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EPA'S RESPONSE TO THE WORLD TRADE CENTER COLLAPSE: CHALLENGES, SUCCESSES, AND AREAS FOR IMPROVEMENT |
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Major Conclusions of Non-EPA Lessons Learned Reports Lessons Learned for Public Health from September 11, 2001: A One Year Perspective; Philip J. Landrigan, M.D., M.Sc., Jordan Slutsky, Angali Garg, M.S., Mona Lisa Mouallem, Lauri Boni; Center for Children's Health and the Environment of the Mount Sinai School of Medicine; September 2002:
Lessons Learned on Environmental, Occupational, and Residential Exposures From the Attack on the World Trade Center; Paul J. Lioy, Ph.D. and Michael Gochfeld, M.D., Ph.D; American Journal of Industrial Medicine, December 2002:
110 Report No. 2003-P-00012 Risk Communication in the Aftermath of the World Trade Center Disaster, George D. Thurston, S.cD. and Lung Chi Chen, PhD, American Journal of Industrial Medicine, December 2002:
Perspective on the Tragedy at the World Trade Center, Joel Shutro, American Journal of Industrial Medicine, December 2002:
Health Effects of World Trade Center Site Workers, Stephen Levin, MD, Robin Herbert, MD, Gwen Skloot, MD, Jamie Szeinuk, MD, Alvin Teirstein, MD, David Fischler, MD, Debra Milek, MD, George Piligian, MD, Elizabeth Wilk-Rivard, MD, and Jacqueline Moline, MD; American Journal of Industrial Medicine, December 2002:
111 Report No. 2003-P-00012 Respiratory Protection at the World Trade Center: Lessons From the Other Disaster, Bruce Lippy, CIH, CSP, January 15, 2002:
Safety and Health of Heavy Equipment Operators at Ground Zero, Bruce Lippy, CIH, CSP, American Journal of Industrial Medicine, December 2002:
Firefighter Safety and Health Issues at the World Trade Center Site, Ronald Spadatora, Deputy Assistant Chief, Fire Department of New York, American Journal of Industrial Medicine, December 2002:
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Report No. 2003-P-00012 Details on Health-Based Benchmarks Needed Acute Exposure Guideline Levels. EPA is responsible for a program involving entities inside and outside the government to develop Acute Exposure Guideline Levels (AEGLs). These guidelines are developed by the National Advisory Committee for Acute Exposure Guideline Levels for Hazardous Substances. The AEGLs address exposures to pollutants that last for 10 minutes, 30 minutes, 1 hour, 4 hours, and 8 hours, and are established to address three potential types of health impacts from these acute exposures: non-disabling, disabling, and death. This program has finalized a limited number of AEGLs; however, none of the finalized guidelines addressed the primary pollutants of concerns for Lower Manhattan after September 11. EPA's Office of Research and Development and the Office of Prevention, Pesticides and Toxic Substances are currently working to establish needed AEGLs. Sub-Chronic Guidelines. EPA also did not have sub-chronic guidelines for the contaminants found in Lower Manhattan on September 11. A TSDR defines sub-chronic as exposures lasting 2 weeks to 1 year. In general, EPA's benchmarks have focused on lifetime cancer risk over a 30-year exposure period. Because sub-chronic guidelines did not exist for the WTC pollutants of concern, these 30-year benchmarks were adjusted to fit the situation found at WTC. For example, to assess sub-chronic (1 year) exposure to dioxin in the ambient air, EPA took the dioxin 30-year exposure benchmark and adjusted it to reflect a 1-year exposure by multiplying the 30-year exposure benchmark by 30. These guidelines should be developed, to the extent possible, before a disaster strikes so that the process can be properly peer reviewed and any necessary revisions made before they are needed. Indoor Air Benchmarks. EPA also did not have risk-based indoor air or bulk dust benchmarks for the pollutants found in dust deposited indoors. A work group formed after September 11, consisting of officials from Federal, New York State, and New York City agencies, developed indoor air benchmarks for COPCs resulting from the WTC towers collapse. These benchmarks, identified in a document entitled "World Trade Center Indoor Air Assessment: Selecting Contaminants of Potential Concern and Setting Health-Based Benchmarks," were initially published in draft in September 2002. The document was peer reviewed and a revised interim final version was published in Apri1 2003. The COPC report could be used as a starting point in developing health benchmarks for additional pollutants that may be encountered in future disasters. EPA 's Homeland Security Strategy includes plans to identify chemical and biological substances for which indoor air reference levels (benchmarks) may be needed, and establish advisory indoor air reference levels for the substances identified. Health-Based