance to 2 feet (0.61 m) or less shall be 

capable of sustaining a minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or 

lanyard in the fully extended position. Self-retracting lifelines and lanyards which do not limit free fall distance to 2 

feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum 

tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended 

position. 

Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and body harnesses 

shall be made from synthetic fibers. 

Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used 

to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or 

shall be designed, installed, and used as follows: 

• As part of a complete personal fall arrest system which maintains a safety factor of at least two; and 

• Under the supervision of a qualified person. 

Personal fall arrest systems, when stopping a fall, shall: 

• Limit maximum arresting force on an employee to 900 pounds (4 kN) when used with a body belt; 

• Limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness; 

• Be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level; 

• Bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet 

(1.07 m); and, 

• Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 

6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less. 

The attachment point of the body belt shall be located in the center of the wearer's back. The attachment point of the 

body harness shall be located in the center of the wearer's back near shoulder level, or above the wearer's head. 

Body belts, harnesses, and components shall be used only for employee protection (as part of a personal fall arrest 

system or positioning device system) and not to hoist materials. 

Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service 

and shall not be used again for employee protection until inspected and determined by a competent person to be 

undamaged and suitable for reuse. 
Standard Operating Procedure Page 10 of 15 

Fall Protection 

 

The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are 

able to rescue themselves. 

Personal fall arrest systems shall be inspected prior to each use for wear, damage and other deterioration, and 

defective components shall be removed from service. 

Body belts (to be used only as a positioning device) shall be at least one and five-eighths (1 5/8) inches (4.1 cm) 

wide. 

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to hoists except as 

specified in other subparts of this Part. 

When a personal fall arrest system is used at hoist areas, it shall be rigged to allow the movement of the employee 

only as far as the edge of the walking/working surface. 

5.5 POSITIONING DEVICE SYSTEMS 

Positioning device systems and their use shall conform to the following provisions: 

Positioning devices shall be rigged such that an employee cannot free fall more than 2 feet (.9 m). 

Positioning devices shall be secured to an anchorage capable of supporting at least twice the potential impact load of 

an employee's fall or 3,000 pounds (13.3 kN), whichever is greater. 

Connectors used with positioning device systems shall be drop forged, pressed or formed steel, or made of 

equivalent materials. Connectors shall have a corrosion-resistant finish, and all surfaces and edges shall be smooth 

to prevent damage to interfacing parts of this system. 

Connecting assemblies shall have a minimum tensile strength of 5,000 pounds (22.2 kN) 

Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, 

breaking, or taking permanent deformation. 

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent unintentional 

disengagement of the snaphook by depression of the snaphook keeper by the connected member, or shall be a 

locking type snaphook designed and used to prevent disengagement of the snaphook by the contact of the snaphook 

keeper by the connected member. As of January 1, 1998, only locking type snaphooks shall be used. 

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall not be engaged: 

• Directly to webbing, rope or wire rope; 

• To each other; 

• To a dee-ring to which another snaphook or other connector is attached; 

• To a horizontal lifeline; or 

• To any object which is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional 

Disengagement could occur by the connected object being able to depress the snaphook keeper and release 

itself. 

Positioning device systems shall be inspected prior to each use for wear, damage, and other deterioration, and 

defective components shall be removed from service. 

Body belts, harnesses, and components shall be used only for employee protection (as part of a personal fall arrest 

system or positioning device system) and not to hoist materials. 
Standard Operating Procedure Page 11 of 15 

Fall Protection 

 

5.6 WARNING LINE SYSTEMS 

Warning line systems and their use shall comply with the following provisions: 

• The warning line shall be erected around all sides of the roof work area. 

• When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) 

from the roof edge. 

• When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the 

roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) 

from the roof edge which is perpendicular to the direction of mechanical equipment operation. 

• Points of access, materials handling areas, storage areas, and hoisting areas shall be connected to the work area 

by an access path formed by two warning lines. 

• When the path to a point of access is not in use, a rope, wire, chain, or other barricade, equivalent in strength 

and height to the warning line, shall be placed across the path at the point where the path intersects the warning 

line erected around the work area, or the path shall be offset such that a person cannot walk directly into the 

work area. 

• Warning lines shall consist of ropes, wires, or chains, and supporting stanchions erected as follows: 

• The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with high-visibility material; 

• The rope, wire, or chain shall be rigged and supported in such a way that its lowest point (including sag) is no 

less than 34 inches (.9 m) from the walking/working surface and its highest point is no more than 39 inches (1.0 

m) from the walking/working surface; 

• After being erected, with the rope, wire, or chain attached, stanchions shall be capable of resisting, without 

tipping over, a force of at least 16 pounds (71 N) applied horizontally against the stanchion, 30 inches (0.8 m) 

above the walking/working surface, perpendicular to the warning line, and in the direction of the floor, roof, or 

platform edge; 

• The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and after being 

attached to the stanchions, shall be capable of supporting, without breaking, the loads applied to the stanchions 

described above; and 

• The line shall be attached at each stanchion in such a way that pulling on one section of the line between 

stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over. 

• No employee shall be allowed in the area between a roof edge and a warning line unless the employee is 

performing roofing work in that area. 

• Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a 

warning line system, guardrail system, or personal fall arrest system. 

5.7 CONTROLLED ACCESS ZONES 

Controlled access zones and their use shall conform to the following provisions. 

When used to control access to areas where leading edge and other operations are taking place, the controlled access 

zone shall be defined by a control line or by any other means that restricts access. When control lines are used, they 

shall be erected not less than 6 feet (1.8 m) nor more than 25 feet (7.7 m) from the unprotected or leading edge, 

except when erecting precast concrete members. 

When erecting precast concrete members, the control line shall be erected not less than 6 feet (1.8 m) nor more than 

60 feet (18 m) or half the length of the member being erected, whichever is less, from the leading edge. The control 

line shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the 

unprotected or leading edge. The control line shall be connected on each side to a guardrail system or wall. 

When used to control access to areas where overhand bricklaying and related work are taking place: 
Standard Operating Procedure Page 12 of 15 

Fall Protection 

 

• The controlled access zone shall be defined by a control line erected not less than 10 feet (3.1 m) nor more than 

15 feet (4.5 m) from the working edge. 

• The control line shall extend for a distance sufficient for the controlled access zone to enclose all employees 

performing overhand bricklaying and related work at the working edge and shall be approximately parallel to the 

working edge. 

• Additional control lines shall be erected at each end to enclose the controlled access zone. 

• Only employees engaged in overhand bricklaying or related work shall be permitted in the controlled access 

zone. 

Control lines shall consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions as follows: 

• Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with highvisibility material. 

• Each line shall be rigged and supported in such a way that its lowest point (including sag) is not less than 39 

inches (1 m) from the walking/working surface and its highest point is not more than 45 inches (1.3 m) [50 

inches (1.3 m) when overhand bricklaying operations are being performed] from the walking/working surface. 

• Each line shall have a minimum breaking strength of 200 pounds (.88 kN). 

On floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying 

operations, controlled access zones shall be enlarged, as necessary, to enclose all points of access, material handling 

areas, and storage areas. On floors and roofs where guardrail systems are in place, but need to be removed to allow 

overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to 

accomplish that day's work shall be removed. 

5.8 SAFETY MONITORING SYSTEMS 

Safety monitoring systems and their use shall comply with the following provisions. 

The employer shall designate a competent person to monitor the safety of other employees and the employer shall 

ensure that the safety monitor complies with the following requirements: 

• The safety monitor shall be competent to recognize fall hazards; 

• The safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard or is 

acting in an unsafe manner; 

• The safety monitor shall be on the same walking/working surface and within visual sighting distance of the 

employee being monitored; 

• The safety monitor shall be close enough to communicate orally with the employee; and 

• The safety monitor shall not have other responsibilities which could take the monitor's attention from the 

monitoring function. 

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to 

monitor employees engaged in roofing operations on low-slope roofs. 

No employee, other than an employee engaged in roofing work [on low-sloped roofs] or an employee covered by a 

fall protection plan, shall be allowed in an area where an employee is being protected by a safety monitoring system. 

Each employee working in a controlled access zone shall be directed to comply promptly with fall hazard warnings 

from safety monitors. 

5.9 COVERS 

Covers for holes in floors, roofs, and other walking/working surfaces shall meet the following requirements: 
Standard Operating Procedure Page 13 of 15 

Fall Protection 

 

• Covers located in roadways and vehicular aisles shall be capable of supporting, without failure, at least twice the 

maximum axle load of the largest vehicle expected to cross over the cover. 

• All other covers shall be capable of supporting, without failure, at least twice the weight of employees, 

equipment, and materials that may be imposed on the cover at any one time. 

• All covers shall be secured when installed so as to prevent accidental displacement by the wind, equipment, or 

employees. 

• All covers shall be color coded or they shall be marked with the word "HOLE" or "COVER" to provide warning 

of the hazard. Note: This provision does not apply to cast iron manhole covers or steel grates used on streets or 

roadways. 

5.10 PROTECTION FROM FALLING OBJECTS 

Falling object protection shall comply with the following provisions: 

• Toeboards, when used as falling object protection, shall be erected along the edge of the overhead 

walking/working surface for a distance sufficient to protect employees below. 

• Toeboards shall be capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any 

downward or outward direction at any point along the toeboard. 

• Toeboards shall be a minimum of 3 1/2 inches (9 cm) in vertical height from their top edge to the level of the 

walking/working surface. They shall have not more than 1/4 inch (0.6 cm) clearance above the walking/working 

surface. They shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. 

Where tools, equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall be 

erected from the walking/working surface or toeboard to the top of a guardrail system's top rail or midrail, for a 

distance sufficient to protect employees below. 

Guardrail systems, when used as falling object protection, shall have all openings small enough to prevent passage of 

potential falling objects. 

During the performance of overhand bricklaying and related work: 

• No materials or equipment except masonry and mortar shall be stored within 4 feet (1.2 m) of the working edge. 

• Excess mortar, broken or scattered masonry units, and all other materials and debris shall be kept clear from the 

work area by removal at regular intervals. 

During the performance of roofing work: 

• Materials and equipment shall not be stored within 6 feet (1.8 m) of a roof edge unless guardrails are erected at 

the edge. 

• Materials which are piled, grouped, or stacked near a roof edge shall be stable and self-supporting. 

Canopies, when used as falling object protection, shall be strong enough to prevent collapse and to prevent 

penetration by any objects which may fall onto the canopy. 

5.11 FALL PROTECTION PLANS 

This option is available only to employees engaged in leading edge work, precast concrete erection work, or 

residential construction work who can demonstrate that it is infeasible or it creates a greater hazard to use 

conventional fall protection equipment. The fall protection plan must conform to the following provisions. 

The fall protection plan shall be prepared by a qualified person and developed specifically for the site where the 

leading edge work, precast concrete work, or residential construction work is being performed and the plan must be 
Standard Operating Procedure Page 14 of 15 

Fall Protection 

 

maintained up to date. Any changes to the fall protection plan shall be approved by a qualified person. A copy of 

the fall protection plan with all approved changes shall be maintained at the job site. The implementation of the fall 

protection plan shall be under the supervision of a competent person. 

The fall protection plan shall document the reasons why the use of conventional fall protection systems (guardrail 

systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater 

hazard. 

The fall protection plan shall include a written discussion of other measures that will be taken to reduce or eliminate 

the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems. 

For example, the employer shall discuss the extent to which scaffolds, ladders, or vehicle mounted work platforms 

can be used to provide a safer working surface and thereby reduce the hazard of falling. 

The fall protection plan shall identify each location where conventional fall protection methods cannot be used. 

These locations shall then be classified as controlled access zones and operated accordingly. 

Where no other alternative measure has been implemented, a safety monitoring system shall be implemented. 

The fall protection plan must include a statement which provides the name or other method of identification for each 

employee who is designated to work in controlled access zones. No other employees may enter controlled access 

zones. 

In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) an investigation of 

the circumstances of the fall or other incident shall be performed to determine if the fall protection plan needs to be 

changed (e.g. new practices, procedures, or training) and shall implement those changes to prevent similar types of 

falls or incidents. 

6.0 REFERENCES

• 29 CFR 1926 Subpart M – 

• http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1926_SUBPART_M.html

7.0 ATTACHMENTS

None 

8.0 RECORD KEEPING

• Employee training certifications 

• Inspections of Safety Nets (when applicable) 

• Fall protection plans (when applicable) 

9.0 EQUIPMENT

• Personal fall arrest system components 
 
WRS Infrastructure & Environment, Inc.
Attachment F 

Scope A- Lower Manhattan Cleaning Procedures 
 1

World Trade Center Indoor Dust Cleaning Program 

 

Scope of Work A

Application: These procedures apply to the cleaning of minimal dust accumulations (light 

coating). If a visual inspection indicates the presence of significant accumulations of dust and/or 

debris from the collapse of the WTC in residences or common spaces (including elevator shafts), 

Scope B procedures shall be applied (refer to Scope of Work B). Residents may be present 

during Scope A cleaning procedures. 

1. Cleaning of Common Spaces 

Common spaces including hallways, stairways and the interior of elevator cars shall be 

cleaned, if requested by the building owner. The Monitoring Contractor in consultation 

with EPA, or EPA’s designee will evaluate and determine if other common areas 

including utility rooms, laundry rooms, compactor rooms, elevator shafts require 

cleaning. Work will begin from the entrance and continue through all common spaces in 

an orderly fashion. A detailed description of the minimum cleaning requirements for 

common space is as follows: 

a. Vacuuming will begin with the ceiling, continue down the walls and include 

floors. A vacuum equipped with a motorized agitator bar will be used to vacuum 

carpets. 

b. Impermeable walls and floors will be wet wiped, after consultation with and 

approval by owner. Wet wiping will not be conducted if it is determined that it 

would cause damage to the surface. 

c. Carpets will be cleaned with a water extraction cleaner after consultation with and 

approval by owner. After cleaning, red rosin construction paper will be applied to 

high traffic areas to protect carpets from soiling. Water extraction cleaning will 

not be conducted if it would cause damage to the carpet. 

d. Surfaces that are not cleaned by wet methods (wet wiping and water extraction 

cleaner) will be vacuumed two times. 

2. Cleaning of HVAC Systems 

HVAC systems that are determined by the Monitoring Contractor to be impacted by dust 

or debris from the collapse of the World Trade Center will be cleaned in accordance with 

the site-specific scope of work prepared by the Monitoring Contractor and approved by 

EPA. HVAC systems cleaning, if warranted, shall be completed prior to the initiation of 

the cleaning of common space or residences within an affected building. In the event that 

the HVAC system for an entire building requires cleaning, a separate, site specific 

contract will be awarded by DEP for this work. If only a portion of an HVAC system 

requires cleaning, then the cleaning contractor will conduct the cleaning utilizing 

specialized labor trained and experienced in duct cleaning. 

HVAC cleaning shall be conducted in accordance with National Air Duct Cleaners 
 2

Association (NADCA) General Specification for the Cleaning of Commercial Heating, 

Ventilating and Air Conditioning Systems and the NADCA Assessment, Cleaning and 

Restoration Standard (ACR 2002). Verification of the effectiveness of HVAC system 

cleaning will be determined by the Monitoring Contractor. If dust or other contaminants 

are evident through visual inspection, those portions of the system where dust or other 

contaminants are present shall be re-cleaned and subjected to re-inspection for 

cleanliness. If the cleaning contractor is not a member of the NADCA, a subcontractor 

that is a member may perform this portion of the work. 

 

3. Cleaning of Residential Spaces 

Residences will be cleaned using HEPA vacuums, water extraction cleaners and wet 

wiping as described below. Surfaces to be cleaned include but are not limited to walls, 

floors, ceilings, ledges, trims, furnishings, appliances, equipment, etc. Encapsulating 

agents shall not be applied. Dry sweeping is prohibited. The cleaning contractor will not 

clean inside of drawers, cabinets, breakfronts and similar enclosed storage or display 

pieces, however, the exterior of these pieces will be cleaned. Cleaning of clothing and 

accessories (handbags, shoes etc.) shall be the responsibility of the occupant. A detailed 

description of the minimum cleaning requirements is as follows: 

a. Terraces, balconies, exterior window sills, window wells and window guards that 

are accessible from the interior of the dwelling, shall be cleaned. 

b. Interior windows, screens, window sills and window guards will be cleaned 

c. Vacuuming will begin with the ceiling, continue down the walls and include the 

floor. A vacuum equipped with a motorized agitator bar will be used to vacuum 

carpets. 

d. Impermeable walls and floors will be wet wiped, after consultation with and 

approval by owner/resident. Wet wiping will not be conducted if it is determined 

that it would cause damage to the surface. 

e. Carpets will be cleaned with a water extraction cleaner after consultation with and 

approval by owner/resident. After cleaning, red rosin construction paper will be 

applied to high traffic areas to protect carpets from soiling. Water extraction 

cleaning will not be conducted if it would cause damage to the carpet. 

f. Fabric covered furniture will be vacuumed and then cleaned with a water 

extractions cleaner after consultation with and if approved by owner/resident. 

Water extraction cleaning will not be conducted if it would cause damage to the 

furniture. 

g. All surfaces including but not limited to floors, walls, curtains, fabric window 

treatments, upholstery and other materials that are not cleaned by wet methods 

(wet wiping and water extraction cleaning) will be HEPA vacuumed two times. 

Fabric covered furniture that is not cleaned by wet methods will be vacuumed 

using an appropriate brush attachment. 

h. Intake/discharge registers of HVAC systems (if present) will be removed/cleaned. 

The first foot of duct work will also be vacuumed; then the register will be 

reinstalled and covered with a layer of 6 mil polyethylene sheeting. 

i. Window and room air conditioners will be vacuumed, wet wiped and removed 
 3

from their housing to allow access to internal portions of the air conditioner. The 

internal portions of the air conditioner and housing will then be vacuumed. Filters 

will be vacuumed and reinstalled. Air conditioners will be reassembled and 

reinstalled after cleaning. 

j. Paperwork and books will be HEPA-vacuumed. 

k. Electrical outlets will be vacuumed. 

l. Appliances such as refrigerators and stoves will be cleaned and moved. The floor 

footprint of the appliances will be cleaned and the appliance will be reinstalled in 

their original positions. 

m. Refrigerator cooling tubes will be brushed and vacuumed. 

n. The first foot of all exhaust duct work (including stove, dryer and bathroom vents) 

where accessible, will be vacuumed. Exhaust fans will be vacuumed and wiped 

o. Unobstructed closet floors will be vacuumed. 

p. Solid objects (electrical equipment, exercise equipment, etc.) will be wet wiped, 

moved to allow cleaning of the underlying surface and will be returned to their 

original location. 

q. Dishwasher toe plates will be removed and the floor beneath the appliance will be 

cleaned. 

r. Baseboard heaters will be cleaned. Protective covers on finned radiant heaters and 

baseboard heaters will be removed to expose heat elements. Fins are to be 

brushed and vacuumed to remove dust. 

s. All cleaning equipment will be vacuumed and/or wet wiped after completion of 

the cleaning and before removal from the work area. 

 

4. HEPA air filtration devices (AFDs) will run continuously during all cleaning activities, as

appropriate given site conditions. AFDs shall be installed and operated to provide a 

minimum of one air change every 15 minutes. Make up air should be derived from a 

non-impacted source (i.e. open window or common spaces previously cleaned). 

5. A minimum of one asbestos supervisor shall be present in each building during work. 

 

6. A Cleaning Checklist (to be developed by EPA) will be completed by the cleaning 

contractor as tasks are completed to document the progress of the cleaning. 

7. The cleaning contractor shall notify the monitoring contractor immediately upon 

completion of the cleaning. The Monitoring Contractor will conduct a thorough visual 

inspection to verify the absence of visible dust accumulations. If dust is observed the 

cleaning contractor will re-clean as necessary at no additional cost. 

8. Air sampling shall be performed by the Monitoring Contractor after the area is free of 

dust accumulations as determined by the Monitoring Contractor. The residence will be 

re-cleaned and re-tested if the clean-up criteria of 0.0009 fibers/cc (PCME measured by 

TEM) is not achieved or if determined necessary by EPA. This clean-up criterion may be 

reevaluated and revised, if determined necessary based on field conditions and analytical 
 4

limitations. 

9. Any damage or loss that occurs during cleaning is the responsibility of the cleaning 

contractor. The cleaning contractor is not responsible for damage or loss caused by the 

acts of third parties not involved in the cleaning activities. 

10. Owner/residents may identify and tag certain furnishings (e.g. carpets and fabric covered 

furniture) for disposal rather than cleaning. Disposal of residents’ personal property shall 

not occur without prior written authorization by the owner. 

11. Disposal of all wastes generated during the cleaning shall be the responsibility of the 

contractor. All waste generated shall be treated as asbestos-containing material (ACM). 

Transportation and disposal of generated waste shall be in compliance with all applicable 

rules and regulations. 

12. If mold or peeling, flaking or chalking paint is observed in the work area, the cleaning 

contractor shall immediately contact the Monitoring Contractor. 

 

13. If in-place materials suspected to contain asbestos are observed the Cleaning Contractor 

shall immediately notify the Monitoring Contractor. The Monitoring Contractor will 

evaluate the condition of the material to identify damaged, deterioration, delamination, 

etc. The Cleaning Contractor shall wrap suspect ACM that is in good or excellent 

condition with 6-mil polyethylene sheeting and seal airtight with duct tape or equivalent 

method prior to cleaning or air monitoring. 

14. In the event that damaged, deteriorated, delaminated, etc. suspected ACM is observed, 

the Cleaning Contractor will notify the Monitoring Contractor. Cleaning or air 

monitoring will not proceed in areas where such suspected ACM is observed until 

instructed otherwise. 
Attachment H 

Synopsis of Cleaning Methods by Building Area and Fact Sheets 
 Study and Non-Study 

19 

Basement Areas

Elevator Shaft and Motor Room, Trash Compactor Room, Fire Equipment Room. 

Cleaning Method: Test 4A – Surface cleaning using industrial HEPA filtered vacuums. 

Air filtration using an air filtration device (AFD). 

Equipment Used: NilfiskTM Vacuum (CFM 127) 

Filtration status: HEPA 

Common Area Size: 642 sq. ft.; 5,136 cu. ft. (Total of all areas, elevator shaft not 

included.)

AFD Status: Required

AFD specification when required: 400/600 cfm 

Unit air exchange rate: 12.8 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Description: Basement areas include: A trash compactor room, an equipment room 

containing the building fire protection controls to the ceiling sprinkler system, a motor control 

room for the elevator, and access to the elevator shaft containing the elevator compartment, as 

well as a common room which provided access to all the above areas. These basement areas are 

accessed through an outside stairwell located in the Cedar Street sidewalk. 

The floors are constructed of concrete. The walls are composed of painted concrete block or 

brick. The elevator shaft floor is compacted soil. The shaft walls are composed of mortar and 

brick. Floor joists and decking of the first floor constitute the ceiling of the basement areas. All 

basement areas appeared to have been hose washed. No significant dust was present. With the 

exception of the ceiling materials, no porous materials were present. Debris such as cardboard 

boxes, used hydraulic oil, rags, discarded elevator parts, and dead rodents were disposed of prior 

to cleanup. The elevator shaft was inspected from the fifth floor to the below grade location 

when access was provided by the elevator contractor. The vertical wall surfaces of the shaft were 

constructed of brick and mortar and presented no visible dust down to the second floor. The 

lower section in the elevator shaft contained sand accumulation from natural deterioration. The 

exposed brick under the elevator framework, to a height of approximately six feet from the 

bottom of the shaft, was encrusted with mud, indicating a high water line some time during the 

building history. 

Difficult Areas Encountered: 

None 

 
 Non-Study 

20 

Lemongrass Grill

1st Floor and basement, Cedar & Liberty Streets 

Cleaning Method: Test 4A - Surface cleaning using industrial HEPA filtered vacuums. Area air filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all 

horizontal surfaces. Test 4D – A/C Duct Cleaning

Equipment Used: NilfiskTM Vacuum (CFM 127), AFD 

Filtration Status: HEPA 

Unit Size: 1st floor: 2,451 sq. ft.; 33,134 cu. ft.; basement: 1,080 sq. ft.; 9,720 cu. ft. 

AFD Status: Required

AFD Specification: 1000/2000 cfm 

Unit Air Exchange Rate: 1st floor: 16.56 min @ 2,000 cfm; basement: 9.72 min @ 1000 

cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: The restaurant encompasses approximately 3,500 square feet. It has 

entrances on both Cedar and Liberty Streets. The establishment is comprised of two floors. The 

first floor is at street level and was used for food service and customer dining. The lower level 

(basement) was used for food preparation and storage. Gypsum ceilings and hard wood floors are 

present throughout the dining area. Wood floor joists from the first floor constitute the basement 

ceiling. The floor is concrete. The dining area is decorated with typical Thai accents consisting 

of bamboo, and thatch. Grills, ovens, refrigerators, tables, chairs and a bar are on the first floor. 

The basement contains a walk-in refrigerator, freezers, preparation table, a dishwasher and dry 

good storage. The establishment’s HVAC system is suspended from the ceiling of the first floor. 

All exterior windows facing the WTC were blown inward depositing significant amounts of dust 

on all surfaces of the first floor. Minimal dust was present in the basement. Prior to cleaning all 

tables, chairs, containerized food and accent decorations were disposed of. Restaurant 

equipment including woks, utensils, pots, pans, and flatware were vacuumed and washed. 

Bottles of liquor were washed and removed by the owner. 

The establishment has one HVAC system. This system provides heating and cooling to the 

dining area via solid metal supply ducts. The system’s return is located in the dining area. A 

second system provides outdoor makeup air to the cooking stations. Cleaning of this system was 

performed in accordance with the site-specific HVAC cleaning procedures prepared by Covino 

Environmental Associates Inc. 
 Study 

12 

Unit 5C - 5th floor, Northwest corner, Liberty Street

Cleaning Method: Test 3A - Surface cleaning with industrial HEPA filtered vacuums. 

Area air filtration not required. Soap and water wet wipe of all horizontal surfaces. 

Test 3B - Surface cleaning with industrial HEPA filtered vacuums. Area air filtration utilizing 

an air filtration device (AFD). Soap and water wet wipe of all horizontal surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127) 

Filtration Status: HEPA

Unit Size: 968 sq. ft.; 10,648 cu. ft. 

AFD Status: Not Required 

AFD Specification: N/A 

Unit Air Exchange Rate: 26.62 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes

Unit Description: This 968 sq. ft. loft facing the WTC site has three bedrooms. The unit has 

hardwood floors and no carpeting. All exterior windows had been blown inward. Significant 

dust and debris had accumulated in the dwelling. All personal items, with the exception of fabric 

covered furniture, were disposed of prior to cleaning. 

Difficult Areas Encountered: 

• Hydronic baseboard heating units 

• Boarded up window openings 

• Cracks and crevices 

• The fourth cleaning was necessary as a result of sawdust and debris deposited in areas 

previously cleaned, by a carpentry crew installing new hardwood flooring. This cleaning 

was conducted using the Test 3B cleaning method. 
 Study 

11 

Unit 5A - 5th floor, Northeast corner, Cedar Street 

Cleaning Method: Test 3B - Surface cleaned using industrial HEPA filtered vacuums. 

Area air filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all 

horizontal surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127) AFD 

Filtration Status: HEPA 

Unit Size: 1,404 sq. ft.; 15,444 cu. ft.

AFD Status: Required 

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 25.74 min @ 600 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 1,404 sq. ft. loft faces Cedar Street and has one bedroom. The unit 

has hardwood floors and no carpeting. It had one damaged window. The dwelling was fully 

furnished and had many personal items all of which were vacuumed, bagged and retained for the 

tenant. Minimal dust was present in the dwelling except for baseboard heating elements and 

window sash frames. 

Difficult Areas Encountered: 

• Owner’s possessions required significant effort 

• Exterior windows and sashes 

• Hydronic baseboard heating units 

• Cracks and crevices 
 Study 

10 

Unit 4D - 4th Floor, Northeast corner, Liberty Street 

Cleaning Method: Test 2A - Surface cleaning using HEPA filtered vacuums. Air filtration 

not required. Soap and water wet wipe of all horizontal surfaces 

Equipment Used: Craftsman® Shop Vacuum, Hoover® Upright Vacuum 

Filtration Status: HEPA 

Unit Size: 968 sq. ft.; 9,196 cu. ft. 

AFD Status: Not Required 

AFD Specifications: N/A

Unit Air Exchange Rate: 22.99 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 968 sq. ft. open loft faces the WTC site. The unit has hardwood 

floors and no carpeting. All exterior windows had been blown inward. Significant dust had 

accumulated in the dwelling. All personal possessions to be retained by the tenant were 

vacuumed and bagged. 

Difficult Areas Encountered: 

• Exterior windows and sashes 

• Hydronic baseboard heating units 

• Boarded window openings 

• Cracks and crevices 

• Tenant possessions required special attention
 Study 

9 

Unit 4C - 4th Floor, Northwest corner, Liberty Street 

Cleaning Method: Test 1A - Surface cleaning using non-HEPA filtered vacuums. Area air 

filtration not required. Soap and water wet wipe of all horizontal surfaces. 

Equipment Used: Eureka® Upright Vacuum, Craftsman® Shop Vacuum

Filtration Status: No HEPA 

Unit Size: 655 sq. ft.; 6,222 cu. ft. 

AFD Status: Not Required

AFD Specification: N/A 

Unit Air Exchange Rate: 15.55 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 655 sq. ft. open loft faces the WTC site. The unit has hardwood 

flooring and no carpeting. All exterior windows had been blown inward. Significant dust had 

accumulated in the dwelling. All personal possessions to be retained by the tenant were 

vacuumed and bagged.

Difficult Areas Encountered: 

• Exterior windows and sashes 

• Hydronic baseboard heating units 

• Boarded window openings 

• Cracks and crevices 
 Study 

8 

Unit 4B - 3rd Floor, Southeast corner, Cedar Street

Cleaning Method: Test 2B - Surface cleaning using HEPA filtered vacuums. Air 

filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all horizontal 

surfaces. 

Equipment Used: Ridgid® Shop Vacuum, Hoover® Upright Vacuum, AFD. 

Filtration Status: HEPA 

Unit Size: 968 sq. ft.; 10,164 cu. ft. 

AFD Status: Required 

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 22.99 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 968 sq. ft. loft facing Cedar Street has four bedrooms. The unit has 

hardwood floors and no carpeting. All exterior windows were intact. The bedrooms were 

temporary structures built of particle board which were dismantled prior to cleaning. Minimal 

dust was present in the dwelling, except for baseboard heating elements and window sash 

frames. 

Difficult Areas Encountered: 

• Exterior windows and sashes

• Hydronic baseboard heating units 

• Cracks and crevices 
 Study 

7 

Unit 4A - 4th Floor, Southeast corner, Cedar Street 

Cleaning Method: Test 2A - Surface cleaning using HEPA filtered vacuums. Area air 

filtration not required. Soap and water wet wipe of all horizontal surfaces. 

