World Trade Center asbestos situation memorandum, December 2001

NYC 9/11 Public Portal Document

10/3/01 - EPA Administrator claims no hazard, despite concurrent release of data showing 1 % or over asbestos 5 to 7 blocks from Ground Zero

Governor Whitman’s 10/3/01 press release states

, no evidence of any significant public health hazard to residents, visitors or workers beyond the immediate World Trade Center area.” (www.epa.gov/epahom e/newsroom .htm)

This same press release states that available EPA data now shows that 48 of 177 bulk dust and debris samples showed asbestos over 1 %. These locations were up to 5 to 7 blocks from Ground Zero. The press release made no comment on the significance of these findings. (www.epa.gov/enviro/nyc/bulkdust/)

The action level under the Clean Air Act (CAA) for asbestos is 1% in surface dusts, debris, and other materials. The CAA regulations for asbestos are under the National Emission Standards for Hazardous Air Pollutants (NESHAP).

The hazard and the regulations are tied to the concentrations in the dusts and other materials themselves,, not in the air, because it is what you do with the dust/material that determines the exposure levels. If the dust is stirred up during an uncontrolled cleanup operation indoors* it will generate higher airborne asbestos levels. That is why the asbestos NESHAP does not give any safe air concentrations in the standard itself, only concentrations in the surface dust itself. These national standards are science-based, peer reviewed, and have been subjected to and withstood numerous court challenges.

EPA took its airborne asbestos readings outdoors where the air is diluted. Thus, EPA’s outdoor air readings are irrelevant in determining whether there are any hazards inside during a cleanup or other normal activities.

It was contrary to the legally-binding applicable CAA NESHAP standards for Governor Whitman to claim that there was no significant health hazard beyond the immediate vicinity of Ground Zero, because she had data at this time showing asbestos in surface dusts at 1% or more beyond Ground Zero.

10/3/01 - Study by HP Environmental uses more sensitive test methods, finds higher asbestos than EPA, and smaller particle sizes

Press articles rq^ort on new study by HP Environmental, which used a more sensitive test method than EPA. The EPA method could only detect asbestos particles greater than 0.5 microns in size, a size which is less hazardous. HP Environmental also found uniquely elevated concentrations of very small-sized asbestos particles, more easily aerosolized, “an asbestos fiber size distribution not previously encountered”.

As an example, when HP Environmental tested air in two buildings that were up to 3 blocks from Ground Zero, only 2 of 11 samples showed asbestos above the limit using the EPA method, but

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