TES V
MANAGEMENT OF WHOLE-STRUCTURE
DEMOLITION DEBRIS CONTAINING
LEAD-BASED PAINT
Prepared For
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C. 20460
Wofk Assignment No.
EPA Region
Site No.
Contract No.
Document No.
Prepared By
Contractor Project Manager
Telephone No.
EPA Work Assignment Manager
Telephone No.
Date Prepared
ROI031
I
N/A
69-W9-0002
TESV.R01031.RT-DCRQ
COM Federal Programs
Corporation
Joan Knapp
(703) 968-0900
Cynthia Greene
(617) 223-5531
November 19, 1993
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T 8LE OF COSTE”iTS
USTOF kCRO\YMS .
LISTOFT BLES ...
LISTOFFIGLRES .
1.0 - Purpose and Organizauon of Document
2.0 Back ound
2.1 Ba k our dofLBPp obkm
2.2 O%erv1e . of Solid Waste Mana emenc Issues ..
2.3 O’ .ervie . MLBP 1ss s
3.0 RegubLions and Requu merits Concerning C,D Debris ..._ . . . . . .. .. .. 7
3.1 Overvie . . .... . . . .. ... . . . .. . . . . . ..
3.2 Federal R:gWaLory Rquiremenu .... ... .._...... .. -
3.2.1 RCRA Sub d C..... .. . . . . . . . . . .. 7
32.1.1 Hazardous Waste Decerminazion ...... ..... _ . ... 8
3 . .2.L2 To :cn Charactcrisdc Le hu g Procedure ..... .... .. 8
3.2.1.3 Land Disposal Resthc ons ......... .. .._...... 8
3.2.1.3 Household Hazardous Waste Exclusion II
3.2.1.4 Re cle SCi p M u1 ——.. . ...._..... . ... ...... II
3.2.2 C!ean Air A i . .. . . . . .. _. _. . . .. . . . .... .. 12
3.2.3 OSHA .. .. .. . .. _. .. 12
3.2.4 RCR.A Subaije D ...... . . .. ..
3.3 Stare Regubzorv Requirements ..... ...... .. I
33.1 N WMOAS tgs.... ......... - -....- . ...-..—-.. I
33.1.1 C nnecacut _____...... . . . ..__...__._.._...... _..
3.3.1.2 M.unc......... .. . .. Ii
3.3.1.3 Massxhuset .................. . _... .. 17
3.3.1.4 New Hampshire . .... . . . . . ... -
3.3.1.5 N w Je ev
3.3.1.6 Rho Je Island ..._ ......... .. — _. . . . .. . . ..
3.3.1.7 Vennoni_..... . .. . . . ._ ...
3.3.2’ Other Stares... .. . ... ..... ..
33.2.1 Kcnruikv...... .. . ... ... . ...
33.2..! Maryland ..
3.3.2.3 New York..... .. .. .. ...
33.2.4 Ohio ... . ..... -... . ... . . ......... . ._.........
3.3.2.5 P nnsyl anu .. . . . ... .. . . ._. . ...
3.3.2.6 Si’uth Carolina _... .. . . . .. . ...... 2 1 )
33.2.7 V .i hIfl 1(QA ... .. ........ 21
3.4 Commercial Faulu. R quiremcnt .. ... . ... 21
4.0 Generation of C/D Debn — 22
4.1 Sources . .._. . .....
4 1.1 P ate Si’ur.: ... _.. — 22
4 I 2 S,UL . .._ . . . .. . 22
. 1.3 F .!:rjj . . _..
42 Types and Quanticie - . ..
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5 0 Sample Collecz on. .
