APPLICABILITY OF RCRA DISPOSAL REQUIREMENTS

                     TO

     LEAD-BASED PAINT ABATEMENT WASTES
                Final Report
                March,  1993
         Technical Programs Branch
       Chemical Management Division
 Office of Pollution Prevention and Toxics
   U.S. Environmental Protection Agency
            401 M Street, S.W.
           Washington,  DC  20460

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                         TABLE
OF CONTENTS
                                                          Page

 EXECUTIVE SUMMARY	'.	. .	     !

 1.0  INTRODUCTION	     4

          1.1 Purpose of the Report	     4
          1.2 RCRA Fackground,	     5
          1.3 Study Design and Results	:	     e
          1.4 Report Organization	„	     9

 2 . 0  TOXICITY TESTING DATA FROM THE HUD DEMO		.    10

 3.0  TCLP TESTING PROGRAM FOR SOLIDS
      AND PLASTIC SHEETING	    14

          3 .1 TCLP Testing of Solids	,	    14
          3.2 Results of TCLP Testing of Solids	.....    15
          3.3 TCLP Testing of Plastic Sheeting		    20
          3.4 Analysis of TCLP  Testing Results
              from Plastic Samples	    21

 4.0   WASTE DISPOSAL EXPERIENCE FROM THE HUD  DEMO	    30

 5 . 0   CONCLUSIONS	    32

 APPENDIX A:   EP-TOX Testing  Data from the HUD Demo,
              Sorted by  Waste Category and Lead
              Concentration in  the Extract.	    34

APPENDIX B:   Solids  Samples  from the HUD Demo
              Analyzed by TCLP. .	    38

APPENDIX C:   Plastic Samples from the HUD Demo	    40

APPENDIX D:   Regression Analysis for Plastic Samples...    42

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                        EXECUTIVE SUMMARY

     A  study was conducted by  the  U.S.  Environmental Protection
Agency's  (EPA's)  Office  of  Pollution Prevention  and Toxics,  in
response  to  a  request  from  Congress  (FY  1990  Appropriations
Conference  Report  on  HUD and  Independent  Agencies  rConference
Report  101-297f p.  30]) that the Agency prepare a  report assuring
that Resource Conservation and Recovery Act (RCRA)  hazardous waste
requirements would  not  be applied to debris  from lead-based paint
(LBP) abatement projects.   (The term "hazardous" is  used throughout
this report  as a legal definition under RCRA Section  3001 (40CFR
Part 261), not as a qualitative toxicological description).   The
study was conducted in  three parts.  First,  data on waste testing
from the  Department of Housing and Urban Development's  (HUD's)
nationwide  abatement   demonstration  project  was  evaluated  to
determine  the  hazardousness  as  defined   under  RCRA  of  various
categories of abatement waste.   Second, EPA designed and conducted
a detailed testing  program for  two  important categories of waste
not adequately tested in the HUD demonstration (large solid debris,
and protective plastic  sheeting) .  Third, waste disposal experience
of HUD's contractor for the demonstration project was  examined to
obtain  preliminary estimates of  the  volume of hazardous waste
generated, and the  cost of disposing of these wastes.

There are three categories of waste produced in large volume during
lead-based paint abatement.  These are:

     *1.  Filtered wash-water;
     2.  Solid  debris,  such as  old woodwork,  plaster,  windows,
         doors, and similar bulky components;
     3.  Plastic sheets and  tape  used to  cover  floors and other
         surfaces.
Filtered wash-water  was found  to be  non-hazardous,  and  may be
disposed of  according to  State and  local requirements.   Solid

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 debris was generally found to be hazardous only if the lead level
 in the paint, as measured  in  the  laboratory  by Atomic Absorption
 Spectrometry  (AAS),  exceeded  approximately  4.0  milligrams  per
 square centimeter  (mg/cm2).  Specifically, 5  of 6  samples tested
 (83%)  whose paint  AAS  lead level exceeded 4.0 mg/cm2  failed  the
 Toxicity Characteristic Leaching  Procedure (TCLP)  test  for  lead
 toxicity.   Conversely,  only 1  of 14 (6%) with paint AAS lead level
 below 4.0  mg/cm2 failed the TCLP test.  Measurements of paint lead
 level by field X-Ray Fluorescence (XRF) were poorly correlated with
 TCLP results.   Due  to the  limited  number and  non-random selection
 of samples tested,  the results for  solid debris are  suggestive
 only,  and require confirmation in a larger study before they can be
 used as a  basis for EPA policy.

 Plastic sheeting was found  to be  hazardous if certain  abatement
 methods were  used.   Based on the samples available to us,  when a
,heat gun was  used  for  paint  removal,  the plastic sheeting  was
 hazardous.   However,  it should  be  noted that, because of  the
 limited availability of samples, all  plastic sheeting  samples
 tested came from  a  single dwelling; it would be  desirable  to
 confirm the above finding  by  testing additional plastic  samples
 from other dwellings where a heat gun was used.  When encapsulation
 (use of flexible wall covering systems of a reinforced fiber type
that form a secure bond with the =ubstrate)  or enclosure  (covering
LBP-contaminated  surfaces  with  wood  paneling, gypsum  board,   or
fabricated  exterior enclosure  systems of  aluminum, vinyl  or wood)
were used,  the  plastic  was  sometimes  marginally hazardous.  When
other  methods were used, in  particular removal  and replacement  of
contaminated components, the plastic was non-hazardous.   It should
be  noted that,  although the  above  findings  are  indicative   of
whether  or  not  various  types of abatement waste are likely to  be
hazardous,   waste generators are ultimately responsible under EPA
regulations for the proper characterization and disposal of their
waste.

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There  are  several  other  categories  of  waste  commonly produced
during abatement, such as sludges, paint chips,  mops and rags, etc.
Many of these  categories,  are often hazardous.   However,  in many
cases the volumes of waste involved may be sufficiently small that
it is cost effective to dispose of them as hazardous, rather than
incurring the expense of testing for lead toxicity.  This trade-off
should be made by abatement contractors on a case-by-case basis.

In HUD's demonstration project,  an average of 217 ibs of hazardous
waste was generated per housing  unit in the three cities for which
data was available,  with an average disposal cost of $255 per unit.
These  estimates  do  not   include  hazardous-waste-related  costs
incurred directly by the abatement contractor,  such as management
time and TCLP testing costs,   They_.are also low to the extent that
large solid debris and plastic sheeting were not generally treated
as hazardous  by the  contractor.   The  impact  of this  cannot be
quantified at present, because records were not kept on volumes of
solid   debris   and  plastic  sheeting   generated  in   the  HUD
demonstration.   The estimates of hazardous waste disposal costs are
high to the extent that unrealistically large amounts of paint were
stripped in the demonstration.  This is because the demonstration
was designed to  evaluate  a range of potential  abatement methods,
and  not necessarily  to  mirror -real-world abatement  practices.
Because stripping of paint is extremely labor-intensive and costly,
and not often necessary,  it is unlikely to be adopted in practice
on a large scale, except for historical properties.

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 1.0   INTRODUCTION AND METHODS

 1.1   PURPOSE OF THE REPORT

 Under the Lead-Based  Paint  Poisoning  Prevention Act  (LBPPA),  as
 amended by the  Housing and Community Development Act  of  1987,  and
 the Stewart B. McKinney Homeless Assistance Amendment Act of 1988,
 the Department  of Housing  and Urban Development  (HUD)  is mandated
 to require inspection, by 1994,  for lead-based  paint (LBP)  in a
 random sample of dwellings and common areas in pre-1978 public and
 Indian family housing.  Under the statute,  paint with lead  levels
 exceeding  1.0 mg/cm2 constitutes a hazard requiring abatement.   In
 addition,  HUD was  required to submit to  Congress a "comprehensive
 and workable plan" for addressing the LBP hazard in  privately-owned
 housing (Comprehensive and Workable Plan  for the Abatement of Lead-
 Based Paint in  Privately Owned Housing:  A Report to Congressf  HUD
 (December  7,  1990).
The large scope of the LBP problem, combined with increasing public
health concern about the effects of even low-level lead exposure to
young  children,  indicates the  potential for a major nationwide
abatement  effort  in  the next  10 years.   Many  LBP  abatements,
especially  those  involving  removal  and  replacement of  doors,
windows  and trim  painted' with  LBP,  produce  large  quantities of
solid waste containing  lead in varying concentrations.   Congress
is concerned that the  potential applicability of hazardous waste
requirements under the  Resource  Conservation  and Recovery Act of
1976 (RCRA) to LBP  abatement waste may substantially increase the
cost of  abatement,  and  has requested  a report from EPA "assuring
that hazardous  waste requirements will not be  applied to debris
from lead-based paint abatement projects".

