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Executive Summary
The September 11, 2001, terrorist
attack on the World Trade Center in New York City and the environmental
aftermath were unprecedented. Airborne dust from the collapse of the
towers blanketed Lower Manhattan and was blown or dispersed into many of
the surrounding office buildings, schools, and residences. This
complex mixture of building debris and combustion by- products contained
such ingredients as asbestos, lead, glass fibers, and concrete dust.
Responding to this crisis required
organizations from all levels of government to coordinate their response
efforts and to make critical public health and safety decisions quickly,
and without all of the data that decision-makers would normally desire.
Unfortunately, this country may
experience more terrorist attacks, and a response to such a tragedy
could be needed again. Accordingly, we initiated this evaluation, in
consultation with the Environmental Protection Agency (EPA) Deputy
Administrator, to evaluate EPA’s response to September 11. During our
evaluation, we sought to answer six specific questions that address how
EPA responded and how it could better respond in the future. Those
questions, along with summaries of what we found and recommendations for
each, follow.
1. Did the available monitoring data
and analyses of that data support EPA’s major public communications
regarding air quality and associated health risks resulting from the
collapse of the World Trade Center (WTC) towers?
EPA’s early public statements
following the collapse of the WTC towers reassured the public regarding
the safety of the air outside the Ground Zero area. However, when
EPA made a September 18 announcement that the air was “safe” to breathe,
it did not have sufficient data and analyses to make such a blanket
statement. At that time, air monitoring data was lacking for several
pollutants of concern, including particulate matter and polychlorinated
biphenyls (PCBs). Furthermore, The White House Council on
Environmental Quality influenced, through the collaboration process, the
information that EPA communicated to the public through its early press
releases when it convinced EPA to add reassuring statements and delete
cautionary ones. An EPA draft risk evaluation completed over a year
after the attacks concluded that, after the first few days, ambient air
levels were unlikely to cause short-term or long-term health effects to
the general population. However, because of numerous uncertainties –
including the extent of the public’s exposure and a lack of health-based
benchmarks – a definitive answer to whether the air was safe to breathe
may not be settled for years to come.
Details regarding the handling of
indoor contamination are discussed in relation to Objective 2 below.
EPA has initiated actions to
strengthen its risk communication procedures for emergency situations,
including the development of a draft Plan for Incident
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Communication. We recommend that the
EPA Administrator continue these efforts and develop procedures for
emergency risk communication to ensure that public pronouncements
regarding health risks and environmental quality are adequately
supported with available data and analysis and are appropriately
qualified.
2. Were EPA actions and decisions in
regard to evaluating, mitigating, and controlling risks to human health
from exposure to indoor air pollutants in the WTC area consistent with
applicable statutes, regulations, policies, guidance, and practice?
EPA’s actions to evaluate,
mitigate, and control risks to human health from exposure to indoor air
pollutants in the WTC area were consistent with applicable statutes and
regulations. These statutes and regulations do not obligate EPA to
respond to a given emergency, allowing for local agencies to lead a
response, and New York City in fact exercised a lead role regarding
indoor air.
Nonetheless, we believe EPA could have taken a more proactive approach
regarding indoor air cleanup. After the City was criticized for its
response, EPA began to assume a lead role in February 2002.
Prior to initiation of the EPA-led
cleanup, many WTC area residents had returned to their homes, and a
study indicated most of them had not followed recommended cleaning
practices. The full extent of public exposure to indoor
contaminants resulting from the WTC collapse is unknown.
We recommend that the EPA
Administrator coordinate with other Federal, State, and local agencies
to develop protocols for determining how indoor environmental concerns
will be handled in large-scale disasters. We also recommend that EPA
work with the Department of Homeland Security and other Federal agencies
to develop and publish oversight criteria, including State and local
agency reporting requirements, for handling indoor air contamination.
3. Were asbestos demolition and
renovation work practice standards followed during WTC cleanup and
recovery operations and, if not, why not?