51 Cw7 t App oa he c CD De r 17
5.1.1 US krrn. H ie Cflç. 27
51.2 Denser cusin Au cr:. . De . e Colo uo . 30
51.3 Rocky oun in & e iaJ - No Future Use Sa cures 31 -
51 E? R tcn vj . . 3’
5.1,5 lndepende t L.iborazor-. • Louis iU . Kernuckv 33
5 1 6 - Demobuonil_ead Aba menc Cona actor . Peabody. Massachusetts 33
5.1.7 Conriectic c Departmeu of Envtronmen J Protection 34
5.2 Hypothetical Sampling Opoons Analysis for Permeable Debris 35
5.2.1 Samplu Permeable De ns After Demolition .. .. 37
5.2.1.1 Dismantle and Sample Each Budding Component (OpQon I) ............. 37
5.2.1.2 Dtsrnancle and Sample Each Lead Componen ’Demo1ish Other
Componenc.s and Sample Composite (Option 2) . . . .- .- ...... 38
5.2.1.3 Demolish &11 Components and Sample Composite (Option 3L.. .. .. 3S
5.2.2 Sampling Permeable Debris Before Demolition ....... .,.......... 38
5.2.2.1 Sample Each Component (Option 4) ——— — —.......... 38
12.2.2 Sample Each Lead Componen omposite Other Components
(Option 5, 39
52.2.3 Composite AU Components (Option 6) 39
5.2.3 ReIau e Cost and Confidence Level of Hypothetical Options .. .. ... . .——- .- . ...... ... 39
53 Recommended Sample Collcuon Protocols for Permeable Debris _______..___._.._...4..41
5.3.1 Planning .....4.A 2
5.3.1.1 Researth
5.3.1.2 -Building Inspection ........______ . .. . . . . .44
5.3.1.3 Use of Lead Screening Procedures During Bui1di g ! - 44
5.3.1.4 SarnplineandAnaly5isPl ji Qugtyft ujaj ceProje. .an.... . . ... .35
5.3.1.5 Job Hazard .Anlyss.... ..... ....__..._. ....__ —
53.2 Recommended Options (or Sampling App hes..._._...._ — — —__.-.-._._.46
5.3.2.1 CompositeSampling ._.._. .________.....___.-._ .._
5.3.2.2 Before Demolition - Sample CoLlection from the Strucn e 47
5.3.2.3 Evaluarion of Composite Sample Results _....__.__..........___.._...49
5.3.2.4 After Demolition Sample Couecuon from the Debris PiIe_..............__
53.3- Sample Collection Method . __ ... 52
5.3.4 Quality Assurance/Quality Con ol Samples (QA/QC)......_..........__.__..._...........,.........
53.5 Summary of Recommended Sample Collection Protocols ._..._.....___...._......._.. 54
6.0 Sample Analysis................. .. .. cc
6.1 Toxicity Charxtensuc Leaching Procedure .. . ... . . . ..
6.2 Synthetic Precipitation Leaching Procedure .. .__._____._.._. . .
6.3 ScreerungTools — ... .. .......
6.4 Recommended Sample Analysts Protocol .. ..
C/D
7.2 8 rdng......... .. .. .. ... .. :. . . .63
7.3 Recycling...... .. ..
7.4 Handling 6$
7.5 Recommended Manacement Protocol For Non-Hazardous C/D Debris ............ 6$
8.0 Management of Hazardous CD Dehrm ... . ..
8.1 Generator Status . ._. .....
8.2 Treatment . . . . 70
8.3 Burning . . ......... . ... —
83.1 Cement K n) . . .. . . ..
832 Other Buriu, F Iiue — 74
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3. R c cL
5 H ndAtng
3 6 Recommended ?rouxol icr H z.r ci C.D Dehns
90 L i wcsure
9 I Human 1- aJth Effects . ... .. .. .
92 En’. tronmenca! Effects ..
9 3 Err. tronmenca! Face and Transport
9 31 Leachabiljcv from Landfills
9 3 2 Leachabihcv from Combustion . jh
9 3.3 Air Emissions
10.0 Recommend Protocols - . . .. ..
10.1 Sample Collection
102 Sample .Anaivsis
10.3 Non-Hazardous C/D Debris Management ..
10.4 Hazardous C Debris Management
11.0 Concrnued Progress ..
11.1 General Approach .
11.2 Recommendations for Continued Progress .. .. 91
11.2.1 Technical — .. —..
11.2.2 Economic _ . .. . . .. . .. 92
11.2.3 Re u1azort —........—..... — 93
11.3 Ongoing Studi .. .. . . 93
11.3.1 U.S. Army Environmenul Hygiene Agency — 94
11.3.2 U.S. EPA Office of PoUu o Prevenuon and Tox.ics 95
11.3.3 U.S. Air Force Armstrong Laboratory . .....
11.3.4 Connecticut Department of Environmental Procecuon ..........._.... ...... _ W i
11.3.5 E.PAJW..D Title X -. .. - 97
References — .. .. ... .. A-I
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LIST OF ACRONYMS