Equipment Used: Hoover® Upright Vacuum, Craftsman® Shop Vacuum 

Filtration Status: HEPA 

Unit Size: 1,368 sq. ft.; 12,996 cu. ft. 

AFD Status: Not Required

AFD Specification: N/A 

Unit Air Exchange Rate: 21.66 min @ 600 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 1,368 sq. ft. open loft faces Cedar Street. The unit has hardwood 

floors and no carpeting. All exterior windows were intact. Minimal dust was present in the 

dwelling, except for the baseboard heating elements and window sash frames. All personal and 

business possessions to be retained by the tenant were vacuumed and bagged. 

Difficult Areas Encountered: 

• Dwelling used as a business for dressmaking, which resulted in cleaning of excessive 

amounts of personal and business related items.

• Exterior windows and sashes 

• Hydronic baseboard heating units 

• Appliances dirty with encrusted grease 
 Study 

6 

Unit 3D - 3rd floor, Northeast corner, Liberty Street 

Cleaning Method: Test 1A - Surface cleaning using non-HEPA filtered vacuums. Area 

air filtration not required. Soap and water wet wipe of all horizontal surfaces. 

Equipment Used: Hoover® Upright Vacuum, Ridgid® Shop Vacuum 

Filtration Status: No HEPA 

Unit Size: 968 sq. ft.; 10,164 cu. ft. 

AFD Status: Not Required

AFD Specification: N/A 

Unit Air Exchange Rate: 25.41 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 968 sq. ft. loft with three bedrooms faces the WTC site. The unit has 

hardwood floors and no carpeting. All exterior windows had been blown inward. Significant 

dust had accumulated in the dwelling. All personal items, with the exception of fabric-covered 

furniture and three pieces of hardwood furniture, were disposed of prior to cleaning. 

Difficult Areas Encountered: 

• Hydronic baseboard heating units 

• Boarded window openings 

• Cracks and crevices
 Study 

5 

Unit 3C - 3rd floor, Northwest corner, Liberty Street

Cleaning Method: Test 1A - Surface cleaning using non-HEPA filtered vacuums. Area air 

filtration not required. Soap and water wet wipe of all horizontal and vertical surfaces. 

Test 3B - Surface cleaning with industrial HEPA filtered vacuums. Area air filtration utilizing 

an air filtration device (AFD). Soap and water wet wipe of all horizontal and vertical surface. 

Equipment Used: Eureka® Upright Vacuum, Craftsman® Shop Vacuum 

Filtration Status: No HEPA 

Unit Size: 655 sq. ft.; 6,877 cu. ft. 

AFD Status: Not Required

AFD Specification: N/A 

Unit Air Exchange Rate: 17.19 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 655 sq. ft. loft with two bedrooms faces the WTC site. The unit has 

hardwood floors and no carpeting. All exterior windows had been blown inward. Significant 

dust had accumulated in the dwelling. All personal items with, the exception of fabric-covered 

furniture, were disposed of prior to cleaning. 

 

Difficult Areas Encountered: 

• Hydronic baseboard heating units 

• Boarded window openings 

• Cracks and crevices 
 Study 

4 

Unit 3B - 3rd floor, Southwest corner, Cedar Street 

Cleaning Method: Scope A - Lower Manhattan Cleaning Procedure - Surface 

cleaning using industrial HEPA filtered vacuums. Area air filtration utilizing an air filtration 

device (AFD). Soap and water wet wipe of all horizontal and vertical surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127), AFD 

Filtration Status: HEPA 

Unit Size: 968 sq. ft.; 10,164 cu. ft. 

AFD Status: Required

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 25.41 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 968 sq. ft. loft facing Cedar Street has three bedrooms. All personal 

items including clothing, kitchenware, books, furniture, and electronic devices were cleaned 

since the tenants plan to reoccupy the unit. Mattresses and carpets were disposed of. All 

exterior windows were intact. Minimal dust was present in the space, except for baseboard 

heating elements and window sash frames. 

Difficult Areas Encountered: 

• Exterior windows and sashes 

• Hydronic baseboard heating units 

• Cleaning of small items including CD’s, tapes, clothes, shoes, kitchenware, etc. 

• Cracks and crevices
 Study 

2 

Unit 2B - 2nd floor, Southwest corner, Cedar Street 

Cleaning Method: Test 3A - Surface cleaning using industrial HEPA filtered vacuums. 

Area air filtration not required. Soap and water wet wipe of all horizontal surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127) 

Filtration Status: HEPA 

Unit Size: 946 sq. ft.; 9,460 cu. ft. 

AFD Status: Not Required

AFD Specifications: N/A 

Unit Air Exchange Rate: 23.65 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 946 sq. ft. loft facing Cedar Street has two bedrooms. The unit 

contains hardwood floors and no carpeting. All exterior windows were intact. Minimal dust was 

present in the dwelling except for baseboard heating elements and window sash frames. All 

personal items, with the exception of fabric-covered furniture, were disposed of prior to cleaning. 

Difficult Areas Encountered: 

• Exterior windows and sashes

• Hydronic baseboard heating units

• Cracks and crevices 
 

 Study 

 1 

Unit 2A – 2nd floor, Southeast corner, Cedar Street 

Cleaning Method: Test 1B - Surface cleaning using non-HEPA filtered vacuums. Area air 

filtratation utilizing an air filtration device (AFD). Soap and water wet wipe of all horizontal 

surfaces. 

Equipment Used: Hoover® Upright, Ridgid® Shop Vacuum, AFD.

Filtration Status: No HEPA 

Unit Size: 1,335 sq. ft.; 13,350 cu. ft. 

AFD Status: Required

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 22.25 min @ 600 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 1,335 sq. ft. loft facing Cedar Street has two bedrooms. The unit has 

hardwood floors and no carpeting. All exterior windows were intact. Minimal dust was present 

in the dwelling, except for baseboard heating elements and window sash frames. All personal 

items were disposed of, with the exception of fabric-covered furniture and kitchenware, prior to 

cleaning. 

Difficult Areas Encountered: 

• Exterior windows and sashes 

• Hydronic baseboard heating units 

• Cracks and crevices
 Study 

3 

Unit 3A - 3rd floor, Southeast corner, Cedar Street 

Cleaning Method: Test 2B - Surface cleaning using HEPA filtered vacuums. Area air 

filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all horizontal 

surfaces. 

Equipment Used: Eureka® Upright, Craftsman® Shop Vacuum and AFD. 

Filtration Status: HEPA 

Unit Size: 1,368 sq. ft.; 14,364 cu. ft. 

AFD Status: Required

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 23.94 min @ 600 cfm 

Minimum Air Exchange Required: Every 30 minutes

Unit Description: This 1,368 sq. ft. loft facing Cedar Street is utilized as office space for the 

Baldwin Realty Company. Carpeting covers half the floor space. The remainder is hardwood 

flooring. All exterior windows were intact. Minimal dust was present in the space, except for 

baseboard heating elements and window sash frames. The space is furnished with office 

equipment including desks, chairs, file cabinets, and tables. 

Difficult Areas Encountered: 

• Exterior windows and sashes

• Recessed lighting 

• Fireplace interior 

• Cracks and crevices 

• Hydronic baseboard heating units
 1 

Synopsis of Cleaning Methods by Building Area

Residential Apartments and Common Areas

Unit 2A. Test: 1B- Ridgid® shop vacuum, Hoover® upright, AFD, no HEPA. Soap and 

water wet wipe of all horizontal surfaces. This 1,335 sq. ft. loft with one bedroom faces 

Cedar Street. Hardwood floors, no carpet, no windows blown in, all personal items 

disposed except for a couch and chairs. Minimal dust accumulation in dwelling except 

for baseboard heating elements. 

Unit 2B. Test: 3A- Industrial HEPA-filtered vacuum, no AFD. Soap and water wet wipe 

of all horizontal surfaces. This 946 sq. ft. loft with 2 separate bedrooms faces Cedar 

Street. Hard wood floors, no carpet, no windows blown in, all personal items except a 

couch, disposed of prior to cleanup. Minimal dust accumulation in dwelling except for 

baseboard heating elements. 

Second Floor Hallway. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test: 4B- Soap 

and water wet wipe of all horizontal and vertical surfaces (this hallway, ceiling and floors 

only). Vinyl tiles on floor, sheet rock walls covered with wall paper glue, painted sheet 

rock ceiling. Minimal dust accumulation. 

Unit 3A. Test: 2B- Craftsman® shop vacuum, Eureka® upright, HEPA and AFD. Soap 

and water wet wipe of all horizontal surfaces. This 1,368 sq. ft. loft (utilized as office 

space for Baldwin Reality) faces Cedar Street. Carpet is present on half the floor 

space; the remainder is hardwood floors. No windows blown in. The area is furnished 

with 10 - 12 wood desks, files and office equipment. Minimal dust accumulation in 

dwelling. 

Unit 3B. Scope A- Lower Manhattan Cleaning Procedure: Industrial HEPA-filtered 

vacuums, AFD. Soap and water wet wipe of all horizontal and vertical surfaces. This 

968 sq. ft. loft with three bedrooms faces Cedar Street. Tenants plan to reoccupy 

dwelling, therefore personal items except for mattresses, carpet and magazines 

remained for cleaning. No windows blown in, hardwood floors, area completely 

furnished, tenants clothes present. Minimal dust accumulation in dwelling except for 

baseboard heating units. 

Unit 3C. Test: 1A- Craftsman® shop vacuum, Eureka® upright, no HEPA, no AFD. 

Soap and water wet wipe of all horizontal and vertical surfaces. Test: 3B- Industrial 

HEPA-filtered vacuum, AFD, and soap and water wet wipe of all horizontal and vertical 

surfaces. This 655 sq. ft. loft with two bedrooms faces ground zero. Hardwood floors, 

windows blown in, no carpet, nearly all personal items disposed of prior to clean up. 

Significant accumulation of dust in dwelling. 

Unit 3D. Test: 1A- Ridgid® shop vacuum, Hoover® upright, no HEPA, no AFD. Soap 

and water wet wipe of all horizontal surfaces. This 968 sq. ft. loft with three bedrooms 

faces ground zero. Hardwood floors, windows blown in, no carpet, all personal items 

except for three pieces of hardwood furniture disposed of. Significant accumulation of 

dust in dwelling. 
 2 

Third Floor Hallway. Test: 4A- Industrial HEPA-filtered vacuums, AFD. Test: 4B- Soap 

and water wet wipe of all horizontal and vertical surfaces (this hallway, ceiling only). 

Plywood floors, sheet rock walls covered with wall paper glue, painted sheet rock 

ceiling. Minimal dust accumulation. 

Unit 4A. Test: 2A- Craftsman® shop vacuum, Hoover® upright, HEPA, no, AFD. Soap 

and water wet wipe of all horizontal surfaces. This 1,368 sq. ft. open loft, faces Cedar 

Street. Hardwood floors, no windows blown in, all personal items removed prior to 

cleanup. Minimal dust accumulation in dwelling except for baseboard heating units. 

Unit 4B. Test: 2B- Ridgid® shop vacuum, Hoover® upright, HEPA, AFD. Soap and 

water wet wipe of all horizontal surfaces. This 968 sq. ft. loft with 4 bedrooms faces 

Cedar Street. Personal items cleaned then bagged. Hardwood floors, no blown in 

windows. Minimal dust accumulation in dwelling except for baseboard heating units. 

Unit 4C. Test: 1A- Craftsman® shop vacuum, Eureka® upright, no HEPA, no AFD. 

Soap and water wet wipe of all horizontal surfaces. This 655 sq. ft. open loft faces 

ground zero. Personal items cleaned then bagged. No carpet, hardwood floors, 

windows blown in. Significant accumulation of dust in dwelling. 

Unit 4D. Test: 2A- Ridgid® shop vacuum, Eureka® upright, HEPA, no AFD. Soap and 

water wet wipe of all horizontal surfaces. This 968 sq. ft. open loft faces ground zero. 

Personal items cleaned then bagged. Hardwood floors, windows blown in. Significant 

accumulation of dust in dwelling. 

Fourth Floor Hallway. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test: 4B- Soap 

and water wet wipe of all horizontal and vertical surfaces (this hallway, ceiling only). 

Plywood floors, sheet rock walls covered with wallpaper glue, painted sheet rock ceiling. 

 Minimal dust accumulation. 

Unit 5A. Test: 3B- Industrial HEPA-filtered vacuum, AFD. Soap and water wet wipe of 

all horizontal surfaces. This 1,404 sq. ft. loft with one bedroom faces Cedar Street. 

Personal items cleaned then bagged. Hardwood floors, no carpet, one blown in 

window. Minimal dust accumulation in dwelling except for baseboard heating units. 

Unit 5C. Test: 3A- Industrial HEPA-filtered vacuum, no AFD. Soap and water wet wipe 

of all horizontal surfaces. Test: 3B- Industrial HEPA-filtered vacuum, AFD. Soap and 

water wet wipe of all horizontal surfaces. This 968 sq. ft. loft with three bedrooms faces 

ground zero. Hardwood floors, no carpet, all personal items removed, windows blown 

in. Significant accumulation of dust in dwelling. 
 3 

Unit 5D. Test: 3B- Industrial HEPA-filtered vacuum, AFD. Soap and water wet wipe of 

all horizontal surfaces. This 1,024 sq. ft. open loft faces ground zero. All personal 

items removed prior to cleaning. Windows blown in, hardwood floors, no carpet. 

Significant accumulation of dust in dwelling. 

Fifth Floor Hallway. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test: 4B- Soap 

and water wet wipe of all horizontal and vertical surfaces (this hallway, ceiling only). 

Plywood floors, sheet rock walls covered with wallpaper glue, painted sheet rock ceiling. 

 Minimal dust accumulation. 

Liberty Street Staircase. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test: 4BSoap and water wet wipe of all horizontal and vertical surfaces. Cast concrete 

steps/landings, sheet rock walls and ceiling. All surfaces covered with gloss paint. 

Minimal dust accumulation. 

Cedar Street Staircase. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test: 4BSoap and water wet wipe of all horizontal and vertical surfaces. Wood steps/landings, 

sheet rock walls and ceiling. Floor covered with vinyl tiles, walls and ceilings covered 

with gloss paint. Minimal dust accumulation. 

Commercial Units

Chiropractor’s Office. Test: 4A- Industrial HEPA-filtered vacuums, AFD. Test: 4BSoap and water wet wipe of all horizontal and vertical surfaces. Test: 4C- Carpet 

cleaning using a commercial carpet wet vacuum with warm water. Test: 4D- A/C Duct 

Cleaning. Test: 4E- Cleaning of bathroom tile floor and desk top wet wipe using water 

only. This 716 sq. ft. office space with 4 examination rooms faces ground zero. All front 

windows were blown in. Excessive amounts of dust present on all horizontal and 

vertical surfaces. Floor areas covered with wall-to-wall carpeting; suspended ceiling 

covered with fibrous tiles. A two foot high void space was above ceiling. Ceiling tiles, 

flexible ventilation ducts and office equipment were removed and disposed of prior to 

cleaning. Void space contained HVAC system, and wood floor joist system for third floor 

apartment. This area contained WTC-related and non-WTC-related dust. The space 

was extremely difficult to clean due to the present of electrical wires, recessed lighting 

fixtures, sprinkler systems and the dry friable nature of the wood support system. 

Mattress Store. Test: 4A- Industrial HEPA-filtered vacuums, AFD. Test: 4B-Soap and 

water wet wipe of all horizontal and vertical surfaces. Test: 4C- Carpet cleaning using a 

commercial carpet wet vacuum with a warm water shampoo solution. Test: 4D- A/C 

Duct Cleaning. 

Test: 4E- Cleaning of vinyl floor tile and window ledge wet wipe using water only. This 

968 sq. ft. open space faces ground zero. All front windows blown in, excessive 

amounts of dust present on all horizontal surfaces. Floor areas covered with wall-towall carpeting and approximately 25 display mattresses and box springs. Ceiling tiles, 

mattresses, office equipment and flexible ventilation ducts removed and disposed of 

prior to cleanup. Void space above suspended ceiling exhibited same characteristics as 

in the Chiropractor’s office.
 4 

Basement

Elevator Shaft/Compactor Room. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Soil 

floor in elevator shaft, concrete floor in compactor room. Cinderblock walls, exposed 

floor joists. 

Commercial Units (Non-Study)

Lemongrass Grill. Test: 4A-Industrial HEPA-filtered vacuum, AFD. Test 4D- A/C Duct 

Cleaning. This 3,500 sq. ft. unit has two floors. The first floor is at street level with 

entrances from both Liberty and Cedar Streets. The lower level (basement) was used 

for food preparation and storage. Gypsum ceilings and hard wood floors are present 

throughout the dining area. Wood floor joists from the first floor constitute the 

basement ceiling. The floor is concrete. The dining area is decorated with typical Thai 

accents consisting of bamboo and thatch. Grills, ovens, refrigerators, tables, chairs and 

a bar are on the first floor. The basement contains a walk-in refrigerator, freezers, 

preparation table, a dishwasher and dry good storage. The establishment’s HVAC 

system is suspended from the ceiling of the first floor. All exterior windows facing the 

WTC were blown inward, depositing significant amounts of dust on all surfaces of the 

first floor. Minimal dust was present in the basement. Prior to cleaning, all tables, 

chairs, containerized food and accent decorations were disposed. Restaurant 

equipment including woks, utensils, pots, pans and flatware were vacuumed and 

washed. 

The Food Exchange. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test 4D- A/C 

Duct Cleaning. This 5,000 sq. ft. unit has three floors. The first floor is at street level 

with entrances from both Liberty and Cedar Streets. This floor was used for food 

service and customer dining. The lower level (basement) was used for food preparation 

and storage. The third level (sub-basement) was used for storage of restaurant 

equipment. Ceramic tile covers the floor area in both the dining room and the 

basement. The floor of the sub-basement is packed soil. All exterior windows had 

been blown inward depositing significant amounts of dust on all surface areas of the 

first floor. Minimal dust was present in the basement. The first floor ceiling by the 

Liberty Street entrance is made of gypsum board. The ceiling on the Cedar Street 

entrance consists of suspended acoustical tile covered with a decorative tin facing. 

Above the suspended ceiling is a two foot void space that houses the HVAC system for 

the establishment. The basement ceiling is a suspended fibrous tile ceiling. The void 

space above both suspended ceilings and the gypsum ceiling contained both WTCrelated and non-WTC-related dust. Asbestos pipe insulation was present in the void 

space of the basement. Grills, refrigerators, tables and chairs are present on the first 

floor. The basement contains walk-in refrigerators, preparation tables, stoves, 

dishwashing areas and dry good storage. Prior to cleaning, all open and bulk stored 

food; fibrous ceiling tiles in the basement; and wrap insulation that had surrounded the 

HVAC systems were disposed of. The HVAC system is located in the void space 

above the dining room ceiling. 
 5 

The Barber Shop. Test: 4A- Industrial HEPA-filtered vacuum, AFD. Test 4E- Water wet 

wipe of all horizontal and vertical surfaces. This 1,268 sq. ft. open space facing the 

WTC Site is located below grade to Liberty Street. The front door of the business was 

blown inward depositing significant amounts of dust and debris down the staircase into 

the rental space. Floor areas were covered with ceramic tiles; the ceiling is a 

suspended system using fibrous tiles. Above the suspended ceiling is a void space 

which accommodates flexible A/C ducts, electrical conduit and lights. All structural 

support members above the ceiling were encapsulated with a non-asbestos insulating 

material. Equipment including chairs, wash sinks, counters and hair care displays were 

located in the shop. The head space above the entrance door houses an A/C 

condenser/compressor unit that was heavily impacted with WTC contaminated dust and 

debris. Ceiling tiles, flexible duct, chairs, display shelving and hair care merchandise 

were disposed of prior to cleaning. Ancillary rooms are adjacent to the shop space that 

extends under Liberty Street. These rooms have earthen floors and are believed to be 

associated with utility companies. They were not cleaned. 

Exterior A/C Condenser/Compressor Units

A/C Condenser/Compressor Units. Test: 2A- Craftsman® shop vacuum, HEPA, no 

AFD. Three commercial condenser/compressor units and four residential 

condenser/compressor units were inspected to determine if they required cleaning of 

WTC-related dust. No significant dust was present on the exterior and interior surfaces 

of the four residential units. It is believed that the condenser/compressor units were 

cleaned prior to the study, by contractors retained by the owner, to remove dust and 

debris from the building roof. The three commercial condenser/compressor units had 

minimal to moderate WTC-related dust/debris.
 6 

Fact Sheets
 Study and Non-Study 

25 

Exterior A/C Condenser/Compressor Units

Three commercial size condenser/compressor units and one cooling tower are located on the 

atrium roof and four residential size condenser/compressor units are located on the 5th floor roof. 

Cleaning Method: Test 2A - Surface cleaning utilizing a vacuum equipped with HEPA 

filtration. 

Equipment Used: Craftsman® Shop Vacuum 

Filtration Status: HEPA 

Unit Size: N/A 

AFD Status: Not Required 

AFD Specifications: N/A 

Unit Air Exchange Rate: N/A 

Minimum Air Exchange Required: N/A 

Description: Three condenser/compressor units and four residential condenser/compressor 

units were inspected to determine if they required cleaning of WTC-related dust. No significant 

dust was present on the exterior and interior surfaces of the four residential units. It is believed 

that the condenser/compressor units were cleaned prior to the pilot, by contractors retained by 

the owner, to remove dust and debris from the building roof. The three commercial 

condenser/compressor units had minimal to moderate WTC related dust/debris. 

Units Inspected but not Cleaned: 

The four condenser/compressor units for dwellings 3A, 5A, 5C, and 5D require no cleaning. 

Units Cleaned: 

• The Food Exchange restaurant cooling tower located on the building atrium roof 

• THAI Restaurant condenser/compressor unit located on the atrium roof 

• Commercial Unit 1, Chiropractors office, condenser/compressor unit 

• Commercial Unit 2, Mattress showroom, condenser/compressor unit

Difficult Areas Encountered: 

None 
 Study 

17 

Mattress Store

2nd Floor, Northwest corner, Liberty Street 

Cleaning Methods: Test

4A - Area air filtration utilizing an air filtration device (AFD). Surface cleaning using a vacuum 

equipped with HEPA filtration. Nilfisk® Vacuum (CFM 127), AFD 

4B - Surface cleaning of horizontal and vertical surfaces using a wet wipe with soap and water. 

4C - Carpet cleaning using a commercial carpet wet vacuum with a warm water shampoo 

solution. “Carpet Express” (Model C-4) 

4D - A/C Duct Cleaning. One A/C system located above the suspended ceiling supplies the 

showroom with air conditioning. The system has two central return grills located under and 

adjacent to the air handler. All flexible duct lines were removed and disposed of. Supply 

diffusers and return grills were removed for cleaning and reinstalled. A professional HVAC 

cleaning company was contracted to clean the HVAC system in accordance with the following 

work outline. 

 The workspace was protected using plastic and tape immediately under the duct system and 

in proximity of the working equipment. 

 Diffusers and return grills were removed. 

 Diffusers and return grills were treated with a degreasing agent. 

 The distribution duct was sealed with a protective barrier to prevent blow back of debris. 

 Diffusers and return grills were washed of degreasing agent and sanitized. 

 The distribution duct and surrounding areas were HEPA vacuumed. 

 The distribution duct openings degreased and sanitized. 

4E - Surface cleaning of horizontal and vertical surfaces consisting of wet wipe using water 

only (vinyl floor tile and window ledge). 

Equipment used: Nilfisk® Vacuum (CFM 127), AFD; Carpet wet vacuum, (Model C-4) 

Filtration status: HEPA 

Unit Size: 946 sq. ft.; 9,460 cu. ft. 

AFD Status: Required under methods A and D 

AFD specification: 400/600 cfm 

Unit air exchange rate: 23.65 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 968 sq. ft. mattress showroom faces the WTC Site. An exterior 

window wall had been blown inward, depositing significant amounts of dust throughout the 

showroom. Approximately twenty-five mattresses were on display in the showroom. Floor 

areas were covered with wall-to-wall carpet and padding. A two-foot void space is located 

above the suspended fibrous tile ceiling. The void space contains an A/C air handling system 

that is suspended from the wood floor joist construction of the 3rd floor unit. The void space 

accommodates the sewer drain pipe, electrical and telephone wires, A/C system duct work, and 

lighting and fire protection systems. The void space contained dust both related to and not related 

to the WTC attack. Ceiling tiles, flexible ducts, furniture, and display items were disposed of 

prior to cleaning. 
 Study 

18 

Mattress Store - Continued

Difficult Areas Encountered: 

• Ceiling void space was cluttered with utilities. 

• The wood structural members above the void space were porous and flaking. 

• Minimal space was available in the void space making it difficult to work. 

• Hydronic baseboard heating units were difficult to clean using vacuum equipment only. 

• Wall-to-wall carpeting was difficult to clean thoroughly. 

• Frequent clogging of vacuum filtration systems occurred due to the quantity of dust. 
 Study 

15 

Chiropractor's Office 

2nd Floor, Northwest corner, Liberty Street 

Cleaning Methods: Test 

4A - Area air filtration utilizing an air filtration device (AFD). Surface cleaning utilizing an 

industrial vacuum equipped with HEPA filtration. NilfiskTM Vacuum (CFM 127), AFD. 

4B - Surface cleaning of horizontal and vertical surfaces using a wet wipe with soap and water. 

4C - Carpet cleaning using a commercial carpet wet vacuum with warm water Carpet ExpressTM

(Model C-4) 

4D – A/C Duct Cleaning. One air handling system located above the suspended ceiling supplies 

interior offices with air conditioning. The system has a central return grill located under the air 

handler. All flexible duct lines were removed and disposed of. Supply diffusers and return grills 

were removed for cleaning and reuse. A professional HVAC cleaning company was contracted 

to clean the HVAC system in accordance with the following work outline: 

 The work area immediately under the A/C system was protected using plastic sheeting. 

 Diffusers and return grills were cleaned with a degreasing agent. 

 Openings in the distribution duct were sealed with a protective barrier to prevent debris blow 

back. 

 Distribution ducts were cleaned using mechanical brushes under negative air and HEPA 

filtration, then washed with a degreasing agent. 

 The blower unit was washed with a degreaser, and the residues were removed using a 

vacuum. 

 All distribution ducts were fogged with a biocide, then encapsulated with an FDA approved 

sealer. 

4E - Surface cleaning of horizontal and vertical surfaces consisting of wet wipe using water only 

(bathroom floor and desk top). 

Equipment Used: Nilfisk® Vacuum (CFM 127); AFD; Carpet wet vacuum, (Model C-4) 

Filtration Status: HEPA 

Unit Size: 836 sq. ft.; 8,360 cu. ft. 

AFD Status: Required under method A and D 

AFD Specifications: 400/600 cfm 

Unit Air Exchange Rate: 20.9 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 
 Study 

16 

Chiropractor's Office – Continued

Unit description: This 716 sq.ft. commercial office space with four examination rooms faces 

the WTC site. All front windows had been blown inward, depositing significant amounts of dust 

and debris throughout the unit. Floor areas were covered with wall-to-wall carpet and padding. 

A two-foot void space is located above the suspended fibrous tile ceiling. The void space 

contains an A/C system suspended from the wood floor joist construction of the 3rd floor unit. 

The space accommodates sewer drain pipes, electrical and telephone wires, A/C system duct 

work, and lighting and fire protection systems. The void space contained dust both related and 

not related to the WTC attack. Ceiling tiles, flexible duct and office equipment were removed 

and disposed of prior to cleaning. 

Difficult Areas Encountered: 

• The ceiling void space was cluttered with utilities. 

• The wood structural members above the void space were porous and flaking. 

• Minimal space was available in the void spaces, making it difficult to work efficiently. 

• The hydronic baseboard heating units were difficult to clean. 

• The wall-to-wall carpeting was difficult to clean thoroughly. 

• Frequent clogging of vacuum filtration systems occurred due to the quantity of dust. 
 Study 

14 

Common Areas 

Vestibule, Elevator, Stairwells, Hallways, Utility Rooms, Trash Chute Accesses and Laundry 

Room. 

Cleaning Method: Test 4A, 4B - Surface cleaning using industrial filtered vacuums. Air 

filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all horizontal and 

vertical surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127), AFD. 

Filtration Status: HEPA 

Unit Size: Four Levels Total: 2,556 sq. ft.; 30,492 cu. ft.

Hallways (per level) 639 sq. ft.; 7,623 cu. ft. 

 Vestibule 150 sq. ft.; 1,500 cu. ft. 

 Elevator Compartment 48 sq. ft.; 384 cu. ft. 

 Laundry Room (Included as hallway) 

 Utility Rooms (Included as hallway) 

 

AFD Status: Required 

AFD Specifications: 400/600 cfm 

Unit Air Exchange Rate: 19.5 min at 400 cfm (hallway) 

Minimum Air Exchange Required: Every 30 minutes 

Description: The vestibule is located on Cedar Street and provides access to the building’s 

only elevator and one stairwell. A second stairwell is accessed from Liberty Street. Four 

hallways connect the two stairwells and elevator access point on each floor (2nd floor to 5th

floor). Each hallway contains a utility room with a trash chute access. The laundry room is 

located off of the 2nd floor hallway. The common areas contain no porous building material. All 

walls and ceilings in the stairwells are painted. Carpeting is not present in any of the common 

areas. Minimal dust was observed in the common areas.

Difficult Areas Encountered: 

• The common areas were used daily by all individuals working in the building. These areas 

were frequently damp mopped to control the migration of dust. 

• Dust accumulations were heavy at the base of the walls where the baseboard trims were 

removed. 

• Hallway walls were vacuumed, but not wet wiped as a result of wallpaper paste residue left 

when the wallpaper was removed prior to the pilot study. 
 Non-Study 

24 

Barber Shop This unit is located in the basement. 

Cleaning Method: Test 4A - Surface cleaning using industrial HEPA filtered vacuums. 

Area air filtration utilizing an air filtration device (AFD). Test 4E - Water wet wipe of all 

horizontal and vertical surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127), AFD. 

Filtration Status: HEPA 

Unit Size: 1,268 sq. ft.; 15,216 cu. ft. 

