World Trade Center: Preliminary Observations on EPA's Second	 
Program to Address Indoor Contamination (20-JUN-07, GAO-07-806T).
                                                                 
The September 11, 2001, terrorist attack on the World Trade	 
Center (WTC) turned Lower Manhattan into a disaster site. As the 
towers collapsed, Lower Manhattan was blanketed with building	 
debris and combustible materials. This complex mixture created a 
major concern: that thousands of residents and workers in the	 
area would now be exposed to known hazards in the air and in the 
dust, such as asbestos, lead, glass fibers, and pulverized	 
concrete. In May 2002, New York City formally requested federal  
assistance to address indoor contamination. The Environmental	 
Protection Agency (EPA) conducted an indoor clean and test	 
program from 2002 to 2003. Several years later, after obtaining  
the views of advisory groups, including its Inspector General and
an expert panel, EPA announced a second test and clean program in
December 2006. Program implementation is to begin later in 2007, 
more than 5 years after the disaster. GAO's testimony, based on  
preliminary work evaluating EPA's development of its second	 
program, addresses (1) EPA's actions to implement recommendations
from the expert panel and its Inspector General, (2) the	 
completeness of information EPA provided to the public in its	 
second plan, and (3) EPA's assessment of available resources to  
conduct the program. We discussed the issues we address in this  
statement with EPA.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-806T					        
    ACCNO:   A71048						        
  TITLE:     World Trade Center: Preliminary Observations on EPA's    
Second Program to Address Indoor Contamination			 
     DATE:   06/20/2007 
  SUBJECT:   Contaminants					 
	     Contamination					 
	     Environmental monitoring				 
	     Government information dissemination		 
	     Health hazards					 
	     Pollution control					 
	     Program management 				 
	     Terrorism						 
	     Program evaluation 				 
	     Testing						 
	     Program implementation				 
	     FEMA Federal Response Plan 			 
	     World Trade Center (NY)				 

******************************************************************
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GAO-07-806T

   

     * [1]Background
     * [2]EPA Incorporated Some Recommendations, but Its Decision Not
     * [3]EPA Did Not Provide the Public With Sufficient Information t
     * [4]EPA Did Not Adequately Assess Resource Needs for the Second
     * [5]Concluding Observations
     * [6]Contacts and Acknowledgments

          * [7]Order by Mail or Phone

Testimony

Before the Subcommittee on Superfund and Environmental Health, Committee
on Environment and Public Works, U.S. Senate

United States Government Accountability Office

GAO

For Release on Delivery
Expected at 10:00 a.m. EDT
Wednesday, June 20, 2007

WORLD TRADE CENTER

Preliminary Observations on EPA's Second Program to Address Indoor
Contamination

Statement of John B. Stephenson, Director
Natural Resources and Environment

GAO-07-806T

Madam Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss the preliminary results of our
ongoing work on the development of the Environmental Protection Agency's
(EPA) second program to address World Trade Center (WTC) indoor
contamination. As you know, the September 11, 2001, terrorist attack on
the World Trade Center turned Lower Manhattan into a disaster site, on a
scale the nation had never experienced. The World Trade Center was a
complex of seven buildings on 16 acres surrounding a 5-acre plaza in Lower
Manhattan. The twin towers were at the center of the complex. Each tower
had 110 floors, with approximately 43,200 square feet on each floor. As
the towers collapsed, Lower Manhattan was blanketed in a mixture of
building debris and combustible materials that coated building exteriors
and streets, as well as the interiors of apartments and offices. This
complex mixture gave rise to another major concern: that thousands of
residents and workers in the area would now be exposed to known hazards in
the air and in the dust, such as asbestos, lead, glass fibers, and
pulverized concrete.

