Correspondence with US-EPA about Asbestos in Demolitions:
by Sharyn Harris
Q: I read with interest the October 1 News Release about Asbestos. Should people living in a well-established city neighborhood with smaller lots be concerned when older homes are being demolished for redevelopment?
A: Yes, demolitions in residential neighborhoods can cause public exposure to asbestos. The case described in our News Release took place in a mixed commercial/residential neighborhood.
Q: When the homes are being demolished there appears to be nothing in place concerning asbestos abatement. A lot of times the beginning of the demolition will begin with the falling of large trees on the house. Then when the bulldozer comes in to finish the job, there is no water being used to keep the asbestos out of the air. It does not appear the demolition workers are suited in anyway to provide protection for themselves or their families.
A: The standards require demolition contractors to remove asbestos first, handling the material carefully to prevent dust. Unfortunately, residential properties are exempt from EPA's asbestos regulations under the Clean Air Act. The regulations fall under the National Emission Standards for Hazardous Air Pollutant for asbestos (the asbestos NESHAP). But if the property has more than 4 dwelling units, such as an apartment building, then the federal standards apply.
Q: A friend who lives in the neighborhood had to have an asbestos abatement in her home. The precautions taken were at the other extreme of what seems to occur when demolitions are happening.
A: If your friend lives in a individual home or in a condo or apartment with less than 5 units, they would not be required to do the abatement by EPA. However, they may live in an area where the State or local agency has stricter requirements. Nevertheless, I see your point that one situation resulted in very thorough control of asbestos dust and others result in zero control.
Q: Does the wording "threshold amount of asbestos" hold the key to my concern? What is the threshold and how would concerned citizens be able to have it determined if a demolition is putting more asbestos into the air than is healthy?
A: "Threshold" means that at least 160 sq feet or 260 linear feet of asbestos was disturbed from the project. Smaller jobs are not regulated by the asbestos NESHAP. The regulations do not include a "safe" level of asbestos emissions to the air. Rather, they were written to impose work practice requirements to prevent any visible dust from leaving the job site, such as keeping the material wet, sealing it in leak-tight bags and carefully lowering it to the ground. As a citizen, you can ask your local building department if they issued a demolition permit for the project, and then contact your Regional EPA office (look in the blue pages of the phone book for EPA) to ask if they have submitted a notice of demolition to EPA. EPA can then check to see if a notice was sent to us and what details are in the notice such as how much asbestos is in the building, who is removing it, where the waste is going, etc.
Q: Are there EPA requirements that must be met in all communities, or do state and local laws tend to supersede the federal mandates?
A: EPA sets the minimum standard, in place since the 1970's and updated most recently in 1990. State and local agencies can impose stricter requirements.
Please see our earlier entry about the problem.