AFD Status: Required 

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 25.36 min @ 600 cfm 

Minimum Air Exchange Rate: Every 30 minutes 

Unit Description: This 1,268 sq. ft. open space facing the WTC Site is located below grade 

to Liberty Street. The front door of the business was blown inward depositing significant 

amounts of dust and debris down the staircase into the rental space. Floor areas are covered with 

ceramic tiles; the ceiling is a suspended system using fiberous tiles. Above the suspended ceiling 

is a void space which accommodates flexible A/C ducts, electrical conduit and lights. All 

structural support members above the ceiling are encapsulated with a non-asbestos insulating 

material. Equipment including chairs, wash sinks, counters and hair care displays are located in 

the shop. The headspace above the entrance door houses an A/C condenser/compressor unit that 

was heavily impacted with WTC contaminated dust and debris. Ceiling tiles, flexible duct, 

chairs, display shelving and hair care merchandise where disposed of prior to cleaning. Adjacent 

to the shop space are ancillary rooms that extend under Liberty Street. These rooms have earthen 

floors and are believed to be associated with utility companies. They were not cleaned. 

Difficult Areas Encountered: 

• Sprayed-on insulation/fire protection applied to structural members in the void space above 

the suspended ceiling prevented effective vacuuming of the area. 

• Significant quantities of WTC dust and debris were deposited into the remote A/C 

condenser/compressor unit and associated housing.

• The space above the fixed ceiling at the entrance to the Barber Shop stairwell was heavily 

impacted, requiring special preparation for access and removal of bulk quantities of WTC 

dust/debris.
 Non-Study 

22 

The Food Exchange

1st floor, basement and sub-basement Cedar & Liberty Street 

Cleaning Method: Test 4A - Surface cleaning using industrial HEPA filtered vacuums. 

Area air filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all 

horizontal surfaces. 

Equipment Used: NilfiskTM Vacuum (CFM 127), AFD 

Filtration Status: HEPA 

Unit Size: 1st floor- 2,324 sq. ft.; 31,606 cu. ft.; basement- 2,596 sq. ft.; 36,344 cu. ft. 

AFD Status: Required

AFD Specification: 400/600 cfm 

Unit air exchange rate: 1st floor 15.80 min @ 2000 cfm, basement 18.17 min @ 2000 cfm. 

Minimum Air Exchange Required: Every 30 minutes 

 

Unit Description: The restaurant encompasses approximately 5,000 square feet. It may be 

entered from either a Cedar Street or a Liberty Street entrance. The establishment is comprised of 

three floors. The first floor is at street level. This floor was used for food service and customer 

dining. The lower level (basement) was used for food preparation and storage. The third level 

(sub-basement) was used for storage of restaurant equipment. Ceramic tile covers the floor area 

in both the dining room and the basement. The floor of the sub-basement is packed soil. All 

exterior windows had been blown inward depositing significant amounts of dust on all surface 

areas of the first floor. Minimal dust was present in the basement. The first floor ceiling by the 

Liberty Street entrance is made of gypsum board. The ceiling on the Cedar Street entrance 

consists of suspended acoustical tile covered with a decorative tin facing. Above the suspended 

ceiling is a two-foot void space that houses the HVAC system for the establishment. The 

basement ceiling is a suspended fibrous tile ceiling. The void space above both suspended 

ceilings and the gypsum ceiling, contained both WTC related and non-WTC related dust. 

Asbestos pipe insulation was present in the void space of the basement. Grills, refrigerators, 

tables and chairs are present on the first floor. The basement contains walk-in refrigerators, 

preparation tables, stoves, dishwashing areas, and dry good storage. Prior to cleaning, all open 

and bulk stored food, fibrous ceiling tiles in the basement, and wrap insulation that had 

surrounded the HVAC systems, were disposed of. The HVAC system located in the void space 

above the dining room ceiling consists of two air handlers that provide heat or cooling to the first 

floor via separate solid metal supply ducts. The system return is from the dining area and void 

space located above the first floor. Cleaning of this system was performed by a subcontractor in 

accordance with a site-specific scope of work prepared by Covino Environmental Associates Inc. 
 Non-Study 

23 

The Food Exchange - Continued

Difficult Areas Encountered: 

• The ceiling void space was cluttered. 

• The wood structural members above void space were porous and flaking. 

• Asbestos pipe wrap insulation was present in void space. 

• Removal of ceiling tiles created dusty conditions. 

• Insect and rodent infestations created unpleasant work conditions. 

• Frequent clogging of vacuum filtration systems occurred due to the quantity of dust and 

rodent droppings.
 Non-Study 

21 

Difficult Areas Encountered: 

• Approximately 200 lbs. of spoiled fish, meat and poultry were removed from freezers and 

refrigerators. 

• There was encrusted grease on, and adjacent to, all cooking surfaces, stove exhaust systems 

and floor areas. 

• Wood structural members in the basement preparation area were porous and flaking. 

• Insect and rodent infestations created unpleasant work conditions. 

• Frequent clogging of vacuum filtration systems occurred due to the quantity of dust and 

rodent droppings.
 Study 

13 

Unit 5D - 5th floor, Northeast corner, Liberty Street 

Cleaning Method: Test 3B - Surface cleaning using industrial HEPA filtered vacuums. 

Area air filtration utilizing an air filtration device (AFD). Soap and water wet wipe of all 

horizontal surfaces.

Equipment Used: NilfiskTM Vacuum (CFM 127), AFD 

Filtration Status: HEPA 

Unit Size: 968 sq. ft.; 10,648 cu. ft. 

AFD Status: Required

AFD Specification: 400/600 cfm 

Unit Air Exchange Rate: 26.62 min @ 400 cfm 

Minimum Air Exchange Required: Every 30 minutes 

Unit Description: This 968 sq. ft. open loft faces the WTC Site. The unit has hardwood 

floors and no carpeting. All exterior windows had been blown inward depositing significant 

amounts of dust and debris throughout the dwelling. All personal items were disposed of prior to 

the cleanup. Significant dust was accumulated in the dwelling. 

Difficult Areas Encountered: 

• Hydronic baseboard heating units 

• Boarded up window openings 

• Cracks and crevices 
Attachment I 

HVAC Cleaning Procedures 
1

General Procedures for Cleaning WTC-Related Contaminants from 

Ventilation Systems at 110 Liberty Street, New York, New York 

1.0 SCOPE 

The procedures contained in this document provide guidance for cleaning WTC-related dust in two 

commercial ventilation systems and in a combustion air make-up riser for the residential units within the 

building located at 110 Liberty Street, New York, New York, and for post-cleaning verification 

sampling. This document includes performance requirements and post-cleaning verification sampling 

for cleaning WTC-related dust and debris from ventilation systems consisting of fans, housings, ducts, 

air control devices, grilles and other components. 

2.0 PURPOSE 

The purpose of this document is to provide minimum requirements for cleaning ventilation system 

components that were impacted by airborne dust from the WTC collapse, and to provide procedures for 

post-cleaning verification sampling following clean-up. 

WTC-related dust is generally considered to have common, consistent, and readily observable 

characteristics visually and tactilely differentiating it from common dust. WTC-related dust generally 

contains extremely fine particles similar in consistency to talcum powder, is light-colored, contains 

pulverized concrete and/or gypsum wallboard, and may contain asbestos fibers. Unless otherwise 

indicated by sampling and analytical testing, the following components shall be assumed to be present in 

WTC-related dust: 

• Man-made Vitreous Fibers 

• Crystalline Silica 

• Lead 

• Asbestos 

For this project, all specified ventilation system components shall be assumed to contain WTC-related 

dust and shall be cleaned accordingly. 

Where sampling and analysis indicate that dust and debris in ventilation systems contain only crystalline 

silica, man-made vitreous fibers, lead, or <1% asbestos contamination, this procedure specifies that duct 

systems shall be cleaned only while maintained under negative pressure using HEPA-filtered vacuum 

collection equipment specific to the duct cleaning industry. All cleaning of air handling equipment shall 

be performed within containment structures that are maintained under negative pressure using HEPAfiltered air filtration devices. 

Where sampling and analysis indicate that dust and debris within a ventilation system contains 1% or 

greater asbestos as determined by standard sampling and analytical techniques, the ventilation system 

cleaning procedure shall be designed by a New York-licensed Project Designer. The cleaning will be 

performed in accordance with local, state and federal regulations as specified in the Project Design. 
2

3.0 APPLICABLE DOCUMENTS 

This section provides full bibliography for references made within this document, or considered in 

preparation of this document. Cleaning and post-cleaning verification sampling should be conducted in 

a manner that is fully compliant with the guidance provided in the following documents, to the extent 

applicable. 

1. ACR 2002, Assessment, Cleaning and Restoration of HVAC Systems, National Air Duct Cleaning 

Association, Washington, D.C. (2002). 

ACR 2002 specifies procedures for cleaning HVAC systems. 

2. NADCA Standard 97-05, Requirements for the Installation of Service Openings in HVAC Systems, 

National Air Duct Cleaning Association, Washington, D.C. (1997). 

NADCA 97-05 includes procedures for installing service openings in HVAC systems and 

construction and material specifications for replacement panels, plates or access doors to cover 

such openings. 

3. SMACNA HVAC Duct Construction Standards – Metal and Flexible, Sheet Metal and Air Conditioning 

Contractors’ National Association, Inc., 2nd Edition (1995). 

The SMACNA standard includes construction and material specifications for access doors for 

covering service openings as required under 7.5 and 11.1.3 of this document. 

4. SMACNA Fibrous Glass Duct Construction Standards, Sheet Metal and Air Conditioning Contractors’ 

National Association, Inc., 6th Edition (1992). 

The SMACNA standard includes construction and material specifications for access doors for 

covering service openings as required under item 6.5.1.2 of this document. 

5. NFPA Standards 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, and 

90B, Standard for the Installation of Warm Air Heating and Air-Conditioning Systems, National Fire 

Protection Association (1999 Edition). 

The NFPA standards include construction and material specifications for replacement coverings on 

service openings as required under item 6.5.1.2 of this document. 

6. Cleaning Fibrous Glass Insulated Air Duct Systems, North American Insulation Manufacturers 

Association (NAIMA), 1993 

This document provides guidance for cleaning fibrous glass-insulated interior ventilation system 

surfaces. 

7. ASHRAE 33-78, Methods of Testing Forced Circulation Air Cooling and Air Heating Coils, 

American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE), 1978 

This document contains procedures for testing air flow through ventilation system thermal coils. 

8. ARI 410-91 Forced-Circulation Air-Cooling and Air-Heating Coils, Air Conditioning and 
3

Refrigeration Institute (ARI), 1991 

This document contains procedures for testing air flow through ventilation system thermal coils. 

9. ASHRAE 62-2001, Ventilation for Acceptable Indoor Air Quality, American Society of Heating, 

Refrigeration, and Air Conditioning Clients (ASHRAE), 2001 

This document provides performance and evaluation criteria for acceptable general ventilation 

system operation. 

10. Military Standard 282, United States Department of Defense (DOD), 1956 

This document contains leak testing procedures for in-place filters used in air filtration devices, HEPA 

vacuums and vacuum collection equipment. 

11. AMCA 99-86, Standards Handbook, Air Movement and Control Association, 1986 

This document contains specifications for air filtration devices. 

12. ASHRAE Terminology of Heating, Ventilation, Air Conditioning, and Refrigeration, American 

Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE), 1991 

This document defines terminology for use in referring to ventilation systems and components. 

13. OSHA Regulations 29 CFR 1910, Occupational Health and Safety Standards 

The OSHA regulations specify health and safety requirements for protecting employees during the 

inspection procedures. 

14. Title 15, Chapter 1, Rules of City of New York Asbestos Regulations 

This document contains New York City regulations regarding asbestos abatement. 

15. NYSDOL – DOSH Regulations – Part 56. ASBESTOS 

This document contains New York State regulations regarding asbestos abatement. 

16. NYC Guidelines on Assessment and Remediation of Fungi in Indoor Environments 

This document contains New York City guidelines regarding microbial remediation. 

4.0 CHARACTERIZATION OF DUST/ENVIRONMENTAL HAZARDS 

Prior to the start of work, an evaluation of the dust shall be performed by an independent environmental 

service contractor. The independent environmental service Contractor shall be experienced in performing 

all necessary sampling procedures for analytical evaluation of the WTC –related dust. 

Prior to the start of work, the independent environmental service Contractor shall make a determination 
4

as to whether the following contaminants are present: 

• Man-made Vitreous Fibers 

• Crystalline Silica 

• Lead 

• Asbestos 

Bulk samples when applicable will be collected for quantitative analysis of the above-referenced 

analytes. Samples for analysis of man-made vitreous fibers, crystalline silica, lead and Asbestos may 

only be submitted to an EPA approved laboratory. Wipe samples and air samples may be taken when the 

quantity of dust to be analyzed is insufficient for bulk collection. 

The onsite Environmental Cleaning Contractor shall note any mold growth, rodent droppings, or other 

biological hazards if observed. 

5.0 SITE EXAMINATION 

Prior to commencing work, all ventilation system/duct cleaning professionals shall visit the site to 

examine the conditions under which the work is to be performed in order to identify those conditions that 

might adversely affect the work. These conditions may include, but may not be limited to the following: 

1. Difficulty accessing ventilation system components. 

2. Ventilation systems components located in parts of the building that are not included in the scope of 

ventilation system cleaning, but that may cause the ventilation system components to become recontaminated following cleaning. 

3. Asbestos-containing materials on ventilation system components to be cleaned or damaged asbestoscontaining materials in the vicinity of the ventilation system components to be cleaned. 

4. Specific scaffolding and/or fall protection requirements. 

6.0 VENTILATION SYSTEM/DUCT CLEANING FIRM REQUIREMENTS 

6.1 The ventilation system/duct cleaning firm shall meet the following minimum health and safety 

requirements: 

Appropriate Respiratory Protection Program as required by 29 CFR 1910.134. 

Appropriate Hazard Communication Training as required by 29 CFR 1910.1200, to include 

health hazards associated with man-made vitreous fibers, crystalline silica, lead, asbestos, and 

microbiological hazards that may likely be encountered in ventilation systems, in addition to 

chemicals brought on site to perform the work. 

Prior experience in cleaning HVAC systems. 

Appropriate personal protective equipment and written program. 
5

An experienced individual to act as a site health and safety supervisor to respond to unanticipated 

health hazards that may be encountered on the site and to ensure implementation of required 

health and safety practices. 

6.2 In addition to the above minimum requirements, the duct cleaning professional shall meet the 

following contaminant-specific requirements: 

6.2.1 Man-made Vitreous Fibers – appropriate Hazard Communication training and personal 

protective equipment 

6.2.2 Crystalline Silica – appropriate Hazard Communication training and personal protective 

equipment 

6.2.3 Lead – appropriate Hazard Communication training, ability to perform personal exposure 

monitoring for airborne lead, ability to comply with requirements of 29 CFR 1910.1025 

6.2.4 Asbestos (< 1%) - – appropriate Hazard Communication training, ability to perform 

personal exposure monitoring for airborne asbestos, ability to comply with requirements 

of 29 CFR 1910.1001 

6.3 All workers shall possess current EPA-accredited training as an Asbestos Worker (32-hour 

training) or as an Asbestos Supervisor (40-hour training). 

7.0 GENERAL PERFORMANCE REQUIREMENTS

In general, all cleaning of air moving equipment and active plenums shall be performed under negative 

pressure using HEPA-filtered air filtration devices. All ducts that are cleaned shall be maintained under 

negative pressure using HEPA-filtered vacuum collection equipment specific to the duct cleaning 

industry. Air filtration devices and vacuum collection equipment shall be exhausted to the outdoors. 

After cleaning of the ventilation system, any areas that are affected by the work must be as clean or 

cleaner than their condition prior to the start of work, and must meet post-cleaning verification 

requirements contained in 8.2 of this document. 

7.1 Containment: WTC-related dust and debris removed by cleaning/remediation process shall be 

collected and precautions taken to ensure that the debris is not otherwise dispersed outside the 

ventilation system during cleaning. After cleaning of the ventilation system, any areas that are 

affected by the work must be as clean or cleaner than their condition prior to the start of work. 

 7.1.1 When working outside the negative air pressure system the ventilation system/duct 

cleaning firm shall install plastic sheeting on the floor surface under and at a minimum of 

3 feet outside the perimeter of the system. All exposed service tools and equipment shall 

be free of debris and contamination from the ventilation system. Tools and equipment 

include (but are not limited to): Vacuum collection equipment, vacuum hoses and 

attachments, air lines and hoses, brushes, extension rods, cables, ladders, power tools, 

hand tools, zoning devices, and inspection equipment. 

7.1.1.2 Contaminated tools and equipment shall be maintained in poly bags until cleaned 

in the designated decontamination area at the work site. 
6

7.1.1.3 Hoses, cables, and extension rods shall be cleaned free of visible debris with 

suitable sanitary damp wipes at the point they are withdrawn from exposed 

ventilation system components or containment areas into general occupant areas. 

7.1.2 Upon removing duct diffusers and grilles prior to cleaning, the ventilation system/duct 

cleaning firm shall provide adequate containment measures to prevent contaminant 

exposure from accumulated debris on these devices. 

7.2 Equipment: All service equipment must operate on standard 110 VAC, 20A circuits. 

7.2.1 Vacuum Collection Equipment: All vacuum collection equipment or air filtration devices 

shall utilize a minimum of HEPA filtration (99.97% at 0.3 micron) final collection 

efficiency at the device's exhaust. Multi-sectioned equipment must not be opened or 

detached in occupied areas once contaminated with debris. Vacuum collection 

equipment shall provide sufficient negative airflow velocity in the ventilation system zone 

being serviced to draw dislodged debris from the mechanical cleaning device to the 

vacuum’s collection chamber (typically a minimum of 3000 feet per minute (fpm) in the 

portion of the HVAC system being cleaned. 

7.2.2 Pressurized Air Source Used for Cleaning Devices: Must provide a minimum of 175 PSI 

at a volume of 15 cubic feet per minute. Device must provide pressurized air free of 

significant moisture, oil and toxic vapors, or be equipped with adequate filtration and 

dryers to remove such contamination. The ventilation system/duct cleaning firm shall 

provide ongoing documentation of the device's delivery of contaminant-free pressurized 

air. 

7.3 Component Cleaning: Mechanical Cleaning procedures include the dislodging of WTC-related 

dust and debris on the interior surfaces of the ventilation system by manual, mechanical, 

pneumatic, or hydro-agitation. Loosened debris shall be collected and removed from the 

ventilation system using suitable vacuum collection equipment and/or HEPA vacuuming 

methods, as specified. 

7.3.1 Cleaning Non-Porous ventilation system components: Cleaning methods shall be used 

that will render the ventilation system components visibly clean. No cleaning method 

shall be used which will damage components of the ventilation system or significantly 

alter the integrity of the system. 

7.3.2 Cleaning Porous Ventilation System Components: Cleaning method shall be used that 

will render the ventilation system components visibly clean and minimize fiber release 

from the porous ventilation system component surface. No cleaning method should be 

used which will damage components of the ventilation system or significantly alter the 

integrity of the system. Porous ventilation system components which exhibit increased 

potential for fiber release (i.e. damaged internal surface bond or coating, and open internal 

seams and joints) shall be replaced or encapsulated with a product approved for that 

purpose upon completion of Mechanical Cleaning procedures. 

7.4 Encapsulation of Ventilation System Components: Encapsulation of porous or degraded 

porous ventilation system components shall be employed only after cleaning and successful 
7

completion of post-cleaning verification procedures by the Environmental Cleaning Contractor 

(see 8.2 of this document). 

7.4.1 Encapsulant coatings shall be applied directly to the interior porous surfaces of ventilation 

system components by hand brushing, rolling, or troweling, or via spray system, with a 

maximum distance of 24" from the spray discharge tip to the surface being treated. 

Encapsulant coatings may not be fogged into the system. A continuous film thickness 

should be achieved in treated areas, as per manufacturer's instructions. 

7.4.2 Ventilation system control devices, heating elements, sensing equipment, grilles, and fans 

must be adequately blocked off or masked so that they will remain free from over-spray 

from the Encapsulation process. 

7.5 Service openings: All access ways cut in the ventilation system for inspection and/or cleaning 

must be repaired so that they shall not significantly alter the airflow or adversely impact the 

facility's indoor air quality. All openings made in the ventilation system must be sealed in 

accordance with industry standards and local codes, using materials acceptable under those 

standards and codes (see Appendix B). 

7.6 Disposal of Debris: All waste and debris removed from the ventilation system shall be doublebagged in 6-mil polyethylene bags and disposed of in accordance with all applicable federal, 

state, and local requirements. 

8.0 QUALITY ASSURANCE

8.1 Health and Safety: The ventilation system/duct cleaning firm shall comply with all applicable 

federal, state, and local requirements for protecting the safety of the ventilation system/duct 

cleaning firm's employees, building occupants, and the environment. No processes or materials 

shall be employed in such a manner that they will create adverse health effects to the building 

occupants, the ventilation system/duct cleaning firm's employees, or the general public. 

8.1.1 The ventilation system/duct cleaning firm shall perform initial exposure monitoring of its 

employees for asbestos and lead in accordance with 29 CFR 1910. 1001 and 29 CFR 

1910.1025, respectively. 

8.1.2 Ventilation system/duct cleaning firm's employees shall use respiratory protection in 

compliance with OSHA 1910.134 

8.1.3 Regardless of exposure assessment results, at minimum the ventilation system/duct 

cleaning firm’s employees shall wear properly fitted, HEPA-filtered (P-100) negative 

half-mask respirators when performing any work related tasks on site which might expose 

them to elevated levels of airborne particulate. 

8.2 Post-cleaning Verification: Prior to re-commissioning a cleaned section of the ventilation 

system (at the end of the work shift, etc.), the ventilation system/duct cleaning firm will obtain 

cleanliness clearance from the Environmental Cleaning Contractor. Ventilation system 

cleanliness will be determined after mechanical cleaning and before the application of any 

surface treatment or introduction of any treatment-related substance to the ventilation system. 

Verification shall be conducted before the ventilation system is restored to normal operation. 
8

Ventilation system components may be evaluated by the Environmental Cleaning Contractor for 

visible cleanliness via direct visual inspection or with a visual inspection system (i.e., mirrors, 

boroscope, remote camera). The Environmental Cleaning Contractor may direct the ventilation 

system/duct cleaning firm to provide additional access openings into the ventilation system, as 

deemed necessary to thoroughly verify cleanliness. 

8.2.1 All porous and non-porous ventilation system surfaces must be visibly clean and capable 

of passing a visual inspection. 

8.2.2 Cleaning of non-porous ventilation system surfaces shall be verified by surface wipe 

sampling performed by the Environmental Cleaning Contractor using specified methods. 

Surface wipe sampling for man-made vitreous fibers, crystalline silica, lead and asbestos 

will be performed. Wipe sample results must meet the following criteria to established 

that cleaning has been adequate: 

• Lead – less that 25 micrograms of lead per square foot using the specified method 

• Asbestos – no asbestos detected using the specified method 

8.2.3 Pre-occupancy air testing: After successful completion of 8.2.1 and 8.2.2, and removal all 

polyethylene sheeting, containments and any remaining visible debris, the ventilation 

system shall be started up and air sampling for man-made vitreous fibers, crystalline 

silica, lead and asbestos will be performed performed by the Environmental Cleaning 

Contractor using specified methods. Airborne concentrations of these contaminants shall 

be within recommended guidelines for acceptable indoor air quality. Occupants may reenter the building only after successful completion of air monitoring. 

8.3 Materials and Workmanship: 

8.3.1 Work shall be executed by skilled persons who are thoroughly trained, experienced and 

completely familiar with the specified requirements and the methods needed for proper 

performance of the project, and shall be in conformance with the best practices of each 

trade involved. 

8.3.2 Work shall present a neat and workmanlike appearance when completed. 

8.3.3 Finish of materials and components shall be consistent with industry good practice. 

8.4 Cleaning: Work and storage areas shall be maintained and kept clean on a daily basis. The 

ventilation system/duct cleaning firm shall final clean the immediate work area(s) with a HEPAfiltered vacuum cleaner to be free of any residual visible WTC-related dust. Materials removed 

and debris resulting from the ventilation system/duct cleaning firm's work shall become the 

property of the ventilation system/duct cleaning firm and shall be removed for appropriate 

disposal (see 7.6 of this document). 

9.0 WORK SEQUENCE AND SCHEDULING

9.1 As a general procedure, cleaning work should follow the ventilation system airflow, beginning at 

the system's return air intakes. Cleaning should proceed from those points to the air handling unit 

(AHU), then out through the air discharge points. This work sequence will reduce the 
9

likelihood of cleaned portions of the ventilation system being re-contaminated if the system is 

reactivated at the end of the work shift. 

9.2 Additional precautions that may be used to protect cleaned surfaces of the ventilation system 

from being re-contaminated by uncleaned ventilation system surfaces. These may include: 1) the 

installation of temporary duct blanks or zoning devices to separate cleaned sections, and 2) 

installation of temporary air filters. 

10.0 PRODUCTS

10.1 Encapsulants: Ventilation system encapsulation products shall be for specific use in ventilation 

systems and applied per manufacturer's instructions. Encapsulants shall be water-based, with low 

VOC (volatile organic compound) emissions, and meet NFPA smoke development and flame 

spread requirements for HVAC system products. 

10.1.1 Ventilation system/duct cleaning firm shall maintain on-site MSDS copies for any 

encapsulant product used in the ventilation system. 

10.1.2 Ventilation system/duct cleaning firm will apply product in strict compliance with 

manufacturer's recommended safety precautions for Ventilation system/duct cleaning 

firm's personnel and building occupants. 

10.1.3 Ventilation system/duct cleaning firm shall comply with any applicable federal, state, or 

local regulations regarding the use of such products. 

10.2 Cleaning Chemicals: Any chemicals used in cleaning ventilation system components (i.e. 

chemical cleaners, degreasers, etc.) shall be applied per manufacturer's instructions. 

10.2.1 Ventilation system/duct cleaning firm shall maintain on-site MSDS copies for any 

cleaning chemical used in the ventilation system. 

10.2.2 Ventilation system/duct cleaning firm shall comply with any applicable federal, state, or 

local regulations regarding the use of such products. 

11.0 EXECUTION

11.1 Preparation - General 

11.1.1 Project Orientation/Preparation: Ensure that a site examination has been performed in 

accordance with Section 5.0 of this document. 

11.1.1.1 Task Coordination: A pre-task performance meeting shall be conducted for 

the project. 

11.1.1.2 Walk-through: Visually inspect the ventilation system prior to the start of 

work and note any mechanical modifications. Note location of all electrical 

panels for fuse reset. Note condition of fans, visible buildups, and accessible 

ductwork. 
10

11.1.2 Site Preparation: To minimize possible contamination and damage, the ventilation 

system/duct cleaning firm shall provide a negative pressure work area containment as 

necessary during ventilation system remediation. 

11.1.2.1 Negative pressure must be maintained by way of an attached external HEPAfiltered air filtration device. The vacuum must provide at least eight (8) airchanges in the containment per hour. 

11.1.2.2 The AHU servicing the area being cleaned must be shut down or zoned-off and 

remain so during the cleaning process. 

11.1.2.3 Only properly trained, authorized individuals may enter the work area while 

cleaning is being performed. 

11.1.3 System Access: Provide necessary access for cleaning and inspection of the ventilation 

system. 

11.1.3.1 Remove and poly bag diffusers if transport to decontamination area will be 

through non-containment areas. Clean all grilles and diffusers. Thoroughly dry 

grilles and diffusers prior to re-installing after cleaning. 

11.1.3.2 Install service openings as specified in Appendix B in return air handling 

systems as necessary to facilitate inspection and cleaning procedures. Access 

points should not exceed fifty (50) foot intervals to accommodate procedures 

and final inspection, unless otherwise deemed acceptable by the building 

management or Environmental Cleaning Contractor. 

11.1.3.3 The structural integrity of the ductwork shall not be significantly altered by the 

installation of service openings (See APPENDIX B). 

11.1.4 Duct Zoning: Ventilation system/duct cleaning firm will isolate sections of the 

ventilation system if needed to facilitate cleaning. 

11.1.4.1 Prior to cleaning, ventilation system airflow control devices may be repositioned 

and zoning devices installed in diffusers and ductwork as necessary to facilitate 

negative airflow from vacuum collection equipment and to avoid contamination 

from entering the conditioned air spaces. 

11.1.4.2 All zoning devices shall be removed and airflow control devices reset to their 

pre-cleaning positions upon completion of cleaning in the work area they serve. 

11.1.4.3 Zoning devices must be disposed of or cleaned free of contaminant debris or 

other suitable measures employed to prevent cross-contamination prior to reuse 

in other ventilation system areas. 
11

11.2 General Cleaning Procedures 

11.2.1 Hand wet-wiping: Wiping may be performed in cases where dry cleaning methods such as 

HEPA vacuuming or mechanical brushing, cannot successfully remove contaminants of concern. 

 Damp wiping should be performed with disposable towels or rags properly wetted with Simple 

Green or a similarly environmentally friendly degreasing agent. If disinfection is required, a 

Foster Products 40-80 HVAC and Wall Disinfectant or equivalent quarternary ammonium 

compound cleaning solution may be used. 

It is not necessary to establish negative pressure in locations where wet wiping is the only 

cleaning performed. If possible, the components to be cleaned should be removed, placed in a 6-

mil polyethylene bag, and cleaned outside of the occupant space. If removal of the components is 

not possible, use of a disposable drop cloth in the work area is recommended. 

11.2.2 Manual HEPA vacuum with soft bristle brush attachment: Manually vacuum internal HVAC 

surfaces from top to bottom to remove all visible debris. Maintain the cleaning zone under 

negative pressure (minimum -0.02 inches water gauge) using a HEPA filtered air filtration 

device during manual vacuuming 

11.2.3 Power driven mechanical or pneumatic brush system for duct runs: This type of equipment may 

only be used in ducts where negative pressure has been established using a HEPA filtered 

vacuum collection device (minimum of 3000 fpm air velocity in cleaning zone of the duct). 

Always work in the direction of the air flow. Apply the mechanical brushing equipment to 

dislodge debris from the interior surfaces of the duct. Following mechanical brushing, all 

surfaces of the cleaning zone shall be air washed with a pressurized air source to transport all 

dislodged debris to the vacuum collection device. Note that air washing alone is not a sufficient 

cleaning method and will not be considered acceptable for proper duct cleaning. 

11.2.4 Chemical wet cleaning of evaporator or chilled water coils: Wet cleaning of the coils and drip 

pan shall be performed using commercially available coil cleaner, subject to approval of 

Environmental Professional. Saturate the coils with a pump sprayer and thoroughly rinse with 

clean water. Cleaning solution and rinse water will collect in the condensate drain pan; if 

significant lead or asbestos contamination has been identified in the dust on the coils and/or in 

the drain pan, the water must be collected and tested for proper disposal. 

Maintain the cleaning zone under negative pressure using a HEPA filtered air filtration device. If 

odors are present and it is not possible to exhaust the HEPA filtered air filtration device outside 

the building, it may be necessary to use an activated carbon bed in air filtration device to 

eliminate odors. 

11.2.5 Electric Heating and Reheat coils: Clean electric heating and reheat coils using only dry 

methods. No water or encapsulant may come into contact with electric heating or re-heat coils. 

