Original signed on November 19, 2001, by James Colman, Assistant Commissioner
Question Under Consideration
The question considered by the Department was: Should the Department adopt EPA's composite sampling policy or alternative Best Management Practices (BMPs) for managing ACJC/wallboard?
This issue arose from redevelopment work at the former Ft. Devens where hundreds of military housing units are to be demolished. The request to utilize alternative removal practices for wallboard with ACJC came from the public agency responsible for redeveloping the base. Alternative practices for managing this waste stream in turn pose public policy challenges in light of the Commonwealth's solid waste management strategy and worker safety standards. The Department's research on this issue led to this decision and the attached Discussion Document .
In order to make this decision, the Department focused on the following questions and related issues:
Is there information for either approach that shows that if adopted, risks related to asbestos in joint compound will not be significantly increased? Is there information to show that the asbestos found in joint compound is less toxic than other forms of asbestos? Is there information to show that exposure due to ACJC removal and disposal is not increased under either a composite sampling or an alternate BMPs approach?
Conclusion: The information needed to adequately assess risks associated with composite sampling or alternative BMPs for ACJC/wallboard is not available. Data gaps that need to be addressed include information on asbestos releases from joint compound under different removal and disposal conditions.
The Department has decided:
- that currently, there is not adequate information to determine whether DEP may adopt either composite sampling or alternate BMPs.
- to find opportunities to conduct a pilot study to develop additional data on exposures related to ACJC removal under alternative sampling and management practices.