Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

indicated that dust from the collapse did not extend beyond Canal Street. Environmental experts told us that ideally a sampling plan should have been implemented that collected and analyzed samples starting at Ground Zero and radiating outward in concentric circles until the boundary of WTC contamination was determined.

Conclusions Extensive ambient monitoring data collected after September 11 demonstrated that outdoor air quality levels around Lower Manhattan eventually returned to pre­ September 11 levels. As such, EPA does not need to take additional actions to address outdoor ambient air quality concerns specifically related to the collapse of the WTC towers.

EPA, in cooperation with FEMA and New York City, 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 employ aggressive testing in all residences and treat buildings as a system. Additionally, EPA should evaluate the potential health risks for pollutants of concern in workspaces and for geographic areas north of Canal Street, in Brooklyn, and any other areas where meteorological data show pollutants of concern may have been deposited.

Recommendations We recommend that the EPA Administrator ensure that EPA Region 2:

6-1. Submit the revised “World Trade Center Indoor Air Assessment: Selecting Contaminants of Potential Concern and Setting Health-Based Benchmarks” document to TERA for a second peer review.

6-2. Implement a post-cleaning testing program to ensure that, in addition to asbestos, the indoor cleanup program has reduced residents’ risk of exposure from all of the identified COPCs to acceptable limits.

6-3. Due to concerns over possible re-contamination of residences cleaned under the Indoor Air Residential Assistance program, EPA should treat buildings as a system and implement a post-cleaning verification program to ensure that residences cleaned by the program have not been re-contaminated.

6-4. Work with FEMA and OSHA to assess whether the ongoing residential testing and cleaning program should be expanded to address potential contamination in workspaces in Lower Manhattan, or whether other measures need to be taken to ensure that workspaces are not contaminated with WTC dust.

53 Report No. 2003-P-00012

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