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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

Final Technical Report of the Public Health Investigation Page 7 of56 placed at each sampling location to collect different particle sizes Including resplrable (PM4 and PM2.5), thoracic (PMlO), and total lnhalable {PMlOO). This resulted In the collection of overlapping, or nested, particulate size fractions.

The particle size determines how deeply a particle can travel Into the respiratory tract. Resplrable particles with diameters of 4 microns or less (PM4) are very small particles that can be breathed In and can travel deeply Into the air sacs of the lung. At some locations another sampler was used that collected a smaller set of resplrable particles, those with diameters of 2Y2 microns (PM2.S) or less. Another sampler collected particles with diameters of 10 microns (PM10) or less. This sampler would collect not only resplrable particles, but also those slightly larger particles that tend to land In the upper regions of the respiratory tract, Including the throat. A fourth sampler collected a larger set of particles, those 100 microns (PM100) or less In diameter. The larger particles In this fraction can land In the nose and throat. Where a particle lands determines what types of health effects might be experienced. Particles too large to travel Into the narrower passages of the lower respiratory tract might deposit In the upper airways (e.g., the nose and throat) and cause Irritation. Similarly, larger particles might cause eye Irritation. If the settled surface dust contains sufficient amounts of particles of a very small size, then effects consistent with particles reaching the lower respiratory tract might occur (coughing, shortness of breath).

Each of the particulate air sample fractions was analyzed for crystalline minerals (quartz, crlstoballte, trldymlte, calcite, portlandlte, gypsum, mica, and halite). X-ray diffraction analysis (XRD) Identifies a mineral by the unique diffraction pattern given off when the x-ray strikes Its surface. The diffraction pattern serves as a "flngerprlntn to Identify the mineral present.

Other air samples were screened for fibers using phase contrast microscopy (PCM) to count the total number of all fibers present. If the concentration of total fibers was higher than the maximum concentration of fibers found In the comparison homes (0.003 fibers per cubic centimeter of air) the sample was re-analyzed for asbestos by transmission electron microscopy (TEM). Additionally, scanning electron microscopy (SEM) was used to look for SVF If the PCM fiber counts was higher than 0.003 fibers per cubic centimeter {f/cc) and If the settled surface dust sample from that area contained SVF.

Settled Surface Dust Samples The composition of settled surface dust reflects particles and fibers that have been tracked Into an area or that were present In the air and have with time, deposited on surfaces. Settled surface dust was collected indoors using a specialized vacuum cleaner. Outside settled surface dust was collected by scooping any visible dust-type material Into a container. As with the air samples, the settled surface dust samples were analyzed to assess the presence of fibers and minerals. The analysis performed does not allow the determJnatlon of what size particles are present In the dust. The composition of the settled surface dust was evaluated to

http://www.atsdr.cdc.gov/asbestos/lowermanhattan/ResSamp_Sep2002_Text.html 07/18/2003 NYC-WTC_000146667

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NYC-WTC_000146667Source: NYC Law Department, mirrored locally

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