Testimony regarding emergency response to environmental disasters
By Marjorie J. Clarke, Ph.D.
http://everest.hunter.cuny.edu/~mclarke/resume.htm
Date: October 15, 2002
To: Senate Committee on Environmental and
Public Works
Subject: Christie Whitman’s recent Testimony to
Congress
I have gone over
a portion of Administrator Whitman’s testimony with an eye towards the accuracy
of her statements, and provide testimony to answer and rebut some of them. For simplicity I am inserting my testimony
in bold blue after each paragraph of her testimony.
EPA RESPONSE AT
WORLD TRADE CENTER
As soon as the first plane hit
the North Tower, EPA activated its emergency response personnel from its
Regional office in lower Manhattan.
Before anyone knew the tragic consequences of the attack, EPA’s
responders were headed to the site to monitor the cloud of smoke and dust.
EPA immediately dispatched
monitoring teams to test the ambient air quality around the World Trade Center
site (WTC) and as far away as Jersey City, New Jersey. On the first day, tests were taken for
asbestos, lead and a class of chemicals associated with fires and fuel called
volatile organic compounds (VOCs). In
most instances on the first day, EPA did not detect the presence of these
pollutants. In some instances, we found
them in very low levels - - well below
a level that would be considered a health threat.
In future environmental
disasters, it is critically important for EPA to frequently publicize the
character and quantity of the monitoring effort. This publicity should be in the media and in greater detail, on
EPA's website. Information should
include (at a minimum): The number of
personnel involved in monitoring each day, the location of monitoring sites,
specific methods of testing, the range of pollutants being tested for, the
frequency of tests, wind and dispersion data.
In addition to this information, it is critically important for all the
sampling and analysis data, air quality standards to which the data are
compared, and, if no standards are available and new levels of concern are
developed, the complete rationale, with references, to be made available on the
internet. After the WTC environmental
disaster, EPA was still refusing to provide data to elected officials in
October citing national security. This
is bogus, and should never be used as an excuse. EPA also refused to make copies of the full dataset available via
email or internet after it stopped using the national security ruse.
EPA performed
environmental sampling of debris, as well as air monitoring and air sampling in
the work zone and support areas. This
data was used to ensure that health and safety plans were implemented to
minimize the exposure to hazardous chemicals of the responders doing the
firefighting, search and rescue efforts and criminal investigations.
EPA did not detect these pollutants
on the second day? What methods of
sampling and testing was used? What was
the detection limit of the tests chosen?
Were these the most sensitive tests available? Published studies and EPA's own data shows that these and other
pollutants were found in the air, some in very large quantities weeks and
months after 9/11 (I attach a study by Paul Lioy, et. al. of Rutgers). EPA was shown to have used the less
sensitive PCM testing for asbestos, when it should have used TEM. Grab sampling of air for a few minutes while
the wind is moving the plume in the opposite direction is also not valid. Longer samples under the plume should have
always been taken.
Again, the point about not
being a health threat is in contention.
What kind of health threat is EPA concerned about? Immediate death only? Isn't the combination/synergy of non-lethal
quantities of pollutants of importance for long-term health impacts? Is EPA ignoring all the new cases of asthma
and other diseases by those exposed that have still not abated? For the future, it is necessary, once again,
to make all sampling information public.
Further, it is important to sample for long enough and choose areas that
would be expected to have the worst contamination or air quality. EPA should also not ignore indoor
contamination or air quality as it did in the WTC case. The cleanup of the indoors should have
commenced immediately, as did the cleanup of the WTC site itself. Evacuations, which were enforced for several
days, should have been extended until both indoors and outdoor areas had been
abated for asbestos, since the entire area was showered with friable asbestos
(and this was known immediately).
Why would there have been a
need to protect workers from the health effects of hazardous materials if there
were no health threat as stated earlier?
What were the results of the health and safety plans, specifically? How many of the responders wore properly
fitted respirators on each day? It is
well known that many did not have respirators, and others who did, did not wear
them. This quantified information
should be made public in any disaster.
How else will anything be learned?
EPA has prepared documents
“Lessons Learned” and 3 risk assessments that have been requested via
FOIA. These have still not been
forthcoming. What are they hiding?
Over the next few days, EPA also
sampled dust and air in Lower Manhattan, Brooklyn, New Jersey and at the Fresh
Kills Landfill in Staten Island. As to
be expected, there were some standards exceeded for certain chemicals within
the fires, but this rarely occurred outside of the World Trade Center site.
This paragraph contradicts her
previous paragraph. Were standards
exceeded or not? Which standards are we
talking about? Are they applicable to
the situation at hand? EPA needs to be
conducting considerable research to determine safe standards for combinations
of pollutants, indoors as well as outdoors.
EPA needs to determine better methods of measuring indoor air pollution
and reservoirs of contamination.
EPA sampled
drinking water from the distribution system and analyzed samples from water
towers on top of buildings. The Agency
also sampled water from the Hudson and East Rivers and wastewater from a sewage
treatment plant in Brooklyn after several rainfalls to check for pollutants
running off the World Trade Center site.