On the day of the attacks, the President signed a major disaster
declaration, which activated the Federal Response Plan. The Federal
Response Plan, now replaced by the National Response Plan, established the
process and structure for the federal government's assistance to state and
local agencies when responding to any major disaster or emergency declared
under the Robert T. Stafford Disaster Relief and Emergency Assistance Act
(Stafford Act).1 In May 2002, after numerous cleanup, dust collection, and
air monitoring activities were conducted outdoors by EPA, other federal
agencies, New York City and New York State, New York City formally
requested federal assistance to clean and/or test residences in the
vicinity of the WTC site for airborne asbestos.2

The Federal Emergency Management Agency (FEMA), which administered the
Federal Response Plan, provided such assistance, entering into interagency
agreements with EPA in 2002 to develop EPA's first program. This program
allowed residents of Lower Manhattan living south of Canal Street
(representing over 20,000 residences) to elect to have their home
professionally cleaned, followed by testing, or to have their home tested
only. Approximately 20 percent of the eligible residences participated in
the program. The majority of these residences were professionally cleaned
before they were sampled for asbestos because their owners selected the
clean and test option rather than the test only option.3 Even though
samples were collected after cleaning in most cases, some residences (less
than 1 percent) were still found to have unsafe levels of asbestos.

142 U.S.C. S 5121, et seq. The purpose of the Stafford Act is "to provide
an orderly and continuing means of assistance by the Federal Government to
State and local governments in carrying out their responsibilities to
alleviate the suffering and damage which result from such disasters." 42
U.S.C. S 5121(b).

2In addition to using asbestos as a trigger for cleanup, in a small subset
of residences, EPA conducted sampling for dioxin, mercury, and 22 metals
to inform a study about the effectiveness of its cleaning techniques.

EPA's first program was criticized by several entities; as a result, EPA
developed a second program, which is the focus of our ongoing work and our
testimony today.4 Let me provide some information on the events leading up
to the second program.

In August 2003, EPA's Inspector General made recommendations that
addressed EPA's initial efforts to clean up indoor contamination following
the towers' collapse, as well as recommendations that focused on EPA's
future preparedness for large-scale disasters resulting in indoor
contamination. The Inspector General reported that the effort to clean up
indoor WTC contamination was inadequate for multiple reasons. For example,
according to the Inspector General, the WTC cleanup did not require that
entire buildings be systematically cleaned, including heating,
ventilation, and air conditioning (HVAC) systems. As a result, the
Inspector General concluded, the contaminants in uncleaned apartments and
common areas could enter the air supply system and re-contaminate cleaned
spaces. With regard to future preparedness, the Inspector General
recommended, among other things, that EPA develop protocols for
determining how indoor environmental contamination would be handled in the
event of a future disaster.

3EPA regional officials overseeing the program told us they assumed that
some residents elected to have testing only because they had their
residences cleaned before EPA's program.

4A lawsuit was filed in March 2004 that, among other things, challenged
the adequacy of EPA's first test and clean program. The case is on appeal
in the U.S. Court of Appeals for the Second Circuit. Benzman v. Whitman,
No. 04-1888 (S.D.N.Y. filed March 10, 2004), appeal docketed, Nos.
06-1166-cv, 06-1346-cv, 06-1454-cv (2nd Cir. March 10, 2006). Pursuant to
its long-standing policy of not addressing issues in ongoing litigation,
GAO has not addressed EPA's first test and clean program.

The White House Council on Environmental Quality (CEQ) indicated in
October 2003 that EPA would organize and lead an expert technical review
panel to address the concerns of the Inspector General and others. In
March 2004, EPA convened the WTC Expert Technical Review Panel, which met
periodically through December 2005. The panel was composed of 20
individuals from academia and from city and federal health and science
agencies, such as the Department of Labor's Occupational Safety and Health
Administration (OSHA) and the Department of Health and Human Services
(HHS). It also included two representatives from the Community-Labor
Coalition (CLC), which is a network of community, tenant, labor, and
environmental organizations formed after September 11, 2001, to advocate
for appropriate health and safety efforts in the recovery from the WTC
attack. The panel's overall task, as outlined by CEQ, was to advise EPA on
efforts to protect New York City residents and workers potentially
affected by the collapse of the World Trade Center. Specifically, the
panel's goals were to help guide EPA in (1) identifying any remaining
risks using exposure and health surveillance information; (2) identifying
any unmet public health needs; and (3) determining steps to further
minimize the risks. In addition, the panel was asked to provide advice for
EPA's second program. Panel members, including the CLC representatives,
submitted individual recommendations to EPA.