The purpose of the present report is -to describe  research conducted
by EPA to:

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     (1) determine which "typical" forms of lead-based paint debris
         would require classification as RCRA hazardous waste; and,
     (2) provide  guidance  for  persons  conducting  lead  paint
         abatements as to which types of waste may be disposed of
         as normal construction debris,  and which must be presumed
         to be hazardous waste unless specifically tested and found
         not to meet RCRA criteria.

1.2  RCRA BACKGROUND
RCRA is  the basic Federal  law  governing waste disposal.   A key
distinction under RCRA  is  that  between solid waste and hazardous
waste.   Solid waste is regulated by the States under RCRA, subject
to minimum  Federal standards.   By  contrast, RCRA  establishes a
"cradle-to-grave" system for the management of hazardous waste from
generation  to  ultimate disposal.    Packaging  requirements  for
hazardous waste under RCRA are described in 40CFR, Parts 173, 178,
179,  and 262 Subpart(c) .,

Under  RCRA,  a  waste  may  be hazardous  either  because of  its
characteristics or because it  is specifically listed as hazardous.
Listed hazardous wastes are unlikely to be generated in lead-based
paint  abatements.     The   four,  hazardous  characteristics  are
ignitability, corrosivity,  reactivity, and  toxicity.   Of these>
cprrosivity  and  toxicity  are  of  most  concern  in  lead  paint
abatements.   Chemicals  used  for paint stripping  are  typically
corrosive.   With  regard to toxicity,   lead is the constituent of
concern  in the  waste.   A waste  is   defined as  exhibiting  the
toxicity characteristic for lead if a standard testing procedure
results in the extraction of lead from the waste  at a concentration
equalling or exceeding 5 milligrams per liter (parts per million).
This level is 100 times  the National  Interim Primary Drinking Water
Standard for lead.

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 Prior to March  1990,  the Extraction Procedure Toxicitv Test  f EP-
 TOX) was  used to determine  whether a waste  was hazardous under
 RCRA.  This  testing procedure was designed to mimic the leaching
 action in a landfill.  The March 1990 revision of the RCRA toxicity
 characteristic   (TC)  replaced the  EP-TOX  with  the  Toxicity
 Characteristic Leaching Procedure  fTCLP) .   The TC became effective
 on September 25,  1990.   However,  small-quantity waste generators
 could continue to use the EP-TOX  until March 1991..   The  TCLP is
 considered to be  a more reliable and reproducible test than the EP-
 TOX.
 Under RCRA,  generators of waste are allowed to rely on the results
 of prior  testing or  experience,  or  knowledge of  the waste  or
 process  generating  the  waste,  in  evaluating  their  waste  to
 determine if it is hazardous.  Thus, the research reported here is
 a first step towards a determination  whether the wastes generated
 in  lead-based  paint   abatement  projects  fall  under  the  RCRA
 definition of hazardous waste.
 1.3   STUDY DESIGN AND RESULTS

 The waste  samples evaluated in this study, and some of the testing
 results, were provided to EPA by HUD from its Demonstration Project
 ("the Demo") on  lead-based paint abatement methods.   The  HUD  Demo
 involved the application of  a wide range of abatement methods to
 vacant  Federal .Housing Administration  (FHA)  housing in  5 cities
 nationwide (Washington,  D.C./Baltimore;  Indianapolis;   Denver;
 Birmingham AL; and, Seattle/Tacoma).  The purpose of  the  Demo was
 to gather  reliable data  on the cost and applicability of  existing
 abatement  techniques  to  public  and private housing.  As  required
 under  RCRA, the  contractor  for  the  Demo,  Dewberry & Davis,
 evaluated waste from the abatements for  lead  toxicity. Results of
 EP-TOX testing conducted in the Demo  were made available to  EPA,
 and  used  ..as  the 'basis for  an  initial  evaluation  of  the
hazardousness of abatement waste.

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The  generally non-hazardous categories  of  waste were:   filtered
wash-water;  disposable work clothes  and respirator filters;  and
rugs  and  carpets.    The  categories  that  were  mixed,  with  both
hazardous  and non-hazardous  samples, were:   paint  chips;  HEPA
vacuum debris, dust from air filters, and paint dust;   sludge from
stripping;  unfiltered liquid waste;  and rags, sponges, mops, HEPA
filters, air  monitoring cartridges, scrapers,  and other materials
used  for testing,  abatement, and clean-up.   The volume of  these
wastes  is expected  to be  relatively small.    A  cost effective
approach may  be to treat all wastes-in the mixed  hazard categories
as subject to RCRA  requirements;  a discussion  of  the trade-off
involved  is  presented in Section  2,     Finally, two  categories,
solid components such as doors and window  frames,  and,  plastic
sheeting used to  protect floors and contain dust during  abatements,
had insufficient testing data from the Demo.

The second stage of the research was a carefully designed testing
program to evaluate solids and plastic sheeting.  These categories
of  waste  are the  highest volume  categories  produced  during
abatement, with the exception of filtered wash-water.   Because of
the change from EP-TOX to TCLP,  EPA decided to test the solids and
plastic sheeting using the TCLP only.

A total of 30 solids  and  30 plastic  samples were selected by EPA
from preliminary lists of available waste from HUD Demo sites.  A
quota of solids samples was specif ied in each of 4 classes based on
available measurements of paint lead levels taken in the field by
Dewberry & Davis.  In this  way,  a  representation of the range of
paint lead levels  encountered  in  practice  was  obtained.    The
plastic sheeting samples were selected to represent both the range
of abatement methods used, and the range of lead levels encountered
in the rooms  from which the  samples were taken.   In practice, it
was not  possible  to obtain all the samples requested by  EPA, due to
the constraints of the Demo schedule.   The final  sample consisted

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 of  20  solids  and 32  plastic  samples,  including substitutions made
 by HUD.  It was not possible  to randomly assign samples to dwelling
 units.  For example, all plastic samples for the  "Heat Gun" method
 of  abatement came  from a single  dwelling.  The confounding of
 dwelling  unit with abatement method  adds  an unknown bias to the
 study.  Nevertheless,  EPA evaluated the final set of  samples and
 concluded that  the design objectives had been adequately met for
 the study to  proceec..

 Six out of twenty solid samples  (30%) , and twelve out of thirty two
 plastic samples  had  TCLP test results exceeding the RCRA standard
 of  5 mg/1 for lead.   The data indicated that wood debris samples
 are expected  to  exceed the 5 mg/1 level on the TCLP whenever the
 lead level in the paint on the surface exceeds 4 mg/cm2,  as measured
 by  a  laboratory  test.   Paint  lead measurements using  an X-Ray
 Fluorescence  detector  (XRF), the usual  method of field  screening
 for lead,  were not found to reliably predict the TCLP result.  For
 plastic samples, the data indicated that plastic sheeting used in
 abatements conducted by the "Heat Gun" method of  paint removal
 generally  fail, the TCLP test.   Some samples from the  "Enclosure"
 (covering  LBP-coritaminated  surfaces  with  wood  paneling,  gypsum
 board, or fabricated exterior enclosure  systems of aluminum, vinyl
 or wood) and "Encapsulation"  (use of flexible wall covering systems
 of  a  reinforced  fiber type that  form a  secure  bond  with  the
 substrate) methods produced  TCLP results slightly in excess of 5
mg/1,  but  never above 5.4 mg/1.  These marginally hazardous results
do not suffice to definitively determine the hazardous waste status
 of  plastic sheeting from  the  "Enclosure"  and  "Encapsulation"
abatement methods; considerably more data would be required to do
 so.    Finally,  no plastic  sheeting  samples  from the  "Chemical
Removal",  "Remove/Replace", or "Abrasive Removal" abatement methods
triggered the TCLP test.

