The conclusions and opinions in this memorandum are those of the author and do not
necessarily reflect those of the U.S. Environmental Protection Agency.
DATE: August 29, 2002
SUBJECT: Stuyvesant High School Testing
– EPA validates use of sonication testing
– Brookfield CT school system using sonication
FROM: Cate Jenkins, Ph.D.
Waste Identification Branch (Mail Code 5304 W)
Hazardous Waste Identification Division
TO: Joel Kupferman
New York Environmental Law and Justice Project
Other Concerned Parties and Responsible Officials
As per my communications with you and several of the parents, I have prepared this
memorandum validating both the use of and results from ultrasonication testing of carpets and
other woven fabrics. It appears that officials responsible for the Stuyvesant High School clean up
are trying to back away from proper testing after finding high asbestos levels with EPA’s
ultrasonication test.
EPA validates and relies on ultrasonication test results as way of showing
hazards of ANY fabric contaminated by asbestos, and recommends
considering their replacement
EPA recently stated that results from the EPA ultrasonication method show high levels of
asbestos in carpet even after HEPA vacuuming and wet extraction cleaning. EPA further states
that there is a potential problem with all asbestos contaminated fabric including upholstered
furniture and curtains as well as carpet, based on ultrasonication tests.
In its fact sheet on all fabrics contaminated with asbestos after the World Trade Center collapse,
EPA discusses two EPA studies which evaluated the effectiveness of cleaning asbestos
contaminated carpet. These two EPA studies used ultrasonication testing, not any microvacuum
test method, to determine asbestos levels before and after cleaning. (Note that on December 9,
1. Press showing Brookfield School System superior cleanup compared to aftermath of WTC
2. Email interchange with Stuyvesant and Howard Bader, IH
3. EPA Ultrasonication method for carpet
- 2 -
2001, I widely distributed a memorandum discussing these same two EPA studies that showed
that neither HEPA vacuuming alone, nor HEPA vacuuming in conjunction with wet extraction,
could effectively remove asbestos from carpets, and reiterated this data in subsequent
Therefore, it is established that EPA is basing its conclusions as to the asbestos hazard from
contaminated carpet and other woven fabrics, and the difficulty in removing asbestos from same,
on ultrasonication test results, not the ASTM microvacuum test results.
Thus, any parties, such as the New York City Board of Education, making decisions for the
asbestos testing and cleanup of the Stuyvesant High School auditorium, would be in opposition
to the position taken by EPA if they claim that results from ultrasonication testing of carpets and
upholstered seats are irrelevant.
The web page fact sheet posted by EPA on its website on August 16, 2002 at
http://www.epa.gov/wtc/factsheets/fabrics.html states the following:
There are two key studies, which were conducted for EPA, which examined the
effectiveness of various cleaning methods on carpets impacted by asbestos. The first,
Evaluation of Two Cleaning Methods for Removal of Asbestos Fibers from Carpet (1),
found that cleaning asbestos- contaminated carpets with a hot-water extraction cleaner
was most effective, reducing asbestos levels by approximately 70%. The second study,
Evaluation of Three Cleaning Methods for Removing Asbestos from Carpet:
Determination of Airborne Asbestos Concentrations Associated with Each Method (2),
again found that a hot-water extraction cleaner was most effective, producing a 60%
reduction in asbestos levels in contaminated carpets. [Both studies used EPA’s
ultrasonication test method to establish the 70 and 60% levels.]
The first study spread asbestos on carpeting and used a steel roller to embed the
asbestos in the carpet; the second study used carpet from an asbestos-contaminated
office building in which the asbestos had been embedded in the carpet by normal foot
traffic. Note that if your carpeting was cleaned prior to reoccupancy, the dust and
whatever asbestos it may have carried had not been embedded in the carpet and the
cleaning may therefore have been more effective (meaning a greater reduction in
asbestos levels).
However, because of the results of these studies, EPA cannot guarantee to residents that
all asbestos fibers, if present, can be removed from fabric items. EPA anticipates that
available cleaning methods for fabric items that were significantly impacted by dust or
debris may not be sufficient to address the concerns of residents or EPA' s concern for
people's long-term health.
With this information in mind, EPA recommends that residents consider replacing some
or all carpets, upholstered furniture or draperies if their home was impacted by WTC dust
or debris.
If a resident decides to discard fabric materials, EPA will remove and dispose of them as
part of the cleaning program, and will provide residents with contacts at the American Red
Cross (ARC) or other service agencies that may be able to provide reimbursement
[Note that EPA is replacing all carpeting and upholstered furniture at government expense
i n residents at the Libby, Montana Superfund site. This disparity in treatment of NYC
residences is egregious.]
- 3 -
Brookfield, CT township using ultrasonication extraction for both carpets and
seat cushions in asbestos contaminated high school auditorium
The Brookfield CT school system is undergoing asbestos abatement over the summer months
after the confirmation of extensive asbestos contamination in several schools. The following
table shows “before” and “after” data for asbestos in carpet, seat cushions, and curtains in the
Brookfield high school auditorium.
Attached to the end of this memorandum is a news article
showing pictures and describing in detail the extensive cleaning efforts that were undertaken. As
seen from the following table, the cleaning was not effective in removing the asbestos.
all results in units of asbestos structures per square centimeter (s/cm
Seat Cushions - Before and after sampling points are not necessarily for the same seats.
Before abatement
ASTM microvacuum method.
After HEPA vacuuming, steam extraction
EPA ultrasonication test method
less than 267 12,835
535 6,417
1,070 23,179
3,210 42,159
1,605 35,861
535 58,989
less than 535 32,260
1,070 16,215
less than 3,243
Carpet - Bef ore and after sampling points are not necessarily for the exact same areas of the carpet.
Before abatement
ASTM microvacuum method.
After HEPA vacuuming, steam extraction
EPA ultrasonication test method
less than 535 115,521
535 405,383
2,675 51,616
less than 891
less than 535
As can be seen, the ASTM microvacuum testing for the Brookfield auditorium before cleaning
was unable to detect the elevated levels of asbestos. Obviously, the carpet and seat cushions
would be more contaminated before cleaning than after. But the ASTM microvacuum results
were LOWER than the ultrasonication results after cleaning.