After obtaining the views of advisory groups, including the Inspector
General, the expert panel, and the CLC, EPA announced its plan for a
second program in December 2006. This 2006 plan targets residents and
building owners in the same portion of Lower Manhattan as EPA's first
program. In the 2006 plan, EPA also provided the results of the sampling
from its first program. The second program is set to begin later in 2007.
As of May 10, 2007, EPA told us, 295 residents and building owners had
enrolled in the second program, compared with 4,166 eligible participants
in the first program. Figure 1 shows the chronology of events preceding
the second program.

Figure 1: Timeline of EPA's WTC Indoor Contamination Activities

aEPA's registration period ended in March 2007, but as of June 20, 2007,
EPA has not begun implementing the program.

Our testimony, which is based on our ongoing work evaluating EPA's
development of its second program, discusses (1) EPA's actions to
implement recommendations from the expert panel and its Inspector General,
(2) the completeness of information EPA provided to the public in its
second plan, and (3) EPA's assessment of available resources to conduct
the program.

In summary, while we found that EPA has taken some actions to incorporate
recommendations from the Inspector General and expert panel members into
its second program, it decided 'not to incorporate other recommendations,
which may limit the program's overall effectiveness. For example, EPA's
second program incorporates recommendations to expand the number of
contaminants tested, from asbestos only, to three additional contaminants
and to test in dust as well as in the air. However, EPA's program does not
incorporate a recommendation to expand the boundaries of cleanup to north
of Canal Street and to Brooklyn. EPA reported that it was unable to
develop a method for distinguishing between normal urban dust and WTC
dust; therefore, the agency reported that it cannot assess the extent of
WTC contamination, and has no basis for expanding the cleanup effort. EPA
did not begin examining methods for differentiating between normal urban
dust and WTC dust until May 2004--nearly 3 years after the disaster--and
therefore the process for differentiating was more difficult. In addition,
EPA's second program does not incorporate recommendations to sample in
HVACs or "inaccessible" locations within apartments and common areas, such
as behind dishwashers. The agency chose to offer more limited testing in a
greater number of apartments and common areas rather than to provide more
comprehensive testing (such as in HVACs) in a smaller number of these
areas. Testing in such a restricted manner make evaluating the adequacy of
clean up efforts very difficult, and may discourage participation.
Moreover, this program does not incorporate the recommendation to test
workplaces because, according to EPA officials, other federal agencies
have procedures to address worker safety. We discussed the issues we
address in this statement with EPA.

EPA did not provide sufficient information in its second plan to allow the
public to make informed choices about their participation. Specifically,
EPA did not fully disclose the limitations in the testing results from its
first program. EPA concluded that a "very small" number of samples from
its first program exceeded risk levels for airborne asbestos. However, EPA
did not explain that this conclusion was to be expected because it took
over 80 percent of the samples after residences were professionally
cleaned. In addition, EPA did not fully explain that its conclusion was
based on participation from only 20 percent of the eligible residences.
Without this additional information, residents who could have elected to
participate might have been discouraged from doing so because of EPA's
conclusion.

EPA did not assess the adequacy of available resources to carry out its
second program effectively. Instead of assessing the costs of carrying out
its program and providing resources accordingly, EPA has simply identified
how much money was left over from the first program. Further, the amount
of funding provided for the second program seems inconsistent with the
scale of second program activities. Specifically, the $7 million EPA plans
to spend for the second program's testing and cleaning is less than 20
percent of the first program's funding, despite an increase in the number
and type of contaminants being sampled. EPA indicated that if demand had
exceeded available resources, EPA would have simply limited participation
in the program.

