LDEQ Protocol to Comply with the LESHAP Regulations Jodi G. Miller, LDEQ and David Eppler, USEPA...

LDEQLDEQ Protocol to Comply Protocol to Comply with the LESHAP Regulationswith the LESHAP Regulations

Jodi G. Miller, LDEQJodi G. Miller, LDEQ

and and David Eppler, USEPADavid Eppler, USEPA

March 15 & 16, 2006March 15 & 16, 2006

LDEQLDEQ Protocol to Comply with the Protocol to Comply with the LESHAP RegulationsLESHAP Regulations

BackgroundBackground

On August 29, 2005, Hurricane Katrina struck southeast Louisiana as a On August 29, 2005, Hurricane Katrina struck southeast Louisiana as a strong Category 4 Hurricane with maximum sustained winds of strong Category 4 Hurricane with maximum sustained winds of approximately 143 mph and gusts up to 165 mph. approximately 143 mph and gusts up to 165 mph.

The parishes of Orleans, St. Bernard and Plaquemines were flooded by The parishes of Orleans, St. Bernard and Plaquemines were flooded by excessive rain and a storm surge of 20-30 ft, overtopping levees, and excessive rain and a storm surge of 20-30 ft, overtopping levees, and ultimately causing the breach of some of the levees.ultimately causing the breach of some of the levees.

On August 31On August 31stst, 2005, 80% of New Orleans was under flood waters as a , 2005, 80% of New Orleans was under flood waters as a result of the breached levees. result of the breached levees.

Other badly affected parishes were St. Tammany, Lafourche, St. John the Other badly affected parishes were St. Tammany, Lafourche, St. John the Baptist, Jefferson, Washington, and Terrebonne. Baptist, Jefferson, Washington, and Terrebonne.

In all, 25 parishes were affected. In all, 25 parishes were affected.


Hurricane Katrina’s Path of Destruction


BackgroundBackground

Less than one month later, on Less than one month later, on September 23-24, 2005, Hurricane September 23-24, 2005, Hurricane Rita moved through the Gulf of Rita moved through the Gulf of Mexico to strike southwest Mexico to strike southwest Louisiana and southeast Texas, Louisiana and southeast Texas, with 120-mph winds and a 20-foot with 120-mph winds and a 20-foot wall of water.wall of water.

19 parishes in all were affected. 19 parishes in all were affected. Those hit worse were: Cameron, Those hit worse were: Cameron, Calcasieu, Vermilion, Iberia, St. Calcasieu, Vermilion, Iberia, St. Mary, and Jeff Davis. Mary, and Jeff Davis.

Rita


NESHAP MatrixNESHAP Matrix(residential structures of 4 units or less- no condos, (residential structures of 4 units or less- no condos,

apartments or commercial buildings)apartments or commercial buildings) TYPE OF STRUCTURETYPE OF STRUCTURE

Unsound structureUnsound structure (structure subject to a governmental (structure subject to a governmental demolition order for which a thorough inspection is not required)demolition order for which a thorough inspection is not required)

ACTIVITYACTIVITY InspectionInspection

NESHAPNESHAP A thorough inspection is not required due to structure being A thorough inspection is not required due to structure being

structurally unsound and in imminent danger of collapse, moved structurally unsound and in imminent danger of collapse, moved off its foundation, or uninhabitable.off its foundation, or uninhabitable.

FLEXIBILITY WITH NAA LETTER – (next slide)FLEXIBILITY WITH NAA LETTER – (next slide)

NESHAP MatrixNESHAP Matrix(residential structures of 4 units or less - no condos, (residential structures of 4 units or less - no condos,

apartments or commercial buildings)apartments or commercial buildings) FLEXIBILITY WITH NAA LETTERFLEXIBILITY WITH NAA LETTER

Unsound structureUnsound structure definition expanded to include homes that definition expanded to include homes that are structurally unsound or moved off their foundation but not are structurally unsound or moved off their foundation but not necessarily in danger of imminent collapse (2/3/06 - 2/3/07)necessarily in danger of imminent collapse (2/3/06 - 2/3/07)

Government issued demolition orders for groups of covered Government issued demolition orders for groups of covered residences (e.g. a block, sub-division, or other appropriate residences (e.g. a block, sub-division, or other appropriate geographic area) the same as an order based on individual geographic area) the same as an order based on individual determination (2/3/06 - 2/3/07)determination (2/3/06 - 2/3/07)

Unsound structures definition expanded to include homes that Unsound structures definition expanded to include homes that are uninhabitable for other environmental reasons. (2/24/06 - are uninhabitable for other environmental reasons. (2/24/06 - 2/24/07). 2/24/07).




