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Profile: Walter Mugdan


Positions that Walter Mugdan has held:

  • EPA's regional counsel




Quote, (November 19, 2001)

   “EPA has two sets of regulations that deal with asbestos ... neither set of regulations is directly applicable to the conditions in the wake of the WTC disaster ... The first set of asbestos-related regulations are part of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) ... pursuant to ... the Clean Air Act ... The second set of regulations are those promulgated by EPA pursuant to the Asbestos Hazard Emergency Response Act (AHERA) ... The AHERA regulations also include a ‘clearance’ standard for inside air in school buildings to be used after asbestos abatement work has been completed, in order to ensure that the space is safe for re-entry by children, teachers and other employees.... EPA began taking ambient air samples ... Once again, the key question ... to what reference standard the test results would be compared in order to determine whether the air was ‘safe.’ ... EPA has not promulgated an outdoor ambient air quality standard for asbestos; nor has any other regulatory agency done so, for that matter. The only standard for asbestos in air that EPA has promulgated is found in the AHERA regulations referenced above. These rule s include what is commonly called a clearance test ... The specified AHERA clearance test procedure includes, inter alia, a step in which air monitored in the affected space is compared with the specified ‘background’ level of 70 structures per square millimeter (70 s/mm 2).” [Mugdan, 1/25/2002 cited in Jenkins, 3/11/2002]

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Walter Mugdan actively participated in the following events:


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