Letter re: EPA/DEP WTC dust cleanup at 114 Liberty Street,

NYC 9/11 Public Portal Document

9

On 9/14/01, EPA Region 2 evacuated its office building at 290 Broadway in lower Manhattan because it found traces of asbestos in settled dust. The tests were only qualitative - EPA had no idea how concentrated the asbestos was. EPA only knew there was asbestos at some undetermined level. For all EPA knew, it could have been at levels lower than background. The thickness of the dust was so small that there was not enough for testing actual concentrations.

But this was enough to set off a panic by EPA Region 2 to evacuate its building for two weeks for professional abatement. EPA also bought respirators for its own employees.

What is relevant is the fact that all the many, many air tests at 290 Broadway from September through December showed no asbestos at all above the detection limit, with one exception: In one TEM air test, the level was 25 structures per square millimeter (25 s/mm^), right at the detection limit, and far below what EPA was telling the public was safe (70 s/mmO. In press statements at the time, EPA clearly stated that the air concentrations at its building at 290 Broadway were safe. However, EPA Region 2 was silent to the press about the fact that it had found asbestos in settled dust at 290 Broadway.

It is a double standard for EPA to now claim that the dust testing at 114 Liberty St. by the residents is irrelevant to risks. The risk from settled dust may not be accurately quantifiable to exact risk levels, but it does clearly represent a risk. EPA policy and government statutes state that any exposure to asbestos is unsafe.

The EPA IG report also noted EPA’s unusual abatement procedures at its 290 Broadway building:’ EPA's Region 2 office, about a half-mile from the WTC site, was evacuated and not re­ opened until 2 weeks after the attacks.... On September 13,2001, EPA tested for asbestos in its building located at 290 Broadway.

See Section N of my 7/4/03 report for a complete description of the testing, evacuation, professional abatement, and press statements about EPA’s Region 2 ofBces at 290 Broadway.’® Note that Appendix K of the 8/21/03 EPA IG report contains incorrect information about the 290 Broadway air test results, incorrectly stating that elevated asbestos levels were found in some air tests. See the references for a detailed explanation."

EPA Inspector General believes EPA should consider settled dust levels for risk assessment

The EPA Inspector General (IG) also does not agree with EPA that settled dust test levels should be ignored, and recommended that EPA develop a standard to establish risk levels for settled dust tests

We believe EPA should ... develop health-related screening levels for asbestos in dust K- factors

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