ATTACHED:

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

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM

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.*

jenkins.cate@epa.gov
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,

*
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.
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
memoranda.)

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
effectiven ess of various clean ing m etho ds o n ca rpets impac ted by asbesto s. The firs t,
Evaluation of Two Cleaning M ethods for R em oval of Asbes tos Fibers from Carpet (1),
found that cleaning asbestos- contaminated carpets with a hot-water extraction cleaner
wa s m ost effective, reducing asbesto s levels by approxim ate ly 70%. The second stu dy,
Eva luation of T hree Clea ning Me thod s for Rem oving Asb esto s from Carpet:
Determ ination of Airborne Asbestos C oncen trations As sociated with Each M ethod (2),
again found that a hot-water extraction cleaner was most effective, producing a 60%
redu ction in asb esto s leve ls in contam inated carp ets. [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 m ay therefore have been m ore effe ctive (m eaning a gre ate r reductio n in
asb esto s leve ls).

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.

W ith this information in mind, EPA recomm ends that residents consider replacing some
or all carpets, upholstered furniture or draperies if their home was impacted by W TC 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 reimbursem ent
assistance.

[Note that EPA is replacing all carpeting and upholstered furniture at government expense
in residents at the Libby, Montana Superfund site. This disparity in treatment of NYC
residences is egregious.]

-2-
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.1 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.

ASBESTOS TESTING, BROOKFIELD HIGH SCHOOL AUDITORIUM

all results in units of asbestos structures per square centimeter (s/cm 2)

Seat Cushions - Before and after sampling points are not necessarily for the same seats.

Before abatement After HEPA vacuuming, steam extraction

ASTM microvacuum method. 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

35,110

Carpet - Before a nd a fter sam pling points a re no t necess arily for the exa ct sa m e are as o f the c arpe t.

Before abatement After HEPA vacuuming, steam extraction

ASTM microvacuum method. 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.

-3-
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.

-4-
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
replaced.

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".

-5-
 The News-Times: Local More than a dusting

The News-Times

More than a dusting

Brookfield asbestos removal is painstaking
By Heather Barr
THE NEWS-TIMES
2002-08-11
As temperatures soared into the 90s on a recent
weekday, workers wearing protective fabric suits and
respirators vacuumed and then wiped down a set of
blinds in a bathroom at Brookfield High School. The air
was as hot and heavy as in a sauna because no air
conditioning or fans are allowed. Each set of blinds takes
up to an hour to clean.

Such attention to detail is required when removing

asbestos fibers. That is why crews have been working
24-hours a day to clean all four schools in Brookfield so
they can open by Aug. 27. Day workers are bused from The News-Times/Wendy Carlson
New Jersey every day, and some supervisors and Asbestos removal cleaners vacuum up and wipe
project managers have been living at the schools. down equipment in the computer room at
Brookfield High School.

Supervisor and foreman Marvin Aguilar’s home for the

last month has been the high school.He taped together
two cots in a school office and used them as a platform
for an inflatable mattress.

On one wall he taped pictures and letters from his

family, which drives from New Jersey on weekends to
visit him. On another wall is a poster showing the inside
of the human body, a reminder that his temporary home
will revert to a nurse’s office when school begins.

The News-Times/Wendy Carlson

Aguilar said it is hard to be away from his family, but he Clean air is filtered out of the chemistry rooms
added the job of cleaning asbestos from the schools is from a tube connected to a machine called a
important to him. microtrap, which collects the air and sends it
through its filters to remove asbestos particles.

"Imagine your child exposed to something like this,” he

said.

"There is no tool, no machine or no miracle,” said

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 The News-Times: Local More than a dusting

George Stokes III, senior project manager of PT&L

Contracting Corp.

"The only way to clean top to bottom is 100 percent

pure labor.”

The tools of an asbestos cleaner are both specialized

and mundane.

Each worker, who is certified to do asbestos clean-up,

wears a full suit of Tyvek, material that keeps out dirt
and dust while allowing body heat to escape. Some also
wear gloves, Tyvek booties over their shoes, Tyvek hair
covering and respirators that cover the mouth and nose.
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.