Benchmarks for Asbestos. As addressed in Chapter 2, health-based asbestos standards for indoor and outdoor air do not exist. The AHERA standard, used as a primary WTC benchmark to communicate asbestos risk for ambient air, is the filter background contamination level estimated when the TEM protocol was developed. Filters with smaller asbestos contamination levels are now available, so that smaller concentrations of asbestos can now be 113 Report No. 2003-P-00012 reliably measured. The TEM analysis of asbestos data in response to the WTC disaster suggests that the minimum detection limit may now be approximately 15 to 20 s/mm2. A significant issue with regard to indoor spaces was the potential exposure from asbestos in dust. In assessing the need for asbestos abatements in indoor spaces in New York Cit , the City relied on the NESHAP definition of asbestos-containing material, which defines asbestos-containing material as 1 percent or more asbestos by volume. This is not a health standard, and dust with less than 1 percent asbestos could pose a health risk. Risk assessors employ a mathematical formula to estimate the amount of asbestos in dust that can be expected to become airborne in order to evaluate the potential risk to human health from asbestos in dust. This factor is known as the "K Factor." However, this factor is not deemed reliable at this time. The panel that completed the peer review for EPA' s indoor standards did not endorse the asbestos-settled dust benchmark because the "the K-factor methodology is, at this time, inadequate for predicting inhalation exposure from asbestos surface loading measurement." We believe EPA should review the AHERA standard and determine whether the standard needs to be revised in light of the fact that better filters are available today, and continue the work of the indoor COPC group to develop health-related screening levels for asbestos in dust. Benchmarks for Exposure to Multiple Pollutants. The synergistic impacts of multiple pollutants on human health in the aftermath of an air quality emergency, such as occurred on September 11, are unknown. Synergistic effects have been documented between asbestos and cigarette smoke. For example, the lung cancer risk from exposure to asbestos is increased if the individual exposed to asbestos is a cigarette smoker. Researchers interviewed indicated that there could be other synergistic effects caused by the wide array of pollutants generated by the collapse of the WTC, but research is not available to make this determination. 114 Report No. 2003-P-00012 EPA Letter Concerning Worker Protection
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OCT 05 2001
Mr. Kelly R. McKinney, P.E. Dear Mr. McKinney: Health and safety concerns for workers at the World Trade Center Disaster Site (WTC) has been a concern from the beginning of the response. In addition to standard construction/demolition site safety concerns, this Site also poses threats to workers related to potential exposure to hazardous substances. Sources of hazardous substances include (1) building materials from the destroyed buildings (primarily asbestos), (2) hazardous materials that were stored in the buildings (refrigerants, hazardous wastes, ethylene glycol, compressed gas cylinders, etc.), and (3) products of combustion being omitted from the fires that continue to burn within the debris piles. EPA, along with a number of other federal, state and your agency, has been gathering information about these threats to worker health. Air sampling by EPA and others indicates that asbestos and other contaminants are present in the air at the WTC. EPA has recommended, and continues to recommend that workers at the Site wear respiratory protection. In addition, EPA has recommended, and continues to recommend, that workers utilize personal protective equipment and the personnel 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. We have observed very inconsistent compliance with our recommendations, however, we do not have authority to enforce the worker health and safety policies for non-EPA/USCG employees. Therefore, EPA believes the Incident Commander should adopt and enforce a site-wide Health and Safety Plan. If there is anything I can do to assist you concerning this matter, please feel free to call me at (732) 321-6656. Sincerely yours,
Bruce Sprague, Chief cc: FCO, FEMA 115 Report No. 2003-P-00012 116 Report No. 2003-P-00012 EPA Response to the Draft Report
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY AUG 8 2002 OFFICE OF THE ADMINISTRATOR MEMORANDUM SUBJECT: Transmittal Memorandum for EPA's Response to Inspector General's (Draft) Evaluation Report: "EPA's Response to the World Trade Center Collapse -- Challenges, Success, and Improvements." (Assignment Number 2002-0000702
FROM: Marianne Lamont Horinko