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The third stage of the research was a brief evaluation of volumes
and disposal costs of hazardous  wastes  in the HUD Demo. In the 3
cities  for  which data  is  available  (Birmingham,  Denver,  and
Seattle/Tacoma),  an  average  of  217 Ibs  of hazardous  waste was
generated per housing unit, with an average disposal cost of $255
per unit.   These per-unit estimates  are low to  the extent that
large solid debris and plastic sheeting were not generally treated
as hazardous by the contractor.  They were disposed of in a solid-
waste landfill and  hence no hazardous waste  disposal  costs were
incurred. The per-unit hazardous waste disposal cost estimates are
high to the  extent that far more stripping of paint was carried out
in the Demo  than would likely occur in practice (stripping of paint
is extremely labor-intensive, costly,  and not often necessary).

1.4  REPORT ORGANIZATION
Section 2.0 of  the report presents a detailed  discussion of the
analysis  of EP-TOX  results  from the  HUD  Demo.    Section  3.0
describes the  follow-on testing  program  for solids and plastic
sheeting designed  and  conducted  by EPA.  Section  4.0  presents a
brief discussion of waste volumes and disposal costs encountered in
the Demo.  Section 5.0 presents the conclusions of the study.

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 2.0  TOXICITY TESTING  DATA  FROM THE HUD DEMO

 As part  of  the  HUD  Demo,  80 abatement waste samples  from 5  cities
 were analyzed  for lead by  EP-TOX.  Appendix  A presents  the  test
 data,  sorted by waste  category  and  lead concentration in  the
 extract.  For each  sample,  the following data  is given:

     1.  Numerical  sample identifier  (SAMPLE ID)
     2.  Sample description
     3.  Lead concentration in EP-TOX extract  (ppm)  (LEAD)
     4.  Waste  category  (CAT)
     5.  City identifier  (CITY)
     6.  Location (address)  identifier (LOG).

 The waste  categories  are based  on the nine waste categories in
 Chapter  11  of  "Lead-Based  Paint;  Interim Guidelines  for Hazard
 Identification  and  Abatement in  Public and Indian Housing"  ("the
 Guidelines"), published by HUD in the Federal Register on April 18,
 1990.  For this  report, the waste category "rugs and carpets"  has
 been added, and the Chapter  11 category "liquid  waste" has  been
 divided  into "filtered wash-water" and "unfiltered liquid waste."
 Thus,  there are eleven waste categories  in  this report.    The
 purpose of waste categorization is  to  facilitate the evaluation of
 waste  as hazardous/non-hazardous,   and to reduce  the  amount of
 testing  which  needs to  be  performed.   RCRA  regulations do  not
 require testing of waste when prior experience  or knowledge of  the
 generator or disposal firm is  sufficient to  make a determination of
 hazardousness.     The  use of appropriate waste categories makes
 prior testing experience much easier to apply.

 Each of  the eleven  waste categories may be classified  in one of
 three ways based on  the EP-TOX lead testing  data from the HUD Demo.
The following waste categories were  found to be  generally non-
hazardous;
                                10

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      a.  Filtered wash-water.
      b.  Disposable work clothes and respirator filters.
      c.  Rugs and carpets.

 Therefore,  abatement  contractors may dispose  of waste  in  these
 categories  according to State and  local  solid  waste regulations.
 However,  contractors should be sure to check with local authorities
 before flushing filtered wash-water down storm  sewers.

 The following categories were found to be  hazardous in at least SQ%
 of  tested cases;
      a.
      b.

      c.
      d.
Paint chips.
High Efficiency  Particle Air (HEPA)  vacuum debris, dust
from air filters, paint dust.
Sludge from stripping.
Unfiltered liquid waste  such as wash water from general
cleanup or from  decontaminating surfaces after solvents
have been  used;  unfiltered  liquid waste  from exterior
blasting.
Rags,  sponges,  mops,   HEPA  filters,   air  monitoring
cartridges,  scrapers,  and  other  materials  used  for
testing, abatement and cleanup.
Abatement-specific  conditions  such as,  for example, the level of
lead  in the paint  or the matrix  holding the  lead,  will affect
whether  or not  waste  in these  categories must  be  treated as
hazardous waste under RCRA regulations.  The abatement contractor,
or disposal firm, may choose to test the specific waste from their
project to determine whether it is hazardous.  However, the above
categories  will  generally  contain  relatively  small  volumes of
waste,  so  that a more  cost-effective  solution may be  to simply
treat  all   the waste  in  these categories  as subject  to  RCRA
hazardous waste requirements.
                                11

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 The trade-off between  TCLP testing and  simply disposing of  the
 waste as hazardous without testing depends on the cost of testing,
 the cost of disposal,  and the likelihood  that the waste will fail
 the TCLP  test.    As  an example,  EPA's  Office  of  Solid  Waste
 estimates  the cost of a  TCLP test  as  $175.   The  average  cost of
 hazardous  waste disposal in  the HUD Demo was $1.18  per  Ib,  see
 Section 4  of this report.  Finally,  the probability that the  above
 wastes will fail the TCLP is approximately 50%.  Thus, if W is the
 number of  Ibs of waste expected in a  particular category,   TCLP
 testing will save money  provided 175  +  (0.5)*(1.18)*W <  1.18*W,
 i.e.,  provided W >297.   Thus,  for the hazardous waste  disposal
 costs  experienced in the Demo, the break-even point for testing is
 approximately  300 Ibs  of waste in a single category  (e.g.,  paint
 chips).   The  break-even  point depends on the cost of hazardous
 waste disposal.  Independent estimates developed by EPA's Office of
 Solid  Waste (OSW)  show  a range of  disposal  costs from $0.18  to
 $1.03  per  pound for off-site  immobilization of the waste  followed
 by  disposal (the most likely  disposal method  for waste  from  lead-
 paint abatements).  These estimates translate to a break-even  point
 for testing of between  340 pounds  and 1940  pounds of hazardous
 waste.   OSW's  disposal cost  estimates  are lower than the actual
 costs experienced by HUD in the Demo.  The differences between  the
 costs are discussed in Section 4.

 The category "solvents and caustics" was not tested.  However,  the
wastes  in  this category are likely to  be hazardous by virtue of
 corrosiveness.  Quantities of waste in this category are expected
to be relatively small,  and again a  cost effective  solution may be
to  treat these wastes  as hazardous.   The  abatement contractor
 should evaluate this trade-off on a case-by-case basis, using the
methodology outlined above.

The following categories had insufficient testing information  from
the HUD Demo:
                                12

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     a.
     b.
"Solids", i.e.,  old woodwork, plaster, windows, doors, and
similar bulky components removed from the building.
Plastic sheets  and  tape used to cover  floors  and other
surfaces during LBP removal.
Aside  from  filtered wash-water,  these  categories  contain the
largest-volume wastes expected to be encountered in LBP abatements.
In  practice,  the abatement  strategy of  choice for  lead-painted
windows,  doors,  and  wooden  trim  will  often  be  removal and
replacement with  new components, particularly  when abatement is
carried  out  as part  of a larger jrenovation project.   Only for
houses of historic  value is the removal  of  the paint from  these
components by stripping likely to be adopted as an abatement method
on  a  large  scale.  Whatever method of abatement is used,   large
volumes  of  plastic  sheeting will  be  used  to  contain  dust and
debris.

Because of the importance of these waste categories, EPA designed
and carried out a  testing program, described in the next section of
the report.   Since  the TCLP  replaced the  EP-TOX test  for all
generators in March 1991,  only TCLP testing was conducted on these
additional solid and plastic samples.
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 3.0  TCLP TESTING PROGRAM FOR SOLIDS AND PLASTIC SHEETING
 3.1  TCLP TESTING OF SOLIDS
 The original design for TCLP testing of solids called for testing
 a total of, 30 samples, drawn from  specified ranges of  XRF  lead
 levels,  as  shown in Table  I.   The  goal of  this  design was  to
 conduct  TCLP testing on samples with a wide range of XRF levels,  in
 order to facilitate the determination of the XRF level which may
 trigger  a positive TCLP.   Unfortunately,  EPA was able to obtain
 from the HUD Demo only 20 samples from a total of 10 dwellings,  as
 described  in detail in Appendix Bv  The inability to select samples
 randomly from dwellings adds an unknown bias to the  evaluation.
 The selected samples are summarized by XRF level in Table  I.   Even
 though only two thirds of the requested samples were obtained, EPA
 decided  to proceed with the  TCLP testing for  two reasons.  First,
 there was  an urgent need for information, even if  incomplete,  on
 the applicability of RCRA  requirements to solids.   Second,  the
 available  samples were concentrated  in  the higher  ranges of XRF
 lead levels which are most likely to  trigger  a positive TCLP.

