Testimony to EPA Expert Panel on WTC contamination

July 26, 2004

Marjorie J. Clarke, Ph.D.


The EPIC report, which has just become available, show a number of aerial photographs of WTC dust accumulations and plumes visible from the air that are almost three years old.What is the intended purpose of displaying aerial photographs of dust in lower Manhattan at this time?Is EPA interpreting the report to demonstrate conclusively that there was zero harmful dust outside a perimeter of dust visible from so far away?EPA is appearing to interpret this report to suggest that satellite and aerial photos should be the means of establishing a limit of where contamination occurred and therefore, the furthest extent of where cleaning should occur.If this is the case, that EPA is drawing lines around dust visible from airplanes is even more ludicrous than EPA saying that apartments should be considered eligible for hazardous waste remediation based only on visual inspection by an inspector on the ground.Even this report has caveats that dust may have been present but not enough to obscure roadlines or cross-walks. Talk to people in Brooklyn.Councilmember Yassky said during a City Council hearing that he saw it ďsnowĒ in Brooklyn Heights. Residents much farther into Brooklyn reported papers and other debris from the WTC.Is such ground truthing data to be disregarded?†† Dust is very light and can travel further.Wipe tests indoors have shown repeatedly that even close visual inspection has been inaccurate at indicating unacceptable levels of WTC asbestos or other pollutants present inside of apartments, either on hard or soft surfaces.


Because dusts containing unacceptable levels of toxic substances cannot even be reliably determined by visual inspection on the ground, and that wipe tests and ultrasonication and the like are necessary to accurately measure the levels of toxics, these photographs should only be used to show the absolute minimum extent of harmful dust accumulations. ††Furthermore, it is important to note that the dusts that settled out immediately were the heaviest, largest particles, not the finer, more inhalable particles that have a greater likelihood of having surfaces coated with toxic organics and heavy metals.As I have testified, these larger particles, visible in aerial photographs, would primarily consist of gypsum and other building materials, which have lower toxicity.Itís the fine, toxic particulate that spread further that is of greater interest in preventing illness.


Why has EPA chosen to fixate only on showing map after map of the dust cloud going southwest towards Jersey City?†† This is a snapshot in time that isnít even specified on the map.How long and when was this the wind direction?What does the wind rose look like for the period from 9/11 until the fires were extinguished in early 2002?†† During the afternoon of 9/12/01, I witnessed the wind shift from going towards Brooklyn to carry pollutants from the WTC over Manhattan, Queens and the Bronx.I could smell it when I was on both 42nd St and and west 72nd St.Most of the time, the winds carried the plume over Brooklyn.All the images shown in the EPIC report (and all reports) should have the time stamp, not just the date, and EPA should not be using aerial photographs to suggest that the wind went in only one direction.(Matt Lorber has done this on at least two occasions that I have witnessed in conferences and presentations using photographs that depict the wind carrying the plume only in a southerly direction over the harbor.)EPA should be studying the plume and calculating the quantity of dust and toxics being emitted each day over the 4+ month period and the direction of the wind during each day to better calculate where deposition occurred and rate of deposition.

The USGS overflights in this time frame which gathered quite a bit of data on species of asbestos and other materials, finding these at least as far north as 23rd St (that is the northern edge of the map).The following urls show some of these maps.





That collections of fibers of asbestos could be seen from such a distance and far north of the WTC in Manhattan shows that it would be erroneous to draw a boundary near Canal.


Why has EPA limited itself to a 2-day period following the collapses?The fires continued for over 100 days and there would have been toxic fallout from the plume of emissions from those fires.


In the Questions and Answers document, EPA answers that the EPIC document proves that EPA addressed the worst contaminated areas.This answer is self-serving, in that it only addressed about 1/5 of the residential buildings and none of the commercial and institutional buildings.


As a result of the inadequate level of scientific investigation demonstrated after the WTC collapses and fires (that we now have to depend, years later, on aerial shots, rather than on scientifically collected samples on the ground in a dense, but very large sampling grid), it does not appear that EPA has learned lessons that will become part of the emergency response in the future.Even in the EPIC report it was stated that the aerial photography was limited in extent, and that the results do not indicate that dust could exist outside the boundaries of the dust visible from space.I am afraid that EPA may be trying to use this report to limit the extent of remediation.I hope Iím wrong.For the next environmental disaster, will EPA immediately gather all its qualified personnel and sampling equipment from all over the US to conduct thorough studies, and then to commence thorough remediation outdoors AND indoors Immediately, or are we doomed to repeat this failure to exert due diligence to learn the truth and clean up the contamination?


Just as the 9/11 Commission made recommendations to change government structures and policies to improve emergency response and prevent future terrorist disasters, so should this panel make such recommendations to protect public health in the future.