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NYC Law Department letter regarding EPA draft report excerpts, July

Machine-extracted title · confidence 100%

Correspondence from NYC Corporation Counsel providing comments on excerpts of a draft EPA evaluation report regarding the WTC response.

NYC-WTC_000146129–000146748

Folder label: “EPA OIG LAW

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NYC 9/11 Public Portal Document

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2) Fcdcrai Hall; 26 Wall Street 01 possiblj across the street at 23 Wall Street 3) *Pace University, 1 Pace Plaza, 10038-1502 4) 26 Federal Plaza and old eomt home wheer radiation site is estab lishcd S} * US Wot th Sta eet (State 01 cit) bldg} 01 next door at tha ee Louis J. Lefkonitz Building 6) * Manhattan Doro Community College, 199 Chambers Street 7) Stll) "saut Higli School ~C=OEM Conmiand Post) 8) Batter) PL Apm tmeut Cornplex 9) * Coast Guard Building, Battery Park area (south Manhattan) 18} **Canal Sta eet Post Office Three Four sites which give the best geographical presentation of the area will be selected, if possible. • recommended based on access and power...

General zone: Existing NYSDEC NJDEP Monitoring Locations w/ TEO MS (mark the TEOMsl

1) Ps 154 - 333 East 135 st Bronx, NY 2) IS 143 - 511 W 1821111, NYC, AIRS Site Code 36-061-0115 3) PS 274 - 800 Bushwlck Avenue, Brooklyn, AIRS Site Code 36-047-0118 4) PS44 In Staten Island, 80 Maple Parkway 5) PS 199 3290 43• Ave, Queerui, NY, AIRS Site Code 36-081-0116 6) Liberty State Park, Jersey City; 7) Rahway, NJ; Landfill To be determined.

Issues/additional requests:

1. Ongolng••Asbestos sampling time and analytical procedure

ERT technical staff have recommended changes in sampling period and analytical method to alleviate strain on laboratory and field personnel. These recommendations include 1) reducing the sampling period to 1 8-12 hour (depending on loading) sample per day starting in the Sam time frame at all ground zero sites and the new near zone and general zone locations, and 2) performing only 1 analytical technique (TEM or PCM) to ensure commonality across sites and reduce laboratory burden. Technical staff believe that daily sampling over an 8 12 hour period combined with the addition of 11 near and general zone sites will provide greater characterization of asbestos than the current attempt at 24 hour sampling just in the ground zero zone. This Issue needs resolution.

Options:

1. Preferred: reduce to ·I 8-12 sample and PCM (and store PCM filters for potential TEM ~lysis based on action level as recoimmended by ASTOR) or TEM (including PCM equivalents ifTEM chosen)

2. reduce to 1 8-12 sample and perfonn both PCM and TEM

3. Immediately reduce to option 1 or 2 until resources and consensus developed to perform 24 hour sampling and both TEM and PCM. (NOTE: just adg!ng operators may create a bottleneck in escort and access logistics).

4. Follow preferred option (and variants of) with small number (e.g.; Sin ground zero zone only) of24 hour sites that perform PCM and TEM

2: ASTDR bas requested indoOr sampling for asbestos before buldlng reentry and toxics sWcates analysis

3. Sampling scale down plan based on data results

NYC-WTC_000146535

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NYC-WTC_000146535Source: NYC Law Department, mirrored locally

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