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.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 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 { 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 Accreditations LAC 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:

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)  List of Recognized Asbestos Disposal Sites:  List of Construction and Demolition Debris Sites:

QUESTIONS  Contact Information: Jodi G. Miller, CHMM, CPM Environmental Scientist Senior LDEQ, Air Permits Division