NYC Law Department letter regarding EPA draft report excerpts, July

NYC 9/11 Public Portal Document

pt. 25,2001 monito~ng pl.a~ ..·.

•Nancy K. Kim• <[email protected]> <[email protected]>, <[email protected]> 9/27/0110:57AM EPA Sept. 25,2001 monitoring plan

rm not sure who should be getting these comments. but here are NYS DOH's comments on EPA's Sept. 25th sampling plan.

1. It appears the voe monitoring is at only 3 locations outside the hot zone. Is the sampling intended for non-worker exposure and residential exposure to VOe's? If so, there should be more areal coverage. The sampling frequency is 2/day, are these grab samples? If so, they won't give a good indication of the exposure for the day. The Plan mentions voe canister sampling in passing but gives no details on location and the. number of samples. 24 hr. canister sampling may be better for the purpose of non-worker exposure measurements. It isn't clear from the plan if the 3 locations for voe monitoring are inside or outside the work zone; our interpretation of the plan is that they are inside the work zone. Therefore, we recommend that voe sampling be added to the near zone monitoring since voes have been deteded on site at high levels and the community is concerned about them.

2. The PM1 O measurements appear to be 24 hr. filters with a four day tum around. The emphasis should be on TEOM continuous sampling for PM 10 as it is for PM 2.5. PM continuous data RAMS samples for dust control advisement are being taken at the landfill zone. Shouldn't the same be done for the WTC work zone area at street level? ·

3. Some of the sampling locations can't be distinguished on the map.

4. The area between location H and Site 3 (lower east side) and south of a location (lower west side) does not have any samples being taken In it. This is a large area without any sample data for PM (10 and 2.5) and asbestos. Consideration should be given to expanding sampling In this area.

5. The heights of the samplers are not given in the plan and should be included in the plan.

6. Phosgene is an analyte. However, if the freon (chlorodifluoromethane) at the wrc Is heated, the fluorine analog or the chlorofluoro analog of phosgene is probably more likely to form than phosgene.

7. We would recommend removing the category of office workers from the tables providing information on levels of interest. Office workers should be considered in the same group as residents.

8. Background levels of analytical parameters should be included as a level of interest.

9. An additional site sbould be added between sites 1 and 3 in the near zone monitomg sites (e.g. betwen Pace Unitersity and Coast Guard Building), especially if the predominant wind diredion Is from the northwest. One way to address this concern is to do all near zone sampling at location I in addition to the work zone sampling.

10. The Canal Street Post Office site is be considered a near zone site in

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