After sealing a room, a worker goes through with a leaf

blower, aiming jets of air at the floors and walls. The
object is to make any asbestos airborne so it can be
sucked into a "microtrap,” a three foot square box with
three filters.

Clean air is vented outside the building.

After the leaf blower makes all dust airborne, workers

go over every surface with a specialized vacuum cleaner
that also has three filters.

Stokes said a Hepa vacuum will trap 99.97 percent of

the asbestos it picks up.

Finally, after the vacuuming, every surface or object is

wiped up to four times with four different cloths.

Room radiators are cleaned using the same process, but

the radiators, where much of the asbestos seemed to
gather, are sealed off from the room with a plastic
bubble around them.

Erin Kiernan
The air in the bubble is then sampled before the plastic
Workers steam clean seats in the auditorium.
is taken down. Later, cloth samples are removed to insure
asbestos does not exist.
Most of the workers are originally from South or Central
America. Marvin Aguilar, a general foreman, walks
around the high school with a radio instructing workers
in Spanish. Supervisors who do not speak Spanish use
red lasers to point out to workers which sites need to be
cleaned.

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 The News-Times: Local More than a dusting

Visitors occasionally arrive for tours. U.S. Rep. Nancy

Johnson, R-6th Dist., walked through the building during
the last week of July.

Before a room is cleaned, workers remove all the

objects inside, from desks to crayons. They are cleaned
in holding areas that are sealed from the rest of the
building.

In the high school’s ceramics room, students still had Erin Kiernan
items in the kiln when school was closed early for the The cleaned sections are covered in plastic until
year. Each object had to be removed carefully and removal is complete.
cleaned.

"When we cleaned we paid attention to students’ projects to make sure they were not damaged
or destroyed. We know a lot of students spent time on a project. We are sympathetic to their
needs,” said Stokes.

"Besides radiators, laboratories (chemistry or biology rooms) were difficult to clean because of
chemicals and items in drawers,” said worker Marco Salgado. "You had to move things one by
one.”

Every item in a contaminated area must be cleaned, including light fixtures, the insides of exit
signs, lockers, and the like.

Cleaning a computer takes up to 90 minutes. All computer mouses and keyboards were thrown
out, along with about 25 computers deemed to be so old they were not worth cleaning.

A total of about 190 computers were cleaned and wrapped in plastic to await an air sampling of
the room in which they were sanitized.

The dust collected in the vacuums, filters and rags is bagged, labeled as dangerous, and taken to
a landfill that accepts asbestos.

A trailer outside the school has a shower and an area for the workers to clean up before going
home if they wish.

High levels of asbestos were found in Huckleberry Hill School in May after music teacher
Margaret Fitzgerald, acting on her own concerns, hired a company to test her room. Further
testing by the district found that all four schools were contaminated.

Students were transported to other schools in the region to for several days at the end of the
year. The town authorized $900,000 toward a clean-up, and state officials approved use of a

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 The News-Times: Local More than a dusting

disaster relief statute that allowed the town to issue short-term bonds for another $3.2 million.
An Aug. 27 referendum is scheduled for residents to vote on whether to pay to cover the notes.

Infinity Environmental Services of New York was hired to clean Huckleberry Hill and Whisconier
Middle schools and PT&L Contracting Corp. of New Jersey was contracted to clean Center School
and the high school. Work began in early July.

A large piece of asbestos hangs from a return air intake duct at Brookfield High, looking like five
or six gray cotton-balls stuck together. Stokes took a photo of it before a small robot on a tether
went through the duct sweeping up all dust. The larger ducts were cleaned by workers who
crawled through them.

Not every inch of each school had to be cleaned so vigorously.

About 11 rooms in Huckleberry Hill School, 45 rooms in Whisconier Middle School, 12 rooms in
Center School and 70 rooms in Brookfield High School were completely cleaned.

Cleaning started after all rooms and areas were tested for asbestos. A color-coded map was
prepared of the inside of each school to guide workers.

