Louisiana Department of Louisiana Department of Environmental QualityEnvironmental Quality

Louisiana Department of Louisiana Department of Environmental QualityEnvironmental Quality

Jodi G. Miller, CHMM, CPM

May 9, 2007

New Orleans/Gulf Coast Challenges and Outcomes

Hurricanes Katrina and Rita

Hurricane Katrina

August 29, 2005

25 parishes under the Emergency Order

Hurricane Rita

Sept. 23-24, 2005

19 parishes under the Emergency Order

Louisiana Parishes – 64Affected Parishes - 35

R

R

R RR

R

R

R,K

R

R

R, K R

K R

K

R K

R K

R

R K

RR

K

K

KK

K

K

K

K

K

K

K

K

K

K

K

K

K

K

Rules, Policies and Guidance**Special Interest - Hurricane Related:  Please Take Note.**

(In Layman’s terms) http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2251

• LDEQ Protocol to Comply with the Louisiana Emission Standards for Hazardous Air Pollutants (LESHAP) Regulations (1/19/06; latest revision 5/10/06)

• LDEQ Inspection Protocol (2/17/06; latest revision 5/5/06)

• Louisiana Katrina/Rita NESHAP Matrix (5/25/06)

• Addendum to ADVF Procedure for Residential ACWM  (3/29/06; latest revision 2/27/07)

• LDEQ Requirements for "Enhanced" Construction & Demolition (C & D) Landfills  (3/10/06; latest revision 6/28/06)

Rules, Policies and Guidance **Special Interest - Hurricane Related:  Please Take Note.**

• J-2 Air Monitoring Report for "Enhanced"

(C & D) Landfills (5/30/06)

• RACM Demolition Assessment Guidelines For Contractors (9/20/06; latest revision 4/25/07)

• Guía para el asesoramiento de las demoliciones de RACM (Sp version 1/25/07) 

• Environmental Regulations Related to Demolition of Construction and Demolition (C&D) Debris (2/28/07)

Rules, Policies and Guidance **Special Interest - Hurricane Related:  Please Take Note.**

• Unauthorized C&D Wastes  (2/28/07)  

• Solid Waste Transporter List (Updated periodically)

• SLIDESHOW:  LDEQ Protocol to Comply with the LESHAP Regulations (March 15 & 16, 2006) 

• SLIDESHOW: Environmental Issues and Concerns: Hurricane Debris Management (1/31/2006)

Rules, Policies and Guidance **Special Interest - Hurricane Related:  Please Take Note.**

• SLIDESHOW: RACM Demolition Training for LDEQ Inspectors (8/17/06; latest revision 10/2/06 - Contractors Welcome to View)

• SLIDESHOW: 2006 Annual Asbestos and

Lead Workshop (9/14/06)

LDEQ Protocol to Comply with the LESHAP Regulations

The purpose of this protocol was to provide guidance for compliance with the standards for the demolition and renovation activities pursuant to the Louisiana Emission Standard for Hazardous Air Pollutants (LESHAP) for asbestos (LAC 33:III.Chapter 51.Subchapter M) and

included:

Guidance on the EPA No Action Assurance Letters (NAA)

(Environmentally Unsound) Determined regulated vs. non-regulated LESHAP structures

(Sound vs. Unsound) Guidance for demolition activities including best management

practices

(wetting, controlled demolitions, site security and air monitoring) Demolition or Renovation Notification Requirements (AAC-2) Requirements of a “Thorough Inspection” (5/5/2006)

LDEQ Protocol to Comply with the LESHAP Regulations

Also included are:

Disposal of Waste Streams resulting from inspections and demolition activities (Type 1, 2 or 3 landfills)

Handling of Debris and Waste Materials from Renovation or Demolition Activities

Louisiana Katrina/Rita NESHAP Matrix (5/25/06)

Options: RACM Abatement [Type 1 or 2]; [Remaining C&D] Category 1 may to be left in the structure during demo [C&D]; Demo on Unsound structures -RACM [Type 1 or 2];

LDEQ Thorough Inspection Protocol

– Asbestos Inspector Accredited by LDEQ is Required– All suspect Asbestos Containing Material (ACM) is sampled and

samples are analyzed by LELAP accredited laboratory, utilizing Polarized Light Microscopy

– The number of samples taken shall be in accordance with the Asbestos Hazard Emergency Response Act (AHERA)

– Partial Inspection to the extent possible

Suspect Regulated ACM consists of:– 1- Friable material – 2- Category I nonfriable ACM that has become friable; – 3- Category I nonfriable ACM that will be or has become friable– 4- Category II nonfriable ACM that has a high probability of becoming

or has become crumbled

Partial - If determined to be homogeneous and no other RACM is identified, the remainder of the structure will be determined to be C&D debris. However, if the inspector determines that the materials in the unstable/inaccessible portion of the structure are not homogeneous or that RACM is present, the unstable/inaccessible portion of the structure will be demolished and disposed as RACM.

Addendum to Asbestos Disposal Verification Form (ADVF) Procedure for

Residential ACWM Procedure: One ADVF per Contractor, per landfill, per day. (Must be in

the same per parish)

The first receiving load for the day must be accompanied by the original ADVF designated for that day.

The landfill accepts the ACWM load with the original ADVF and the accompanying form, Addendum to ADVF for Transportation and Disposal of ACWM which indicates the company names and truck #s to be used by the ADVF that day

The driver proceeds to the asbestos disposal area - where the contractor, truck company name, truck number, and initials are entered on the addendum sheet.

The Landfill personnel verify that the truck is on the Addendum submitted by the major contractor and verifies the yardage.

Addendum to Asbestos Disposal Verification Form (ADVF) Procedure for Residential ACWM 

Procedure: One ADVF per Contractor, per landfill, per day. (Must be in the same per parish)

Landfill personnel enter the yardage by the respective truck every time the truck delivers a load for that day.

The total yardage per truck and the total yardage per major contractor are tallied at the end of each day.

Landfill personnel certify that the loads listed on the form were received and properly disposed.

A hard copy is retained by the Landfill and the originals mailed to LDEQ with a copy to the major contractor within 30 days of receipt.

LDEQ Requirements for "Enhanced" C & D Landfills 

NESHAP Compliant Type III Landfills

In addition, these approved enhanced landfills:

Must cover daily

Must conduct air monitoring

Monitoring must be performed per the approved schedule

Analyze via TEM is the fibers/cc using Polarized Contrast Microscopy (PCM) is ½ the OSHA Permissible Exposure Limit (PEL of .05 f/cc)

Maintain records

Notify the Dept. of any discrepancies

Asbestos Team

Consists of:

Main Office Personnel (Air Permits & other Divisions)

Field Staff Contact Persons (Surveillance Division)

http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2251

Federal partners (EPA, COE, OSHA, FEMA, etc.)

Questions 225-219-3004

Asbestos WebDemo

Site

Field Staff HQ staff

Questions?