AAS - Atomic .:iorpnon Spectrome y
AEHA - U.S A : Eivtronmencal Hygiene Agency
ARARs - Applica .e and Relevant or Appropriate Requirements
APCD - Aix Pollc:cn Con ol Device
ATSDR Agency f:: Toxic Substances Disease Regis y
BDAT Best De :ns ated A ailable Technology
BRAC - Base Rez. :2nment and CLosure
CAA - Clean A Act
CID - Cons uc:: n and Demolition
CDC Centers &r Disease Control
CFR - Code ot Fe eraI Regulations
CKD - Cement k. n dust
CPSC Consume: Product Safety Commission
CT DEP - Sute of C nnecucut Department of Environmental Protecuon
DRA - Denver H using Authorit
DOD U.S. De :ment of Defense
DOE - U.S: De a..-rnenc of Energy
DQOs - Dauqua : ob,ecti es
EP - Exuactjc ;rocedure•
EPA - U.S. En’. nmencal Protection Agency
ESD - U.S. En’. c onmenui Protection Agency. Environmental Services Division
EMSL-ORD - U.S. En’ cnmenul Protection Agency. Environmental Monitoring Systems
Laboraccr - Office of Research and Development
FR - Federa(Re icrer
HUD - U.S. De -menc of Housing and Urban Development
HSWA - Hazardous and Solid Waste Amendments
kg - Kilograms
LBP . - Lead- ba .se, paint
LBPPPA Lead-Based Paint Poisoning Prevention Act.
LDRs - Land biscosal Restrictions
LHA - Louisville Housing Authority
MCL Maximum contaminant level
mg /cm 2 - Miuigramslsqua.re centimeter
mg/kg — Milhigrams.kilogram
mg/L Milligrams,lier
rnL/g - Milhilicers.gram
MS/MSD Matrix SptkefMaaix Spike Duplicate
MSW - Municipal ‘solid v.a te
NE WMOA - Northeast Wd\CC \1ana ement Officials Association
OPPT - U.S. En ir nmenul Pr tection Agency - Office of Pollution Pre enuon .rnd
lox icc
OR.P - .Oxidacior --du tion pocencial
OSHA - Occupauc’- . l .ind Health Adm lnlstratLon
OSWER - U.S. En’. ir ul Protection Agency - Ottice ot Solid Waste and
Emerge . R pon . .e
pcd
ppm - Parts pe
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LIST OF ACRONYMS
(Continued)
QAJQC QuaJic Assurar.ce.’Qualicy Coritiol
RMA - Rocky Mountain .lrsenal
RCRA - Resource Conser anon and Recovery Act
SPLP - Synthetic Precipiradon Leaching Procedure
SWAIP - Special Waste Authoriza on and Iniplementation Plan (South Carolina)
TCLP Toxicity Characteristic Leaching Procedure
!.Lg/dI Micrograms per deciliter
Lg/k - Micrograms,kilo
- Micrograms/cubic meter
- Micrometer
USAEC - U.S. Army Environrnentaj Center
XR.F X-ray fluorescence
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LIST OF TABLES
Thble I \ W\1OA SLat s CD ‘tana emeni Surnmjrv .
T bk —• I ‘ ‘ ase Composition I P : i e: in C D Debris
Table -2 CiD Waste Composiocn Pe : tuge in Mcuu Toronto 25
Table 5.1 Compai,son of Kno .n Saxnplir Appro ies 28
Table 5.2 Hypothetical Opoons for S npluig Permeable Debris 36
Table 5.3 Analysis of Hypothe :ai Opucris 40
Table 5-4 Sample Collection from the Sc -xttue.Opoons for Composiang 48
Table 5.5 Evaluation of Composite Results _.... •. .. 50
Table 6-1 Data Comparinit SPLP and TCL? Methods
Table 6.2 Comparison 01 Field and Laboraiorv Lead Data. 58
Table 7-1 NaDonaj C’D Waste Re ulaxor. 0ver iew .. .. 62
Table 7.2 Summai f yj f Energy Policies In Studied Sia es __.. 66
Table 8-1 A1cernati Tre.umenc Standards for l(azardou Debris .. ..7 1
Table 8.2 Applicabk Treatment Standards for Physical E aaction ... ........ 72
Table 9.1 Effects of L d Le eIs in Sod on Microbial Activity .. 79
Table 9.2 Solubility Product Constants for Lead .tinerals .. 80
Table 9-3 Lead Concenuations In Combustion Ash .. 83
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LIST OF FIGURES
F!gt e 5-1 Summary of Recommended Sai pIing Appro3ch s for P bk
DemoI ticn Debris
Fivire 10.1 Summary of Recommended Sampling Approa h s for P ieabIe
Demoliuoi Debris
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1.0 PURPOSE \DORG;\lZ;TlO\ OFDOCL’IE\T
There is a growing national C flCCfl about the e zs of leac e pasure on hum: he. Itt .