ACTIVITYACTIVITY Pre-demolitionPre-demolition

NESHAPNESHAP Regulated ACM removal not possible due to condition of structure Regulated ACM removal not possible due to condition of structure Exterior ACWM may be removed (by licensed contractor) if no Exterior ACWM may be removed (by licensed contractor) if no

visible emissions are generated, but all waste (both ACWM and all visible emissions are generated, but all waste (both ACWM and all other material from the remaining standing structure) must be other material from the remaining standing structure) must be disposed of in a NESHAP compliant landfilldisposed of in a NESHAP compliant landfill

FLEXIBILITY WITH NAA LETTER - NoneFLEXIBILITY WITH NAA LETTER - None




ACTIVITYACTIVITY DemolitionDemolition

NESHAPNESHAP Must be wetted throughout demolition process (i.e. prior to and Must be wetted throughout demolition process (i.e. prior to and

during the demolition process) to eliminate visible emissions. during the demolition process) to eliminate visible emissions. Asbestos trained and accredited Supervisor/Contractor must be Asbestos trained and accredited Supervisor/Contractor must be

presentpresent




Unsound structureUnsound structure (structure subject to a (structure subject to a governmental demolition order for which a thorough governmental demolition order for which a thorough inspection is not required)inspection is not required)

ACTIVITYACTIVITY Transportation Transportation

NESHAPNESHAP Manage waste streams as ACWM (wet and cover Manage waste streams as ACWM (wet and cover

trucks)trucks)




Unsound structureUnsound structure (structure subject to a (structure subject to a governmental demolition order for which a thorough governmental demolition order for which a thorough inspection is not required)inspection is not required)

ACTIVITYACTIVITY DisposalDisposal

NESHAPNESHAP NESHAP compliant state asbestos permitted landfillNESHAP compliant state asbestos permitted landfill FLEXIBILITY WITH NAA LETTERFLEXIBILITY WITH NAA LETTER Disposal of asbestos containing material in Disposal of asbestos containing material in

“enhanced” (to become NESHAP compliant) C&D “enhanced” (to become NESHAP compliant) C&D landfills for all residential structures. (No NAA needed) landfills for all residential structures. (No NAA needed) Enhanced C&D disposal sites approved by LDEQ.Enhanced C&D disposal sites approved by LDEQ.



Sound structureSound structure (structure that is able to be thoroughly inspected) (structure that is able to be thoroughly inspected)

ACTIVITYACTIVITY Inspection Inspection

NESHAPNESHAP Accredited asbestos Inspectors requiredAccredited asbestos Inspectors required Thorough inspection required of each structure Thorough inspection required of each structure Structure is subject to a governmental demolition order.Structure is subject to a governmental demolition order.




Sound structureSound structure (structure that is able to be thoroughly (structure that is able to be thoroughly inspected)inspected)

ACTIVITYACTIVITY Pre-demolitionPre-demolition

NESHAPNESHAP Regulated ACM removalRegulated ACM removal Licensed asbestos contractor required Licensed asbestos contractor required Adequately wet prior to removal to eliminate visible emissionsAdequately wet prior to removal to eliminate visible emissions Handle material in a way to prevent damageHandle material in a way to prevent damage



apartments or commercial buildings)apartments or commercial buildings)

TYPE OF STRUCTURETYPE OF STRUCTURE


ACTIVITYACTIVITY DemolitionDemolition

NESHAPNESHAP Once regulated ACM is removed, no additional requirements - Once regulated ACM is removed, no additional requirements -

only C&D remaining (transport & dispose in a C&D Landfill)only C&D remaining (transport & dispose in a C&D Landfill)





