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Regulating Asbestos in Louisiana. by Jodi G. Miller , CHMM, CPM Louisiana Solid Waste Conference March 28, 2008. LAC 33:III.Subchapter M, Section 5151 Emission Standard for Asbestos
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Regulating Asbestos in Louisiana by Jodi G. Miller, CHMM, CPM Louisiana Solid Waste Conference March 28, 2008
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.F • Standard 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.N • Active Waste Disposal Sites • LAC 33:III.Subchapter M, Section 5151.P • Training and Accreditation • (refers back to LAC 33:III. Chapter 27) Louisiana Regulations Concerning Regulated Asbestos-containing Material (RACM)
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}. Louisiana Regulations Concerning Accreditations, etc.
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. Contractor Licensing/Accreditations “How it Works”
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 LDEQ Asbestos AccreditationsLAC 33:III.Chapter 27
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. How Would a Disposal Site Become Recognized to Accept Regulated Asbestos- Containing Waste Material
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 Hurricane Guidance, Etc.
QUESTIONS • Contact Information: Jodi G. Miller, CHMM, CPM Environmental Scientist Senior LDEQ, Air Permits Division 225-219-3004 Jodi.Miller@la.gov