NYC 9/11 Public Portal Document
New York City Department of Environmental Protection
Comments on the Clearance Criteria
According to the information in the IRIS database and USEPA web site, the USEPA “estimates
that breathing air containing 0.0004 f/cc during a lifetime would result in not greater than a one
in ten thousand increased chance of developing cancer”. “Reference concentrations and
reference doses have not been established.”
The information on limitations in the IRIS database indicates that “alterations in the unit risk
invalidates and distorts their application in estimating the potential risk”. “The figure is based on
a lifetime exposure and may not be appropriately applied to less than lifetime exposure
situations.” The calculation to a 30-year exposure based on the information in IRIS may not be
valid.
“The unit risk is based on fiber counts made by PCM and should not be applied directly to
measurements made by other analytical techniques”. “The correlation between PCM fiber
counts and TEM measurements is very poor.” “The correlation between PCM fiber counts and
TEM fiber coimts is very uncertain and no generally applicable conversion factor exists for these
two measurements”. The adopted conversion factor was based on the geometric mean from data
sets that included both measurements and had a wide range of values for the conversion.
The collection of 4000 liters of air will result in clogged filters. In addition, the increased
sampling time and inconvenience to unit occupants should be considered. The laboratory effort
(interpreted fi-om the cost per sample increase) does not justify the increased air volume
collection. Based on conversations with laboratories, the cost per sample increase would be
between $15 and $25. The air sampling technician costs are typically in the range of $35 per
hour and the inconvenience to the concerned citizens is not measurable.
The 3-day turnaround time is high if we are to consider the receipt of elevated levels and need
for further action.
NYC-WTC_000149444
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