Comment -- Docket No. EPA-HQ-ORD-2005-0028

The following is my comment respectfully submitted regarding the Quality
Assurance Project Plan for external review for the Alternative Asbestos
Control Method demonstration project scheduled to be performed at Fort
Chaffee, Arkansas:

Methods for abating asbestos are, and continue to be, updated and
improved. The main reason for adjusting the methods for asbestos
abatement is generally to minimize asbestos exposure, and thus there are
community benefits from improved health and air quality.

The proposed project at Fort Chaffee is not representative of most
municipal facilities since the Fort Chaffee facilities are single story,
and have a clearance of approximately 1,000 feet from the nearest
occupied site and far greater in some directions. The Fort Chaffee
facilities are in a remote, secure location. Most facilities in city
areas are multi-story and are in close proximity to, or adjacent to,
other facilities. The photos of the Fort Chaffee facilities reveal no
basements. Many facilities in municipal areas have basements and thus
any asbestos not removed would traverse to and accumulate in the
basement of the facility. This may necessitate an asbestos removal of
material in the basement which would also include any contaminated
construction debris and thus may increase the cost, time, and effort to
perform the demolition activity.

The Alternative Asbestos Control Method is intended to accelerate the
demolition of many abandoned buildings around the nation that remain
standing, currently presenting a variety of serious risks to nearby
residents and supposed to transform former blighted areas to be
available for redevelopment, creating jobs and tax revenues for
communities. Since asbestos related diseases have a latency period of
15-25 years the risks of not abating asbestos cannot be measured with
accuracy immediately. The present methods of abating regulated asbestos
containing materials create jobs in the asbestos removal industry and
thus tax revenues are already created and in place with current methods
of demolition.

The Alternative Asbestos Control Method is stated as removing the
**most** friable asbestos-containing materials before demolition.
Friability is not subjective, and is noted in the federal NESHAPs as
material when dry, can be crumbled, pulverized, or reduced to powder by
hand pressure. Placing the word "most" along with friable confuses the
definition of friable in the asbestos NESHAPs.

The Alternative Asbestos Control Method is noted to trap asbestos fibers
and minimize their potential release to the air. Current demolition
practices cannot prevent all emissions to the ambient air, and since
asbestos fibers are not visible to the observer there is no air
monitoring method currently in use that will confirm amounts of asbestos
fibers present in the ambient air. The use of amended water or any other
control on most facilities in municipal areas will not completely
prevent visible emissions. Asbestos abatement and resulting inspections
to insure all regulated asbestos-containing material is removed prior to
demolition is at the present time the only method of insuring no visible
emissions of asbestos fibers during demolition.

The Alternative Asbestos Control Method is noted as including extensive
environmental monitoring, and will have a representative of the City
Health Department or the USEPA to stop work if conditions so merit.
Present air monitoring methods cannot confirm that there are no asbestos
fibers in the ambient air, and since asbestos fibers are not visible to
observers, any representatives present are not able to insure that
asbestos emissions are being produced by the demolition operation. The
only method of insuring no asbestos emissions is to abate all regulated
asbestos prior to the demolition. Having a representative at the site
therefore will not insure there are no asbestos emissions.

The Method is to use water to penetrate dust layers and surfaces, and
trap asbestos fibers and minimize their potential release to air. Many
wall systems are composed of building materials that do not readily
accept water, \[e.g. plaster, joint cement\] and penetration by water in
these systems is difficult. The only method of insuring that there is no
asbestos fiber release to the air is to abate the regulated wall systems
in a contained area by licensed abatement contractors. Generally,
asbestos contractors employ the use of HEPA systems in containment to
insure a negative air flow to insure that there are no asbestos
emissions during asbestos wall system removal. The use of water on a
wall system without abating the asbestos cannot insure that there will
be no asbestos emissions to the ambient air.

The project is to have all wastewater generated from the demolition
collected and properly disposed of as asbestos-containing waste. A two
inch layer of soil is to be removed to ensure that no residual soil
contamination remains at the site. If the asbestos were properly abated
prior to demolition there is no need to contain the wastewater.
Wastewater being contained "at the site" does not allow for asbestos
contaminated water being displaced into the ground, and thus cannot be
removed from the site. Additionally, in a municipal area the water has a
potential for runoff into the sewerage system, and control for
wastewater would not be practical. The removal of a two-inch layer of
soil at the site does not account for asbestos that may have traversed
off the site and may have contaminated additional areas not at the
immediate demolition site. Presently the method of insuring no
asbestos-containing material has traversed off site is by abating the
regulated asbestos prior to demolition activities.

Local departments and the USEPA have filed complaints and issued letters
of violation for failure to remove regulated asbestos-containing
materials prior to demolition. A recent example is Administrative
Consent Order EPA-5-04-113(a) MI-03 which was issued to a demolition
contractor in the Detroit Area for violating 40 CFR 61.145 in a
demolition operation. Enforcement of the present asbestos NESHAPs is
crucial and important with the result being improved air quality in
municipal areas. Continued uniform and consistent enforcement is
essential to insure air quality is maintained in local municipal areas.

SUMMARY:

Present methods of asbestos abatement prior to demolition have been
useful in assisting municipalities in removing dangerous and unsafe
facilities for further development. The asbestos removal industry and
the demolition industry have created jobs and tax revenues for local
communities and have helped to insure the health and safety of workers
and residents. Improved air quality is a result of competent, licensed
asbestos contractors performing asbestos abatement prior to demolition
activities. The Fort Chaffee method may not insure the health and safety
of persons if used in municipal areas. The method may not insure a high
standard of air quality. Work that has been traditionally used in
asbestos abatement and general demolition operations may be offset by
wastewater removal costs, and other work that is not necessary in a
traditional asbestos abatement project.