Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

Both NYCDDC and OSHA officials told us that the WTC site was under continuous dust suppression, and the latter said this dust suppression was very successful. An EPA On-Scene Coordinator told us that once dust suppression began, water was sprayed wherever there was dust and, to the best of his knowledge, this practice was successful. OSHA officials further stated that it would have been too dangerous to send abatement contractors into WTC 4, WTC 5, or WTC 6 to remove asbestos-containing material before demolition.

Both NYCDDC and EPA officials told us that when asbestos-containing material (e.g., pipe wrapping, steel insulation) was encountered during the removal, it was tested and treated in accordance with asbestos abatement procedures. According to the NYCDDC official, the majority of the asbestos-containing material was encountered when removing the remnants of the basement levels of WTC 6.

EPA Situation Reports confirmed statements about asbestos abatements and recorded instances where asbestos was found during debris removal and asbestos abatements performed. For example, the EPA May 23,2002, Situation Report noted that:

Twelve (12) bulk asbestos samples were taken in the Bl, B2, B3, levels of (WTC) Building 6. The samples were taken from sprayed on insulation at the request ofNYC DOI. Of the twelve samples, nine (9) should (sic) results were in excess of 1% Chrysotile asbestos, the results rangedfrom 1.30% to 30.80%. The three samples that were not above 1% were detectfor Chrysotile asbestos.

According to the April 5, 2002, Situation Report, bulk testing showed that one sample of the pipe wrap that was being removed as part of this abatement contained 66 percent amosite" asbestos.

l/I/drk Practices Related to Transporting Waste Not Always Followed

To minimize dust emissions. City, State, and Federal officials established procedures for trucks hauling debris from the site. These procedures included the use of tarps (nylon mesh) to cover debris and procedures for wetting down the trucks before they left the site. The truck wetting operation was performed by contractors for EPA. The large volume of traffic made ensuring compliance with procedures difficult. Particularly in the weeks immediately following the disaster, trucks hauling debris from the site did not consistently stop to be wetted down before leaving the site. As a result. New York City obtained assistance from the New York State Department of Environmental Conservation Police and the National Guard to ensure that trucks stopped at the wash stations before leaving

11 Amosite is a form of amphibole asbestos. Several studies suggest that amphibole asbestos may be more harmful than chrysotile asbestos, particularly for mesothelioma. Test results from the site showed that the asbestos was predominantly chrysotile, not amphibole.

36 Report No. 2003-P-00012

NYC-WTC_000145391