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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 12 of56 · A review of the building sampling results from this investigation Indicates that there Is not a consistent spatial distribution pattern of asbestos, SVF, mineral components of concrete, and mineral components of wallboard In air and settled surface dust. This Indicates that the materials are heterogeneously distributed. There are many factors that may contribute to the heterogeneous distribution, Including whether the area was cleaned (Indoors and outdoors), cleaning method, date since last cleaning, and how much dust was Initially In the area. It Is not clear which factors contributed to this pattern.

· Results from this Investigation do not necessarily reflect conditions that would be found In other buildings, at other times just following the collapse, or after the sampling period. The measurements reflect conditions present at the time of the sampling (November 4-December 12, 2001) In the buildings and areas sampled. The limited number of results obtained from the comparison areas above 59th Street may or may not reflect the New York City-specific background levels of asbestos, SVF, mineral components of concrete (quartz, calcite, and portlandlte), and mineral components of building wallboard (gypsum, mica, and halite).

Recommendations

Based upon the conclusions of this Investigation, the New York City Department of Health and Mental Hygiene and the U.S. Agency for Toxic Substances and Disease Registry make the following recommendations.

Because more asbestos, synthetic vitreous fibers (e.g., fiberglass), mineral components of concrete (quartz, calcite, and portlandlte), and mineral components of building wallboard (gypsum, mica, and halite) were found In settled surface dust In lower Manhattan residential areas when compared to comparison residential areas, the New York City Department of Health and Mental Hygiene and the U.S. Agency for Toxic Substances and Disease Registry are recommending that people continue to conduct frequent cleaning with HEPA vacuums and damp cloths/mops to reduce the potential for exposure.

· To ensure that the recommended frequent cleaning Is effective and to ensure that the health of the people of New York City Is protected, the New York City Department of Health and Mental Hygiene and the U.S. Agency for Toxic Substances and Disease Registry are recommending additional monitoring of residential areas In lower Manhattan. In addition, an investigation should be conducted to better define background levels specific to the city of New York for asbestos, synthetic vitreous fibers, mineral components of concrete (quartz, calcite, and portlandlte), and mineral components of building wallboard (gypsum, mica, and halite).

· Lower Manhattan residents concerned about possible World Trade Center-related dust In their residential areas can request cleaning and/or testing from the U.S. EnvlronmentalProtectlon Agency (EPA) by logging on to the agency's World Trade Center Web page at www.epa.gov/wtc or by calling the EPA hotline at 1-

http://www.atsdr.cdc.gov/asbestos/lowermanhattan/ResSamp_Sep2002_Text.html 07/18/2003 NYC-WTC_000146672

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NYC-WTC_000146672Source: NYC Law Department, mirrored locally

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