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

NYC 9/11 Public Portal Document

There are no methods or protocols for taking dust samples from surfaces. Thus, trying to run a PLM % asbestos test on dust violates the AHERA regulations.

The PLM methodfor % asbestos is too insensitive to find asbestos at levels of concern

EPA used PLM % asbestos analyses of thick WTC fallout on streets outdoors. Many, if not most, of these samples showed no detectable asbestos.^' See the tables at fire end of this memo for a summary of the findings. The PLM method is unreliable at concentrations of 1% and less. In other investigations, EPA found that soil samples below the level of detection of PLM did in fact have high levels of asbestos when analyzed with SEM (scanning electron microscopy) methods.22 Thus, many of the outdoor dust samples in Manhattan probably were actually contaminated with asbestos.

Likewise, if landlords did manage to test their fine indoor dust layers and found no asbestos by the PLM method, it could well have been there in hazardous amounts.

Current EPA recommendations for Manhattan cleanup will leave most asbestos

To this date, EPA still recommends the unsafe and ineffective cleanup recommendations of the NYC Department of Health (NYC DOH). The EPA web page from early October until this present day specifically states that schools, businesses, and residences should be cleaned using the NYC DOH methods.^’ Not only are these methods ineffective, they are also unsafe to those who follow them, as detailed in my December 3 and 19, 2001 memoranda.^"*

Dry-type HEPA vacuums do not remove asbestos from carpets

The NYC DOH recommends dry-type HEPA vacuum cleaners, even though the EPA has found that dry-type HEPA vacuum cleaners simply do not remove the asbestos from the carpeting any better than a regular vacuum cleaner, removing essentially none atall?^ Professional abatement firms recognize that dry HEPA vacuums are ineffective in removing asbestos. There is documentation of at least one certified asbestos abatement firm who removed and disposed of all carpeting which was over padding in common areas in an apartment building near Ground Zero, in recognition of fire fact that there was no way to remove the asbestos.^®

The same EPA studies also document the fact that even the wet-extraction HEPA vacuum cleaners are inefficient in removing asbestos from carpeting - only 60-70%.

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