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EPA memorandum on WTC environmental data concealment, July 2004

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EPA internal memorandum addressing allegations that NYC and EPA concealed environmental data following 9/11, with evidence not previously evaluated in an August 2003 EPA Inspector…

NYC-WTC_000153780–000153811

Folder label: “WORLD TRADE CENTER - JOHN LADUCA FILES

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NYC 9/11 Public Portal Document

The Senate's cloakrooms and press gallery were reopening Wednesday, a day after they had been shut down because asbestos was detected in the adjacent Senate chamber. ...

A piece of the fiber was discovered in the chamber's ventilation system Sunday night as work on an asbestos abatement project was ending, said Eva Malecki, spokeswoman for the Capitol architect's office.

Tests in the chamber found readings as high as 99 structures per square millimeter. Federal law considers anything above 70 to be a problem. A structure is an asbestos particle or piece of a particle. Officials realized Tuesday that similar problems might exist in the cloakrooms and press gallery because they share some auxiliary ducts with the chamber, Malecki said. Reporters and press gallery staff were told to leave the gallery at about 1 p.m. EDT. ...

The response to the Senate contamination problem was appropriate and within guidelines and regulatory standards set by EPA. The response to the WTC collapse was not. Furthermore, citizens were being exposed to many other contaminants in addition to asbestos after 9/11, which should have caused even greater concern.

EPA presumption: asbestos hazard from implosions/fires Regardless of whether or not EPA had data showing hazardous levels of asbestos at the time of their early statements, there is an established EPA presumption there will be hazardous levels if a building implodes with an ensuing fire.

EPA has regulatory guidance under the Clean Air Act asbestos standards (National Emission Standards for Hazardous Air Pollutants) which requires removal of all asbestos from a building if it is going to be demolished by an implosion with the subsequent possibility of a fire.

To the point, EPA states that if the military is going to use a building for target practice, and a fire may result, then asbestos materials must be removed first?’

EXPLOSIONS/IMPLOSIONS Building implosions utilizing explosive devices constitute a rarely-used demolition technique. In simplest form, this method is accomplished through the use of explosive charges placed strategically throughout a building so that the building collapses in on itself and debris does not radiate outward to any appreciable distance. Relatively large quantities of dust are created, however, and the direction and magnitude of transport are matters of concern. ...

The destruction of buildings during military target practice is considered to be another form of explosive demolition. Category I materials may remain in place during target practice. However, if it can be expected that the building and ACM will burn as a result of explosive demolition, the ACM must be removed prior to demolition.

Thus, EPA did not need any testing to know that there would be an asbestos hazard in lower Manhattan after 9/11. In the absence of data or even if there was limited non-statistical data, EPA should have evacuated the areas impacted by the WTC dust cloud and plume.

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NYC-WTC_000153792Source: NYC Law Department, mirrored locally

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