ACTIVITYACTIVITY TransportationTransportation

NESHAPNESHAP ACWM waste - place in leak-proof containers, wet, cover truckACWM waste - place in leak-proof containers, wet, cover truck C&D - no requirements (handle according to State/local C&D - no requirements (handle according to State/local

requirements)requirements)





ACTIVITYACTIVITY DisposalDisposal

NESHAPNESHAP ACWM waste - State asbestos permitted landfill (Type 1 or 2)ACWM waste - State asbestos permitted landfill (Type 1 or 2) C&D waste - No requirements (handle according to State/local C&D waste - No requirements (handle according to State/local

requirements)requirements)


If a residential structure has been effectively demolished by a If a residential structure has been effectively demolished by a hurricane; collection, treatment and disposal of the debris is not hurricane; collection, treatment and disposal of the debris is not regulated.regulated. Letter dated November 9, 2005, EPA (Coleman) to US Army Corps Letter dated November 9, 2005, EPA (Coleman) to US Army Corps of Engineers (Smithers), states: “If a building or other structure was of Engineers (Smithers), states: “If a building or other structure was totally destroyed by a hurricane, then the National Emission totally destroyed by a hurricane, then the National Emission Standard for Asbestos, 40 C.F.R. Part 61, Subpart M (Asbestos Standard for Asbestos, 40 C.F.R. Part 61, Subpart M (Asbestos NESHAP) does not apply to any subsequent activities. For such NESHAP) does not apply to any subsequent activities. For such destroyed structures, you may immediately begin removal and destroyed structures, you may immediately begin removal and proper disposal of the resulting debris.”proper disposal of the resulting debris.”

LDEQLDEQ Protocol to Comply with the LESHAP RegulationsProtocol to Comply with the LESHAP Regulations

I. Structures Not Subject to Asbestos Demo/Reno I. Structures Not Subject to Asbestos Demo/Reno RegulationsRegulations


II. Structures Not Subject to Asbestos Demo/Reno RegulationsII. Structures Not Subject to Asbestos Demo/Reno Regulations

Demolition/Renovation conducted by homeowners or the Demolition/Renovation conducted by homeowners or the homeowner’s contractor is not subject to the Asbestos homeowner’s contractor is not subject to the Asbestos Demolition regulations. Demolition regulations.

References: 40 CFR Subpart M. § 61.154References: 40 CFR Subpart M. § 61.154 and and LAC 33:III.Subchapter M. Section 5151.B Definition of FacilityLAC 33:III.Subchapter M. Section 5151.B Definition of Facility

- - any institutional, commercial, public, industrial, or residential structure, any institutional, commercial, public, industrial, or residential structure, installation, or building (including any structure, installation, or building installation, or building (including any structure, installation, or building containing condominiums or individual dwelling units operated as a containing condominiums or individual dwelling units operated as a residential cooperative, residential cooperative, but excluding residential buildings having four or but excluding residential buildings having four or fewer dwelling units);fewer dwelling units); any ship; and any active or inactive waste disposal any ship; and any active or inactive waste disposal site. For purposes of this definition, any building, structure, or installation site. For purposes of this definition, any building, structure, or installation that contains a loft used as a dwelling is not considered a residential that contains a loft used as a dwelling is not considered a residential structure, installation, or building. Any structure, installation or building structure, installation, or building. Any structure, installation or building that was previously subject to this Subchapter is not excluded, that was previously subject to this Subchapter is not excluded, regardless of its current use or function.regardless of its current use or function.


Demolition of Residential Structures Conducted as Demolition of Residential Structures Conducted as

a Result of a Government Order a Result of a Government Order are Regulatedare Regulated

Regulated Residential StructuresRegulated Residential Structures

Multiple buildings being demolished as a result of the hurricanes in accordance with a government order are considered an “installation” as defined in the asbestos LESHAP.

Installation - any building or structure or any group of buildings or structures at a single demolition or renovation site that are under the control of the same owner or operator (or owner or operator under common control).

Because of this definition, the demolitions of multiple residential structures are regulated.


