EPA memo re: asbestos assessment and Superfund advantages, Jan 2002

NYC 9/11 Public Portal Document

Administration (FEMA) for reimbursement. This is false, and not borne out by the many accounts of citizens trying to apply for such costs. Some insurance companies have paid for cleaning, but others have not. Sometimes volunteers cleaned out buildings, and sometimes the Red Cross handed out vouchers for cleaning, but not by professional asbestos abaters. There are no statistics on what has actually happened.

Disorganized cleanup resulting in re-contamination of previously cleaned areas

The disorganization of the cleanup is resulting in cross-contamination of previously cleaned areas. Some individual apartments may well be cleaned using professional abatement. But if another apartment is not cleaned, the air ducts for the whole building can become contaminated again. Dusts can be tracked from one area inside the building which is not effectively cleaned to another area which is cleaned.

3. ADVANTAGES FOR A CLEANUP UNDER SUPERFUND At this time, I believe that the best solution to the problem in Lower Manhattan is to invoke one or more parts of the Comprehensive Environmental Response and Liability Act (CERCLA), or Superfund. It would bring order to the situation and begjn to alleviate the current exposures to asbestos, fiberglass, fine particulates, and other toxic substances like mercury and fead. It would enable the use of better methods to test and monitor the contamination, particularly for asbestos. It would take the financial burden away from citizens and transfer them to the government.

It would add credibility to the final solution after the action was completed. Under CERCLA, there would be a point in time where the government could announce that the action was finished, and that Manhattan was restored. Otherwise, there will be no opportunity for the government to declare closure.

Two types of action under Superfund are possible

In Montana, the governor exercised the “silver bullet” option under CERCLA by requesting that EPA put Libby on the fest track for listing on the National Priorities List, which means making it a Superfund site. As a result, Libby does not have to wait years for EPA to assess its hazards and rhake comparative cost-benefit judgements. Federal money would go immediately to the cleanup, although the state would be required to contribute 10% of the costs. The costs should not be a problem to New York, as the federal government is already contributing as much as it

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