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EPA report review comments, April 2003

Machine-extracted title · confidence 95%

DEP staff requested to review EPA draft report on WTC exposure and sampling issues for legal comment.

NYC-WTC_000163101–000163102

Folder label: “E-mails 2003 M. Gilsenan

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NYC 9/11 Public Portal Document

attachC'^to them or very fine particles composed of unusual combinations of silica coalesced with lead or other toxic materials."

My questions to EPA would include: What is the relationship between particle configuration and location of exposure (indoor vs outdoor)? What about the issue of source strength (amount of material that would have been entrained in a typical indoor apartment)?

page 8 bottom "Limited available evidence suggest the incursion of asbestos to the indoor environment. A small study which sampled the indoor environment of two apartments on September 18 showed very high indoor levels of asbestos"

There is evidence (including the DOH/ATSDR indoor study) that would indicate that the two apartments mentioned above are outliers and do not represent the vast majority of indoor spaces in Lower Manhattan. In any event, a sample size of two would not be large enough to justify EPAs conclusion.

page 11 top "Difficulties associated with site access and security, power supply sources, equipment availability and analytical capacity hindered efforts by EPA and the NYSDEC to put air monitors in place immediately after the attack...other contaminants were not sampled until September 23, such as dioxin."

My experience with EPA is that the reasons given are inadequate for an extraordinarily long delay (given events). However, I think it would be more appropriate for OEM to respond. I have sent it to OEM and will followup with them today.

page 33 top "They (Lioy et al) also noted that penetration of substantial quantities of WTC-derived dust into indoor office or residential spaces likely notably increased the potential for indoor exposures (via ingestion or by inhalation of re-entrained particles) to high levels of constituent elements and compounds."

What is the basis for this statement?

The document is technically rigorous and well written when documenting outdoor exposures but includes many such statements on indoor exposures with limited data to support them. I'm not sure we gain anything by pointing out the uncertaintly contained within them.

>» "Cohen, Jay" <[email protected] > 04/06/03 01:36PM >» Kelly:

Have you submitted comments on behalf of DoH concerning the EPA draft report that we talked about? If you have, can I get a copy of them? If you have not, are you going to submit and is there anything that I can help with. Please e-mail or call me at (212) 676-9219 as the deadline is April 7, 2003. Thanks.

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NYC-WTC_000163102

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