TO: Nikki Tinsley This memorandum transmits the Agency's consolidated response to the subject draft report ("Draft Report"). With this memo, I formally request the EPA's comments be included as part of the final version of the official report. The unprecedented terrorist attack on the World Trade Center (WTC) and the enormity of its aftermath compelled responding government agencies to write a new book on disaster response. While the Draft Report acknowledges the situation that the nation -- and New York City in particular -- confronted following the disaster, the nature of its criticisms, conclusions and recommendations do not reflect those circumstances. In fact, this document is infected with the attitude that somehow "business as usual" conduct should have prevailed. See Appendix R Note 1 I am exceedingly proud of the response that the men and women of EPA made in the aftermath of the World Trade Center collapse. Along with other first responders, our people were there within hours of the attack and hundreds of our specialists devoted long hours under difficult conditions to provide assistance and information. EPA responded with its heart as well as its science to protect the health of the public and the workers involved in rescue and recovery. In all, we took over 25,000 samples and conducted a quarter of a million measurements of nearly 700 potential contaminants. See Appendix R Note 2 EPA's response was extraordinary, especially when examined in the chaotic context in which we and other governing bodies found ourselves. EPA began monitoring immediately for contaminants -- without benchmarks or standards that applied to the disaster situation such as ambient asbestos -- and we did it without electricity, in the midst of firefighting and rescue 117 Report No. 2003-P-00012 operations, in the midst of high security concerns, and surrounded by construction equipment moving debris. The New York City Emergency Command Center was destroyed, agencies' New York offices were closed, communications services in Lower Manhattan were inoperative, and airlines were shut down. Given the magnitude of the disaster, the massiveness of the response, the very real security issues at stake, and the many entities involved, it was essential that the Executive Branch coordinate the federal response. At a time of national emergency, the people expect the government to speak with one voice. See Appendix R Note 3 Indeed, one of the key lessons learned is the need for centralized communications during times of national crisis. The creation of the Department of Homeland Security institutionalized the coordination of communications in one Department. The Draft Report, however, goes to great length to erroneously criticize federal efforts, specifically the Council on Environmental Quality (CEQ), to coordinate health and safety communications. EPA, along with other agencies and departments responsible for environment, health and safety, acted to provide the best health and safety guidance to those who lived and worked in Lower Manhattan, based on available data and using our best professional judgment under extraordinary circumstances. We continuously monitored the environmental effects of the explosion, fire and ultimate collapse of the WTC buildings. We made this data available as widely and as transparently as possible. Our public statements at every stage conveyed our best professional advice based on the most current data available. See Appendix R Note 4 We continue to evaluate our response to identify improvements that can be made in how we manage and respond to future situations of this magnitude. A few weeks after the attacks, EPA commissioned a formal report, conducted by an objective outside contractor, to assess the "lessons learned" from these events. Many of the "lessons learned" that we have been implementing since 2002, anticipated most of those the Draft Report now highlights. We are making every effort to strengthen our planning and response systems to be as ready as possible for any unforeseen catastrophic event, and we are committed to continuing to provide the public with the best possible environmental information and assistance in times of national crises. See Appendix R Note 5 The Report lacks sufficient acknowledgement of our efforts to implement our "lessons learned," and is flawed in its lack of recognition in other areas such as: EPA's message was communicated to different audiences.
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The Report erroneously focuses on five early Agency press releases, neglecting the extensiveness of EPA's communications. See Appendix R Note 7
An immediate and continuing problem in measuring and communicating environmental risk associated with the WTC dust/debris cloud was the fact that for many of the contaminants of concern, there were no health based standards.
