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U.S. Environmental Protection Agency	18-P-0271
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I	% Office of Inspector General	September 18,2018
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At a Glance
Why We Did This Project
Our objective was to determine
whether EPA Region 4 and the
state of North Carolina followed
appropriate procedures in
addressing claims of an improper
asbestos demolition at the
Old Davis Hospital site in
Statesville, North Carolina.
Under the National Emission
Standards for Hazardous Air
Pollutants (NESHAP), specific
work practices must be
implemented by the property
owner to control the release of
asbestos fibers into the air.
In October 2015, a caller
contacted the National Response
Center with a complaint that a
potentially improper demolition
was underway at the Old Davis
Hospital site and that an
unspecified amount of asbestos
was potentially released.
This report addresses the
following:
•	Cleaning up and revitalizing
land.
•	Partnering with states and
other stakeholders.
Delayed Cleanup of Asbestos Debris at the
Old Davis Hospital Site Necessitates Changes
for EPA Region 4 and North Carolina
EPA Region 4 and North Carolina
followed procedures at the Old
Davis Hospital site; however, those
procedures did not result in the
timely removal of asbestos that
posed a potential threat to human
health and the environment.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
What We Found
EPA Region 4 and the state of
North Carolina followed appropriate
procedures at the Old Davis Hospital
site. In late October 2015, personnel
from the state of North Carolina
observed piles of debris at the site
suspected of containing asbestos,
which they later verified. However, it
took over 7 months for the state to request the EPA's assistance in performing
a removal of asbestos at the site in early June 2016, during which time there
was a potential threat of asbestos exposure.
EPA Region 4 followed its established procedures when it referred the
National Response Center notification to North Carolina for review, as North
Carolina had delegated authority. However, the state did not take action to
timely remediate the site's asbestos-containing waste material and demolition
debris. The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) provides federal authority for responding to releases
and potential releases of hazardous substances that may endanger public
health or the environment, but North Carolina does not have CERCLA
authority. State officials did not fully understand the extent to which the EPA
could assist in the removal.
As a result of the state's lack of action, individuals near the demolition site
were at risk of asbestos exposure. In June 2016, the EPA used its CERCLA
authority to conduct a time-critical removal at the site. In September 2016, the
EPA on-scene coordinator reported that the $1.4 million cleanup of the Old
Davis Hospital site was complete.
Recommendations and Planned Agency Corrective Actions
We recommend that EPA Region 4, in coordination with appropriate North
Carolina state officials, document clarification of the existing NESHAP
authorities. We also recommend that EPA Region 4 implement internal
controls to verify North Carolina's enforcement of work practices under the
Asbestos NESHAP at demolition and renovation sites, specifically in regard to
keeping asbestos-containing debris wet until the debris can be transported to
an approved landfill. EPA Region 4 concurred with our draft report findings,
with comment, and provided acceptable corrective actions.
Listing of OIG reports.

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