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EPA'S RESPONSE TO THE WORLD TRADE CENTER COLLAPSE: CHALLENGES, SUCCESSES, AND AREAS FOR IMPROVEMENT |
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Table K-3: Bulk Dust Sampling at 110 Greenwich
[2] = Residential soil screening level from EPA's Hazard Evaluation Handbook. Only accounts for health risk from ingestion. [3] = No result reported in NYC Response database. On October 10, 2001, two bulk dust samples inside 100 Church Street were collected and analyzed for asbestos. The results of this testing, done at the Department of Justice's request, found that one of the samples contained 1.1 percent asbestos while the other was non-detect. On October 23, 2001, 10 air samples were collected at 100 Church Street and analyzed for asbestos. The samples were analyzed by both the TEM and PCM methods. All TEM results were below the AHERA standard of 70 s/mm2 and all PCM results were below .01 f/cc. This testing was performed on the 18th and 19th floors after these floors had been cleaned. 95 Report No. 2003-P-00012 Table K-4: Indoor Air Test Results from October 23, 2001
KEY:
NOTES: General Services Administration Monitoring of Federal Buildings From September 13, 2001, through January 2, 2002, the General Services Administration, which is responsible for Federal building management, arranged for indoor environmental testing at Federal buildings located at 290 Broadway, 26 Federal Plaza, 201 Varick Street, and 1 Bowling Green. Over 100 air samples were analyzed and all samples were below the AHERA standard of 70 s/mm2. All but four air samples analyzed by TEM were non-detect for asbestos. The four samples that detected asbestos all occurred between September 13 and September 19, 2001. Two samples showed 25 s/mm2 and two samples could not be analyzed because the filters were overloaded. The only testing for asbestos in dust was conducted on September 14, 2001. Three dust samples collected in the lobby of 290 Broadway and two collected outside the building on September 13, 2001, showed the presence of chrysotile asbestos by TEM analysis. The results for these tests only reported whether asbestos was present or not, not the percentage of asbestos in the sample. Table K-5 through K-7 provide more information on the results of indoor testing of Federal buildings. 96 Report No. 2003-P-00012 K-5: Asbestos Air Testing
K-6: Asbestos Dust Testing at 290 Broadway
"Characterization of Particulate Found in Apartments After Destruction of the World Trade Center." [18] This study was conducted at the request of the Ground Zero Elected Officials Task Force. This study selected two residential apartment buildings for sampling -- one presumed to have significant WTC dust contamination and the other not -- based on their locations. Six air samples were collected from inside one apartment building and five from the other. All 11 samples were analyzed by the TEM method. The study found higher levels of _______________ 18 Eric J. Chatfield, Ph.D., Chatfield Technical Consulting Limited, and John R. Kominsky, M.Sc., CIH, CSP, CHMM, Environmental Quality Management, Inc.; October 12, 2001. 97 Report No. 2003-P-00012 airborne asbestos in apartment building expected to have WTC dust contamination. Further, the study found that asbestos levels in both buildings exceeded the AHERA standard of 70 s/mm2:
"Health Risks from Exposures to Asbestos and Inorganic Metals Due to Collapse of the World Trade Center. [19] The results of the aforementioned "Characterization of Particulate Found in Apartments After Destruction of the World Trade Center" study were analyzed by a consultant for the Ground Zero Elected Officials Task Force to address possible health risks to residents and workers from exposure to the levels of inorganic metals and asbestos contamination found in the study. "Final Report of the Public Health Investigation to Assess Potential Exposures to Airborne and Settled Surface Dust in Residential Areas in Lower Manhattan, NYCDOH, and ATSDR." [20] This was the largest study in terms of buildings analyzed and was conducted by ATSDR and NYCDOH. The final report was issued in September 2002. The study collected dust and air samples in and around 30 residential buildings (encompassing 59 apartment units) in Lower Manhattan, along with 4 buildings north of 59th Street for comparison purposes. Of the 59 apartments sampled, 50 -- or 85 percent -- had been reportedly cleaned (professionally or otherwise) prior to ATSDR 's sampling. The study concluded that the increased risk of cancer or other adverse lung health effects from prolonged exposure to WTC dust was greater than 1-in-10,000 for those areas sampled. This risk was based on several worst-case scenario assumptions. These worst-case assumptions were that apartments tested would not be cleaned after sampling, all fibers detected were asbestos, and the levels detected in the study represented long-term levels. The report noted that for individuals who frequently clean their apartments using HEPA vacuums and damp cloths/mops or take part in the EPA cleaning program, it was unlikely their exposure would resemble worst-case conditions. The report noted that when evaluating the health risks from indoor contamination, it did not take into account the potential effects of high doses of dust, fibers, and other materials that people in the WTC area at the time of the attacks may have experienced. The report noted these exposures could add to the public's risk of long-term health effects. _______________ 19 Dr. E.B. Ilgren, MD, MA, D Phil, October 11, 2001. 20 New York City Department of Health and Mental Hygiene and U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry, as part of the World Trade Center Environmental Assessment Workgroup, September 2002. 98 Report No. 2003-P-00012 Details on Use of Respirators at Ground Zero Reports on Lack of Respirator Use An October 2001 report [21] by the National Institute of Environmental Health Sciences discussed worker safety issues at the WTC site for the period up to October 5, 2001. The report's observations generally focused on construction workers at the site and not Fire Department rescue team or Federal disaster assistance personnel. According to the report:
