Internal routing form for WTC environmental documents, date unknown

NYC 9/11 Public Portal Document

Our efforts are consistent with the NCP provisions regarding the respective roles of different federal agencies and organizational elements, such as the National and Regional Response Teams and the On-Scene Coordinator. [See 40 C.F.R. Part 300 Subpart B.]

We are responding to residents’ concerns in a manner consistent with the NCP. [See, for example. Section 300.415(n) of the NCP (“Community relations in removal actions”).] In brief:

(a) we have designated spokespersons for our programs related to the attack on the WTC, who respond to inquiries and keep the community informed regarding our actions. They will make available data related to indoor air concerns in lower Manhattan, providing such data in a manner that does not divulge the address of a given residence or the name of a given resident;

(b) we have been meeting and will continue to meet with public interest groups or other interested or affected parties, as appropriate, to solicit their concerns and information needs, and find out how or when citizens would like to be involved in the process;

(c) we have prepared a draft communications strategy and many fact sheets much of this informational material addresses many of the concerns raised in the meetings with community members;

(d) we have established at least one local information repository in lower Manhattan (290 Broadway) which is accessible to the public. At that location we will make available documents which have formed the basis of our actions.

We have met with interested members of the public on the scope of work that is the basis of NYC’s solicitation for the cleanup and testing program. Working with NYC, significant changes were made to the scope based on the recommendations provided by the public.

We have developed the clearance level (that is, the risk-based cleanup goal) to determine when cleaning can cease at a residence under the Indoor Air Residential Assistance Program - WTC Dust Cleanup. The development of this level has been consistent with the NCP. For example, under the NCP, removals performed either by EPA with Superfund monies or by responsible parties need to attain applicable or relevant and appropriate requirements (ARARs) “to the extent practicable considering the exigencies of the situation.” [Section 300.415(j) of the NCP] For the Indoor Air Residential Assistance Program - WTC Dust Cleanup there are not any directly applicable standards. So, as is a common practice in removal actions under the NCP, we have developed a risk­ based clearance number for asbestos in air, taking into consideration other standards. We have consulted with peers in the scientific community regarding the use of this level as an extremely protective long-term risk guideline.

NYC-WTC_000151598