Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

WTC towers. EPA. in ooopetatioB with FEMA and New York City, has initiated a large-sc^ indoor cleanup. In our opinion, this cleanup should meet the mhumum criteria for protecting human beattk teat EPA has established for Superfond deanujs. .Also, the indoor eteaiung and testing program should employ aggressive testing la aS residences and treat buildiogs as a system. Additionally, EPA should evaluate the potentisd health risks fra* pollutants of concern in wojk spaces and for geographic areas north trf Canal Street, in Brootc^yn, and any other areas where meteorological data show pollntants of concern, may have been deposited."

Ret<«BTO<Bd**ion: Ito the EPA Adrainisbator ensure toot EPA Region 2:

Submit the revised "World Trade Center Indoor Air Assesnstent: Sefectirtg Contaminants of Potential Concern tod Setting Health-Based Benchmarks: docamecd to TERA for a second pecs review.”

bnpientant a post-eicarang tostotg prograni to emsure that, in addition to A^iestos, the indoor ctean^p program has reduced residents’ risk of e^toswe from all of the identified COPCs to atxeptable liraits.

Dim: to conoeros ovex possible rs-contaminatioa of rosidertces ekaned under the Indoor Air Residential Assistance program. EPA should treat hfuildinga as a system and implement a post-cliamiag verificatioo program to ensure tint residences cleaned by the jat^pam have mn been re-contamifitHod. Wads with HEMA skI OSHA to assess whether the tHagoing Tesidentid teslmg and elcaait^ program should be expiUKted to address poteatiaJ coniaminatioo is work spaces is I-owcr Manhattan, or w4iether other measures need to be taken to ensure Ont work Spaces are not conTamiaated with WTC dust.

F.PA Response:

EPA, in cac^uRction with New York City and has iaitiateci and neatly completed a ha^«5cale indoor deanup under the Federal Response Flan - twt Superfund and die jnoipam baa met the ccltena for {notecting human health. Under this prograan EPA did cleaning and testing in 675 building “footprints’" as ideotified in the city's building unventory. Emm NYC retards, there aj^icar to be itoout 224X83 residcatiel unite below Canal Street 'Theae are 2,323 buildiiig footprints which would also include: See Appendix R approximately 1550 commercial buildings. If a cleanup prograro were expanded to Note 18 mcMe all of these buildings footprints and die commwcial ^lace thcreuo, it would be a momunental undettaking which EPA studies and data indicate is not necessaty

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127 Report No. 2003-P-00012

NYC-WTC_000145482