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NYC Law Department letter regarding EPA draft report excerpts, July

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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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the listing of Air Monitoring Sites. It Is listed as a general zone location on the able of entitled "Draft Ambient Air Monitoring Plan Status - Draft Near zone and General Poplulation Zone Site Status."

11. Silicate dust Is listed as a monitoring parameter. We are assuming this is crystalline silica rather than silicate dust. We recommend that the monitoring method for crystalline silica be NIOSH Method 7500, as given in the NIOSH Manual of Analytical Methods.

.12. The overview of the plan has crystalline silica (replaces silicates) being monitored at 6 locations (A - S) in the work zone. We are assuming that all 6 locations will be in the work zone although some of the locations from A - S are outside the work zone. If the crystalline silica (replaces silicates) are elevated, we recommend monitoring for silica in the near zone area. Suggested sites: A. C, E, F, K for starters.

13. We assume that the levels of Interest table will be consistent with the tables that CDC/ATSDR and the EAWG are developing. Those tables need to be constructed to allow some judgement In Interpreting the results since we expect contaminant levels will vary and that variation will have to be considered (i.e. one high concentration compared to a level of Interest at one location in only one sample should probably not be Interpreted the same as a relatively small, but constant exceedence, at several locations). This Is required because neither the plan nor the level of Interest table provide guidance In how to interpret multiple sampling results (multiple locations, multiple days). We recognize that it Is probably impossible in the plan or tables to provide guidance that fits all situations ..

14. We recommend considering obtaining CO measurements In the near zone, given the levels that are being found in the work zone.

CC: <[email protected]>. <[email protected]>. <[email protected]>. <[email protected]>. <[email protected]>. "G. Anders Carlson" <[email protected]>, "Robert L.Chinery"<[email protected]>, "Edward G. Hom" <[email protected]>, "Daniel A. Luttinger" <[email protected]>

NYC-WTC_000146553

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NYC-WTC_000146553Source: NYC Law Department, mirrored locally

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