Background

After the collapse of the World Trade Center and the accompanying spread
of dust resulting from the collapse, EPA, other federal agencies, and New
York City and New York State public health and environmental authorities
focused on numerous outdoor activities, including cleanup, dust
collection, and air monitoring. In May 2002, New York City formally
requested federal assistance to clean and test building interiors in the
vicinity of the WTC site for airborne asbestos. Such assistance may be
made available to state and local governments under the Stafford Act and
the National Response Plan, which establishes the process and structure
for the federal government to provide assistance to state and local
agencies when responding to threats or acts of terrorism, major disasters,
and other emergencies.5 FEMA, which coordinates the federal response to
requests for assistance from state and local governments, entered into
interagency agreements with EPA to develop and implement the first and
second indoor cleanup programs for residents in Lower Manhattan.

5The National Response Plan replaced the Federal Response Plan. The
Federal Response Plan was in effect on September 11, 2001.

EPA Incorporated Some Recommendations, but Its Decision Not to Adopt Others May
Limit the Second Program's Effectiveness

In response to recommendations from the Inspector General and expert panel
members, EPA's second program incorporates some additional testing
elements. For example, EPA is testing for a wider range of contaminants.
In addition to asbestos, EPA will test for man-made vitreous fibers, which
are in such materials as building and appliance insulation; lead; and
polycyclic aromatic hydrocarbons, a group of over 100 different chemicals
that are formed during the incomplete burning of coal, oil, gas, and
garbage. EPA will also test dust as well as the air. In order to test the
dust for these contaminants, EPA had to develop cleanup standards.
However, EPA's second program does not incorporate the following other
recommendations: (1) broadening the geographic scope of the testing
effort, (2) testing HVACs and "inaccessible" locations, and (3) expanding
the program to include workplaces.6

Broadening the geographic scope of testing. EPA did not expand the scope
of testing north of Canal Street, as well as to Brooklyn, as advisory
groups had recommended. EPA reported that it did not expand the scope of
testing because it was not able to differentiate between normal urban dust
and WTC dust, which would have enabled it to determine the geographic
extent of WTC contamination. Some expert panel members had suggested that
EPA investigate whether it was feasible to develop a method for
distinguishing between normal urban dust and WTC dust. EPA ultimately
agreed to do so. Beginning in 2004--almost 3 years after the disaster--EPA
conducted this investigation. EPA officials told us that because so much
time had passed since the terrorist attack, it was difficult to
distinguish between WTC dust and urban dust. EPA ultimately abandoned this
effort because peer reviewers questioned its methodology; EPA decided not
to explore alternative methods that the peer reviewers had proposed.
Instead, EPA will test only in an area where visible contamination has
been confirmed by aerial photography conducted soon after the WTC attack.
However, aerial photography does not reveal indoor contamination, and EPA
officials told us that they knew that some WTC dust was found immediately
after the terrorist attacks outside the area eligible for its first and
second program, such as in Brooklyn.

Testing HVACs and in inaccessible areas. In its November 2005 draft plan
for the second program, EPA had proposed collecting samples from a number
of locations in HVACs. In some buildings HVACs are shared, and in others
each residence has its own system. In either case, contaminants in the
HVAC could re-contaminate the residence unless the system is also
professionally cleaned. However, EPA's second program will not provide for
testing in HVACs unless tests in common areas reveal that standards for
any of four contaminants have been exceeded. EPA explains in the second
plan that it will not sample within HVACs because it chose to offer more
limited testing in a greater number of apartments and common areas rather
than provide more comprehensive testing in a smaller number of these
areas. Similarly, EPA had proposed sampling for contaminants in
"inaccessible" locations, such as behind dishwashers and rarely moved
furniture within apartments and common areas. Again, because it was unable
to differentiate between normal urban dust and WTC dust, EPA stated that
it would not test in inaccessible locations in order to devote its
resources to as many requests as possible. In fact, EPA only received 295
requests from residents and building owners to participate in the second
program, compared with 4,166 eligible participants in the first program.7

6EPA's second program does allow commercial building owners to request
testing and cleaning, but does not permit workers or employers to do so.

