Document Jn9rJgopYvYa1485d2Y4zvze

PPG INDUSTRIES,INC. CHEMICALS P.O. BOX 1000 August 21, 1985 LAKE CHARLES, LA. 70602 Henry Graham, Jr. Louisiana Chemical Association Suite 2040, One American Place P. o. Box 1188 Baton Rouge, Louisiana 70821 RE: Proposed Asbestos Regulations Dear Mr. Graham: PPG Industries, Inc. submits the following comments on the proposed amendments to Subpart F - Emission Standards for Asbestos, in Part IV of the Louisiana Air Quality Regulations. PPG owns and operates facilities in Lake Charles which utilize asbestos in the production of chlorine and caustic soda. In addition, although all new insulation material now utilized is of a non-asbestos nature, some amount of asbestos insulation still remains in service from past installations. Because of this, PPG will be affected by these proposed regulations and is interested in their future enforcement. SECTION 81.3(d)(1) The DEQ proposes that written notice of intention to demolish or renovate, including deminimus quantities, shall be provided by the facility owner/operator and the prime contractor. The elimination of deminimus quantity notification exceptions would require that the Air Quality Division (AQD) be notifi d each time the insulation from a single valve or one foot of pipe must be removed for repair/replacement/inspection purposes. This imposes an additional notification requirement which PPG views as unnecessary. It is highly unlikely or necessary that the AQD will or should send a field inspector to personally oversee the removal of such insignificant quantities of asbestos, which is one of the major reasons for such notification. SL 105026 H nry Graham, Jr. August 21, 1985 Page 2 Additionally, tha requirement that the prime contractor also notify the AQD is felt to be redundant in that it serves no useful purpose; this requirement should be eliminated, sine the owner/operator must also make the required notification. In the event that the prime contractor would fail to notify as required, the AQD could conceivably shutdown the asbestos removal project even though notice had been received from the owner/operator. Such a move by the AQD would delay the owner/operator in the completion of demolition projects and, in some instances, the start of new construction. SECTION 81.3(d)(3) THE ADVF In this paragraph, the AQD proposes that each notification of demolition/renovation (including deminimus quantity) received will result in a confirmation letter to the owner/operator accompanied by an Asbestos Disposal Verification Form (ADVF). They propose that the ADVF accompany each shipment of asbest s to the disposal facility. The ADVF will only be valid for a period of 60 days from the date of notification and the disposer will not be allowed to accept any asbestos for disposal unless a valid ADVF accompanies each shipment. There are several problems with this proposal. The first being that most significant demolition/renovation projects require several shipments of the asbestos insulation to the disposal facility. The proposal makes no provisions for obtaining additional forms as needed. The second problem is the disposal of deminimus quantities f asbestos insulation. Because the ADVF is valid for only 60 days, the owner/operator would be required to make more shipments to disposal facilities of amounts of insulation that are considerably less than cost effective for waste handling. The proposal makes no provisions for the storing of asbestos insulation from the deminimus project quantities until a significant amount has been collected. At a minimum, the provisions of this section should be revis d to provide a solution to the above, or better yet, eliminat d altogether since the information contained on the ADVF is repetitive (already contained in the Notification). With the elimination of the deminimus quantity exception, we are concerned with a possible time delay in receiving a confirmation letter and ADVF. SL 105027 Henry Graham, Jr. August 21, 1985 Pag* 3 Tha supposed purpose of this form is to enable the AQD to better track the demolition/renovation/disposal of asbestos Insulation. But, current regulations already require the name and address of the disposal facility utilized be provided to the AQD as a part of their notification requirements. Thus, the new form is unnecessary and redundant. INSULATION VS. NON-INSULATION ASBESTOS The proposed form states that no asbestos may be received by the disposal facility without a valid ADVF. Because there is no distinction between asbestos insulation and asbestos from other sources (C12/NaOH production), it is obvious that notification to the AQD would be necessary (in order to receive an ADVF) before asbestos from other sources could be shipped for disposal. This would mean additional reporting in order to obtain the ADVF necessary for the disposal of this material and could also cause the curtailment of production for lack of the proper paperwork. At present, there are no notification requirements regarding the disposal of asbestos, other than insulation. Also, all shipments of waste asbestos must be accompanied by either a Uniform Hazardous Waste Manifest or an alternate form which provides the necessary shipping information per D.O.T. Regulations which include the information contained on the ADVF. Therefore, some distinction should be made between insulation and non-insulation types of asbestos and the use of ADVF's should not be considered in connection with non-insulation asbestos. As a final comment, some consideration should be given by the AQD to using the present Uniform Manifest System already in place (by the DEQ Hazardous Waste Division) for the purpos of tracking asbestos disposal. This would eliminate the additional paperwork proposed by the AQD, serve them in tracking this waste from generation through disposal, and eliminate notification for notification's sake. Sincerely yours APP/bh bcc: D. Cannon (GO) H. Hank A. J. Kublcek U. .1 Peavri R. J. Samel son (GO) File #1101.2.04 SL 105028