- 4 -
Stuyvesant High School carpet and seat cushion testing
Stuyvesant High School was contaminated with asbestos from the fallout from the World Trade
Centers. The auditorium carpet was cleaned with HEPA vacuuming and some type of wet
extraction method. After cleaning the carpet was tested with the superior EPA sonication
method. It was found to contain from 60,000 to 2,500,000 structures asbestos per square
centimeter, which is unacceptably high.
Stuyvesant appears to be avoiding additional testing using ultrasonication methods based in part
on the advice of Mr. Howard Bader, the consultant hired by the Parent Teachers Association.
Reportedly, Mr. Bader is claiming that EPA’s ultrasonication method is “new” and that it is only
a “research method” and that it is “impossible to relate the results of ultrasonication [as opposed
to ASTM microvacuum results] to hazards.”
Mr. Bader is incorrect. The EPA method, even if newer, would take precedent over any ASTM
method, since it is an official EPA method which underwent all the necessary impartial
government review prior to its promulgation. Furthermore, the EPA ultrasonication method was
published in final form in 1993, two years earlier than the 1995 ASTM microvacuum method, so
it is not in any way “new.” Furthermore, the EPA method is hardly a research method; it is
offered by over 12 major asbestos laboratories, in some cases at prices lower than the ASTM
microvacuum method!
As far as the claim of not being able to relate the results to possible hazards, Mr. Bader is again
wrong. As seen from the beginning of this memorandum, EPA has interpreted the results from
ultrasonication studies of carpets to be a reliable indicator of the fact that neither HEPA
vacuuming nor wet extraction processes will remove embedded asbestos, and that after the WTC
collapse citizens should consider disposing of carpet and other fabric items.
Mr. Bader has been incorrect in his understanding of ultrasonication extraction before. On May
17, 2002, Mr. Bader sent me an email claiming that EMSL Laboratories could only perform 10
ultrasonication extraction tests a day, and this was the reason that EMSL would not be able to
perform ultrasonication tests of carpet for EPA during the free testing of residences in
Manhattan. I suspected that this information was incorrect, and contacted EMSL laboratories
myself. EMSL informed me that it would be using other laboratory locations for the EPA testing
and therefore was not limited to only 10 ultrasonication tests per day.
Interestingly, Mr. Bader stated in his email that he did not have the necessary expertise to
comment on whether higher volume air sampling should be used to test residences in Manhattan.
EPA will be performing this more sensitive air testing, because the AHERA air clearance test
cannot detect the very low asbestos levels of concern because too small a volume of air is
pumped. It is like trying to find a needle in a haystack by only testing one handful of hay.
Obviously, Mr. Bader is not as familiar with testing as other aspects of evaluating cleanup
requirements after the WTC collapse.
A copy of this email interchange between Mr. Bader, EMSL laboratories, and myself is attached.
The “seat beating” air testing that was done at the Stuyvesant auditorium is highly suspicious.
- 5 -
1. Rhode, Vernon (August 27, 2002) Personal communication. S & B Environmental, LLC, 40
Valley Field Road S., Sandy Hook, CT 06482. S & B Environmental was contracted by the
Brookfield, CT town Selectmen to independently monitory the abatement progress in the
Brookfield school system. Note that the 8/27/02 tables from S&B Environmental had a
typographical error in the units, showing asbestos concentrations as “structures per square mm"
instead of the correct units: “structures per square cm".
Behind closed doors, with no independent observers, the seat cushions in the Stuyvesant
auditorium were reportedly “beaten” while the air was tested for asbestos. No asbestos in the air
was found.
It defies all credibility that no asbestos would be found in the air after beating the seat cushions!
Perhaps the monitors were not held within 2 feet of the cushions while they were being beaten,
the breathing zone of a person who would sit in the chair. Or, the beating could have taken place
long before any air testing, or only immediately prior to air testing. Probably, too few seats were
beaten, even if the beating took place during the entire testing period. The air testing might not
have been at the high sensitivity levels planned in EPA’s testing for Manhattan (much higher
sensitivity than 2 s/mm2). Or, the operator of the air testing device might not have turned on the
air pump or closed the portal to the air collection device. We do not know.
The seat cushions should be tested using EPA’s ultrasonication method, as was done for the
Brookfield School System. Sufficient numbers of seats should be tested to insure some degree of
statistical significance. Curtains and other woven fabrics throughout the school should also be
testing using sonication. To allay any doubts and protect the children, all these items should be
The News-Times: Local More than a dusting
The News-Times
Mo r e t h a n a d u s t in g
Br o o k fie ld a s b e s t o s r e m o v a l is p a in s t a k in g
By Heather Barr

The News-Times/Wendy Carlson
Asbestos removal cleaners vacuum up and wipe
down equipment in the computer room at
Brookfield High School.

The News-Times/Wendy Carlson
Clean air is filtered out of the chemistry rooms
from a tube connected to a machine called a
microtrap, which collects the air and sends it
through its filters to remove asbestos particles.
As t e mpe ra t ure s s oa re d int o t he 90s on a re ce nt
we e kda y, worke rs we a ring prot e ct ive fa bric s uit s a nd
re s pira t ors va cuume d a nd t he n wipe d down a s e t of
blinds in a ba t hroom a t Brookfie ld High School. The a ir
wa s a s hot a nd he a vy a s in a s a una be ca us e no a ir
condit ioning or fa ns a re a llowe d. Ea ch s e t of blinds t a ke s
up t o a n hour t o cle a n.
Such a t t e nt ion t o de t a il is re quire d whe n re moving
a s be s t os fibe rs . Tha t is why cre ws ha ve be e n working
24- hours a da y t o cle a n a ll four s chools in Brookfie ld s o
t he y ca n ope n by Aug. 27. Da y worke rs a re bus e d from
Ne w Je rs e y e ve ry da y, a nd s ome s upe rvis ors a nd
proje ct ma na ge rs ha ve be e n living a t t he s chools .
Supe rvis or a nd fore ma n Ma rvin Aguila r’s home for t he
la s t mont h ha s be e n t he high s chool. He t a pe d t oge t he r
t wo cot s in a s chool office a nd us e d t he m a s a pla t form
for a n infla t a ble ma t t re s s .
