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Environmental Impact of 9/11 Attacks

EPA's reponse to the disaster vs. its legally mandated role

Project: Environmental Impact of the 9/11 Attacks
Open-Content project managed by Derek, paxvector

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A Senate report on Section 303 of the Clean Air Act states: “The levels of concentration of air pollution agents or combination of agents which substantially endanger health are levels which should never be reached in any community. When the prediction can reasonably be made that such elevated levels could be reached even for a short period of time—that is that they are imminent—an emergency action plan should be implemented.” [Environmental Protection Agency, 9/15/1983; Office of US Congressman Jerrold Nadler, 4/12/2002 pdf file]

Category Tags: Indoor remediation, EPA's reponse

With the passage of the Clean Water Act of 1972, the scope of the National Contingency Plan (NCP) is extended to cover hazardous substance releases in addition to oil spills. [Environmental Protection Agency, 12/23/2004] The NCP is a component of the US government’s National Response System, “a multi-layered system of individuals and teams from local, state, and federal agencies, industry, and other organizations that share expertise and resources to ensure that oil spill control and cleanup activities are timely and efficient” and that threats to human health and the environment are minimized. [Environmental Protection Agency, 4/19/2004] When in effect, the plan is administered by the EPA, which is required by law to follow specific procedures and guidelines, including designating an “On-Scene Coordinator” (OSC), who is responsible for directing response efforts and coordinating all other efforts at the scene of a discharge or release. In the event that the EPA delegates any tasks to state or local authorities, the EPA is responsible for ensuring that the response is in accordance with EPA standards. [US Code, Vol. 40, sec. 300; Jenkins, 7/4/2003 pdf file]

Category Tags: Indoor remediation, EPA's reponse, Key Events

A final rule is issued on the Emergency Planning and Community Right-to-Know Act (EPCRA). The rule states a “community right-to-know” public notification must be issued whenever there is a spill of any carcinogen in concentrations over 0.1 percent. [US Code, Vol. 40, sec. 372.38]

Category Tags: EPA's reponse

NESHAP regulations require use of the transmission electron microscopy (TEM) method to determine whether asbestos-derived wastes are asbestos free: “Transmission electron microscopy (TEM) shall be used to analyze the output material for the presence of asbestos.” In order to be considered “asbestos-free,” TEM results must indicate that the waste contains no asbestos. [US Code, Vol. 40, sec. 61.155] The TEM method is far superior to polarized light microscopy (PLM) testing, a less expensive method that is often used to test for the presence of asbestos in bulk building material. The PLM method is limited by relatively weak magnification (100-400x) and it is sometimes unable to distinguish asbestos material from other materials like tar and petroleum binding components that may also be present in the building material. As a result of these deficiencies, the PLM method cannot reliably detect asbestos at concentrations of less than 1 percent and it is incapable of detecting asbestos fibers that are less than .25 micrometers in width. [Jenkins, 3/11/2002 pdf file] TEM uses 20,000X or greater magnifications as well as powerful chemical (EDXA) and mineralogical (SAEDP) tools. Not only can TEM differentiate asbestos from non-asbestos fibers, but it can also distinguish one species of asbestos from another. [International Asbestos Testing Lab, 1/12/2006]

Category Tags: Misuse of EPA standards, EPA's reponse, Key Events

The EPA issues a pamphlet answering common questions on the Asbestos NESHAP regulations (see April 18, 1989). One question asks: “Is there a numeric emission limit for the release of asbestos fibers during renovations or demolitions in the asbestos NESHAP regulation?” The EPA answers that although there is no numeric emission limit, NESHAP “does specify zero visible emissions to the outside air from activity relating to the transport and disposal of asbestos waste.” In other words, if any emissions are visible during transport or disposal, the level of asbestos is unsafe. [Environmental Protection Agency, 12/1990]

Entity Tags: Environmental Protection Agency

Category Tags: Misuse of EPA standards, EPA's reponse, Key Events

1992: Federal Response Plan Becomes Law

The Federal Response Plan (FRP) is developed and becomes Public Law 93-288. The FRP provides “a process and structure for the systematic, coordinated, and effective delivery of Federal assistance to address the consequences of any major disaster or emergency declared under the Robert T. Stafford Disaster Relief and Emergency Assistance Act.” The plan can be called into action by the president of the United States in times of emergency. Once invoked, the Federal Emergency Management Agency (FEMA) coordinates the efforts of any Emergency Support Functions (ESF) involved. In the event of a hazardous materials release, the EPA is charged with overseeing the federal government’s response. The Federal Response Team (FRT) and Regional Response Teams (RRTs) are charged with “carry[ing] out their duties and responsibilities as put forth in the NCP [National Oil and Hazardous Substances Pollution Contingency Plan] (see 1972) and agency implementing procedures.” [Federal Emergency Management Agency, 8/1997]