            TABLE  I;  DESIGN  FOR TCLP  TESTING  OF SOLIDS
XRF Level (mg/cm2)
1-2
2-4
4-8
>8
N/A
Number of Samples
(Original Design)
5
10
10
5
0
Number of Samples
Available
0
5
8
5
2
Appendix B presents the following information for each sample:
     a.  Numerical sample identifier
                                14

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      b.   Unit- address
      c.   Substrate from which the sample was taken
      d.   Location of the sample within the unit
      e.   XRF lead  measurement on  the substrate  from which  the
          sample was taken (where available).

 In 2  cases,  no  XRF measurement was  availab.le.   Thus,  18 of the 20
 samples  have an  XRF lead measurement.   In  addition to the  TCLP
 test,  chemical  analysis of a sample of paint from  each solid was
 conducted to determine the concentration of lead in the paint,  both
 by weight and on an area basis.

 3.2  RESULTS OF TCLP TESTING  OF SOLIDS

 Table II  shows  the.TCLP testing results  for  the 20  solids  samples
 tested, sorted in decreasing order of the lead concentration in the
 TCLP  extract.   The  data is taken,from  the  report "Hazardous Waste
 Support;  Report for Work Assignment No.  21.  Lead Abatement Waste
 Analysis", prepared for  EPA's  Office  of  Solid Waste by  Science
 Applications International  Corporation (SAIC)  under EPA Contract
 No. 68-W9-0011  (July 31, 1990).   The first column of the table
 shows  the sample identifier from Appendix B.  The second  column,
 labelled  "LAB LEAD  (mg/cm2)",  shows the area  concentration  of lead
 in  the paint on the sample,   in  units of milligrams  per square
 centimeter, as measured in the laboratory.  The area of the  painted
 surface was first measured  and then the concentration of  lead on
 the sample was measured using AAS.  For one sample, ID  # 105, the
 areji  concentration  is  reported  as  a  range.    The   analytical
 laboratory experienced difficulty determining the area of paint on
 this  sample, due to extreme weathering of the  sample.   The third
 column, labelled "LAB LEAD (mg/kg)»,  shows  the  concentration of
 lead  in the paint by weight,  as measured in  the laboratory.   The
units of this measurement are  milligrams per kilogram, i.e., parts
per million.  The fourth column of  the table,  labelled "XRF LEAD
                                15

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(mg/cm2)11,  shows the area concentration  of  lead in the paint, as
measured in the field by an X-Ray Fluorescence instrument.   For two
samples, ID #'s 102 and  104,  no XRF  measurement was available.
Finally, the last column  presents the  result of the TCLP test on
the sample, as  the  concentration of lead in the TCLP extract, in
units of milligrams per  liter  (parts  per million) .   Two of the
results, for sample  ID  #«s  102  and  108,  were below the detection
limit of the procedure.
        TABLE II;  TCLP  TESTING  RESULTS FOR  SOLIDS SAMPLES
SAMPLE ID
105
101
112
120
119
107
109
113
111
110
114
118
104
106
116
115
103
117
108
102
LAB LEAD
(mg/cm2)
3.4 - 5.1
9.3
5.3
19.4
19.4
3.9
6.2
0.86
0.72
0.028
2.8
3.9
0.38
3.4
2.9
0.54
2.2
1.1
0.016
0.12
LAB LEAD
(mg/kg)
94800
103000
50400
171000
174000
24300
96500
32700
5360
580
40400""""""
43800
21700
98200
27400
6240
20400
15300
670
2430
XRF LEAD
(mg/cm2)
5.9
6.1
9.7
9.4
9.4
2.8
8
6.8
5.3
8.2
4.6
4.8
N/A
8.7
4.8
3.1
3.7
3.1
3.1
N/A
TCLP LEAD
(mg/1)
21
13
12
10
9.5
5.4
4.8
4.5
4.1
3.4'
2.5
2.3
2.1
1.2
1.0
0.9
0.8
0.4
<0.3
<0.3
                               16

-------
 Six of the twenty samples analyzed (30%) exceeded the RCRA toxicity
 characteristic limit of 5 rag/1 lead in the TCLP extract.  It is
 clear from the table that the higher  TCLP results are associated
 with higher  area  concentrations  of  lead,  as measured  in  the
 laboratory.   Figure I is a plot of area lead concentration versus
 TCLP result.   For plotting purposes,  the  area  lead concentration
 for sample # 105 has been treated  as  the  average  of  the reported
 range, and the TCLP results below the  detection limit of 0.3 mg/1
 have been  set to 0.3 mg/1.  The plot confirms the impression given
 by the table.  Of the 6 samples with paint AAS lead level exceeding
 4.0 mg/cm2, 5 (83%)  failed the TCLP.  Conversely, only 1 of 14 (6%)
 with AAS level below 4.0 mg/cm2 failed TCLP.  The data suggests the
 following rule Of thumb:  TREAT AS HAZARDOUS WASTE ALL SOLID DEBRIS
 WITH AREA  LEAD CONCENTRATION.  AS  MEASURED IN  THE  IABORATORY.
 EXCEEDING 4.Q mg/cm2.  However,  this rule  is based  on  limited data
 of doubtful  representativeness.   It  requires  confirmation in  a
 larger study before  being used  as  a  basis  for  EPA policy  with
 respect to debris from lead paint abatements.

 For  field  testing purposes, it  would be  very  convenient if  XRF
 measurements   of   lead  concentration,  rather  than   laboratory
 measurements,  could be  used as  a  predictor of  hazardous waste
 status.    This is  because  extensive  XRF testing  is  routinely
 conducted  prior to abatement.    Unfortunately,  the data reported
 here  does not indicate  a  sufficiently  strong  relationship between
 XRF and laboratory lead measurements for practical  use.   Figure II
 is  a plot  of TCLP result versus  XRF lead  measurement for the 18
 samples for which an XRF measurement was available.  Clearly,  the
 relationship  between the two variables is weak.  For example,  XRF
measurements  as  high as 8.7 mg/cm2 are associated with low TCLP
results.   Conversely, one XRF measurement of 2.8 mg/cm2 has a TCLP
result of 5.4 mg/1.  There are two possible causes for the weaker
relationship  observed  between XRF measurements  and the TCLP than
between  laboratory  measurements  and  the  TCLP.     First,  XRF
                                17

-------
TC
25-

20-
15-

10-
5-
o •
XP Cma/D

1

.
I
I
I
1
i
II •








I I III
0 5 10 15 20
AREA LEAD CONCENTRATION Cn>9/cm23
Figure I.  Plot of TCLP Result for Solids Samples Against Paint
Lead Concentration on an Area Basis,  as Determined by Laboratory
Analysis .
                              18

-------
    TCLP Cmg/ID
  25 -
   20 •
   15
   10
~l
 A


 XRF LEAD
                                      T
                                      6
~T
 10
Figure II.  Plot of TCLP Result  for Solids Samples Against Paint
Lead  Concentration  on  an  Area  Basis,   as  Determined by  XRF
Analyzer
                               19

-------
 measurements are known to  be much less accurate  than  laboratory
 measurements of  lead  in  paint.    Second,  the  XRF measurement
 reported for a sample was  not necessarily taken  on  the  specific
 piece of  debris  analyzed  by the TCLP.   For  example,  the  TCLP
 analysis for debris  from a door might have  been conducted  on  a
 piece of the door some distance from where the XRF measurement was
 taken.   Variations in paint thickness therefore contribute further
 to inaccuracies in x.he XRF  measurement  for our  purposes.

