Stafford schools to make changes to asbestos management practice following EPA review of complaint

A photo of the front of the Ferry Farm Elementary School buildingThe review was conducted by the EPA after a complaint from a community member with ties to Ferry Farm Elementary School. The EPA did not release the community member’s name and she asked to remain anonymous out of concern about possible repercussions.

She was concerned about the school division’s possible noncompliance with the 1986 federal Asbestos Hazard Emergency Response Act and how it affects Ferry Farm. Under the act, local education agencies are required to identify possible asbestos-containing materials in school buildings, develop a management plan for those materials and make the plan available for public review.

School divisions are also required to “provide yearly notification to parents, teachers, and employee organizations on the availability of the school’s asbestos management plan and any asbestos-related actions taken or planned in the school,” according to an EPA fact-sheet on AHERA.

The community member said she has never received communication about possible asbestos-containing materials in the school, which was initially constructed in 1957 with renovations and additions completed in 1963, 1989 and 1992.

According to schools spokeswoman Sherrie Johnson, AHERA management plans are available to be viewed at each school that has one.

The schools, as identified in the division’s 1989 AHERA management plan, are Moncure, Falmouth, Ferry Farm, Garrisonville, Grafton Village, Hartwood, Stafford and Widewater elementary schools; Wright, Drew, Stafford and Gayle middle schools; and Stafford and North Stafford high schools.

“Information on the division’s AHERA Management Program is on the division’s web site and can be easily found by engaging the search engine using ‘AHERA’ as the search word,” Johnson continued.

The community member felt that online availability of the information doesn’t meet the requirement of annual notification, and also has concerns about how asbestos-containing materials will be handled in the upcoming $1.8 million renovation to parts of Ferry Farm.
Asbestos-containing materials will not release asbestos fibers—which, if inhaled, can cause lung cancer and other health problems—unless they are disturbed or damaged in some way by aging or physical impact. These materials are most dangerous when they become friable, or able to be crumbled by hand.

According to Ferry Farm’s 1989 AHERA management plan, friable asbestos-containing materials were found at Ferry Farm, as well as both friable and nonfriable suspected asbestos-containing materials. At the time, identified and assumed asbestos-containing materials were located in the ceiling tile, pipe and boiler insulation, floor tile and adhesives throughout the school.

More recently, results of six-month and three-year reinspection reports, which are mandated under AHERA, show that identified and assumed asbestos-containing materials still exist in fire doors throughout the school, tile adhesive in the storage room, art room and basement wing, glue dots behind chalk and bulletin boards in the original portions of the school, the stage curtains and the blue floor tile in the cafeteria and associated spaces.

According to the most recent two reviews, conducted by Apex Cos. in September 2018 and April of this year, all the identified and assumed asbestos-containing materials are in good shape with low potential for future damage—with the exception of the blue floor tile in the cafeteria, where cracking adjacent to the stage has “high potential for future damage.”

In April, the EPA confirmed that it was investigating the Ferry Farm complaint about noncompliance.

“EPA has received and is reviewing a complaint from a concerned citizen regarding compliance with [AHERA] at the Ferry Farm Elementary School,” EPA spokesman Roy Seneca wrote in an email to The Free Lance–Star.
According to Scott Horan, assistant superintendent for operations at Stafford County Public Schools, “No inspection was done by EPA.”

“We just exchanged some information through phone calls and emails, very informal,” he wrote in a May 15 email forwarded by Johnson to The Free Lance–Star.

In an April 11 email exchange between Horan and EPA compliance and enforcement officer Christine Convery, forwarded to The Free Lance–Star by the Ferry Farm community member, Convery wrote,
“It is EPA’s position that [local education agencies] may put AHERA info and documents on their website, however relevant parties must be notified at least once a year in writing (example: in local paper, as a flyer home to parents, etc.) of the availability of the info. In other words, the relevant parties must be notified that the information is on the website, otherwise they will have no idea that it’s there.”

In his May 15 email, Horan wrote that the division will “improve our communication to the community by ensuring the AHERA information is on each school website as well as a future notice will be sent out to the community through the school newsletter once a year.”
“We are in the process of making all the AHERA reports accessible on the division’s website by going to the website,” he continued. “In the past, we just had our required statement and who to contact. To date, we have several school data reports in place and the remaining should be in place by the end of [May].”

Convery wrote to the Ferry Farm community member on April 24 that she is still working with the school to determine when the school community will first receive a notice in writing about identified and assumed asbestos-containing materials.
Regarding the upcoming renovation, Horan said asbestos abatement plans would be posted on the school’s website and the division’s website when final design documents are completed in late August.
The 2019–20 school year begins Aug. 12 for Stafford County Public Schools.

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