See Appendix R Note 8 Could things have been done better? Certainly. Were mistakes made? Without a doubt. But like other agencies of government in the wake of this event, EPA has reviewed its response, asked tough questions about its conduct, and begun the process of change and improvement. To be a valid basis for planning, the Draft Report needed to capture the things that went right -- and the vast majority of our efforts did -- as well as what needs to be improved. This Report simply seems out of touch with the reality of what took place at the World Trade Center, and thus it trivializes both the horrendous event that occurred and the extraordinary efforts of EPA and other responders. See Appendix R Note 9 By ignoring that good work, ,the Report leaves a bruised population wondering once again if their government properly served them at their time of greatest need. The fact is, the dedicated people of the EPA -- and government at all levels -- rose to the challenge of the World Trade Center disaster ... and performed out courage and distinction. [AB-2] 119 Report No. 2003-P-00012
EPA's Response to the World Trade Center Collapse: GENERAL OBSERVATIONS Response to the World Trade Center collapse was unprecedented in the challenges it presented to federal, state and local emergency responders. [AB-3] EPA undertook immediate efforts to ascertain the presence of contaminants from the collapse and fires, and to assist FEMA and New York City in all phases of the subsequent recovery and cleanup. EPA's activities included sampling and analysis of ambient air and water; wash down and decontamination of vehicles; removal and disposal of hazardous materials; vacuuming of dust and debris from streets; supplying personal protective equipment; assisting Financial District in retrieval of electronic files/papers; and provision of data and health information to the public. To illustrate the magnitude of the activities conducted at the site, over 25,000 samples were taken representing 227,000 measurements of 692 potential contaminants. The initial response continued until May 2002 and at times, involved as many as 290 EPA and U.S. Coast Guard personnel, and 200 Agency contractors. See Appendix R Note 10 While the report acknowledges the unprecedented nature of the response to the terrorist attack upon the WTC, many of its findings and recommendations imply that the response could have been conducted in a manner consistent with a standard regulatory approach, e.g. implementation of NESHAPs asbestos regulations. Further, the report does not recognize that the WTC response and clean up efforts were conducted in the absence of adequate background concentrations for the contaminants of potential concern, e.g., typical levels of asbestos or dioxin in an urban apartment. Having such information available would have greatly simplified the effort to delineate areas that were impacted and determine when indoor residential environments were cleaned to pre-event condition. Additionally, the report does not acknowledge the Agency's massive campaign to provide quality information to the public -- through hundreds of media interviews, tens of thousands of fact sheets and handouts and innovative use of the internet, including information in three languages. Lastly, and most importantly, the report fails to recognize the nature of decision making in a catastrophic emergency. We must accept that a future incident may involve a scenario o;r contaminant that we simply cannot foresee. This means that while work can and should be done to develop protocols, standards and benchmarks -- when an event of the magnitude of the World Trade Center attack occurs, many decisions will based on the best professional judgment of emergency responders from all branches and levels of government, through the leadership ranks of the Department of Homeland Security. See Appendix R Note 11 120 Report No. 2003-P-00012 CHAPTER 2 EPA STATEMENTS ABOUT AIR QUALITY NOT ADEQUATELY QUALIFIED Report Conclusions/Recommendations:
EPA Response: The EPA "statement" referred to in the report was made days after the attack, based on air sampling at seven sites surrounding the WTC site. The Agency knew, from testing conducted at the time of the 1993 WTC bombing, that asbestos was the primary contaminant of concern outside the WTC site. Following 9/11, the news media was filled with stories about possible asbestos contamination of the air. Tens of thousands of residents and hundreds of thousands of workers were displaced and scared. EPA's initial statement was made in direct response to the public's concern about asbestos contamination. The EPA press release from which the statement was quoted detailed the monitoring that led to the statement and made it clear that further monitoring for asbestos and other contaminants would take place. EPA subsequently made this and extensive additional monitoring data available on an interactive Web site that allowed people to track data at mapped monitoring stations. See Appendix R Note 12 EPA never withheld data from the public and sampling results were reported out as soon as they were reviewed. Results were communicated in discussions with media representatives, federal, state and local officials, elected officials and interested