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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 t

1. ASBESTOS CONTAMINATION IN BUILDINGS, MANHATTAN COMPARED TO LIBBY SUPERFUND SITE

In Libby, Montana, interiors of homes and residential soils have been contaminated with asbestos from an adjacent vermiculite mining operation. Homes have vermiculite insulation in attics, and vermiculite was used for gardening. In addition, there are numerous waste piles of venniculite in the area.’ On December 20, 2001, the Governor of Montana designated Libby for fast-track listing as a Superfund site under the Comprehensive Environmental Response and Liability Act (CERCLA)."

In Lower Manhattan, interiors of residences and offices were contaminated with asbestos, fiberglass, fine particulate matter, and possibly significant concentrations of other toxic materials from the fallout from the implosion of the World Trade Center (WTC).

Tables at the end of this memo provide levels of asbestos in settled dusts and air in two apartments before cleanup from the Ground Zero Task Force Study,’ and levels of asbestos in settled dusts in one apartment after cleanup from a study by the New York Environmental Law and Justice Project.*

Use of “PCM-equh'alent” asbestos data from Manhattan for comparison to Libby

In order to compare asbestos levels found in Manhattan with that from Libby, the data in the tables is for asbestos fibers longer than 5 pm, width greater than 0.25 pm, and an aspect ration greater than or equal to 3 to 1. This is called “PCM-equivalent asbestos.” The data from Libby only includes asbestos levels that are PCM-equivalent. The Ground Zero Task Force Study^ of WTC contamination provided not only total asbestos levels, but also PCM-equivalent asbestos levels.

The reason why only fibers longer than 5 pm (PCM-equivalent) are given in the Libby risk assessment is because many believe that asbestos fibers shorter than this cannot cause cancer, because they can be eliminated from the body. Not all agree.

Comparison of Libby and Lower Manhattan data

As can be seen from the above tables, the asbestos contamination in Lower Manhattan, up to seven blocks away from Ground Zero, is comparable or higher than that found in Libby,

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