On one wa ll he t a pe d pict ure s a nd le t t e rs from his
fa mily, which drive s from Ne w Je rs e y on we e ke nds t o
vis it him. On a not he r wa ll is a pos t e r s howing t he ins ide
of t he huma n body, a re minde r t ha t his t e mpora ry home
will re ve rt t o a nurs e ’s office whe n s chool be gins .
Aguila r s a id it is ha rd t o be a wa y from his fa mily, but he
a dde d t he job of cle a ning a s be s t os from t he s chools is
import a nt t o him.
"Ima gine your child e xpos e d t o s ome t hing like t his , ” he
s a id.
"The re is no t ool, no ma chine or no mira cle , ” s a id
http://www.newstimes.com/cgi-bin/dbs.cgi?db=news&view_records=1&id=33793&Print_Story=1&ssi=1 (1 of 5) [8/13/02 1:33:16 PM]
The News-Times: Local More than a dusting

The News-Times/Wendy Carlson
George Stokes III, the senior project manager,
stacks up some of the cleaned items that have
been put in storage and surrounded by plastic.

Erin Kiernan
Workers steam clean seats in the auditorium.
Later, cloth samples are removed to insure
asbestos does not exist.
Ge orge St oke s III, s e nior proje ct ma na ge r of PT&L
Cont ra ct ing Corp.
"The only wa y t o cle a n t op t o bot t om is 100 pe rce nt
pure la bor. ”
The t ools of a n a s be s t os cle a ne r a re bot h s pe cia lize d
a nd munda ne .
Ea ch worke r, who is ce rt ifie d t o do a s be s t os cle a n- up,
we a rs a full s uit of Tyve k, ma t e ria l t ha t ke e ps out dirt
a nd dus t while a llowing body he a t t o e s ca pe . Some a ls o
we a r glove s , Tyve k boot ie s ove r t he ir s hoe s , Tyve k ha ir
cove ring a nd re s pira t ors t ha t cove r t he mout h a nd nos e .
Aft e r s e a ling a room, a worke r goe s t hrough wit h a le a f
blowe r, a iming je t s of a ir a t t he floors a nd wa lls . The
obje ct is t o ma ke a ny a s be s t os a irborne s o it ca n be
s ucke d int o a "microt ra p, ” a t hre e foot s qua re box wit h
t hre e filt e rs .
Cle a n a ir is ve nt e d out s ide t he building.
Aft e r t he le a f blowe r ma ke s a ll dus t a irborne , worke rs
go ove r e ve ry s urfa ce wit h a s pe cia lize d va cuum cle a ne r
t ha t a ls o ha s t hre e filt e rs .
St oke s s a id a He pa va cuum will t ra p 99. 97 pe rce nt of
t he a s be s t os it picks up.
Fina lly, a ft e r t he va cuuming, e ve ry s urfa ce or obje ct is
wipe d up t o four t ime s wit h four diffe re nt clot hs .
Room ra dia t ors a re cle a ne d us ing t he s a me proce s s , but
t he ra dia t ors , whe re much of t he a s be s t os s e e me d t o
ga t he r, a re s e a le d off from t he room wit h a pla s t ic
bubble a round t he m.
The a ir in t he bubble is t he n s a mple d be fore t he pla s t ic
is t a ke n down.
Mos t of t he worke rs a re origina lly from Sout h or Ce nt ra l
Ame rica . Ma rvin Aguila r, a ge ne ra l fore ma n, wa lks
a round t he high s chool wit h a ra dio ins t ruct ing worke rs
in Spa nis h. Supe rvis ors who do not s pe a k Spa nis h us e
re d la s e rs t o point out t o worke rs which s it e s ne e d t o be
cle a ne d.
http://www.newstimes.com/cgi-bin/dbs.cgi?db=news&view_records=1&id=33793&Print_Story=1&ssi=1 (2 of 5) [8/13/02 1:33:16 PM]
The News-Times: Local More than a dusting

Erin Kiernan
The cleaned sections are covered in plastic until
removal is complete.
Vis it ors occa s iona lly a rrive for t ours . U. S. Re p. Na ncy
Johns on, R- 6t h Dis t . , wa lke d t hrough t he building during
t he la s t we e k of July.
Be fore a room is cle a ne d, worke rs re move a ll t he
obje ct s ins ide , from de s ks t o cra yons . The y a re cle a ne d
in holding a re a s t ha t a re s e a le d from t he re s t of t he
In t he high s chool’s ce ra mics room, s t ude nt s s t ill ha d
it e ms in t he kiln whe n s chool wa s clos e d e a rly for t he
ye a r. Ea ch obje ct ha d t o be re move d ca re fully a nd
cle a ne d.
"Whe n we cle a ne d we pa id a t t e nt ion t o s t ude nt s ’ proje ct s t o ma ke s ure t he y we re not da ma ge d
or de s t roye d. We know a lot of s t ude nt s s pe nt t ime on a proje ct . We a re s ympa t he t ic t o t he ir
ne e ds , ” s a id St oke s .
"Be s ide s ra dia t ors , la bora t orie s ( che mis t ry or biology rooms ) we re difficult t o cle a n be ca us e of
che mica ls a nd it e ms in dra we rs , ” s a id worke r Ma rco Sa lga do. "You ha d t o move t hings one by
one . ”
Eve ry it e m in a cont a mina t e d a re a mus t be cle a ne d, including light fixt ure s , t he ins ide s of e xit
s igns , locke rs , a nd t he like .
Cle a ning a comput e r t a ke s up t o 90 minut e s . All comput e r mous e s a nd ke yboa rds we re t hrown
out , a long wit h a bout 25 comput e rs de e me d t o be s o old t he y we re not wort h cle a ning.
A t ot a l of a bout 190 comput e rs we re cle a ne d a nd wra ppe d in pla s t ic t o a wa it a n a ir s a mpling of
t he room in which t he y we re s a nit ize d.
The dus t colle ct e d in t he va cuums , filt e rs a nd ra gs is ba gge d, la be le d a s da nge rous , a nd t a ke n t o
a la ndfill t ha t a cce pt s a s be s t os .
A t ra ile r out s ide t he s chool ha s a s howe r a nd a n a re a for t he worke rs t o cle a n up be fore going
home if t he y wis h.