A January 2002 report [22] prepared by a certified industrial hygienist for the Operating Engineers National Hazmat Program noted that during the period October 2 -16, 2001, less than half of the heavy equipment operators regularly used respirators when working on the "pile" at Ground Zero, and often this use decreased to less than one-third of the workers. This report, which discussed respiratory protection lessons from the WTC disaster, concluded that the respirators NIOSH recommended for use at the site were correct and sufficiently protective provided that they were properly tested and conscientiously worn. In contrast to the recovery operation at the WTC site, the January 2002 report noted that workers conducting WTC debris sorting and inspection at the Fresh Kills landfill were wearing half-face respirators, hard hats, eye protection, and Tyvek suits. The author noted that respiratory protection compliance by workers at Fresh Kills was reported to be approximately 90 percent as _______________ 21 "Worker Education and Training Program (WETP) Response to the World Trade Center Disaster: Initial WETP Grantee Response and Preliminary Assessment of Training Needs," Donald Elisburg, John Moran, National Institute of Environmental Health Sciences WETP, National Clearinghouse for Worker Safety and Health Training, October 6, 2001. 22 "Respiratory Protection at the World Trade Center: Lessons From the Other Disaster," Bruce Lippy, CIH, CSP, January 15,2002. 99 Report No. 2003-P-00012 opposed to 30-50 percent compliance at the WTC site. The author observed that:
". ..debris is pulled by workers from the smoking, twisted wreckage of the
World Moreover, the author noted that workers at the landfill were officially informed that not wearing respirators would result in disciplinary action. OIG investigators from our New York office who participated in the recovery operations confirmed the report's conclusions about the difference in respiratory use between the WTC and landfill sites. EPA Actions to Encourage Respirator Use As demonstrated by a fact sheet prepared on September 11, 2001, EPA's emergency response officials immediately recognized the need for and recommended the use of air purifying respirators [23] at Ground Zero (a copy of this document is available on our OIG web site). EPA officials told us this fact sheet was provided to a FEMA official, but was not issued. We contacted a FEMA representative who told us that the flyer was not issued because it was decided that New York City should handle worker protection issues. EPA also provided respirators for workers at the site. According to a May 1, 2002, letter from EPA's Region 2 Administrator to Senator Joseph Lieberman (D-CT) and Senator George Voinovich (R-OH), EPA had distributed 22,100 air purifying respirators and 30,500 sets of P100 particulate cartridges to New York City by September 22, 2001. Additionally, 600 respirators (MSA and 3m brand) and 2,000 cartridges (GME-P100) were provided to the New York State Department of Environmental Conservation and the New York State Department of Health. The bulk of EPA-procured equipment was transported from EPA's Edison facility by the New York National Guard to the New York City Office of Emergency Management for distribution to response workers. As the rescue phase progressed, EPA emergency response officials told us they were concerned about the lack of respirator use at Ground Zero and outlined these concerns in a letter to NYCDOH dated October 5, 2001. This letter outlined the threat of potential exposure of workers to hazardous substances. The letter noted that EPA "... has recommended, and continues to recommend, that workers utilize personal protective equipment and the personal wash stations to prevent the spread of asbestos and other hazardous substances from the WTC to their homes, cars, public transportation, food service locations, etc." The letter stated that EPA had observed very inconsistent compliance with its recommendations, but did not have the authority to enforce compliance with non-EPA/United States Coast Guard employees. The letter concluded by recommending that the Incident Commander adopt and enforce a site-wide Health and Safety Plan. A copy of the letter is in Appendix P. _______________ 23 NIOSH recommended the use of half-face negative pressure respirators with P-100, organic vapor/acid gas (P-100/0V/AG) cartridges. Respirators must be properly fitted to provide adequate protection against airborne hazards. 100 Report No. 2003-P-00012 Health Impacts of Lack of Respirator Use at Ground Zero Two studies documented acute health effects suffered by emergency and construction workers at Ground Zero. A study [24] of firefighters who responded to the collapse concluded that intense, short-term exposure to material generated during the collapse of the World Trade Center was associated with bronchial responsiveness and the development of cough. The study found that the following percentages of firefighters developed "World Trade Center cough" that was severe enough to require at least 4 weeks of medical leave:
