DOH/DEP asbestos fact sheet draft, 105 Duane Street

NYC 9/11 Public Portal Document

Predicting air levels if cleanup is inadequate

Air levels might also be predicted if the cleanup is inadequate As discussed in my December 6 memorandum, the EPA determined that neither conventional nor HEPA vacuums were capable of removing `significant amounts of asbestos from carpet. Only the wet-extraction HEPA vacuums removed the asbestos particles which adhere to the carpeting.8 Even the wet extraction HEPA vacuums did not remove all of the asbestos, only about 60% •I \ ty _ P' j s _ n ,l ! ~f~: i,,, Y ",ail r r 7 Ta Y'G • - 7.;

{> Thus, the same or similar levels of asbestos could regain in the carpets as tleitwere`beforethe cleanup After cleanup, the air levels could remain as high as projected in Table 2. The dust to -s t,•. , - n both of the apartments in the Ground Zero Task Force study (Table 2) was not that thick, onlya fine dusting where Y-you could still read the wnting on PP papers on a'table even in the hi exposure Y P, building This small amount of dust could easily work its way into the carpet and remain n— +~r ,~ ;., s. ; t in ,1.+': S 1 e a =~aL.Yi ~•F,e si c .:. } (I have been informed that typically, in asbestos abatement; carpeting isremoved and discarded L53 \Q( because of the inability to remove all the asbestos ` More documentation on recommendations and this practice is requested Information on actually testing or test methods for asbestos { k~ contaminated carpeting is also solicited.; jenkins Cate@epaigov) ` rrx sw y + CALCULATING TOTAL DOSE FROM A SDR s .a. - ( Y~, `f "* CUMULATIVE EXPOSURE INDEX ~. ° shy, ~~~ r ~ ,>T ._ ! r ~ ~'~ >

F Lt f x .t

The Agency for Toxic Substances and Disease Registry (ATSDR) ispart of the Centers for ' Disease Control. It develops toxicological profiles in response to the Comprehensives ' _ Environmental Response Compensation, and Liability ' Act (CERCLA, or Superfund). These profiles are subjected to extensive reviewby the most prestigiousscientists aswell as bein g: reviewed and commented upon by affected .industries and the public.-: The: ATSDR found that the :r `:. "cumulative exposure," or total dose, was valid for predicting the probability of suffering health effects from asbestos There w no "threshold" or safe`leve]''` t. Y

• .A number of researchers have found that the occurrence of asbestosis and king cancer correlates with cumulative exposure (that is, the product of concentration [PCM fibers/mL] multiplied by years of exposure). Therefore, human exposures are expressed below as PCM f-yr/mL

[A] number of other studies indicate that king cancer risk is Imearly related to cumulative dose without any obvious thres hold

In other words, it does not matter whether or not you got the same total dose over L snort period - of time at higher levels, or a long peric,d of time at lower levels. The health effects will be the same. The ATSDR does explain that there is no absolute correlation of the total dose with health effects, but uses it as a valid method to evaluate health risks.

Table 3 lists some of the "cumulative doses" found by the ATSDR to be associated with asbestos health effects. The table also gives examples of what the air asbestos levels are required for different time periods to achieve this dose.

FILE No. A74983669 EXHIBIT # -7-

NYC-WTC 000125978