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EPA memorandum regarding asbestos reservoir, June 2002

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Forwarded EPA memorandum dated June 9, 2002, concerning the Asbestos Reservoir and carpet testing methods.

NYC-WTC_000140083–000140124

Folder label: “EPA Cate Jenkins

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NYC 9/11 Public Portal Document

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concentrations before and after cleaning. Airborne asbestos concentrations were two to four times greater during than before the carpet cleaning activities. Neither the level of asbestos contamination in the carpet nor the type of cleaning method used greatly affected the difference between the airbone asbestos concentration before and during cleaning.

16. U.S. Army Corps of Engineers (1992) Asbestos Abatement Guideline Detail Sheets, Engineer Pamphlet 1110-1-11. Posted on the internet at http://www.usace.army.mil/inet/usace-docs/eng-pamphlets/epl 110-1-11/entire.pdf

See page 11 of the Corps of Engineer’s publication for a table which states that removal is the only option for carpet, and pages 48 and 49 for the procedures for removal. These guidelines are for carpet that is only contaminated with low levels of asbestos, as well as carpet defined as “asbestos containing” having over 1% asbestos. The carpet must be HEPA vacuumed before disposal. This is not to make it free of asbestos, or decontaminated, but instead just to reduce the levels. The carpet must still be removed and replace.

17. EPA (1997) Rules of thumb for superfund remedy selection. Publication No. EPA 540-R-97- 013, NTIS PB97-963301. Posted at www.epa.gov/superfund/resources/rules/

EPA (2000) Presenter’s manual for: “Superfund Risk Assessment and How you Can Help”. Publication No. EPA/540/R-99/013. Posted at www.epa.gov/superfund/programs/risk/vdmanual.pdf

The EPA does not consider any exposure to a man-made carcinogen to be acceptable, but does base its actions in existing exposure situations according to the degree of elevated risk. The EPA chooses a degree of protection, or risk level, as a criteria for abating exposures.

18. U.S. EPA (April 25, 1986) Toxic Substances; Asbestos Abatement Projects. Final Rule. Federal Register, Volume 51, p. 15722 fF.

19. Asbestos School Hazard Detection and Control Act (June 14, 1980) Public Law (P.L.) 96- 270, § 1, 94 Stat. 487, 20 USCS § 3601 (2001). Available at http://www.findlaw.com/ or http://uscodc.house.gov/ § 3601. Congressional statement of findings and purposes (a) The Congress finds that- (1) exposure to asbestos fibers has been identified over a long period of time and by reputable medical and scientific evidence as significantly increasing the incidence of cancer and other severe or fatal diseases, such as asbestosis: (2) medical evidence has suggested that children may be particularly vulnerable to environmentally induced cancers; (3) medical science has not established any minimum level of exposure to asbestos fibers which is considered to be safe to individuals exposed to the fibers...

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