Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document WIC towers. EPA, in cooperation with FEMA and New York City, has initiated a large-scale indoor cleanup. In our opinion, this cleanup should meet the minimum criteria for protecting human health that EPA has established for Superfund cleanups. Also, the indoor cleaning and testing program should ernmploy aggressive testing ia alt residences and treat buildings as a system. Additionally, EPA should evaluate the potential health risks for pollutants of concern in work spaces and for geogruphic areas north of Canal Street, in Brooklyn, and any other areas where meteurological data show pollutants of concer may have been ton: That the EPA Administrator ensure that EPA Region 2° Submit the revised “World Trade Center Indoor Air Assessment: Selecting Contaminants of Potentis] Concern and Setting Health-Based Benchmarks: document to TERA for a second peer review.” Implerocnt a post-cleaning testing program to ensure that, in addition to asbestos, the indoor cleanup program has reduced residents’ sisk of exposurc from all of the identified COPCS to acceptable Sienits. Duc to concems over possibic re-contamination of residences cleaned under the Indoor Air Residential Assistance program, EPA should treat buildings as a system and implement a post-cleaniug verification program to ensure that residences cleaned by the Piogrant have not been re-contaminated. Work with FEMA and OSHA to assess whether the ongoing residential testing and cleaning program should be expanded to address potential contamination in work spaces in Lower Manhattan, or whether other measures need to be taken to ensure that work spaces are not contaminated with WTC dust. EPA Response: EPA, in conjunction with New York City and FEMA, has initiated and nearly completed 3 Jarge-scale indoor cleanup under the Federal Kesponse Plan — not Superfund and the progran has met the criteria for protecting human health. Under this program EPA did cleaning and testing in 675 building “footprints” as identified in the city's building inventory. From NYC moords, there appear to be about 22,000 residential units below Canal Street. There are 2,323 building footprints which would also include Appendix R 1550 commercial buildings. If a cleanup prograro were expanded to —— [Note 19 inchide all of these buildings footprints and the commercial space therein, it. would be a monumental undertaking which EPA shudies and data indicate is mot necessary 127 Report No. 2003-P-00012 NYC-WTC_000145658