Dry clean using one or more of the following methods: 

11.2.6 Manual HEPA vacuum 

11.2.7 Pressurized air cleaning (only if cleaning zone is maintained under negative pressure) 

11.2.8 Manual brushing using manual HEPA vacuum to collect dust 
12

Maintain the cleaning zone under negative pressure using a HEPA filtered air filtration device 

whenever possible. 

11.3 Site-specific Cleaning Procedures 

11.3.1 Lemon Grass Restaurant 

This is a 2,351 sq ft space with variable ceiling height. One air handling unit is located above the 

ceiling toward the south end of the floor. This is a recirculating air unit with no outdoor air 

supply. Return air enters the unit through a grille located in the side of the unit. The air handling 

unit is accessible and is provided with access doors. The air handling unit distributes supply air 

through a main supply air duct and several branch ducts. Supply air diffuser openings are located 

on the underside of the supply duct (most of the diffusers have been removed). The supply 

diffuser openings extend in a line to the north of the air handling units and are spaced 

approximately 15’ apart. There are approximately four 18” supply diffuser openings located to 

the north of the air handling unit. There is a separate ducted make-up air system that delivers 

outdoor air to the cooking stations. The make-up air system consists of a single duct with 

diffuser openings on the underside of the duct, and a blower assembly that is located in-line with 

the duct. Outdoor air is provided to the make-up air system through a ducted outdoor air intake 

located in an exterior wall of the building approximately 10’ above ground level. 

VENTILATION SYSTEM COMPONENTS TO BE CLEANED 

The following system components will be cleaned in the Lemon Grass Restaurant: 

a. Air handling unit and components 

b. Reheat Coil 

c. Supply air ducts and terminal diffusers 

d. Makeup Air System 

e. Dissembled Duct Sections on Floor 

CLEANING PROCEDURES 

General: Any interior surfaces of the air handling unit or ventilation system that are porous shall 

be cleaned using manual HEPA vacuuming methods. After successful completion of visual 

inspection and verification sampling, a lockdown encapsulant shall be applied to the porous 

surfaces using a hand-operated sprayer or brush, using care not to coat electrical or mechanical 

components. 

Note that if any dissembly of the air handling units is required to complete the work, the air 

handling unit shall be reassembled by a qualified HVAC professional after all parts are dry and 

are verified clean. 

Note that all HEPA air filtration devices and HEPA-filtered vacuum collection devices shall be 

exhausted to the outdoors. 
13

Air Handling Unit

1. Ensure that the air handling unit motor is locked out and is electrically isolated, and place 

the air handling unit and its components under containment prior to beginning work. A 

temporary Zip-wall containment of 6-mil, fire retardant polyethylene sheeting extending from 

the floor to the ceiling deck, and maintained under negative pressure using a HEPA-filtered 

air filtration device is sufficient. The footprint of the containment should be large enough to 

accommodate a ladder or scaffolding. Note that WRS Infrastructure and Environment, Inc. 

may construct the containment prior to the start of ventilation system cleaning. In addition, 

WRS Infrastructure and Environment, Inc. shall install a service opening to facilitate cleaning 

of interior components. The access panel shall be installed in the supply air duct between the 

blower and the reheat coil. 

2. Clean the filter racks at the return air side of the unit by damp wiping. 

3. Prior to cleaning, place polyethylene sheeting underneath the coils. Wet clean the 

upstream and downstream sides of cooling coils. Apply manufacturer-approved cleaning 

solution to the coils using low pressure methods (i.e., airless sprayer, hand operated pump). 

4. Clean the blower assembly and blower housing in place. The blower assembly and 

blower housing shall be cleaned by a combination of hand vacuuming, damp wiping and air 

washing. As required in this document, air washing shall only be performed after a vacuum 

collection device has been installed. 

5. HEPA vacuum remaining interior surfaces and components (e.g., condenser equipment 

and compartment, controls, outside air vent to condenser compartment) to remove all visible 

debris. No encapsulant materials may be used inside the condenser compartment. 

6. Perform a final cleaning by wet-wiping and/or HEPA vacuuming methods of the interior 

work area containment surfaces, ladders, equipment etc. prior to final visual inspection and 

wipe sampling. 

Reheat Coils

1. Clean the electric reheat coil (located inside the supply air duct) by dry vacuuming or air 

washing. No liquids may come into contact with the electric reheat coil. 

Supply Air Ducts and Terminal Diffusers

1. Remove all terminal diffusers into 6-mil polyethylene bags and proceed to the enclosure 

constructed for cleaning of the air handling unit. Terminal diffusers shall be wet-cleaned. 

The diffusers should be sprayed with Simple Green or a similar environmentally safe 

degreaser and hand washed as needed to remove adhered materials. 

2. Seal the diffuser openings using 6-mil polyethylene sheeting to be secured with duct tape. 

3. Install a vacuum collection device at the terminal end of the duct section to be cleaned. If the 

entire duct is not cleaned as one unit, then isolate the section of the duct to be cleaned using a 

zoning device. 

4. The supply air duct shall be cleaned using a pressurized air/mechanical brush system in 

 combination with a vacuum collection device. The direction of cleaning shall be from the air 

handler toward the terminal end of the duct. (It is permissible to use a mechanical brush 

 followed by application of pressurized air in lieu of combination style equipment.) The 
14

 vacuum collection equipment shall be configured to maintain a minimum of 3000 feet per 

minute air velocity in the cleaning zone. 

Make –Up Air System

1. All non-porous surfaces of the outdoor air intake located on the exterior of the building 

shall be cleaned using manual wet-wiping and HEPA vacuuming methods as needed to 

remove adhered materials. Note that the air intake for the condenser compartment of the 

air handling unit is located adjacent to the outdoor air intake for the makeup air system 

and should be cleaned concurrently. 

2. The section of the duct from the outdoor air intake through the blower unit shall be 

cleaned using HEPA vacuum methods. It may be necessary to install a service opening in 

order to perform this cleaning. 

3. Clean blower assembly and blower housing in place by a combination of hand 

vacuuming, damp wiping and air washing. As required in this document, air washing 

shall only be performed after a vacuum collection device has been installed. 

4. Seal the diffuser openings using 6-mil ethylene sheeting to be secured with duct tape. 

5. The makeup air duct shall be cleaned using a pressurized air mechanical brush system in 

combination with a vacuum collection device. The direction of cleaning shall be from the 

blower assembly toward the terminal end of the duct. (It is permissible to use a 

mechanical brush followed by application of pressurized air in lieu of combination style 

equipment.) It may be necessary to install a service opening in order to perform the duct 

cleaning. The vacuum collection equipment shall be configured to maintain a minimum of 

3000 feet per minute air velocity in the cleaning zone. 

Dissembled Duct Sections on Floor

1. Transport dissembled duct sections to the enclosure constructed for cleaning of the air 

handling unit for wet cleaning. The dissembled duct sections should be sprayed with 

Simple Green or a similar environmentally safe degreaser and hand washed as needed to 

remove adhered materials. 

11.3.2 Food Exchange Restaurant 

This is a 2,324 sq ft space with 10’ high suspended acoustical ceiling on the south side and a 

solid gypsum drywall suspended ceiling on the north side. An older tin ceiling is present on the 

deck of the south side and an additional layer of gypsum is attached to the deck on the north side. 

 Prior to the start of work, the suspended acoustical ceiling on the south side will be removed by 

WRS Infrastructure and Environment, Inc. 

Two nearly side-by-side air handling units are located above the ceiling. These are recirculating 

air units with no outdoor air supply. Return air enters the ceiling plenum through passive return 

grilles located in the false ceiling below each unit. The air handling units draw return air from the 

ceiling plenum through grilles in the sides of the units. The air handling units distribute supply air 

to supply air ducts that extend to the north and to the south of the units. The ducts are 

approximately 50’ long (north-south dimension). Supply air is distributed to the occupant space 

through supply diffusers off of the supply duct; the diffusers are flush with the false ceiling. 

There are supply grilles off the supply air duct that extend in a line to the north and to the south 
15

of the air handling units; these are spaced approximately 15’ apart. There are 5 supply grilles 

each located to the north and south of the air handling units.. The air handling unit is not 

provided with access doors and is difficult to access. 

VENTILATION SYSTEM COMPONENTS TO BE CLEANED 

The following system components in the Food Exchange Restaurant will be cleaned: 

a. Air handling units and components 

b. Supply air ducts and terminal diffusers 

CLEANING PROCEDURES 

General: Any interior surfaces of the air handling unit or ventilation system that are porous shall 

be cleaned using manual HEPA vacuuming methods. After successful completion of visual 

inspection and verification sampling, a lockdown encapsulant shall be applied to the porous 

surfaces using a hand-operated sprayer or brush, using care not to coat electrical or mechanical 

components. 

Note that if any dissembly of the air handling units is required to complete the work, the air 

handling unit shall be reassembled by a qualified HVAC professional after all parts are dry and 

are verified clean. 

Note that all HEPA air filtration devices and HEPA-filtered vacuum collection devices shall be 

exhausted to the outdoors. 

Air Handling Units

1. Ensure that the air handling unit motors are locked out and is electrically isolated, and place 

the air handling units and their components under containment prior to beginning work. A 

temporary Zip-wall containment of 6-mil, fire retardant polyethylene sheeting extending from 

the floor to the ceiling deck, and maintained under negative pressure using a HEPA-filtered 

air filtration device is sufficient. The footprint of the containment should be large enough to 

accommodate a ladder or scaffolding. Note that WRS Infrastructure and Environment, Inc. 

may construct the containment prior to the start of ventilation system cleaning. 

2. Clean the filter racks at the return air sides of the units by damp wiping. 

3. Prior to cleaning, place polyethylene sheeting underneath the coils. Wet clean the upstream 

and downstream sides of cooling coils. Apply manufacturer-approved cleaning solution to 

the coils using low pressure methods (i.e., airless sprayer, hand operated pump). 

4. Clean the blower assembly and blower housing in place. The blower assembly and blower 

housing shall be cleaned by a combination of hand vacuuming, damp wiping and air washing. 

 As required in this document, air washing shall only be performed after a vacuum collection 

device has been installed. 

5. HEPA vacuum remaining interior surfaces and components to remove all visible debris. No 

encapsulant materials may be used inside the condenser compartment. 
16

Reheat Coils

1. Note that if reheat coils are present, by dry vacuuming or air washing. No liquids may come 

into contact with the electric reheat coil. 

Supply Air Ducts and Terminal Diffusers

1. Remove all terminal diffusers into 6-mil polyethylene bags and proceed to the enclosure 

constructed for cleaning of the air handling unit. Terminal diffusers shall be wet-cleaned. 

The diffusers should be sprayed with Simple Green or a similar environmentally safe 

degreaser and hand washed as needed to remove adhered materials. 

2. Seal the diffuser openings using 6-mil polyethylene sheeting to be secured with duct tape. 

3. Install a vacuum collection device at the terminal end of the duct section to be cleaned. If the 

entire duct is not cleaned as one unit, then isolate the section of the duct to be cleaned using a 

zoning device. 

4. The supply air duct shall be cleaned using a pressurized air/mechanical brush system in 

combination with a vacuum collection device. The direction of cleaning shall be from the air 

handler toward the terminal end of the duct. (It is permissible to use a mechanical brush 

followed by application of pressurized air in lieu of combination style equipment.) The 

vacuum collection equipment shall be configured to maintain a minimum of 3000 feet per 

minute air velocity in the cleaning zone. (See Requirements Section for use of this 

equipment.) 

11.3.3 Combustion Make-up Air Riser 

The combustion make-up air riser extends from the ceiling of a second floor mechanical closet to 

the roof of the building. 

VENTILATION SYSTEM COMPONENTS TO BE CLEANED 

The following system components will be cleaned: 

a. Combustion riser 

b. Associated vents 

c. Roof cap 

CLEANING PROCEDURES 

Note that the HEPA-filtered vacuum collection devices shall be exhausted to the outdoors. 

Combustion riser, associated vents and roof cap

1. Remove all vents into 6-mil polyethylene bags and proceed to work area appropriate for 

cleaning the vents. The vents shall be wet-cleaned. The vents should be sprayed with Simple 

Green or a similar environmentally safe degreaser and hand washed as needed to remove 

adhered materials. 

2. Seal the vent openings using 6-mil polyethylene sheeting to be secured with duct tape. 

3. Install a vacuum collection device at the bottom of the riser on the second floor. 
17

4. The combustion riser shall be cleaned using a pressurized air/mechanical brush system in 

combination with a vacuum collection device. The direction of cleaning shall be from the 

roof down toward the second floor. (It is permissible to use a mechanical brush followed by 

application of pressurized air in lieu of combination style equipment.) The vacuum collection 

equipment shall be configured to maintain a minimum of 3000 feet per minute air velocity in 

the cleaning zone. (See Requirements Section for use of this equipment.) 

5. Remove the roof cap if possible and place on a polyethylene sheet. Wet-clean by damp 

wiping in place or if removed, spray with Simple Green or a similar environmentally safe 

degreaser and hand wash as needed to remove adhered materials. 
1

APPENDIX A 

DEFINITIONS

1. Access Doors: Covers for service openings consisting of pre-fabricated operable or removable 

entry panels, which are installed in a ventilation system to facilitate inspection and maintenance 

services. 

2. Air Conveyance System, Air Handling System, HVAC System, Ventilation System: The 

ventilation system is any interior surface of a building's air distribution system for conditioned 

spaces and/or occupied zones (See definition of air handling system, ASHRAE 62-1989). This 

includes the entire air distribution system from the points that the air enters the system to the 

points that air is discharged from the system. The return air grilles, air ducts (except ceiling 

plenums) to the air handling unit (AHU), the interior surface of the AHU, mixing box, coil 

compartment, condensate drain pans, humidifiers, and dehumidifiers, supply air ducts, fans, fan 

housing, fan blades, spray eliminators, turning vanes, filters, filter housings, reheat coils, and 

supply diffusers are all considered part of the ventilation system. 

3. Air Filtration Device (also referred to as Negative Air Machine): An external air moving 

device which can be temporarily connected to a section or sections of an ventilation system to 

create negative airflow for cleaning and remediation procedures, employing a minimum of 

DOP-tested HEPA final filtration if exhausted indoors. 

4. Air Washing: For duct cleaning, this term applies to the use of pressurized air, in combination 

with a Vaccuum Collection Device, for transporting dislodged debris into the vacuum 

collection equipment. 

5. Ceiling Plenum: A non-ducted area between the ceiling over a conditioned building space and 

the floor above, through which air is transported to a conditioned space from an ventilation 

system (ceiling supply air plenum), or from a conditioned space to an ventilation system 

(ceiling return air plenum). 

6. Coils: Devices inside the ventilation system, which temper and/or dehumidify the air 

transported by the ventilation system. These include heat exchangers, with or without extended 

surfaces, through which either water, ethylene glycol solution, brine, volatile refrigerant, steam, 

or electricity is circulated for the purpose of total cooling (sensible cooling plus latent cooling) 

or sensible heating of a forced-circulation air stream (See ASHRAE 33-78 and ARI 410-91). 

7. Debris: Any solid materials, including particulate substances, in the ventilation system not 

intended to be present. 

8. DOP Testing: The percentage of removal of 0.3 micrometer particles of dioctylphthalate 

(DOP) is used to rate high efficiency air filters, those with efficiencies above about 98 percent 

(See Military Standard 282, U.S. Department of Defense, 1956). 

9. Ductwork (Ducts): A system of passageways for distribution and extraction of air (See 

ASHRAE Terminology of Heating, Ventilation, Air Conditioning, and Refrigeration, 1991). 
2

10. Encapsulation: The application of a bridging (resurfacing) or penetrating compound on 

internal ventilation system surfaces to bond, mechanically resurface, or lock-down fibrous and 

other ventilation system components which have deteriorated or been damaged, to control the 

entrainment of particulates from these components into the airstream. 

11. Environmental Cleaning Contractor: The Environmental Cleaning Contractor at 110 Liberty 

Street is WRS Infrastructure and Environment, Inc., as the authorized by the USEPA . 

12. Environmental Service Contractor: An independent environmental contractor performing an 

initial assessment of the WTC-related dust, as authorized by the USEPA 

13. Fan: A power driven machine that moves a volume of air by converting rotational mechanical 

energy to an increase in the total pressure of the moving air (See AMCA 99-86). 

14. HEPA Filter: High efficiency particulate air filter capable of a 99.97% collection efficiency for 

a 0.3 micron size particle as per DOP testing. 

15. Mechanical Cleaning: Physical removal of debris and other foreign matter from ventilation 

system surfaces. 

16. Negative Air (Vacuum Collection) Cleaning: Procedure for removal of debris from a 

ventilation system using a HEPA-filtered Vacuum Collection Device for particulate control and 

capture. 

17. Non-Porous Surface: Any surface of the ventilation system in contact with the air stream 

which cannot be penetrated by either solutions or air. This would exclude ventilation system 

materials such as wood, fiberboard, thermal/acoustic insulation, and concrete. 

18. Porous Surface: Any surface of the ventilation system in contact with the air stream which can 

be penetrated by either solutions or air, including but not limited to ventilation system materials 

such as wood, fiberboard (ductboard), fibrous thermal/acoustic insulation, and concrete. 

19. Pressure Drop: (1) Loss in pressure, as from one end of a refrigerant line to the other, from 

friction, static, heat, etc. (2) Difference in pressure between two points in a flow system, 

usually caused by frictional resistance to fluid flow in a conduit, filter, or other flow system 

(See ASHRAE Terminology of Heating, Ventilation, Air Conditioning, and Refrigeration, 

1991). 

20. Sanitization: A process to reduce the proliferation of microbial growth in an ventilation 

system, usually involving the application of a biocide agent. 

21. Source Removal: An HVAC hygiene mitigation process, which involves the physical capture, 

removal, and controlled containment of foreign matter from an ventilation system. 

22. Static Pressure: The normal force per unit area that is exerted on the interior surfaces of the 

ventilation system by the air. 
3

23. ULPA Filter: High efficiency particulate air filter capable of a 99.99% collection efficiency for 

a 0.1 micron size particle. 

24. Vacuum Collection Device or Equipment: a HEPA-filtered device for duct cleaning used to 

place a duct system or sections of a duct system under negative pressure and to collect and 

transport dust and debris that has been dislodged by mechanical cleaning. This device 

overcomes greater static pressures than those typical of air filtration devices. 

25. Ventilation system/duct cleaning firm: Service firm contracted to provide ventilation system 

cleaning and/or hygiene remediation for a facility. 

26. Visibly Clean: Determined by internal visual inspection, that all portions or components of the 

ventilation system are free of any visible debris. 

27. Visual Inspection: Examination of ventilation system components to evaluate the presence of 

visible contamination using the human eye other optical instrument. Visual inspection may be 

aided by the use of telescoping inspection mirrors and flashlights inserted through service 

openings. 

28. Visual Inspection System (VIS): Optical device such as a still camera, borescope, or CCTV 

(closed circuit television) video camera system employed to perform a visual hygiene 

evaluation and/or documentation of internal areas in an HVAC system. 

29. Zoning Device: A physical barrier consisting of a balloon or other device for 

blocking/segregating a ventilation duct. 
1

APPENDIX B 

INSTALLATION OF SERVICE OPENINGS IN AIR HANDLING SYSTEMS

[B.1] Service openings in Sheet Metal Ventilation System Components: Any Service openings shall 

be made in such a way as to not significantly weaken the structural integrity of the metal 

ventilation system component and provide an air tight seal once secured. Ventilation 

system/duct cleaning firm must provide a finished surface deemed visually acceptable by the 

Client and in the opinion of the Client, not reduce the building's aesthetic qualities. Work cut 

and patched in an unsatisfactory manner shall be removed and replaced by the Ventilation 

system/duct cleaning firm at no additional cost to the Client. Upon completion of inspection 

and/or cleaning services, the Service openings shall be sealed in accordance with job 

specifications, with one of the following closure techniques: 

 (1) Install gasketed removable Access Doors. 

 (2) Install sheet metal panels fastened with sheet metal screws and sealed with silicone 

chalk, mastic or duct sealant. 

[B.2] Service openings in Externally Insulated Sheet Metal Ventilation System Components: (See 

[C.1] Service openings in Sheet Metal Ventilation System Components) Upon closure of 

Access Hole, external insulation must be replaced as necessary and the edges secured with 

either an approved water-based bridging encapsulant for canvas-wrapped insulated duct 

exteriors or reinforced 4" wide foil tape on foil-faced insulated duct exteriors. 

[B.3] Service openings in Fibrous Lined Sheet Metal Ventilation System Components: Any Service 

openings shall be made in such a way as to not significantly weaken the structural integrity of 

the metal ventilation system component or create fiber shed from the internal insulation at the 

cut area once the Access Hole is closed. Upon completion of inspection and/or cleaning 

services, the Service openings shall be sealed in accordance with the following closure 

techniques: 

(1) Install gasketed, insulated Access Doors. The cut edge of the internal insulation lining 

at the Access Hole must be sealed with an approved Bridging Encapsulant to prevent 

fiber shed, and the insulation on the cover plate should fit securely in the cut-out area. 

(2) Pressure fitting round hole plugs (for Service openings 3" diameter or smaller in 

low/medium positive air pressure applications) after an approved ventilation system 

Bridging Encapsulant has been applied to the cut edge of the internal insulation to 

prevent fibershed. 

(3) Install sheet metal panels affixed with similar insulation to match the removed portion 

of insulation from the service opening, fastened with sheet metal screws and sealed with 

silicone chalk, mastic or duct sealant. The cut edge of the internal insulation lining at 

the Access Hole must be sealed with an approved bridging encapsulant to prevent fiber 

shed, and the insulation on the cover plate should fit securely in the cut-out area. 
2

[B.4] Service openings in Fibrous Glass Ventilation System Components (Duct board): Any Service 

openings shall be made in such a way as to not significantly weaken the structural integrity of the 

Fibrous Glass Ventilation System Component or create fiber shed from the product at the cut area once 

the Access Hole is closed. Upon completion of inspection and/or cleaning services, the Service 

openings shall be sealed in accordance with job specifications, with one of the following closure 

techniques: 

 (1) Install gasketed, insulated Access Doors which will seal the internal cut edge to prevent 

fibershed, or after an approved ventilation system Bridging Encapsulant has been 

applied to the cut edge of the internal insulation to prevent fibershed 

 (2) Make a shiplap or a 45 degree inward "pumpkin" access cut in the ductboard, and 

reinstall the cut piece after inspection and/or cleaning with a tape that complies with UL 

181 or UL 181A closure systems (See NAIMA's Cleaning Fibrous Glass Insulated Air 

Duct Systems - Recommended Practice, 1993). 
Attachment J 

Reporting of Analytical Results 
KEY FOR THE ANALYTICAL TABLES

Compound/Type Analytical Method Units Criterion

Asbestos

Air PCM f/cc 0.01 (secondary) 

 TEM AHERA S>0.5_/cc 0.022 (secondary) 

 TEM PCMe S>5_/cc 0.0009 (primary clearance)) 

Micro vacuum TEM AHERA S/cm2

 not available 

Wipe TEM AHERA S/cm2

 not available 

Dioxin - TEQ EMPC (ND=1/2)

Air Method 8290 ng/m3 0.001 (primary clearance) 

Wipe Method 8290 ng/m2

 4 (primary clearance) 

Gypsum

Air NIOSH 7500 mg/m3

 not available 

Wipe NIOSH 7500 mg/m2

 not available 

Lead

Air NIOSH 7300 _g/m3

 1 (primary clearance) 

Micro vacuum NIOSH 7300 _g/ft2 25 (comparison value) 

Wipe NIOSH 7300 _g/ft2 25 (primary clearance) 

Mineral: alpha-Quartz

Air NIOSH 7500 mg/m3 4 (primary clearance) 

Wipe NIOSH 7500 mg/m2 not available 

Mineral: Calcite

Air NIOSH 7500 mg/m3 not available 

Wipe NIOSH 7500 mg/m2

 not available 

Mineral: Cristobalite

Air NIOSH 7500 mg/m3 not available 

Wipe NIOSH 7500 mg/m2 not available 

Mineral: Tridymite

Air NIOSH 7500 mg/m3

 not available 

Wipe NIOSH 7500 mg/m2 not available 

MMVF

Air SEM/PLM mmvf_S/L 10 (primary clearance) 

Wipe SEM/PLM mmvf_S/c not available 

 (=S/cm2) 

PAH

Air Method 8270 _g/m3

 0.2 (primary clearance) 

Wipe Method 8270 _g/m2

 300 (primary clearance) 

Total Dust

Micro vacuum NADCA mg/cm2

 0.5 (secondary) 

 
Page 1 of 4

Unit 2B Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-2B-005 Microvac 6331.52 S/cm2 Chrysotile

9094-M-2B-006 Microvac 11871.6 S/cm2 Chrysotile

9094-M-2B-007 Microvac 25326.1 S/cm2 Chrysotile

9094-W-2B-001 Wipe ND < 2366.41 S/cm2

9094-W-2B-002 Wipe ND < 2366.41 S/cm2 Anthophyllite/Chrysotile

9094-W-2B-003 Wipe 102096 S/cm2 Chrysotile

9094-W-2B-004 Wipe 5540.08 S/cm2 Chrysotile

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-008 Air 0.003 f/cc

9094-A-2B-009 Air 0.005 f/cc

9094-A-2B-010 Air 0.002 f/cc

9094-A-2B-008 Air 0.0068 S>0.5u/cc Chrysotile

9094-A-2B-009 Air 0.0095 S>0.5u/cc Chrysotile

9094-A-2B-010 Air 0.0026 S>0.5u/cc Chrysotile

9094-A-2B-008 Air ND < 0.0009 S>5u/cc Chrysotile

9094-A-2B-009 Air ND < 0.0009 S>5u/cc Chrysotile

9094-A-2B-010 Air ND < 0.0009 S>5u/cc Chrysotile

9094-M-2B-020 Microvac 22160.3 S/cm2 Chrysotile

9094-M-2B-021 Microvac 10288.7 S/cm2 Chrysotile

9094-M-2B-022 Microvac 72284.9 S/cm2 Chrysotile

9094-M-2B-023 Microvac 11080.2 S/cm2 Chrysotile

9094-W-2B-015 Wipe ND < 5916.01 S/cm2

9094-W-2B-016 Wipe ND < 5916.01 S/cm2

9094-W-2B-017 Wipe ND < 5916.01 S/cm2 Chrysotile

9094-W-2B-018 Wipe ND < 5916.01 S/cm2 Chrysotile

9094-W-2B-019 Wipe 5935.8 S/cm2 Chrysotile

 
Page 2 of 4

Unit 2B Results

 Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-2B-002 Wipe 0.488 ng/m2

9094-W-2B-003 Wipe 0.526 ng/m2

9094-W-2B-004 Wipe 0.642 ng/m2

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-W-2B-016 Wipe 0.556 ng/m2

9094-W-2B-017 Wipe 0.522 ng/m2

9094-W-2B-018 Wipe 0.476 ng/m2

9094-W-2B-019 Wipe 0.563 ng/m2

Gypsum

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-013 Air ND < 0.016 mg/m3

9094-A-2B-014 Air ND < 0.016 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-2B-005 Microvac ND < 2.32 ug/ft2

9094-M-2B-006 Microvac 4.54 ug/ft2

9094-M-2B-007 Microvac ND < 2.32 ug/ft2

9094-W-2B-002 Wipe ND < 4.65 ug/ft2

9094-W-2B-003 Wipe 97 ug/ft2

9094-W-2B-004 Wipe 17.5 ug/ft2

 
Page 3 of 4

Unit 2B Results

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-011 Air 0.197 ug/m3

9094-A-2B-012 Air 0.193 ug/m3

9094-M-2B-020 Microvac ND < 2.32 ug/ft2

9094-M-2B-021 Microvac ND < 2.32 ug/ft2

9094-M-2B-022 Microvac ND < 2.32 ug/ft2

9094-M-2B-023 Microvac ND < 2.32 ug/ft2

9094-W-2B-016 Wipe ND < 4.65 ug/ft2

9094-W-2B-017 Wipe 9.9 ug/ft2

9094-W-2B-018 Wipe 18.7 ug/ft2

9094-W-2B-019 Wipe 7.41 ug/ft2

Post 2nd cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-024 Air 0.309 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-013 Air ND < 0.004 mg/m3

9094-A-2B-014 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-013 Air ND < 0.016 mg/m3

9094-A-2B-014 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-013 Air ND < 0.016 mg/m3

9094-A-2B-014 Air ND < 0.016 mg/m3

 
Page 4 of 4

Unit 2B Results 

 Mineral: Tridymite

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-013 Air ND < 0.016 mg/m3

9094-A-2B-014 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-2B-002 Wipe 629.55 S/cm2

9094-W-2B-003 Wipe 13163.22 S/cm2

9094-W-2B-004 Wipe 400.62 S/cm2

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-2B-008 Air 6.645 S/L

9094-A-2B-009 Air 1.685 S/L

9094-A-2B-010 Air 3.922 S/L

9094-W-2B-015 Wipe ND < 57.23 S/cm2

9094-W-2B-016 Wipe 114.46 S/cm2

9094-W-2B-017 Wipe 228.93 S/cm2

9094-W-2B-018 Wipe 171.69 S/cm2

9094-W-2B-019 Wipe 171.69 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-2B-002 Wipe U 290 ug/m2

9094-W-2B-003 Wipe U 290 ug/m2

9094-W-2B-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-W-2B-016 Wipe U 290 ug/m2

9094-W-2B-017 Wipe U 290 ug/m2

9094-W-2B-018 Wipe U 290 ug/m2

9094-W-2B-019 Wipe U 290 ug/m2
Page 1 of 5 

Unit 2A Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-2A-006 Microvac 3561.48 S/cm2 Chrysotile

9094-M-2A-007 Microvac 30866.2 S/cm2 Chrysotile

9094-M-2A-008 Microvac 20973.2 S/cm2 Chrysotile

9094-M-2A-009 Microvac ND < 1582.88 S/cm2

9094-W-2A-001 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-2A-002 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-2A-003 Wipe 56192.2 S/cm2 Chrysotile

9094-W-2A-004 Wipe 18994.6 S/cm2 Chrysotile

9094-W-2A-005 Wipe 3165.76 S/cm2 Chrysotile

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-010 Air 0.003 f/cc

9094-A-2A-011 Air 0.003 f/cc

9094-A-2A-012 Air 0.002 f/cc

9094-A-2A-010 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-2A-011 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-2A-012 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-2A-010 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-2A-011 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-2A-012 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-2A-022 Microvac 45903.5 S/cm2 Chrysotile

9094-M-2A-023 Microvac ND < 3165.76 S/cm2 Chrysotile. Asbestos detected 

below detection limit.

