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DEP WTC General Correspondence Form

Machine-extracted title · confidence 70%

Generic form or header page from the Department of Environmental Protection regarding general World Trade Center notices and requests.

NYC-WTC_000149798–000149882

Folder label: “GENERAL 2

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Scanned page image, NYC-WTC_000149850
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OCR status: ok · source: pdftotext

NYC 9/11 Public Portal Document

New York City Department of Environmental Protection

Comments on the Clearance Criteria

According to the information in the ERIS database and USEPA web site, the USEPA “estimates that breathing air containing 0.0004 free 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 counts 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 from 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.

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N YC-WTC_000149850

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NYC-WTC_000149850Source: NYC Law Department, mirrored locally

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