NYC 9/11 Public Portal Document
are unfounded. There is testimony that is true:. tThe trucks transporting WTC debris were not
marked as carrying hazardous waste. Howeyenj-They were not marked in this manner because
they were not carrying hazardous waste. This is just one example where testimony should have
been critically evaluated before including it in the report. Of more concern is the uncritical
acceptance of testimony of trucks not being wetted down properly and trucks not being covered
properly, both resulting in the release of dust. The area around Stuyvesant High School was
among the most thoroughly monitored in the City. There is no data to show that this area was
contaminated by the operation of the transfer station from trucks to barges in the vicinity of the
High School. Thus, if there was a release of dust, it was so insignificant as to present no risk at
all to health and safety and should not be highlighted in this report. EPA itself, represents that
air sampling concerning barge operations indicated that 99.83% of the samples were below the
screening levels. The City consequently recommends that this paragraph be deleted.
18. The paragraph that begins at the bottom of page 12 should be modified. The last
sentence reports that there was lead found in the ventilation system of Stuyvesant High School.
The sentence also reports that it was not determined whether this lead was from WTC fallout.
Given the dearth of air samples that were positive for lead and the fact that lead is unlikely to
travel far as an airborne particulate, it is very unlikely that the lead found in the ventilation
system was from WTC fallout. Even if it was, this has nothing to do with the City’s EPA's
fNOTE: this is the IG’s report on the EPA's response and we should keep the focus on the EPAI
response to the terrorist attacks on the World Trade Center. While this may be of some academic
interest, it has no place in this part of the report. The City recommends that this sentence be
deleted.
19. The first paragraph in the section labeled “Asbestos Levels During Demolition and
Debris Removal” is misleading. It unduly emphasizes that after September 2001 there were 7
air monitoring samples which exceeded the AHERA standard. It does not mention that there
were approximately 40,000 samples taken during this period. Considered in this context, the fact
that there were only seven exceedances demonstrates that the danger from asbestos was, in
essence, non-existent. The report not only does not draw this conclusion, which is warranted,
but it mischaracterizes the seven exceedances as showing the sporadic presence of asbestos in the
ambient air. Given the extensive monitoring, less than one exceedance per month can hardly
even be characterized as '’sporadic.” We recommend that the paragraph be revised to delete the |
table showing the exceedances and any reference to the table be deleted. And, also reference that
two of the exceedances were near Stuyvesant High School. Reference to Stuyvesant implies that
this location should be given preference over other locations near the site. The fourth sentence
of the paragraph should be revised to read, “Out of approximately 40,000 samples taken fi-om
October 2001 through May 2002 there were only seven exceedances of the AHERA standard.”
The seventh sentence should be revised to read, “The above information shows the virtual non
existence of asbestos in the ambient air in publicly accessible locations at levels of concern
established by EPA for the WTC response (i.e., the AHERA standard) from October 2001 to
May 2002.”
20. The second full paragraph on page 20 beginning, “The indoor residential cleanup
program” is inaccurate. The second sentence states that the Governor of New York did not
declare a public health emergency. Although the Governor did not declare a public health
emergency, he declared a “general emergency”, which is construed to include a public health
Revised Draft SB Comments.doc 6 8/3/3
NYC-WTC_000153032
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