Initial findings of medical examinations of workers directly involved in rescue and recovery efforts also found evidence of acute health impacts. Preliminary results of these examinations released in January 2003 and reported in the Washington Post concluded that 78 percent of those sampled had suffered lung ailments and 88 percent had experienced ear, nose, and throat problems in the months immediately following the attack. Further, a September 2002 report [25] by the Mount Sinai School of Medicine concluded that protection of workers at Ground Zero was "seriously inadequate." The report noted that the response of workers in the first few hours and days after the attack without regard to their personal safety was laudable and understandable. However, according to the Mount Sinai report, a lack of enforcement of worker protection measures in the weeks and months that followed was not excusable. _______________ 24 "Cough and Bronchial Responsiveness in Firefighters at the World Trade Center Site," David J. Prezant, M.D., et al, New England Journal of Medicine, Vol. 347, No.11, September 12, 2002. 25 "Lesson Learned tor Public Health from September 11, 2001: A One-Year Perspective, " Philip J. Landrigan, M.D., M.Sc., et al, September 2002. 101 Report No. 2003-P-00012 102 Report No. 2003-P-00012 Cleaning Procedures for Residents Opting to Have Their Residences Cleaned
103 Report No. 2003-P-00012 104 Report No. 2003-P-00012 Details from EPA and Non-EPA Lessons Learned Reports Recommendations of EPA Lessons Learned Reports Headquarter's Lessons Learned Report 1. Clarify Involvement of Senior EPA Leaders, and Confirm Authority of Emergency Response Personnel in Decision-Making and Communications During National Emergencies
2. Revisit, and Revise as Needed, Existing Internal and External Emergency Response Coordination Plans and Structures; Conduct Interagency Training and Exercises to Solidify Government-wide Understanding of Roles, Responsibilities, and Capabilities
105 Report No. 2003-P-00012 3. Develop an Emergency Response Infrastructure to Address both Data Analysis Issues and Information Management
4. Develop EPA Policies and Procedures for Public Information Dissemination During National Emergencies, Within Established Emergency Response Plans and Structures
5. Increase the Agency's Emergency Response Resources, and Address the Unique Demands of OSC Positions in Human Resource Processes
6. Invest in the Safety and Security of EPA Staff and Facilities, Including Telecommunications Needs
7. Identify and Address National Environmental Vulnerabilities
Region 2 Lessons Learned Recommendations 1. EPA Region 2 should undertake an effort to connect with senior officials of the Federal Emergency Management Agency, U.S. Army Corps of Engineers, and the Department of Health and Human Services on a routine basis to ensure EPA mission is clearly understood. 2. Region 2 needs to develop a comprehensive approach to emergency management and response, perhaps based upon the NFPA 1600 Standard, that includes all divisions in the region. This would::
3. Region 2 should identify a team of dedicated people who will respond in the event of a new crisis. This would limit the stress on personnel who might otherwise be pulled from the current response to another, as well as allowing designated staff to prepare, to the extent possible, for the possibility of mobilization. This could be accomplished by assigning an individual to a particular task until they are directly and explicitly relieved. In addition, a feedback mechanism could be established to encourage and solicit concerns during and after a response. 4. The Region's Continuity of Operations Plan (COOP) needs to be reviewed and updated. 5. Senior leadership of Region 2 and Regional staff not currently assigned to emergency response who might respond in a disaster, should participate in introductory training and education on basic disaster management and response. This would include intergovernmental relationships that are inherently different than typical Superfund emergency response and removal. 107 Report No. 2003-P-00012 6. Public information, risk communications, and crisis communications must be organized and strategized in advance of a disaster. Region 2 should develop a comprehensive approach -which includes Headquarters and regional Federal and State partners -on how to handle crisis communications. Then, in a disaster event, relationships are established, lines of coordination and communication are established, and communications/public affairs officers can focus on tactics rather than trying to develop a framework in the midst of the emergency. Mechanisms should be in place for resolving differences about the interpretation of risk and the appropriate response. 7. Nationally, EPA should examine policies and procedures for ESF #10 activation and coordination with USCG to ensure roles and responsibilities are executed according to the FRP . Additional Recommendations 1. As soon as possible, educate Region 2 personnel and management on Agency and Region responsibilities and authorities during a disaster or crisis with emphasis on the relationship between the Stafford Act, FRP, National Contingency Plan (NCP) and ICS. Include suggested peer relationships with counterpart agencies at all levels, but especially at the senior management level (e.g., regional administrators). 2. National Issue - Adopt an incident management system that is consistent across all regions, has common terms and plugs into other crisis/consequence management structures. National and regional management systems should be compatible Regional Issues - Create Regional crisis management structure, staffed by people with authority, commitment and qualifications, to improve roles and communication between management and OSCs. Develop an incident management system for Region 2 that:
Regional Interagency Coordination Team (RICT)
Regional Incident Command System (ICS)
Emergency Operations Center (EOC)
3. Develop a Regional Strategy and Standard Operating Procedures (SOP) for communicating risk to the public during a crisis.
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5. Develop agreements and processes for the emerging data generation and management mission including:
6. Need a corporate philosophy on how to manage expectations in a crisis (internally outside of Region 2 emergency responders and externally). Consider:
7. Develop a crisis management plan. SOPS, COOP, should address all issue categories
8. Clearly identify scope and boundaries of work within authorities and expertise. (e.g. logistical tasks) (e.g. accept only Mission Assignment with authority?)
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