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