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Regulating Asbestos in Louisiana by Jodi G. Miller, CHMM, CPM Louisiana Solid Waste Conference March 28, 2008
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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).
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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.
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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.
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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.
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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)
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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}.
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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.
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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: http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2251
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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.
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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
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QUESTIONS Contact Information: Jodi G. Miller, CHMM, CPM Environmental Scientist Senior LDEQ, Air Permits Division 225-219-3004 Jodi.Miller@la.gov
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