Category Tags: EPA's reponse

A study commissioned by the EPA, “Evaluation of Three Cleaning Methods for Removing Asbestos from Carpet,” finds that available methods of asbestos removal from carpets and upholstery are incapable of effectively removing the fibers. “The wet cleaning method reduced the level of asbestos contamination in the carpet by approximately 60 percent, whereas neither dry cleaning method had any notable effect on the asbestos level,” the report says. [Environmental Protection Agency, 1993; Jenkins, 7/4/2003 pdf file]

Category Tags: EPA's reponse, Key Events

A study commissioned by the EPA, “Asbestos Fiber Reentrainment During Dry Vacuuming and Wet Cleaning of Asbestos-Contaminated Carpet,” finds that using HEPA vacuums and carpet shampooing in an effort to remove asbestos from carpets is ineffective and actually increases the air concentrations of asbestos. [Environmental Protection Agency, 1993; Jenkins, 7/4/2003 pdf file]

Category Tags: EPA's reponse, Key Events

The current version of OSHA Regulation 1910.1001, “Polarized Light Microscopy of Asbestos—Non-Mandatory,” recommends the use of “transmission electron microscopy” (TEM) to test for the presence of asbestos instead of the older, less sensitive method, known as “polarized light microscopy” (PLM). The regulation notes that “TEM is a powerful tool to identify fibers too small to be resolved by light microscopy and should be used in conjunction with this method when necessary” and suggests that “when optical techniques [PLM] are inadequate, there is ample indication that alternative techniques [TEM and SEM] should be used for complete identification of the sample.” SEM, or “Scanning Electron Microscopy,” is another method that provides less analytical information about the asbestos fiber than TEM. [US Code, Vol. 29, sec. 1910.1001]

Category Tags: EPA's reponse, Key Events

The Office of Management and Budget (OMB) issues its “Annual Report to Congress on Combating Terrorism” which reaffirms the EPA’s responsibility to respond to any hazardous materials emergencies caused by terrorist attack and provide the affected public with all information relevant to their health and safety. The report observes that the EPA has “expertise in performing off-site monitoring, extent of contamination surveys, working with health officials to establish safe cleanup levels, conducting protective cleanup actions, and communicating technical information/data to impacted citizens…” Moreover, the OMB notes that “EPA’s first responders (On-Scene Coordinators or OSCs) from all 10 regions have been actively involved with local, State, and Federal authorities in responding to threats of terrorism,” and that “EPA’s response to such threats is an extension of its existing hazardous materials response capability developed over more than 30 years as a leader of the National Response System (see 1972).” [Office of Management and Budget, 7/2001 pdf file; Environmental Protection Agency National Ombudsman, 3/27/2002]

