Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document tn summary, EPA’s initial role in support of New York city and State officials in no way created additional health risk to workers ar residents. In fact, EPA and other federal, state and city agencies responded to the best of their abilities to reduce potential risk os quickly aad as reasonably as poasiblc. EPA generally agrees with the recommendarians concerning coordination with the Department of Homeland Security and other federal oo ssetsesee agencies, and that 2he topic of roles and responsibilities for all levels of government wede-y ealid R | reganting potential contamination of indoor spaces should be further explored. The Agency further agrees tist consideration should be given to possible identification of sampling racthods, benchruatks, circumstances where goveroment-assisted cleanups are appropriate, funding support and comununications. CHAPTER 4 ASBESTOS EMISSION CONTROL WORK PRACTICES INCONSISTENT Report Conclasion/Recommendation: « Conckusian: “Although many steps were taken to coduce asbestos emissions from the WTC site, problems were encountered in fally implementing the applicable NESHAP requirements for emergency situations, such ss ensuring that trucks transporting debris were adequately wetted dawn before leaving the WTC site. Further, the placement of WTC debris, unloading and transfer operation near schools and residences compounded the potential impact of not implementing normally required NESRAP requirements. : Given the fikeliheod that many buildings across the country may contain asbestos, EPA and State and tocal agencies need to establish improved monitoring and oversigix, procedures for ensuring appropriate NESHAP work practices are followed in responding to situations that cuuse widespread damage.” * Recosamendation: The EPA Administrator ensure that EPA Regional and Headquarters personne are aware of the “Guidelines for Catastrophic Emergency Situations Involving Asbestos.” including its application in the event of future terrorist attacks or other disasters. EPA develop specific monitoring, reporting and oversipht procedures for ensurmg that foderal, State, end local responders fallow the appropriate asbestos NESHAP work practices, inchiding initiating ecforcement actions when EPA observes viatations of NESHAP work practices. EPA Response: in the immediate aftermath of WTC collapse and fires, “eavuring” compliant work practices was extremely difficult. This was net for lack of knowledge about whet should be done, but tather 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 5 124 Report No. 2003-P-00012 NYC-WTC_000145655