9094-M-2A-024 Microvac 13454.5 S/cm2 Chrysotile

9094-W-2A-017 Wipe ND < 1183.2 S/cm2

9094-W-2A-018 Wipe ND < 1183.2 S/cm2

 
Page 2 of 5 

Unit 2A Results

9094-W-2A-019 Wipe 4396.89 S/cm2 Chrysotile

9094-W-2A-020 Wipe ND < 2366.41 S/cm2 Chrysotile. Asbestos detected 

below detection limit.

9094-W-2A-021 Wipe ND < 1183.2 S/cm2

Post 2nd Cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-025 Air 0.001 f/cc

9094-A-2A-026 Air 0.001 f/cc

9094-A-2A-027 Air 0.001 f/cc

9094-A-2A-028 Air 0.002 f/cc

9094-A-2A-029 Air 0.001 f/cc

9094-A-2A-030 Air 0.001 f/cc

9094-A-2A-025 Air 0.0022 S>0.5u/cc Chrysotile

9094-A-2A-026 Air 0.0013 S>0.5u/cc Chrysotile

9094-A-2A-027 Air 0.0042 S>0.5u/cc Chrysotile

9094-A-2A-028 Air ND < 0.0005 S>0.5u/cc

9094-A-2A-029 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-2A-030 Air ND < 0.0005 S>0.5u/cc

9094-A-2A-025 Air 0.0004 S>5u/cc Chrysotile

9094-A-2A-026 Air 0.0009 S>5u/cc Chrysotile

9094-A-2A-027 Air 0.0004 S>5u/cc Chrysotile

9094-A-2A-028 Air ND < 0.0005 S>5u/cc

9094-A-2A-029 Air ND < 0.0005 S>5u/cc

9094-A-2A-030 Air ND < 0.0005 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-2A-002 Wipe 0.585 ng/m2

9094-W-2A-003 Wipe 1.21 ng/m2

9094-W-2A-004 Wipe 0.752 ng/m2

9094-W-2A-005 Wipe 0.843 ng/m2

 
Page 3 of 5 

Unit 2A Results

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-W-2A-018 Wipe 0.557 ng/m2

9094-W-2A-019 Wipe 0.507 ng/m2

9094-W-2A-020 Wipe 0.556 ng/m2

9094-W-2A-021 Wipe 0.647 ng/m2

Gypsum

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-015 Air ND < 0.016 mg/m3

9094-A-2A-016 Air ND < 0.016 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-2A-006 Microvac 4.03 ug/ft2

9094-M-2A-007 Microvac 14.4 ug/ft2

9094-M-2A-008 Microvac 3.89 ug/ft2

9094-M-2A-009 Microvac ND < 2.32 ug/ft2

9094-W-2A-002 Wipe ND < 4.65 ug/ft2

9094-W-2A-003 Wipe 49.4 ug/ft2

9094-W-2A-004 Wipe 35.4 ug/ft2

9094-W-2A-005 Wipe 44.6 ug/ft2

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-013 Air ND < 0.052 ug/m3

9094-A-2A-014 Air ND < 0.052 ug/m3

9094-M-2A-022 Microvac ND < 2.32 ug/ft2

9094-M-2A-023 Microvac ND < 2.32 ug/ft2

9094-M-2A-024 Microvac ND < 2.32 ug/ft2

9094-W-2A-018 Wipe ND < 4.65 ug/ft2

 
Page 4 of 5 

Unit 2A Results 

 9094-W-2A-019 Wipe 11.3 ug/ft2

9094-W-2A-020 Wipe ND < 4.65 ug/ft2

9094-W-2A-021 Wipe ND < 4.65 ug/ft2

Mineral: alpha-Quartz

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-015 Air ND < 0.004 mg/m3

9094-A-2A-016 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-015 Air ND < 0.016 mg/m3

9094-A-2A-016 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-015 Air ND < 0.016 mg/m3

9094-A-2A-016 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-015 Air ND < 0.016 mg/m3

9094-A-2A-016 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-2A-002 Wipe ND < 57.23 S/cm2

9094-W-2A-003 Wipe 629.55 S/cm2

9094-W-2A-004 Wipe 2117.56 S/cm2

9094-W-2A-005 Wipe 343.39 S/cm2

 
Page 5 of 5 

Unit 2A Results

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-A-2A-010 Air 0.825 S/L

9094-A-2A-011 Air 0.617 S/L

9094-A-2A-012 Air 1.284 S/L

9094-W-2A-017 Wipe 57.23 S/cm2

9094-W-2A-018 Wipe 114.46 S/cm2

9094-W-2A-019 Wipe 171.69 S/cm2

9094-W-2A-020 Wipe 57.23 S/cm2

9094-W-2A-021 Wipe 114.46 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-2A-002 Wipe U 290 ug/m2

9094-W-2A-003 Wipe 290 ug/m2

9094-W-2A-004 Wipe U 290 ug/m2

9094-W-2A-005 Wipe U 290 ug/m2

Post 1st cleaning - Test 1B

Sample ID Matrix Detected Result Comment

9094-W-2A-018 Wipe U 290 ug/m2

9094-W-2A-019 Wipe U 290 ug/m2

9094-W-2A-020 Wipe U 290 ug/m2

9094-W-2A-021 Wipe U 290 ug/m2
Page 1 of 2

2nd Floor Hallway Results

Asbestos

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-001 Air 0.003 f/cc

9094-A-2ND-002 Air 0.002 f/cc

9094-A-2ND-001 Air 0.0011 S>0.5u/cc Chrysotile

9094-A-2ND-002 Air 0.0025 S>0.5u/cc Chrysotile

9094-A-2ND-001 Air 0.0005 S>5u/cc Chrysotile

9094-A-2ND-002 Air ND < 0.0005 S>5u/cc

Gypsum

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-005 Air ND < 0.009 mg/m3

9094-A-2ND-006 Air ND < 0.009 mg/m3

Lead

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-003 Air ND < 0.052 ug/m3

9094-A-2ND-004 Air ND < 0.052 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-005 Air ND < 0.004 mg/m3

9094-A-2ND-006 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-005 Air ND < 0.017 mg/m3

9094-A-2ND-006 Air ND < 0.017 mg/m3
Page 2 of 2

2nd Floor Hallway Results

Mineral: Cristobalite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-005 Air ND < 0.017 mg/m3

9094-A-2ND-006 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-005 Air ND < 0.017 mg/m3

9094-A-2ND-006 Air ND < 0.017 mg/m3

MMVF

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-2ND-001 Air ND < 0.071 S/L

9094-A-2ND-002 Air 0.067 S/L
Page 1 of 4

Unit 3A Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-3A-005 Air 0.006 f/cc

9094-A-3A-006 Air 0.004 f/cc

9094-A-3A-005 Air ND < 0.0009 S>5u/cc

9094-A-3A-006 Air ND < 0.0008 S>5u/cc

9094-M-3A-006 Microvac 116688 S/cm2 Chrysotile

9094-M-3A-007 Microvac 435336 S/cm2 Chrysotile

9094-M-3A-008 Microvac 72805.3 S/cm2 Chrysotile

9094-M-3A-009 Microvac 80784 S/cm2 Chrysotile

9094-W-3A-001 Wipe ND < 2366.41 S/cm2

9094-W-3A-002 Wipe ND < 2366.41 S/cm2

9094-W-3A-003 Wipe ND < 2366.41 S/cm2

9094-W-3A-004 Wipe 4748.64 S/cm2 Chrysotile

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-010 Air 0.004 f/cc

9094-A-3A-011 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3A-012 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3A-010 Air 0.0009 S>0.5u/cc Chrysotile

9094-A-3A-011 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3A-012 Air 0.0009 S>0.5u/cc Chrysotile

9094-A-3A-010 Air ND < 0.0009 S>5u/cc

9094-A-3A-011 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3A-012 Air ND < 0.0009 S>5u/cc

9094-M-3A-022 Microvac 94972.8 S/cm2 Chrysotile

9094-M-3A-023 Microvac 23743.2 S/cm2 Chrysotile

9094-M-3A-024 Microvac 3957.2 S/cm2 Chrysotile

9094-M-3A-025 Microvac ND < 3165.76 S/cm2

9094-W-3A-017 Wipe 15037.4 S/cm2 Chrysotile
Page 2 of 4

Unit 3A Results

 9094-W-3A-018 Wipe ND < 11832 S/cm2 Particulate matter; sensivity 

(11832 s/cm2) not reached.

9094-W-3A-019 Wipe 3957.2 S/cm2 Chrysotile

9094-W-3A-020 Wipe 3165.76 S/cm2 Chrysotile

9094-W-3A-021 Wipe ND < 2366.41 S/cm2 Chrysotile

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3A-002 Wipe 0.54 ng/m2

9094-W-3A-003 Wipe 0.616 ng/m2

9094-W-3A-004 Wipe 0.592 ng/m2

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-W-3A-018 Wipe 0.535 ng/m2

9094-W-3A-019 Wipe 0.606 ng/m2

9094-W-3A-020 Wipe 0.597 ng/m2

9094-W-3A-021 Wipe 0.706 ng/m2

Gypsum

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-015 Air ND < 0.016 mg/m3

9094-A-3A-016 Air ND < 0.017 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-3A-006 Microvac ND < 4.65 ug/ft2

9094-M-3A-007 Microvac ND < 4.65 ug/ft2

9094-M-3A-008 Microvac ND < 4.65 ug/ft2

9094-M-3A-009 Microvac ND < 4.65 ug/ft2

9094-W-3A-002 Wipe ND < 4.65 ug/ft2

9094-W-3A-003 Wipe 38.9 ug/ft2

9094-W-3A-004 Wipe 12 ug/ft2

 
Page 3 of 4

Unit 3A Results 

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-013 Air 0.116 ug/m3 Field blank contamination 

(Validation = R).

9094-A-3A-014 Air 0.131 ug/m3 Field blank contamination 

(Validation = R).

9094-M-3A-022 Microvac 4.85 ug/ft2

9094-M-3A-023 Microvac ND < 2.32 ug/ft2

9094-M-3A-024 Microvac 4.39 ug/ft2

9094-M-3A-025 Microvac ND < 2.32 ug/ft2

9094-W-3A-018 Wipe ND < 4.65 ug/ft2

9094-W-3A-019 Wipe 10.5 ug/ft2

9094-W-3A-020 Wipe 9.29 ug/ft2

9094-W-3A-021 Wipe ND < 4.65 ug/ft2

Mineral: alpha-Quartz

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-015 Air ND < 0.004 mg/m3

9094-A-3A-016 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-015 Air ND < 0.016 mg/m3

9094-A-3A-016 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-015 Air ND < 0.016 mg/m3

9094-A-3A-016 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-015 Air ND < 0.016 mg/m3

9094-A-3A-016 Air ND < 0.017 mg/m3

 
Page 4 of 4

Unit 3A Results 

 MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-3A-005 Air 3.283 S/L

9094-A-3A-006 Air 0.903 S/L

9094-W-3A-002 Wipe 57.23 S/cm2

9094-W-3A-003 Wipe 801.24 S/cm2

9094-W-3A-004 Wipe 686.78 S/cm2

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-3A-010 Air 1.226 S/L

9094-A-3A-011 Air 0.819 S/L

9094-A-3A-012 Air 1.734 S/L

9094-W-3A-017 Wipe ND < 22.89 S/cm2

9094-W-3A-018 Wipe ND < 22.89 S/cm2

9094-W-3A-019 Wipe ND < 22.89 S/cm2

9094-W-3A-020 Wipe ND < 22.89 S/cm2

9094-W-3A-021 Wipe ND < 22.89 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3A-002 Wipe U 290 ug/m2

9094-W-3A-003 Wipe U 290 ug/m2

9094-W-3A-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-W-3A-018 Wipe U 290 ug/m2

9094-W-3A-019 Wipe U 290 ug/m2

9094-W-3A-020 Wipe U 290 ug/m2

9094-W-3A-021 Wipe U 290 ug/m2
Page 1 of 5

Unit 3B Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-3B-009 Air 0.03 f/cc

9094-A-3B-010 Air 0.006 f/cc

9094-A-3B-009 Air ND < 0.0009 S>5u/cc

9094-A-3B-010 Air ND < 0.0009 S>5u/cc

9094-M-3B-006 Microvac 20944 S/cm2 Chrysotile

9094-M-3B-007 Microvac 4986.67 S/cm2 Chrysotile

9094-M-3B-008 Microvac ND < 4488 S/cm2

9094-W-3B-001 Wipe ND < 2366.41 S/cm2

9094-W-3B-002 Wipe ND < 2366.41 S/cm2

9094-W-3B-003 Wipe 3165.76 S/cm2 Chrysotile

9094-W-3B-004 Wipe ND < 2366.41 S/cm2

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-011 Air 0.003 f/cc

9094-A-3B-012 Air 0.003 f/cc

9094-A-3B-013 Air 0.004 f/cc

9094-A-3B-011 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3B-012 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3B-013 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3B-011 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3B-012 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3B-013 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-3B-023 Microvac 22951.8 S/cm2 Chrysotile

9094-M-3B-024 Microvac 33240.5 S/cm2 Chrysotile

9094-M-3B-025 Microvac 13454.5 S/cm2 Chrysotile
Page 2 of 5

Unit 3B Results

9094-W-3B-018 Wipe 741.975 S/cm2 Chrysotile

9094-W-3B-019 Wipe ND < 739.502 S/cm2 Chrysotile - Asbestos detected

 below detection limit.

9094-W-3B-020 Wipe 4699.18 S/cm2 Chrysotile

9094-W-3B-021 Wipe 3957.2 S/cm2 Chrysotile

9094-W-3B-022 Wipe 2473.25 S/cm2 Chrysotile

Post 2nd cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-039 Air ND < 0.001 f/cc

9094-A-3B-040 Air ND < 0.001 f/cc

9094-A-3B-041 Air 0.001 f/cc

9094-A-3B-039 Air ND < 0.0005 S>0.5u/cc

9094-A-3B-040 Air ND < 0.0005 S>0.5u/cc

9094-A-3B-041 Air ND < 0.0005 S>0.5u/cc

9094-A-3B-039 Air ND < 0.0005 S>5u/cc

9094-A-3B-040 Air ND < 0.0005 S>5u/cc

9094-A-3B-041 Air ND < 0.0005 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3B-002 Wipe 0.712 ng/m2

9094-W-3B-003 Wipe 0.506 ng/m2

9094-W-3B-004 Wipe 1.13 ng/m2

9094-W-3B-005 Wipe 0.526 ng/m2

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-W-3B-019 Wipe 0.913 ng/m2

9094-W-3B-020 Wipe 0.94 ng/m2

9094-W-3B-021 Wipe 0.915 ng/m2

9094-W-3B-022 Wipe 0.866 ng/m2

 
Page 3 of 5

Unit 3B Results 

 Gypsum

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-016 Air ND < 0.008 mg/m3

9094-A-3B-017 Air ND < 0.008 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-3B-006 Microvac ND < 4.65 ug/ft2

9094-M-3B-007 Microvac ND < 4.65 ug/ft2

9094-M-3B-008 Microvac ND < 4.65 ug/ft2

9094-W-3B-002 Wipe ND < 4.65 ug/ft2

9094-W-3B-003 Wipe 11.5 ug/ft2

9094-W-3B-004 Wipe 9.65 ug/ft2

9094-W-3B-005 Wipe 0 ug/ft2 Sample lost by laboratory.

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-014 Air 0.225 ug/m3

9094-A-3B-015 Air 0.238 ug/m3

9094-M-3B-023 Microvac ND < 2.32 ug/ft2

9094-M-3B-024 Microvac ND < 2.32 ug/ft2

9094-M-3B-025 Microvac ND < 2.32 ug/ft2

9094-W-3B-019 Wipe ND < 4.65 ug/ft2

9094-W-3B-020 Wipe 51.6 ug/ft2

9094-W-3B-021 Wipe 10.9 ug/ft2

9094-W-3B-022 Wipe 7.27 ug/ft2

Post 2nd cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-W-3B-037 Wipe ug/ft2 Sample was received broken; 

not analyzed.

9094-W-3B-038 Wipe ND < 4.64 ug/ft2

 
Page 4 of 5

Unit 3B Results 

 Mineral: alpha-Quartz

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-016 Air ND < 0.004 mg/m3

9094-A-3B-017 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-016 Air ND < 0.016 mg/m3

9094-A-3B-017 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-016 Air ND < 0.016 mg/m3

9094-A-3B-017 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-016 Air ND < 0.016 mg/m3

9094-A-3B-017 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-3B-009 Air 14.78 S/L

9094-A-3B-010 Air 2.644 S/L

9094-W-3B-002 Wipe 744.01 S/cm2

9094-W-3B-003 Wipe 2289.26 S/cm2

9094-W-3B-004 Wipe 744.01 S/cm2

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-A-3B-011 Air 1.528 S/L

9094-A-3B-012 Air 2.209 S/L

9094-A-3B-013 Air 0.946 S/L

9094-W-3B-018 Wipe 57.23 S/cm2
Page 5 of 5

Unit 3B Results 

 9094-W-3B-019 Wipe ND < 57.23 S/cm2

9094-W-3B-020 Wipe ND < 57.23 S/cm2

9094-W-3B-021 Wipe 57.23 S/cm2

9094-W-3B-022 Wipe ND < 57.23 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3B-002 Wipe U 290 ug/m2

9094-W-3B-003 Wipe U 290 ug/m2

9094-W-3B-004 Wipe U 290 ug/m2

9094-W-3B-005 Wipe U 290 ug/m2

Post 1st cleaning - Scope A

Sample ID Matrix Detected Result Comment

9094-W-3B-019 Wipe U 290 ug/m2

9094-W-3B-020 Wipe U 290 ug/m2

9094-W-3B-021 Wipe U 290 ug/m2

9094-W-3B-022 Wipe U 290 ug/m2
Page 1 of 6 

Unit 3C Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-3C-005 Microvac 127160 S/cm2 Chrysotile

9094-M-3C-006 Microvac 286110 S/cm2 Chrysotile

9094-M-3C-007 Microvac 190740 S/cm2 Chrysotile

9094-M-3C-008 Microvac 589050 S/cm2 Chrysotile

9094-W-3C-001 Wipe ND < 2366.41 S/cm2

9094-W-3C-002 Wipe 2374.32 S/cm2 Chrysotile

9094-W-3C-003 Wipe 55400.8 S/cm2 Chrysotile

9094-W-3C-004 Wipe 75978.2 S/cm2 Chrysotile/Amosite.

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-009 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-010 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-011 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-009 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-010 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-011 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-3C-021 Microvac 223582 S/cm2 Chrysotile

9094-M-3C-022 Microvac 39967.7 S/cm2 1 Actinolite and 100 Chrysotile

9094-M-3C-023 Microvac 888172 S/cm2 Chrysotile

9094-M-3C-024 Microvac 147406 S/cm2 Chrysotile

9094-W-3C-016 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-3C-017 Wipe 12663 S/cm2 Chrysotile

9094-W-3C-018 Wipe 77561.1 S/cm2 Chrysotile

9094-W-3C-019 Wipe ND < 2366.41 S/cm2

9094-W-3C-020 Wipe 13454.5 S/cm2 Chrysotile
Page 2 of 6 

Unit 3C Results

Post 2nd cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-025 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-026 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-027 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-028 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-029 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-025 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-026 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-027 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-028 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-029 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-025 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-026 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-027 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-028 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3C-029 Air S>5u/cc Not analyzed due to 

overloading of particulates.

Post 3rd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-3C-032 Air ND < 0.001 f/cc

9094-A-3C-033 Air ND < 0.001 f/cc

9094-A-3C-034 Air ND < 0.001 f/cc

9094-A-3C-035 Air 0.004 f/cc

9094-A-3C-036 Air 0.002 f/cc

9094-A-3C-037 Air 0.002 f/cc

9094-A-3C-032 Air ND < 0.0005 S>0.5u/cc

9094-A-3C-033 Air ND < 0.0005 S>0.5u/cc

9094-A-3C-034 Air ND < 0.0005 S>0.5u/cc
Page 3 of 6 

Unit 3C Results

9094-A-3C-035 Air ND < 0.0005 S>0.5u/cc

9094-A-3C-036 Air ND < 0.0005 S>0.5u/cc

9094-A-3C-037 Air ND < 0.0005 S>0.5u/cc

9094-A-3C-032 Air ND < 0.0005 S>5u/cc

9094-A-3C-033 Air ND < 0.0005 S>5u/cc

9094-A-3C-034 Air ND < 0.0005 S>5u/cc

9094-A-3C-035 Air ND < 0.0005 S>5u/cc

9094-A-3C-036 Air ND < 0.0005 S>5u/cc

9094-A-3C-037 Air ND < 0.0005 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3C-002 Wipe 0.558 ng/m2

9094-W-3C-003 Wipe 6.2 ng/m2

9094-W-3C-004 Wipe 1.32 ng/m2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-W-3C-017 Wipe 0.618 ng/m2

9094-W-3C-018 Wipe 0.56 ng/m2

9094-W-3C-019 Wipe 0.557 ng/m2

9094-W-3C-020 Wipe 0.525 ng/m2

Gypsum

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-014 Air ND < 0.016 mg/m3

9094-A-3C-015 Air ND < 0.017 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-3C-005 Microvac 68.4 ug/ft2

9094-M-3C-006 Microvac 135 ug/ft2

9094-M-3C-007 Microvac 43.3 ug/ft2

9094-M-3C-008 Microvac 39.4 ug/ft2
Page 4 of 6 

Unit 3C Results 

 9094-W-3C-002 Wipe ND < 4.65 ug/ft2

9094-W-3C-003 Wipe 750 ug/ft2

9094-W-3C-004 Wipe 48.7 ug/ft2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-012 Air 0.289 ug/m3

9094-A-3C-013 Air 0.261 ug/m3

9094-M-3C-021 Microvac 6.32 ug/ft2

9094-M-3C-022 Microvac 9.66 ug/ft2

9094-M-3C-023 Microvac 26.9 ug/ft2

9094-M-3C-024 Microvac 6.47 ug/ft2

9094-W-3C-017 Wipe 5.02 ug/ft2

9094-W-3C-018 Wipe 8.03 ug/ft2

9094-W-3C-019 Wipe 6.01 ug/ft2

9094-W-3C-020 Wipe ND < 4.65 ug/ft2

Post 2nd cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-030 Air 0.394 ug/m3

9094-A-3C-031 Air 0.364 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-014 Air ND < 0.004 mg/m3

9094-A-3C-015 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-014 Air 0.027 mg/m3

9094-A-3C-015 Air ND < 0.019 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-014 Air ND < 0.016 mg/m3

9094-A-3C-015 Air ND < 0.017 mg/m3
Page 5 of 6 

Unit 3C Results

 Mineral: Tridymite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-014 Air ND < 0.016 mg/m3

9094-A-3C-015 Air ND < 0.017 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3C-002 Wipe 343.39 S/cm2

9094-W-3C-003 Wipe 744.01 S/cm2

9094-W-3C-004 Wipe 343.39 S/cm2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-009 Air 1.793 S/L

9094-A-3C-010 Air 2.431 S/L

9094-A-3C-011 Air 3.883 S/L

9094-W-3C-016 Wipe 57.23 S/cm2

9094-W-3C-017 Wipe 171.69 S/cm2

9094-W-3C-018 Wipe 400.62 S/cm2

9094-W-3C-019 Wipe 114.46 S/cm2

9094-W-3C-020 Wipe 114.46 S/cm2

Post 2nd cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3C-025 Air 91.796 S/L

9094-A-3C-026 Air 5.061 S/L

9094-A-3C-027 Air 5.254 S/L

9094-A-3C-028 Air 4.384 S/L

9094-A-3C-029 Air 8.099 S/L

 
Page 6 of 6 

Unit 3C Results

 PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3C-002 Wipe U 290 ug/m2

9094-W-3C-003 Wipe 1046.6 ug/m2

9094-W-3C-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-W-3C-017 Wipe U 290 ug/m2

9094-W-3C-018 Wipe U 290 ug/m2

9094-W-3C-019 Wipe U 290 ug/m2

9094-W-3C-020 Wipe U 290 ug/m2
Page 1 of 5

Unit 3D Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-3D-005 Microvac 280500 S/cm2 Chrysotile

9094-M-3D-006 Microvac 44880 S/cm2 Chrysotile

9094-M-3D-007 Microvac 64114.3 S/cm2 Chrysotile

9094-W-3D-001 Wipe 4748.64 S/cm2 Chrysotile

9094-W-3D-002 Wipe ND < 2366.41 S/cm2

9094-W-3D-003 Wipe 172534 S/cm2 Chrysotile

9094-W-3D-004 Wipe 118716 S/cm2 Chrysotile

9094-W-3D-005 Wipe 4748.64 S/cm2 Chrysotile

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-008 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-009 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-010 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-008 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-009 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-010 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-008 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-009 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-3D-010 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-3D-020 Microvac ND < 3165.76 S/cm2 Chrysotile. Asbestos detected 

below detection limit.

9094-M-3D-021 Microvac 29283.3 S/cm2 Chrysotile

9094-M-3D-022 Microvac 34823.4 S/cm2 Chrysotile

9094-W-3D-015 Wipe 14245.9 S/cm2 Chrysotile

9094-W-3D-016 Wipe 3957.2 S/cm2 Chrysotile

9094-W-3D-017 Wipe 10288.7 S/cm2 Chrysotile
Page 2 of 5

Unit 3D Results

9094-W-3D-018 Wipe 10288.7 S/cm2 Chrysotile

9094-W-3D-019 Wipe 10288.7 S/cm2 Chrysotile

Post 2nd cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-023 Air 0.001 f/cc

9094-A-3D-024 Air ND < 0.001 f/cc

9094-A-3D-025 Air 0.006 f/cc

9094-A-3D-026 Air 0.005 f/cc

9094-A-3D-023 Air ND < 0.0005 S>0.5u/cc

9094-A-3D-024 Air ND < 0.0004 S>0.5u/cc

9094-A-3D-025 Air ND < 0.0005 S>0.5u/cc

9094-A-3D-026 Air ND < 0.0005 S>0.5u/cc

9094-A-3D-023 Air ND < 0.0005 S>5u/cc

9094-A-3D-024 Air ND < 0.0004 S>5u/cc

9094-A-3D-025 Air ND < 0.0005 S>5u/cc

9094-A-3D-026 Air ND < 0.0005 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3D-002 Wipe 0.492 ng/m2

9094-W-3D-003 Wipe 1.77 ng/m2

9094-W-3D-004 Wipe 1.24 ng/m2

9094-W-3D-005 Wipe 0.663 ng/m2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-W-3D-016 Wipe 0.568 ng/m2

9094-W-3D-017 Wipe 0.533 ng/m2

9094-W-3D-018 Wipe 0.576 ng/m2

9094-W-3D-019 Wipe 0.556 ng/m2

 
Page 3 of 5

Unit 3D Results

 Gypsum

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-013 Air ND < 0.008 mg/m3

9094-A-3D-014 Air ND < 0.008 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-3D-005 Microvac 50.7 ug/ft2

9094-M-3D-006 Microvac ND < 4.65 ug/ft2

9094-M-3D-007 Microvac ND < 4.65 ug/ft2

9094-W-3D-002 Wipe ND < 4.65 ug/ft2

9094-W-3D-003 Wipe 201 ug/ft2

9094-W-3D-004 Wipe 112 ug/ft2

9094-W-3D-005 Wipe ND < 4.65 ug/ft2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-011 Air 0.074 ug/m3 Field blank contamination 

(Validation = R).

9094-A-3D-012 Air 0.126 ug/m3 Field blank contamination 

(Validation = R).

9094-M-3D-020 Microvac ND < 2.32 ug/ft2

9094-M-3D-021 Microvac 5.71 ug/ft2 Field blank contamination 

(Validation = R).

9094-M-3D-022 Microvac ND < 2.32 ug/ft2

9094-W-3D-016 Wipe 8.22 ug/ft2

9094-W-3D-017 Wipe 9.8 ug/ft2

9094-W-3D-018 Wipe ND < 4.65 ug/ft2

9094-W-3D-019 Wipe ND < 4.65 ug/ft2

Mineral: alpha-Quartz

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-013 Air ND < 0.004 mg/m3

9094-A-3D-014 Air ND < 0.004 mg/m3

 
Page 4 of 5

Unit 3D Results 

 Mineral: Calcite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-013 Air ND < 0.016 mg/m3

9094-A-3D-014 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-013 Air ND < 0.016 mg/m3

9094-A-3D-014 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-013 Air ND < 0.016 mg/m3

9094-A-3D-014 Air ND < 0.017 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3D-002 Wipe 228.93 S/cm2

9094-W-3D-003 Wipe 572.31 S/cm2

9094-W-3D-004 Wipe 1259.09 S/cm2

9094-W-3D-005 Wipe 343.39 S/cm2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-3D-008 Air 1.965 S/L

9094-A-3D-009 Air 0.984 S/L

9094-A-3D-010 Air 5.513 S/L

9094-W-3D-015 Wipe ND < 22.89 S/cm2

9094-W-3D-016 Wipe 22.89 S/cm2

9094-W-3D-017 Wipe ND < 22.89 S/cm2

9094-W-3D-018 Wipe ND < 22.89 S/cm2

9094-W-3D-019 Wipe ND < 22.89 S/cm2

 
Page 5 of 5

Unit 3D Results 

 PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-3D-002 Wipe U 290 ug/m2

9094-W-3D-003 Wipe 290 ug/m2

9094-W-3D-004 Wipe U 290 ug/m2

9094-W-3D-005 Wipe U 290 ug/m2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-W-3D-016 Wipe U 290 ug/m2

9094-W-3D-017 Wipe U 290 ug/m2

9094-W-3D-018 Wipe U 290 ug/m2

9094-W-3D-019 Wipe U 290 ug/m2
Page 1 of 2

3rd Floor Hallway Results

Asbestos

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-001 Air 0.005 f/cc

9094-A-3RD-002 Air 0.004 f/cc

9094-A-3RD-001 Air ND < 0.0005 S>0.5u/cc

9094-A-3RD-002 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-3RD-001 Air ND < 0.0005 S>5u/cc

9094-A-3RD-002 Air ND < 0.0005 S>5u/cc

Gypsum

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-004 Air ND < 0.008 mg/m3

9094-A-3RD-005 Air ND < 0.008 mg/m3

Lead

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-003 Air ND < 0.052 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-004 Air ND < 0.004 mg/m3

9094-A-3RD-005 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-004 Air ND < 0.017 mg/m3

9094-A-3RD-005 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-004 Air ND < 0.017 mg/m3

9094-A-3RD-005 Air ND < 0.017 mg/m3

 
Page 2 of 2

3rd Floor Hallway Results 

 Mineral: Tridymite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-004 Air ND < 0.017 mg/m3

9094-A-3RD-005 Air ND < 0.017 mg/m3

MMVF

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-3RD-001 Air 0.095 S/L

9094-A-3RD-002 Air 0.147 S/L
Page 1 of 5

Unit 4A Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-4A-005 Microvac 4664.88 S/cm2 Chrysotile

9094-M-4A-006 Microvac 11874.2 S/cm2 Chrysotile

9094-M-4A-007 Microvac 1696.32 S/cm2 Chrysotile

9094-W-4A-001 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-4A-002 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-4A-003 Wipe 2374.32 S/cm2 Chrysotile

9094-W-4A-004 Wipe ND < 2366.41 S/cm2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-008 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-009 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-010 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-008 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-009 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-010 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-008 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-009 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-010 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-4A-020 Microvac 3165.76 S/cm2 Chrysotile

9094-M-4A-021 Microvac ND < 3165.76 S/cm2 Chrysotile. Asbestos detected 

below detection limit.

