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

NYC 9/11 Public Portal Document

This indicates that there are multiple bcations around Libby that are likely to contain asbestos fibers in indoor dust, and that this dust may serve as an on-going source of potential exposure for residents.

Note that the dusts inside Libby residences were found to have the highest calculated cancer risks for the Superfund-designated site.

Complex regulatoiy strategies and whole environmental statutes address the necessary protocols for asbestos abatement inside buildings, just because it will not go away by itself after a few weeks, months, or years with ordinary cleaning measures. The National Emission Standards for Hazardous Air Pollutants (NESHAPS) under the Clean Air Act and the regulatory requirements under the Asbestos Hazard Emergency Response Act (AHERA) both include rigorous methods to stringently clean every surface, like inside air ducts, and removal of carpets, drapes, and upholstered furniture which caimot be effectively cleaned, even AFTER the offending asbestos objects such as insulation, ceiling tiles, and asbestos floor tiles have been removed from the building. During these abatements, trained certified personnel must be wearing HEPA respirators and protective clothing. Etc.

EPA’s crude air testing cannot detect hazardous levels of asbestos

EPA has demonstrated a willingness and promptness in responding to concerns of citizens by coming out to apartments and other buildings and conducting an air test for asbestos. This testis called the “AHERA TEM clearance test,” which stands for Asbestos Hazard Emergaicy Response Act transmission electron microscopy. EPA is using this AHERA TEM clearance test and claiming that if is shows 70 or fewer asbestos structures per square millimeter, then the air is safe:'®

In evaluating data from the World Trade Center and the surrounding areas, EPA is using a protective standard under AHERA, the Asbestos Hazard Emergency Response Act, to evaluate the risk from asbestos in the outdoor and indoor air. This is a very stringent standard . .. The number of structures - material that has asbestos fibers on or in it - is then counted. The measurements must be 70 or fewer structures per square millimeter. . .

This statement by EPA is false and a gross misrepresentation of the AHERA regulations which do not in any way claim that a simple air test alone showing 70 or fewer structures per square millimeter can be used directly to determine if air is safe.

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