citizens. The Agency did coordinate press releases with the Council for Environmental Quality (CEQ). This is neither unusual nor unexpected during a catastrophic disaster on the scale See Appendix R Note 13 121 Report No. 2003-P-00012 of the WTC attacks. EPA acknowledges that there are lessons to be learned about how to communicate more effectively, especially in the difficult area of risk communication, and has made this a priority as it implements "lessons learned" from both 9/11 and the Columbia accident. EPA's Homeland Security Strategic Plan includes goals which commit EPA to use reliable information to ensure informed decision-making and to disseminate timely, quality environmental information to all levels of government, industry and public. See Appendix R Note 13 Chapter 3 EPA's RESPONSE TO INDOOR ENVIRONMENT CONSISTENT WITH STATUTES AND REGULATIONS BUT MAY HAVE DELAYED NEEDED HEALTH PROTECTION Report Conclusions/Recommendations:
Develop protocols for determining how indoor environmental concerns will be handled in large-scale disasters, to include addressing: 122 Report No. 2003-P-00012 The agency or agencies responsible for testing and/or overseeing testing of indoor spaces; Sampling methods to be used in analyzing indoor contamination; Benchmarks to be used in assessing whether the indoor contamination pose a threat; Under what circumstances government-asssisted cleanups are warranted; How these cleanups will be funded; and The agency or agencies responsible for communicating testing results and appropriate cleaning instructions. Develop and publish oversight criteria and State and local agency reporting requirements for those agencies involved in cleaning up buildings and other disasters. EPA Response: EPA disagrees that unprotected residents and workers may have experienced unnecessary exposures to asbestos or other pollutants as a result of delay in providing a government-organized and adequately monitored cleanup in Lower Manhattan. From the beginning, FEMA, New York City and State, as well as EPA provided advice to residents on cleanup methods (wet wiping/mopping, HEPA vacuuming) that has proven effective. In addition, residents with more than minimal dust, were urged to use professional, asbestos abatement cleaners. FEMA provided financial assistance to residents to enable them to relocate while cleanup was being done, and New York City provided guidance and cleanup requirements to building owners. All this took place in the absence of a "Government-organized cleanup." Subsequent EPA studies show that the basic cleaning techniques that were recommended were effective in reducing dust and reducing dust to below health based benchmarks where these could be identified. In summary, EPA feels that the advice and assistance provided was sufficient to enable the affected population to take appropriate action to minimize further risk. See Appendix R Note 14 With respect to the outside environment, EPA provided personal protective equipment, repeatedly stated that workers at Ground Zero should use this equipment and were at greater risk than the surrounding population. Additionally, the Agency consistently raised concerns over the use of protective equipment to local officials. Additionally, EPA separately advised anyone with acute symptoms to consult with their physicians and acknowledged that sensitive populations, such as those with respiratory illnesses might react differently than the general population, and also should consult their physicians. See Appendix R Note 15 123 Report No. 2003-P-00012 In summary, EPA's initial role in support of New York city and State officials in no way created additional health risk to workers or residents. In fact, EPA and other federal, state and city agencies responded to the best of their abilities to reduce potential risk as quickly and as reasonably as possible. EPA generally agrees with the recommendations concerning coordination with the Department of Homeland Security and other federal agencies, and that the topic of roles and responsibilities for all levels of government regarding potential contamination of indoor spaces should be further explored. The Agency further agrees that consideration should be given to possible identification of sampling methods, benchmarks, circumstances where government-assisted cleanups are appropriate, funding support and communications. CHAPTER 4 ASBESTOS EMISSION CONTROL WORK PRACTICES INCONSISTENT Report Conclusion/Recommendation:
EPA Response: In the immediate aftermath of WTC collapse and fires, "ensuring" compliant work practices was extremely difficult. This was not for lack of knowledge about what should be done, but rather as a matter of practically implementing these practices under extreme conditions of duress. Search and rescue operations were going on in the presence of See Appendix R Note 16 124 Report No. 2003-P-00012 debris removal including removing molten steel beams from the site. Search, rescue and construction equipment surrounded the site. EPA worked with New York City and State agencies to set up truck routes, wet-down stations, on-site wetting of debris, wetting at the barges, and wash stations for workers on the pile at Ground Zero. Given the physical impediments and the intensity of the situation, it took time to implement best work practices fully. As the various federal, state and local agencies became organized in their response and set up communications with debris cleanup contractors, these problems were eliminated, to the maximum extent possible. With respect to the recommendations, EPA agrees that the regulations for NESHAPS should be reviewed to determine whether additional procedures are necessary to provide to federal, State and local responders. Additionally, the applicability of NESHAPS to disaster situations may need to clarified. See Appendix R Note 16 CHAPTER 5 AIR QUALITY-RELATED COMMUNICATIONS NOT EFFECTIVE IN GETTING PUBLIC AND WORKERS TO TAKE RECOMMENDED PRECAUTIONS Report Conclusion/Recommendation:
