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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 Page9 of56 Air Sampling Results

Total fiber counts of air samples taken in lower Manhattan were similar to the comparison areas above 59th Street sampled during this investigation. The six lower Manhattan areas that had elevated total fiber counts were re-examined by TEM and SEM to determine the types of fibers. The TEM and SEM results Indicated that neither asbestos nor synthetic vitreous fibers (e.g., fiberglass) contributed to the elevated total fiber counts.

Air sampling results for minerals detected quartz (a form of crystalline silica) and other building-related materials In lower Manhattan. The other forms of crystalline silica were not detected In any air samples except for a one-time detection of crlstoballte. The estimated concentrations of these minerals In air were low. In some locations, mineral components of concrete (quartz, calcite, and portlandlte) and mineral components of building wallboard (gypsum, mica, and halite) were detected In air samples at higher estimated levels In lower Manhattan residential areas than In samples taken at comparison residential areas above 59th Street. The levels of minerals seen In airborne dust do not pose potential health hazards even for a continuous year of exposure at the highest levels detected.

Settled Surface Dust Results

Results of the settled surface dust analysis Indicate the composition of settled surface dust In lower Manhattan Is different than the dust analyzed from the comparison areas above 59th Street. Although the materials found are consistent with materials expected from the World Trade Center collapse, these results cannot determine the actual source of the materials present because these materials are common building components and can come from other sources In a busy urban area.

In lower Manhattan, asbestos was found In Indoor dust In 15 of 83 (18%) samples from residential units and common areas at levels ranging from less than 1% (<1%) to 1.5%. Asbestos was detected in 6of14 (43%) outdoor samples at levels ranging from <1% to 3.4%. Indoor settled surface dust contained SVF In 40 of 83 (48%) locations ranging from 2% to 35% of the dust content. SVF was detected In 11of14 (79%) outdoor locations at levels ranging from 1% to 72%. No asbestos or SVF was detected in dust In the comparison areas above 59th Street.

The XRD analysis for crystalline minerals In settled surface dust is semiquantitative (estimated values, Indicated by "Jn). However, quartz, calcite, portlandlte and gypsum appear to make up a higher percentage of dust In some buildings in lower Manhattan when compared to settled surface dust samples from buildings above 59th Street. Quartz was detected up to an estimated 31%J versus up to 2%J found in the comparison areas above 59th Street. Neither crlstobalite nor trldymite was detected In any of the settled surface dust samples. Similarly gypsum was found at a maximum estimated concentration of 300/oJ In settled surface dust, higher than the 4%J estimated In the comparison areas above 59th Street. Calcite and portlandlte had maximum concentrations of 21%J and 8%J respectively. At lower Manhattan

http://www.atsdr.cdc.gov/asbestos/lowermanhattan/ResSamp_Sep2002_Text.html 07/18/2003 NYC-WTC_000146669

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NYC-WTC_000146669Source: NYC Law Department, mirrored locally

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