Entity Tags: US Congress

Category Tags: EPA's reponse, Key Events

The World Trade Center twin towers collapse—the south tower at 9:59 a.m. and the north tower half an hour later at 10:28 a.m. [CNN, 9/12/2001; New York Times, 9/12/2001; New York Times, 9/12/2001; Washington Post, 9/12/2001; MSNBC, 9/22/2001; Associated Press, 8/21/2002] The collapses create huge dust clouds that roll through the streets of Lower Manhattan, breaking windows and forcing dust and debris into the interior of surrounding buildings.
Composition of dust - Chemicals and materials present in the billowing clouds include pulverized plaster, paint, foam, glass fibers and fragments, fiberglass, cement, vermiculite (used as a fire retardant instead of asbestos), chrysotile asbestos, polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls, polychlorinated dibenzodioxins, polychlorinated dibenzofurans, pesticides, phthalate esters, brominated diphenyl ethers, cotton fibers and lint, tarry and charred wood, soot, rubber, paper and plastic. [Allergy, Asthma & Immunology Online, 9/15/2001; CNN, 11/4/2001; Lioy et al., 7/2002; US Geological Survey, 10/2002 pdf file] The dust has an extremely high pH. [US Geological Survey, 11/27/2001; St. Louis Post-Dispatch, 2/10/2002]
Distribution of dust and debris - The debris will be distributed very unevenly throughout the city because of their varying weights. Dusts containing relatively heavy components, such as pulverized concrete and glass, will settle near the World Trade Center, whereas dust containing lighter components, like asbestos, will fall to the ground in greater relative concentrations at a further distance. Heavy metals—including zinc, strontium, lead and aluminum—will also be deposited a relatively large distance away from the disaster site. [Lioy et al., 7/2002; US Geological Survey, 10/2002 pdf file; Jenkins, 7/4/2003 pdf file]
Composition of smoke/debris plume - Combustible materials buried in the rubble of the towers provides fuel for a fire that will burn until December. Many of the materials are made of substances that when burned release highly toxic fumes. According to Thomas Cahill, a professor of physics and engineering, “The debris pile acted like a chemical factory. It cooked together the components and the buildings and their contents, including enormous numbers of computers, and gave off gases of toxic metals, acids, and organics for at least six weeks.” [BBC, 9/10/2003; Reuters, 9/11/2003]
bullet The two towers contained as many as 50,000 personal computers, each containing small amounts of mercury and about 4 lbs of lead. The towers also contained roughly 300 mainframe computers. [Nordgren, Goldstein, and Izeman, 2/2002 pdf file; Kupferman, 2003 pdf file]
bullet Thousands of fluorescent lamps in the buildings contained mercury. [Nordgren, Goldstein, and Izeman, 2/2002 pdf file; Kupferman, 2003 pdf file]
bullet Thousands of chairs and other office furniture contained chemicals like polybrominated diphenyl ethers, which pose dangers similar to PCBs. [Nordgren, Goldstein, and Izeman, 2/2002 pdf file]
bullet Several of the WTC’s tenants are known to have had toxic materials on site. For example, there was a Secret Service shooting range that kept millions of rounds of lead ammunition on hand. And a US Customs lab had in its inventory thousands of pounds of arsenic, lead, mercury, chromium, and other toxic substances. [Kupferman, 2003 pdf file]
bullet Other products in the buildings included synthetic fabrics, plastics, laminates, the di-electric fluids that encase electrical cables, capacitors, electrical cable insulation and transformers. The toxins resulting from the combustion of these materials include toxic lead, volatile organic compounds, dioxins (see December 27, 2002), mercury, nickel, vandium, sulphur, PAHs, PCBs and furans. [Nordgren, Goldstein, and Izeman, 2/2002 pdf file]
Distribution of smoke/debris plume - The aerosol plume will move from the WTC site in Lower Manhattan directly over Brooklyn where it will drop much of its toxic debris, contaminating the neighborhoods of Brooklyn Heights, DUMBO (Down Under the Manhattan Bridge Overpass), Cobble Hill, Boerum Hill, Park Slope and beyond. New York City Council member David Yassky, who is in Brooklyn campaigning on this day, will later recount in an interview with Newsday, “There was a film of dust on everything—on cars, stores, everywhere in Brooklyn Heights. If you were there, as I was, you saw several hours of debris rain down on your neighborhood.” [Newsday, 8/23/2002; Newsday, 9/30/2002]

Category Tags: Indoor remediation, Misuse of EPA standards, EPA's reponse, Rescue/recovery workers, Key Events

The 47-story WTC Building 7 collapses. It housed New York City’s emergency command center, offices of the FBI, CIA, and various commercial offices. The collapse of the building buries an electrical substation containing more than 130,000 gallons of oil from transformers and high-voltage lines—most of which contain low levels of hazardous PCBs—that provides fuel for a fire that will burn for more than three months contaminating the city’s air with a number of toxins including dibenzo-p-dioxins, dibenzofurans, and other polynuclear aromatic hydrocarbons. [Washington Post, 9/12/2001; Hang, 11/26/2001; New York Daily News, 11/27/2001; New York Daily News, 11/29/2001; Stanford Report, 12/5/2001; Environmental Law, 12/26/2001; Alexander's Gas & Oil Connections, 1/9/2002; Kupferman, 2003 pdf file]

Category Tags: Indoor remediation, Misuse of EPA standards, EPA's reponse, Rescue/recovery workers, Key Events