High le ve ls of a s be s t os we re found in Huckle be rry Hill School in Ma y a ft e r mus ic t e a che r
Ma rga re t Fit zge ra ld, a ct ing on he r own conce rns , hire d a compa ny t o t e s t he r room. Furt he r
t e s t ing by t he dis t rict found t ha t a ll four s chools we re cont a mina t e d.
St ude nt s we re t ra ns port e d t o ot he r s chools in t he re gion t o for s e ve ra l da ys a t t he e nd of t he
ye a r. The t own a ut horize d $900, 000 t owa rd a cle a n- up, a nd s t a t e officia ls a pprove d us e of a
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The News-Times: Local More than a dusting
dis a s t e r re lie f s t a t ut e t ha t a llowe d t he t own t o is s ue s hort - t e rm bonds for a not he r $3. 2 million.
An Aug. 27 re fe re ndum is s che dule d for re s ide nt s t o vot e on whe t he r t o pa y t o cove r t he not e s .
Infinit y Environme nt a l Se rvice s of Ne w York wa s hire d t o cle a n Huckle be rry Hill a nd Whis conie r
Middle s chools a nd PT&L Cont ra ct ing Corp. of Ne w Je rs e y wa s cont ra ct e d t o cle a n Ce nt e r School
a nd t he high s chool. Work be ga n in e a rly July.
A la rge pie ce of a s be s t os ha ngs from a re t urn a ir int a ke duct a t Brookfie ld High, looking like five
or s ix gra y cot t on- ba lls s t uck t oge t he r. St oke s t ook a phot o of it be fore a s ma ll robot on a t e t he r
we nt t hrough t he duct s we e ping up a ll dus t . The la rge r duct s we re cle a ne d by worke rs who
cra wle d t hrough t he m.
Not e ve ry inch of e a ch s chool ha d t o be cle a ne d s o vigorous ly.
About 11 rooms in Huckle be rry Hill School, 45 rooms in Whis conie r Middle School, 12 rooms in
Ce nt e r School a nd 70 rooms in Brookfie ld High School we re comple t e ly cle a ne d.
Cle a ning s t a rt e d a ft e r a ll rooms a nd a re a s we re t e s t e d for a s be s t os . A color- code d ma p wa s
pre pa re d of t he ins ide of e a ch s chool t o guide worke rs .
To s e pa ra t e non- cont a mina t e d rooms from cont a mina t e d a re a s , la rge bla nke t s of pla s t ic we re
a t t a che d t o doorwa ys t hroughout t he building. Signs wa rning "As be s t os : Ca nce r a nd Lung
Dis e a s e Ha za rd, ” we re pos t e d t hroughout e a ch s chool.
In s ome rooms , t he s pe cia lis t s cle a ne d only t he ra dia t ors a nd a ir duct s , a nd ja nit ors cle a ne d t he
re s t .
Some ca rpe t s we re re move d, but t he re s t we re s t e a m- cle a ne d. Cont ra ct ors we re a ble t o s a ve
hundre ds of cus hione d cha irs by s t e a m- cle a ning t he m.
As be s t os le ve ls a re rule d s a fe only a ft e r e a ch s chool ge t s a fina l t e s t of a ir t ha t is circula t e d wit h
blowe rs .
And t he n Aguila r, t he s upe rvis or a nd fa t he r of four, will be a ble t o pa ck up his phot os a nd le t t e rs
a nd fina lly s le e p in his own be d a ga in.
"I mis s my fa mily, ” he s a id.
Cont a ct He a t he r Ba rr
a t hba rr@ne ws t ime s . com
or a t ( 203) 731- 3331.
http://www.newstimes.com/cgi-bin/dbs.cgi?db=news&view_records=1&id=33793&Print_Story=1&ssi=1 (4 of 5) [8/13/02 1:33:16 PM]
Cate Jenkins
05/20/02 01:47 PM
To: amy.rutkin@mail.house.gov, envjoel@ix.netcom.com,
ihconsult@msn.com, jan1006@comcast.net,
actsnyc@cs.com, paulwoodsbartlett@hotmail.com,
mclarke@shiva.hunter.cuny.edu, flynnktm@aol.com,
lisette.morton@mail.house.gov, dave@nycosh.org,
Subject: Howard Bader's misrepresentation of EMSL's capacity
to do carpet sonication tests under EPA cleanup
contract, and concurrence with my comments on other
As per the below interchange between Howard Bader,
he director of EMSL Laboratories, and myself,
it is apparent that EMSL Laboratories does
have the capacity to perform sonication extraction tests
of carpet samples for residents under the EPA downtown
cleanup contract.
Howard Bader's email to me claiming that EMSL did not
have the resources to do this was erroneous.
The following from Robert DeMalo from EMSL Laboratories makes it
clear that EMSL can perform these inexpensive tests,
even though they are labor intensive. Each sonication extraction
of carpets would only cost $200 on the open
market, substantially less if under a large contract with
the additional cost savings.
Sonication extractions of carpet are important. They will show
over 100 times the amount of asbestos that a microvacuum
sample will show.
Carpets are resevoirs of asbestos, and
cannot be cleaned effectively even with HEPA wet extraction
procedures. Typical professional asbestos abatement
procedures simply dispose of asbestos contaminated carpet.
That is what they are doing in Libby, Montana.
Howard Bader does concur with me on the other aspects of my
comments on EPA's draft scope of work and testing, however.
"DeMalo, Robert" <RDemalo@EMSL.com>
05/20/02 11:04 AM
To: Cate Jenkins /DC/USEPA/US@EPA
RE: Howard Bader's quotation of Robert DeMalo
- - - - - - - - - - - - - - - - - - - - - - -
Dear Ms. Jenkins,
EMSL is currently under contract for both the outdoor
and residential sampling events with the USEPA.
Presently, we utilize our Manhattan branch
for the ground zero samples and our Long
Island branch for the landfill samples.
The phase 2 of the residential work has not
been clearly defined.I was told testing will
be made available to approximately 15,000 residences
through a hotline. Furthermore, an upper limit
of 75,000 samples was estimated.

The ability for EMSL to handle this amount of
samples will depend on at what rate the
samples are submitted to the laboratory and what
turnaround time is expected. I do not have
this information at this time.