EPA No Action Assurance Letters for EPA No Action Assurance Letters for Structurally Structurally

Unsound ResidencesUnsound Residences

No Action Assurance Letters

EPA letters dated February 3, 2006, and February 24, 2006 include:

1. Residences that are structurally unsound and in danger of imminent collapse,

2. Residences that are subject to a government issued demolition order because the structure has been moved off of its foundation, and

3. Residences that are subject to government issued demolition orders because they are uninhabitable for other environmental reasons (e.g., from excessive flood damage rendering the home uninhabitable).


Demolition of Unsound Residential StructuresDemolition of Unsound Residential Structures

Unsound Homes Constructed Prior to January 1, 1980

No asbestos inspections are required.

1. Since no inspections are conducted, construction & demolition debris is assumed to contain Regulated Asbestos-Containing Material (ACWM).

2. All LESHAP regulations apply:Licensing, Accreditation, Notification (AAC-2), wetting during demolition, bagging, labeling, use of manifests or Asbestos Disposal Verification Forms, (ADVFs), and wetting during transportation, and disposal.

3. Disposal in a solid waste/asbestos approved Type 1 (Industrial) or 2 (Municipal & Commercial) Landfill is required.



Unsound Homes Constructed On or After January 1, 1980

1. No asbestos inspections are required.

2. Since no inspections are conducted, construction & demolition debris is assumed to contain Potential Asbestos-Containing Material (PACM).

3. All LESHAP regulations apply:

Licensing, Accreditation, Notification (AAC-2), wetting during demolition, bagging, labeling, use of manifests or Asbestos Disposal Verification Forms (ADVFs) during transportation, and disposal.

4. Disposal in an enhanced solid waste/asbestos C&D landfill is required.



Recommendations for Demolition of Residential Structures Containing Asbestos-Containing Waste Material (ACWM)

1. Each structure should be knocked down in a controlled manner to minimize excess breakage of asbestos containing material. Debris should be wetted/misted during demolition, interim staging, and loading activities.

2. Load C&D debris into polyethylene lined dumpsters that are leaktight.

3. Label, and transport to the appropriate landfill with ADVF.

4. Category I asbestos containing material (vinyl tile, mastic, etc.) need not be removed and segregated from the C&D debris if it does not have a high probability of becoming friable. If this material does not become friable by the forces expected to act on the material in the course of demolition, it may be disposed at an approved C&D landfill.


Demolition of Sound Residential StructuresDemolition of Sound Residential Structures

Structurally Sound Homes

1. A “thorough inspection” by an asbestos inspector accredited by the LDEQ may be performed.

(See attached “LDEQ Inspection Protocol for a “thorough inspection”)

2. If a thorough inspection is performed, and no regulated ACM is found, the Construction and Demolition (C&D) debris is disposed in an approved C&D debris (Type 3) landfill.

3. If a thorough inspection is performed, and regulated ACM or non-regulated ACM is found and removed, the ACWM must be disposed in an approved Type 1 or 2 landfill. The non-regulated ACM may be disposed in a designated area of an approved C&D landfill, and the remaining C&D debris may be disposed in an approved C&D debris landfill.

4. If a thorough inspection is not performed, the C&D debris is assumed to be regulated, and the ACWM must be disposed in an approved Type 1 or 2 Landfill.


Removal of RACM from Inside Sound StructuresRemoval of RACM from Inside Sound Structures Shut windows and doors. If they cannot be shut, install critical

barriers (e.g. polyethylene sheeting). Sufficient wetting is required to manage emissions during removal, bagging, and disposal.

a. Negative air is not required;b. The wet method must be employed to remove the Regulated ACM;c. Regulated ACM waste must be bagged and labeled;d. Bulk material left behind must be visually inspected and cleaned appropriately;e. No air monitoring clearance is necessary;f. Walls, ceilings, floors, etc. must be encapsulated to ensure ACM fibers are not being released during demolition and loading;g. Follow demolition procedures as noted in this Guidance; and h. Use OSHA worker protection guidelines.

