EPA memorandum regarding asbestos reservoir, June 2002

NYC 9/11 Public Portal Document

regulations for other solid toxics indoors, based on the amount of the toxic substance per surface area.40

This is why tests for settled asbestos dust inside building are based on the number of asbestos structures per square centimeter (s/cm^). This is true for either EPA’s ultrasonication test for carpet, as well as for the ASTM 5755 microvacuum method for dusts on hard surfaces.

At least Region 1 was correct in deriving its interior dust standard for asbestos based on a surface concentration level (asbestos structures per square centimeter, or s/cm^).

Region 2 reverses 1% standard for settled asbestos dust

EPA Region 2 has recently reversed their position that 1% asbestos in dusts is the benchmark for the WTC cleanup. In a March 21,2002 statement to the press, EPA stated that the 1% level was only a “guideline,” but not a health standard."”

In the days after Sept. 11, federal officials repeatedly referred to two "standards,” one for asbestos in dust and debris and another for asbestos fibers in air. For dust and debris, the agency standard was 1% asbestos content.. .. But as Jenkins explains in her memo, federal regulations never meant the 1% figure to be considered a health standard or even to be applied to measure dust.

"We have never said it was a health standard," said the EPA's Mears about the 1%. "We're only using it as a guideline. We say clean up the dust and get rid of the dust regardless of whether it's 1% or below 1 % — it doesn't matter."

In a January 25,2002 speech, Counsel for Region 2, Walter Mugdan also stated that the 1% level was not a health standard, but only the detection limit of an older test method for asbestos:"'

Note that the 1% standard Is not necessarily health- or risk-based, but rather keyed to the detection limits of the specified analytical method [PLM].

Even though Region 2 has backed off its 1% standard in the statements quoted above, it has yet to change its official statements on the EPA website which advise citizens of NYC on the hazards of WTC fallout.""

Will NYC DEP change its position on 1% asbestos dust inside buildings?

It remains to be seen whether or not the NYC DEP will reverse it position on 1% asbestos in dusts inside buildings. This is particularly important since the NYC DEP will be in charge of the decontamination of the most heavily impacted buildings near Ground Zero, those not even

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