LDEQ Demolition LDEQ Demolition Inspector Training Inspector Training by Jodi G. Miller LDEQ Air Permits Division With Assistance from Betty Brousseau Michael Drury Kevin Cousins LDEQ Surveillance Division Initial: September 19, 2006 Revised: October 2, 2006
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LDEQ Demolition Inspector Training by Jodi G. Miller LDEQ Air Permits Division With Assistance from Betty Brousseau Michael Drury Kevin Cousins LDEQ Surveillance.
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Initial: September 19, 2006Revised: October 2, 2006
LDEQ Demolition Inspector TrainingLDEQ Demolition Inspector Training
Introduction
Katrina destroyed many homes. Many of the older homes that will be demolished have asbestos-containing materials (ACM). Homes that have been identified or assumed to have ACM must be handled in a special way to ensure that there is no release of asbestos fibers, which could violate the federal and state rules governing asbestos removal (LESHAP).
The purpose of this class is to review the Demo Inspector checklist and LESHAP regulations to ensure that you understand what is required during the demolition process.
If demolition is being conducted by the homeowner (or their contractor) then LESHAP is not applicable.
Section A - ASBESTOS MANAGEMENT:
1.Is there an accredited asbestos supervisor onsite?If yes, Name: Accreditation#:
Yes No N/A
2. Are all workers that are directly involved in the demolition accredited asbestos workers? (Asbestos personnel MUST have LDEQ Asbestos Accreditation Photo ID OR LDEQ Asbestos Accreditation Certificate and Photo ID)
Yes No N/A
3. Is air monitoring being done on site? If yes name of the company conducting the Air Monitoring:
____________________ Name of onsite Accredited air monitor: __________________________Air monitor Supervisor/Contractor Accreditation #:
___________________________
Yes No N/A
4. Has the structure/debris been wetted prior to demolition, during demolition, interim staging and loading?
Yes No N/A
5. Was the debris loaded into a clear polyethylene “visqueen” lined container/vehicle? Yes No N/A
6. Was the polyethylene liner closed/secured/sealed “burrito wrapped”when loading was completed?
Yes No N/A
7. Has the generator information label been placed on the “burrito wrap” (generator name, site address, and date)?
Yes No N/A
8. Has the asbestos warning label been placed on the “burrito wrap”? Yes No N/A
9. Is the debris being transported on an Asbestos Disposal Verification Form (ADVF)? Yes No N/A
10. Which landfill is the debris being sent to for disposal?
Demo Inspector Checklist
Section B: DEBRIS MANAGEMENT:
1.Were the household hazardous wastes, white goods and electronic wastes removed from the demolition debris prior to loading the debris into the transport vehicle?
Yes No N/A
Section C – Additional Comments:
Demo Inspector Checklist
Revised 9/8/06
For asbestos questions call Kevin Cousins @ 225-572-4006, 225-315-8913 or Mickey Drury @ 985-373-7481
For debris, HHW, white goods, landfill questions, call Wayne Desselle @ 504-919-9355 or 504-736-7712.
Demo Inspector ChecklistDemo Inspector Checklist
AI #: 138648-Orleans (Parish specific)
Hurricane Katrina/Rita (Hurricane specific)
Date of Assessment: Parish: Orleans
Demolition location: City: New Orleans
Asbestos contractor: Crew #:
Asbestos supervisor: Phone #:
Asbestos contractor mailing address:
Prime contractor:
Prime contractor Responsible Official: Phone #:
Prime contractor mailing address:
Corps Q/A (if applicable):
Lead Inspector:
Other inspectors:
If demolition is being conducted by the homeowner (or their contractor) then LESHAP is not applicable.
Section A: ASBESTOS MANAGEMENT:
1.Is there an accredited asbestos supervisor onsite?If yes, Name: Accreditation#:
LAC 33:III.5151.3.hNo response action shall be conducted at a facility regulated by
this Section unless at least one asbestos abatement contractor/supervisor is physically present…
For the purpose of hurricane activities regarding residential structures, one supervisor may be allowed to supervise more than one demolition if the structures are adjacent to each other where the Supervisor can visibly see the demolition operation.
All asbestos abatement workers who are performing response actions other than SSSD activities shall be supervised by an asbestos contractor/supervisor.
Yes No N/A
Section A: ASBESTOS MANAGEMENT: (Cont’d)
1.Is there an accredited asbestos supervisor onsite? (Cont’d)If yes, Name: Accreditation#:
Proof consists of LDEQ issued Asbestos Accreditation Certificate and Photo ID or LDEQ Asbestos Accreditation Photo ID card.
For the purpose of hurricane activities regarding residential structures, if a DEQ accreditation certificate only is provided, a picture ID verifying that the Worker or Supervisor is the same person on the DEQ accreditation certificate is required.
LAC 33:III.5151.2739.B.5Readily available proof of accreditation for workers and
supervisors shall be at the job site or within the facility's confines.