 3.3   TCLP  TESTING OF  PLASTIC  SHEETING

 A  large choice of potential  samples of 6-mil plastic floor  covering
 from  units in the HUD Demo was made available  to EPA.  From these,
 EPA specified  30 sampling locations from each of  which 10  square
 feet  of plastic, weighing approximately  100  grams,  were to be
 taken.   Of the specified  samples, 20 were  actually available.  An
 additional  12  were provided  by  HUD as substitutes.   Appendix  C
 presents a  summary of the plastic samples.  For each sample,  the
 following information is  given:
     a.
     b,
     c,
     d.
     e.

     f.
     g.
Numerical sample ID  (ID)
Address of the unit
Selection  code  (SEL);  ORG  =  original  sample actually
obtained;  SUB  =  HUD  substitution;   N/A  =  originally
requested sample which was unavailable
Room from which sample was taken  (ROOM)
Average lead level of tested  surfaces in the room (mg/cm2)
(MEAN)
Number of surfaces tested in the room  (N)
Abatement method.
The specification of the  30  sampling  locations was guided by two
considerations.  First, EPA wanted to obtain samples from each of
the  abatement methods  used  in the  Demo,  but especially  from
                                20

-------
 chemical removal and heat  gun methods,  because it was  felt that
 these were the methods  most likely to contaminate the plastic and
 trigger a positive TCLP result.  Second,  EPA wanted to take samples
 from rooms with higher levels of lead.  The average XRF measurement
 taken in the room was used as a proxy for the amount of lead in the
 room.  Rooms with  the highest average level within each abatement
 method were specified for sampling.
 i
 The  32   samples  actually  obtained  represent  an   acceptable
 approximation  to  the  design  criteria  stated  above.    Of  the
 abatement  methods,   only  removal  and  replacement   is   poorly
 represented.   There  is  adequate representation of  the  higher room
 lead levels, even though the substitutes generally come from rooms
 with less lead.  However, the abatement  method used is confounded
 with the dwelling, in the sense that the samples for most  methods
 come from only one or two  dwellings.  For  example,  all heat  gun
 samples come from the same  dwelling.  This confounding introduces
 an  unknown but unavoidable  bias into the study results.
                                          *
 3.4   ANALYSIS OF TCLP TESTING RESULTS FROM PLASTIC SAMPLES

 Table III shows the results  of the TCLP testing  of  the  plastic
 samples,  again taken from the SAIC report previously  referenced.
 The  variables   reported are  as  follows.    "ID"  is   the  sample
 identifier given in Appendix  C.  "TCLP"  is the result  of the TCLP
 test  procedure,  in milligrams of lead per liter  in the extract.
 "ROOM LEAD" is  the  arithmetic mean of all XRF lead measurements in
 the room from which the plastic sample was taken, in milligrams per
 square  centimeter.    "PRIMARY  METHOD"  is  the primary method of
 abatement applied to  surfaces in the  room, as reported  by Dewberry
 & Davis,  the contractor for the HUD  Demo.   "SECONDARY METHOD" is
the secondary method of abatement applied,  whenever more than one
method was used in the room.  The determination of primary versus
secondary method was  based on the number of surfaces abated  by each
method.
                                21

-------
TABLE III;  TCLP TESTING RESULTS FOR PLASTIC SAMPLES
ID
i
2
3
4
5
$
7
8
1 9
10
11
12
13
14
' 15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
TCLP
fmcr/1)
< 0.3
0.47
5.4
1.2
<0.3
0.41
<0.3
0.67
<0.3
8.4
15
17
28
12
46
40
5.9
3.1
60
0.78
0.44
2,1
0,98
0.67
0.69
8.3
0.41
< 0.3
< 0.3
< 0.3
5.4
0.5
ROOM LEAD
(ma /cm2)
2.6
3.2
5.6
9.4
3.4
8.6
5.4
9.4
9.6
2.6
6.9
7.4
8.7
8.8
8.9
9.3
0.4
1.1
8.3
1.3
1.4
1.5
1.6
1.8
2.8
1.3
2.2
7
2.8
3.6
6.6
2.2
PRIMARY
ABATEMENT METHOD
Encapsulation
Encapsulation
Encapsulation
Encapsulation
Encapsulation
Encapsulation
Abrasive Removal
Abrasive Removal
Abrasive Removal
Heat Gun
Heat Gun
Heat Gun
Heat Gun
Heat Gun
Heat Gun
Heat Gun
Enclosure
Heat Gun
Heat Gun
Chemical Removal
Chemical Removal
Chemical Removal
Chemical Removal
Chemical Removal
Chemical Removal
Enclosure
Enclosure
Enclosure
Enclosure
Enclosure
Encapsulation
Encapsulation
SECONDARY METHOD




Enclosure
Enclosure











Chemical Removal
Enclosure






Heat Gun

Encapsulation
Remove / Rep lace
Remove /Replace


                        22

-------
  Twelve of the thirty  two  samples tested (38%) exceeded the  TCLP
  toxicity characteristic  limit of  5 mg/1 for lead.  Of these,  8 had
  "Heat  Gun"  as  primary  method of abatement,  2  had "Enclosure",  and
  2 had  "Encapsulation".   The 8 "Heat  Gun"  samples were the  highest
  values reported.  The  higher of the  two  "Enclosure"  samples,  with
  TCLP  level of  8.3  mg/1, had "Heat  Gun" as  secondary method of
  abatement.  The 8 "Heat Gun" samples  'and  the 2 "Enclosure"  samples
  all came from the same  housing unit, whereas the 2 "Encapsulation"
  samples  were  from distinct units  different from the unit  for  the
  other  10.   The TCLP result  for each of  these, 5.4 mg/1, was  the
  smallest of those exceeding 5 mg/1.  The tentative conclusion to be
  drawn  from the data appears  to be that plastic sheeting should be
  treated  as hazardous  waste whenever the  "Heat Gun"  method of
  abatement is used,  and that there is a  potential for triggering
 RCRA   hazardous   waste   requirements   when   "Enclosure"   or
  "Encapsulation"  are used.    Contrary  to  prior  expectation,  the
  "Chemical Removal"  abatement method resulted  in very  low  TCLP
 results for the plastic sheeting.

 Further  analyses were  conducted to explore  the  quantitative
 relationship between the level  of  lead in the  room, the abatement
 method  used,  and the  result of  the  TCLP  test  on the  plastic
 sheeting.  Figure III shows  a plot of TCLP  result in mg/1  versus
 "ROOM LEAD" in mg/cm2.  TCLP results  below the detection limit of
 0.3 mg/1 have been set to 0.3 mg/1. The plot is coded according to
 the primary method of abatement:  1  = Abrasive removal; 2 = Chemical
 Removal; 3 = Encapsulation;  4 = Heat Gun;  5 = Enclosure.  The  plot
 indicates that  the "ROOM  LEAD" is  a poor  predictor of TCLP  level.
 Accordingly,  a  more refined measure  of  lead  in the room  was
"developed from  so-called  "Part C» data sheets supplied by Dewberry
 & Davis.  The Part C  sheets provide, for each component abated,  the
 XRF lead  level in the paint  (or a laboratory measurement if XRF was
 not used), and a measure of  the total quantity of paint present,  in
 either  square  feet or lineal feet.   The  Part  C data was used  to
                                23

-------
T(
60

str



40"
30"

20"



10"


0"
:LP Cmo/ O
4
1 = Abrasive Removal
2 = Chem i ca I Remova I
3 = Encapsulation
4 = Heat Gun 4
5 = Enc I osure
4

4

4
4
4
....
5.4
5 3 3
4
2 3 2
3222 5 35 335 1 5 3 ^1
I > II I |
3 2 4 6 8 10

















MEAN XRF LEAD IN ROOM Cmg/cm2D
Figure III.   Plot of  TCLP Result for  Plastic Samples Against
Average Area Lead Concentration of Abated Surfaces in the Room as
Determined by XRF Analyzer (Coded by Primary Abatement Method)
                              24

-------
  develop  an  estimate  of  the  total  mass  of lead abated in each room
  by  each  abatement method.   The  calculations  are described below.

  The first step was to convert lineal feet to estimated square feet.
  Table  IV shows the conversion  factors  for lineal feet to  square
  feet developed in discussions with Dewberry & Davis,   it should be
  emphasized that these conversion factors are approximate.  The next
  step was to develop  an estimate of total mass of  lead on  each
  abated component.  The  formula used was:

     LEAD (kg) =  [AREA (sq. ft. )] *[XRF LEAD  (mg/ cm2) ] *0. 000929.

 In  calculating  component areas,  it was assumed that doors were
 painted on both sides, that  shelves were painted on one side only
 and that 20% of  the  total area of a window  was painted surface!
 The estimated  mass of  lead was  then  totalled  in  each  room by
 abatement method used.    Table  V  shows  the  results  of  these
 calculations.   The columns show the total mass of lead abated in
                         FACTORS FOR LI
                                  CONVERSION FACTOR
  Baseboards
                                  1.0 (Baltimore)
                                  0;33 felsewherel
  Window Sills
  Window Trim
  Stringers
the room by  each  abatement  method.   The last column of the table
gives the  total mass of  lead  abated in the room  by all methods
used.  Figure IV shows a plot of TCLP result versus total mass of
lead abated for the heat gun abatement method.  The plot indicates
a strong linear relationship  (R* = 0.78) between TCLP result and
                               25

-------
    TCLP
  60
  50
  40
  30
  10
     I

     0
        r

        -i

TOTAL ROOM LEAD
Figure IV.   Plot of TCLP Result  for Plastic Samples,  for  "Heat
Gun" Abatement Method,  Against Total Mass of Lead Abated in the
Room, as Determined from XRF Measurements and Surface Dimensions
                               26

-------
 total lead abated.  Figure V is similar to Figure IV,  but  includes
 only those samples where  "Heat Gun" was not the  primary method of
 abatement.   As noted before,  abatement methods  3  (encapsulation)
 and 5 (enclosure) produce higher TCLP levels than methods  1 and 2,
 but there  appears to be  only a weak  relationship to total lead
 abated, in contrast to method 4  (heat  gun).