During a conference call, EPA Region 8 offers Region 2 free use of 30 to 40 electron microscopes, along with analysts, to test bulk dust samples in New York City. [Jenkins, 3/11/2002 pdf file] EPA Region 8 has a contract with EMSL Laboratories for the microscopes, which they are using to evaluate soils at the Libby, Montana cleanup site (see (August 2001)). Region 8 says they can get twelve of the scopes to Manhattan the next day. But William Muszynski, Region 2’s Acting Administrator, rejects the offer in less than polite terms. “We don’t want you fucking cowboys here,” Muszynski is later alleged to have said. “The best thing they could do is transfer you to Alaska.” [Jenkins, 3/11/2002 pdf file; Jenkins, 7/4/2003 pdf file] Instead, the EPA and other federal and city government agencies will use the outdated polarized light microscopy (PLM) testing method (see November 20, 1990) to test for the presence of asbestos fibers. [Seattle Post-Intelligencer, 2/28/2001; St. Louis Post-Dispatch, 1/14/2002]

Entity Tags: William Muszynski

Category Tags: EPA's reponse, Key Events

EPA Administrator Christie Whitman announces that the EPA is monitoring levels of airborne contaminants in and around the area of Manhattan. She says that samples so far are “reassuring about potential exposure of rescue crews and the public to environmental contaminants.” The tests “found either no asbestos or very low levels of asbestos.” In Brooklyn, which is directly in the WTC smoke plume’s path (see 9:59 a.m. September 11, 2001 and 10:28 a.m. September 11, 2001), she says that “levels of lead, asbestos and volatile organic compounds in air samples… were not detectable or not of concern.” [Environmental Protection Agency, 9/13/2001] However, her statements contradict results from transmission electron microscopy (TEM) tests that were conducted the previous day (see (September 12, 2001)).

Entity Tags: Christine Todd Whitman, Environmental Protection Agency

Category Tags: EPA's reponse, Government tests, Deception, Key Events

The New York City Department of Environmental Protection recommends in a memo to building owners in Lower Manhattan that they use the polarized light microscopy (PLM) method to determine the asbestos contamination level in their buildings instead of transmission electron microscopy (TEM) which is far more accurate (see November 20, 1990). [Wall Street Journal, 5/9/2002 pdf file]

Entity Tags: The New York City Department of Environmental Protection (DEP)

Category Tags: EPA's reponse, Key Events

An EPA press release summarizes the agency’s response to the September 11 attacks under its authority pursuant the National Contingency Plan (NCP) (see 1972). [Environmental Protection Agency, 9/24/2001]

Entity Tags: Environmental Protection Agency

Category Tags: EPA's reponse, Key Events

The decision to reopen Stuyvesant High School in Lower Manhattan is made based on tests of indoor air samples taken by the EPA. Two EPA “On Scene-Coordinators” (OSCs) (see (8:50 a.m. EST) September 11, 2001) are present at the meeting and participate in the decision-making. One of the OSCs is Charlie Fitzsimmons. [Environmental Protection Agency National Ombudsman, 3/27/2002]

Entity Tags: Charlie Fitzsimmons, Stuyvesant High School

Category Tags: EPA's reponse

On October 9, students of Stuyvesant High School, an elite public school known for its rigorous math and science curriculum and ethnic diversity, return to class. [Associated Press, 10/19/2001; Associated Press, 10/26/2001] The two EPA On-Scene Coordinators (OSC) who took part in the decision to re-open the school (see October 5, 2001) are present for the re-opening. [Environmental Protection Agency National Ombudsman, 3/27/2002] The school is located four blocks north of the WTC site and is downwind from its smoke plume. It is also adjacent to where debris is being loaded from uncovered trucks—some 350 per day—onto barges around the clock. A week after re-opening the school, approximately 100 of the high school’s 3,200 students and teachers complain of respiratory difficulty, mysterious headaches, nausea, sore throats, and nosebleeds. Some students wear respirators to school to protect themselves. [Associated Press, 10/19/2001; Associated Press, 10/26/2001; New York Daily News, 11/1/2001; New York Daily News, 12/20/2001]

Entity Tags: Stuyvesant High School, Charlie Fitzsimmons

Category Tags: EPA's reponse, Key Events

Environmental Protection Agency (EPA) Administrator Christie Todd Whitman, appearing before Congress, states: “Under the provisions of PDD 62, signed by President Clinton in 1998, the EPA is assigned lead responsibility for cleaning up buildings and other sites contaminated by chemical or biological agents as a result of an act of terrorism. This responsibility draws on our decades of experience in cleaning up sites contaminated by toxins through prior practices or accidents.” Her deputy, Linda Fisher, will repeat this to Congress a week later (see December 5, 2001). [US Congress, 4/12/2002]