Appendix AAppendix A

LDEQ Inspection Protocol for LDEQ Inspection Protocol for

“thorough inspections”“thorough inspections”

Regulated Asbestos-Containing Material (RACM) is:Regulated Asbestos-Containing Material (RACM) is:

Friable asbestos material;Friable asbestos material;

Category I nonfriable ACM that has become friable; Category I nonfriable ACM that has become friable;

Category I nonfriable ACM that will be or has been Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, in subjected to sanding, grinding, cutting, or abrading, in accordance with 40 CFR Subpart M-National Emission accordance with 40 CFR Subpart M-National Emission Standard Standard for Asbestos, 61.141. Definitions; andfor Asbestos, 61.141. Definitions; and

Category II nonfriable ACM that has a high probability of Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the powder by the forces expected to act on the material in the course of demolition or renovation operations.course of demolition or renovation operations.

Appendix AAppendix A

LDEQ Inspection Protocol for LDEQ Inspection Protocol for

“thorough inspections”“thorough inspections”

A thorough inspection includes:A thorough inspection includes:

Visual inspection - Visual inspection - (all suspect Asbestos Containing Material (ACM) is (all suspect Asbestos Containing Material (ACM) is identified and sampled or is presumed to be positive for asbestos.)identified and sampled or is presumed to be positive for asbestos.)

Sampling Sampling – Use AHERA protocol – Use AHERA protocol

Category I Category I (vinyl asbestos tile, window caulking, etc.). No sampling is (vinyl asbestos tile, window caulking, etc.). No sampling is necessary if in good condition & may be left in the structure during necessary if in good condition & may be left in the structure during demodemo

Category IICategory II – – (cementitious material such as roofing shingles and (cementitious material such as roofing shingles and siding may be assumed asbestossiding may be assumed asbestos

Waste Accepted at Waste Accepted at “ENHANCED” C & D LANDFILLS“ENHANCED” C & D LANDFILLS

Post-1980 Unsound residential structures Post-1980 Unsound residential structures that are subject to government issued that are subject to government issued demolition orders because they are demolition orders because they are structurally unsound and in danger of structurally unsound and in danger of imminent collapse, or uninhabitable for imminent collapse, or uninhabitable for other environmental reasons. other environmental reasons.

LDEQ REQUIREMENTS FOR LDEQ REQUIREMENTS FOR “ENHANCED” C & D LANDFILLS“ENHANCED” C & D LANDFILLS

C&D site must give prior notice to the LDEQ C&D site must give prior notice to the LDEQ indicating their request to perform indicating their request to perform enhanced C&D activities, enhanced C&D activities,

Submit an Operational Plan that meets the Submit an Operational Plan that meets the Requirements for Enhanced C&D landfills, Requirements for Enhanced C&D landfills, and and

Receive advanced approval by LDEQ prior Receive advanced approval by LDEQ prior to taking the waste.to taking the waste.


Adequate Perimeter Air Monitoring Adequate Perimeter Air Monitoring (sampling pump 1 liter/ minute 8 hr TWA)(sampling pump 1 liter/ minute 8 hr TWA)

Sample Methods:Sample Methods: NIOSH 7400 – PCM NIOSH 7400 – PCM (Phase Contrast Microscopy)(Phase Contrast Microscopy)

(as long as the sample does not exceed ½ the PEL)(as long as the sample does not exceed ½ the PEL)

NIOSH 7402 - TEM NIOSH 7402 - TEM (Transmission Electron (Transmission Electron Miscroscopy)Miscroscopy)

LELAP LELAP (La. Environmental Lab Accreditation Program)(La. Environmental Lab Accreditation Program)

Sample turn-around - 48 hours Sample turn-around - 48 hours


Detection LimitsDetection Limits

i.i. The sample method detection limit shall The sample method detection limit shall be 0.01 – 0.02 f/ccbe 0.01 – 0.02 f/cc

ii.ii. The OSHA permissible exposure limit The OSHA permissible exposure limit (PEL) for asbestos fibers is 0.1 f/cc(PEL) for asbestos fibers is 0.1 f/cc

Iii. If the sample exceeds more than ½ the Iii. If the sample exceeds more than ½ the PEL PEL (more than.05 f/cc)(more than.05 f/cc), the sample is , the sample is analyzed by TEM.analyzed by TEM.