Expanding the program to include workers/workplaces. According to EPA's
second program plan, the plan is "the result of ongoing efforts to respond
to concerns of residents and workers." Workers were concerned that
workplaces in Lower Manhattan experienced the same contamination as
residences. In its second program, EPA will test and clean common areas in
commercial buildings, but will do so only if an individual property owner
or manager requests the service. EPA stated that employees who believe
their working conditions are unsafe as a result of WTC dust may file a
complaint with OSHA or request an evaluation by HHS's National Institute
of Occupational Safety and Health. Concerns remain, however, because these
other agencies do not have the authority to conduct cleanup in response to
contaminant levels that exceed standards. In addition, OSHA's standards
are designed primarily to address airborne contamination, while EPA's test
and clean program is designed to address contamination in building spaces,
whether the contamination is airborne or in settled dust. Thus, OSHA can
require individual employers to adopt work practices to reduce employee
exposure to airborne contaminants, whereas EPA's test and clean program is
designed to remove contaminants from affected spaces.

7A total of 640 individual residents and building owners registered for
the second program. Of this total, 295 eligible participants submitted the
necessary access agreements.

EPA Did Not Provide the Public With Sufficient Information to Make Fully
Informed Decisions

EPA did not provide sufficient information in its second plan so that the
public could make informed choices about their participation.
Specifically, EPA did not fully disclose the limitations in the testing
results from its first program. While EPA stated that the number of
samples in its first program exceeding risk levels for airborne asbestos
was "very small," it did not fully explain that this conclusion was
limited by the following factors.

Participation. Participation in the program came from about 20 percent of
the residences eligible for participation. In addition, participation was
voluntary, which may suggest that the sample of apartments was not
representative of all the residences eligible for the program. Those who
chose to participate may not have been at greatest risk.

Contaminants tested. EPA's cleanup decisions were based only on tests for
asbestos, rather than other contaminants, and the decisions focused on
airborne contamination rather than contamination in dust inside
residences.

Sampling protocol. EPA took over 80 percent of the samples after
professional cleaning was complete. Therefore it is not surprising that
EPA found few samples exceeding its asbestos standard.

EPA also did not explain in its second program plan that its first
program's test results excluded samples that were discarded because they
were "not cleared"--that is, could not be analyzed because the filter had
too many fibers to be analyzed under a microscope. However, EPA's final
report on its first program stated that residences with more than one
inconclusive result, such as filter overload, were encouraged to have
their residences re-cleaned and re-tested. EPA did not explain the impact
of excluding these samples or other data limitations from its conclusion
that the number of samples exceeding asbestos standards was very small.
Without providing complete explanations of the data, residents who could
have elected to participate might have been discouraged from doing so.

EPA Did Not Adequately Assess Resource Needs for the Second Program

EPA did not take steps to ensure that resources would be adequate to
achieve the second program's objectives. Instead, EPA is implementing this
program with the funding remaining after its first program--approximately
$7 million. EPA could not provide us with any basis for determining
whether this funding level is appropriate. EPA officials told us that they
were unable to determine the cost of the program without knowing the
number of participants. However, we note that funds available for the
second program are less than 20 percent of the first program's funding,
despite an increase in the number and type of contaminants being sampled.

Almost two-thirds of the panel members told us they did not believe the $7
million for the sampling and cleanup was sufficient. According to one of
the expert panel's chairmen--a former EPA Assistant Administrator--the $7
million was sufficient for initial sampling in the second program, but not
for sampling and cleanup. If demand had exceeded available resources, EPA
would have simply limited participation by ranking program applicants on
the basis of their proximity to the WTC site.

Concluding Observations

Shortcomings in EPA's second program to test and clean residences for WTC
contamination raise questions about the agency's preparedness for
addressing indoor contamination resulting from future disasters. The
effectiveness of this program may be limited because some important
recommendations were not incorporated, and because program implementation
will not begin until later this year--more than 5 years after the World
Trade Center collapsed. Furthermore, owing to these factors, the majority
of panel members do not support EPA's second program, noting that it was
not responsive to the concerns of residents and workers harmed by the
collapse of the WTC towers, it was scientifically and technically flawed,
or it was unacceptable because it would not identify the extent of
contamination. Some panel members questioned the value of participating in
EPA's program, and even stated that they would discourage participation.