I can tell you that EMSL plans on utilizing,
at a minimum, our 6 regional labs that are
the closest proximity to NYC: Manhattan, Long
Island, Elmsford, Piscataway, Buffalo and
Westmont, NJ (Corporate office & Lab). If
the sample influx exceeds these 6 labs, then
I will consider utilizing our other 15 nationwide
labs. The carpet sonication method is labor intensive,
especially on the preparation steps.
I did quote Howard Bader 10 samples
per day, however this was only for
our Manhattan lab. Until I can get a
project schedule, I cannot predict what
laboratory capacity will be. I hope
this information is helpful.
Thank you,
Robert De Malo
-----Original Message-----
From: Jenkins.Cate@epamail.epa.gov
Sent: Monday, May 20, 2002 10:11 AM
To: rdemalo@emsl.com
Subject: Howard Bader's quotation of Robert DeMalo
- - - - - - - - - - - - - - - - - - - - - - -
I just left you a voice mail message. The attached
is an email from Howard Bader, who contacted you
regarding the EPA contract. I was wondering if
he was quoting you accurately.
As I stated in my voice mail message, I have no
official duties related to the EPA contract.
However, in l discussions with concerned
citizens, I was suggesting offering them the
option of having sonication extraction tests
performed on their carpet. I had not previously
contacted your laboratory regarding sonication
extractions under the EPA contract, or intend
to in the future. I had called you earlier
asking whether your lab could perform these
services on behalf of private parties who
were wondering about their options for testing a
co-op in Manhattan, not related to
the EPA contract.
Since Howard Bader is quoting you now,
I would personally be surprised if EMSL were
planning on fulfilling all of its analytical
capabilities with only one laboratory out
of the many available EMSL facitilies,
or that if requested by EPA to perform
additional services that did in fact
tax current EMSL resources, that EMSL
would not consider increasing the available
staff either trained to do sonication
extrations or consider sub-contracting
out sonication extractions to other laboratories.
Thank you very much for clearing up any confusion.
Cate Jenkins
Howard Bader <hbader1@nyc.rr.
To: Cate Jenkins /DC/USEPA/US@EPA

cc: "Rutkin, Amy" <Amy.Rutkin@mail.house.gov>

Subject: Re: Response to your tele message 05/17/02 02:22 PM
- - - - - - - - - - - - - - - - - - - - - - -
Cate, my voice mail message to you was not
intended to say I disagreed with
you, rather it was to express concerns
I had. I spoke to Rob Di Malo of EMSL
before my call to you and he thought
they would be heavily burdened with
just doing the air and microvac samples.
He thought EMSL could only do 10
sonication samples per day. I'm not
sure how many other labs do this work.
This may be a huge problem for a potential
15,000 apartment project. I'm also concerned
that we can establish an agreed upon
criteria for evaluating the sample results.
I agree with you that the publics health should
come before cost or convenience, however
we need to make sure whatever we
recommend can actually be accomplished
(given the time parameters at
Since that time I have read your
detailed e-mail. I agree with you on
all the remaining items except the air
sample analysis methodology, I don't
have the expertise to comment this.
----- Original Message -----
From: <Jenkins.Cate@epamail.epa.gov>
To: <hbader1@nyc.rr.com>
Sent: Friday, May 17, 2002 12:38 PM
Subject: Response to your tele message
- - - - - - - - - - - - - - - - - - - - - - -
Howard, I could not get you by phone.
But if you are reading this, you got my
email of the comments I sent Amy.
The sonication extraction only cost $250.
It is hardly a research option. Many labs
offer it. And remember, we are talking about
protecting citizens. We do not need to
consider bogging down the labs. Not many
people will choose to use it. You can't
say it will stretch the resources of any
labs, because the volume of the other
samples they will be doing far exceeds
any sonication samples.
I talked to the president of EMSL
who got the indoor monitoring subcontract,
and they can do it. Also, you seemed
dubious about the high volume air samples.
But EMSL already says that EPA is going
to require 4800 liters of air, so I am not asking
for anything not planned.
My attitude is that we really need to be
protective of the citizens here. It may be
that industrial hygienists did not offer these
options to New Yorkers in the past, but that
should not influence their advice now. I really
do not think that any IH is at risk for liability
by NOW recommending these more protective
tests because they did not do them in the past.
Now that the government is paying the bill,
the lower quality testing recommended by
IH's in the past should be forgotten
and excused because the citizen
was paying for it.
i 1111111111111111111111111111111

Methods for the Analysis of
James R. iVlillelte, Ph.O./\ P. J. Clark, B
Kim A. Brm:kelt, Ph.D., C and R. K. Whecles"
(Key words: Asbestos, Transmission Electron Microscopy [rEM), Carpeting, Ultrasonic Treatment, Microvacuum)
! NTIS is lButho;ized to reproduce and sell this
i report. Permission lor lurther reproduction
Irom the owner.
Assessing asbestos fiber contamination in a carpet is
compncated' by the nature of the carpeting - be<ause of
the pne's rough surface and thickness, samples cannot be
collected directly from carpet for analysis by TEM. Two
indired methods are currently used by laboratories when
preparing samples for measuring the amount of asbestos
present in carpet material. One is an ultrasonic shaking
technique which requires that a portion of the carpet be cut
out and sent to the laboratory. The other is a micro-
vacuuming technique which has been used generally in the
assessment of asbestos in settled dust in bundings. It is not
destructive to the carpet. Both methods utilize TEM to
identify, measure and count the asbestos fibers found. Each
can provide important but different information when an
assessment of the level of contamination of carpeting is
being made. The ultrasonic shaking .. (bulk-carpet sonication)
technique gives an index of the asbestos contamination
throughout the entire carpet piece and the micro-vacuuming
technique gives an index of the readily releasable asbestos
fiber from the carpet surface.
