Sacramento Metropolitan Air Quality Management District (SMAQMD) Update!

Notice of Public Hearing
Sacramento Metropolitan Air Quality Management District
Proposed Amendments to Rule 902 – Asbestos

Date:         July 26, 2012

Time:        9:30 a.m.

Location:    Room 1450 (Board of Supervisors’ Chambers)
County Administration Building
700 H Street
Sacramento, California 95814

The Board of Directors of the Sacramento Metropolitan Air Quality Management District (District) will consider the adoption of proposed amendments to Rule 902 – ASBESTOS.

Rule 902 contains work practice requirements for owners and operators of facility renovations, demolitions, and other asbestos handling activities.  Staff is proposing minor changes to the demolition and renovation sections of the rule to be more specific that consultants are included as owners or operators, to include sampling provisions that are consistent with the District’s current survey form, and to restructure some of the rule language.

Rule 902 implements the federal asbestos requirements of 40 CFR Part 61 Subpart M, which has been delegated to the District by the U.S. Environmental Protection Agency (EPA).  The rule will be submitted to EPA pursuant to the District’s delegation authority at 40 CFR 61.04(c)(9)(ii)(F).

Copies of this notice, the proposed rule, and the staff report are posted on the District's website at this location: www.airquality.org/notices/index.shtml.  Paper copies may be viewed at the District office or purchased for a fee of 25¢ per page plus mailing costs.

By this notice, all interested parties are specifically requested to provide comments on the proposed amendments.  Oral testimony may be directed to the Board of Directors at the public hearing on July 26, 2012.  You can also submit your comments via mail to the Sacramento Metropolitan AQMD, 777 12th Street, 3rd Floor, Sacramento, CA 95814, Attention: Joe Carle (916) 874-4838 or via email to JCarle@airquality.org.

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SMAQMD
777 12th Street, 3rd Floor
Sacramento, CA 95814
www.airquality.org
Telephone: (916) 874-4800 or (800) 880-9025 (toll free within Sacramento County)
Fax: (916) 874-4899

California Proposes Amendments to Cap-and-trade Regulations for Linkage With Quebec

The California Air Resources Board (CARB) proposed amendments to the state’s cap-and-trade regulations to effectuate linkage between the state’s program and a cap-and-trade program established by Quebec. Among other things, the proposed regulations provide for a joint auction of allowances in November. CARB also proposed amendments relating to trading mechanics and market oversight. The proposed amendments are subject to a 45-day comment period, and then will be on the agenda for a meeting of the board on June 28. The proposed amendments and related materials are available at http://www.arb.ca.gov/regact/2012/capandtrade12/capandtrade12.htm.

Contaminated Debris under RCRA

As with contaminated soil, debris is very different in physical form from the process wastes that EPA evaluated when establishing LDR treatment standards. The definition of debris in §268.2(g) is:

"Debris means solid material exceeding a 60 mm particle size that is intended for disposal and that is: a manufactured object; or plant or animal matter; or natural geologic material. However, the following materials are not debris: any material for which a specific treatment standard is provided in Subpart D, Part 268, namely lead-acid batteries, cadmium batteries, and radioactive lead solids; process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludges, or air emission residues; and intact containers of hazardous waste that are not ruptured and that retain at least 75% of their original volume. A mixture of debris that has not been treated to the standards provided by §268.45 and other material is subject to regulation as debris if the mixture is comprised primarily of debris, by volume, based on visual inspection."
Several aspects of the debris definition warrant discussion:

1. Debris is material that is bigger in one dimension than 2.5 inches (60 mm).
2. Debris is material that is intended for disposal. When manufacturing operations are shut down, a very common material that is encountered is metallic equipment and components that might be contaminated with hazardous constituents. If this material is recycled instead of disposed, it is not "debris" subject to the LDR debris standards. In other words, recycling rather than disposing material may eliminate the need to comply with the debris standards.
3. Examples of manufactured objects that are "debris" are gloves and other personal protective equipment, solder paste wipes, pipes, pumps, valves, etc. that will be disposed (perhaps due to radioactive contamination that makes them nonrecyclable). [RO 14660]
4. An example of plant material that would be "debris" is a tree stump.
5. An example of geologic material that would be "debris" is a rock.
6. The language about intact containers addresses drums that might be dug up as part of a remediation project. If the drums contain hazardous waste and are intact, the contents of the drums must be treated to meet §268.40 standards for whatever waste codes are associated with the contained wastes. In other words, intact drums of hazardous waste are not eligible for the more lenient alternative treatment standards for debris. On the other hand, if a ruptured drum is excavated, it may be managed under the debris standards.
7. The language about material being primarily debris based on visual inspection implies that it is not necessary to run a sieve analysis to determine if a waste is mostly debris, as opposed to something else (e.g., soil). A visual assessment is all that is required.

 

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