 To further explore the relationship between mass of lead abated and
 TCLP result,  several  regression analyses were run.  The results are
 presented in Appendix D.   Two  of  the regression models  fitted have
 promise as  tools for predicting the  hazardous waste status  of
 plastic sheeting used in abatements.  However, much further testing
 and refinement would  be needed before practical application of any
of the regression models.
                               27

-------
T
10"
8"

6"

4 "
2"

0"
CLP Cn^/ O

1 = Abras I ve Remova I
5
2 = Chem i ca I Remova I
3 = Encapsulation
5 = Enc I osure
5
3 3
•
2
3
212
2^ 3 3 3
3g 1 5 5 3
I I I I I I
0 1 23 4 5









TOTAL ROOM LEAD C^QD
Figure V.  Plot of TCLP Result for Plastic Samples Against Total
Mass of Lead Abated in the Room,  Determined from XRF Measurements
and Surface Dimensions, for  Samples  for which Heat Gun was not
the Primary Abatement Method (Coded by Primary Abatement Method)
                              28

-------
V;	MASS OF LEAD ABATED (Ka\ . BY
                   29

-------
 4.0  WASTE DISPOSAL EXPERIENCE FROM THE HUD DEMO
 In Birmingham, Denver, and Seattle/Tacoma, the HUD contractor was
 required to conduct the EP-TOX test on abatement waste, and treat
 as hazardous  any  waste failing the test.   Requirements in other
 states may vary since  the RCRA program is delegated to States to
 administer.   Accordingly,  individual states  may  interpret  the
 regulations somewhat  differently in  certain situations or  have
 their own state regulations regarding specific  wastes.   Further,
 municipal regulations  may impose additional requirements.   The
 contractor reports the following summary experience of volumes of
 hazardous waste generated and  associated  disposal  costs fThe  HUD
 Legd-Based	Paint  Abatement  Demonstration  (FHA) ,  HUD,  Office  of
 Policy Development and Research (August 1991)):

 TABLE VI;  VOLUME OF HAZARDOUS  WASTE  AND DISPOSAL COSTS FOR  THREE
                               CITIES IN THE HUD  DEMO
CITY/(# UNITS)
Birmingham (23)
Denver (57)
Sea/Tac (16)
3 CITIES (96)
QUANTITY OF HAZ
WASTE (Ibs)
TOTAL
11,900
7,350
1,550
20,800
PER UNIT
517
129
97
217
COST OF DISPOSAL
TOTAL
$10,221
$9,625
$4,675
$24,521
PER UNIT
$444
$169
$292
$255
PER LB
$0.86
$1.31
$3.02
$1.18
Thus, the per-unit average in the 3 cities was 217 Ibs of hazardous
waste, with an  average  disposal cost of $255 per unit.  Disposal
cost  averaged $1.18 per  Ib.   These costs  include waste stream
analysis by the disposal contractor, pick-up, and disposal but do
not include TCLP testing costs incurred by the abatement contractor
to classify waste, or the cost of abatement contractor management
time  devoted  to the hazardous  waste issue.   More  detailed cost
breakdowns, e.g., transportation costs,  were not available.   The
                                30

-------
 hazardous waste disposal costs experienced in the Demo are higher
 than independent estimates developed by EPA's Office of Solid Waste
 (OSW).  For off-site immobilization followed  by disposal (the most
 likely disposal method for waste from lead-based paint abatements),
 OSW estimates a cost of between $0.18  and $1.03 per pound.  This is
 lower than  the average cost  of $1.18  experienced in the  Demo,
 especially when we note that the Demo waste was  not treated.   The
 likely reason  for the difference  is  the  small  volume of  waste
 disposed of in the Demo. As  Table VI shows, the per-pound disposal
 costs in the Demo were  inversely related to the volume of  waste
 disposed of.

 Caution should be exercised in extrapolating the  experience of the
 Demo to larger abatement programs.   First, it must be remembered
 that solids and plastic sheeting were generally treated as ordinary
 solid  waste in the Demo.  A requirement to treat these items as
 subject to RCRA requirements could substantially  increase the  cost
 of disposal.  However, no estimates are available  to quantify this.
 Second,  the  mix of  abatement strategies  used   in  the Demo is
 unlikely to reflect  future practice.  For example, a considerable
 amount  of  paint stripping  was conducted in the  Demo  to test out
 different  approaches.    in  practice,   however,  paint removal is
 unlikely,  except  in  special  circumstances  such  as  historic
 properties, because it is extremely labor-intensive.  Thus,  future
 abatements will probably generate much less sludge from stripping
and heat gun operations than  did the Demo.  This factor would tend
to reduce hazardous waste disposal costs as compared to the Demo.
                               31

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5.0  CONCLUSIONS

The major conclusions of this study are as follows:

     1.   Waste from lead-based paint abatements in the categories:
          filtered   wash-water,   disposable  work   clothes   and
          respirator  filters,   and  rugs  and  carpets,  is  non-
          hazardous under RCRA,  and may be disposed of  as solid
          waste.
     3.
Waste in the categories:  paint chips; HEPA vacuum debris,
dust  from  air filters,  and paint dust;  sludge  from
stripping;  unfiltered  liquid waste;  and,  rags,  sponges,
mops, HEPA filters, air monitoring cartridges, scrapers,
and  other materials  used for  testing,  abatement,  and
cleanup,  may  be  either  hazardous or   non-hazardous,
depending  on  abatement  conditions.    Waste  in  these
categories may either  be  tested to determine whether it
is hazardous, or  may  be disposed of as hazardous  waste
without testing.   Since relatively small volumes of  waste
are expected in these  categories, disposal as hazardous
waste  may  be  the  cost-effective  solution   for  the
generator,  depending   on  the cost  of hazardous  waste
disposal, the volume of waste involved, the cost of TCLP
testing, and  the  estimated probability  that the  waste
will fail the TCLP test anyway.

Waste  in the  "solids"  category,  i.e.,   old woodwork,
plaster, doors,  and  similar  bulky  components  removed
during abatement,  was  found to be  generally hazardous
when the lead level in the paint exceeded 4 milligrams
per square  centimeter, as  determined  by a  laboratory
analysis.  This suggests that waste with paint at  lower
lead levels may be disposed of as solid waste.  However,
this study examined only a limited number  of solid debris
                     32

-------
  samples  selected in  a non-random fashion.   Thus,  the
  results are suggestive only, and require confirmation in
  a  larger  study before being used  as the basis for  EPA
  policy with respect to waste from lead paint abatements.

  Field X-Ray  Fluorescence  (XRF)  measurements of lead  in
  paint are not sufficiently accurate to permit an accurate
  determination of the hazardous waste  status of "solids".

 Waste in the category of plastic sheeting and tape used
 to cover floors and  other  surfaces during abatement is
 hazardous when the "Heat Gun" method  of paint removal is
 used.  However,  this conclusion  is  based on a  set of
 samples all taken from a single dwelling.  When "Chemical
 Removal",   "Abrasive  Removal",  or  "Remove/Replace"  are
 used,  plastic  sheeting   is   not   hazardous.     When
 "Encapsulation" or "Enclosure" are the abatement methods
 used, plastic  sheeting sometimes slightly exceeds  the
 TCLP limit for lead in waste.

 The total  quantity  of lead abated  in a  room by  each
 abatement method used has potential as a predictor of the
 hazardousness of plastic sheeting waste.   More research
 would be needed to  develop  a predictive model, however.

