Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

First, toe vast mass of dust and debris from toe WTC collapse has been removed. This is a result of cleanup during firn resporse actions, toe Ground Zero cleanup, cleanup of building exteriors by toe private sector and New York City. Second, in 95 % of the over 4,100 residences cleaned and tested or tested only, toe aritestos in toe air tesudls were See Appendix R non-detect. Lastly, cleanup techniques rtf wet mopping, wet wiping and HEPA INote 20 vacuuming were found to be successful in achieving health-based benefaroarks for WTC coataminacts of concern. EPA focused upon a cleanup program for residences, because this is where individuals spend toe roost time and where the greatest need for assistance in conducting cleanup and getting reassurance was evident.

Regarding dw need for “aggressive" air aampUng, EPA notes that scientists and physicians eatpert in environmental health issues advised EPA at a meeting convened by_____________ toe New York Academy of Medicine io June 2002, that aggressive sampling was not a Isee Appendix R rcpnEsentaiivo cteMfidoa for testing and potenoal exposotc. In addition, EPA’s Note 21 Confitmation Ckaaing Study did not find a measurable difference in use of modified or aggressive air disturtence technique in ^mpling.

Lastly, EPA did evaluate toe potetdial for health risks, qualitatively, for areas North of Conal Street, in Brooklyn, and beyond. The determination was that lower Manhattan ww the pctneipal impact area where toe mass of building materials from ths collapse was See Appendix R deposited and where die most lira plume exposure oocurred. In addition, EPA’s N<de22 judgement is that commercial establishments had alternative souicas of assistance to fund cleanup activity. EPA and OSHA have cootdinatBd throughout the indoor cleanup program, and OSHA has agreed to investigate any complaints by woricers in commercial establishments of dust exposure.

With respect to toe recommendation toot EPA submfr toe revised “World Trade Center Indoor Air Assessmenl” for a second peer review, the Agency disagrees. HPA does agree___________ that, as part of its efforts to develop indoor health based benchmarks, a protocol for See Appendix R estaWisBing these would be useftilly peer reviewed. Such a general protocol could take Note 23 into account what was done fw toe WTC Contaninwnts of Potential Concern (COPQ. EPA does not see any benefit to further peer review of toe WTC spoafic document

With respect to the tecommendHtioB that EPA implement a post-cleaning testing program to ensure that, in addititm to asbestos, the indoor cleanup program has reduced residents' risk of exposure frooi all of die identified COPCs to acceptable limits, the Agency disagrees. EPA believes drat the health based asbestos in air clearance testing is effective in reducing the potential fin* risk related to WTC contanuzianis. The results of (he See Appendix R Confirmation Cleaning Study support this, and the study results provide effective Note 24 guidance for additionaJ deaimp vdiere Acre are continued concerns.

respect to the recommeiidHtion that doe to concens overp<«sible rc-oontamiaation of residences cleaned under die Indoor Air Residential Assistance program, EPA should

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128 Report No. 2003-P-00012

NYC-WTC_000145659