Burning Buildings

[Lenny Siegel <lsiegel@cpeo.org>]

At this past week-end's focus group of RAB members from Army Ammunition
Plants, participants saw a video showing the demolition, by deliberately
set fires, of buildings at the Sunflower Army Ammunition Plant in
Kansas.

Back in my files, I found a letter from US EPA justifying the practice:

"... asbestos abatement prior to demolition is technically impracticable
for majority of the structures owing to the risk of explosion.
Consequently, the Sunflower Army Ammunition Plant cannot comply with the
applicable National Emission Standards for Hazardous Air Pollutants
requirements concerning asbestos (in the context of building
demolition). The waiver of this provision is justified by the conditions
stated in the National Contingency Plan, "compliance with the
requirement will result in greater risk to human health and the
environment than other alternatives," and "compliance with the
requirement is technically impracticable from an engineering
perspective."

This same argument might be used at any location where buildings
containing high levels of lead-based paint of asbestos containing
materials may also contain nitrocellulose, nitroglycerin, or multi-based
propellant.

Ironically, a federal appeals court just upheld a fine imposed by the
state of Tennesseem, under the Clean Air Act, on the Milan Army
Ammunition Plant for its failure to comply with the state's rules for
asbestos removal.

All of these World War II era Ammunition Plants contain buildings and
pipes with asbestos. The removal of the asbestos may (but might not be)
be considered cleanup where property disposal is intended.

LS
-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org