HWTR Dangerous Materials

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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 1908-97 - 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).

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).

ASTM (the American Society for Testing and Materials) is a not-for-profit organization that provides a forum for the development and publication of voluntary consensus standards for materials, products, systems and services.  ASTM develops standard test methods, specifications, practices, guides, classifications, and terminology in 130 subject areas. As used in ASTM, a standard is a document that has been developed and established within the consensus principles of the Society and that meets the approval requirements of ASTM procedures and regulations.

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:

1. Scope

1.1 This guide describes a method for selecting samples of building components coated with paints suspected of containing lead. The samples are collected from the debris waste stream created during demolition, renovation, lead hazard control, or abatement projects. The samples are subsequently analyzed in the laboratory for lead.

1.1.1 The debris waste stream is assumed to have more than one painted component, for example, metal doors, wood doors, and wood window trim.

1.2 This guide is intended for use when sampling to test for lead only and does not include sampling considerations for other metals or for organic compounds. This guide also does not include consideration of sampling for determination of other possible hazardous characteristics of the waste.

1.3 This guide assumes that the individual component types comprising the debris waste stream are at least partially segregated and that the volume of each type of component in the debris waste stream may be estimated.

1.4 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.

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:

  • One - Screen, Sample and Segregate
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    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).

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  • Two - Screen and Segregate
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    Plan Two - Screen and Segregate
    1. Uses field screening to identify lead contaminated components.
    2. Dispose of the lead-contaminated components as dangerous waste without further testing.
    3. Disposes of the non-contaminated components as solid waste.

    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.

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  • Three - Composite Sample and Demolish
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    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.

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  • Four - Screen and Calculate Lead Concentration
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    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
    1. Use field screening to find the components with lead-based paint.
    2. Record the dimensions of the lead-based paint coated surfaces and calculate the total painted surface area (in square centimeters) on the components to be removed.
    3. Sample the paint on the surface of the components to be removed, and test them at a laboratory to find the average weight percent of lead in the lead-based paint, the average paint thickness (in centimeters), and the average paint density (in milligrams per cubic centimeter).
    4. Estimate the mass (in kilograms) of the components to be removed. Traditional engineering and/or demolition industry methods may be used.
    5. Determine the mass-concentration of lead in the debris as follows:
    Volume of lead-based paint in cubic centimeters = Painted surface area in centimeters squared x Average paint thickness in centimeters
    Mass of lead-based paint in milligrams = Average paint density in milligrams per cubic centimeter x Volume of lead-based paint in cubic centimeters
    Mass of lead in the lead-based paint in milligrams = Average weight percent of lead in the lead-based paint x Mass of lead-based paint in milligrams

    Mass-concentration of lead in the structure in milligrams per kilogram = Mass of lead in the lead-based paint in milligrams divided by the Estimated mass of the structure in kilograms

    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:

    Mass of lead in the lead-based paint in milligrams

    =

    Average field XRF value in milligrams per centimeters squared

    x

    Painted surface area in centimeters squared

    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.

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  • Five - Demolish and Test
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    Plan Five - Demolish and Test

    1. Demolish the building.
    2. Take representative samples of the debris.
      • Take at least one composite sample per container (e.g. roll-off).
      • Each composite sample should consist of several random sub-samples that are characteristic of the type of waste in the container.
    3. Send the composite for TCLP analysis.
    4. If the sample TCLP results are below 5.0 mg/l, dispose of the entire quantity as solid waste.
    5. If any of the samples come back with lead concentrations of 5.0 mg/l or more, then dispose of the entire quantity as dangerous waste.

    Ecology strongly recommends use of another method to take samples prior to building demolition, for the following reasons:

    • Waste components with high lead levels cannot be identified, or separated in the container, which may cause the entire container of debris to become dangerous waste.
    • Building debris is usually tough, fibrous and heterogeneous; therefore difficult to sample compared to the screening methods above. Samples may not to be representative of the waste stream and increases the possibility of false positives and false negatives.
    • Once the debris is generated it becomes a solid waste subject to dangerous waste regulations. The debris must be stored and managed at the site while the lab results are pending. The waste is more likely to be mismanaged, along with time delays from waiting for test results.
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