1-8-06

Environmental Protection Agency

Mailcode: 28221T

1200 Pennsylvania Ave., NW.

Washington, D.C. 20460

RE: EPA-HQ-ORD-2005-0028

To Whom It May Concern,

Re: Fort Chaffee Alternative Asbestos Control Method

This new experiment is based on a work practice theory that was inserted
in the NESHAPS regulation for emergency only demolition. This is not a
good idea for the environment or the public's health as a standard
practice. This idea came from the fact that occasionally, buildings have
to be knocked down because it is extremely dangerous to send in workers
to a structurally damaged building. This is in the regulation because
fire, hurricanes, tornadoes, explosions and other unplanned events
damage buildings to an extent that the owners cannot safely send in
people to do normal work practice. This was an exemption not a means of
demolition. It is this way for it is not the safest way to accomplish
the task at hand. The EPA has said in its own National Emission
Standards for Hazardous Air Pollutants that Asbestos is a known
Carcinogen. Why would it now say that asbestos is OK to breathe in our
bodies?

The Health and Safety plan, prepared by Mr. Glen M. Shaul, Task Order
Manager, is long and detailed for Construction sites for many events and
problems that can happen on a construction site. This plan covers many
contingencies for demolition. I would like to address the asbestos
issues.

What I would like to address is in the plan dated in November of 2005.

In section 1.2, page 1-4. The plan states that once the required Class I
friable RACM is removed, the demolition proceeds using amended water
suppression before, during and after demolition to trap asbestos fibers
and minimize potential release into the air.

How is the amending solution to be added to the water? I know of no way
that this is being done presently.

Page 2

Secondly, it states that waste water generation is collected and
filtered and all debris is disposed of as asbestos waste. These
buildings are old army barracks, I assume, built over dirt.

How can one collect water and filter it if it is sprayed on the ground.
Won't it soak in to the ground? What do we do then?

Next it says debris is treated as asbestos waste. How are you going to
get the waste into bags? After the demolition of the building with a
front end loader, how do you bag the waste here?

In Section 6.2 Environmental Monitoring

This plan circumvents the OSHA standard, another federal agency, and
changes the monitoring on all perimeters. I was told that there is a new
term of 60 degree angle positioning of the buildings. Is this monitoring
of all the buildings, or one at a time? If this is a test of a new
process, should it not be one building at a time? The area is too big to
get good monitoring of the process as a whole.

If this experiment is to be a national standards, why not follow the
rule that every one else has to follow.

In section 6.2.1 Page 6-3, It states that the building demolition is to
take one day. I am amazed that an agency designed to protect the land,
air and water from known pollutants can stamp this experiment as valid.
Would not a prudent process call for more than a one eight hour test to
be considered valid? Other agencies do not get this wide of a brush to
paint with on new processes. If this procedure is passed by the EPA
won't the Agency then inform all other Municipal, County, State and
Federal Governmental Agencies that it is permissible to demolish all
buildings using this method? Will this method also be allowed for medium
sized buildings with an abundance of asbestos on the property? Will
obsolete manufacturing plants and dated storage buildings also fall
under the new proposed guidelines? These types of buildings contain more
Class II non friable and friable ACM (Asbestos Containing Materials). If
it is not removed properly, it will cause tremendous damage to the
environment, the workers and innocent bystanders.

In section 6.4.4.2, this section speaks of air monitoring of ambient air
during loading of bagged ACM (asbestos containing materials). Is not the
class I Friable asbestos taken out before knocking over the building? Is
this talking about the waste from bulldozing the material over, be put
on bags? The EPA has stated in the past that there is no known safe
limit of asbestos exposure. Is the EPA now changing this position?

Are the processes, written in this plan, now to be the regulation to be
followed by all demolition contractors as they do this work? Are we
rewriting regulations? Have the present rules been reviewed to see if
this is in line with other rules now in place?

Page 3

How will these written procedures be enforced, as practice or rule?

If it is practice it can be ignored, if it is rule it is enforceable to
be done at all work sites?

Are Section 7 and Section 8 required or suggested? Again, if suggested,
they will be ignored, if required, they are enforceable.

Section 8.5 says equipment (large and small) shall be hydro spray. I
assume this is done with a garden water hose or fire hose. Where is the
water collected and filtered?

I assume we do not want to contaminate the ground.

We do not see this alternative process working safely.

We also believe that a one time test doesn't make a scientific
evaluation of the work procedure that can be safely and repeatedly used
across the country.

We have not read and cannot find what the scientific method that will be
used by the EPA to conduct a second evaluation as stated in a memorandum
stamp dated August 10, 2005 from Mr. Thomas Skinner, Acting Assistant
Administrator to Richard Greene, Regional Director, Region 6. How will
this second evaluation be done? How will the second test compare to the
alternative method described? Again we ask why only one test. This does
not seem scientific?

If you are looking for a cheaper way to get rid of asbestos, this is it.
You will not see asbestos getting inside of people. You will only find
out of the exposure when the people around the country get sick in the
future. This is the reason the regulation on asbestos were written in
the first place.

Sincerely Yours,

John P. Shine Sr.

Apprentice Coordinator

Health and Safety Director

Heat and Frost Insulators & Asbestos Workers

3850 S. Racine Ave.

Chicago, Ill. 60609