Statement of  Marjorie J. Clarke, Ph.D. - revised



Before the New York City Council Committee on Environmental Protection

November 8, 2001


I thank the Environmental Protection Committee for inviting me to testify at Oversight Hearings on the Environmental Impacts on Lower Manhattan Due to the Terrorist Attack on the World Trade Center.  Though I am Scientist in Residence at Lehman College, and an adjunct professor at Hunter College, I am testifying on my own behalf, since I have not had time to clear any statement with CUNY.  My background in this area stems from my stint in the 1980s as the Department of Sanitation's specialist on emissions from incinerators.  I have also served on a National Academy of Sciences committee on Health Effects of Waste Incineration.


Before I begin with my prepared remarks, I want to respond to something that was brought up earlier.  The Committee should know that a gram of diesel particulate is not as dangerous as asbestos, dioxin, PCB, or many other organic compounds and heavy metals, so even though we have a lot of information about the carcinogenicity of this one pollutant, we shouldn't lose sight of each and every one of the other name and unnamed pollutants created by the incineration of everything in the World Trade Center that we don't have lots of information about.  It's important to note that many of the hazardous air pollutants (e.g., benzene, dioxin, PCB) are carcinogenic and/or toxic in the parts per billion range, and heavy metals and acid gases are toxic in the parts per million range. 


There are several issues of importance to the public in the way the City as well as USEPA has handled air quality issues in lower Manhattan since Sept. 11.  While there has been universal praise for the Administration for its handling of the disaster, most of those who have been exposed to the lingering emissions and dust are worried or sick.  The environmental agencies protest that nothing is wrong because each individual pollutant is below action levels most of the time.  But it is clear that a large number of pollutants are significantly elevated above background levels.  I received an email from Dr. David Cleverly of EPA that dioxin was 50 times normal background levels, but not as high as actionable levels.  Background levels refer to what is loosely considered to be "normal" levels of any given pollutant in the atmosphere.  It is assumed that most pollutants exist in "clean" air at trace quantities (this might be parts per billion, parts per trillion, etc).  But what does it mean if dioxin plus several other toxic organic compounds, heavy metals, acids and particulate matter are elevated or even many times background levels and borderline actionable?  It seems likely that breathing air in which many toxic or carcinogenic pollutants are borderline actionable is worse for public health than breathing air in which only one pollutant is borderline.  Yet this is how the standards are written.  Is it protective of public health to look at each pollutant one at a time, ignoring the additive effects of inhaling a mixture?  Are there synergistic interactions between some of these compounds that increase the impacts further?  Since ambient air standards are for individual pollutants, it is imperative that research be done to assess the impacts on public health of combinations of pollutants.  Standards need to be rewritten as well to assess the impacts of synergy.


This is a new type of air pollution source, with characteristics of a crematorium, a solid waste incinerator, an asbestos factory, and even an ash-spewing volcano.  No emissions standards exist for this type of source, though I am familiar with emissions standards for incinerators.  Many of us remember the bitter battles between Brooklyn residents and the City over the Brooklyn Navy Yard plant.  The emissions from this plant would have been controlled well over 90% for most pollutants, and yet we have an incinerator downtown which continues to burn totally uncontrolled.  The size of the World Trade Center "plant" has been many times the size of any incinerator, two months have passed, and we have heard very little about a serious attempt to contain the emissions from the site and put out the fires.  Why aren't we discussing erecting a temporary structure (dome) over the site, and installing incinerator emissions controls to clean the air inside the dome?  Initially, while recovery operations are briefly suspended, the fires could be starved by injecting nitrogen.  


Entrainment of pollutant-laden fine dust is also occurring, as we heard, by loading debris into trucks and barges.  There are standards for reducing entrainment of incinerator ash.  These involve spraying water and containment in leak-proof, covered trucks.  Why aren't we following those?


Air Quality Data has been selectively shared with the public, leaving the public mistrustful.  EPA initially listed only asbestos in air, asbestos in dust and a gross measure of particulate matter in air.  After several weeks passed, EPA added PCB and lead.  All told, this was maybe 20 pages of information. Then, in a televised public forum (City Club forum), EPA said that all of its data was online.  I subsequently learned that EPA had 900 pages of data, including a list of heavy metals, dioxins and furans, acid gases, as well as those items listed.  But EPA has demanded that people who want to see the data come to the repository and look at it.  I asked for an electronic copy.  I was told I was the first one to ask for it!  But I was told that would not be possible.  How could this be, since the data Surely exist on someone's computer? The Manhattan Borough President's office was told it could have a copy, but that it had to write a Freedom of Information request.  As far as I know, that office still has not received the data and we have been talking about getting this data to them for a week or so.  It is just this kind of secretive behavior that invites people who do go down to view the full datasets, to quote data selectively.  If the data were available in a spreadsheet, then academic, environmental, and community institutions could have already started studies.  Those who want to conduct analyses are still unable to do so.


I'll close by drawing an analogy with the way the environmental agencies are dealing with the public health hazard downtown.  In south Florida, where I grew up, in the 1940s, as tourism was quickly growing, the government kept information about hurricanes secret for fear that too much information would hurt business, particularly the tourist trade.  Predictably, south Florida got walloped a couple of times, and then the government, wisely, decided to make an about-face and become the world's experts on hurricane tracking, prediction, alerts, and mitigation.  They established a world-class center in Coral Gables to serve as the source of information and research.  Later, by the time I was six, I was tracking every hurricane's progress on a chart I got for free at the 7-11 store by listening to the radio for coordinates.


We have exactly the same situation here.  There is a lot we don't know.  The government wants to protect business and the tourist trade.  The government has kept a great deal of information off limits to anyone for the first several weeks, and lately it has made it difficult to obtain in any usable form.  Even worse than this is that we don't know the long-lasting impacts of the initial huge, dense dust cloud on those running in its midst.  We don't know the additive and synergistic effects of many toxic and carcinogenic pollutants that continue to be emitted from the fires or entrained from the dust as it blows off the rooftops and ledges. Will these compromise immune systems, making them vulnerable to future attacks?  Now is a time for the environmental agencies to pull their heads from the sand, make an about-face, release all data and interpretive guidelines on the Web.  The Council should assist by committing City funds and encouraging the Administration to seek federal 9/11 grants to conduct ongoing, comprehensive surveillance of symptoms in affected populations, buy filters for residents, pay for proper cleanup, research the acute and long-term impacts on health of highly concentrated combinations of pollutants acting for a short time, as well as elevated levels of combinations acting for longer periods of time.  The government should write new standards to reflect short-term exposure to high concentrations as well as synergistic effects.  I know that the City is loathe to write its own pollution standards, preferring to rely on federal, but in some cases we have acted, and this is clearly one of them.  We need to have more contingency planning for different types of environmental disasters as this new war against terrorism progresses.  This is the only way to regain public trust. Recalling the hurricane example, and realizing that we may not be finished with terrorism, becoming the world's experts in environmental health disasters and being truly open with the public is the best course of action in the long term.