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Refer to Dangerous Waste Test Methods for more information about testing.
The most accurate way to determine lead, asbestos, PCBs and other environmental hazards at a site is to hire an independent hazard assessment expert to survey for them. An assessment contractor should be separate and financially independent from any environmental remediation companies that could be hired to remove the hazards.
Sampling and testing requirements of Chapter 173–303 WAC Exit Ecology - The Dangerous Waste Regulations, are found in section -110, Sampling and Testing Methods. All methods and publications referenced or listed in section -110 are incorporated into Ecology’s regulations.
The document titles and included sampling procedures listed in WAC 173-303-110 Exit Ecology are as follows:
The methods and equipment used for obtaining representative samples of a waste will vary with the type and form of the waste. Ecology will consider samples collected using the sampling methods below or the most recent version of such methods for wastes with properties similar to the indicated materials, to be representative samples of the wastes:
Copies of these representative sampling methods are available from the department except for the ASTM standards.
For free copies of Ecology publications contact your Regional Department of Ecology Office, or Ecology HQ at (360) 407-6752 or e-mail your request to dzin461@ecy.wa.gov.
Copies of the ASTM (American Society for Testing Materials) methods are copyrighted and may only be purchased from ASTM which is a private organization.
American Society for Testing Materials (ASTM) Exit Ecology
1916 Race Street
Philadelphia, PA 19103
Phone: (610) 832-9585
Fax: (610) 832-9555
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.
A representative sample is defined in the Dangerous Waste Regulations, WAC 173–303-040 as "a sample which can be expected to exhibit the average properties of the sample source."
Sampling of contaminated sandblast grit, wash water, HEPA filters, solvent solutions, paint chips and so on at a work site should be done following the advice of the dangerous waste testing laboratory, and any relevant testing guidance given in the following publications.
Department of Ecology Publications:
Environmental Protection Agency Publication:
If the waste is not intended to include the substrate the substrate should not be sampled. For example:
If a door or window component will be refinished or stripped of paint for remodeling or lead abatement the sample taken for disposal analysis should include the finish and the solvent mixture, but not the underlying wood, metal or concrete.
If the waste includes the substrate, such as a concrete foundation, the sample should include a sample of the finish in approximate proportion to the substrate. The sample of the painted or varnished finish may therefore be quite small.
Sampling of entire buildings or parts of buildings for lead and other hazardous materials is difficult and is not currently addressed in the Dangerous Waste Regulations.
Refer to Suggested Sampling Plans for Building Debris Disposal for guidance.
Other regulatory agencies have developed guidelines for sampling and testing of lead-based paint in residential dust, paint and soil. Lead paint abatement screening plans and devices such as the XRF scanner can provide knowledge to direct dangerous waste designation.
Refer to the section on Sampling and Testing for Residential Lead Abatement for more information.
Samples collected may be composited (that is, combined) for laboratory analysis provided that samples for different components (i.e., floors and interior window sills) are combined in separate composites. The number of samples in a composite will increase the weight of the sample. EPA recommends that the laboratory that will do the chemical analysis be consulted to determine the appropriate number of samples that can be combined in one composite. All subsamples in a composite should be collected from approximately the same size area.
A single room with suspected lead paint may have several different surfaces that are not representative of each other. For example, there may be differences in the paint or varnish on the door, walls, trim boards, windows, floors, and ceiling in one room. The ceiling, wall plaster, floor tiles and any pipe wrappings may have asbestos. There may be PCBs in paint used around high heat equipment. Exterior or interior paints may have mercury as a fungicide or other dangerous metals as pigment.
The great variability in hazardous concentrations at different points on the same painted surface must be considered when screening or sampling for lead and other hazardous constituents. A 1993 study found that field duplicate samples for lead spectroscopic analysis by NIOSH method 7082, on single painted components (such as window sash), varied by 30-60% from results on the same component but taken several inches away.
See the report, A Field Test of Lead-based Paint Testing Technologies, EPA number 747-R-95-002a, May 1995, available on the Internet at http://www.epa.gov/oppt/lead/pubs/summary.txt Exit Ecology or from the National Lead Information Clearinghouse at 1-800-424-LEAD.
A more detailed technical report, A Field Test of Lead-based Paint Testing Technologies, Technical Report, EPA number 747-R-95-002b is also available.
Using knowledge to designate a waste may require taking screening samples. For example a paint chip analysis could show that there are no regulated metals in a paint coating. The generator would not be required to run a Toxicity Characteristic Leaching Procedure (TCLP) test for lead or mercury before the waste is disposed.
Statistical sampling strategies or screening plans can also help the generator find areas that need to be tested by the dangerous waste test methods. They also help decide how many designation testing samples to take. Sampling strategies are different for different media such as paint, dust, and soil.
Although Federal RCRA hazardous waste regulations and the state dangerous waste regulations regulate the test methods used for waste disposal designation they do not regulate screening strategies used to take test samples - other than the requirement to take a representative sample.
Sampling of entire buildings or parts of buildings for lead and other hazardous materials is difficult and is not currently addressed in the Dangerous Waste Regulations. Refer to suggested Suggested Sampling Plans for Building Debris Disposal (Non-regulatory guidance on where to take samples and how many to take) for further guidance.
The two most common lead screening methods are taking readings from an XRF instrument and using chemical test kits. Paint chips for total metals laboratory analysis are also taken to check lead levels before the more expensive TCLP tests are run. XRF readings and paint chip analysis can be used for dangerous waste designation screening but chemical test kits cannot be used.
For more information refer to the section on Sampling and Testing for Residential Lead Abatement .