Workers responding to emergencies are adequately protected by the development and strict enforcement of health and safety plans. Health hazard information is effectively communicated to emergency response crews. 125 Report No. 2003-P-00012 Sufficiently detailed health risk information is effectively communicated to the public, including actions that the public should take to reduce their potential exposure to harmful pollutants. EPA Response: With respect to worker safety on or near the debris pile at Ground Zero, although OSHA had direct responsibility, EPA supported them in many ways. EPA immediately provided a large supply of respirators for the workers, followed by a long-term and concerted effort to educate workers about the need to wear the masks. Further, EPA's worker-safety message was stressed repeatedly in news releases, media interviews, public meetings and appearances, on the Agency's WTC Web site, in flyers and posters at the worker wash station that EPA provided. See Appendix R Note 17 With respect to the public's reported need for better information, EPA and other federal, State and local agencies provided the most comprehensive and up to date information available. As mentioned earlier in response to Chapter 1, extensive air monitoring data was available on an interactive Web site and air sampling results were reported out as soon as they were reviewed in discussions with media representatives, federal, state and local officials, elected officials and interested citizens. While government agencies, including EPA, should examine risk communication tools and skills in emergency situations and make improvements, the public sometimes wants information that is simply not scientifically available, or is not available quickly. EPA feels that the efforts made in conjunction with New York City and State, FEMA and OSHA provided reasonable assurance that worker's and the general public's exposure to contaminants was minimized. As the report acknowledges, EPA has initiated actions to improve risk communications to the public, and with regard to worker safety, is participating in a FEMA-led Interagency effort to provide uniform occupational safety and health policy under the Federal Response Plan. CHAPTER 6 FURTHER ACTIONS NEEDED TO ADDRESS CURRENT WTC RESPONSE Report Conclusion/Recommendation:
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EPA Response: EPA, in conjunction with New York City and FEMa, has initiated and nearly completed a large-scale indoor cleanup under the Federal Response Plan -- not Superfund and the program has met the criteria for protecting human health. Under this program EPA did cleanign and testing in 675 building "footprints" as identified in the city's building inventory. From NYC records, there appear to be about 22,000 residential units below Canal Street. There are 2,323 building footprints which would also include approximately 1550 commercial buildings. If a cleanup program were expanded to include all of these buildings fo;otprints and the commercial space therein, it would be a monumental undertaking which EPA studies and data indicate is not necessary See Appendix R Note 19 127 Report No. 2003-P-00012 First, the vast mass of dust and debris from the WTC collapse has been removed. This is a result of cleanup during the response actions, the Ground Zero cleanup, cleanup of building exteriors by the private sector and New York City. Second in 95% of the over 4,100 residences cleaned and tested or tested only, the asbestos in the air results were non-detect. Lastly, cleanup techniques of wet-mopping, wet wiping and HEPA vacuuming were found to be successful in achieving health-based benchmarks for WTC contaminants of concern. EPA focused upon a cleanup program for residences, because this is where individuals spend the most time and where the greatest need for assistance in conducting cleanup and getting reassurance was evident. See Appendix R Note 20 Regarding the need for "aggressive" air sampling, EPA notes that scientists and physicians expert in environmental health issues advised EPA at a meeting convened by the New York Academy of Medicine in June 2002, that aggressive sampling was not a representative condition for testing and potential exposure. In addition, EPA's Confirmation Cleaning Study did not find a measurable difference in the use of modified or aggressive air disturbance technique in sampling. See Appendix R Note 21 Lastly, EPA did evaluate the potential for health risks, qualitatively, for areas