Record KeepingRecord Keeping

i.i. Chain of Custody documentation shall be kept to Chain of Custody documentation shall be kept to document and verify samples,document and verify samples,

ii.ii. Calibration checks shall also be recorded,Calibration checks shall also be recorded,

iii.All records required by this section shall be iii.All records required by this section shall be maintained for 2 years, andmaintained for 2 years, and

iv.All records required by this section shall be iv.All records required by this section shall be maintained on-site and be made available for maintained on-site and be made available for inspection purposes or at the request of the inspection purposes or at the request of the Department.Department.


Notification and Response ActionsNotification and Response Actions

i.i. Sample results indicating asbestos fibers above the OSHA Sample results indicating asbestos fibers above the OSHA PEL of 0.1 f/cc - Notify LDEQ’s Single Point of Contact PEL of 0.1 f/cc - Notify LDEQ’s Single Point of Contact (SPOC) 225-219-3640 within 1 hour.(SPOC) 225-219-3640 within 1 hour.

ii.ii. Cease operations - investigate to determine the source of Cease operations - investigate to determine the source of the asbestos fibers.the asbestos fibers.

iii.iii.Report results of the investigation in writing to SPOC Report results of the investigation in writing to SPOC within 24 hours of completing the investigation. within 24 hours of completing the investigation.

iv.iv.Implement appropriate corrective action. Implement appropriate corrective action. v.v. Once approved, may begin site operations. Frequency of Once approved, may begin site operations. Frequency of

sampling shall return to daily. sampling shall return to daily.


Reporting of Air Monitoring and Sampling ResultsReporting of Air Monitoring and Sampling Results

i.i. During the first quarter (3 month period) During the first quarter (3 month period) Monthly reportingMonthly reporting

ii.ii. After the first quarter of operation After the first quarter of operation Semi- annual reporting (every six months), andSemi- annual reporting (every six months), and

iii.Use LDEQ approved air monitoring report form iii.Use LDEQ approved air monitoring report form Submit completed forms to the Office of Environmental Submit completed forms to the Office of Environmental

Services, Air Permits Division, ATTN: Jodi Miller.Services, Air Permits Division, ATTN: Jodi Miller.


Follow LESHAP RegulationsFollow LESHAP Regulations LAC 33:III.Subchapter M, Section 5151.N LAC 33:III.Subchapter M, Section 5151.N

Active Disposal Waste Sites Active Disposal Waste Sites

1. No Visible Emissions1. No Visible Emissions2. Daily Cover 2. Daily Cover - 6 inches of compacted nonasbestos-containing - 6 inches of compacted nonasbestos-containing

material, material, oror -- petroleum-based or other dust suppression agent, petroleum-based or other dust suppression agent,

or or - alternative emissions control method.- alternative emissions control method.


Follow LESHAP RegulationsFollow LESHAP Regulations

LAC 33:III.Subchapter M, Section 5151.N LAC 33:III.Subchapter M, Section 5151.N Active Disposal Waste SitesActive Disposal Waste Sites

Warning signsWarning signs

- Must be easily read - Must be easily read

- 20 inch × 14 inch upright format signs - 20 inch × 14 inch upright format signs

- Conform to a certain legend - Conform to a certain legend



LAC 33:III.Subchapter M, Section 5151.N LAC 33:III.Subchapter M, Section 5151.N Active Disposal Waste SitesActive Disposal Waste Sites

Must be fenced in a manner adequate to deter Must be fenced in a manner adequate to deter access by the general public.access by the general public.

Upon request, the Department will determine Upon request, the Department will determine whether a fence or a natural barrier adequately whether a fence or a natural barrier adequately deters access by the general public.deters access by the general public.