Madam Chairman, this concludes my prepared statement. I would be happy to
respond to any questions that you or Members of the Subcommittee may have.

Contacts and Acknowledgments

Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this testimony. For further
information about this testimony, please contact John B. Stephenson,
Director, Natural Resources and Environment (202) 512-3841, or
[email protected] . Key contributors to this testimony were Janice
Ceperich, Katheryn Summers Hubbell, Karen Keegan, Omari Norman, Diane B.
Raynes, Carol Herrnstadt Shulman, and Sandra Tasic. Additional assistance
was provided by Katherine M. Raheb.

(360720)

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Highlights of [15]GAO-07-806T , testimony before the Subcommittee on
Superfund and Environmental Health, Committee on Environment and Public
Works, U.S. Senate

June 20, 2007

WORLD TRADE CENTER

Preliminary Observations on EPA's Second Program to Address Indoor
Contamination

The September 11, 2001, terrorist attack on the World Trade Center (WTC)
turned Lower Manhattan into a disaster site. As the towers collapsed,
Lower Manhattan was blanketed with building debris and combustible
materials. This complex mixture created a major concern: that thousands of
residents and workers in the area would now be exposed to known hazards in
the air and in the dust, such as asbestos, lead, glass fibers, and
pulverized concrete. In May 2002, New York City formally requested federal
assistance to address indoor contamination. The Environmental Protection
Agency (EPA) conducted an indoor clean and test program from 2002 to 2003.
Several years later, after obtaining the views of advisory groups,
including its Inspector General and an expert panel, EPA announced a
second test and clean program in December 2006. Program implementation is
to begin later in 2007, more than 5 years after the disaster.

GAO's testimony, based on preliminary work evaluating EPA's development of
its second program, addresses (1) EPA's actions to implement
recommendations from the expert panel and its Inspector General, (2) the
completeness of information EPA provided to the public in its second plan,
and (3) EPA's assessment of available resources to conduct the program. We
discussed the issues we address in this statement with EPA.

EPA has taken some actions to incorporate recommendations from the
Inspector General and expert panel members into its second program, but
its decision not to incorporate other recommendations may limit the
overall effectiveness of this program. For example, EPA's second program
incorporates recommendations to expand the list of contaminants it tests
for, and to test for contaminants in dust as well as the air. However, it
does not incorporate a recommendation to expand the boundaries of cleanup
to better ensure that WTC contamination is addressed in all locations. EPA
reported that it does not have a basis for expanding the boundaries
because it cannot distinguish between normal urban dust and WTC dust. EPA
did not begin examining methods for differentiating between normal urban
dust and WTC dust until nearly 3 years after the disaster, and therefore
the process for finding distinctions was more difficult. In addition,
EPA's second program does not incorporate recommendations to sample
heating, ventilation, and air conditioning (HVAC) systems. According to
EPA's plan, the agency chose to offer limited testing in a greater number
of apartments and common areas rather than provide more comprehensive
testing (such as in HVACs) in a smaller number of these areas.

EPA's second plan does not fully inform the public about the results of
its first program. EPA concluded that a "very small" number of samples
from its first program exceeded risk levels for airborne asbestos.
However, EPA did not explain that this conclusion was to be expected
because it took over 80 percent of the samples after residences were
professionally cleaned. Without this additional information, residents who
could have participated might have opted not to do so because of EPA's
conclusion.

EPA did not assess the adequacy of available resources for the second
program. EPA stated that it plans to spend $7 million on this program,
which is not based on any assessment of costs, but is the funding
remaining from the first program. Without careful planning for future
disasters, timely decisions about data collection, and thorough
communication of sampling results, an evaluation of the adequacy of
cleanup efforts may be impossible.

Aerial Image of North World Trade Center Tower on 9/11

Source: NYPD Photo Unit.

References

Visible links
  15. http://www.gao.gov/cgi-bin/getrpt?GAO-07-806T
*** End of document. ***