EPA memorandum on WTC environmental data concealment, July 2004

NYC 9/11 Public Portal Document

Any "overload" results should be presumed to be higher than 70 s/mm^ for two reasons. First, "overload" means that there was such an excess of particulate material on the collection device that the laboratory could not even make a reading, meaning there was a high level of all particulates, including asbestos.

Second, whenever there were "overload" results from the TEM tests in early days, the corresponding tests at the same location using a light microscope (PCM) were much higher than the PCM levels where asbestos was verifiably over 70 s/mm^. In other words, paired tests looked like this:

TEM electron microscope result PCM light microscope result Location A 45 s/mm^ 0.010 f/cc Location B 157 s/mm^ 0.040 f/cc Location C overload 0.080 f/cc

Even if the "overload" results are ignored, then 18% of the 87 tests (16 out of 87) between 9/12/01 and 9/29/01 were over 70 s innT . This is significant.

In contrast, in its 10/3/01 press release, EPA claimed that only 6% (27 out of 442) air samples IN THE IMMEDIATE VICINITY of Ground Zero were over 70 s/mm^.

Summary of deletions and alterations of the original NYC data

The Appendix to this memorandum compares the two different versions of the same NYC data.

Tests above 70 s/mm^

NYC altered 6 of the original test results that showed asbestos over 70 s/mm^. NYC altered the data by either deleting the sampling location and accompanying data altogether, claiming that no asbestos was found (below the detection limit), or claiming that there were no TEM tests at the particular location for that day.

"Overload" tests

NY C altered 11 of the results that were overloaded. Overload means that there were such high levels of asbestos and other particulates in the test device that asbestos could not even be counted. As discussed earlier, overload samples are presumptive of concentrations over 70 s/mm“. NYC altered the data by either claiming that no asbestos was found (below the detection limit), or claiming that there were no TEM tests at the particular location for that day.

Tests where asbestos found, but below 70 s/mm^

NYC also altered the tests results where asbestos was found in the air, but found at levels lower than 70 s/mm^ . This is highly significant as well, because NYC as well as EPA were claiming that there was no detectable asbestos in most instances. The altered version of the

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