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
2. Are all workers that are directly involved in the demolition accredited asbestos workers?
LAC 33:III.5151.2739.B.5 Readily available proof of accreditation for workers and supervisors
shall be at the job site or within the facility's confines.
Proof of Accreditation: (Asbestos personnel MUST have LDEQ Asbestos Accreditation Photo ID OR LDEQ Asbestos Accreditation Certificate and Photo ID)
(Workers are inside the barrier tape) (The term “Worker” does not
apply to Truck Drivers if they stay in the truck with windows rolled up; or are FEMA Archaeologists) See proof of Accreditation above
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
3. Is air monitoring being done on site? If yes name of the company conducting the Air Monitoring: ____________________ Name of onsite Accredited air monitor: ________________ Air monitor Supervisor/Contractor Accreditation #: ________________________
See proof of Accreditation above
LAC 33:III.2799.A.4Contracted air-monitoring personnel must be accredited
contractors/supervisors.
LAC 33:III.5151.P.1.ee. Air Monitor Personnel. A person must be trained as an asbestos
contractor/supervisor in accordance with LAC 33:III.2799.Appendix A—Agent Accreditation Plan, Paragraph A.4 and accredited to conduct air monitoring for an asbestos abatement project or related activity in facilities regulated by this Section.
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
4. Has the structure/debris been wetted prior to demolition, during demolition, interim staging and loading?
If visible emissions are observed, wetting is not adequate. Inform Supervisor & Corps representative on site of this concern.
LAC 33:III.5151.B. DefinitionsAdequately Wet—sufficiently mix or penetrate with liquid to prevent
the release of particulates. If visible emissions are observed coming from asbestos-containing material, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet. Once contained, water droplets formed inside disposal containers will be sufficient evidence of being adequately wet.
LAC 33:III.5151.F.3.i For facilities described in Subparagraph F.1.c (government ordered
demo) of this Section, adequately wet the portion of the facility that contains RACM during the wrecking operation.
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
4. Has the structure/debris been wetted prior to demolition, during demolition, interim staging and loading? (cont’d)
LAC 33:III.5151.F.3.f.if. For all RACM, including material that has been removed or
stripped:i. adequately wet the material and ensure that it remains wet until
collected and contained or treated in preparation for disposal in accordance with Subsection J of this Section;
Yes No N/A
5. Was the debris being loaded into a clear polyethylene “visqueen” lined container/vehicle? The visqueen/polyethylene or blend liner may be glued and/ or taped in burrito fashion or waste can be loaded into reinforced polyethylene bags, but must be secure and leak tight. LAC 33:III.5151.F.3.d d.After a facility component covered with, coated with, or containing RACM has been taken out of the facility as a unit or in sections pursuant to Subparagraph F.3.b of this Section, it shall be stripped or contained in leak-tight, clear, transparent wrapping.
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
6. Was the polyethylene liner closed/secured/sealed “burrito wrapped” when loading was completed?
The visqueen/polyethylene or blend liner can be glued and/ or taped in burrito fashion or waste can be loaded into reinforced polyethylene bags, but must be secure enough to withstand travel to the landfill.
LAC 33:III.5151. J.1.a.iii
iii. after wetting, seal all asbestos-containing waste material in leak-tight, clear, transparent containers (i.e., bags) while wet; or, for materials that will not fit into containers without additional breaking, put materials into leak-tight, clear, transparent wrapping. If utilizing plastic drums to contain ACM, the transparent wrapping requirement is not necessary. If drums are used to store bagged material, the bags must be transparent;
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
7. Has the generator information label been placed on the “burrito wrap”?
Visqueen/polyethylene or blend liner must be labeled with generator information prior to transporting offsite.
LAC 33:III.5151.J.1.a
a. Adequately wet and store asbestos-containing waste material as follows: v. for asbestos-containing waste material to be transported off the facility site, label containers or wrapped materials with the name of the waste generator and the location at which the waste was generated; . . .
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
8. Has the asbestos warning label been placed on the “burrito wrap”?
LAC 33:5151.J.1.a.iv-v
iv. label the containers or wrapped materials specified in this Subsection using warning labels specified by Occupational Safety and Health Standards of the Department of Labor, Occupational Safety and Health Administration (OSHA) under 29 CFR 1910.1001(j)(2) or 1926.58(k)(2)(iii). The labels shall be printed in letters of sufficient size and contrast so as to be readily visible and legible;
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
9. Is the debris being transported with an Asbestos Disposal Verification Form (ADVF)? If yes, list the ADVF#: _______________
Asbestos Disposal Verification Form (manifest) – Write in #Don’t spend anymore time on this. The Contractors are aware that the ADVF is required to be onsite, so there should not be anissue here.
LAC 33:III.5151.F.2.g.iiig. use the following procedures in order that the department can trace disposal of asbestos-containing waste material:
iii. the waste transporter shall transport the asbestos-containing waste material with the ADVF to a recognized disposal site and complete, sign, and relinquish the ADVF to the disposal site owner or operator at the time the asbestos waste is delivered for burial; etc.
