NYC 9/11 Public Portal Document
TO 917185954544 P.08/08
.JUL-29-2002 17:57 FROM US EPA REGION 2 ORC
Notes
1. As I noted in my April 25 letter, while the NCP authorizes EPA to take actions to address the
release and threatened release of a hazardous substance into the environment. Section
300.400(i)(3) of the NCP states, “Activities by the federal and state governments in
implementing this subpart are discretionary governmental functions. This subpart does not create
in any private party a right to federal response or enforcement action. This subpart does not
create any duty of the federal government to take any response action at any particular time.”
2. Many have commented that this risk range, used for remedial sites under CERCLA, is the one
that should apply to the indoor Air Residential Assistance Program - World Trade Center Dust
Cleanup Program. As discussed elsewhere in this letter, EPA has developed a particularly
stringent clearance level for asbestos in lower Manhattan residences. Nonetheless, for the
following reasons, even if this were a remedial site, the 1 O'* cancer risk - which is a “point of
departure” referenced in the NCP - would not he used because it is impracticable to achieve. All
protocols chosen for the Indoor Air Residential Assistance Program - World Trade Center Dust
Cleanup Program are designed to reach the lowest level of detection that is reasonable with
established methods. For asbestos, the sampling and analytical protocols chosen are designed to
attain risk estimates of 1 x iOA To reach estimates of-1 x l O'*, extraordinary modifications
would have to be employed to either significantly increase the volume of air being sampled or-to
go to extraordinary expense to analyze many more grids on each sample filter. An increase in the ,
sample volume, through an increase in flow rates fiom 10 to 15 liters/minute to 500 to 1,000 -
liters/minute would lower the detection level. However, the only equipment available to operate
at these rates are large units that are impractical to bring into a residence. Achieving flow rates
this high has not been tested using the sampling protocols, and there would be a high likelihood
of compromising the sampling filters. To achieve detection levels consistent with 1x10'* risk
values by running the equipment for longer periods of time would require increasing the period
of sampling from 8 hours to 33 days. These two issues make it impractical to achieve a 1 x 10'*
detection level.
TOTAL P.08
NYC-WTC_000144809
OCR can misread numbers and units. Confirm readings against the page image before using them.
NYC-WTC_000144809Source: NYC Law Department, mirrored locally
A project proposal outlining the timeline, methods, and justification for cleaning HVAC systems in residential units affected by World Trade Center dust.
Joint announcement of a comprehensive plan by the EPA and city partners to address indoor air quality concerns in residential units south of Canal Street.
EPA Region 2 responds to a congressional inquiry about the joint EPA-DEP program for testing and cleaning lower Manhattan homes after the WTC collapse.
An EPA memorandum discussing asbestos wipe sampling, projected airborne levels from settled dust, and estimated cancer risks for World Trade Center cleanup scenarios.
An EPA memorandum discussing asbestos wipe sampling, projected airborne levels from settled dust, and estimated cancer risks for World Trade Center cleanup scenarios.
EPA Region 2 response to inquiry about the joint EPA-DEP World Trade Center residential dust cleanup and testing program funded by FEMA, noting approximately 5,300 requests…
EPA Region 2 responds to a congressional inquiry about the joint EPA-DEP program for testing and cleaning lower Manhattan homes after the WTC collapse.