Suggested Sampling Plans for Building Debris Disposal
Federal RCRA hazardous waste regulations and the state dangerous waste regulations regulate the test methods used for waste disposal designation, but they do not regulate screening strategies used to take test samples, other than the requirement to take a representative sample. The dangerous waste regulations defines a representative sample as "a sample which can be expected to exhibit the average properties of the sample source." Dangerous Waste testing regulations do not regulate how many waste samples to take or where to take them as long as one representative sample is done of each waste to be tested.
The following sampling plans for dangerous waste disposal are suggestions:
ASTM Standard E 1908-10
The Standard Guide for Sample Selection of Debris Waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb).
The Standard Guide for Sample Selection of Debris Waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb), is copyrighted by ASTM and cannot be reproduced here. ASTM describes the Standard as follows on their Store web site:
Five Sampling and Waste Characterization Plans
These sampling and waste characterization plans are adapted from the Connecticut Department of Energy and Environmental Protection. They provide guidance for the management and disposal of lead-contaminated materials generated in the lead abatement, renovation and demolition industries:
Plan One - Screen the building components to be removed using a field method such as portable XRF. Take representative samples of the components that field screening indicates are lead-contaminated and send for TCLP analysis. Segregate those materials which fail the TCLP test (i.e. have lead concentrations over 5.0 mg/l) for removal as dangerous waste. The remainder is solid waste. Selecting a representative sample: The most conservative approach is to sample every individual component. This may result in excessive and unnecessary sampling for some projects. An alternative approach is to sample each similarly-contaminated surface (one sample of each room that has a different paint surface, one sample of each unique baseboard, trim, siding etc.). Take a full cross sectional piece of the component for linear components (trim, baseboards, windowsills etc.). Take proportional amounts of the component for non-linear components (for a window take proportional amounts of any glass, wood, metal, paint and glazing compound).
Plan Two - Screen and Segregate
This method saves the money that would be spent on TCLP testing but may increase the amount that would be spent on dangerous waste disposal.
This approach by-passes the requirement for TCLP testing, but since any lead-contaminated components are disposed as dangerous waste, the environmental goals are met. Current literature indicates most lead painted components fail the TCLP, so this approach may give the same results as Plan One above.
Plan Three -Composite Sample and Demolish This method uses a composite sample to determine the lead content of the entire building debris. Use this plan in situations where it is strongly expected that the entire quantity of debris will not fail the TCLP. Use of this method in marginal situations may result in increased sampling and analysis costs without ultimately reducing disposal costs. Identify the different components to be removed (e.g. foundation, framing, siding, roof, drywall, trim, windows, doors, insulation etc.). Take aliquots or sub-samples of each component using a power drill, or by removing portions of the component. Select the sub-samples carefully to ensure that the resulting composite sample will be truly representative of the component. Mix the sub-samples together in proportion to their percent by weight in the total quantity of debris being removed. The resulting weight of the composite sample is not important, except that it must equal or exceed the 100-gram minimum sample weight specified for the TCLP test. Take one composite sample per structure, or one per 2500 square feet of floor space, whichever results in the greater number of samples. Send the composite for TCLP analysis. If the samples all come back with lead concentrations below 5.0 mg/l dispose of the debris as solid waste. If any of the samples come back with lead concentrations of 5.0 mg/l or more, then Dispose of the structure represented by the sample as dangerous waste, or Retest the structure to determine the individual hazardous components and dispose of them as dangerous waste. For further information about this method refer to: Decontamination Techniques for Buildings, Structures, and Equipment, M. P. Esposito, J.L. McArdle, A.H. Crone, and J.S. Greber, Noyes Data Corporation, Park Ridge NJ, 1987. Lead Testing and Abatement Manual, Guidelines for the Abatement of Lead Hazards in Connecticut, State of Connecticut Department of Public Health and Addiction Services, Lead Poisoning Prevention Program, 150 Washington Street, Hartford CT 06106.
This method involves using knowledge based on known data to calculate the concentration of lead in the entire quantity of debris. It is best used where the contamination is confined to a distinct layer such as the paint. The full and versions of this method are described:The Full Version
The 100 milligrams per kilogram value used above represents the lowest possible mass analysis concentration which could leach out greater than 5.0 milligrams per liter in a TCLP test. This is due to the 20:1 dilution ratio of the TCLP test protocol, and also assumes that 100% of the lead in the sample will leach out. Although in reality 100% of the lead would rarely leach out this assumption must be made in the place of actual TCLP results. This "worst-case" assumption adds a "safety factor" to compensate for errors in the data or in calculating the mass of the structure.
If the initial test results show that the average weight percent of lead in the lead-based paint, the average paint thickness, or the average paint density varies widely from one part of the structure to another, it may be better to do separate "mass of lead-based paint" or "mass of lead in the lead-based paint" calculations for each part of the structure with similar values. The individual results for the different parts of the structure could then be summed before dividing by the mass of the entire structure.
As an example, consider a structure where the interior has only low levels of lead based paint, but the exterior has multiple thick layers of high-lead paint.
A simpler alternative is to use the highest numbers in each category for the calculation on the entire structure. If the calculation passes the 100 milligrams per kilogram test even with the highest values, there is no need to go through the additional effort to weight the different portions of the structure in this manner, since the result can only be lower.The Shortcut Version:
A short-cut variation of the above method is useful as a quick screening tool, to direct TCLP sampling efforts, or to confirm non-hazardous characterization of materials with low levels of lead contamination. Samples are not necessary.
Use numerous field XRF values and the painted surface area to calculate the "mass of lead in lead-based paint" value as follows:
The calculation then proceeds from this point as outlined in step 5 of the Full Version above.
If the XRF readings vary widely from one part of the structure to another, then the "mass of lead in the lead-based paint" calculation should be done separately for each part of the structure. Sum the mass calculations before dividing by the mass of the entire structure.
The simpler alternative is to use the highest XRF readings for the entire structure and compare it to the 100 mg/kg standard in the "worst case" approach discussed above.Hide this content.
Plan Five - Demolish and Test
Ecology strongly recommends use of another method to take samples prior to building demolition, for the following reasons:
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