EPA did not find any levels that posed either human health or ecological
risks. Over the course of ten months,
the Agency took 24,500 samples of air, dust, drinking water and river
water. Because many were analyzed for
more than one pollutant, these samples yielded more than 212,500 results.
Regarding vacuuming of dust
from streets, press reports a few months ago showed that the contractors were
not using HEPA vacuums to remove dust for several days. Further, NYC Department of Sanitation street
sweepers, not equipped with vacuums, were employed to "clean" the
streets. There were times, documented,
where the street sweepers were sweeping dry, and blowing dust into peoples'
eyes and noses. EPA should have been in
complete control of the situation. In
the future, EPA needs to take control of state and local "cleaning"
and monitoring to assure that inadequate or dangerous procedures are not
used. That EPA erected a large tent for
cleaning the workers was laudable. Why
didn't it also erect a containment structure to contain contaminants from the
barge loading activity? This would not
have been difficult. Speaking of
containment, and since prevention of contamination is always better than
remediation, why did EPA not work to put the fires out as soon as
possible? Once it was determined there
was no hope for survivors, EPA should have worked with other agencies to block
the subterranean tunnels, and covered the pile to suffocate the fire. Allowing highly toxic and carcinogenic
pollutants to be generated for 100 days needlessly exposed the public to
elevated and dangerous air quality. In
the future, EPA should work hard to contain and prevent further pollution in the
cases of environmental disasters. If
the methodology does not exist, it should be developed.
The Agency vacuumed dust from the
streets, parks and other public spaces.
EPA took the lead in establishing and running worker and truck wash stations
in both Lower Manhattan and on Staten Island to prevent dust from migrating
from the recovery site. In November,
EPA erected what is thought to be the largest worker wash tent in the world - a
31,000 square-foot heated structure at which workers could vacuum, wash off,
shower, and get a hot meal.
Regarding the water samples,
what levels are considered to be a threat to human or ecological health? Is EPA categorically saying that the
elevated levels of a combination of pollutants in the water are not additive or
synergistic in effect on human or ecological health? And, just as EPA has learned that dust settling indoors can be
reentrained, causing long-term exposure to contaminants, the same can be said
of contaminants that were flushed out to the Hudson and East rivers via the
storm drains. When the river bottom is
stirred up due to storms or dredging, is there no ecological threat? New research is needed to clarify and
answer these questions, and provide more protective standards, as well as point
towards better methods of "cleaning" contaminated areas. Merely moving contaminants from streets to
water bodies is not cleaning. EPA
should make public, on its website, all samples, immediately, and in future
disasters, as soon as the analyses are complete.
EPA has responded to the ongoing
concerns of lower Manhattan residents with the announcement of a residential
indoor dust cleanup program. This
program was developed with assistance from New York City, the Federal Emergency
Management Agency, and other members of the Indoor Air Task Force. Since the announcement of the program, EPA
has met with resident and tenant organizations, environmental and community
groups, community boards and many city, state, and Federal elected officials to
refine the program. On June 3, EPA
activated a hotline and online form for residents to sign up for cleaning and
testing or to get their homes tested for asbestos. EPA began testing homes in August and began cleaning in
September.
EPA is lauding itself for
responding to residents' complaints about indoor air quality by instituting a
voluntary program 9 months after the disaster.
This is preposterous. Instead,
and in future disasters, EPA should assure, by thorough testing of ALL indoor
spaces, nooks and crannies, that air quality is safe and that there are no
remaining reservoirs of contamination (i.e., contaminated dust) BEFORE
permitting residents to return and businesses, schools, etc. to reopen. EPA should not leave it to local
authorities, to landlords or to tenants to determine if air quality is safe or
contaminant reservoirs are present.
That EPA permitted the city agencies to require landlords and tenants to
clean hazardous wastes from indoor spaces using inadequate cleaning tools and
without proper protective equipment should be illegal if it isn't already.
EPA's indoor cleaning
program's educational materials do not include any information to explain why
EPA reversed its repeated statements that the air was safe, so downtown
residents have no motivation to sign up.
EPA's educational methods are paltry in scope, not using the broadcast
or print media to explain why cleanup is necessary. Educational campaigns should not only be informational, but also
motivational or they will not be effective.
Multiple approaches (various media, outreach methods) are necessary for
success. Each person should be reached
at least once, and by different means (people are busy, and can forget). It is well known that in order to implement
behavior change successfully, there should be no inconvenience or cost
involved. EPA has not made this clear
in its educational materials (i.e. that temporary lodging will be provided and
that replacement cost for carpets, drapes and upholstered furniture will be
provided). That EPA has assumed that
ALL businesses have done asbestos abatements is unfortunate, and
incorrect. Office workers are still
being exposed to contamination. EPA has
not made any effort to test office space or make the results public.
All these changes must happen
in this and future disasters. There is
much work to do to prepare for future environmental disasters. As it stands now, if there is another
terrorist attack, the same procedures will be followed, despite all the myriad
of things EPA did wrong, or allowed to happen.
Even if there is never another environmental disaster resulting from a
terrorist attack, natural disasters, such as earthquakes and tornadoes, will
still happen, and can result in fires and building collapses (just imagine an
8.5 earthquake right under San Francisco).
We need to be ready.