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

Machine-extracted title · confidence 100%

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

AIRBORNE ASBESTOS, BUILDING INTERIORS PCM-equivalent MANHATTAN fibers permilliiter (f/mL) PCM-equivalent fibers and bundles longer than 5 Micrometers

Ground Zero Task Force Study,*® data from Table 16. HIGH EXPOSURE BUILDING, 250 South End Ave, BEFORE CLEANUP, PASSIVE CONDITIONS (no activities to disturb dusts). Fibers and bundles longer than 5 micrometers. TEM analysis using the International Standards Organization ISO10312 direct transfer method

250SEA-10D-A1. Apartment 10D, den 0.063

250SEA-10D-A2, Apartment 10D, den 0.060

250SEA-10D-A3, Apartment 10D, living room 0.048

250SEA-10D-A4, Apartment 10D, living room 0.075

250SEA-10D-A5, Apartment 10D, bedroom 0.081

Ground Zero Task Force Study, Table 8.*® PCM-equivalent fibers and bundles longer than 5 micrometers. PASSIVE CONDITIONS (no activities to disturb dusts) LOW EXPOSURE BUILDING, 45 Warren St. BEFORE CLEANUP. TEM analysis using the ISO10312 direct transfer method.

45 WAR-2-A1,2nd floor living room “not statistically significant" [detected but uncertain]

45 WAR-2-A2, 2nd floor living room ND

45 WAR-2-A3, 2nd floor master bedroom 0.010 HP Environmental Study, Table 6.*^ Two building interiors near Ground Zero. PASSIVE CONDITIONS, BEFORE CLEANUP. Analyses by the modified EPA Level II TEM method where samples were heavily loaded (all 3 samples below where asbestos detected), which uses indirect preparation to separate out interferences from other non-asbestos parts of WTC dusts. Study demonstrated that up to 10 times more asbestos was detectable by this method.

Sample 2 0.007

Sample 7 0.167

Sample 9 0.346

8 out of 11 samples, interior of 2 buildings near collapsed WTC towers, ND

EPA data, PASSIVE CONDITIONS, AFTER INCOMPLETE CLEANUP. EPA has been usually not using the simple AHERA TEM clearance test method inside buildings at the request of detected tenants and others. This isaviolation of the AHERA protocols, which only allow this test to be performed AFTER professional and complete asbestos abatement, which must thoroughly clean all surfaces. The AHERA TEM clearance method is only meant as an inexpensive, but not an assurance by itself, that asbestos has been adequately abated. The use of a leaf blower or other strong fan in conjunction with taking the air sample would be needed for that in addition to wipe samples of surfaces. EPA Region 8 found that at Libby, even when there were activities going on to disturb dusts, air monitors worn by people sitting on couches, etc. always gave higher readings than a stationary air monitor in the same room (such as is the case in the AHERA TEM test).

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NYC-WTC_000140252

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NYC-WTC_000140252Source: NYC Law Department, mirrored locally

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