**Terry
Trent------------------------------------------------------------------------------------------**

**6185 Barbara Lane**

**Auburn, California 95602**

**Tel: (916) 745-2073**

**Fax: (916) 745-1050**

December 10, 2004

EPA Docket Center (EPA/DC),

Room B102, EPA West Building,

1301 Constitution Avenue, N.W.,

Washington, D.C. 20460,

Attention Docket ID No. EPA-HQ-ORD-2005-0028

**Re: Test Alternative Method to Remove Asbestos**

**Docket ID No. EPA-HQ-ORD-2005-0028**

**Informal Comments**

Ladies and Gentlemen,

Anticipating this day some years ago, I have previously conducted
experimental testing with 95% to 99% long fiber natural occurring
Tremolite asbestos to determine the effects of the addition of
surfactants. The reasons for such inquiry follow from the common
worldwide use of surfactant molecules in the use of particle bioweapons,
to enhance the distribution, aerosolability and breathing potential of
said particles - combined with the increasing use of surfactants as a
control method for natural occurring Tremolite asbestos in California.

The question of course, given the nature of use of surfactants with
bioweapons, and the obvious chemistry involved throughout the class of
molecular structures titled "surfactants" was: "could the use of
surfactants as a control method in combination with Tremolite asbestos
fibers be at any point, increasing the ability of the fibers to be
breathed in by human workers or bystanders"? The resulting answer was an
unequivocal yes.

**[Observations:]{.underline}**

Tremolite asbestos fibers are individually, highly, gross negatively
charged particles. The more common form of asbestos, Chrysotile, is a
positively charged fibrous particle. The removal of Tremolite asbestos
from the ground, in a nearly pure pristine state (meaning non friable),
when placed in water, with minimal additional applied mechanical
disturbance, (gentle swirling of the container) immediately causes
fibers to disassociate into their smallest possible fibrous diameter
components. The individual fibers are highly hydrophobic. Thus the
application of the word "friable" is mostly inconsequential with
unadulterated Tremolite asbestos and may be so with all mineral fibers.

**[Method and Limitations:]{.underline}**

Tremolite fibers directly from the natural occurring veins, cleaned by
water then ground to a fine wet powder, were treated with surfactants
and compared to a similarly ground sample that was not treated with
surfactants. Initially, when partially dried, both samples were sticky,
fibrous masses tightly clinging together. There appeared to be no
advantage in accretion by adding surfactants. When completely dried both
masses remained tightly compacted, sticky, adhering tightly to test
surfaces, once again noting no advantage to the addition of surfactants
for accretion purposes.

Upon thorough drying, the masses were separately ground further to a
fine powder. At this point the powders were tested for their ability to
become airborne, by observation alone. Although both powders became
airborne with applied breeze, it was apparent that the surfactant
treated sample, became airborne more readily. However, more importantly
the surfactant treated material did not stick to the sides of the
containing vessel at all. The individual fibers of the untreated sample
readily adhered to the sides of the containing vessel. At this point,
the experiment was discontinued. The results were well within what was
to be expected.

**[Related Experiment:]{.underline}**

In 1997 this author tested Tremolite asbestos for its relative settling
in air in comparison to Chrysotile asbestos and it was found, as a class
of fiber, with no gradient between the two types, to settle out of air
far more rapidly than Chrysotile. No mention of this behavior was found
in the world literature. However, many of the consequences of this
behavior are readily seen in studies from French New Caledonia, Metsovo
Greece, Crete, Cyprus, etc. Confirmation of this phenomena occurring in
water did appear in the literature in one instance. Confirming
documentation of this behavior was later found in WR Grace records from
the 1970s in which no consequences or elaboration were described. This
phenomena was further confirmed in writing to me, by EPA researchers in
Libby, Montana who have subsequently failed to elaborate either publicly
or privately the full consequences. Important to my conclusion below is
the fact that ambient air monitoring results for Tremolite asbestos and
certainly at least one other highly toxic fiber type Erionite, is for
all intents and purposes, not representative of human exposures nor the
way these exposures occur in greatest part.