We could not conclusively
determine the extent to which required work practices regarding the
control of asbestos were followed at the WTC site during demolition and
debris removal. Since
asbestos is a known human carcinogen, EPA has established stringent work
practices to control emissions of asbestos resulting from demolition and
renovation projects. We found that a significant requirement to reduce
emissions in emergency demolitions – wetting damaged buildings before
demolition and keeping the waste material wet after demolition – was
followed. However, work practices applicable to the transport of debris
from the site were employed inconsistently. The specific impact on air
quality of any variance from EPA’s asbestos emergency work practices is
unknown.
We recommend that the EPA
Administrator develop specific procedures for ensuring that Federal,
State, and local responders follow the appropriate NESHAP work practices
for catastrophic emergency situations involving asbestos.
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4. To what extent were EPA and
government communications regarding air quality and associated health
risks: (a) received by the public; (b) understood by the public; and (c)
effective in getting people to take the desired actions to reduce their
potential health risks?
After the WTC terrorist attack,
people received information from many different sources, and many
factors – in addition to government communications – could have
influenced their actions. Information is a critical component in helping
the public minimize their exposure to potential health hazards.
However, evidence gathered through
government hearings, news polls, health studies, and our interviews
indicated that the public did not receive sufficient air quality
information and wanted more information on associated health risks.
Also, evidence indicated that government communications were not
consistently effective in persuading the public to take recommended
precautions. Because of
these concerns, the OIG conducted a survey of New York City residents
regarding government communications. These results will be reported
separately.
EPA has initiated several actions to
improve its risk communications procedures during emergencies. Further,
EPA is working with the Federal Emergency Management Agency to clarify
roles and responsibilities for ensuring worker safety during an
emergency response. We recommend that EPA continue to coordinate efforts
to establish clear Federal roles.
5. What additional actions, if any,
should EPA take to improve its response and recovery efforts in the WTC
area related to ambient and indoor air quality?
The majority of officials contacted
indicated EPA did not need to take additional actions to address outdoor
ambient air quality concerns.
However, concerns were expressed regarding indoor contamination, and
several more measures can be taken to ensure that indoor cleanup
effectively minimizes health risk exposure. We recommend that EPA
implement a testing program to ensure the indoor cleanup effectively
reduced health risks from all pollutants of concern, and implement a
verification program to determine whether previously cleaned residences
have been recontaminated.
6. Should EPA revise its preparation
and contingency planning for dealing with air pollution resulting from
environmental catastrophes?
The events of September 11 had
national security ramifications not previously experienced, and many
persons interviewed spoke highly of the response of EPA and its
employees. Still, we, as well as EPA and others, have identified lessons
learned from the response that can improve EPA’s preparedness for future
disasters.
An overriding lesson learned was
that EPA needs to be prepared to assert its opinion and judgment on
matters that impact human health and the environment. Although many
organizations were involved in addressing air
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quality concerns resulting from the
WTC collapse, subsequent events have demonstrated that, ultimately, the
public, Congress, and others expect EPA to monitor and resolve
environmental issues. This is the case even when EPA may not have the
overall responsibility to resolve these issues or the necessary
resources to address them.
EPA has initiated many actions as a
result of its own internal lessons learned exercises. Based on our
review, we our making a number of recommendations to improve EPA’s
emergency response capabilities in three areas: (1) contingency
planning, (2) risk assessment and characterization, and (3) risk
communication.
Agency and New York City Comments
and OIG Evaluation
In her August 8, 2003 response to
the draft report, the EPA Acting Administrator stated that she was proud
of the men and women of EPA and that the Agency’s response was
extraordinary. Although
she generally agreed with the recommendations of our draft report (with
the exception of Chapter 6), she responded that our report lacked
sufficient acknowledgment of EPA’s efforts in several areas. For
example, she noted that our report focused too heavily on the Agency’s
press releases and did not sufficiently consider the Agency’s other
forms of communication or the Agency’s “lessons learned” efforts. She
provided several specific comments outlining the Agency’s disagreement
with some of the report’s findings and conclusions. A detailed summary
of the Agency response and our evaluation is included at the end of each
chapter. The Agency’s complete response and our evaluation of that
response are included as Appendices Q and R, respectively.
New York City officials responded to
excerpts from the draft report and provided us with specific comments
and clarifications which we incorporated into the final report, as
appropriate. New York City’s response is attached as Appendix S and our
evaluation of that response is attached as Appendix T.
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