NYC-WTC_000209427

NYC 9/11 Public Portal Document

The sections in this memorandum include:

HOW TO USE ERA'S ULTRASONICATION EXTRACTION TEST

Finding a lab and submitting samples

Ideas for taking carpet and other fabric samples

ASTM microvacuum method is inadequate for carpets and other woven fabrics

NYC APARTMENT BUILDING USES ERA’S ULTRASONIC CARPET TESTING

EPA FINDS HERA VACUUMING DOES NOT REMOVE ASBESTOS FROM CARPETS, AND EPA POLICY ON CONTAMINATED CARPETS

Regulations and policy on replacing asbestos-contaminated carpet

RELATING ASBESTOS DUST LEVELS WITH HEALTH RISKS

ERA’S zero standard for asbestos in dust

Data showing background levels of asbestos in dust inside buildings

Estimating air concentrations and risks from settled dust levels

REGION 1's BENCHMARK - SETTLED ASBESTOS DUST - BROOKFIELD SCHOOLS

Description of Region 2's risk assessment for settled asbestos dust: Use of a “K-factor" to back-calculate dust levels from background air levels

Region 1 misrepresentation of background air levels and safety levels

Region 1 chose an inapplicable K-factor to justify a higher dust level

Region 1 failed to use real-world background dust levels

Re-calculation of Region 1 dust benchmark with more appropriate values

Brookfield School System and community rejection of EPA Region 1 benchmark of 45,000 s/cm^ for dust

ERA REGION 2 BENCHMARK OF 1% ASBESTOS IN WTC DUST

Region 2 cafeteria-style derivation of 1% asbestos dust standard from out-of-context NESHAP regulations

EPA has established that 1% asbestos is not a safe level

EPA always regulates toxic dusts on interior surfaces by the amount per surface area, not the % in a dust

Region 2 reverses 1% standard for settled asbestos dust

APPENDIX A - CHART FOR ESTIMATING AIR ASBESTOS LEVELS FROM DUST

APPENDIX B - ASBESTOS AIR CONCENTRATIONS AND RISKS

ENDNOTES AND REFERENCES

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