To separate non-contaminated rooms from contaminated areas, large blankets of plastic were
attached to doorways throughout the building. Signs warning "Asbestos: Cancer and Lung
Disease Hazard,” were posted throughout each school.

In some rooms, the specialists cleaned only the radiators and air ducts, and janitors cleaned the
rest.

Some carpets were removed, but the rest were steam-cleaned. Contractors were able to save
hundreds of cushioned chairs by steam-cleaning them.

Asbestos levels are ruled safe only after each school gets a final test of air that is circulated with
blowers.

And then Aguilar, the supervisor and father of four, will be able to pack up his photos and letters
and finally sleep in his own bed again.

"I miss my family,” he said.

Contact Heather Barr

at hbarr@newstimes.com

or at (203) 731-3331.

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 Cate Jenkins To: amy.rutkin@mail.house.gov, envjoel@ix.netcom.com,
ihconsult@msn.com, jan1006@comcast.net,
05/20/02 01:47 PM actsnyc@cs.com, paulwoodsbartlett@hotmail.com,
artandpolitics@yahoo.com,
mclarke@shiva.hunter.cuny.edu, flynnktm@aol.com,
lisette.morton@mail.house.gov, dave@nycosh.org,
jbennett@nycosh.org
cc:
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
issues

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
[mailto: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
- - - - - - - - - - - - - - - - - - - - - - -
Rob,
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
703/308-0453

_____________________________________________
_____________________________________________
_____________________________________________

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
hand).
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.
Cate
 '/PB93194355
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''''---- ----~

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
ireport. Permission lor lurther reproduction
~~e Dbtai~ Irom the ~opvrighl 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.
.The Ultrasonic Preparation Procedure
major concem in builJings Iha! contain asbestos-con-
(I~ EPA) lilterecl vacuum cleaner or a hot water extraction cleaner
(~teal11 cleaner). The potential for airborne asbestos fiber
n':l:nlrainml:nt during ca~t 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 activities.~·:-
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 ~onicated 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 ha~ been published about how to measure
asbestos lihers in clothin!! and fabric materials." nle other method
is a vacuuming proced~re 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 year~ for the analysis ofasocstos in drinking water. 5 .6

A 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
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! beak~E_~~t<liningJ9QITI!lli!lt~!S_~f.0.19'o solution
. REPRODUCED BY
U.S. DEPARTMENT OF COMMERCE
NATIONAL TECHNICAL INFORMATION SERVICE 21
 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 the top. Atth i~ 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 ~lIn 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 cont~lins 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 (cellulo~e
ester lilter)7 orthe Yamatc. et al.. rrocedure (rolycarbonate tilter).~
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 ~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 2 area(orotilcr
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
. ~Iltached to the face cap as a noale 10. 1l1e end of the n07.z1e is cut
at 45 dq~rees. 1l1e cassette is connected to a personal sampling
rump with tlexible tubing. The pumr and cassette assembly are
calibrated to 2 L/min. The I00-cm 2 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%
~1I:1: ... __ .• ' ..... __ ........ _ ........ '"'~I
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 cellul()~e e~tcr 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 rrepar~ltilln
procedure. A samrle blank is prepared in an identical way ~IS 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:
EFAx 100 X NOSTR
= STRUCTURES /AREA OF
GO X GOA X SPL X V THE CARPET
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
'J
- •
-------- --------
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) LAB B (Sonication) LAB B (Microvac)

