NYC 9/11 Public Portal Document
MAY-29-2002 21:22 U.S. EPA/DEPP 212 6373772 P. 03/08
lead role on building clean-up and re-entry and has performed a follow-up investigation of
asbestos contamination at 105 Duane Street.
3. (Comparison of Libby and Lower Manhattan data)
Issue - Asbestos concentration in WTC (Ground Zero Task Force Report, 10/12/01) apartment
dust (lZcm2) is 22 times higher than Libby interior dust samples.
Response - This statement is true in a very limited context, only. At Libby, PCM equivalent
fibers in surface dust were estimated using two different methods. The Phase 2 method included
only three samples (the highest value, 3.658 fZcm2, was in fact 22 times lower than the highest
value 79,000 f/cm2 at WTC). However, the Phase 1 method (which included 25S samples, and is
closer in approach to die methodology used at WTC) recorded a value of22,645 fZcm2, over 6
limes higher than Phase 2 results. When the total of all dust samples from Libby are compared to
WTC dust samples, the max’mum values differ by a factor of less than 4. It should be noted that
it would be n-ore appropriate to compare average values rather than maximum values but neither
the WTC Ground Zero report or the Libby Endangerment Assessment provided this information.
More importantly, the WTC-impacted apartment (45 Warren St.) was vacant and unremediated.
Hence, the concentration of asbestos in dust is not representative of actual or long-term
exposure.
4. (Comparison of Libby and Lower Manhattan data)
Issue “ Why is EPA leaving people to their own devices in the cleanup of NYC, while
intervening to clean homes at taxpayers expense in Libby because of an ‘imminent and
substantial endangerment to the public health’?
Response - First, the comparison of these situations has limited usefullness; the sites are not
alike in many respects. Tn Libby, potential long-term risks are being evaluated under a “no action
scenario” to support inclusion on the National Priority List (NPL). NPL listing will enable
Superfund trust monies and legal authorities to be used in order to assess years of widespread
asbestos contamination resulting from past mining activities. Il also provides a means to evaluate
remedial options that may be necessary. At WTC, EPA is part of a multi-organization team
under the auspices, in a federally declared disaster, of the Federal Response Plan responding to
an emergency of unforscen magnitude. Emphasis has been directed toward minimizing the
envirommental impact through a rapid and comprehensive remediation of WTC-related
contaminants. Consequently, long-term exposures are not anticipated because die source material
(building remnants r ud residual dust/debris) is being removed. To assess the impact of the Trade
Center collapse, EPA has performed extensive ambient air monitoring for asbestos (24 hours a
day, 7 days a week) throughout the WTC area. The City of New York has taken the lead to
address indoor asbestos contamination and has partnered with the Agency for Toxic Substances
and Disease Registry (ATSDR) to conduct a study of asbestos and other mineral fibers inside
buildings. EPA has provided support for this study.
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