U.S. Environmental Protection Agency	15-P-0168
* O) \ Office of Inspector General	June 16,2015
At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), evaluated the EPA's
Alternative Asbestos Control
Method (AACM) experiments to
assess the amount of asbestos
released into the environment.
During a separate OIG review,
we found conditions that
caused us to review the impact
of a portion of the Asbestos
National Emission Standards
for Hazardous Air Pollutants
(Asbestos NESHAP).
Since 1973, the EPA's
Asbestos NESHAP regulation
has allowed buildings that are
structurally unsound and in
imminent danger of collapse to
be demolished without first
removing regulated asbestos-
containing materials. The
demolition of these buildings
resulted in the generation of
highly contaminated asbestos
runoff wastewater.
This report addresses
the following EPA goal
or cross-agency strategy:
 Addressing climate change
and improving air quality.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
EPA Should Update Guidance to Address the
Release of Potentially Harmful Quantities
of Asbestos That Can Occur Under EPA's
Asbestos Demolition Standard
What We Found
The AACM experiments show that under
the EPA's Asbestos NESHAP standard, the
demolition of buildings that are structurally
unsound and in imminent danger of collapse,
and constructed with an asbestos-containing joint
compound orTransite, can release significant
amounts of asbestos into runoff wastewater.
Under the EPA's asbestos
demolition standard,
demolishing buildings
that are structurally
unsound and in imminent
danger of collapse can
release enough asbestos
into the environment to
pose a potential risk to
human health.
The untreated discharge of runoff wastewater can
contaminate the soil at the site or the water into
which it is discharged. The AACM experiments
demonstrate that the amount of asbestos released into runoff wastewater can
often exceed the legally reportable quantity for asbestos, which is 1 pound in a
24-hour period. As a result, the Asbestos NESHAP demolitions under the Code
of Federal Regulations (CFR) at 40 CFR  61.145(a)(3) could require notification
to the National Response Center in compliance with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)  103 if a
reportable quantity is released into the environment.
Upon a CERCLA  103 notification, the EPA is tasked with determining the
seriousness of the release and the need for an immediate response or cleanup.
To be consistent with the CERCLA process where reportable quantity releases
are occurring during Asbestos NESHAP demolitions, the EPA needs to assess
the potential public health risk posed by these releases.
Planned Corrective Actions
The acting Assistant Administrator for Air and Radiation did not agree with our
recommendations. However, the agency agreed that its guidance in the area
reviewed was "dated and disparate" and proposed alternative corrective actions,
which we accept. The actions include assembling a team of experienced
asbestos experts to advise and assist the Office of Air and Radiation in producing
an updated consolidated guidance document which has practical application to
the regulated community. All recommendations are resolved.