LAC 33:III.Subchapter M, Section LAC 33:III.Subchapter M, Section 5151.N 5151.N Active Disposal Waste SitesActive Disposal Waste Sites

- Maintain waste shipment records (LDEQ ADVFs) - Maintain waste shipment records (LDEQ ADVFs)

- Copies to the generator & LDEQ w/in 30 days- Copies to the generator & LDEQ w/in 30 days

- Submit discrepancy reports, if needed- Submit discrepancy reports, if needed

- Maintain records for 2 years - Maintain records for 2 years



LAC 33:III.Subchapter M, Section LAC 33:III.Subchapter M, Section 5151.N 5151.N Active Disposal Waste SitesActive Disposal Waste Sites

- Maintain records on location, depth and area, and Maintain records on location, depth and area, and quantity quantity

- Upon closure, submit records to LDEQUpon closure, submit records to LDEQ- Notify the Department in writing at least 45 days Notify the Department in writing at least 45 days

prior to excavatingprior to excavating

LDEQ Demolition Debris MatrixLDEQ Demolition Debris Matrix

A.A. Pre-1980 Unsound Residential Structures Pre-1980 Unsound Residential Structures

Government ordered, 4-plex and smallerGovernment ordered, 4-plex and smaller

No inspection requiredNo inspection required No segregation requiredNo segregation required Mechanical demolition allowedMechanical demolition allowed Wet method appliedWet method applied Clear poly lined dumpsterClear poly lined dumpster All waste to a Type 1 or 2 landfillAll waste to a Type 1 or 2 landfill No Action Assurance letter is not requiredNo Action Assurance letter is not required


B.B. Post-1980 Unsound Residential Structures Post-1980 Unsound Residential Structures

Government ordered, 4-plex and smallerGovernment ordered, 4-plex and smaller

No inspection requiredNo inspection required No segregation requiredNo segregation required Mechanical demolition allowedMechanical demolition allowed Wet method appliedWet method applied Clear poly lined dumpsterClear poly lined dumpster All waste to an Enhanced C&D debris LandfillAll waste to an Enhanced C&D debris Landfill Complies with NAAComplies with NAA


C.C. Pre-1980 Sound Residential Structures Pre-1980 Sound Residential Structures Government ordered, 4-plex and smallerGovernment ordered, 4-plex and smaller

Inspection by accredited asbestos inspector requiredInspection by accredited asbestos inspector required Segregation – asbestos abatement requiredSegregation – asbestos abatement required Mechanical demolition allowed for C&D after removal of ACMMechanical demolition allowed for C&D after removal of ACM Wet method appliedWet method applied Clear poly lined dumpsterClear poly lined dumpster ACWM to a Type 1 or 2 landfillACWM to a Type 1 or 2 landfill Segregated Category II (siding/shingles) to be disposed in a C&D Segregated Category II (siding/shingles) to be disposed in a C&D

approved landfill that accepts Cat II or a Type 1 or 2 Landfillapproved landfill that accepts Cat II or a Type 1 or 2 Landfill All remaining C&D waste to a C&D LandfillAll remaining C&D waste to a C&D Landfill No Action Assurance letter is not requiredNo Action Assurance letter is not required


D. Post 1980 Sound Residential Structures D. Post 1980 Sound Residential Structures Government ordered, 4-plex and smallerGovernment ordered, 4-plex and smaller

Inspection by accredited asbestos inspector requiredInspection by accredited asbestos inspector required Segregation – asbestos abatement requiredSegregation – asbestos abatement required Mechanical demolition allowed for C&D after removal of ACMMechanical demolition allowed for C&D after removal of ACM Wet method appliedWet method applied Clear poly lined dumpsterClear poly lined dumpster ACWM to a Type 1 or 2 landfillACWM to a Type 1 or 2 landfill Segregated Category II (siding/shingles) to be disposed in a C&D Segregated Category II (siding/shingles) to be disposed in a C&D

approved landfill that accepts Cat II or a Type 1 or 2 Landfillapproved landfill that accepts Cat II or a Type 1 or 2 Landfill All remaining C&D waste to a C&D LandfillAll remaining C&D waste to a C&D Landfill No Action Assurance letter is not requiredNo Action Assurance letter is not required

QUESTIONSQUESTIONS

For questions, you may contact:For questions, you may contact:

Jodi G. Miller at LDEQ 225-219-3004 or Jodi G. Miller at LDEQ 225-219-3004 or [email protected]@la.gov

David Eppler at EPA 214-665-6529 or David Eppler at EPA 214-665-6529 or

[email protected]@epa.gov

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