5,400,000 4,800,000 21,000

2 3,050,000 3,300,000 30,000

3 "*68,000 *5,400 *<350

4 3,600,000 3,800,000 74,000

5 3,400,000 3,000,000 50,000

6 4,300,000 2,500,000 95,000

7 3,200,000 3,600,000 18,000

8 2,000,000 4,700,000 35,000

*at detection limit

Data on Precision and Percent Recovery 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
Studies on tile precision and level of recovery of asbestos of tile
hulk-carpet piece ultrasonic shaking (sonication) technique ;Uld the coliectell Previous use and traffic patterns were not taken into
Illicro-v,lcuumingh:chniquc were perfonned as part of the 198X account in collecting the samples. The samples were collected in
EPA study.'! Six samples were collected using each method from a random manner and some samples may have been from areas
carpet artilicially contaminated with approximately I billion (I x where an appliance such as a soft drink machine may have stood
previously. The data which include some interlaboratory compari-
I()'l) asbestos structures per ~quare foot (sift) or I.OX x IOOstr/cm 2.
nle artilicial contamination was accomplished by spraying a sons arc presented in Table I. Although there appears to be one
'known areaof a carpet with a water solution of known asbestos outlier in the data set. thl.! relative stands deviation was calculated
concentration. Because there was no independent way to measure using all eight data points for each mcthod. The Sr for the
the concentration of asocstos on the carpet. no.accuracy detenni- microvacuum technique was 77'10 and for the bulk-carpet sonica-
nation could be made. However. the relative cl"liciem:y of recovery tion procedure was 51 Ck for Lab A and 47% for Lab B. nle mean
of onl.! method to the other could oc assessed. nle mean asbcsto~ recovery of the microvacuuming technique compared to the bulk-
recovery using the microvacuuming technique was 2.3.'( 107 s/IY! carpet sonication prC?Cedure was 1%.
(2.5 x 10-1 s/cm 2 ). This was approximately 3% of the mean recovery
of till.! hulk-carpet sonication extraction technique which was 7.9 x Discussion
lOx sjrt2 (X.5 x lOs s/cm 2). nle calculated coefficient of variation
(CV) for the microvacuum technique was 166%. The CV for the The answer to the question about which method is best for
bulk-carpet sonication procedure was 43%. It should be noted that assessing the asbestos level in carpeting depends on the specitic
thl.! values given in referl.!ncc 2 for structures per square foot are the question being asked. In the 1988 EPA carpet study the authors
correct values. I I Thl.!rc was an English/metric conversion error in concluded that sonication of bulk -carpet samples provided a more
thl.! article which provided incorrect values for structures per square precise and accurate estimate of asbestos concentrations in carpet
meter throughout the paper. than the micro-vacuuming sampling technique. Their conclusion
A similar set of tests using "real world" carpeting that had was based in part on data which showed that the microvacuuming
been contaminated over a· 15 -year period of nonnal use has been technique was shown to recover signi ficantly less asbestos from the
pcrlomled by the authors' laboratories. Thc carpet samples were carpet than the ultrJsonic extraction technique.
collected from a cafeteria in the Social Security Administration in The fact that one technique is more efficient in recovering
Baltimore. Maryland nlccafcteria had an acoustical plasterceiling 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 Ih()~e 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
Ilhl'r~ 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 blllk-c~lrpct
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 i~ 10 he removeu, it is k~!'o lil-.dy Ihat a piece Illay h..: ":Ul
if Ihe int":llt is to study th..: c!"fectiv..:ness of various cleaning
procedures.
It is probable tilat a relationship exists h.;t\\ieen carpet con-
tamination and air levels of asb..:s!os produced during cleaning ami
olh..:racti\'ilie~. 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 basi~ 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.
REFEREt\CES
II Wilmoth. R. e., T.J. Powers ;111r1J. R. f'vlillettc, "Ohscrvatiofl!>011
Stmlks Useful to Asbc~tos 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 Asbe~!Os Fibers from Carpet and Associnted Airhorm: Fiber
Con..:entralions." Presented at Environmental Management ·91.ll1e Ninlh
t\nnual Convention and Expt)~ition 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 F;lbric~ ". ,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. 1Sl)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. "~!OSH 74n:::."
NfOSH MWllwl of ,\lIu/l'li( al MCliIOr/.,. Pp. 740 I-I - 7401-7 ( 19S7).

