Attachment 3e Woods Ferry bath house(s) ACM variance request (2 pages).pdf

1258 Boiling Springs Road • Spartanburg, SC 29303 • Phone 864-541-8736 www.crossroadsenv.net

April 3, 2020

Mr. Brian Woodcock

SC DHEC

2600 Bull Street Columbia, South Carolina 29201

Re: Request for Variance Woods Ferry Campground Bath Houses

Dear Mr. Woodcock:

Crossroads Environmental, LLC performed asbestos inspections of two (2) bath houses, located on the Woods Ferry Campground site, which is located in Union County, and is a part of Francis Marion & Sumter National Forest.

The two (2) bath houses, which are scheduled for demolition, are of cinderblock construction. The interior surfaces of the cinderblocks are coated with an asbestos-containing skim coat, which is under layers of paint. Prior to bidding out the demolition, Crossroads Environmental, LLC, on behalf of the Forest Service of Francis Marion & Sumter National Forest, is requesting a variance to perform the abatement as a “demo in place” for the following reasons:

• It is highly unlikely that the skim coat can be entirely removed from the porous block, regardless of removal methods.

• Since the skim coat is painted, there would be less risk of fiber release as a “demo in place” performed properly than by using methods that would be required to remove the skim coat.

• The bath houses are extremely remote, with little access to power sufficient for blasting, etc.

• Cost to remove the coating (if possible) from the block rather than treat the block as ACM would be financially burdensome.

Photos are included below for your reference:

Variance Request April 3, 2020 Bath Houses at Woods Ferry Campground Page 2 of 2

1258 Boiling Springs Road • Spartanburg, SC 29303 • Phone 864-541-8736 www.crossroadsenv.net

The abatement will be provided under Project Design by a SC-DHEC Licensed Project Designer. Please feel free to contact me if you have any questions or need additional information regarding this project.

Sincerely, Kay H. Horton Project Designer