Yes No N/A
Section A: ASBESTOS MANAGEMENT:
10. Which landfill is the debris being sent to for disposal? ___________
See attached list of disposal sites that accept this type of waste
LAC 33:III.5151.J.2.a2. All asbestos-containing waste material shall be deposited as soon as is practical by the waste generator at:a. a waste disposal site operated in accordance with the provisions of
Subsection N [Standard for Active Waste Disposal Sites] of this Section
Note: Please complete the Field Interview Form (FIF) if there are any Areas of Concern (AOC) prior to leaving the site and leave a copy with the Asbestos Contractor/Supervisor, and ensure that the Corps site representative is aware of the concerns.
Section - DEBRIS MANAGEMENT:
1.Were the household hazardous wastes, white goods and electronic wastes removed from the demolition debris prior to loading the debris into the transport vehicle?
Yes No N/A
Section C – Additional Comments:
Demo Inspector Checklist
Revised 9/8/06
For asbestos questions call Kevin Cousins @ 225-572-4006, 225-315-8913 or Mickey Drury @ 985-373-7481
For debris, HHW, white goods, landfill questions, call Wayne Desselle @ 504-919-9355 or 504-736-7712.
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the FieldDescription: The hose from the water truck (parked on Hwy 23) was Description: The hose from the water truck (parked on Hwy 23) was
unable to reach the back of the demolition site. This area was not unable to reach the back of the demolition site. This area was not being wet down during demolition.being wet down during demolition.
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the Field
Description: Excavator rolling on RACM Debris
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the Field
Description: Unmanned water hose (see arrow)
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the Field
• Description: Excavator rolling on RACM debrisDescription: Excavator rolling on RACM debris
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the FieldDescription: Dust emissions from RACM debris due to Description: Dust emissions from RACM debris due to
inadequate wetting.inadequate wetting.
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the Field
Description: Incomplete burrito wrap; the front of the truck Description: Incomplete burrito wrap; the front of the truck was not lined.was not lined.
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the Field
Description: Incomplete burrito wrap; the top of the Description: Incomplete burrito wrap; the top of the burrito bag was not sealed.burrito bag was not sealed.
Types of Concerns to Look For in the FieldTypes of Concerns to Look For in the FieldDescription: Burrito wrap taped over the trailer crossbar. This Description: Burrito wrap taped over the trailer crossbar. This
would prevent the burrito bag from sliding out in one piece.would prevent the burrito bag from sliding out in one piece.
Additional CommentsAdditional Comments
Supervisors need to be aware of the demo protocol.
Need for adequate supervision at sites; more than just the excavator operator and the hose man.
Most of the problems we have encountered were due to inadequate supervision.
Rolling on RACM Debris is not allowed under any circumstances.
• Leak-tight container (Complete bag or glue &/or taping)• The idea is for the bag to slide out in one piece. No
gluing of the bag to the sides of the trailer; do not tape the top of the bag over the trailer crossbar
• Clear plastic or polyethylene is required• Need tape and/or glue (must be secure)• Back flap under side flaps, front flap over side flaps• Generator label - prefer indelible marker
In practice, DEQ only requires tape or glue…just as long as the wrap is sealed and holds up in transport. (recent problems)
Additional CommentsAdditional Comments
Wetting of Debris:Wetting of Debris:
• Structure must be wet down before the demolition begins.
• Excavator should not be working unless there is somebody working the water hose.
• Must have properly operating equipment (hoses in good shape, adequate pressure).
• Mention pressure washer attachment; still must use a large volume hose for the roof.
• If two pieces of equipment are working, may need two water hoses.
Additional CommentsAdditional Comments
Asbestos Accreditations:Asbestos Accreditations:
• Hot zone workers, equipment operators, air-monitors, and supervisors must have their LDEQ asbestos accreditation certificate and photo ID; or LDEQ asbestos accreditation ID onsite.
• Copy of LDEQ accreditation certificate & own ID picture ID is allowed.
Health & Safety IssuesHealth & Safety Issues
Level D Protection is Required in the affected areas: Level D Protection is Required in the affected areas:
This includes:
Type 2 Safety vests
Hard hats
Wrap around Eye protection
Steel toe boots
Safety equipment can be purchased from WW Grainger
Health & Safety IssuesHealth & Safety Issues
Level D Protection is Required in the affected areas: Level D Protection is Required in the affected areas:
Staff are also required to wear:Long pantsLDEQ T-shirts or other LDEQ shirts for identification
Reminder: Tetanus shots should be up to date
Health & Safety IssuesHealth & Safety Issues
Take care not to step on: Take care not to step on: - - Broken glass- Nails
Stay out of the “hot zone”Stay out of the “hot zone”For personal safety, the following is recommended:- Sunscreen- Insect repellent- Bottled Water (which can be picked up from 1st floor loading dock)
QuestionsQuestions
Field Contacts:
Kevin Cousins 504-736-7736 W225-572-4006 cell 225-315-8913 alternate cell; or