North of Canal Street, in Brooklyn, and beyond. The determination was that lower Manhattan was the principal impact area where the mass of building materials from the collapse was deposited and where the most fire plume exposure occurred. In addition, EPA's judgment is that commercial establishments had alternative sources of assistance to fund cleanup activity. EPA and OSHA have coordinated throughout the indoor cleanup program, and OSHA has agreed to investigate any complaints by workers in commercial establishments of dust exposure. See Appendix R Note 22 With respect to the recommendation that EPA submit the revised "World Trade Center Indoor Air Assessment" for a second peer review, the Agency disagrees. EPA does agree that, as part of its efforts to develop indoor health based benchmarks, a protocol for establishing these would be usefully peer reviewed. Such a general protocol could take into account what was done for the WTC Contaminants of Potential Concern (COPC). EPA does not see any benefit to further peer review of the WTC specific document. See Appendix R Note 23 With respect to the recommendation that EPA implement a post-cleaning testing program to ensure that, in addition to asbestos, the indoor cleanup program has reduced residents' risk of exposure from all of the identified COPCs to acceptable limits, the Agency disagrees. EPA believes that the health based asbestos in air clearance testing is effective in reducing the potential for risk related to WTC contaminants. The results of the Confirmation Cleaning Study support this, and the study results provide effective guidance for additional cleanup where there are continued concerns. See Appendix R Note 24 With respect to the recommendation that due to concerns over possible re-contamination of residences cleaned under the Indoor Air Residential Assistance program, EPA should 128 Report No. 2003-P-00012 treat buildings as a system and implement a post-cleaning verification program to ensure that residences cleaned by the program have not been re-contaminated, EPA disagrees. EPA has done post-cleaning testing in common spaces, in residences. EPA does not believe further testing to assure there has not been recontamination is needed. The testing results to date do not show widespread exceedences; the vast amount of dust from the WTC and streets and buildings (exterior and interior) has been removed. Retesting would involve over 4,000 dwelling units with an average of 5 asbestos in air samples per unit, or at least 20,000 additional samples. Cleanup work in lower Manhattan has largely been completed. See Appendix R Note 25 With respect to the recommendation that EPA work with FEMA and OSHA to assess whether the ongoing residential testing and cleaning program should be expanded to address potential contamination in work spaces in Lower Manhattan, or whether other measures need to be taken to ensure that work spaces are not contaminated with WTC dust, EPA disagrees. As previously mentioned, EPA focused upon a cleanup program for residences, because this is where individuals spend the most time and where the greatest need for assistance in conducting cleanup and getting reassurance was evident. Further as stated above, the Agency has no data to support the need for a massive testing and cleanup program in Lower Manhattan. See Appendix R Note 26 CHAPTER 7 EPA SHOULD CONTINUE EFFORTS TO IMPROVE CONTINGENCY PLANNING Report Conclusion/Recommendation:
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EPA Response: With respect to the conclusion, EPA emphasizes that, at the WTC response, it certainly did exercise its opinions and judgments on matters impacting human health and the environment and will continue to do so within the context of its authorities and its role under the Federal Response Plan. With respect to the recommendations, it should be recognized that the Department of Homeland Security looks to EPA and other agencies to assist them in identification of potential targets and critical infrastructure. In fact, EPA has already provided much of the information recommended, to DHS. EPA collects the data under various legislative and regulatory programs and uses it to develop approaches and establish plans of action for protection of public health and safety in collaboration with State and local agencies. EPA generally agrees with the other Chapter 7 recommendations See Appendix R Note 27 130 Report No. 2003-P-00012 _______________ American-Buddha Librarian's Comments: [AB-1] Is that because they are going to die really soon? What a bunch of lies and excuse-making. [AB-2] What went right? The people went completely unprotected. What else is there? [AB-3] "Unprecedented," eh? Hurricane Katrina was "unprecedented" too, according to Mike Brown. As Inigo said to Vizzini on The Cliffs of Insanity in the movie "The Princess Bride," after hearing Vizzini expostulate again and again every time something went wrong -- "Inconceivable!" -- "You keep using that word. I do not think it means what you think it means." "A uniform sampling protocol and centralized collection of all testing results is needed, and Government agencies appear to have ignored their own precedents [e.g. government intervention in Gramercy Park and Libby, Montana]." |