9094-M-4A-022 Microvac 47486.4 S/cm2 Chrysotile

9094-W-4A-015 Wipe 1978.6 S/cm2 Chrysotile

9094-W-4A-016 Wipe 1582.88 S/cm2 Chrysotile

9094-W-4A-017 Wipe ND < 1183.2 S/cm2 Chrysotile. Asbestos detected 

below detection limit.

9094-W-4A-018 Wipe 6331.52 S/cm2 Chrysotile

9094-W-4A-019 Wipe ND < 1183.2 S/cm2 Chrysotile. Asbestos detected 

below detection limit.

 
Page 2 of 5

Unit 4A Results 

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-023 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-024 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-025 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4A-023 Air ND < 0.0009 S>0.5u/cc

9094-A-4A-024 Air ND < 0.0008 S>0.5u/cc

9094-A-4A-025 Air ND < 0.0009 S>0.5u/cc

9094-A-4A-023 Air ND < 0.0009 S>5u/cc

9094-A-4A-024 Air ND < 0.0008 S>5u/cc

9094-A-4A-025 Air ND < 0.0009 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4A-002 Wipe 0.836 ng/m2

9094-W-4A-003 Wipe 0.583 ng/m2

9094-W-4A-004 Wipe 0.553 ng/m2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-W-4A-016 Wipe 0.701 ng/m2

9094-W-4A-017 Wipe 0.659 ng/m2

9094-W-4A-018 Wipe 0.701 ng/m2

9094-W-4A-019 Wipe 0.752 ng/m2

Gypsum

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-013 Air ND < 0.008 mg/m3

9094-A-4A-014 Air ND < 0.008 mg/m3

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-026 Air ND < 0.008 mg/m3

9094-A-4A-027 Air ND < 0.008 mg/m3

 
Page 3 of 5

Unit 4A Results 

 Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-4A-005 Microvac ND < 4.65 ug/ft2

9094-M-4A-006 Microvac ND < 4.65 ug/ft2

9094-M-4A-007 Microvac ND < 4.65 ug/ft2

9094-W-4A-002 Wipe 5.66 ug/ft2

9094-W-4A-003 Wipe 21.5 ug/ft2

9094-W-4A-004 Wipe 9.41 ug/ft2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-011 Air 0.442 ug/m3

9094-A-4A-012 Air 0.31 ug/m3

9094-M-4A-020 Microvac ND < 2.32 ug/ft2

9094-M-4A-021 Microvac ND < 2.32 ug/ft2

9094-M-4A-022 Microvac 2.58 ug/ft2

9094-W-4A-016 Wipe ND < 4.65 ug/ft2

9094-W-4A-017 Wipe 10.7 ug/ft2

9094-W-4A-018 Wipe ND < 4.65 ug/ft2

9094-W-4A-019 Wipe ND < 4.65 ug/ft2

Mineral: alpha-Quartz

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-013 Air 0.008 mg/m3

9094-A-4A-014 Air ND < 0.004 mg/m3

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-026 Air ND < 0.004 mg/m3

9094-A-4A-027 Air ND < 0.004 mg/m3

 
Page 4 of 5

Unit 4A Results 

 Mineral: Calcite

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-013 Air ND < 0.017 mg/m3

9094-A-4A-014 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-026 Air ND < 0.017 mg/m3

9094-A-4A-027 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-013 Air ND < 0.017 mg/m3

9094-A-4A-014 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-026 Air ND < 0.017 mg/m3

9094-A-4A-027 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-013 Air ND < 0.017 mg/m3

9094-A-4A-014 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-026 Air ND < 0.017 mg/m3

9094-A-4A-027 Air ND < 0.017 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4A-002 Wipe 400.62 S/cm2

9094-W-4A-003 Wipe 629.55 S/cm2

9094-W-4A-004 Wipe 171.69 S/cm2

 
Page 5 of 5

Unit 4A Results 

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4A-008 Air 0.187 S/L

9094-A-4A-009 Air 0.435 S/L

9094-A-4A-010 Air 0.286 S/L

9094-W-4A-015 Wipe ND < 22.89 S/cm2

9094-W-4A-016 Wipe ND < 22.89 S/cm2

9094-W-4A-017 Wipe 22.89 S/cm2

9094-W-4A-018 Wipe ND < 22.89 S/cm2

9094-W-4A-019 Wipe ND < 22.89 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4A-002 Wipe U 290 ug/m2

9094-W-4A-003 Wipe U 290 ug/m2

9094-W-4A-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-W-4A-016 Wipe U 290 ug/m2

9094-W-4A-017 Wipe U 290 ug/m2

9094-W-4A-018 Wipe U 290 ug/m2

9094-W-4A-019 Wipe U 290 ug/m2
Page 1 of 4

Unit 4B Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4B-001 Wipe ND < 2366.41 S/cm2

9094-W-4B-002 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-4B-003 Wipe 18203.1 S/cm2 Chrysotile

9094-W-4B-004 Wipe 13454.5 S/cm2 Chrysotile

9094-W-4B-005 Wipe 3165.76 S/cm2 Chrysotile

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-006 Air 0.006 f/cc

9094-A-4B-007 Air 0.004 f/cc

9094-A-4B-008 Air 0.005 f/cc

9094-A-4B-006 Air ND < 0.0009 S>5u/cc

9094-A-4B-007 Air ND < 0.0009 S>5u/cc

9094-A-4B-008 Air ND < 0.0009 S>5u/cc

9094-W-4B-013 Wipe ND < 2366.41 S/cm2

9094-W-4B-014 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-4B-015 Wipe 4748.64 S/cm2 1 Anthophyllite and 5 Chrysotile

9094-W-4B-016 Wipe ND < 2366.41 S/cm2

9094-W-4B-017 Wipe ND < 2366.41 S/cm2

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4B-002 Wipe 1.14 ng/m2

9094-W-4B-003 Wipe 0.653 ng/m2

9094-W-4B-004 Wipe 0.979 ng/m2

9094-W-4B-005 Wipe 0.889 ng/m2

 
Page 2 of 4

Unit 4B Results 

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-W-4B-014 Wipe 2 ng/m2

9094-W-4B-015 Wipe 0.614 ng/m2

9094-W-4B-016 Wipe 0.647 ng/m2

9094-W-4B-017 Wipe 0.582 ng/m2

Gypsum

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-011 Air ND < 0.016 mg/m3

9094-A-4B-012 Air ND < 0.017 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4B-002 Wipe ND < 4.65 ug/ft2

9094-W-4B-003 Wipe 50 ug/ft2

9094-W-4B-004 Wipe 14 ug/ft2

9094-W-4B-005 Wipe 30 ug/ft2

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-009 Air 0.241 ug/m3

9094-A-4B-010 Air 0.246 ug/m3

9094-W-4B-014 Wipe ND < 4.65 ug/ft2

9094-W-4B-015 Wipe 6.68 ug/ft2

9094-W-4B-016 Wipe ND < 4.65 ug/ft2

9094-W-4B-017 Wipe ND < 4.65 ug/ft2

Post 2nd cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-018 Air 0.183 ug/m3

9094-A-4B-019 Air 0.171 ug/m3

 
Page 3 of 4

Unit 4B Results

 Mineral: alpha-Quartz

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-011 Air ND < 0.004 mg/m3

9094-A-4B-012 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-011 Air ND < 0.016 mg/m3

9094-A-4B-012 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-011 Air ND < 0.016 mg/m3

9094-A-4B-012 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-011 Air ND < 0.016 mg/m3

9094-A-4B-012 Air ND < 0.017 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4B-002 Wipe 286.16 S/cm2

9094-W-4B-003 Wipe 629.55 S/cm2

9094-W-4B-004 Wipe 400.62 S/cm2

9094-W-4B-005 Wipe 686.78 S/cm2

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-A-4B-006 Air 0.658 S/L

9094-A-4B-007 Air 1.664 S/L

9094-A-4B-008 Air 1.096 S/L

9094-W-4B-013 Wipe 286.16 S/cm2

9094-W-4B-014 Wipe 228.93 S/cm2
Page 4 of 4

Unit 4B Results 

 9094-W-4B-015 Wipe 400.62 S/cm2

9094-W-4B-016 Wipe 171.69 S/cm2

9094-W-4B-017 Wipe 57.23 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4B-002 Wipe U 290 ug/m2

9094-W-4B-003 Wipe U 290 ug/m2

9094-W-4B-004 Wipe U 290 ug/m2

9094-W-4B-005 Wipe U 290 ug/m2

Post 1st cleaning - Test 2B

Sample ID Matrix Detected Result Comment

9094-W-4B-014 Wipe U 290 ug/m2

9094-W-4B-015 Wipe U 290 ug/m2

9094-W-4B-016 Wipe U 290 ug/m2

9094-W-4B-017 Wipe U 290 ug/m2
Page 1 of 5 

Unit 4C Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-4C-005 Microvac 432562 S/cm2 Chrysotile

9094-M-4C-006 Microvac 349442 S/cm2 Chrysotile

9094-M-4C-007 Microvac 140795 S/cm2 Chrysotile

9094-M-4C-008 Microvac 252025 S/cm2 1 Amosite and 103 Chrysotile

9094-W-4C-001 Wipe ND < 2366.41 S/cm2

9094-W-4C-002 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-4C-003 Wipe 49069.3 S/cm2 Chrysotile

9094-W-4C-004 Wipe 3165.76 S/cm2 Chrysotile

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-009 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4C-010 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4C-011 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-4C-009 Air 0.0038 S>0.5u/cc Chrysotile

9094-A-4C-010 Air 0.0026 S>0.5u/cc Chrysotile

9094-A-4C-011 Air 0.0026 S>0.5u/cc Chrysotile

9094-A-4C-009 Air 0.0009 S>5u/cc Chrysotile

9094-A-4C-010 Air ND < 0.0009 S>5u/cc

9094-A-4C-011 Air ND < 0.0009 S>5u/cc

9094-M-4C-023 Microvac 23347.5 S/cm2 Chrysotile

9094-M-4C-024 Microvac 23743.2 S/cm2 29 Chrysotile and 1 Actinolite

9094-M-4C-025 Microvac 126630 S/cm2 Chrysotile

9094-W-4C-018 Wipe ND < 2366.41 S/cm2

9094-W-4C-019 Wipe ND < 2366.41 S/cm2

9094-W-4C-020 Wipe 3165.76 S/cm2 Chrysotile
Page 2 of 5 

Unit 4C Results

9094-W-4C-021 Wipe < 2366.41 S/cm2 Chrysotile

9094-W-4C-022 Wipe < 2366.41 S/cm2 Chrysotile

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4C-002 Wipe 0.57 ng/m2

9094-W-4C-003 Wipe 1.36 ng/m2

9094-W-4C-004 Wipe 0.975 ng/m2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-W-4C-019 Wipe 0.507 ng/m2

9094-W-4C-020 Wipe 0.606 ng/m2

9094-W-4C-021 Wipe 0.511 ng/m2

9094-W-4C-022 Wipe 0.512 ng/m2

Gypsum

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-014 Air ND < 0.016 mg/m3

9094-A-4C-015 Air ND < 0.016 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-4C-005 Microvac 76.1 ug/ft2

9094-M-4C-006 Microvac 83.7 ug/ft2

9094-M-4C-007 Microvac 69.8 ug/ft2

9094-M-4C-008 Microvac 70.8 ug/ft2

9094-W-4C-002 Wipe ND < 4.65 ug/ft2

9094-W-4C-003 Wipe 181 ug/ft2

9094-W-4C-004 Wipe 77.5 ug/ft2
Page 3 of 5 

Unit 4C Results

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-012 Air 0.131 ug/m3

9094-A-4C-013 Air 0.195 ug/m3

9094-M-4C-023 Microvac ND < 2.32 ug/ft2

9094-M-4C-024 Microvac ND < 2.32 ug/ft2

9094-M-4C-025 Microvac ND < 2.32 ug/ft2

9094-W-4C-019 Wipe ug/ft2 Sample was not received at 

the laboratory.

9094-W-4C-020 Wipe 14.9 ug/ft2 Field blank contamination 

(Validation = R).

9094-W-4C-021 Wipe 8.28 ug/ft2 Field blank contamination 

(Validation = R).

9094-W-4C-022 Wipe 7.81 ug/ft2 Field blank contamination 

(Validation = R).

Post 2nd cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-026 Air 0.374 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-014 Air ND < 0.004 mg/m3

9094-A-4C-015 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-014 Air ND < 0.016 mg/m3

9094-A-4C-015 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-014 Air ND < 0.016 mg/m3

9094-A-4C-015 Air ND < 0.016 mg/m3
Page 4 of 5 

Unit 4C Results

Mineral: Tridymite

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-014 Air ND < 0.016 mg/m3

9094-A-4C-015 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4C-002 Wipe 57.23 S/cm2

9094-W-4C-003 Wipe 1030.17 S/cm2

9094-W-4C-004 Wipe 343.39 S/cm2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment

9094-A-4C-009 Air 6.316 S/L

9094-A-4C-010 Air 4.119 S/L

9094-A-4C-011 Air 2.549 S/L

9094-W-4C-018 Wipe 57.23 S/cm2

9094-W-4C-019 Wipe 228.93 S/cm2

9094-W-4C-020 Wipe 343.39 S/cm2

9094-W-4C-021 Wipe 114.46 S/cm2

9094-W-4C-022 Wipe 228.93 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4C-002 Wipe U 290 ug/m2

9094-W-4C-003 Wipe 290 ug/m2

9094-W-4C-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 1A

Sample ID Matrix Detected Result Comment
Page 5 of 5 

Unit 4C Results

9094-A-4C-016 Air U 0.174 μg/m3

9094-A-4C-017 Air U 0.16 μg/m3

9094-W-4C-019 Wipe U 290 ug/m2

9094-W-4C-020 Wipe U 290 ug/m2

9094-W-4C-021 Wipe U 290 ug/m2

9094-W-4C-022 Wipe U 290 ug/m2
Page 1 of 5

Unit 4D Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-4D-006 Microvac 241883 S/cm2 Chrysotile

9094-M-4D-007 Microvac 101779 S/cm2 Chrysotile

9094-M-4D-008 Microvac 91601.3 S/cm2 Chrysotile

9094-M-4D-009 Microvac 79727 S/cm2 Chrysotile

9094-M-4D-010 Microvac 68700.8 S/cm2 Chrysotile

9094-M-4D-011 Microvac 39580.8 S/cm2 Chrysotile

9094-W-4D-001 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-4D-002 Wipe ND < 2366.41 S/cm2

9094-W-4D-003 Wipe 34031.9 S/cm2 Chrysotile

9094-W-4D-004 Wipe 2374.32 S/cm2 Chrysotile

9094-W-4D-005 Wipe 3165.76 S/cm2 Chrysotile

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-012 Air 0.004 f/cc

9094-A-4D-013 Air 0.02 f/cc

9094-A-4D-014 Air 0.004 f/cc

9094-A-4D-012 Air 0.0009 S>0.5u/cc Chrysotile

9094-A-4D-013 Air 0.0055 S>0.5u/cc Chrysotile

9094-A-4D-014 Air 0.0009 S>0.5u/cc Chrysotile

9094-A-4D-012 Air ND < 0.0009 S>5u/cc

9094-A-4D-013 Air 0.0009 S>5u/cc Chrysotile

9094-A-4D-014 Air ND < 0.0009 S>5u/cc

9094-M-4D-024 Microvac 29679 S/cm2 Chrysotile

9094-M-4D-025 Microvac 44518.5 S/cm2 Chrysotile

9094-M-4D-026 Microvac 24732.5 S/cm2 Chrysotile
Page 2 of 5

Unit 4D Results

9094-M-4D-027 Microvac 37593.4 S/cm2 Chrysotile

9094-M-4D-028 Microvac 45507.8 S/cm2 Chrysotile

9094-M-4D-029 Microvac 25721.8 S/cm2 Chrysotile

9094-W-4D-019 Wipe 2374.32 S/cm2 Chrysotile

9094-W-4D-020 Wipe < 2366.41 S/cm2 Chrysotile

9094-W-4D-021 Wipe 26117.5 S/cm2 Chrysotile

9094-W-4D-022 Wipe 43529.2 S/cm2 Chrysotile

9094-W-4D-023 Wipe 18994.6 S/cm2 Chrysotile

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4D-002 Wipe 0.878 ng/m2

9094-W-4D-003 Wipe 2.51 ng/m2

9094-W-4D-004 Wipe 0.728 ng/m2

9094-W-4D-005 Wipe 0.692 ng/m2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-W-4D-020 Wipe 0.571 ng/m2

9094-W-4D-021 Wipe 0.694 ng/m2

9094-W-4D-022 Wipe 0.522 ng/m2

9094-W-4D-023 Wipe 0.557 ng/m2

 Gypsum

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-017 Air ND < 0.016 mg/m3

9094-A-4D-018 Air ND < 0.016 mg/m3

 
Page 3 of 5

Unit 4D Results 

 Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-4D-006 Microvac 83.5 ug/ft2

9094-M-4D-007 Microvac 66 ug/ft2

9094-M-4D-008 Microvac 26.2 ug/ft2

9094-M-4D-009 Microvac 39.9 ug/ft2

9094-M-4D-010 Microvac 78.2 ug/ft2

9094-M-4D-011 Microvac 72.1 ug/ft2

9094-W-4D-002 Wipe ND < 4.65 ug/ft2

9094-W-4D-003 Wipe 169 ug/ft2

9094-W-4D-004 Wipe 17.4 ug/ft2

9094-W-4D-005 Wipe 17.1 ug/ft2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-015 Air 0.146 ug/m3 Lab blank contamination 

(Validation = R).

9094-A-4D-016 Air 0.137 ug/m3 Lab blank contamination 

(Validation = R).

9094-M-4D-024 Microvac 2.4 ug/ft2

9094-M-4D-025 Microvac ND < 2.32 ug/ft2

9094-M-4D-026 Microvac ND < 2.32 ug/ft2

9094-M-4D-027 Microvac ND < 2.32 ug/ft2

9094-M-4D-028 Microvac ND < 2.32 ug/ft2

9094-M-4D-029 Microvac ND < 2.32 ug/ft2

9094-W-4D-020 Wipe 20.4 ug/ft2 Lab blank contamination 

(Validation = R).

9094-W-4D-021 Wipe 66 ug/ft2 Lab blank contamination 

(Validation = R).

9094-W-4D-022 Wipe 10.6 ug/ft2 Lab blank contamination 

(Validation = R).

9094-W-4D-023 Wipe 15.6 ug/ft2 Lab blank contamination 

(Validation = R).

Post 2nd cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-030 Air 0.055 ug/m3

9094-W-4D-031 Wipe ND < 4.65 ug/ft2
Page 4 of 5

Unit 4D Results

Mineral: alpha-Quartz

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-017 Air ND < 0.004 mg/m3

9094-A-4D-018 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-017 Air ND < 0.016 mg/m3

9094-A-4D-018 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-017 Air ND < 0.016 mg/m3

9094-A-4D-018 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-017 Air ND < 0.016 mg/m3

9094-A-4D-018 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4D-002 Wipe 400.62 S/cm2

9094-W-4D-003 Wipe 2174.79 S/cm2

9094-W-4D-004 Wipe 286.16 S/cm2

9094-W-4D-005 Wipe 457.85 S/cm2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-A-4D-012 Air 1.398 S/L

9094-A-4D-013 Air 9.553 S/L

9094-A-4D-014 Air 2.124 S/L

9094-W-4D-019 Wipe 57.23 S/cm2

9094-W-4D-020 Wipe 171.69 S/cm2
Page 5 of 5

Unit 4D Results 

 9094-W-4D-021 Wipe 572.31 S/cm2

9094-W-4D-022 Wipe 228.93 S/cm2

9094-W-4D-023 Wipe 228.93 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-4D-002 Wipe U 290 ug/m2

9094-W-4D-003 Wipe 325.8 ug/m2

9094-W-4D-004 Wipe U 290 ug/m2

9094-W-4D-005 Wipe U 290 ug/m2

Post 1st cleaning - Test 2A

Sample ID Matrix Detected Result Comment

9094-W-4D-020 Wipe U 290 ug/m2

9094-W-4D-021 Wipe U 290 ug/m2

9094-W-4D-022 Wipe U 290 ug/m2

9094-W-4D-023 Wipe U 290 ug/m2
Page 1 of 2

Unit 4th Floor Hallway Results

Asbestos

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-001 Air 0.003 f/cc

9094-A-4TH-001 Air ND < 0.0009 S>0.5u/cc

9094-A-4TH-001 Air ND < 0.0009 S>5u/cc

Gypsum

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-003 Air ND < 0.008 mg/m3

Lead

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-002 Air 0.184 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-003 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-003 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-003 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-003 Air ND < 0.016 mg/m3
Page 2 of 2

Unit 4th Floor Hallway Results

MMVF

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-4TH-001 Air 0.735 S/L
Page 1 of 6

Unit 5A Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-5A-005 Microvac 319742 S/cm2 Chrysotile

9094-M-5A-006 Microvac 139821 S/cm2 Chrysotile

9094-M-5A-007 Microvac 5935.8 S/cm2 Chrysotile

9094-M-5A-008 Microvac ND < 3165.76 S/cm2

9094-M-5A-009 Microvac 64106.6 S/cm2 Chrysotile

9094-M-5A-010 Microvac 33240.5 S/cm2 Chrysotile

9094-M-5A-011 Microvac 34625.5 S/cm2 Chrysotile

9094-W-5A-001 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-5A-002 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-5A-003 Wipe 233475 S/cm2 Chrysotile

9094-W-5A-004 Wipe 22951.8 S/cm2 Chrysotile

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-012 Air 0.009 f/cc

9094-A-5A-013 Air 0.005 f/cc

9094-A-5A-014 Air 0.004 f/cc

9094-A-5A-012 Air 0.0009 S>5u/cc

9094-A-5A-013 Air ND < 0.0009 S>5u/cc

9094-A-5A-014 Air ND < 0.0007 S>5u/cc

9094-M-5A-024 Microvac 30866.2 S/cm2 Chrysotile

9094-M-5A-025 Microvac 41154.9 S/cm2 Chrysotile

9094-M-5A-026 Microvac 40363.4 S/cm2 Chrysotile

9094-M-5A-027 Microvac ND < 3165.76 S/cm2 Chrysotile

9094-M-5A-028 Microvac 3561.48 S/cm2 Chrysotile

9094-M-5A-029 Microvac 7914.4 S/cm2 Chrysotile
Page 2 of 6

Unit 5A Results

9094-M-5A-030 Microvac 75186.8 S/cm2 Chrysotile

9094-W-5A-019 Wipe ND < 2366.41 S/cm2

9094-W-5A-020 Wipe ND < 2366.41 S/cm2

9094-W-5A-021 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-5A-022 Wipe ND < 2366.41 S/cm2

9094-W-5A-023 Wipe ND < 2366.41 S/cm2

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5A-002 Wipe 0.528 ng/m2

9094-W-5A-003 Wipe 0.565 ng/m2

9094-W-5A-004 Wipe 0.747 ng/m2

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-W-5A-020 Wipe 0.587 ng/m2

9094-W-5A-021 Wipe 0.604 ng/m2

9094-W-5A-022 Wipe 0.57 ng/m2

9094-W-5A-023 Wipe 0.569 ng/m2

Gypsum

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-017 Air ND < 0.028 mg/m3

9094-A-5A-018 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-034 Air ND < 0.009 mg/m3

9094-A-5A-035 Air ND < 0.009 mg/m3
Page 3 of 6

Unit 5A Results

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-5A-005 Microvac ND < 2.23 ug/ft2

9094-M-5A-006 Microvac ND < 2.23 ug/ft2

9094-M-5A-007 Microvac ND < 2.23 ug/ft2

9094-M-5A-008 Microvac ND < 2.23 ug/ft2

9094-M-5A-009 Microvac ND < 2.23 ug/ft2

9094-M-5A-010 Microvac 3.46 ug/ft2

9094-M-5A-011 Microvac ND < 2.23 ug/ft2

9094-W-5A-002 Wipe 4.79 ug/ft2

9094-W-5A-003 Wipe 191 ug/ft2

9094-W-5A-004 Wipe 2000 ug/ft2

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-015 Air 0.083 ug/m3

9094-A-5A-016 Air 0.07 ug/m3

9094-M-5A-024 Microvac 2.6 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-M-5A-025 Microvac 4.15 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-M-5A-026 Microvac 2.6 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-M-5A-027 Microvac 0.78 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-M-5A-028 Microvac 0.975 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-M-5A-029 Microvac 1.02 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-M-5A-030 Microvac 5.27 ug/ft2 Sample was analyzed by 

graphite furnace AA.

9094-W-5A-020 Wipe ND < 4.65 ug/ft2

9094-W-5A-021 Wipe 43.5 ug/ft2

9094-W-5A-022 Wipe 10.5 ug/ft2

9094-W-5A-023 Wipe 39.7 ug/ft2
Page 4 of 6

Unit 5A Results

Post 2nd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-W-5A-031 Wipe 8.55 ug/ft2 Estimated concentration (J).

9094-W-5A-032 Wipe ND < 4.65 ug/ft2

9094-W-5A-033 Wipe ND < 4.65 ug/ft2

Mineral: alpha-Quartz

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-017 Air ND < 0.007 mg/m3

9094-A-5A-018 Air ND < 0.004 mg/m3

Post 2nd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-034 Air ND < 0.004 mg/m3

9094-A-5A-035 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-017 Air ND < 0.028 mg/m3

9094-A-5A-018 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-034 Air ND < 0.017 mg/m3

9094-A-5A-035 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-017 Air ND < 0.028 mg/m3

9094-A-5A-018 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-034 Air ND < 0.017 mg/m3

9094-A-5A-035 Air ND < 0.017 mg/m3

 
Page 5 of 6

Unit 5A Results

 Mineral: Tridymite

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-017 Air ND < 0.028 mg/m3

9094-A-5A-018 Air ND < 0.016 mg/m3

Post 2nd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-034 Air ND < 0.017 mg/m3

9094-A-5A-035 Air ND < 0.017 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5A-002 Wipe 297.6 S/cm2

9094-W-5A-003 Wipe 1308.15 S/cm2

9094-W-5A-004 Wipe 792.45 S/cm2

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5A-012 Air 1.499 S/L

9094-A-5A-013 Air 2.603 S/L

9094-A-5A-014 Air 0.651 S/L

9094-W-5A-019 Wipe 286.16 S/cm2

9094-W-5A-020 Wipe 57.23 S/cm2

9094-W-5A-021 Wipe 114.46 S/cm2

9094-W-5A-022 Wipe 57.23 S/cm2

9094-W-5A-023 Wipe 114.46 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5A-002 Wipe U 290 ug/m2

9094-W-5A-003 Wipe U 290 ug/m2

9094-W-5A-004 Wipe U 290 ug/m2

 
Page 6 of 6

Unit 5A Results 

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-W-5A-020 Wipe U 290 ug/m2

9094-W-5A-021 Wipe U 290 ug/m2

9094-W-5A-022 Wipe U 290 ug/m2

9094-W-5A-023 Wipe U 290 ug/m2
Page 1 of 6

Unit 5C Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-5C-005 Microvac 132284 S/cm2 Chrysotile

9094-M-5C-006 Microvac 136128 S/cm2 Chrysotile

9094-M-5C-007 Microvac 117133 S/cm2 Chrysotile

9094-W-5C-001 Wipe 9497.28 S/cm2 Chrysotile

9094-W-5C-002 Wipe 3165.76 S/cm2 Chrysotile

9094-W-5C-003 Wipe 97347.1 S/cm2 Chrysotile

9094-W-5C-004 Wipe 30074.7 S/cm2 Chrysotile

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-009 Air 0.004 f/cc

9094-A-5C-010 Air 0.015 f/cc

9094-A-5C-011 Air 0.005 f/cc

9094-A-5C-009 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-010 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-011 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-5C-021 Microvac ND < 1582.88 S/cm2 Chrysotile

9094-M-5C-022 Microvac 174117 S/cm2 Chrysotile

9094-M-5C-023 Microvac 74395.4 S/cm2 Chrysotile

9094-W-5C-016 Wipe 2374.32 S/cm2 Chrysotile

9094-W-5C-017 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-5C-018 Wipe ND < 2366.41 S/cm2

9094-W-5C-019 Wipe 3165.76 S/cm2 Chrysotile

9094-W-5C-020 Wipe 3165.76 S/cm2 Chrysotile

Post 2nd cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-024 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-025 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-026 Air f/cc Not analyzed due to 

overloading of particulates.
Page 2 of 6

Unit 5C Results 

9094-A-5C-027 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-028 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-024 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-025 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-026 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-027 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-028 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-024 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-025 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-026 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-027 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5C-028 Air S>5u/cc Not analyzed due to 

overloading of particulates.

Post 3rd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5C-031 Air 0.001 f/cc

9094-A-5C-032 Air ND < 0.001 f/cc

9094-A-5C-033 Air 0.001 f/cc

9094-A-5C-034 Air 0.003 f/cc

9094-A-5C-031 Air 0.0026 S>0.5u/cc Chrysotile

9094-A-5C-032 Air 0.0004 S>0.5u/cc Chrysotile

9094-A-5C-033 Air 0.0026 S>0.5u/cc Chrysotile

9094-A-5C-034 Air 0.0021 S>0.5u/cc Chrysotile

9094-A-5C-031 Air 0.0004 S>5u/cc Chrysotile

9094-A-5C-032 Air ND < 0.0004 S>5u/cc

9094-A-5C-033 Air 0.0016 S>5u/cc Chrysotile

9094-A-5C-034 Air 0.0015 S>5u/cc Chrysotile

 
Page 3 of 6

Unit 5C Results

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5C-002 Wipe 0.79 ng/m2

9094-W-5C-003 Wipe 2.55 ng/m2

9094-W-5C-004 Wipe 0.575 ng/m2

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-W-5C-017 Wipe 0.794 ng/m2

9094-W-5C-018 Wipe 0.494 ng/m2

9094-W-5C-019 Wipe 0.567 ng/m2

9094-W-5C-020 Wipe 0.556 ng/m2

Gypsum

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-014 Air ND < 0.016 mg/m3

9094-A-5C-015 Air ND < 0.016 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-5C-005 Microvac 104 ug/ft2

9094-M-5C-006 Microvac 293 ug/ft2

9094-M-5C-007 Microvac 133 ug/ft2

9094-W-5C-002 Wipe 6.95 ug/ft2

9094-W-5C-003 Wipe 336 ug/ft2

9094-W-5C-004 Wipe 43.6 ug/ft2
Page 4 of 6

Unit 5C Results

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-012 Air 0.095 ug/m3

9094-A-5C-013 Air 0.101 ug/m3

9094-M-5C-021 Microvac ND < 2.32 ug/ft2

9094-M-5C-022 Microvac ND < 2.32 ug/ft2

9094-M-5C-023 Microvac ND < 2.32 ug/ft2

9094-W-5C-017 Wipe ug/m2 Sample was received broken; 

not analyzed.