major concem in builJings Iha! contain asbestos-con-
taining material (ACM) is the extent to which the carpet
may serve as a reservoirofasbes!os fibers that have been
released from the ACM by one mechanism or another. I The
Asbestos Hazard Emergency Response Act (AHERA) requires
that all carpel in areas of school buildings in which ACM is
present be cleaned with either a high-efticiency particulate air
Environmental Choices Technical Supplement· March/Apn11993
EPA) lilterecl vacuum cleaner or a hot water extraction cleaner
cleaner). The potential for airborne asbestos fiber
n':l:nlrainml:nt during cleaning activities was shown in
stuJil:s in which airbome asbestos concentrations were found to be
bctwl:en two and fourtimes greater during cleaning than before the
carpet cleaning
There arc currently two Illl:thods used by the authors' labora-
tories forcollccting and indirectly preparing samples toevaluale the
amount of asbestos in or on a carpet. Direct collection and direct
preparation procedures such as tape lift sampling have been
investigated and cannot be used effectively with carpeting. There
arc currently no standard EPA methods for assessing asbestos in
carpeting. One of the methods which is used is an ultrasonic
extraction procedure in which a square piece cut from a carpet is
milJly in water with surfactant to relea!ie Jsocstos fibers
both on the surface and embedded in the carpel. This method is
similar to one that been published about how to measure
asbestos lihers in clothin!! and fabric materials." nle other method
is a vacuuming which uses a moelilied air sampling
cassette to vacuum a sample of dust primarily from the surt-ace of
the carpet. The microvacuuming technique is non-destructive to the
carpel. Both methods use the particle dispersion techniques devel-
oped over the for the analysis ofasocstos in drinking water.
. The Ultrasonic Preparation Procedure
Samples of carpet arc collected by cuLting a piece t usually 10
centimeters by 10 centimeters) from the carpet with a rJzor blade
or utility knife and placing it in a wiele-mouth polyethylene jar or
zip-Ioc bag. In the laboratory. five (5) centimeter by five (5)
centimeter squares of carpet are cut and placed carpet-side down in
a .h0Q9_f!!illiU!e! solution
of the surfactant aerosol OT or a 0.002% solution of the surfactant
methyl cellulose in particle-free water. The beaker is placed in an
ultrasonic bath for 30 minutes. The carpet piece is removed anu
ri nsed into the beaker wi th 100 mill il itt::rs of particle-free water. The
entire suspt::nsion (200 milliliters.) is then shaken vigorously by
hand to disperse the particles and then alloweu to sit for twO minutes
to allow the denser panicles to sink and the light particles to tloat
to t he top. Atth time. three measured al iqllots ofdi rferent volumes
L .....• 11.. _. __ 11 \ .. _._,1/,\ __ .1 ,":,1.".... f:::'{",\, __ ... __ .• ' ..... __ ........ _ ........
\lI."'tUc.lIIY '-'II\,; lJ. \\:11'\ I\J) dilU IIllJ \.JVJ 1111111111. ......&.')) UI\,., ",,,llU"-'l\,..U
with disposable graduated pipettes 1/4 to 1/2 inch below the water
surface in the beaker. The aliljllllt is mixed with particle-free water
to make 50 mi IIi I iters and Ii ltered through a 0.22 pore size mi .\cd
cellulose ester lilter or a 0.2 flill polycarbonate lilter backed by an
0.45 fli11 rore size cellulose ester lilter. If by visual observation. the
initial beaker large non-asbestos fibers (carret material).
the entire suspclI-;ion is passeu through a coarse stainless steelll1t::sh
screen. The filters are dried and prepared for TEivI analYSIS
according to the NIOSH 7402 preparation rrocedure
ester lilter)7 orthe Yamatc. et al.. rrocedure (rolycarbonate
Atleast two TEivI grids from d i ITerent areas orthe Ii Iter arc prepared
for each sample. After the three liltrations arc completed. the
remaining suspension is transrerred to a graduated cylinder and the
volume recorded. 1l1is volume is auded to the volumes of the
measured aliljuots to obtain the total volume of the sample. 1l1is
accounts for the variable amount of water absorbed in the carpet
during proces.-;ing. A sample blank is prepared in identical way
as the sample. although no carpet segment is actually used in the
ultrasonic rrocedure.
The Microvoc Technique
Samples which arc collected by microvacuuming are
commonly referred to as microvac samples or .microvac dust
samples. They are collected byvacuuminga lOOcm
known area) of carpet wi th a membrane fi Iter air-sampl ing cassette
and vacuum pump. 1l1e samrling assembly consists of a 25-mm
diameter mixed cellulose ester filter contained in a three-piece
standard J\ HERA'J air casseHe with a one (I) inch piece of tubing
. to the face cap as a noale 1 0. 1l1e end of the n07.z1e is cut
at 45 1l1e cassette is connected to a personal sampling
rump with tlexible tubing. The pumr and cassette assembly are
calibrated to 2 L/min. The I 00-cm
area is vacuumed by moving
the tilter cassette nozzle across the carpet to agitate the carpet pile ..
1l1e carpet is vacuumed· for approximately 30 seconds in one
direction. then another 30 seconds in a direction 90 degrees to the
first. Arterone minute of vacuuming. the pump is tumedoff and the
fi lLer cassetle nozzle is plugged and the cassette is labeled.
In the laboratory. the unopened microvacuuming cassettes are
wet-wiped and then rrcrared for analysis under clean room condi-
tions. 1l1e cassettes and filters are rinsed out with particle-free
water and refiltered through a second lilter which is used in the
analysis. 1l1e original filter is washed during the sample prepara-
tion procedure but otherwise is not used in the preparation.
Specifically. the plug from the nozzle of the cassette is
removed and the cassette is filled with approximately 10 ml of
pretilLered water. The plug is replaced and the cassette is shaken
vigorously by hand fortwo to three seconds. The entire cap of the
cassette is removed and the suspension poured into a pre-cleaned
200 ml glass medical specimen bottle. All visible traces of the
sample are rinsed into the specimen bottle with a plastic sljuin bottle
of filtered water. This procedure is repeated two additional times
for a total of three washings. Next. the nozzle is rinsed two or three
times into the specimen bottle. Typically. the total amount of water
used in the rinse is arproximately 70 to 75 mi. The water level in
the specimen bottle is then carefully adjusted to 100 ml with
preti Itered water. The rH of the water is adjusted to 3-4 using a 1.0%
for three minutes to make a uniform suspension. Aner two minutes
of settling. a measured volume of suspension is extractl:d with a
graduated pirette inserted halfway into the sample solution. The
aliquot is mixed with particle-free water in the tiller funnel and
tiltered through a 0.22 flm pore 'iize mixed tiltt::r
backed by an5.0 flm rme size cellulose ester Ii Iter. The Ii Iter is dried
and prepared according to the AHERA air samrle
procedure. A samrle blank is prepared in an identical way the
sample. although no carpet segment is actually vacuul1ll:Li.
