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EPA memo re: asbestos assessment and Superfund advantages, Jan 2002

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Memorandum comparing asbestos data in Manhattan to other sites and arguing for cleanup under the Superfund statute.

NYC-WTC_000140235–000140258

Folder label: “EPA Cate Jenkins

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NYC 9/11 Public Portal Document

by the American Society for Testing and Materials (ASTM) and the International Standards Organization (ISO).

Dr. Chatfield was also the lead investigator in the Ground Zero Task Force study of Lower Manhattan, where state of the art methods were again used. The HP Environmental study, also included in the tables, utilized the best methods which could be devised for characterizing Lower Manhattan.

Whether addressed through a CERCLA action or any other means, Lower Manhattan has not undergone adequate testing. Within EPA itself, we do not have the expertise to design or carry out state of the art testing protocols for asbestos. For other hazardous substances, we do have expertise, but not for asbestos. The experts I know of at this present time include the researchers responsible for the Ground Zero Task Force study (Eric Chatfield and John Kominsky), the researchers for the HP Environmental study (Hugh Granger, Thomas McKee, James Millette, Piotr Chmielinski, and George Pineda), and Michael Beard of Research Triangle Institute.

4. SUMMARY, ASBESTOS RISK ASSESSMENT FOR WTC DUSTS

My December 19, 2001 memo’® provided a detailed rationale for projecting cancer and asbestosis risks from WTC fallout by calculating exposures from the very limited data which is currently available. In that assessment, various exposure scenarios were hypothesized, and risks of lung cancer for smokers and non-smokers, mesothelioma (a cancer of the chest cavity), and asbestos risks were hypothesized. As stated at the beginning of this memorandum, I believe that initiating such an effort fills a critical need that was thwarted in the appropriate EPA offices by the constant reassurance of high level EPA officials that no such assessment was necessary.

PCM-equivalent correction factor and other changes to risks in December 19 memo

My December 19 risk assessment used the concentration of all asbestos fibers, not just “PCM- equivalent” fibers (those longer than 5 ^m, width greater than 0.25 pm, and an aspect ration greater than or equal to 3 to 1) in making calculations of risk. An explanation was provided as to why this correction was not made, along with providing a range of 80 to 90% non-PCM- equivalent fibers for WTC asbestos if such a correction were to be used. This was based on two studies; From the Ground Zero Task Force study,’’ the PCM-equivalent fibers ranged from 1.3 to 20% of total asbestos fibers/bundles for 8 different samples of settled dusts, with a mean of 8.7%. For the HP Environmental study,’’ for 3 air samples, PCM-equivalent fibers ranged from

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NYC-WTC_000140247Source: NYC Law Department, mirrored locally

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