9094-W-5C-018 Wipe 10.3 ug/ft2

9094-W-5C-019 Wipe 7.69 ug/ft2

9094-W-5C-020 Wipe 6.86 ug/ft2

Post 2nd cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-029 Air 0.674 ug/m3

9094-A-5C-030 Air 0.757 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-014 Air ND < 0.004 mg/m3

9094-A-5C-015 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-014 Air ND < 0.016 mg/m3

9094-A-5C-015 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-014 Air ND < 0.016 mg/m3

9094-A-5C-015 Air ND < 0.016 mg/m3

 
Page 5 of 6

Unit 5C Results

Mineral: Tridymite

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-014 Air 0.027 mg/m3

9094-A-5C-015 Air ND < 0.016 mg/m3 

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5C-002 Wipe 457.85 S/cm2

9094-W-5C-003 Wipe 457.85 S/cm2

9094-W-5C-004 Wipe 1144.63 S/cm2

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-009 Air 13.399 S/L

9094-A-5C-010 Air 19.25 S/L

9094-A-5C-011 Air 8.129 S/L

9094-W-5C-016 Wipe 1774.17 S/cm2

9094-W-5C-017 Wipe 744.01 S/cm2

9094-W-5C-018 Wipe 4211.37 S/cm2

9094-W-5C-019 Wipe 2758.14 S/cm2

9094-W-5C-020 Wipe 1316.32 S/cm2

Post 2nd cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-A-5C-024 Air 2.266 S/L

9094-A-5C-025 Air 16.598 S/L

9094-A-5C-026 Air 12.621 S/L

9094-A-5C-027 Air 1.614 S/L

9094-A-5C-028 Air 0.829 S/L

Post 3rd cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5C-031 Air ND < 0.066 S/L

9094-A-5C-032 Air ND < 0.064 S/L
Page 6 of 6

Unit 5C Results 

 PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5C-002 Wipe U 290 ug/m2

9094-W-5C-003 Wipe 303.5 ug/m2

9094-W-5C-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 3A

Sample ID Matrix Detected Result Comment

9094-W-5C-017 Wipe U 290 ug/m2

9094-W-5C-018 Wipe U 290 ug/m2

9094-W-5C-019 Wipe U 290 ug/m2

9094-W-5C-020 Wipe U 290 ug/m2
Page 1 of 4

Unit 5D Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-5D-006 Microvac 83892.6 S/cm2 Chrysotile

9094-M-5D-007 Microvac 470907 S/cm2 Chrysotile

9094-W-5D-001 Wipe ND < 2366.41 S/cm2 Amosite

9094-W-5D-002 Wipe ND < 2366.41 S/cm2

9094-W-5D-003 Wipe ND < 2366.41 S/cm2 Chrysotile

9094-W-5D-004 Wipe 4748.64 S/cm2 Chrysotile

9094-W-5D-005 Wipe 36406.2 S/cm2 Chrysotile

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-008 Air 0.004 f/cc

9094-A-5D-009 Air 0.002 f/cc

9094-A-5D-010 Air 0.004 f/cc

9094-A-5D-008 Air ND < 0.0006 S>5u/cc

9094-A-5D-009 Air ND < 0.0007 S>5u/cc

9094-A-5D-010 Air ND < 0.0007 S>5u/cc

9094-M-5D-020 Microvac 284918 S/cm2 Chrysotile

9094-M-5D-021 Microvac 12267.3 S/cm2 Chrysotile

9094-W-5D-015 Wipe ND < 5916.01 S/cm2

9094-W-5D-016 Wipe ND < 5916.01 S/cm2

9094-W-5D-017 Wipe ND < 5916.01 S/cm2

9094-W-5D-018 Wipe ND < 5916.01 S/cm2

9094-W-5D-019 Wipe ND < 5916.01 S/cm2

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5D-002 Wipe 0.668 ng/m2

9094-W-5D-003 Wipe 0.56 ng/m2

9094-W-5D-004 Wipe 0.562 ng/m2

9094-W-5D-005 Wipe 0.609 ng/m2
Page 2 of 4

Unit 5D Results

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-W-5D-016 Wipe 0.498 ng/m2

9094-W-5D-017 Wipe 0.608 ng/m2

9094-W-5D-018 Wipe 0.55 ng/m2

9094-W-5D-019 Wipe 0.631 ng/m2

Gypsum

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-013 Air ND < 0.016 mg/m3

9094-A-5D-014 Air ND < 0.016 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-5D-006 Microvac 27.1 ug/ft2

9094-M-5D-007 Microvac 49.1 ug/ft2

9094-W-5D-002 Wipe 7.35 ug/ft2

9094-W-5D-003 Wipe 4.68 ug/ft2

9094-W-5D-004 Wipe 25.3 ug/ft2

9094-W-5D-005 Wipe 32.1 ug/ft2

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-011 Air 0.079 ug/m3

9094-A-5D-012 Air 0.08 ug/m3

9094-M-5D-020 Microvac ND < 2.32 ug/ft2

9094-M-5D-021 Microvac ND < 2.32 ug/ft2

9094-W-5D-016 Wipe ND < 4.65 ug/ft2

9094-W-5D-017 Wipe 12.8 ug/ft2

9094-W-5D-018 Wipe ND < 4.65 ug/ft2

9094-W-5D-019 Wipe ND < 4.65 ug/ft2

 
Page 3 of 4

Unit 5D Results 

Mineral: alpha-Quartz

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-013 Air ND < 0.004 mg/m3

9094-A-5D-014 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-013 Air ND < 0.016 mg/m3

9094-A-5D-014 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-013 Air ND < 0.016 mg/m3

9094-A-5D-014 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-013 Air ND < 0.016 mg/m3

9094-A-5D-014 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5D-002 Wipe 251.82 S/cm2

9094-W-5D-003 Wipe 206.03 S/cm2

9094-W-5D-004 Wipe 712.21 S/cm2

9094-W-5D-005 Wipe 595.21 S/cm2

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-A-5D-008 Air 9.814 S/L

9094-A-5D-009 Air 7.358 S/L

9094-A-5D-010 Air 8.424 S/L

9094-W-5D-015 Wipe 171.69 S/cm2

9094-W-5D-016 Wipe 228.93 S/cm2
Page 4 of 4

Unit 5D Results 

9094-W-5D-017 Wipe 171.69 S/cm2

9094-W-5D-018 Wipe 114.46 S/cm2

9094-W-5D-019 Wipe 228.93 S/cm2

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-5D-002 Wipe U 290 ug/m2

9094-W-5D-003 Wipe U 290 ug/m2

9094-W-5D-004 Wipe U 290 ug/m2

9094-W-5D-005 Wipe U 290 ug/m2

Post 1st cleaning - Test 3B

Sample ID Matrix Detected Result Comment

9094-W-5D-016 Wipe U 290 ug/m2

9094-W-5D-017 Wipe U 290 ug/m2

9094-W-5D-018 Wipe U 290 ug/m2

9094-W-5D-019 Wipe U 290 ug/m2
Page 1 of 2

5th Floor Hallway Results

Asbestos

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-001 Air 0.004 f/cc

9094-A-5TH-002 Air 0.004 f/cc

9094-A-5TH-001 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-5TH-002 Air S>5u/cc Not analyzed due to 

overloading of particulates.

Post 2nd cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-005 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-5TH-006 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-5TH-005 Air ND < 0.0009 S>0.5u/cc

9094-A-5TH-006 Air ND < 0.0009 S>0.5u/cc

9094-A-5TH-005 Air ND < 0.0009 S>5u/cc

9094-A-5TH-006 Air ND < 0.0009 S>5u/cc

Gypsum

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-004 Air ND < 0.016 mg/m3

Lead

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-003 Air 0.189 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-004 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-004 Air ND < 0.016 mg/m3

 
Page 2 of 2

Unit 5th Floor Hallway Results

 Mineral: Cristobalite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-004 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-004 Air ND < 0.016 mg/m3

MMVF

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-5TH-001 Air 0.617 S/L

9094-A-5TH-002 Air 0.562 S/L
Page 1 of 2

Barber Shop Results

Asbestos

Post 1st cleaning - Test 4A, 4E

Sample ID Matrix Detected Result Comment

9094-A-BS-005 Air ND < 0.001 f/cc

9094-A-BS-006 Air ND < 0.001 f/cc

9094-A-BS-007 Air ND < 0.001 f/cc

9094-A-BS-005 Air ND < 0.0004 S>0.5u/cc

9094-A-BS-006 Air ND < 0.0004 S>0.5u/cc

9094-A-BS-007 Air ND < 0.0004 S>0.5u/cc

9094-A-BS-005 Air ND < 0.0004 S>5u/cc

9094-A-BS-006 Air ND < 0.0004 S>5u/cc

9094-A-BS-007 Air ND < 0.0004 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-BS-001 Wipe 0.661 NG/M2

9094-W-BS-002 Wipe 0.692 NG/M2

9094-W-BS-003 Wipe 0.636 NG/M2

9094-W-BS-004 Wipe 0.767 NG/M2

Post 1st cleaning - Test 4A, 4E

Sample ID Matrix Detected Result Comment

9094-W-BS-010 Wipe 0.503 NG/M2

9094-W-BS-011 Wipe 0.526 NG/M2

9094-W-BS-012 Wipe 0.5 NG/M2

9094-W-BS-013 Wipe 0.577 NG/M2

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-BS-001 Wipe ND < 4.64 ug/ft2

9094-W-BS-002 Wipe 12.1 ug/ft2 Field blank contamination 

(Validation = R).

9094-W-BS-003 Wipe 25.9 ug/ft2 Field blank contamination 

(Validation = R).

9094-W-BS-004 Wipe 42.9 ug/ft2

 
Page 2 of 2

Barber Shop Results

Post 1st cleaning - Test 4A, 4E

Sample ID Matrix Detected Result Comment

9094-A-BS-008 Air ND < 0.051 ug/m3

9094-A-BS-009 Air ND < 0.052 ug/m3

9094-W-BS-010 Wipe ND < 4.65 ug/ft2

9094-W-BS-011 Wipe ND < 4.65 ug/ft2

9094-W-BS-012 Wipe ND < 4.65 ug/ft2

9094-W-BS-013 Wipe ND < 4.65 ug/ft2

MMVF

Post 1st cleaning - Test 4A, 4E

Sample ID Matrix Detected Result Comment

9094-A-BS-005 Air ND < 0.067 S/L

9094-A-BS-006 Air 0.302 S/L

9094-A-BS-007 Air 0.078 S/L

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-W-BS-001 Wipe U 290 ug/m2

9094-W-BS-002 Wipe U 290 ug/m2

9094-W-BS-003 Wipe U 290 ug/m2

9094-W-BS-004 Wipe U 290 ug/m2

Post 1st cleaning - Test 4A, 4E

Sample ID Matrix Detected Result Comment

9094-W-BS-010 Wipe U 290 ug/m2

9094-W-BS-011 Wipe U 290 ug/m2

9094-W-BS-012 Wipe U 290 ug/m2

9094-W-BS-013 Wipe 290 ug/m2
Page 1 of 2

Cedar Street Staircase Results

Asbestos

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-001 Air 0.003 f/cc

9094-A-CS5-001 Air 0.001 f/cc

9094-A-CS3-001 Air 0.001 S>0.5u/cc Chrysotile

9094-A-CS5-001 Air 0.0015 S>0.5u/cc Chrysotile

9094-A-CS3-001 Air ND < 0.0005 S>5u/cc

9094-A-CS5-001 Air 0.0005 S>5u/cc Chrysotile

Gypsum

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-003 Air ND < 0.009 mg/m3

9094-A-CS5-003 Air ND < 0.009 mg/m3

Lead

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-002 Air ND < 0.052 ug/m3

9094-A-CS5-002 Air ND < 0.051 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-003 Air ND < 0.004 mg/m3

9094-A-CS5-003 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-003 Air ND < 0.017 mg/m3

9094-A-CS5-003 Air ND < 0.017 mg/m3
Page 2 of 2

Cedar Street Staircase Results

Mineral: Cristobalite

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-003 Air ND < 0.017 mg/m3

9094-A-CS5-003 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-003 Air ND < 0.017 mg/m3

9094-A-CS5-003 Air ND < 0.017 mg/m3

MMVF

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-CS3-001 Air ND < 0.069 S/L

9094-A-CS5-001 Air 0.068 S/L
Page 1 of 10

Chiropractor’s Office Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-CHR-010 Air 0.016 f/cc

9094-A-CHR-011 Air 0.006 f/cc

9094-A-CHR-010 Air ND < 0.0009 S>5u/cc

9094-A-CHR-011 Air ND < 0.0009 S>5u/cc

9094-M-CHR-006 Microvac 601494 S/cm2 Chrysotile

9094-M-CHR-007 Microvac 166202 S/cm2 Chrysotile

9094-M-CHR-008 Microvac 1709500 S/cm2 Chrysotile

9094-M-CHR-009 Microvac 10967100 S/cm2 Chrysotile

9094-W-CHR-001 Wipe 17411.7 S/cm2 Chrysotile

9094-W-CHR-002 Wipe 145625 S/cm2 Chrysotile/Amosite.

9094-W-CHR-003 Wipe 18203.1 S/cm2 Chrysotile

9094-W-CHR-004 Wipe 84684.1 S/cm2 Chrysotile/Amosite.

9094-W-CHR-005 Wipe 51443.6 S/cm2 Chrysotile

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-014 Air f/cc Not analyzed, uneven 

distribution of material on the 

9094-A-CHR-015 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-016 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-014 Air S>0.5u/cc Not analyzed, uneven 

distribution of material on the 

9094-A-CHR-015 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-016 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-014 Air S>5u/cc Not analyzed, uneven 

distribution of material on the 

9094-A-CHR-015 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-016 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-CHR-026 Microvac 4748.64 S/cm2 Chrysotile

9094-M-CHR-027 Microvac 164619.52 S/cm2 Chrysotile

9094-M-CHR-028 Microvac 22753.9 S/cm2 22 Chrysotile and 1 

Anthophyllite
Page 2 of 10

Chiropractor’s Office Results

9094-M-CHR-029 Microvac 23743.2 S/cm2 Chrysotile

9094-W-CHR-021 Wipe 2967.9 S/cm2 Chrysotile

9094-W-CHR-022 Wipe 3957.2 S/cm2 Chrysotile

9094-W-CHR-023 Wipe 109219 S/cm2 Chrysotile

9094-W-CHR-024 Wipe 89432.7 S/cm2 1 Amosite and 112 Chrysotile

9094-W-CHR-025 Wipe ND < 739.502 S/cm2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-030 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-031 Air 0.441 f/cc

9094-A-CHR-032 Air 0.018 f/cc

9094-A-CHR-030 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-031 Air 0.1767 S>0.5u/cc Chrysotile

9094-A-CHR-032 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-030 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-031 Air 0.039 S>5u/cc Chrysotile

9094-A-CHR-032 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-W-CHR-037 Wipe < 6720.06 S/cm2 Chrysotile

9094-W-CHR-038 Wipe 12480.1 S/cm2 Chrysotile

9094-W-CHR-039 Wipe 115201 S/cm2 1 Amosite and 59 Chrysotile

9094-W-CHR-040 Wipe 15360.1 S/cm2 Chrysotile

9094-W-CHR-041 Wipe < 5740.85 S/cm2 Chrysotile

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-042 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-043 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-044 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-045 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-046 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-042 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.
Page 3 of 10

Chiropractor’s Office Results

9094-A-CHR-043 Air 0.0075 S>0.5u/cc

9094-A-CHR-044 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-045 Air 0.0007 S>0.5u/cc

9094-A-CHR-046 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-042 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-043 Air 0.0033 S>5u/cc

9094-A-CHR-044 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-CHR-045 Air ND < 0.0007 S>5u/cc

9094-A-CHR-046 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-CHR-051 Microvac 21504.2 S/cm2 Chrysotile

9094-M-CHR-052 Microvac 31488.3 S/cm2 Chrysotile

9094-M-CHR-053 Microvac 54144.5 S/cm2 Chrysotile

9094-M-CHR-054 Microvac 59520.6 S/cm2 Chrysotile

Post 1st cleaning - Test 4D

Sample ID Matrix Detected Result Comment

9094-A-CHR-056 Air 0.001 f/cc

9094-A-CHR-057 Air 0.001 f/cc

9094-A-CHR-058 Air 0.003 f/cc

9094-A-CHR-056 Air ND < 0.0004 S>0.5u/cc

9094-A-CHR-057 Air ND < 0.0004 S>0.5u/cc

9094-A-CHR-058 Air ND < 0.0005 S>0.5u/cc

9094-A-CHR-056 Air ND < 0.0004 S>5u/cc

9094-A-CHR-057 Air ND < 0.0004 S>5u/cc S>5u/cc
Page 4 of 10

Chiropractor’s Office Results

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-CHR-012 Air 0.000305 ng/m3

9094-W-CHR-002 Wipe 1.03 ng/m2

9094-W-CHR-003 Wipe 0.547 ng/m2

9094-W-CHR-004 Wipe 0.788 ng/m2

9094-W-CHR-005 Wipe 0.544 ng/m2

9094-A-CHR-058 Air ND < 0.0005

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-W-CHR-022 Wipe 1.01 ng/m2

9094-W-CHR-023 Wipe 0.999 ng/m2

9094-W-CHR-024 Wipe 1.2 ng/m2

9094-W-CHR-025 Wipe 1.15 ng/m2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-W-CHR-038 Wipe 0.933 ng/m2

9094-W-CHR-039 Wipe 1.12 ng/m2

9094-W-CHR-040 Wipe 0.982 ng/m2

9094-W-CHR-041 Wipe 0.712 ng/m2

Post 1st cleaning - Test 4E

Sample ID Matrix Detected Result Comment

9094-W-CHR-061 Wipe 0.598 NG/M2

9094-W-CHR-062 Wipe 0.616 NG/M2

9094-W-CHR-063 Wipe 0.645 NG/M2

Pre-water wipe

Sample ID Matrix Detected Result Comment

9094-W-CHR-055 Wipe 0.708 NG/M2

Gypsum

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-019 Air ND < 0.017 mg/m3

9094-A-CHR-020 Air ND < 0.008 mg/m3
Page 5 of 10

Chiropractor’s Office Results

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-035 Air 0.014 mg/m3

9094-A-CHR-036 Air 0.011 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-049 Air 0.009 mg/m3

9094-A-CHR-050 Air 0.012 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-CHR-006 Microvac 28.2 ug/ft2

9094-M-CHR-007 Microvac 7.22 ug/ft2 Estimated concentration (J).

9094-M-CHR-008 Microvac 181 ug/ft2 Estimated concentration (J).

9094-M-CHR-009 Microvac 69.3 ug/ft2 Estimated concentration (J).

9094-W-CHR-002 Wipe 433 ug/ft2

9094-W-CHR-003 Wipe 346 ug/ft2

9094-W-CHR-004 Wipe 116 ug/ft2

9094-W-CHR-005 Wipe 74.7 ug/ft2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-017 Air 0.617 ug/m3

9094-A-CHR-018 Air 0.499 ug/m3

9094-M-CHR-026 Microvac 9.66 ug/ft2

9094-M-CHR-027 Microvac 3.67 ug/ft2

9094-M-CHR-028 Microvac 5.25 ug/ft2

9094-M-CHR-029 Microvac 9.23 ug/ft2

9094-W-CHR-022 Wipe 11.2 ug/ft2

9094-W-CHR-023 Wipe 146 ug/ft2

9094-W-CHR-024 Wipe 64.5 ug/ft2

9094-W-CHR-025 Wipe 5.97 ug/ft2
Page 6 of 10

Chiropractor’s Office Results

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-033 Air 0.503 ug/m3

9094-A-CHR-034 Air 0.486 ug/m3

9094-W-CHR-038 Wipe 7.12 ug/ft2

9094-W-CHR-039 Wipe 147 ug/ft2

9094-W-CHR-040 Wipe 556 ug/ft2

9094-W-CHR-041 Wipe 6.61 ug/ft2

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-047 Air 1.89 ug/m3

9094-A-CHR-048 Air 2.56 ug/m3

9094-M-CHR-051 Microvac 14.5 ug/ft2

9094-M-CHR-052 Microvac 18.5 ug/ft2

9094-M-CHR-053 Microvac 17.4 ug/ft2

9094-M-CHR-054 Microvac 17.9 ug/ft2

Post 1st cleaning - Test 4D

Sample ID Matrix Detected Result Comment

9094-A-CHR-059 Air ND < 0.052 ug/m3

9094-A-CHR-060 Air ND < 0.052 ug/m3

Post 1st cleaning - Test 4E

Sample ID Matrix Detected Result Comment

9094-W-CHR-061 Wipe ND < 4.65 ug/ft2

9094-W-CHR-062 Wipe 954 ug/ft2

9094-W-CHR-063 Wipe ND < 4.65 ug/ft2

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-019 Air ND < 0.008 mg/m3

9094-A-CHR-020 Air ND < 0.004 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-035 Air ND < 0.004 mg/m3

9094-A-CHR-036 Air ND < 0.004 mg/m3
Page 7 of 10

Chiropractor’s Office Results

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-049 Air ND < 0.004 mg/m3

9094-A-CHR-050 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-019 Air ND < 0.034 mg/m3

9094-A-CHR-020 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-035 Air ND < 0.017 mg/m3

9094-A-CHR-036 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-049 Air ND < 0.017 mg/m3

9094-A-CHR-050 Air ND < 0.016 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-019 Air ND < 0.034 mg/m3

9094-A-CHR-020 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-035 Air ND < 0.017 mg/m3

9094-A-CHR-036 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-049 Air ND < 0.017 mg/m3

9094-A-CHR-050 Air ND < 0.016 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-019 Air ND < 0.034 mg/m3

9094-A-CHR-020 Air ND < 0.016 mg/m3
Page 8 of 10

Chiropractor’s Office Results

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-035 Air ND < 0.017 mg/m3

9094-A-CHR-036 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-049 Air ND < 0.017 mg/m3

9094-A-CHR-050 Air ND < 0.016 mg/m3

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-CHR-010 Air 4.579 S/L

9094-A-CHR-011 Air 7.869 S/L

9094-W-CHR-002 Wipe 53415.98 S/cm2

9094-W-CHR-003 Wipe 30523.42 S/cm2

9094-W-CHR-004 Wipe 18314.25 S/cm2

9094-W-CHR-005 Wipe 744.01 S/cm2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-CHR-014 Air 0.522 S/L

9094-A-CHR-015 Air 1.461 S/L

9094-A-CHR-016 Air 1.843 S/L

9094-W-CHR-021 Wipe 57.23 S/cm2

9094-W-CHR-022 Wipe 57.23 S/cm2

9094-W-CHR-023 Wipe 515.08 S/cm2

9094-W-CHR-024 Wipe 457.85 S/cm2

9094-W-CHR-025 Wipe ND < 57.23 S/cm2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-CHR-030 Air 17.579 S/L

9094-A-CHR-031 Air 60.606 S/L

9094-A-CHR-032 Air 5.598 S/L

9094-W-CHR-037 Wipe ND < 57.23 S/cm2
Page 9 of 10

Chiropractor’s Office Results

9094-W-CHR-038 Wipe 57.23 S/cm2

9094-W-CHR-039 Wipe 228.93 S/cm2

9094-W-CHR-040 Wipe 68.86 S/cm2

9094-W-CHR-041 Wipe 171.69 S/cm2

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-CHR-042 Air 1.668 S/L

9094-A-CHR-043 Air 0.35 S/L

9094-A-CHR-044 Air 5.499 S/L

9094-A-CHR-045 Air 0.126 S/L

9094-A-CHR-046 Air 0.514 S/L

Post 1st cleaning - Test 4D

Sample ID Matrix Detected Result Comment

9094-A-CHR-056 Air 0.135 S/L

9094-A-CHR-057 Air 0.539 S/L

9094-A-CHR-058 Air 0.7 S/L

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-CHR-012 Air 0.15 μg/m3

9094-A-CHR-013 Air 0.16 μg/m3

9094-W-CHR-002 Wipe 290 ug/m2 Estimated concentration (J).

9094-W-CHR-003 Wipe 290 ug/m2 Estimated concentration (J).

9094-W-CHR-004 Wipe U 290 ug/m2

9094-W-CHR-005 Wipe U 290 ug/m2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-W-CHR-022 Wipe U 290 ug/m2

9094-W-CHR-023 Wipe U 290 ug/m2

9094-W-CHR-024 Wipe U 290 ug/m2

9094-W-CHR-025 Wipe U 290 ug/m2
Page 10 of 10

Chiropractor’s Office Results

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-W-CHR-038 Wipe U 290 ug/m2

9094-W-CHR-039 Wipe U 290 ug/m2

9094-W-CHR-040 Wipe U 290 ug/m2

9094-W-CHR-041 Wipe U 290 ug/m2

Post 1st cleaning - Test 4E

Sample ID Matrix Detected Result Comment

9094-W-CHR-061 Wipe U 290 ug/m2

9094-W-CHR-062 Wipe U 290 ug/m2

9094-W-CHR-063 Wipe U 290 ug/m2

Pre-water wipe

Sample ID Matrix Detected Result Comment

9094-W-CHR-055 Wipe U 290 ug/m2
Page 1 of 1

Elevator Shaft Results

Asbestos

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-ELV-001 Air 0.001 f/cc

9094-A-ELV-002 Air ND < 0.001 f/cc

9094-A-ELV-005 Air ND < 0.001 f/cc

9094-A-ELV-001 Air ND < 0.0004 S>0.5u/cc

9094-A-ELV-002 Air ND < 0.0004 S>0.5u/cc

9094-A-ELV-005 Air ND < 0.0004 S>0.5u/cc

9094-A-ELV-001 Air ND < 0.0004 S>5u/cc

9094-A-ELV-002 Air ND < 0.0004 S>5u/cc

9094-A-ELV-005 Air ND < 0.0004 S>5u/cc

Lead

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-ELV-003 Air ND < 0.05 ug/m3

9094-A-ELV-004 Air ND < 0.052 ug/m3

MMVF

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-ELV-001 Air 0.67 S/L

9094-A-ELV-002 Air 0.167 S/L

9094-A-ELV-005 Air 0.203 S/L
Page 1 of 4

The Food Exchange Results

Asbestos

Before Cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-W-FE-001 Wipe ND < 302504 S/cm2

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-018 Air 0.001 f/cc

9094-A-FE-019 Air 0.001 f/cc

9094-A-FE-020 Air 0.001 f/cc

9094-A-FE-018 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-019 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-FE-020 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-018 Air ND < 0.0005 S>5u/cc

9094-A-FE-019 Air 0.0005 S>5u/cc Chrysotile

9094-A-FE-020 Air ND < 0.0005 S>5u/cc

9094-W-FE-015 Wipe ND < 30250.4 S/cm2

9094-W-FE-016 Wipe ND < 30250.4 S/cm2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-FE-002 Air 0.001 f/cc

9094-A-FE-003 Air ND < 0.001 f/cc

9094-A-FE-004 Air 0.001 f/cc

9094-A-FE-005 Air ND < 0.001 f/cc

9094-A-FE-008 Air ND < 0.001 f/cc

9094-A-FE-009 Air ND < 0.001 f/cc

9094-A-FE-010 Air ND < 0.001 f/cc

9094-A-FE-011 Air ND < 0.001 f/cc

9094-A-FE-002 Air 0.001 S>0.5u/cc Chrysotile

9094-A-FE-003 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-004 Air ND < 0.0005 S>0.5u/cc Chrysotile

9094-A-FE-005 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-008 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-009 Air ND < 0.0005 S>0.5u/cc
Page 2 of 4

The Food Exchange Results 

 9094-A-FE-010 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-011 Air ND < 0.0005 S>0.5u/cc

9094-A-FE-002 Air ND < 0.0005 S>5u/cc

9094-A-FE-003 Air ND < 0.0005 S>5u/cc

9094-A-FE-004 Air ND < 0.0005 S>5u/cc

9094-A-FE-005 Air ND < 0.0005 S>5u/cc

9094-A-FE-008 Air ND < 0.0005 S>5u/cc

9094-A-FE-009 Air ND < 0.0005 S>5u/cc

9094-A-FE-010 Air ND < 0.0005 S>5u/cc

9094-A-FE-011 Air ND < 0.0005 S>5u/cc

Gypsum

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-023 Air ND < 0.008 mg/m3

Lead

Before Cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-W-FE-001 Wipe 1310 ug/ft2

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-021 Air ND < 0.053 ug/m3 Estimated concentration (J).

9094-A-FE-022 Air ND < 0.052 ug/m3 Estimated concentration (J).

9094-W-FE-015 Wipe 136 ug/ft2

9094-W-FE-016 Wipe 183 ug/ft2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-FE-006 Air ND < 0.053 ug/m3

9094-A-FE-007 Air ND < 0.05 ug/m3

9094-A-FE-012 Air ND < 0.052 ug/m3

9094-A-FE-013 Air ND < 0.052 ug/m3

9094-A-FE-014 Air ND < 0.05 ug/m3

 
Page 3 of 4

The Food Exchange Results 

 Mineral: alpha-Quartz

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-023 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-023 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-023 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-023 Air ND < 0.017 mg/m3

MMVF

Before Cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-W-FE-001 Wipe 11732.44 S/cm2

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-FE-018 Air ND < 0.066 S/L

9094-A-FE-019 Air ND < 0.066 S/L

9094-A-FE-020 Air ND < 0.067 S/L

9094-W-FE-015 Wipe ND < 57.23 S/cm2

9094-W-FE-016 Wipe ND < 57.23 S/cm2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-FE-002 Air ND < 0.069 S/L

9094-A-FE-003 Air ND < 0.072 S/L

9094-A-FE-004 Air ND < 0.086 S/L

9094-A-FE-005 Air ND < 0.074 S/L

9094-A-FE-008 Air 0.14 S/L
Page 4 of 4

The Food Exchange Results 

 9094-A-FE-009 Air 0.145 S/L

 

9094-A-FE-010 Air ND < 0.079 S/L

9094-A-FE-011 Air ND < 0.072 S/L

Total Dust - NADCA vacuum

Post 1st cleaning - HVAC System (NADCA)

Sample ID Matrix Detected Result Comment

9094-M-FE-017 Microvac 0.013 mg/cm2
Page 1 of 4

Lemongrass Grill Results

Asbestos

Before cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-W-LG-009 Wipe ND < 30250.4 S/cm2

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-023 Air 0.001 f/cc

9094-A-LG-024 Air 0.001 f/cc

9094-A-LG-025 Air 0.001 f/cc

9094-A-LG-026 Air 0.001 f/cc

9094-A-LG-023 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-024 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-LG-025 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-LG-026 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-023 Air ND < 0.0005 S>5u/cc

9094-A-LG-024 Air ND < 0.0005 S>5u/cc

9094-A-LG-025 Air ND < 0.0005 S>5u/cc

9094-A-LG-026 Air ND < 0.0005 S>5u/cc

9094-W-LG-020 Wipe ND < 12100.2 S/cm2

9094-W-LG-021 Wipe ND < 12100.2 S/cm2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-LG-001 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-002 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-003 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-004 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-005 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-018 Air ND < 0.001 f/cc

 

9094-A-LG-001 Air S>0.5u/cc Not analyzed due to 

 overloading of particulates.