**[Discussion:]{.underline}**

Testing conducted in 1997 inside several homes that had been built atop
surface Tremolite asbestos deposits, in the El Dorado County area of
California, indicated that the Tremolite fibers naturally and quite
strongly adhere to all surfaces, horizontal and vertical, inside common
dwellings. Additional lung burden testing conducted later with deceased
animals in the area indicated high Tremolite lung burdens indicative
that not all Tremolite fibers were clinging to surfaces as much as may
be desired. The not sticking part of any particle is the desirable
effect or reason for adding surfactants (along with neutral molecules
such as bentonite to further enhance this effect) to manufactured
particle bioweapons in the first place, thus making the particles more
available for breathing in any given environment, and more readily re
aerosolized once the particles settle to the ground or adjacent
surfaces.

The chemistry of surfactants indicate that these molecular products may
be quite useful as wetting agents (moisture penetrating ability), and
most likely give off highly desirable results when used
[initially]{.underline} as a control method for Tremolite asbestos.
(Perhaps better results than just water use alone due to the ability to
penetrate and carry moisture with them more readily into different
asbestos containing substances, particularly when under demolition). In
addition, these products [initially]{.underline} give the indication as
a strong and lasting accretion device. However, the later drying and
grinding that will inevitably occur, by either picking up the material
for disposal or later on at a disposal site, will most likely result in
a material that is more readily aerosolized and made more available for
aerosolization by virtue of the loss of charge of the individual fibers.

Of course this effect would be more drastic and of much greater concern
in a natural occurring Tremolite asbestos environment since one must
assume that building demolition and the subsequent dumping site would be
under far more scrutiny and control than a residential home built on
surface Tremolite asbestos. If for some reason such scrutiny and control
are not assured, then the addition of surfactants would be of equal or
perhaps even greater concern for building demolition.

It should be noted here, that the removal of "asbestos" only from
buildings is often connected with the idea that the removed "asbestos"
will be taken to a dump site where it will no longer be a danger to
human inhalation. In Calaveras County, California the long time site of
statewide "asbestos" dumping, sites have been capped inadequately and
construction atop these dump sites has allowed for residential builders
to dig up the asbestos in residential areas, with no controls in place
at all. Seemingly, the "asbestos" removal process as has been practiced
to date, is simply an exercise of removing the problem from one area, to
become the problem of someone else in another area in the future. The
use of surfactants can enhance the problem for those who are temporally
placed downstream in this process.

As indicated above, the use of surfactants is wide spread in Tremolite
containing soils of residential areas of California, the very few such
areas that exist today. It is likely that an approval or even a
recommendation for their use with the demolition of buildings, may
likely further carry over to uses not specifically approved, with far
less oversight and control available. It is difficult for this author to
imagine a more uncontrolled use of surfactants than spraying them onto
hundreds of acres of surface Tremolite asbestos fibers, then grinding
them up with tractors. However, I am certain I have not thought it all
the way through and that additional surprises, or shocks as the case may
be, await all of us on this topic.

**[Conclusion:]{.underline}**

It is becoming more commonly accepted that differing mineral fiber
types, erroneously and egregiously defined and grouped under the catch
all word "asbestos", exhibit vastly different levels of toxicity. In
addition it has not been commonly known, in fact curiously neglected,
that these fibers exhibit vastly different behaviors in any environment
leading up to human exposures. Regulatory and clinical consequences of
different mineral fiber behaviors should be apparent to all, but if it
is not, one should minimally say here that using one technique of
control/measurement/exposure limit etc., for one fiber type can very
easily enhance and cause further neglect for another fiber type. As has
been demonstrated over the last 60 years in Libby Montana. The use of
chemicals of any type as a control substance, as is apparent here, may
further enhance the levels of human exposure to any or all mineral fiber
types at some point.

In addition those mineral fiber types not grouped as "asbestos" that
remain unregulated such as "Erionite" fibers, which are present in many
natural occurring surface deposits in the western United States, soon to
be residential sites, indicate via the literature and observations of
researchers, that these fibers will become subject to enhanced
aerosolized availability to human breathing through the use of
surfactants. Approval of the use of surfactants in building demolition
will undoubtedly further the general belief that it is a good idea to
use surfactants as a control with all mineral fiber exposure scenarios.
The current experimental results indicate otherwise. Dumping of building
demolition products that have been treated with surfactants will
undoubtedly lead to at least some enhanced human exposures. Further
investigation is of course, as with all things, required. Any additional
investigation of this topic is highly recommended to be accomplished by
others outside the direct supervision or control of EPA personnel.

Thank you,

Terry Trent