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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 Page45 of56 b. Noncancer Pulmonary Effects

Several of the minerals detected contribute to fibrotic lung damage and may result In several diseases that reduce lung function Including silicosis, asbestosis, other mineral fibroses, emphysema, and other respiratory disorders. The mechanisms and pathology of these conditions are similar, and the effects of these agents may be considered at least additive. However, each material has a different toxicity based on the mineral properties of that material. Less bloperslstent materials, such as SVF, have the least long-term toxicity, and more bloperslstent material, such as asbestos, have greater long-term toxicity. In general, the order of toxicity may be SVF < mica < silica < asbestos, based on solublllty and availability for clearance. No factors currently exist to combine risk estimates for these different materials.

CONCLUSIONS

On the basis of the analytical results of samples taken between November 4 through December 11, 2001, and information collected during the sampling effort, the New York City Department of Health and Mental Hygiene and the U.S. Agency for Toxic Substances and Disease Registry make the following conclusions (not In order of Importance).

• 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 transmission electron microscopy (TEM) and scanning electron microscopy (SEM). The TEM and SEM results Indicated that neither asbestos nor SVF contributed to the elevated fiber counts.

· Low levels of asbestos were found In some settled surface dust, primarily below Chambers Street. Many of the lower Manhattan locations sampled had been previously cleaned prior to this Investigation. No asbestos was detected in the comparison Indoor dust samples taken north of 59th Street. The City of New York has conducted follow-up activities at the locations where asbestos was detected In settled surface dust. Only two follow-up locations, outdoor areas, required professional asbestos abatement. Following-up activity at the other locations did not find any asbestos containing materials.

• When compared with the results obtained from the comparison sampling locations, the lower Manhattan residential areas sampled by this Investigation tended to have a greater percentage of SVF (primarily fiberglass), mineral components of concrete (quartz, calcite, and portlandlte), and mineral components of building wallboard (gypsum, mica, and halite) In settled surface dust. However, the frequency of detections and prevalence patterns of these minerals are similar In both residential areas.

• Exposure to significant amounts of synthetic vitreous fibers (SVF), mineral components of concrete (quartz, calcite, and portlandlte), and mineral components of building wallboard (gypsum) may cause skin rashes, eye Irritation, and upper respiratory Irritation) all of which have been voiced as concerns by

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

NYC-WTC_000146705

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NYC-WTC_000146705Source: NYC Law Department, mirrored locally

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