U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Early Warning Report:
Use of Unapproved
Asbestos Demolition Methods
May Threaten Public Health
Report No. 12-P-0125
December 14, 2011

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Report Contributors:
Eric Lewis
Martha Chang
Wendy Wierzbicki
Michael Wilson
Benjamin Beeson
Abbreviations
AACM	Alternative Asbestos Control Method
EPA	U.S. Environmental Protection Agency
NESHAP	National Emission Standards for Hazardous Air Pollutants
OSHA	Occupational Safety and Health Administration
RACM	Regulated asbestos-containing material
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	OIG Hotline@epa.gov.	write: EPA Inspector General Hotline
phone:	1-888-546-8740	1200 Pennsylvania Avenue NW
fax:	202-566-2599	Mailcode 2431T
online:	http://www.epa.gov/oiq/hotline.htm.	Washington, DC 20460

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< rJK-7 5	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
| Wl/V ®	WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
December 14, 2011
MEMORANDUM
SUBJECT: Early Warning Report:
Use of Unapproved Asbestos Demolition Methods
May Threaten Public Health
Report No. 12-P-0125
FROM: Arthur A. Elkins, Jr. fjUSW u
Inspector General
TO:	Lisa P. Jackson
Administrator
The Office of Inspector General received allegations that the U.S. Environmental Protection
Agency (EPA) has authorized the use of unapproved methods to demolish buildings containing
asbestos. EPA may also have violated Occupational Safety and Health Administration (OSHA)
regulations designed to protect workers during previous experimental asbestos demolitions. Our
initial research indicates that these allegations have merit. We will continue to review these
allegations; however, the current and proposed use of unapproved methods requires your
immediate attention.
Background
Asbestos is a human carcinogen with no safe level of exposure. Asbestos exposure can lead to
serious diseases such as asbestosis, lung cancer, and mesothelioma. In 1973, EPA issued the
Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) to protect
human health by reducing exposure to asbestos during building demolitions and other activities.
According to the Asbestos NESHAP, regulated asbestos-containing material (RACM) must be
removed by specially trained technicians prior to demolition. RACM does not need to be
removed when the building is structurally unsound and in danger of imminent collapse. This
method reduces the release of friable asbestos by removing asbestos intact.
Beginning in 1999, EPA considered alternative methods to augment the Asbestos NESHAP.
These demolition methods, such as the Fort Worth Method and the Alternative Asbestos Control
Method (AACM), leave some or all RACM in place. Demolition equipment applies mechanical
12-P-0125
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forces that shred the RACM, potentially releasing asbestos fibers into the environment and
endangering public health. Buildings are wetted during demolition in an attempt to limit the
release of asbestos fibers. However, EPA has not approved or shown that these "wet" methods
are protective of human health. In July 2011, EPA's Office of Research and Development ended
its research on the AACM due to technical deficiencies.
Use of Unapproved Methods Threatens Health and Safety
Our preliminary research indicates that unapproved methods are currently being used or
considered at multiple sites. The Hanford Superfund Site, near Richland, Washington, is one
location where the use of AACM-like methods has been allowed by EPA under conditions that
are less restrictive than required by the Asbestos NESHAP. EPA is also considering other
unapproved methods for demolition at a gaseous diffusion plant in Paducah, Kentucky. The use
of unapproved methods is counter to EPA regulations. The current and proposed use of
unapproved methods may jeopardize the health and safety of the public.
For example, settled dust results obtained from testing during AACM demolition experiments at
Fort Chaffee, Arkansas, and Fort Worth, Texas, demonstrated asbestos fiber releases. Video
footage and photos show government employees and contractors at the demolition sites without
personal protective equipment, a possible violation of OSHA asbestos worker protection
requirements. Because settled dust results indicate that asbestos escaped the restricted areas,
unprotected workers adjacent to the restricted areas and any members of the public in the vicinity
of the sites may have been exposed. EPA should identify the workers that were present, and
notify them according to OSHA regulations. Further, EPA should notify the surrounding public
of potential asbestos exposure during these AACM experiments.
EPA should immediately and clearly communicate NESHAP and OSHA requirements for the
demolition of asbestos-containing structures to regional, program, and field offices to prevent
potentially hazardous asbestos exposures. EPA should notify these offices that unapproved
methods are not to be used without obtaining appropriate waivers. Further, EPA should identify
all sites, such as Hanford, with work plans that contain EPA authorization to use unapproved
methods for asbestos demolitions, and retract any such approvals that deviate from the Asbestos
NESHAP regulation. In addition, EPA should assess whether any authorizations resulted in
potential asbestos exposure of workers or the public, and notify them accordingly.
Thank you for your prompt attention to this important matter. If you have any questions, please
contact me at (202) 566-0847 or elkins.arthur@epa.gov. or Wade Najjum at (202) 566-0827 or
nai i um. wade@epa. gov.
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