9094-A-LG-002 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-003 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.
Page 2 of 4

 

Lemongrass Grill Results 

 9094-A-LG-004 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-005 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-018 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-001 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-002 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-003 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-004 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-005 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-LG-018 Air ND < 0.0005 S>5u/cc

Post 2nd cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-LG-010 Air ND < 0.001 f/cc

9094-A-LG-011 Air ND < 0.001 f/cc

9094-A-LG-012 Air ND < 0.001 f/cc

9094-A-LG-013 Air ND < 0.001 f/cc

9094-A-LG-014 Air 0.001 f/cc

9094-A-LG-015 Air 0.001 f/cc

9094-A-LG-016 Air 0.001 f/cc

9094-A-LG-010 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-011 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-012 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-013 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-014 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-015 Air ND < 0.0005 S>0.5u/cc

9094-A-LG-016 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-LG-010 Air ND < 0.0005 S>5u/cc

9094-A-LG-011 Air ND < 0.0005 S>5u/cc

9094-A-LG-012 Air ND < 0.0005 S>5u/cc

9094-A-LG-013 Air ND < 0.0005 S>5u/cc

9094-A-LG-014 Air ND < 0.0005 S>5u/cc
Page 3 of 4

Lemongrass Grill Results

 9094-A-LG-015 Air ND < 0.0005 S>5u/cc

9094-A-LG-016 Air 0.0005 S>5u/cc Chrysotile

Gypsum

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-030 Air ND < 0.009 mg/m3

Lead

Before cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-W-LG-009 Wipe 10700 ug/ft2 Estimated concentration (J)

Post 1st Cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-027 Air ND < 0.053 ug/m3 Estimated concentration (J).

9094-A-LG-028 Air ND < 0.052 ug/m3 Estimated concentration (J).

9094-A-LG-029 Air ND < 0.053 ug/m3 Estimated concentration (J).

9094-W-LG-020 Wipe 25.9 ug/ft2 Method blank contamination 

(Validation = R).

9094-W-LG-021 Wipe 166 ug/ft2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-LG-006 Air 0.168 ug/m3

9094-A-LG-007 Air 0.16 ug/m3

9094-A-LG-008 Air 0.347 ug/m3

9094-A-LG-019 Air ND < 0.059 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-030 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-030 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-030 Air ND < 0.017 mg/m3
Page 4 of 4

Lemongrass Grill Results 

Mineral: Tridymite

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-030 Air ND < 0.017 mg/m3

MMVF

Before cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-W-LG-009 Wipe ND < 57.23 S/cm2

Post 1st cleaning - HVAC System

Sample ID Matrix Detected Result Comment

9094-A-LG-023 Air ND < 0.096 S/L

9094-A-LG-024 Air ND < 0.086 S/L

9094-A-LG-025 Air ND < 0.067 S/L

9094-A-LG-026 Air ND < 0.089 S/L

9094-W-LG-020 Wipe ND < 57.23 S/cm2

9094-W-LG-021 Wipe ND < 57.23 S/cm2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-LG-001 Air ND < 0.075 S/L

9094-A-LG-002 Air ND < 0.068 S/L

9094-A-LG-003 Air ND < 0.082 S/L

9094-A-LG-004 Air ND < 0.066 S/L

9094-A-LG-005 Air ND < 0.063 S/L

9094-A-LG-018 Air ND < 0.072 S/L

Total Dust - NADCA vacuum

Post 1st cleaning - HVAC System (NADCA)

Sample ID Matrix Detected Result Comment

9094-M-LG-022 Microvac 0.005 mg/cm2
Page 1 of 2

Liberty Street Staircase Results

Asbestos

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-001 Air 0.005 f/cc

9094-A-LS5-001 Air 0.003 f/cc

9094-A-LS3-001 Air ND < 0.0005 S>0.5u/cc

9094-A-LS5-001 Air 0.0005 S>0.5u/cc Chrysotile

9094-A-LS3-001 Air ND < 0.0005 S>5u/cc

9094-A-LS5-001 Air 0.0005 S>5u/cc Chrysotile

Gypsum

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-003 Air ND < 0.009 mg/m3

9094-A-LS5-003 Air ND < 0.008 mg/m3

Lead

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-002 Air ND < 0.052 ug/m3

9094-A-LS5-002 Air ND < 0.052 ug/m3

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-003 Air 0.022 mg/m3

9094-A-LS5-003 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-003 Air ND < 0.017 mg/m3

9094-A-LS5-003 Air ND < 0.017 mg/m3

Mineral: Cristobalite

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-003 Air ND < 0.017 mg/m3

9094-A-LS5-003 Air ND < 0.017 mg/m3
Page 2 of 2

Liberty Street Staircase Results

 Mineral: Tridymite

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-003 Air ND < 0.017 mg/m3

9094-A-LS5-003 Air ND < 0.017 mg/m3

MMVF

Post 1st cleaning - Test 4A, 4B

Sample ID Matrix Detected Result Comment

9094-A-LS3-001 Air 0.14 S/L

9094-A-LS5-001 Air 0.072 S/L
Page 1 of 11

Mattress Shop Results

Asbestos

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-MAT-012 Air 0.025 f/cc

9094-A-MAT-013 Air 0.283 f/cc

9094-A-MAT-014 Air 0.008 f/cc

9094-A-MAT-015 Air 0.004 f/cc

9094-A-MAT-012 Air ND < 0.0009 S>5u/cc

9094-A-MAT-013 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-014 Air ND < 0.0008 S>5u/cc

9094-A-MAT-015 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-M-MAT-005 Microvac 378132 S/cm2 Chrysotile

9094-M-MAT-006 Microvac 371977 S/cm2 Chrysotile

9094-M-MAT-007 Microvac 39572 S/cm2 Chrysotile

9094-M-MAT-008 Microvac 823098 S/cm2 Chrysotile

9094-M-MAT-009 Microvac 182031 S/cm2 Chrysotile

9094-M-MAT-010 Microvac 123465 S/cm2 Chrysotile

9094-M-MAT-011 Microvac 72812.5 S/cm2 Chrysotile

9094-W-MAT-002 Wipe 7122.96 S/cm2 Chrysotile

9094-W-MAT-003 Wipe 11080.2 S/cm2 Chrysotile

9094-W-MAT-004 Wipe 10288.7 S/cm2 Chrysotile

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-018 Air 0.006 f/cc

9094-A-MAT-019 Air 0.006 f/cc

9094-A-MAT-020 Air 0.009 f/cc

9094-A-MAT-018 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-019 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-020 Air 0.0009 S>0.5u/cc Chrysotile

9094-A-MAT-018 Air S>5u/cc Not analyzed due to 

overloading of particulates.
Page 2 of 11

Mattress Shop Results

9094-A-MAT-019 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-020 Air 0.0009 S>5u/cc Chrysotile

9094-M-MAT-030 Microvac 18203.1 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-M-MAT-031 Microvac 35614.8 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-M-MAT-032 Microvac 53817.9 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-M-MAT-033 Microvac 56983.7 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-M-MAT-034 Microvac 58566.6 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-M-MAT-035 Microvac 23743.2 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-M-MAT-036 Microvac 47486.4 S/cm2 Chrysotile - Field Blank 

contamination (Validation = J).

9094-W-MAT-026 Wipe 1582.88 S/cm2 Chrysotile

9094-W-MAT-027 Wipe 48277.8 S/cm2 Chrysotile

9094-W-MAT-028 Wipe 197860 S/cm2 Chrysotile

9094-W-MAT-029 Wipe 134545 S/cm2 Chrysotile

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-037 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-038 Air 0.042 f/cc

9094-A-MAT-039 Air f/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-037 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-038 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-039 Air S>0.5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-037 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-038 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-A-MAT-039 Air S>5u/cc Not analyzed due to 

overloading of particulates.

9094-W-MAT-045 Wipe 2374.32 S/cm2 Chrysotile

9094-W-MAT-046 Wipe 27304.7 S/cm2 Chrysotile

9094-W-MAT-047 Wipe 35614.8 S/cm2 44 Chrysotile and 1 

Anthophyllite

9094-W-MAT-048 Wipe ND < 23664.1 S/cm2 Particulate matter; sensitivity 

(7914 s/cm2) not reached.
Page 3 of 11

Mattress Shop Results

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-049 Air 0.006 f/cc

9094-A-MAT-050 Air 0.006 f/cc

9094-A-MAT-051 Air 0.008 f/cc

9094-A-MAT-052 Air 0.008 f/cc

9094-A-MAT-053 Air 0.007 f/cc

9094-A-MAT-049 Air 0.0067 S>0.5u/cc Chrysotile

9094-A-MAT-050 Air 0.0032 S>0.5u/cc Chrysotile

9094-A-MAT-051 Air 0.0106 S>0.5u/cc Chrysotile

9094-A-MAT-052 Air 0.0041 S>0.5u/cc Chrysotile

9094-A-MAT-053 Air 0.0047 S>0.5u/cc Chrysotile

9094-A-MAT-049 Air 0.0025 S>5u/cc Chrysotile

9094-A-MAT-050 Air 0.0016 S>5u/cc Chrysotile

9094-A-MAT-051 Air 0.0025 S>5u/cc Chrysotile

9094-A-MAT-052 Air 0.0016 S>5u/cc Chrysotile

9094-A-MAT-053 Air 0.0016 S>5u/cc Chrysotile

9094-M-MAT-058 Microvac ND < 3840.04 S/cm2

9094-M-MAT-059 Microvac ND < 3840.04 S/cm2 Chrysotile - Asbestos detected

 below detection limit.

9094-M-MAT-060 Microvac 12480.1 S/cm2 Chrysotile

9094-M-MAT-061 Microvac 95040.9 S/cm2 Chrysotile

9094-M-MAT-062 Microvac 6720.06 S/cm2 Chrysotile

9094-M-MAT-063 Microvac 4800.04 S/cm2 Chrysotile

9094-M-MAT-064 Microvac ND < 3840.04 S/cm2 Chrysotile - Asbestos detected

 below detection limit.

Post 1st cleaning - Test 4D

Sample ID Matrix Detected Result Comment

9094-A-MAT-067 Air ND < 0.001 f/cc

9094-A-MAT-068 Air ND < 0.001 f/cc

9094-A-MAT-071 Air ND < 0.001 f/cc

9094-A-MAT-067 Air ND < 0.0005 S>0.5u/cc

9094-A-MAT-068 Air ND < 0.0005 S>0.5u/cc

9094-A-MAT-071 Air ND < 0.0005 S>0.5u/cc
Page 4 of 11

Mattress Shop Results

9094-A-MAT-067 Air ND < 0.0005 S>5u/cc

9094-A-MAT-068 Air ND < 0.0005 S>5u/cc

9094-A-MAT-071 Air ND < 0.0005 S>5u/cc

Dioxin TEQ EMPC (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-MAT-016 Air 0.000221 ng/m3

9094-A-MAT-017 Air 0.00017 ng/m3

9094-W-MAT-002 Wipe 0.584 ng/m2

9094-W-MAT-003 Wipe 0.647 ng/m2

9094-W-MAT-004 Wipe 0.598 ng/m2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-W-MAT-026 Wipe 0.797 ng/m2

9094-W-MAT-027 Wipe 0.805 ng/m2

9094-W-MAT-028 Wipe 0.691 ng/m2

9094-W-MAT-029 Wipe 0.846 ng/m2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-W-MAT-045 Wipe 0.812 ng/m2

9094-W-MAT-046 Wipe 0.903 ng/m2

9094-W-MAT-047 Wipe 0.838 ng/m2

9094-W-MAT-048 Wipe 0.678 ng/m2

Post 1st cleaning - Test 4E

Sample ID Matrix Detected Result Comment

9094-W-MAT-072 Wipe 0.647 NG/M2

9094-W-MAT-073 Wipe 0.613 NG/M2

Pre-water wipe

Sample ID Matrix Detected Result Comment

9094-W-MAT-065 Wipe 0.849 NG/M2

9094-W-MAT-066 Wipe 0.698 NG/M2
Page 5 of 11

Unit Mattress Shop Results

Gypsum

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-023 Air ND < 0.008 mg/m3

9094-A-MAT-024 Air ND < 0.008 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-042 Air ND < 0.008 mg/m3

9094-A-MAT-043 Air ND < 0.008 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-056 Air ND < 0.008 mg/m3

9094-A-MAT-057 Air ND < 0.008 mg/m3

Lead

Before cleaning

Sample ID Matrix Detected Result Comment

9094-M-MAT-005 Microvac 5.56 ug/ft2 Estimated concentration (J).

9094-M-MAT-006 Microvac 18.4 ug/ft2 Estimated concentration (J).

9094-M-MAT-007 Microvac 7.66 ug/ft2 Estimated concentration (J).

9094-M-MAT-008 Microvac 5.28 ug/ft2

9094-M-MAT-009 Microvac 3.52 ug/ft2

9094-M-MAT-010 Microvac 2.62 ug/ft2

9094-M-MAT-011 Microvac ND < 2.32 ug/ft2

9094-W-MAT-002 Wipe ND < 4.65 ug/ft2

9094-W-MAT-003 Wipe 38.9 ug/ft2

9094-W-MAT-004 Wipe 77 ug/ft2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-021 Air 0.198 ug/m3

9094-A-MAT-022 Air 0.195 ug/m3

9094-M-MAT-030 Microvac ND < 2.32 ug/ft2

9094-M-MAT-031 Microvac ND < 2.32 ug/ft2

9094-M-MAT-032 Microvac ND < 2.32 ug/ft2
Page 6 of 11

Mattress Shop Results

9094-M-MAT-033 Microvac ND < 2.32 ug/ft2

 9094-M-MAT-034 Microvac 3.29 ug/ft2

9094-M-MAT-035 Microvac 2.56 ug/ft2

9094-M-MAT-036 Microvac ND < 2.32 ug/ft2

9094-W-MAT-026 Wipe ND < 4.65 ug/ft2

9094-W-MAT-027 Wipe 22.2 ug/ft2

9094-W-MAT-028 Wipe 43.9 ug/ft2

9094-W-MAT-029 Wipe 42.2 ug/ft2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-040 Air 0.363 ug/m3

9094-A-MAT-041 Air 0.352 ug/m3

9094-W-MAT-045 Wipe ND < 4.65 ug/ft2

9094-W-MAT-046 Wipe 10.6 ug/ft2

9094-W-MAT-047 Wipe 91.5 ug/ft2

9094-W-MAT-048 Wipe 79.3 ug/ft2

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-054 Air 0.174 ug/m3

9094-A-MAT-055 Air 0.189 ug/m3

9094-M-MAT-058 Microvac ND < 2.32 ug/ft2

9094-M-MAT-059 Microvac ND < 2.32 ug/ft2

9094-M-MAT-060 Microvac ND < 2.32 ug/ft2

9094-M-MAT-061 Microvac ND < 2.32 ug/ft2

9094-M-MAT-062 Microvac 3.82 ug/ft2

9094-M-MAT-063 Microvac ND < 2.32 ug/ft2

9094-M-MAT-064 Microvac ND < 2.32 ug/ft2

Post 1st cleaning - Test 4D

Sample ID Matrix Detected Result Comment

9094-A-MAT-069 Air ND < 0.051 ug/m3

9094-A-MAT-070 Air ND < 0.051 ug/m3
Page 7 of 11

Mattress Shop Results

Post 1st cleaning - Test 4E

Sample ID Matrix Detected Result Comment

9094-W-MAT-072 Wipe 19.5 ug/ft2 Sample was broken at the 

laboratory; ID not confirmed.

9094-W-MAT-073 Wipe 5.06 ug/ft2 Sample was broken at the 

laboratory; ID not confirmed.

9094-W-MAT-074 Wipe 38.2 ug/ft2

Pre-water wipe

Sample ID Matrix Detected Result Comment

9094-W-MAT-065 Wipe ND < 4.65 ug/ft2

9094-W-MAT-066 Wipe 20 ug/ft2 Estimated concentration (J).

Mineral: alpha-Quartz

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-023 Air ND < 0.004 mg/m3

9094-A-MAT-024 Air ND < 0.004 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-042 Air ND < 0.004 mg/m3

9094-A-MAT-043 Air ND < 0.004 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-056 Air ND < 0.004 mg/m3

9094-A-MAT-057 Air ND < 0.004 mg/m3

Mineral: Calcite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-023 Air ND < 0.016 mg/m3

9094-A-MAT-024 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-042 Air ND < 0.016 mg/m3

9094-A-MAT-043 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-056 Air ND < 0.017 mg/m3

9094-A-MAT-057 Air ND < 0.017 mg/m3
Page 8 of 11

Mattress Shop Results

Mineral: Cristobalite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-023 Air ND < 0.016 mg/m3

9094-A-MAT-024 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-042 Air ND < 0.016 mg/m3

9094-A-MAT-043 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-056 Air ND < 0.017 mg/m3

9094-A-MAT-057 Air ND < 0.017 mg/m3

Mineral: Tridymite

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-023 Air ND < 0.016 mg/m3

9094-A-MAT-024 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-042 Air ND < 0.016 mg/m3

9094-A-MAT-043 Air ND < 0.016 mg/m3

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-056 Air ND < 0.017 mg/m3

9094-A-MAT-057 Air ND < 0.017 mg/m3
Page 9 of 11

Mattress Shop Results

MMVF

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-MAT-012 Air 11.716 S/L

9094-A-MAT-013 Air 92.184 S/L

9094-A-MAT-014 Air 3.766 S/L

9094-A-MAT-015 Air 4.159 S/L

9094-W-MAT-002 Wipe 1201.86 S/cm2

9094-W-MAT-003 Wipe 23710.15 S/cm2

9094-W-MAT-004 Wipe 572.31 S/cm2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-A-MAT-018 Air 3.19 S/L

9094-A-MAT-019 Air 2.834 S/L

9094-A-MAT-020 Air 3.802 S/L

9094-W-MAT-026 Wipe 114.46 S/cm2

9094-W-MAT-027 Wipe ND < 57.23 S/cm2

9094-W-MAT-028 Wipe 228.93 S/cm2

9094-W-MAT-029 Wipe 686.78 S/cm2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-A-MAT-037 Air 1.457 S/L

9094-A-MAT-038 Air 6.206 S/L

9094-A-MAT-039 Air 1.753 S/L

9094-W-MAT-045 Wipe ND < 57.23 S/cm2

9094-W-MAT-046 Wipe 171.69 S/cm2

9094-W-MAT-047 Wipe 286.16 S/cm2

9094-W-MAT-048 Wipe 286.16 S/cm2
Page 10 of 11

Mattress Shop Results

Post 1st cleaning - Test 4C

Sample ID Matrix Detected Result Comment

9094-A-MAT-049 Air 4.723 S/L

9094-A-MAT-050 Air 1.051 S/L

9094-A-MAT-051 Air 1.203 S/L

9094-A-MAT-052 Air 2.127 S/L

9094-A-MAT-053 Air 2.092 S/L

Post 1st cleaning - Test 4D

Sample ID Matrix Detected Result Comment

9094-A-MAT-067 Air ND < 0.067 S/L

9094-A-MAT-068 Air ND < 0.069 S/L

9094-A-MAT-071 Air ND < 0.047 S/L

PAH TEF (ND=1/2)

Before cleaning

Sample ID Matrix Detected Result Comment

9094-A-MAT-016 Air U 2.7 μg/m3

9094-W-MAT-002 Wipe U 290 ug/m2

9094-W-MAT-003 Wipe 290 ug/m2

9094-W-MAT-004 Wipe 290 ug/m2

Post 1st cleaning - Test 4A

Sample ID Matrix Detected Result Comment

9094-W-MAT-026 Wipe U 290 ug/m2

9094-W-MAT-027 Wipe U 290 ug/m2

9094-W-MAT-028 Wipe U 290 ug/m2

9094-W-MAT-029 Wipe U 290 ug/m2

Post 1st cleaning - Test 4B

Sample ID Matrix Detected Result Comment

9094-W-MAT-045 Wipe U 290 ug/m2

9094-W-MAT-046 Wipe U 290 ug/m2

9094-W-MAT-047 Wipe U 290 ug/m2

9094-W-MAT-048 Wipe U 290 ug/m2
Page 11 of 11

Mattress Shop Results

Post 1st cleaning - Test 4E

Sample ID Matrix Detected Result Comment

9094-W-MAT-072 Wipe U 290 ug/m2

9094-W-MAT-073 Wipe U 290 ug/m2

Pre-water wipe

Sample ID Matrix Detected Result Comment

9094-W-MAT-065 Wipe U 290 ug/m2

9094-W-MAT-066 Wipe U 290 ug/m2
Attachment K 

Summary of Mercury Vapor Results Using the Lumex Vapor Analyzer 
Summary of Mercury Vapor Results 

Using the Lumex® Vapor Analyzer

1

This information was provided by Dr. Clyde Johnson, Assistant Professor of Environmental Sciences at 

Medgar Evers College (City University of New York). 

Statistics for Combined Data 

WTC Residential Confirmation Cleaning Study1

Statistic Value 

N 163

Mean 53.6

Std 39.1

Skew 1.3

cv 0.73

var 1525

stderr 3.1

max 210

P99 180

P95 130

P90 107

Q3 74

median 46

Q1 22

P5 11

min 3

S-Wa 0.90

P_S-Wb 2.64E-09

a

Shapiro-Wilk test statistic for normality 

b

Probability that the data come from a normal 

 distribution 
Summary of Mercury Vapor Results 

Using the Lumex® Vapor Analyzer

1This information was provided by Dr. Clyde Johnson, Assistant Professor of Environmental Sciences at Medgar Evers College (City University of New York). 

WTC Residential Confirmation Cleaning Study – Statistics by Area Type 

Area n mean std skew cv var 

err 

Std max P99 P95 P90 Q3 Med ian Q1 P5 min S-Wa P_S-Wb 

Apt 2A 16 79.7 15.9 -1.42 0.20 252.8 4.0 102 102 102 99 89 80 72.5 34 34 0.89 0.05 Apt 2B 11 49.5 6.6 0.81 0.13 43.7 2.0 62 62 62 59 55 47 45 42 42 0.91 0.25 Apt 3C 13 33.5 14.6 0.88 0.44 213.4 4.1 67 67 67 49 42 35 22 15 15 0.93 0.31 Apt 3D 10 22.8 13.9 1.35 0.61 193.5 4.4 50 50 50 47.5 27 17 14 10 10 0.80 0.02 Apt 4A 20 70.1 41.9 2.35 0.60 1753.9 9.4 210 210 177 125.5 69.5 59.5 52 28.5 15 0.72 < 0.00 Apt 4B 11 34.8 25.7 2.97 0.74 661.6 7.8 110 110 110 40 34 27 21 20 20 0.57 < 0.00 Apt 4C 11 25.9 14.8 1.35 0.57 218.1 4.5 60 60 60 41 34 20 15 11 11 0.87 0.08 Apt 4D 10 24.4 8.2 -0.02 0.34 67.4 2.6 35 35 35 34.5 30 26 16 15 15 0.85 0.05 Apt 5A 12 64.6 20.0 1.00 0.31 401.2 5.8 104 104 104 98 75.5 58.5 49.5 40 40 0.89 0.12 Apt 5C 10 32.3 41.6 3.08 1.29 1733.3 13.2 150 150 150 88 23 20.5 19 11 11 0.47 < 0.00 Apt 5D 7 19.9 38.0 2.64 1.91 1445.1 14.4 106 106 106 106 7 6 4 3 3 0.49 < 0.00 Office 1800 Mattress 7 53.0 10.3 -0.01 0.19 106.3 3.9 69 69 69 69 59 53 46 37 37 0.99 > 0.99 Office Chiropractor 15 114.9 27.5 0.59 0.24 756.8 7.1 179 179 179 144 130 114 91 77 77 0.95 0.58 AreasCommon 

c 8 66.4 66.1 1.15 1.00 4371.4 23.4 180 180 180 180 113.5 36 24 4 4 0.82 0.04 

Outdoor 2 35.0 29.7 . 0.85 882.0 21.0 56 56 56 56 56 35 14 14 14 . . aShapiro-Wilk test statistic for normalitybProbability that the data come from a normal distribution 

Common Areas: lobbies, hallways, trash compactor room c
WTC Residential Confirmation Cleaning Study 

Summary of Mercury Vapor Results Using the Lumex® Vapor Analyzer 

1This information was provided by Dr. Clyde Johnson, Assistant Professor of Environmental Sciences at Medgar Evers College (City University of New York). 

Legend

Abbreviation Description Sample Size 

2# Apartment Number 7 - 20 

O 1800 Mattress Office 7 

CA CO Chiropractor Office 15 

lobbies) Common Areas (hallways, 8 

OD Outdoor 2 

Note: The figure shows ‘box and wisker’ plots for each room type. The box represent the 25the median; the bottom and top of the horizontal bars within the box represent mean mercury vapor reading; the plus signs (+) in the ‘box’ represent the 

th and 75th percentiles 

bottom and top wiskers represent the 5(or Q1 and Q3), respectively; and the 

th

and 95th percentiles (P5 and P95), 

respectively. 
Attachment L 

Photo Documentation
WTC Residential

Confirmation Cleaning

Study

110 Liberty St.

New York, NY
Lemongrass Grill

Dsc00042

Pre-Cleaning Conditions

Lemongrass Grill

080102-002

Vacuuming Dust
Lemongrass Grill

092702-001

Post-Cleaning Sampling

Lemongrass Grill

082102-006

Post-Cleaning Sampling
The Food Exchange

081502-D2-011

Pre-Cleaning Conditions

The Food Exchange

081602-006

Vacuuming Dust
The Food Exchange

092402-005

Post-Cleaning Sampling

The Food Exchange

092402-004

Post-Cleaning Sampling
Barber Shop

090902-018

Pre-Cleaning Conditions

Barber Shop

091702-006

Vacuuming Dust
Barber Shop

092502-008

Post-Cleaning Sampling

Barber Shop

100302-002

Post-Cleaning Sampling
Chiropractor’s Office

062102-D1-011

Pre-Cleaning Conditions

Chiropractor’s Office

072402-011

Vacuuming Dust
Chiropractor’s Office

080202-011

Post-Cleaning Sampling

Chiropractor’s Office

100102-001

Post-Cleaning Sampling
Mattress Store

062102-D1-027

Pre-Cleaning Conditions

Mattress Store

071802-009

Vacuuming Dust
Mattress Store

100102-005

“Water Only” Washing of Floor

Mattress Store

100202-003

Post-Cleaning Sampling
Unit 2A

062102-D1-006

Pre-Cleaning Conditions

Unit 2A

071602-001

Wet Wiping Dust
Unit 2A

072202-005

Post-Cleaning Sampling

Unit 2A

091802-003

Post-Cleaning Sampling
Unit 2B

062102-D2-011

Pre-Cleaning Conditions

Unit 2B

062802-006

Pre-Cleaning Conditions
Unit 2B

070102-002

Post-Cleaning Sampling

Unit 2B

081402-015

Cleaned Unit
Unit 3A

Dsc00261

Pre-Cleaning Conditions

Unit 3A

071802-002

Vacuuming Dust
Unit 3A

072302-004

Post-Cleaning Sampling
Unit 3B

Dsc00230

Pre-Cleaning Conditions

Unit 3B

072502-010

Vacuuming and Wet Wiping Dust from Personal Items
Unit 3B

Dsc00025

Post-Cleaning Sampling

Unit 3B

091702-019

Cleaned Unit
Unit 3C

Dsc00321

Pre-Cleaning Conditions

Unit 3C

071102-018

Vacuuming Dust
Unit 3C

071302-D1-003

Post-Cleaning Sampling

Unit 3C

091202-003

3

rd Cleaning – Vacuuming Dust
Unit 3D

Dsc00366

Pre-Cleaning Conditions

Unit 3D

071102-010

Vacuuming Dust
Unit 3D

072402-032

Post-Cleaning Sampling

Unit 3D

091302-004

Post-Cleaning Sampling
Unit 4A

061902-Dsc00017

Pre-Cleaning Conditions

Unit 4A

071902-003

Vacuuming Dust
Unit 4A

072502-017

Post-Cleaning Sampling

Unit 4A

091002-002

Post-Cleaning Sampling
Unit 4B

061902-Dsc00109

Pre-Cleaning Conditions

Unit 4B

070902-007

Vacuuming Dust
Unit 4B

071202-013

Post-Cleaning Sampling

Unit 4B

081202-011

Completed Unit
Unit 4C

061902-Dsc00189

Pre-Cleaning Conditions

Unit 4C

070802-001

Wet Wiping Dust
Unit 4C

Dsc0038

Post-Cleaning Sampling

Unit 4C

072402-009

Completed Unit
Unit 4D

061902-Dsc00149

Pre-Cleaning Conditions

Unit 4D

070102-004

Vacuuming Dust from Personal Belongings
Unit 4D

082002-016

Post-Cleaning Sampling

Unit 4D

081302-005

2

nd Cleaning – Washing Floor
Unit 5A

061802-D2-030

Pre-Cleaning Conditions

Unit 5A

071002-012

Vacuuming Dust
Unit 5A

071102-010

Post-Cleaning Sampling

Unit 5A

081202-014

Completed Unit
Unit 5C

061802-D1-020

Pre-Cleaning Conditions

Unit 5C

062802-009

Vacuuming Dust
Unit 5C

080902-002

Post-Cleaning Sampling

Unit 5C

092002-001

3

rd Post-Sampling
Unit 5D

061802-D2-021

Pre-Cleaning Conditions

Unit 5D

062602-019

Vacuuming Dust
Unit 5D

062902-003

Post-Cleaning Sampling

Unit 5D

062802-002

Completed Unit
Common Areas

092502-S.stairs-003

Wet Wiping Dust

Common Areas

092602-S.stairs2fl-007

Post-Cleaning Sampling