Report criticizes EPA demolition protocols

The Inspector General of the Environmental Protection Agency released a report last week recommending the agency update its guidance with regard to the demolition of asbestos-contaminated buildings. Studies conducted by the Office of the Inspector General demonstrated the demolition of contaminated structures could pose a potential human health risk due to the release of asbestos fibers in runoff wastewater.

The Inspector General, following a study of the release of asbestos caused by the demolition of contaminated structures concluded:

“Analysis of the data collected by the EPA during Alternative Asbestos Control Method experiments shows that under specific conditions asbestos NESHAP demolitions can release significant amounts of wetted asbestos into the environment … Because asbestos NESHAP demolitions are allowed to occur and may be releasing harmful amounts of asbestos into the environment, the EPA needs to assess the potential public health risk posed by the release of reportable quantities and inform the regulated community of the potential CERCLA 103 reporting requirements.”

Under current protocols, contaminated areas are soaked with water to prevent the release of asbestos fibers into the air. The Inspector General criticized the protocol because the wastewater from the wetting process creates contaminated runoff, which could result in contaminated streams or other property onto which the water runs.

The study was conducted on dilapidated structures under controlled conditions. The structures were characterized as subject to imminent collapse due to their condition. In each case, the runoff wastewater was collected and reportable quantities of asbestos were detected.

The agency’s team leader for Libby, Rebecca Thomas, said she hadn’t yet seen the report, but said the results wouldn’t apply to operations in Libby.

“EPA uses water to manage dust during removal projects,” Thomas said. “We use enough water to ensure that dust does not leave the project site, but not so much water that runoff could leave the project site. We also collect confirmation samples following completion of each removal to ensure that the remedy is protective.”

The agency is expected to complete its remedial action in the Libby area within the next three to five years, according to Thomas. Once the remedial action is completed, the site will go into long-term operation and maintenance status. The long-term maintenance of the remedy will depend upon institutional controls, or regulations, to manage exposure to contaminated materials left behind.

The agency’s proposed plan for the Libby Superfund site, released last month, acknowledges the fact that asbestos will be left in place after the active phase of the clean-up is completed.

“Institutional controls are an important part of the remedy and are required with all alternatives to manage future releases of Libby amphibole asbestos or ‘waste left in place,’” the plan reads. “Libby amphibole asbestos will remain at the site and could become a new source of exposure after the construction portion of the remedy described above is implemented. It is not practical to remove all Libby amphibole asbestos that is sealed behind indoors walls or to excavate all Libby amphibole asbestos that is in soil. Contaminated soil may be left beneath the surface after contaminated soil is removed. Libby amphibole asbestos may also remain in wall cavities and other interior locations that are inaccessible.”

Future releases of asbestos could occur from such simple actions as renovation or remodeling of properties wherein asbestos was previously sealed behind walls. Release could also occur in instances such as the demolition of a property, or destruction from a fire or other disaster, such as occurred earlier this year when a house on Mineral Avenue in Libby was consumed by fire.

The institutional controls referenced in the agency’s proposed plan are vague and provide no information about how future releases created by demolition, excavation or destruction of property could be managed by local personnel in order to prevent exposure, it establishes the goal of managing future exposure, even though the Inspector General stated in the report that no exposure to asbestos is safe.

“According to the United States Department of Health and Human Services, asbestos is a human carcinogen with no safe level of exposure, and can lead to serious diseases such as asbestosis, lung cancer and mesothelioma,” the report read.

The Inspector General recommended the agency re-evaluate current wetting protocols for dilapidated structures in light of the study’s findings and assess the potential human health risk from such releases.