EPA memorandum on WTC dust wipe sampling and cancer risk

NYC 9/11 Public Portal Document TO 917185954544 P.06/08 JUL-29-2^2 17=55 FROM US EPA REGION 2 ORC

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We are responding to residents’ concerns in a manner consistent with the NCP. [See, for example, Section 3C0,415(n) of the NCP, 40 C.F.R. § 300.415(n) (“Community relations in removal actions”).] hi brief:

(a) we have designated spokespersons for our programs related to the attack on the I WTC, who respond to inquiries and keep the community informed regarding our actions. They will make available data related to indoor air concerns in lower Manhattan, providing such data in a manner that does not divulge the address of a given residence or the name of a given resident;

(b) we have been meeting and will continue to meet with public interest groups or other interested or affected parties, as appropriate, to solicit their concerns and information needs, and find out how or when citi2ens would like to be involved in the process; i (c) we are preparing a communications strategy which will address many of the concerns raised in the meetings with community members and other relevant infonnation and will specify the community relations activities that we expect to 1 undertake during the Indoor Air Residential Assistance Program -WTC Indoor i Dust Cleanup; and

(d) we have established at least one local information repository in lower Manhattan (290 Broadway) wliich is accessible to the public. At that location we will make available documents wliich have formed the basis for our actions. I Working with the city we have made changes to the scope of work which will fonn the basis of the city’s’contractor solicitation for the cleanup and testing program based on concerns raised by interested members of the public.

We have developed the clearance level (that is, the risk-based clean up goal) to detennine when cleaning can cease at a residence under the Indoor Air Residential Assistance Program -WTC Dust Cleanup. The development of this level has been consistent with the NCP. For example, under the NCP, removals performed either by EPA with Superfund monies or by responsible parties need to attain applicable or relevant and appropriate requirements (ARARs) “to the extent practicable considering the exigencies of the situation.” [Section 300.415(i) of the NCP, 40 C.F.R. § 300.415(j).] For the Indoor Air Residential Assistance Program -WTC Dust Cleanup, it was determined that there were no directly applicable standards. So, as is a common practice in removal actions under the NCP, 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 assure that this level represents an extremely protective long-term risk guideline.

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