EPA response letter regarding WTC dust program, March 2003

NYC 9/11 Public Portal Document

Enclosure 1 Notes

Note 1: We have developed the clearance level (that is, the risk-based cleanup goal) to determine when cleaning is effective in a residence participating in the Program. For the Program, there are not any directly applicable standards that have broad scientific support which correlate airborne exposure to dust containing hazardous substances. Accordingly, as is conunon practice in removal actions under the National Oil and Hazardous Substances Contingency Plan, we have developed a risk-based clearance number for asbestos in air, taking into consideration other standards. We have consulted with peers in the scientific community to confirm that the chosen clearance level is a protective long-term risk guideline.

Note 2: Initial personal air monitoring was performed by the Cleaning Contractors, in accordance with OSHA requirements, at a minimum of one employee per shift per residence per quadrant for the first 10 weeks of cleaning operations. Currently samples are being taken at one sample per quadrant per day. Results of this sampling are being provided to both the EPA and OSHA and are also available to the employees or their designated representative in accordance with 29 CFR 1910.1020 and 29 CFR 1926.1101.

Note 3; In a residence not meeting the clearance level where only testing was conducted, EPA recommends that the home be cleaned and re-tested. In a residence where both cleaning and testing were done, EPA attempts to identify potential sources of pollutants and then re-clean and re-test the home to meet the clearance level.

Note 4: I am informed that under New York State law, the use of PPE in asbestos projects is addressed in the New York State Labor Law and its implementing regulations, and in the Rules of the City of New York. PPE is required only for workers involved in “asbestos projects” or “minor asbestos projects” under DEP’s Asbestos Rules, and involved in“asbestos projects” under the New York State Labor Law.

Note 5: For instance, governmental financial assistance, including but not limited to grants and low interest loans for commercial property owners, was and still is available through the Small Business Administration, New York State Economic Development, New York City Economic Development Corporation, and FEMA. For further information on governmental funding for commercial and business properties, you may contact Joseph Picciano, Acting Regional Director, FEMA Region 2 at (212) 680-3609.

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