Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

Eirsa, the vast mass of dust and debris from the "WTC collapse has been removed. This is a result of cleanup during the response actions, foe Ground Zero deaaup, cleanup of building exteriors the private Stttor andNew York City. Second, in 95 % of the over_____ 4,100 residences cleaned and tested or tested only, tire asbestos in the air rtetdts were See Appendix R nmi-detect- Lastly, cleanup techniques of wet mopping, wet wipir^ and HEPA INote 20 vacuuming were found to be succ^sful at achieving health-based boichroarks for WTC contaminants of concern. EPA focused upon a cleanq» program for residences, because this is whne individuaJs spend foe most time and where the greatest need for assistance in GonductOBg cleanup and getting reassurance was evident

Regseding the need for “a^rossive” air aampUng, EPA notes that scientists and physicians expert in aaviionmental health issues advised EPA at a meeting convened by_____________ die New York Academy of Medicine io June 2002, that aggressive sampling was not a ISee Appendix R representative oondition for testing and potential exposoie. In addition, EPA’s Note 21 Confitmation Cleaning Study did not find a measurable difference in foe use of modified or aggressive air distarbance technique in sampling.

Lastly, EPA did evaluate the potential for health risks, quaJitativety, for areas North of Conal Street, in Brooklyn, and beyond. The determination was that lower Manhattan nw___________ the pcincipal impact area where the mass of building materials from the collapse was See Appendix R deposited and iMuans die most the plume ejsposuie occurred. In addition, EPA’s Note 22 judgement is tbat coramcrcisi establishments had alternative ajuxees of assistance to ftmd cleamip activity. EPA and OSHA have coordinated throughout the indoor cleanup program, and OSHA has agreed to investigate any oomplaitifs by workers in commercial establishments of dost exposure.

With respect to the rccoiumcndation that EPA submit foe revised “World Trade Center Indoor Air Assessment” for a second peer review, the Agency diss^ees. EPA does agree___________ Ihat, as pan of its efforts to develop indoor health toaed ‘benchmarks, a protocol for ISee Appendix R estahlisbiDg these would be usefiitly peer reviewed. Such a general protocol could take Note 23 into account what was done for foe WTC CcaManririanis of Potential Concern (COPC). EPA does not see any benefit to further peer review of foe WTC specific document

With mpect to the Tecornmendation tiiat EPA baptement a post-cleaning toting program to ensure that, in addition to asbestos, the indoor cleanup program has reduced residents' risk ofexposure ftotn all of the identified COPCs to acceptable limits, the Agency disagrees. EPA believes that the health based asbestos io air clearance testirrg is effective in reducing the potential for risk (dated to WTC contamiiuantx. The results of die See Appendix R Confirmation Cleaning Study support this, and the study results provide effective Note 24 guidance for additional cleanup vdiere there are continued concerns.

respect to fte recomraeadHtion that doe to concems over possibk re-contamination of residences cleaned under the Indoor Air Residential Asastance program, EPA should

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128 Report No. 2003-P-00012

NYC-WTC_000145483