Asbestos Counting
In the transmission electron microscope. the number of each
type of asbestos structures. chrysotile or amrhibole. is detennineu
by examining a known arcaon the grid in terms of a number of grid
openll1gs. The asbestos fibers are identitied on the ba.,is of
morphology. selected area electron diffraction (Sf\ ED I and/or
energy dispersive X-ray spectrometry (EDS).
The samrles arc counted following the EPA (Yamatc) Provi-
sional Method 'or the AHERA cOllnting rules. Thc choice of
counting methods depends on the par1icular interest of the anal: sl.
1l1e Yamate counting rules provide more information about the
sizes of structures found by the analyst than do the AHERA
counting rules. The amount of asbestos in a given sarnrle is
expressed as structures per square foot. structures per sljuarc
centimeter or structures rcr square meter. 1l1C value is calcubted
using the following equation:
NOSTR = Number of asbestos structures counted in
the, analysis
EFA ::: Effective filter area of the final sampling
filter in square millimeters
GO = Number of grid openings analyzed
GOA = Average area of one TEM grid opening
in square millimeters
S PL = Amount of carpet area sampled (in square feet
or square centimeters)
v = Volume of sample filtered
Environmental ChoicesTedtnical Supplement. March/Apn11993

Table I-Results of Carpet Analyses for Asbestos Samples Randomly Chosen in Cafeteria
Carpet After Conventional (Dry) Vacuuming (all values in asbestos structures per square centimeter)
Sample # LAB A (Sonication)
2 3,050,000
3 *68,000
4 3,600,000
5 3,400,000
6 4,300,000
7 3,200,000
8 2,000,000
*at detection limit
Data on Precision and Percent Recovery
Studies on tile precision and level of recovery of asbestos of tile
hulk-carpet piece ultrasonic shaking (sonication) technique ;Uld the
Illicro-v,lcuumingh:chniquc were perfonned as part of the 198X
EPA study.'! Six samples were collected using each method from
carpet artilicially contaminated with approximately I billion (I x
I ()'l) asbestos structures per foot (sift) or I.OX x IOOstr/cm
nle artilicial contamination was accomplished by spraying a
'known areaof a carpet with a water solution of known asbestos
concentration. Because there was no independent way to measure
the concentration of asocstos on the carpet. no.accuracy detenni-
nation could be made. However. the relative cl"liciem:y of recovery
of onl.! method to the other could oc assessed. nle mean
recovery using the microvacuuming technique was 2.3.'( 10
(2.5 x 10-1 s/cm
). This was approximately 3% of the mean recovery
of till.! hulk-carpet sonication extraction technique which was 7.9 x
lOx sjrt2 (X.5 x lOs s/cm
). nle calculated coefficient of variation
(CV) for the microvacuum technique was 166%. The CV for the
bulk-carpet sonication procedure was 43%. It should be noted that
thl.! values given in referl.!ncc 2 for structures per square foot are the
correct values. I I Thl.!rc was an English/metric conversion error in
thl.! article which provided incorrect values for structures per square
meter throughout the paper.
A similar set of tests using "real world" carpeting that had
been contaminated over a· 15 -year period of nonnal use has been
pcrlomled by the authors' laboratories. Thc carpet samples were
collected from a cafeteria in the Social Security Administration in
Baltimore. Maryland nlccafcteria had an acoustical plasterceiling
LAB B (Sonication) LAB B (Microvac)
4,800,000 21,000
3,300,000 30,000
*5,400 *<350
3,800,000 74,000
3,000,000 50,000
2,500,000 95,000
3,600,000 18,000
4,700,000 35,000
containing I to 5% chrysotile. Ali furnishings had been removed
from the cafcteria and the area had been vacuumed with a
conventional dry vacuum ckaner twice before the samples were
coliectell Previous use and traffic patterns were not taken into
account in collecting the samples. The samples were collected in
a random manner and some samples may have been from areas
where an appliance such as a soft drink machine may have stood
previously. The data which include some interlaboratory compari-
sons arc presented in Table I. Although there appears to be one
outlier in the data set. thl.! relative stands deviation was calculated
using all eight data points for each mcthod. The Sr for the
microvacuum technique was 77'10 and for the bulk-carpet sonica-
tion procedure was 51 Ck for Lab A and 47% for Lab B. nle mean
recovery of the microvacuuming technique compared to the bulk-
carpet sonication prC?Cedure was 1%.
The answer to the question about which method is best for
assessing the asbestos level in carpeting depends on the specitic
question being asked. In the 1988 EPA carpet study the authors
concluded that sonication of bulk -carpet samples provided a more
precise and accurate estimate of asbestos concentrations in carpet
than the micro-vacuuming sampling technique. Their conclusion
was based in part on data which showed that the microvacuuming
technique was shown to recover signi ficantly less asbestos from the
carpet than the ultrJsonic extraction technique.
The fact that one technique is more efficient in recovering
fibers than the other may be important for some studies investigat-
ing the cleaning oflhe totaf carpet. However. there is reason to
believe Ihat carpets can act as a trap for asbestos fibers and that
activities shOI1 of carpet removal may not disturb asbestos fibers
which have worked their way deep into the carpet pile.
For fibers which can be readily rcentraincd into the air
·Crom the carpet surface during cleaning activities the
lllicrovacllull1ing procedure may be more appropriate. This is
reasonabk considering that the 111 iCfovacUUl1l ing procedurecollecls
t"mm the top layer of thl:! carpet and the bulk-carpet sonication
proc"dun: shakes out more tibers which may be embeuded (Jccpin
the carpet pik. The tlala show that the sonication of
samples is a more precise procedure than the microvacuumillg
procedure. However. the microvacullll1ing procedure has an
;tdv;l1ltage of being non-destructive. While some builcling owners
may be willing [0 ha\'\': a rieu:: of carpL:ting cut from their building
if tile carpel 10 he removeu, it is lil-.dy Ihat a piece Illay h..: ":Ul
if Ihe int":llt is to study th..: c!"fectiv..:ness of various cleaning
It is probable tilat a relationship exists h.;t\\ieen carpet con-
tamination and air levels of asb..:s!os produced during cleaning ami
For a given carpet. ,I higher level of'asbestos in the
carpet would be expected 10 produce a high..:r level in the air for a
particular activity. The two methods described here will provide
the f(1r eV;lluating the !evcl of asbestos contamination in
carpeting to be compared wilh levels of asheslos in the air produced
during studiL:s or r..:-cntrainment.
