NYC 9/11 Public Portal Document
MAY-29-2002 21:26 U.S. EPA/DEPP 212 6373772 P.08/08
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fibrogenic activity, while short fibers have lower fibrogenic activity. This relationship may be
associated with the inability of macrophages to engulf and remove fibers that are significantly
larger than themselves.” However, this same reference also states: “Results from human studies
suggests that short asbestos fibers also may be important in causing pulmonary fibrosis. These
studies showed that, in groups of chrysotile miners and millers and amosite-exposed shipyard
and insulation workers with asbestosis, histologically-graded fibrosis was positively correlated
with mean fiber concentration in lung tissue, but was negatively corelated with mean fiber
length.” More research is reeded on the role of short fibers (5' um and less) in asbestosis
induction. It should be noted, however, that the AHERA standard of 70 frmm2 (which counts
fibers >.5 um) is well below the asbestos concentration associated with asbestosis.
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15. (Cancer risks for Libby compared to Lower Manhattan)
Issue - Risk calculations from the Libby Endangerment Assessment (12/20) are enmpared to
risk estimates from hypothetical scenarios at thi WTC,
Response - The risk calculations from the Libby Endangerment Assessment were based on
actual asbestos air sampling results (analyzed by TEM) which were subsequently converted to
PCME fiber counts. Risk calculations for hypothetical exposure scenarios associated with the
WTC have been performed and were based on the asbestos load (f/cm2) of settled dust, rather
than air samples. As previously mentioned, the relationship between asbestos concentration in
settled dust and ambient air is highly variable and depends on dust re-entrainment potential and
ambient conditions (e.g,, air exchange rates) as well as asbestos load (f/cin2). In addition, since
there was no air sampling for the WTC risk calculations, the conversion to PCME relied on
limited indoor sampling data from secondary sources to’arrive at a PCME estimation of 20% of
total TEM fibers. The 20% value represents the upper bound of the range (1.3% - 20%) of
correlations between PCME and total TEM fiber counts from the aforementioned indoor
sampling data, Tliousands of asbestos air samples in the ambient air collected by EPA since 9/11
indicate that PCME is less than 10% of total TEM fiber counts.
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TOTAL P.0S
NYC-WTC_000148138
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