Beyond the asbestos, beyond the visible dust and pulverized concrete and all the known contaminants addressed by the residential cleanup program are a slew of worse substances that have been virtually ignored in the public debate. In 6 World Trade Center, a U.S. Customs laboratory specializing in testing of toxic chemicals, fuels and metals was operating at the time of the attacks. It was irreparably damaged and subsequently demolished. The exact volume of chemicals in the building on 9/11 is unknown, but waste manifests from the New York Port Authority show that large amounts of arsenic, mercury and other dangerous substances were removed from the building on a regular basis in the years leading up to Sept. 11.

And according to the Natural Resources Defense Council, two Con Edison substations in the basement of Building 7 stored 130,000 gallons -- the equivalent of nearly 2,400 55-gallon barrels -- of PCB-contaminated waste oil on Sept. 11. They also contained working transformers that had PCBs in them. PCBs pose an extraordinary risk to human health: They are a probable carcinogen, and other effects include damage to unborn fetuses, to the reproductive, immune and nervous systems, and to the gastrointestinal system and liver.

A University of Toronto study looked at the dissipation of these PCBs and, swabbing filmy residue from glass windows on the outsides of downtown Manhattan buildings, found that samples contained 10 times the normal amount of PCBs usually found in East Coast urban areas like Baltimore and Philadelphia. The concentrations decreased with distance from ground zero. According to the EPA's own final report on air quality, levels of PCBs in street-level air sampling in the two months immediately following Sept. 11 ranged from 18 to 150 times normal background levels. The EPA characterized those levels as just "slightly elevated," and said levels returned to "normal" in the months that followed.

The EPA concluded that, because the period of exposure was so short, PCBs did not pose a public health threat in New York. But the EPA report did not consider the possibility of long-term exposure to PCBs through indoor dust or other means, like seepage into the neighboring Hudson and East Rivers and the ocean. Environmental experts point out that the high levels of contaminants the EPA says dissipated from the air in the first few months after 9/11 had to go somewhere -- and they settled into the dust, along with a long list of heavy metals.

William Horgan is a certified industrial hygienist working for Assessment Resources and Technologies, Inc., a New York consulting firm specializing in property and hazard assessment. No one in New York spent as much time testing for heavy metals, let alone volatile organic compounds like dioxin and PCBs, after the Trade Center attacks. "I see the heavy metal contamination as equal to if not greater than the asbestos contamination," Horgan said, reflecting on more than 150 floors in high-rise buildings he has personality analyzed. "Pretty much on every floor we found one of the components: lead, cadmium or mercury."

When it comes to heavy metals, the EPA's January 2003 final report on air quality in Lower Manhattan is contradictory and confusing. It says that indoor dust samples "did not appear to show any notably high lead contaminations." But then it goes on to state: "Indoor exposures to lead-contaminated WTC-derived dust that penetrated indoors could continue to pose risks to individuals reoccupying buildings not cleaned by effective decontamination procedures." The report concludes that while heavy metal levels outdoors were alarmingly high following Sept. 11, they returned to normal background levels after just a few months and were unlikely to pose a human health risk. It did not address the indoor risk.

But Horgan calls the EPA reports about heavy metals and organic compounds misleading. Roughly 75 percent of the tests he conducted found lead levels above the U.S. Department of Housing and Urban Development threshold requiring lead abatement. And while mercury is rarely found indoors, he found it in dozens of buildings -- making the levels even more alarming. "In the years I've been doing this, I've never found mercury in any of our buildings," he said. "Why all of a sudden would we find mercury?"

It's not a leap to figure out where all this stuff came from, Horgan said. Mercury was used in the screens of laptop computers -- thousands of which were inside the twin towers -- as well as in fluorescent lights. Cadmium, another metal found in testing, can be found in batteries and paints. The lead could be from the paint in the World Trade Center towers or from the solder on the pipes, the chrome from the chromium steel used in the buildings' beams, the anodized aluminum used to build the two airplanes that crashed into them, or even the dye used in the leather and fabric covering the thousands of office chairs inside.

Worse still, an alarming report of dioxin contamination -- a carcinogenic byproduct of partially burnt materials like wood, chairs, and jet fuel -- comes directly from the EPA. The final report notes dioxin levels as high as 1,000 times normal urban background levels and calls the WTC dioxin release the largest in the world -- with concentrations 170 times the size of the second-largest known North American release at an incinerator in Buffalo, N.Y. "It would be reasonable to conclude that the concentrations to which people could potentially be exposed ... within or near the WTC site found through the latter part of November [2001], are likely the highest ambient concentrations that have ever been reported."

In reaction, Nadler, Kupferman and others asked the EPA to designate lower Manhattan a federal Superfund site -- a designation they say would not only establish a clear protocol for cleanup, but show that the EPA takes the hazard seriously. The EPA report states clearly that the levels of dioxin found and the estimated human exposure that would result would normally trigger a Superfund designation, but then inexplicably dismisses the risk only a paragraph later: "The EPA judges these incremental cancer risks to be of minimal concern." The EPA report states, again, that long-term exposure is not a risk because ambient air levels returned to normal. The agency has conducted several hundred tests for metals and organic compounds in indoor dust since the residential cleaning began, but few results have been released.

When asked whether a risk from dioxin exposure remained, EPA spokeswoman Bonnie Bellows said only that whatever risks existed have been -- and are being -- addressed by the cleanup. Bellows said the EPA and local government agencies had adequate systems in place to handle the lower Manhattan cleanup, and that the protocol that would be established under Superfund would be superfluous to systems already in place. A Superfund designation in New York would also make cleanup astronomically expensive.

"Superfund is there primarily to deal with abandoned sites and where there is no other source of funding for cleanup," Bellows said. "The bottom line is that there were hazardous materials present in the dust from the World Trade Center. It was addressed and cleaned up, and it's completely acceptable to clean up without having it listed on the national priorities site."

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