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Stmlks Useful to 0&;0.1 Activities". Microscope. 39:299-:\ 11
( ISl(1).
1) Komin,ky. J.R" R.W. Frcyberg. 1. Chcsson. W.e. Cain. TJ.
Pov,.!.:rs, T.J. ami R.e. Wilmoth. "Evalualion or' Two ClI;llning Mcthntls
I'or the Removal of Asbe,lOs Fibers I'rom ClrpCt." :\m.11Id. /'h" Assoc .
./. 51 (9):5(JO-504. (1,)<)\).
J) Kamlll"k),. 1.R .. Frcybeq;. R.W .. K.A. Bmd;ell. B.A. HolicH.
Re. Wi Il110th. and PJ. CI'lrJ.;, "Evaluation otThrec ClI;;lI1ing Methods for
Removal or Fibers from Carpet and Associnted Airhorm: Fiber
Con..:entralions." Presented at Environmental Management ·91.ll1e Ninlh
t\nnual Convention and or tile EnviromlH:l1wl Inlonllarion
Assodallon. April X. 19l)2, Pillsburgh. Pa.
-I) Chalticld. E.L" Analytical Prmocol I'or Deh.:rmillalion of c\,bcs-
10 ... COf1Wl11lnaliolJ of Chlliling and Olher ". ,Vlic/'IJ.\('O/i<'. 3)0):11 1-
222 (I'J90).
5) Chalficld.EJ. ami \1.J. Dillon. ,'\lIulrticallllclllOdJ()rlii'lcJ'llIi/1I/'
lioll ofashcslOsj7hers ill H·ma. U.S. EPA-nOO/-l-X4·0 .. B. 1 Sl)O)].
6) Br:lt.:kell.K.r\.. P.J. Clark ,mu 1.R. Millcl!c. "A iVh:lhml for Ill.:
Analysi, of Asbl.!slOs Finers in Water Using MCE Filters". Micros('()/ll'.
-IO( 3): 159-163. ( I 'N::: 1
7) Carter. J.W .. P./\. Baron and D.G. Taylor. 74n:::."
NfOSH MWllwl of ,\lIu/l'li( al MCliIOr/.,. Pp. 740 I-I - 7401-7 ( 19S7).
Yam;!te.;\1.. S.c. alll! R.D. Gibbons. ";\Ic!houlliogy for
IIlI! Me;lsun:mcnt of Airhome Aso.:slOS Conc!.!ntralions hy Eb:lrnn
Micro:.copy". Dm!1 Hel'OI'!. Wa.\hingzon. D.C.: Ortiec of Research inti
Development. U.S. EPA. COnlr:lct l\o. /1)0)-02-3260, IlJX-I.
lJ) U .S . .EPA. Ashestos Ha:r.;Jrd Emcrgcl1I.:Y Response ,'\'ct (AHERA I
Regulations. (-10 CFR 763 Subpan E). Oct. 30. I <)X7.
IU) Microv:l!;ulIming sampl!.!rs arc (;omlncrcially available from
Environll1<:lrics. Inc .. 1019 Banklon Dr .. Charl!.!ston. S.c. :::9-l06
II) Personal communication: KUl1)illsky.l.R.'alld R.W. Freynerg.
EnvironmelllalQuality Manag!.!I11CrH. Inc .. CilKinnali, Ohio.
A lTI [OR Af-1'lUATIO:liS
A .Iallles R. Mil/me. PhD .. ami R.K. Whl'l'IL'.I'. i),IVA. /I/C, 550()
Oak/}I'(wk Pkwy .. tl2()(). Norcross. GA 30093.
BpI Clark.. U.S. £lIl'imlllllcnW/ Pm(('uioll Agency Risk
i?edllclioll Engineering uliJlIl'(lrory. Mai/slOp4.J5.::6 West ;Harrill
LlItlter King Dr .. Cincinnati. Off 45268.
C Kim A. Bl'ackell, Pit. D .. IT Corporarioll.11499 CheSler Road.
Cincillilati. 01-145146.
Environmental Choices T edtnical Supplement. March/April 1993
(Pfet11t! read /nstTUclion!S 01'1 the ff!Veru IHf(Nl! -
3.; '. PB93-19.4355
Jim R. Millette Kim A. Brackett
Patrick J Clark
R.K. Wheeles
1. MVA, Inc. 5500 Oakbrook Pkwy, #200 Norcross, GA 30093
2. IT Corp. 11499 Chester Rd., Cincinnati, OH 45246 l1.CONTRACT/GRANTNO.
3. U.S. EPA 26 W. Martin Luther King Dr., Cincinnati,
OH 45268
Risk Reduction Engineering Laboratory--Cincinnati, OH
Office of Research and Development-
Final .lournal Artirlp
U.S. Environmental Protection Agency
Cincinnati, OH 45268 EPA/600/14
Project Officer;:: Patrick Clark t513 569-7561; "Environmental
Choices - Technical Supplement", Volume 1(2):21-24. March/April 1993
. ..p\
Because of the nature of carpet pile, no s'amples can be directly prepared from
carpet for analysis by transmission electron microscopy (TEM). Two indirect methods
are currently used by laboratories when preparing samples for measuring the amount of
asbestos present in carpet material. One is an ultrasonic shaking technique which
requires that a portion of the carpet be cut and sent to the laboratory. The other is
a which has been used generally in the assessment of asbestos
in dust in buildings. It is not destructive to the carpet. Both methods
utilize TEM to identify, measure and count the asbestos fibers found. Each can provide
important but different information when an assessment of the level of contamination
of carpeting is being made., ___
Transmission Electron Microscopy
Indirect Preparation
EPA Form 2220-1 (R.v. 4-77) PREVIOUS EDITION 15 OeSOI..ETE
GS-.·Minera 1 s)
RT- Sertentine)
lectron Microscopy
GS-Mi croscopy)
Particulate Sampling
'r.:'_';lmnlinr'l' RT_rnnron+r;:l . .;" ...
. 19. SECUf'(ITY Ct:ASS IT/lIS 121. NO. OF PAGES

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