 In the HUD Demo, the cost of waste stream analysis, pick-
 up,  and disposal  of hazardous  waste was $255 per unit.
 This does not include TCLP  testing costs  incurred by the
 abatement contractor  to classify waste,  or the cost of
 abatement  contractor  management time  devoted to  the
 hazardous  waste issue.   For this reason  and because
 solids and plastic sheeting were not treated as hazardous
waste in the Demo,  hazardous waste disposal costs may be
higher in practice.  Further data is needed to quantify
this.
                      33

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                            APPENDIX A

EP-TOX TESTING DATA FROM THE HUD DEMO.  SORTED BY WASTE CATEGORY AND
                LEAD  CONCENTRATION IN THE EXTRACT
                                34

-------
SAMPLE ID
SAMPLE DESCRIPTION
                                                  LEAD CAT CITY LOG
                                                 (PP»)
89-5010:
89-5024:
89-5023:
89-5019:
89-5017:
89-5005:
89-5004:
KTA - 5:
89-5015:
89-5133:
89-5161:
89-5029:
89-5016:
89-5020:
89-5026:
89-5135:
89-5127:
KTA - 1:
KTA - 3:
90-146:
KTA - 4:
KTA - 2:
90-147:
90-145:
89-5301:
90-157:
89-5163:
90-154:
90-150:
90-153:
89-5160:
89-5168:
89-5030:
89-5167:
89-5006:
89-5003:
89-5169:
89-5165:
89-5008:
89-5012:
89-5166:
89-5011:
89-5136:
89-5129:
89-5132:
89-5159:
Paint from bathroom tile and master
Paint from baseboard trim
Heat gun paint debris
Debris from use of heat gun
Paint debris - "Peel-Away"
Paint debris - "Peel-Away"
Paint debris - heat gun
Paint chips r
Paint from cedar shake
Paint chips
Exterior heat gun chips (paint)
HEPA vac debris
HEPA vac debris
HEPA vac debris
Negative air prefilter impregnated dust
HEPA vacuum contents
HEPA vacuum contents
Drywall with 4 sq.in 1.5 mg/sq.cm paint
Painted wood
Window, attic vent, door frame
KTA#2, plus 4 sq.in 1.5 mg/sq.cm paint
Painted wood
Window frame and trim
Cedar shake, wall 1, 2nd level
Plastic from floor and bags
Chemical treatment sludge
it Peel -Away" sludge w/rag dye, paper
Chemical treatment sludge
Heat gun sludge
Heat gun sludge .......
Vinegar/chem neutralizer Peel-Away wash
Wash used before neutralizer (Peel-Awav)
TSP wash water
TSP and neutralizer wash (Peel-Away)
Liq on poly below chem stripper cleanup
Non-filtered wash/rinse water
5 mic filt rinse water-sanding/Peel-Away
5 mic filtered rinse water - "Peel-Away"
20, 5 micron filtered hand wash water
5 micron filtered hand wash water
5 mic filtered rinse water - heat gun
Non-filtered hand wash water
Filtered (5 micron) waste water
Rinse/wash water supernatant
Rinse/wash water sludge
5 mic filtered rinse water - "Peel-Away"
0
1.3
1.4
2.4
5.6
5.8
9.7
11.4
18
18
52
0
1.3
2.6
7.5
13
22
0.5
0.7
0.72
1.7
2.1
8
140
34
0.64
1
1.22
12
40
620
5.7
45
50
69
77
0
0
0
0
0
0
0
0
0.7
4
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
6
6
6
6
6
6
7
7
7
7
7
8
8
8
8
8
8
8
8
8
8
1
1
1
1
1
1
1
4
1
JL
2
3
i
JL
1
JL
1
JL
1
2
&•
2
4
4
5
4
4
5
1
JL
3
5
4
5
5

3
4
1
4
1
1
3
4
1
JL
1
4
1
2
ft
2
2
3
1
3
2
2
ft
3
1
1
JL
14
1
JL
5
*J
6

3
^
3
fj
3
5
+J
4
14
14
JL*V
9
14
14
JL"V
1O
JL w
1
JL
6
V
13
7
12
10
1 1
JL J. •
6
7
3
«J
7
1
1
8
7
0
£*
3
•J
/
2
£*
4
^
4
6
                               35

-------
SAMPLE ID
SAMPLE DESCRIPTION
LEAD CAT CITY LOC
89-5013:
89-5018:
89-5137:
89-5164:
89-5162:
89-5027:
89-5134:
89-5131:
89-5138:
89-5007:
89-5302:
90-152:
89-5172:
90-155:
90-149:
89-5014:
89-5021:
89-5022:
90-156:
90-148:
90-151:
90-158:
89-5170:
90-159:
89-5009:
89-5128:
89-5130:
89-5171:
89-5300:
89-5032:
89-5031:
89-5025:
89-5033:
89-5028:
89-5139:
5 micron filter used during hand washing
Sand paper from use of HERA sander
5 micron filter with waste
5 mic rinse water filter - "Peel-Away"
5 mic rinse water filter - "Peel-Away"
Negative air filter
HEPA cartridge
HEPA filters from vacuum
Wiping of HEPA vac filter
Paper towels - chem stripper cleanup
Rag - TYVEK suit used to wipe floor
TYVEK suit and rubber gloves - heat gun
PAPR filter - Peel Away
Respirator filter - chemical treatment
TYVEK suit and rubber gloves - heat gun
Respirator filters - heat gun use
Protective suit - chem stripper use
Respirator filters (3 weeks use)
TYVEK suit and rubber gloves-chem treat
Heat gun - respirator filter
Heat gun - respirator filter
Respirator filter - chemical treatment
PAPR filter - mainly sanding
TYVEK suit and gloves
TYVEK suit used during heat gun use
Respirator filters
Composite poly & TYVEK suits
PAPR filter - mainly heat gun use
Rug and pad
Orange foam back and fiber back carpet
Red & black foam back carpet
Red carpet
Corrugated foam pad; fiber back carpet
Green carpet
Blank of wipe "Diaparene"
0
0
0.5
0.7
1.4
4.7
27
95
97
110
220
0
0
0
0
0
0
0
0.53
0.54
0.55
0.68
0.9
0.99
1.2
2.1
3.2
3.9
0
0
0
0
0
1.4
0
9
9
9
9
9
9
9
9
9
9
9
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
11
11
11
11
11
11
12
1
1
2
4
3
1
2
2
2
1
3
5
4
5
5
1
1
1
5
5
5
5
3
5
1
2
2
4
3
1
1
1
1
1
2
3
3
5
7
6
2
5
4
5
1
6
11
7
12
10
1
3
3
12
10
11
13
8
13
1
4
4
7
6
1
1
2
1
2
5
LOCATION CODES

 1 = 4033 Vallejo (Denver)
 2 = 4320 Zuni (Denver)
 3 = 2921 Curtis (Denver)
 4 - 615 Udel (Indianapolis)
 5 = 922 E. 42nd Street  (Indianapolis)
 6 = 905 Drum (Washington, D.C.)
                                 36

-------
  7
  8
  9
 10
 11
 12
 13
 14
      6155 Parkway  (Baltimore)
      5716 Sheridan (Washington,  D.C.)
      3425 38th  Place  (Birmingham)
      1778 Jefferson (Birmingham)
      4104 Main  Street  (Birmingham)
      1415 30th  Street  (Birmingham)
      4340 Greenwood (Birmingham)
      KTA samples - Baltimore, address unknown
CITY CODES

1 = Denver
2 = Indianapolis
3 = Washington, D.C.
4 = Baltimore
5 = Birmingham, Alabama

CATEGORY CODES
    Paint chips
    HEPA vac debris, dust from air filters, paint dust
    Old woodwork, plaster, windows, doors, and similar bulky
    components removed from the building
    Plastic sheets and tape used to cover floors and other surfaces
    during LBP removal
    Solvents and caustics used during stripping
    Sludge from stripping
    Unfiltered liquid waste such as wash-water from general cleanup
    or from decontaminating surfaces after solvents have been used;
    unfiltered liquid waste from exterior blasting
8 = Filtered wash water
9 = Rags, sponges, mops, HEPA filters, air monitoring cartridges,
    scrapers, and other materials used for testing, abatement and
    cleanup
10 = Disposable work clothes and respirator filters
11 = Rugs and carpets
12 = Blanks
4 =

5 =
6 =
7 =
                                37

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                    APPENDIX B




