National Asbestos Meeting State Challenges/Issues/Problems

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National Asbestos Meeting State Challenges/Issues/Problems Mid-West Regional Environmental Consortium M.W.R.E.C. Illinois Indiana Michigan Minnesota Ohio Wisconsin US EPA, Region 5 Friday, June 24 th, 2011

Illinois Licensure: - In process of re-writing State code. - Will include an increase in licensing fees. - Large amount of enforcement performed over the past year.

Indiana NESHAP: - Significant increase in notification submittals. - 2 Compliance Inspectors resigned w/in 30 days of each other, working to fill vacant positions and bring up to speed. - Criminal Investigation currently ongoing.

Indiana Licensure: - Online Asbestos License Renewal Summary Launched September 1, 2010 64% online renewals as of June 13, 2011 Available State Resources used to design individual & contractor online application, security features, & monitoring oversight. Software programs utilized include Mylicense 2000, which incorporates E-Gov, E- Verification Microsoft.net web applications and a client server application called License 2000. License applications submitted by mail have gone from a 4 to 6 week turn around time to a 2 week turn around. Online license fees are paid by credit/debit card at time of renewal. A percentage of online applicants are randomly computer generated to participate in a bi-annual audit.

Michigan NESHAP: - Loss of experienced staff due to retirements and budget/funding issues. - High workload. Number of submitted notifications has increased significantly i.e. 3500 (FY09) to 6000 (FY10) to over 8000 (FY11). This number does not included subsequent revisions. - Antiquated submission requirements - postmark requirement. Handling of paper is an enormous burden on the program.

Michigan Licensure: - Changes in administration due to retirements: Asbestos Program Manager (Tony Casaletta) Training Coordinator (Fred Kirkland) - We are keeping busy getting in notifications, training, accreditations, and contractor licensing. Things don't seem to be slowing down.

Minnesota NESHAP: - Reduction in inspection staff over the years. - Added responsibility of regulating lead abatement regulations with the same number of inspection staff covering both program areas. - Conducting rulemaking and outreach for EPA's Lead RRP regulations. - MN Pollution Control Agency's (NESHAP) staff reduction to a half an administrative staff person (.5 FTE). No centralized presence of a NESHAP program in the Twin Cities.

Minnesota Licensure: - Lack of a dedicated NESHAP program. - Combining of Lead & Asbestos programs without an increase in staff. Additional duties assigned to existing staff. - Lack of support and concern from EPA.

Ohio NESHAP: - Increase in large residential urban demolition projects due to NSP funds, leads to... lack of understanding where residential structure exemption legitimacy applies; significant increase in number of notifications (from hundreds to over a thousand); - A better/clearer definition of "friable" and determining when/how ACM becomes friable... especially for Category I (resilient flooring).

Ohio Licensure: - Cross-training & P.D. re-development due to merging of Lead & Asbestos Programs. - 2010 Rule Revision adding building inspection & survey report requirements.

Wisconsin NESHAP: - Operating the program with 1 FTE position and 2 half time LTE inspectors. Will be hiring 1 FTE Inspector for the Southeast Region of WI. - Continue to encounter the occasional rip and run operation where no notice is filed and substantive violations are encountered. - Seeing an increase in improper waste disposal sites and issues with recycling of buildings and co-mingling of asbestos materials. There is an increase in facilities that recycle building demolition waste for use as biofuel.

Wisconsin Licensure: - Combined DNR & DHS electronic notification system established. - Nice to have an updated 'Asbestos in your Home' pamphlet from U.S. EPA website available for printing.

Overview 1. Increase in notifications. 2. Reductions in staff. 3. Doing more with less (States with combined asbestos & lead programs). 4. Outlook? Dependent on State Budgets!

QUESTIONS?