Environmental compliance log and action tracking sheet

NYC 9/11 Public Portal Document . . ...

Predicting air levels if cleanup is inadequate

Air levels might also be predicted if the cleanup is inadequate. As discussed in my December 6 , ; j •i memorandum, the EPA determjhed that neither convcntfonal nor HEPA vacuums were capable '' ; " ' ’ of remoWng sigriificSit amounts of asbestos frpm cMpet. Only the wetrextraction HEPA ‘ ' vacuums removed the asbestos particles which adhere to the carpeting,’ Even the wet-extraction ; , ' THEPA vacuums did not remove all ofthe asbestos; only about 60%.; . .<

Thus, dip same or similar levels of asbestos could remain in the cmpets as their were before the ,t cleanup. After cleanup, the air levels could remain as high as projected in Table 2. The dust in / ‘u. u; v,', ' ■ both of the apartments in the Ground Zero Task Force study (Table 2) was not that thick, only a . • ‘ ';" ’ , '■ ‘ fine dusting where you could still read the writing on papers on a table even in the high exposure'' ; ’ , building.. This small amount of dust could easily work its way into the carpet and remain.

(I have been informed thattypically, in asbestos abatement, carpeting is removed and discarded \ b. ' __ because of the inability to remove all the asbestos. More documentation on recommendations .'7,. and this practice is requested. Information on actually testing or test methods for asbestos •, j . f' contaminated carpeting is also solicited, [email protected]) ,MOst<s®tsfisis«#sisy \ CALCULATING TOTAL DOSE FROM ATSDR’s ' ' b,/ ’’ ’ t/ ' * , ''

EIE to be related to heaWi effects ;J ; Cnmulative, or total dose, found by ATSDR , .

p, 7-' B\ The Agency for Toxic Substances and Disease Registry (ATSDR) is part of the Centers for ,, Disease Control. It develops toxicological profiles in response to the Comprehensives f .. Mil k. -i.:., <; Environmental Response, Compensation, and Liability Act (CERCLA, or Superfimd). These . f. -— '. profiles are subjected to extensive review by the most prestigious scientists as well as being / i. s iT - r i reviewed and commented upon by affected industries and the public. The ATSDR found that the KV' ’ - ‘ ri? ‘ '. “cumulative exposure,” or total dose, was valid for predicting the probability of suffoing health Lr - , \ effects fi-om asbestos. There was no “threshold” or safe level.’ • Lr/sf V. .... .. , A number of researched have found that the occurrence of asbestosis and lung cancer correlates . , ~ , '5 - with cumulative exposure (that is, the product of concentration [PCM fIbers/mL] multiplied by , iiiii® exDosures are expressed -j■ Ayears of exposure). Therefore, human exposures exoressed below as PCM f.yr/mU f-vr/mb ., .. feSli .- '"■ < [A] number of other studies indicate that lung cancer risk is linearly related to cumulative dose without any obvious threshold ^ssiWSffisrKSaB’wWiftBSaS/SHSSSiSS B«S«as? In other words, it does not matter whether Or not you got the same total dose over a short period 1, ; of time at higher levels, or a long period of time at lower levels. The health effects will be the ; same. The ATSDR does explain that there is no absolute coirelation of the total dose with health *• { effects, but uses it as a valid method to evaluate health risks.

liiffcTable 3 lists some of the “cumulative doses” found by the ATSDR to be associated with asbestos '........' health effects. The table also gives examples of what the air asbestos levels are required for different time periods to achieve this dose. . - ill! ; , . ; . FILENO.A74983669 EXHIBIT # IW VJ

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