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ASTM (the American Society for Testing and Materials) has a homepage at http://www.astm.org/ Exit Ecology.
The Connecticut Department of Environmental Protection has a homepage at http://dep.state.ct.us/ Exit Ecology.
The following sampling plans for dangerous Waste disposal are suggestions. 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.
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, Chapter 173-303 WAC Exit Ecology, Section - 040 as "a sample which can be expected to exhibit the average properties of the sample source."
Refer to Representative Samples in the section on Dangerous Waste Disposal Sampling Requirements for more information.
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).
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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 from the debris waste stream created during demolition, renovation, or lead abatement projects. The lead toxicity of the waste then is determined by analysis of the leachate resulting from use of the Toxicity Characteristic Leaching Procedure (TCLP).
1.2 This guide is intended for use to sample debris waste created by renovation or lead abatement projects in and around buildings and related structures to determine the lead (Pb) toxicity of the waste.
1.3 This guide is intended for use when sampling to test for lead (Pb) only and does not include sampling considerations for other toxic metals or for toxic organic compounds. This guide also does not include consideration of sample for determination of other possible hazardous characteristics of the waste
1.4 This guide assumes that the individual type debris wastes are at least partially segregated and that each type waste may be viewed easily.
1.5 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.
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Adapted from the Guidance for the Management and Disposal of Lead-Contaminated Materials Generated in the Lead Abatement, Renovation And Demolition Industries, revised October 18, 1996, Connecticut Department of Environmental Protection Exit Ecology:
How to take the representative sample
Number of samples
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).
This method saves the money that would be spent on TCLP testing but may increase the amount that would be spent on 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. The Connecticut Department of Environmental Protection feels that the current literature on lead concentrations in debris indicates that a large portion of selected lead-contaminated components fail the TCLP so this approach may turn out nearly the same in result as Plan One above.
This method uses a composite sample to access the lead content of all of the 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.
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.
A similar method is found in ASTM 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), Copyright 2000, American Society for Testing and Materials, West Conshohocken, PA 19428-2959. E-mail the ASTM Support Desk at support@astm.org
This method was developed by the Denver Housing Authority for lead abatement projects in residential structures.
Field screening may be used before removal to limit the material that will be tested. Field screening will reduce the amount work but will increase the chances that the composite will fail the TCLP.
This method is labor intensive and is best suited to renovations and lead abatements which involve the removal of a fairly small number of building components.
Sawing the components creates a significant lead dust hazard to workers, residents or occupants of the structure and possible soil contamination. Protection of workers and the surroundings is necessary.
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 shortcut versions of this method are described:
| 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 |
Is the mass concentration less than 100 milligrams per kilogram?
If yes, the debris can be disposed as solid waste.
If no, the entire structure must either be re-evaluated using one of the other methods in this section, or it must be disposed as dangerous waste.
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.
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 Main Method 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.
Ecology strongly recommends using another method to characterize the waste before removal for the following reasons:
High lead levels in waste components cannot be identified, or separated in the container, so the whole container may become a dangerous waste.
Building debris is usually tough, fibrous and non-heterogeneous and therefore difficult to sample compared to the screening methods above. This leads to non-representative sampling and the increased possibility of false positives and false negatives.
Once the debris is created it is a waste and is subject to the solid and dangerous waste regulations. The debris must be stored and managed at the site while the lab results are pending. The chances that the waste will be mismanaged on site and the time delays from waiting for test results increase.