NYC 9/11 Public Portal Document
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The sections in this memorandum include:
HOW TO USE ERA'S ULTRASONICATION EXTRACTION TEST
Finding a lab and submitting samples
Ideas for taking carpet and other fabric samples
ASTM microvacuum method is inadequate for carpets and other woven fabrics
NYC APARTMENT BUILDING USES EPA’s ULTRASONIC CARPET TESTING
EPA FINDS HEPA VACUUMING DOES NOT REMOVE ASBESTOS FROM CARPETS, AND
EPA POLICY ON CONTAMINATED CARPETS
Regulations and policy on replacing asbestos-contaminated carpet
RELATING ASBESTOS DUST LEVELS WITH HEALTH RISKS
EPA’s zero standard for asbestos in dust
Data showing background levels of asbestos in dust inside buildings
Estimating air concentrations and risks from settled dust levels
REGION 1's BENCHMARK - SETTLED ASBESTOS DUST - BROOKFIELD SCHOOLS
Description of Region 2's risk assessment for settled asbestos dust:
Use of a “K-factor” to back-calculate dust levels from background air levels
Region 1 misrepresentation of background air levels and safety levels
Region 1 chose an inapplicable K-factorto justify a higher dust level
Region 1 failed to use real-world background dust levels
Re-calculation of Region 1 dust benchmark with more appropriate values
Brookfield School System and community rejection of EPA Region 1 benchmark of
45,000 s/cm^ for dust
EPA REGION 2 BENCHMARK OF 1% ASBESTOS IN WTC DUST
Region 2 cafeteria-style derivation of 1% asbestos dust standard from out-of-context
NESHAP regulations
EPA has established that 1% asbestos is not a safe level
EPA always regulates toxic dusts on interior surfaces by the amount per surface area,
not the % in a dust
Region 2 reverses 1% standard for settled asbestos dust
APPENDIX A - CHART FOR ESTIMATING AIR ASBESTOS LEVELS FROM DUST
APPENDIX B - ASBESTOS AIR CONCENTRATIONS AND RISKS
ENDNOTES AND REFERENCES
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