June 13, 2007

ORD Docket

Environmental Protection Agency

Mailcode: 28221T

1200 Pennsylvania Ave., NW.

Washington, DC 20460

Subject: Docket ID No. EPA-HQ-ORD-2007-0362

To whom it may concern:

The North Carolina Health Hazards Control Unit (HHCU) administers the
Asbestos Hazard Management Program Rules in North Carolina. These rules
incorporate the EPA National Emission Standards for Hazardous Air
Pollutants (NESHAP). As a state agency that already administers asbestos
regulations, we have prepared the following comments on the comparison
of the "Alternative Asbestos Control Method" (AACM) and the NESHAP
Method for Demolition of Asbestos-Containing Buildings.

(1) In the executive summary it states that "most" of the RACM must be
    removed prior to demolition under the NESHAP. However, in the
    introduction section it states that "all" of the RACM must be
    removed prior to demolition.

(2) On page 1: Allowing municipalities to conduct wholesale demolition
    of buildings that do not meet the criteria of structurally condemned
    and in danger of imminent collapse as referenced in 61.145 (a)(3) of
    the NESHAP would cause a direct conflict in the way states
    administer and enforce the NESHAP regulation.

(3) On page 2: The paragraph that references Exhibit 1 uses words like
    "conceptually" and "believe" to describe what asbestos-containing
    building materials (ACBM) can or cannot be left in place prior to
    demolition. This study is centered on two types of ACBM and there is
    no data to support such a claim about the other types of ACBM
    listed. The chart itself should be identified as a draft or
    suggestion.

Docket ID No. EPA-HQ-ORD-2007-0362

EPA-AACM

June 13, 2007

Page 2

(4) On page 4, Item 2.0: The study is limited to a one-story building.
    How can EPA extrapolate or expand this to a maximum three-story
    building? Were structural engineers brought into the study to assess
    the different types of buildings and the building components used in
    construction?

(5) On page 4, Item 3.0: The AHERA sampling regulations do not require
    destructive sampling, or the sampling of roofing products or the
    exterior portion of the building. EPA should clarify this in order
    to meet the NESHAP requirement to thoroughly inspect.

(6) On page 5: It states that no bulldozers, explosives or burning will
    be permitted during the demolition. EPA should also add a statement
    about not allowing wholesale recycling or salvaging. EPA should also
    state that no grinding of the building or building components will
    be allowed.

(7) On page 6: A detailed list is provided stating which
    asbestos-containing materials (ACM) can be left in place using the
    AACM process and which ACM must be removed prior to using the AACM
    process. The HHCU fails to understand where this list came from and
    how can EPA make such a broad extrapolation based upon "one study"
    that only involved the demolition of sheetrock/joint compound and
    vinyl asbestos floor tile. There should be other studies conducted
    to address the three-thousand plus types of ACM used in the United
    States before taking such a position.

(8) On page 6: In Table 1 some of the terminology is unclear. For
    example, what type of shingles is EPA referring to under the
    miscellaneous material? Where would EPA place the asbestos cement
    flooring material or the asbestos poured cement roof? Will EPA
    address all three thousand plus ACBM individually?

(9) On page 7, Item 6.0: EPA should also add a statement about droughts
    and city/county enforced water restrictions that may delay the
    demolition activity.

(10) On page 8, Item 8.0: Lining haulers with poly is a problem with
     many landfills located in North Carolina. The landfill owners and
     operators do not want the haulers lined with poly because of the
     problem with keeping the poly buried.

(11) On page 9, Item 8.3: It is unclear why EPA states that the plastic
     must be disposed of as RACM when it can be cleaned.

(12) On page 9, Item 8.4: It is unclear how EPA can state that all of
     the removed soil must be removed as RACM when soil sampling results
     may prove different. It is also unclear if EPA would consider all
     of the wood, brick and metal from the building as asbestos
     contaminated or as RACM.

Docket ID No. EPA-HQ-ORD-2007-0362

EPA-AACM

June 13, 2007

Page 3

(13) On page 28, Item 4.1.2: Who would have the responsibility to
     monitor the wind and stop the demolition contractor when the wind
     exceeds 15 miles per hour?

(14) On page 34, Item 4.1.3.4: The process by which you collected soil
     sub-samples and then composite the soil samples for analysis would
     be a good method for naturally occurring asbestos. However, it is
     our experience that collecting soil samples to determine the
     presence of asbestos fibers from ACBM is very similar to trying to
     find the needle in the hay stack.

(15) On page 38: The photograph identifies the asbestos workers wearing
     their respirators over their tyvek clothing. Not only were the
     workers wearing their respirators inappropriately, they appear to
     be in violation of several OSHA standards.

(16) On page 49-50, Amended Water System: We are familiar with the Class
     "A" Foam Concentrate from a previous fire suppression study in
     North Carolina. However, we do not see demolition contractors
     utilizing the product or applying the product correctly. Water with
     a detergent would be less expensive and more readily available.

(17) On page 52, Item 4.4.2.2: The study used the Class-"A" foam and
     water for so many minutes per application. However, we cannot
     determine from the study how many total gallons of water were used.
     From this study is there a minimum number of gallons used per
     square foot? Depending on how much water is used, it could be
     possible that the weight of the water would cause the building or
     part of the building to be structurally compromised.

(18) On page 64, Item 5.1.5: The soil samples were collected within the
     area of the containment berm and came from a depth of ½ inch. This
     type of sampling for asbestos in the soil does not account for
     asbestos building debris that may have been deposited in the crawl
     or buried on-site in the years past. How will EPA address the issue
     of ACM debris located in the crawl space or identified during the
     soil excavation when the study sets a recommendation to remove 2
     inches of soil from the building's footprint?

(19) On page 67, Item Personal Air Samples: It is unclear why EPA used
     the ISO Method 10312-1995, Ambient Air -- Determination of Asbestos
     Fibers -- direct Transfer Transmission Electron Microscopy Method
     for analyzing personal air samples. It is our understanding the EPA
     has not approved this method.

(20) On page 139: The cost comparison between the two buildings is not a
     true reflection of a real world abatement followed by a demolition.
     If the \$ 2400.00 for the pre-demolition asbestos NESHAP inspection
     included the soil samples then too many samples were taken. The
     cost of preparing the abatement specification, for a project that
     would not even require an asbestos specification in North Carolina,
     is too high. Based upon a conversation with one of our asbestos
     contractors who has looked at this study, the asbestos abatement
     cost is too high.

Docket ID No. EPA-HQ-ORD-2007-0362

EPA-AACM

June 13, 2007

Page 4

(21) North Carolina requires that all individuals conducting asbestos
     management activities be accredited in the proper accreditation
     category. If the AACM were approved by EPA and municipalities were
     allowed to demolish buildings without removing certain types of
     ACBM prior to demolition, the individuals doing the work would
     likely have to be accredited. This requirement would add
     significantly to the total cost of the project.

The Health Hazards Control Unit submits these comments with the intent
of providing a safe environment for the citizens of our State, along
with the concern of providing a manageable process to ensure that
demolishing buildings which contain some types of ACBM are followed
using the appropriate state and federal regulations. We appreciate the
effort being put forth by EPA to make this study available to the public
for comment.

If you have any questions about our comments please feel free to contact
me at (919)707-5950.

Sincerely,

Mary T. Giguere, CIH

Manager

Health Hazards Control Unit

MTG/jwd