~) Yam;!te.;\1.. S.c. A~arwa!. alll! R.D. Gibbons. ";\Ic!houlliogy for

,
IIlI! Me;lsun:mcnt of Airhome Aso.:slOS Conc!.!ntralions hy Eb:lrnn
·SAMPLING 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.
PUMPS REPAIRED~ lJ) U .S ..EPA. Ashestos Ha:r.;Jrd Emcrgcl1I.:Y Response ,'\'ct (AHERA I
·BATTERY PACKS Regulations. (-10 CFR 763 Subpan E). Oct. 30. I<)X7.

REBUILT IU) Microv:l!;ulIming sampl!.!rs arc (;omlncrcially available from

Environll1<:lrics. Inc .. 1019 Banklon Dr .. Charl!.!ston. S.c. :::9-l06

·LO VOL AND HI VOL II) Personal communication: KUl1)illsky.l.R.'alld R.W. Freynerg.
EnvironmelllalQuality Manag!.!I11CrH. Inc .. CilKinnali, Ohio.
PUMPS
·PERSONAL PUMPS
·PAPR'S REPAIRED
·FAST TURNAROUND
A lTI [OR Af-1'lUATIO:liS
·WARRANTY GIVEN
Save 40% to 50% on
Repairs and Batteries.
Also:The Perm-O-Fix 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.
Acetone Vaporizer Built
and Sold BpI Clark.. U.S. £lIl'imlllllcnW/ Pm(('uioll Agency Risk
ATLANTA LAB SYSTEMS i?edllclioll Engineering uliJlIl'(lrory. Mai/slOp4.J5.::6 West ;Harrill
115 CEDAR TRACE LlItlter King Dr .. Cincinnati. Off 45268.
_ JlOSWEll, GA 30075
(404) 993-7850 C Kim A. Bl'ackell, Pit. D .. IT Corporarioll.11499 CheSler Road.
Cincillilati. 01-145146.

Environmental Choices Tedtnical Supplement. March/April 1993

 TECHNICAL REPORT DATA
(Pfet11t! read /nstTUclion!S 01'1 the ff!Veru IHf(Nl! COmplf!li~-;' -
1. REPORT NO. 3.; '. PB93-19.4355
EPA/600/J-93/167
4. TITL.E ANO SUBTITLE 5. REPORT DATE

METHODS FOR THE ANALYSIS OF CARPET SAMPLES

,
.FOR.ASBES:rO~:-::-::-::-::-:-:-~~~~-::--___~
. 6. PERFORMING ORGANIZATION CODe

7. AUTHOR(SI 1 2 8. PERFORMING ORGANIZATION REPORT NO.

Jim R. Millette Kim A. Brackett
Patrick J Clark 3 R.K. Wheeles 1
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
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
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE DF REPORT AND PERIOD COVEREO

Risk Reduction Engineering Laboratory--Cincinnati, OH Final .lournal Artirlp

i 14. SPONSORING AGENCY CODE
Office of Research and Development-
U.S. Environmental Protection Agency
Cincinnati, OH 45268 EPA/600/14
15~SUPPLEMENTARYNOTeS Project Officer;:: Patrick Clark t513 569-7561; "Environmental
Choices - Technical Supplement", Volume 1(2):21-24. March/April 1993
'''. ABSTRACT
. ..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 micro-vacuuming~technique which has been used generally in the assessment of asbestos
in se~tled 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., ___=~_

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group

Asbestos Asbestos
Transmission Electron Microscopy ~ GS-.·Minera 1s)
Carpet RT- Sertentine)
Indirect Preparation lectron Microscopy
GS-Mi croscopy)
RT-Microanalysis)
Particulate Sampling
'r.:'_';lmnlinr'l' RT_rnnron+r;:l . .;" ... ~
18. DISTRIBUTION STATEMENT . 19. SECUf'(ITY Ct:ASS IT/lIS R~po,t) 121. NO. OF PAGES
UNCLASSIFIED 6
RELEASE TO PUBLIC 20. SECURITY. CLASS (TIiis-p<JR'" 22. PRICE

UNCLASSIFIED
EPA Form 2220-1 (R.v. 4-77) PREVIOUS EDITION 15 OeSOI..ETE