en uonmenc T edemoUuc. of v hole uc:i. .res ontalnin2 lead-based paint ‘LBP
potential source ci lead e posi.ire that requLre uncerscandinz and warranc .i m rLtgem
protocol to rrunirruze threats o human health and the environment. This draft ce hnical report
has been prepared to aid the U.S. En ironrnental Protection Agency (EPA) Reg on I in the
development of a protocol fcr management of hole.sauèture debris containing LBP
Management inckzdes sampling. analyzn . handling. recycling, burning. e3ting and dispc ing
This draft report meets the requirements of ork assignment number RU 1031. under EP .
con acr number 68 -W9-0002.
A discussion of the research and analysis performed to date by CDM Federal is presented in thi
report. This document represents a “snap-shot” in time of the state of the issues. With this
information, draft protocols are recorru ended.. It is anticipated that these findings and
recommendations will serve as a foundation v.hich stimulates further discussion and research on
the subject. which will ultima:dv lead to final EPA protocols.
This report is specifically limited to LBP debris generated from demolition of whole s .icture ’.
It mentions, but does not focus on. LBP abatement wastes, debris generated during remodeling or
renovation of suuctures. or LBP that has migrated from its original surface and become a
contaminant in neighboring soils or surface acers. These are all important issues related to LBP
and its impact on human health and the environment, but are beyond the scope of this document
Various topics pertaining to the management of hote•su’ucture demolition debris containing
LBP are presented in this report. Background information, current regulations and practices.
recommended protocols, and requirements for additional research and analysis are addressed.
The organizationof topics in specific sections follows:
• Section 1 presents the purpose and organiza on of the document.
• Section 2 summanze the b kground issues regarding LBP and solid aste
management.
• Section 3 presents haLk round intormation on regulations and requirements
pertaining to consti u tion’d oltcion (C/D debns containing LBP.
• Section 4 pro tde b .ick rou J tnforrruoon on the generation of CfD debris.
• Section 5 presents.! cornpr 1 nsi’.e r..il is of sample colleenon. including various
protccols u1cw-re : use. h :: iI mpling op 1ons. and recomrrended proto ols
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• Section 6 discusses sample analysis and presenLs recommended pr cok
• Section 7 provides a discu on of management options for non-hazar ou C 0 decr
including landfilling. burning, and recycling Recommended protocob are dLSCuss d
• Section 8 presents informanon on management req uisements for hazardous CiD
debris, including generator status. n’eatment. burning, recycling, and handlln2.
Recommended protocols are provided.
• Section 9 discusses background information on lead exposure and presents available
information on human health effects, environmental effects, and fate and ‘anspo
including lead leachability from landfills and combustion ash and lead air emissions,
• Section 10 recommends draft protocols for four important topics: Sample coLlection.
sample analysis, management of non-hazardous C/D debris, and management of
hazardous C/D debris.
• Section 11 provides recommendations for continued progress in evaluating these
issues. Recommendations in the following areas are provided: technical, regulatory.
and economic. Status summaries for ongoing studies are presented.
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2.0 BACKGROI\D
2.1 B ACNGRO D OF LEAD-BASED PALNT PROBLFM
Historically, many different types of paint used tn the United States ha e contained as one of
their components lead or a leaded compound. such as lead o tide or lead chromate. The former
as used in white paint and the latter in red paint, chiefly used as a primer. Lead as a major
ingredient in many types of house paint for years prior to and chrouQh World War (I. In the earls
l950s. other pigment materials became more popular. but lead compounds ere still used in
some pigments and as drying agents. Lead-based paint (LBP) is found throughout this coun . ’
inside and outside of homes and buildings. on s uctures such as bridges and water storage tanks.
and on products sold in the marketplace. LBP may eventually migrate from its intended surface.
and may be inhaled or ingested by humans, posing to them a health hazard. While the sources of
lead, such as gasoline and water systems using lead pipes or lead-based solder in copper piping
systems. have been significantly reduced in recent years. the LBP in older su ucaire remains a
significant problem.
Federal regulatory efforts regarding LBP began with the enactment of the Lead-Based Paint
Poisoning Prevention Act (LBPPPA) in 1971. In 1973. the Consumer Product Safety
Commission (CPSC) established a ma.xirnum lead content of 0.5 percent by weight in a dry film
of paint newly applied. In 1978. the CPSC lowered the allowable lead level in paint to 0.06
percent.
