LIBBY vs.

MANHATTAN – DIFFERENT ASBESTOS TESTING METHODS

2/14/02 – Cate Jenkins, Ph.D., Hazardous Waste Identification Division, EPA. Opinions/views are the author’s, not necessarily those of the EPA.
Peter Grevatt, Ph.D., Science Advisor, EPA’s Office of Solid Waste and Emergency Response, public statement on 2/11/02
that the same testing methods were used Manhattan after the WTC collapse as in the Libby, MT Superfund site. This is not
true, as seen from the following table. Less sensitive methods were used in Manhattan. Furthermore, EPA Region 2 in New
York refused the offer of EPA Region 8 (responsible for Libby) to provide more sensitive asbestos testing (SEM) in
Manhattan after the collapse of the WTC, explained below.

AIR TESTING METHODS

LABORATORY LABORATORY INSTRUMENT
INSTRUMENT
TEM - transmission electron microscope
PCM - phase Can find extremely small as well as larger “respirable size” particles

contrast
microscope
OS HA r equ ires th is old
metho d, which only dete cts
the la rger of the “res pirab le
size” particles (those over 5
micrometers long)
EPA loosely is calling any TEM method to be the “AHERA” method. This is to distinguish air tests using the TEM instrument from OSHA air tests using the
PCM method. The Asbestos Hazard Emergency Response Act (AHERA) actually only specifies one particular TEM method (leaf blo wer, professional
abatement). The difference between TEM methods is in the ways the air is actually sampled, as below:
DIFFERENT SAMPLING METHODS, SAME TEM LABORATORY INSTRUMENT
AHERA TE M Clearance TEM -- outside air, low TEM -- inside air, peo ple TEM -- ultra-low
Test sensitivity actually w earing air detection limits for
monitors on their belts. highest sensitivities
Neither Region 8 or Used by EPA Region 2 Used by EPA Region 8 Not used by Region 8 or
Region 2 used th is for Manhattan for Libby Superfund site Region 2
method
EPA regs, 40 CFR 763 App A Air monitors outside, at least Res ident s we nt ab out th eir Very large volumes of air over
7 to 8 feet o ff the groun d. normal activities, like cleaning longer time periods, and/or the
One-horsepower leaf blower Much higher than breathing house, picking young children laboratory analyst “reads”
before test, then fan to keep zone of a small child. Air up from carpeted floors, more area of the filter through
dust suspended. Because outside diluted. sitting beside children which the air was passed
leaf blower suspends jumping on couches, etc. during sampling.
thousands of times mo re Low sensitivity, high detection
asbestos than when no limit of 0.0083 s/mL, higher Region 8 found th at a Labs c an use this meth od to
activities to disturb dusts, the than the level of concern, simultaneous stationary dete ct as bes tos in air at le vels
air level for passing test is: 0.000004 f/mL (PCM ). monitors inside the same of 0.0000 04 f/mL , the health
houses did not register as risk level sought by EPA
70 structures/sq. millimeter high asbestos levels as the (Integrated Risk Management
= 0.02 s/mL (all fibers) monitors that the people were Information System, IRIS).
= 0.01 f/mL (PCM fibers) actually wearing.
OUTSIDE DUST, SOIL, AND DEBRIS TESTING
LABORATORY INSTRUMENT LABORATORY INSTRUMENT

SEM – Scanning Electron Microscope PLM – Polarized Light Microscope

Can quickly determine the presence of asbestos in bulk dusts and soils at Crude , slower o lder me thod wh ich can find percen t levels of as bestos .
much lower levels than can be found by PLM. Typically cannot find asbestos below 1%.

Used by E PA Reg ion 8 for Libby Supe rfund site Used by EPA Region 2 for Manhattan

Determined the presence of asbestos that PLM measurements could not Used by Region 2 for dusts found on the streets only. Not used for inside
detect in Libby. Supplemented the use of PLM measurements. Region 8 buildings, first because EPA did not sample inside buildings, and second
found that PLM not reliable for under 1% asbestos, even though hazardous bec aus e the meth od its elf ca nno t be u sed for thin films o f dus t. This is
leve ls we re still p rese nt. Stu dy fo und 0.00 1% asbe stos in soils could still because there is not enough of the dust to scrape together to make a large
generate 0.01 s/mL airborne asbestos, a hazardous level. But PLM enoug h sam ple.
methods could not detect asbestos at these levels.
The ASTM wipe and microvacuum methods described below must be used
On 9/12/01, in a conferen ce call, EPA R egion 8 offered to instead.
provide Region 2 the use of 30 to 40 scanning electron
microscopes (SEM’s) to assist in the fast evaluation of
asbesto s in the W TC fallout , along w ith the ana lysts.
Twelv e of the SE M’s cou ld have b een in N ew Yo rk City in
one day. SEM’s had been used in the quick evaluation of
dusts during the bombing of the World Trade Towers seven
years ago. EPA Region 2 refused the assistance, choosing
instead to use the crude PLM method.

INSIDE DUST TESTING, THIN FILMS OF DUST

LABORATORY INSTRUMENT

TEM - transmission electron microscope

Can find extremely small as well as larger “respirable size” particles

SAMPLING METHODS

WIPE SAMPLES, ASTM method D 6480 MICROVACUUM, ASTM method D 5755

Not used by EPA Region 2. No inside samples taken. Used by E PA Reg ion 8 for Libby Supe rfund site

Used for Grou nd Zero Task F orce stu dy for M anhattan apartm ents