Entity Tags: Christine Todd Whitman, Environmental Protection Agency, US Congress

Category Tags: EPA's reponse, Key Events

Deputy EPA Administrator Linda Fisher, appearing before Congress, states: “Under the provisions of PDD 62, signed by President Clinton in 1998, the EPA is assigned lead responsibility for cleaning up buildings and other sites contaminated by chemical or biological agents as a result of an act of terrorism. This responsibility draws on our decades of experience in cleaning up sites contaminated by toxins through prior practices or accidents.” [US Congress, 12/5/2001]

Entity Tags: US Congress, Linda Fisher

Category Tags: EPA's reponse

The EPA’s National Ombudsman’s office publishes a report criticizing the EPA’s response to the contamination that was caused by the destruction of the World Trade Center. Robert J. Martin, the EPA National Ombudsman, finds that the “EPA has neither fully used its legal authorities nor its existing hazardous materials response capabilities as a leader of the National Response System to aid the victims of the terrorist attack….” [Environmental Protection Agency National Ombudsman, 3/27/2002]
Observations -
bullet The EPA “initiated the National Contingency Plan (NCP) by mobilizing EPA On-Scene Coordinators (OSCs) [from various locations in the US to work] in Lower Manhattan (see (8:50 a.m. EST) September 11, 2001) to sample indoor and outdoor air, dust and water to, among other things, determine the levels of contamination.”
bullet “[T]he United States Geological Survey (USGS) testified that the plume of contaminated dust from the attacks was highly caustic with pH readings at least as high as 12.1 (see September 20, 2001).”
bullet “The Director of the Occupational Safety and Health Administration, has concluded that all dust from the World Trade Center attack must be presumed to be asbestos containing material (ACM) (see January 31, 2002).”
bullet “During the last thirty years as a leader of the National Response System, EPA has used the National Contingency Plan as a framework to perform indoor air testing and remediation where there have been releases of hazardous material into homes, schools, and/or offices throughout the United States.”
Conclusions -
bullet “A clear reading of the definition of hazardous waste under the Resource Conservation and Recovery Act (RCRA), leads to the reasonable conclusion that all of the material, released from the attack may be a hazardous waste.”
bullet “[A]ny cleanup of this dust, should have been and must now be performed in Ml compliance with the OSHA regulations including but not limited to 29 CFR 1910 and 1926.”
bullet “The EPA is not being honest about the presence of EPA On Scene-Coordinators in New York (see October 5, 2001) (see October 9, 2001-October 19, 2001) (see March 11th, 2002).”
bullet “EPA has not fully discharged its duties under PDD (Presidential Directive) 62 (see November 28, 2001), the National Contingency Plan (NCP) (see 1972), and the 2001 OMB Annual Report to Congress on Combating Terrorism (see August 2001). EPA has abandoned its responsibilities for cleaning up buildings (both inside and out) that are contaminated, or that are being re-contaminated, as a result of the uncontrolled chemical releases from the World Trade Center terrorist attack.”
Recommendations -
bullet “EPA Region II should, pursuant to authorities under Presidential Directive PDD 62, and the National Contingency Plan (NCF) immediately clean the ducts and upgrade the ventilation systems to install high efficiency filtration at the Stuyvesant High School during spring break.”
bullet “EPA Region II should execute authorities under Presidential Directive PDB 62, the National Contingency Plan (NCP), and consistent with Administrator Whitman’s statement in Libby, Montana four days before the World Trade Center terrorist attack, issue legal guarantees to all building owners, building managers, local businesses, the New York City Board of Education, and condominium and coop owners to protect them from assuming the costs of cleanup from the terrorist attack on the World Trade Center.”
bullet “Consistent with Presidential Directive PDD 62, the National Contingency Plan (NCP), and Administrator Whitman’s statement in Libby, Montana four days before the World Trade Center terrorist attack, EPA Region II should cleanup all impacted buildings (interiors and exteriors) in conjunction with corresponding remediation at ‘ground zero.’”

Entity Tags: Environmental Protection Agency, Robert J. Martin

Category Tags: EPA's reponse, Deception, The Transfer of the EPA Ombudsman, Key Events

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