SOLIDS SAMPLES FROM THE  HUD DEMO ANALYZED BY TCLP
                        38

-------
Sample
ID
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
Unit Address
5230 16th
17 Tacoma
3924 E. 30th
3421 N. Gale
2739 Mura
1321 E. 27th
2931 Riggs
1422 E. 34th
•1422 E. 34th
1422 E* 34th
1422 E. 34th
1422 E. 34th
1422 E. 34th
1422 E. 34th
3449 Kinnear
3449 Kinnear
3449 Kinnear
3449 Kinnear
1649 Temple
1649 Temple
Substrate
WTM
BSB
DRF
FENCE
DOOR
WDW
DOOR
DRF
WSL
WDW
DRF
COL
DOR
WTM
DOR (FRONT)
DOR (FRONT)
DOR WLA
DRF WLA
DRF (FRONT)
DRF (REAR)
Location XRF
(rag/cmz)
Garage WL4
BD # 2
EXT (LV RM)
EXT
EXT
BSM
GAME # 2
KIT
EXT
EXT
BAT
EXT
EXT
EXT
EXT
EXT
EXT
EXT
EXT
EXT
6.1
N/A
3.7
N/A
5.9
87
• /
2.8
3.1
ff • JL.
8.0
8.2
5.3
9.7
6.8 •
4C
• u
3.1
4.8
3 1
••* • J_
4.8
9.4
9.4
39

-------
            APPENDIX C




PLASTIC SAMPLES FROM THE HUD DEMO
               40

-------
 ID
ADDRESS
                       SEL  ROOM
                                 MEAN    N
                               (mq/cm2)
                                                         METHOD
 9     4895 Vallejo    ORG
 8     4895 Vallejo    ORG
 7     4895 Vallejo    ORG
 20    1304 Walters    ORG
 2.1    1304 Walters    ORG
 25    1304 Walters    ORG
 24    1304 Walters    ORG
 22    1304 Walters    ORG
 23    1304 Walters    ORG
 5     1665 Macon      ORG
 6     2516 N.  8th     ORG
 4     1308 Wallace    ORG
 3     1308. Wallace    ORG
 29    1422 East 34th  ORG
 30    1422 East 34th  ORG
 16    2931 Riggs      ORG
 11    2931 Riggs      ORG
 14    2931 Riggs      ORG
 15    2931 Riggs      ORG
 13    2931 Riggs      ORG
 2     1308 Wallace    SUB
 32    3745 Eudora     SUB
 1     1665 Macon      SUB
 31    338  Chester     SUB
 26    2931 Riggs      SUB
 27    4895 Vallejo    SUB
 28    3565 Krameria    SUB
 10    2931 Riggs      SUB
 12    2931 Riggs      SUB
 18    2931 Riggs      SUB
 17    2931 Riggs      SUB
 19    2931 Riggs      SUB
 N/A    3311 West  Walsh  N/A
 N/A    617  Elk          N/A
 N/A    1321 East  27th   N/A
 N/A    1321 East  27th   N/A
 N/A    407  South  30th   N/A
 N/A    407  South  30th   N/A
 N/A    407  South  30th   N/A
 N/A    407  South  30th   N/A
 N/A    3311 West Walsh  N/A
 N/A    1422 East  34th   N/A
                     KIT          9.6   1
                     LVG ROOM     9.4   1
                     HALL (BLV)   5.4   2
                     BED 2        1.3   2
                    . BED 1        1.4   2
                     BASEMENT     2.8   2
                     BATH (2LV)   1.8   2
                     KIT          1.5   2
                     LVG ROOM     1.6   2
                     LVG ROOM     3.4   5
                     BATH         8.6   8
                     BATH         9.4  13
                     KIT          5.6  16
                     PANTRY       2.8   7
                     BATH         3.6   2
                     HALL (LVL 2)  9.3   2
                     DIN RM 1     6.9   2
                     BED 3        8.8   2
                     LVG ROOM     8.9   8
                     BED 1        8.7   5
                     GAME         3.2   1
                     EXT WALL     1.2  10
                     HALL         2.6   2
                     BED 2        2.1  12
                     KIT          1.3   5
                     HALL (LV1)    2.2   1
                     KIT            7   2
                     LAUNDRY      2.6   2
                     BED 2        7.4   2
                     DIN RM  2     1.1   2
                     GAME #1      0.41
                     BATH         8.3  10
                     BED 3        6.1   1
                     PANTRY        5.6   8
                     BATH          16   7
                     KIT        11.3   6
                     BATH (LVL  1)  9.9   6
                     HALL (1LV)    4.1   8
                     KIT (LVL 1)   4.7   4
                     LAUNDRY (BLV  4.5   1
                     HALL (BLV)    7.5   4
                     KIT            4   8
  Abrasive Removal
  Abrasive Removal
  Abrasive Removal
  Chemical Removal
  Chemical Removal
  Chemical Removal
  Chemical Removal
  Chemical Removal
  Chemical Removal
   Encap,  Enclose
   Encap,  Enclose
    Encapsulation
    Encapsulation
   Enclosure, R/R
   Enclosure, R/R
          Heat Gun
          Heat Gun
          Heat Gun
          Heat Gun
          Heat Gun
    Encapsulation
    Encapsulation
    Encapsulation
    Encapsulation
Enclose, Heat Gun
        Enclosure
 Enclosure, Encap
         Heat Gun
         Heat Gun
   Heat Gun, Chem
   Heat Gun, Chem
Heat Gun, Enclose
 Chemical Removal
   Encap, Enclose
    Encapsulation
    Encapsulation
        Enclosure
   Enclosure,  R/R
   Enclosure,  R/R
   Remove/Replace
   Remove/Replace
        R/R, Encl
CODES: MEAN
          N
        SEL
        ORG
        SUB
        N/A
       Arithmetic average of XRF measurements in the room
       Number of XRF measurements in the room
       Selection code
       original sample actually obtained
       HUD substitution
       originally requested sample which was unavailable
                                41

-------
                             APPENDIX D

               REGRESSION ANALYSIS FOR PLASTIC SAMPLES

 Several regression analyses were conducted to further  explore and
 quantify the relationship between  the  mass of lead  abated  and the
 TCLP results for plastic samples.   The first analysis  had  TCLP as
 dependent variable, and estimates of the total mass of lead abated by
 each abatement method  (see  Section 3.4) as  independent variables.
 The fitted model was
     TCLP (mg/1)   =
0.23 + 0.65*[ABR REM] + 2.40*[CHEM REM]
+ 0.64*[ENCAP] + 40.96*[HEAT GUN]
+ 13.56*[ENCL] - 31.83*[REM/REP],
where each dependent variable represents the total kilograms of lead
abated in a  room by the corresponding abatement method.   This model
explained 85.1% of the  variability  in the TCLP results.   However,
only  the variables HEAT GUN and ENCL were  significant in the model.
Accordingly,  a second regression,  with only these two variables  as
independent  variables,  was  run,  resulting  in the following fit:

    TCLP (mg/1)  = 0.33  + 40.9*[HEAT  GUN] + 13.3*[ENCL].

This  model explained 84.8%  of the variability  in TCLP, so there was
essentially  no  loss  of explanatory  power versus the  full  model.
Finally,  a model with just HEAT GUN as independent variable was run,
with  the following result:

    TCLP (mg/1)  = 1.79  + 41.4*  [HEAT  GUN].

This  model explained 78.4%  of variability.

The second and third models  have potential use in developing decision
rules for determining  whether  plastic sheeting  from an  abatement
needs to be treated as hazardous  waste.    For example,  the  second
model predicts .that 10  of the  32 samples would fail the  TCLP  test.
Of these 10, 8 actually  did.   Thus, 4 of  the 12 samples  actually
failing the TCLP test are not predicted to  do so by the model,  while
2 samples which  did not fail are predicted to  fail.   The  4  samples
not predicted to fail  by the model are those with the  4 smallest TCLP
levels above the 5 mg/1 cutoff.   The  2 samples  incorrectly predicted
to fail  both had  TCLP levels below the detection limit of  0.3  mg/1.
The  predicted  values  from the model  were  11.2  and   12.7  mg/1
respectively.  The predictive power of this model, based on currently
available data,  is clearly  limited.   Further  data  collection and
model refinement would be necessary before practical application.

The third model predicts 7 failures of the 12 that actually occurred.
It fails  to  predict correctly  for the  5 samples with the  smallest
TCLP  levels  exceeding  5 mg/1.    However, the model always predicts
correctly for those samples  whose TCLP level was less than 5 mg/1.
This  simpler  model performs slightly  better than  the two-variable
                                 42

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43

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-------