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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

Montana, a designated Superfund site.

Most of the available data for Manhattan is before even a rudimentary cleanup. One particular piece of data, the residue inside an air vent at 105 Duane St., three blocks outside the boundary where EPA said there was any contamination (7 blocks from Ground Zero), is particularly alarming. This air duct sample was taken on December 3, 2001, long after all cleanups that had been thought necessary were completed.

The highest level of dust inside a building in Manhattan was 79,000 structures (asbestos fibers) per square centimeter (s/cm^). This was at 45 Warren St., an apartment building 4 blocks away from Ground Zero where all of the windows faced north, away from the World Trade Towers, locked in on all other 3 sides by other buildings. To the casual observer, this apartment would not be described as being heavily contaminated. There is a color photograph included at the begiiming of the study,® where a dining room table showing only a light dusting from WTC fallout, the dark grain of the wood clearly visible.

In comparison, the highest concentration of interior dust found inside a home at Libby was only 3658 s/cm^. This means the highest amount of asbestos lying on a surface in Manhattan was 22 times that ever found in Libby.

The logical question thus arises: Why is EPA leaving people to their own devices in the cleanup of New York City, while intervening to clean homes at taxpayers expense in Libby because of an “imminent and substantial endangerment to public health”?

2. INEFFECTIVE CLEANUP OF WTC ASBESTOS TO DATE

To date, the cleanup of the WTC fallout containing asbestos, fiberglass, fine particulate matter, and possible significant concentrations of other toxic materials is not proceeding efficiently or effectively.

Asbestos does not leave buildings with ordinary cleaning methods

The asbestos contamination is not going to leave buildings in Manhattan by itself with ordinary cleaning any more than it will in Libby. In the case of Libby, MT, the EPA stated:’

-3-

NYC-WTC_000140237

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NYC-WTC_000140237Source: NYC Law Department, mirrored locally

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