Regulating Asbestos in Louisiana by Jodi G. Miller, CHMM, CPM Louisiana Solid Waste Conference March...

Regulating Asbestos in Louisiana

by

Jodi G. Miller, CHMM, CPM

Louisiana Solid Waste Conference

March 28, 2008

Louisiana Regulations Concerning Regulated Asbestos-containing Material

(RACM)

LAC 33:III.Subchapter M, Section 5151 Emission Standard for Asbestos

LAC 33:III.5151.F Standard for Demolition and Renovation (adopted from the NESHAP program, however, Louisiana is more stringent):

10-working day notification (AAC-2) prior to any demolition project or renovation involving asbestos;

Submit any changes prior to beginning operations;Any person or company contracted to perform a demo or

reno activity must be licensed by the Louisiana State Licensing Board for Contractors (LSLBC).

Louisiana Regulations Concerning Regulated Asbestos-containing Material

(RACM)

LAC 33:III.Subchapter M, Section 5151.FStandard for Demolition and Renovation:

Any project generating Asbestos Containing Waste Material (ACWM) will receive an Asbestos Disposal Verification Form (ADVF);Procedures for Emission Control: “Adequate Wetting” (or written permission from the Administrative Authority);Leak-tight clear transparent wrapping;No burning of any ACM (RACM, Category I, or Category II);After completion of the project, remove all loose debris;Notify the LDEQ Regional Office w/in 24 hrs.

Louisiana Regulations Concerning Regulated Asbestos-containing Material

(RACM)

LAC 33:III.Subchapter M, Section 5151.J Standard for Waste Disposal:

Label the containers storing wetted ACM;Store all wrapped and contained ACM in a labeled

secure area, non-public, tamper proof area until it can be transported;

Mark vehicles while loading and unloading;Maintain waste shipment records using an ADVF

during transport and disposal.

Louisiana Regulations Concerning Regulated Asbestos-containing Material

(RACM)

LAC 33:III.Subchapter M, Section 5151.M Reporting and Recordkeeping:

For the purpose of demo/reno, basically use of an AAC-7 form for Active Waste Disposal Sites AAC-7(is) for in state disposal facilities, or AAC-7(os) for out of state disposal facilities.

Louisiana Regulations Concerning Regulated Asbestos-containing

Material (RACM)

LAC 33:III.Subchapter M, Section 5151.NActive Waste Disposal Sites

LAC 33:III.Subchapter M, Section 5151.PTraining and Accreditation (refers back to LAC 33:III. Chapter 27)

Louisiana Regulations Concerning Accreditations, etc.

LAC 33:III.Chapter 27: Accreditations, Training, Schools and State Buildings:

Louisiana Asbestos Accreditations (Form AAC-1);Training Providers (Form AAC-3); Trainers (Form AAC-4); and Management Plans (Form AAC-8) for Schools and State Buildings only {Revised 10/19/07}.

Contractor Licensing/Accreditations “How it Works”

Contractor submits application for a commercial license to the Louisiana State Licensing Board for Contractors

{225-765-2301 or LSLBC.com};Attend and pass a 40-hour AHERA (Asbestos Hazard

Emergency Response Act) Supervisor/Contractor (S/C) training course at a recognized training provider;

Apply for LDEQ accreditation for Supervisor/ Contractor, which will be the “Qualifying party” for the LSLBC;

Qualifying Party must pass a business and law exam at the LSLBC;

Submit a copy of LDEQ S/C accreditation to LSLBC;Complete AHERA training and LDEQ accreditation for all

workers & supervisors.

LDEQ Asbestos AccreditationsLAC 33:III.Chapter 27

Asbestos Disciplines: Worker, Contractor/ Supervisor,

Inspector, (For schools and state buildings only: Management Planner and Project Designer);

Persons applying for asbestos disciplines, complete an Asbestos Accreditation Affadavit (AAC-1) form, fees, picture, training documents, and other documents as required;

Use the most current application as posted on the LDEQ. Asbestos and Lead page: http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2251

How Would a Disposal Site Become Recognized to Accept Regulated

Asbestos- Containing Waste Material

LAC 33:III.5151 requires that landfills attain a Type I (industrial) or a Type II (residential &/or commercial) solid waste permit or hazardous waste (RCRA Subtitle C) permit first;

An AAC-7 (is) or AAC-7 (os) form must then be completed and submitted to the LDEQ Air Permits Division along with a copy of the pages of the solid waste permit regarding asbestos handling and disposal, and a copy of the signature page of the permit;

LDEQ will review and approve the AAC-7 and therefore, recognize the landfill to accept such wastes, or deny the application.

Hurricane Guidance, Etc.

Hurricane Debris Guidance: RACM Guidelines for Debris Contractors (Revised

10/10/07)www.deq.louisiana.gov/portal/Default.aspx?tabid=2251

List of Recognized Asbestos Disposal Sites:http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2251

List of Construction and Demolition Debris Sites:http://www.deq.louisiana.gov/portal/tabid/259/Default.aspx

QUESTIONS

Contact Information:

Jodi G. Miller, CHMM, CPM

Environmental Scientist Senior

LDEQ, Air Permits Division

225-219-3004

Jodi.Miller@la.gov