NYC 9/11 Public Portal Document
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NOU-12-2002 16:47 FROM US ERA REGION 2 ORC TO 917135954544 ^04/05
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relative potency compared to benzo[a]p>Tcne,; which is the mosftoxic of the PAHs. The TEF procedure
generally uses '/a of the detection limit in*the calculations when the reported value is below the detection
limit. As the results from 125 Cedar Street were all non-detect, the TEF calculations yield a value of 580
gg/m’ when calculated using /2 the detection limit. The PAH data set would have been more robust had
the detection limit been set at 2.5 /ig. If a detection limit of 2.5 /zg would Irave been used, the TEF
calculations would have yielded a value of 290 assuming that the samples remained as non-detect.
This distinction is important because tire numeric criteria presented in the COPC document is 300 iiQ/'m". .
In an attempt to make an informed evaluation of the PAH data from 125 Cedar Street, a comparison was
made to PAH data which USBPA collected from 110 Liberty Street, The PAH data from 110 Liberty'
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indicated that the concentration of the seven PAHs used in the TEF calculations were primarily non-
detect at a detection limit of 2.5 /xg-' This indicates that even if a lower detection limit was used at 125
Cedar Street, the results would likely indicate non-detect for the PAHs, similar to what was observed at
110 Liberty Street. In addition/spme of the PAHs that are not included in the calculation of TEFs (i.e.,
non-carcinogenic PAI-Is) were the most frequently detected PAHs at 110 Liberty and were detected at
concentrations above 5 gg. The non-carcinogenic PAHs are not included in the TEF calculations because
they arc less toxic than the carcinogenic^PAHs, therefore identification of a non-carcinogenic PAH would
not increase the TEF value. Thus, it would be expected that some of the non-carcinogenic PAHs would
have been detected above 5 fig if they were present at 125 Cedar Street. The combination of these two
factors provides evidence tliat the data collected at 125 Cedar Street can be accepted even though the
detection limit was not as low as it could have been. In addition, the pre-cleaning PAH results are similar
I to the results observed at 110 Libeify Street. The post-cleaning PAH samples at 110 Liberty Street were
all below the numeric criteria as well. Therefore, even though the post-cleaning samples from 125 Cedar
Street were not evaluated, it is expected’that the samples will all be below the numeric criteria based on
I the pre-cleaning samples being below the criteria and the .similarity to wbat was observed at 110 Liberty
Street. Thus, for PAHs, the data we reviewed indicates that PAHs arc not a hazard at 125 Cedar Street.
Dioxin - Tire analytical data for dioxinfthat was reviewed consisted only of pre-cleaning samples. Post
cleaning samples were also collected, however the analytical results are not available at this date. When
the analysis is completed for the post-cleaning samples, USEPA will review the data. We reviewed 66
wipe results which were analyzed for dioxin. Evaluation of dioxin results is similar to that reported above
I for PAHs in that the results for individual congener groups arc adjusted and summed to provide toxic
equivalency for 2,3,7,8-TCDD, the most toxic dioxin congener, using a process called toxic equivalents
t (TEQs). .Similar to the PAH data the TEQ calculations use '4 of the detection limit in tire TEQ
calculations. The detection limit was acceptable and all of the samples met the numeric criteria of 4
ng/m*. The pre-cleaning dioxin results ^’e similar to the results observed at 110 Liberty Street. The post
cleaning dioxin samples at 110 Liberty Street were all below the numeric criteria as well. Tlrerefore, even
though the post-cleaning samples from 125 Cedar Street were not evaluated, it is expected that the
samples will all be below the numeric criteria based on the prc-cleaning samples being below' the criteria
and the similarity to what was observed’at 110 Liberty Street. Thus, for dioxin, the data we reviewed
indicates that dioxin is not a hazard at 125 Cedar Street.
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Lead - Wc reviewed approximately 72 wipe sample results which were analyzed for lead. There were 10
samples that were above the numeric criteria, of 25 pg/ft^ listed in the COPC document. The apartments
I which exceeded the numeric criteria were 12N, 1 IN, IOS, ION, 9N, 8S, SN, 3S, and 2S. These
apartments were recleaned and retested'(14 samples). Six units met the numeric criteria, however three
units (12N, 1 IN, and 1 OS) did not meetVne numeric criteria. These three units were recleaned and
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retested. Apartment 12N and IOS met the numeric criteria after the second cleaning. Apartment 1 IN did
not meet the numeric criteria and required a third cleaning. The results for apartment 1 IN after the third
I cleaning were below the numeric criteria. Thus, for lead, the data we reviewed indicates that lead is not a
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hazard at 125 Cedar Street. - ।
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NYC-WTC_000156091
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