In October of 1991. the Centers for Disease Conuol (CDC) lowered the blood-lead level “level
of concern” standard to 10 micrograms of lead per deciliter of blood, and estimated that 3 million
U.S. children have lead concen ’ations above this danger Level. The U.S. Environmental
Protection Agency EPA) estimates that one out of six American children under the age of six
has elevated 1ea6 c1s in the blood. As a result of this problem. the Clinton Adrrünisu’ation is
seeking a 70 perce increase. to nearly S35 million dollars for the 1994 fiscal year. in spending
on lead pollution’ programs at EPA. and has launched a public information campaign to prevent
lead poisoning. (Washington Post. May 5. 1993) The Agency for Toxic Substances Disease
Regisn y (.ATSDR) estimates that 42 mLlllon homes contain LBP. affecting 12 million children.
(U.S. HUD. 1990) Americans re e pected’to spend S234 million on projects involving
abatement of lead this year. Ve York flrnt’ , March 2!. 1993)
In the 1970s. the principal hazard to children as thought to be paint chips containing lead.
primanlv found in homes with peding paint R earch in the early l9SOs s io ed. however. that
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ad u : s of $pc. . concem. in p be use the smaller ::cles i — - - ov
t e bcd and in P Ce ause : e com.mcr methods of pal: mo a!. .-: _ -
and bur:-: g. create XCess i e amounts of ust. Enteriar LBP dust can o come normal
abrasion cf painted urfaces. such as the opening and closing of windo’ . s Lead st is
especia1I hazardous to young children because they play on the floors ‘bhere dus: sectks. and
engage in a great deal of hand-to• mouth acuvity.
Lead dust from exterior paint is also a problem. For many years. exterior paint films were
designed to “chalk.” or Lose some of the surface paint due to rain arid ul aviolet Lilt. in order to
keep the surface look ng fresh. The lead pigment which washed off in this process accumulated
in the soil around the house. Other sources of lead in soils include irriproperLy performed
exterior LBP abatement work and deposition of lead from gasoline. (U.S. HUD. 1990) Lead-
contaminated soil poses a hazard to children playing in or near it. and dirt u’a ked indoors can
lead to increased Lead dust levels in the home.
While adults may suffer various ailments due to excessive lead exposure. the groups most at risk
from exposure to lead are fetuses, infants, and children under six. Excessive blood-lead levels
can seriously damage a child’s brain and cena’al nervous system. Lead poisoning in children can
cause attention span deficits, impaired hearing, reading and learning disabilities, delayed
cognitive development, reduced IQ scores. mental retardation, seizures. convulsions, coma, and
even death. In adults, high blood-Lead levels may increase blood pressure and ha e other effects.
(U.S. HE’D, 1990)
2.2 OVER VIE%V OF’ SOLIT) WASTE MANAGEMENT ISSUES
Despite the human health problems associated with LBP. it is typically a relatively minor
component of most building demolition projects which generate consn ’ucdon and demolition
(CID) debris. Tbczefore, the majority of LBP CD debris will not be managed as a hazardous
waste. Metho4 j r ks management should be consistent with the solid waste management goals
set by EPA, and should include source reduction. recycling, and combustion as preferential to
landfilling.
2.3 OVERVIEW OF LBP ISSUES
There is a need for nadonv .ide con istencv with respect to the management of hoLe-su’ucrure
demolition debris containing LBP. A protocol should be developed that is environmentally
beneficial, protects human health, is enforceable, and promotes proper management. While a
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lar :e cenuge of the debr-.s may contain LBP. the rnapor .t:. of the debr: i —
haz:::ous because it IS not a Li ed v aste and dce not exhibit a hazardou Lh. ,. -
The g ancities of CfD was:e epor:ed in various locations acro the nation ‘ ar . c , rn rn
from 0 12 to 352 pounds pe capita per day (pcd. A 19 S EPA Report to COngre\ cn olid
waste disposal e umated approximately 3 1.5 million tons per eir of CfD aste on an
average generat:on rate of 0.72 pcd. (EPA. 1988) However, more recent studies ha e ug e ted
that this value is underestimated and that it is not possible to reliably estimate C/D generation
rates due to the large number of variables associated with GD aste generation. I n fact., in the
1990 and 1992 updates of the EPA report Characterization of Municipal Solid Waste in the
United States. CID generation rates were not included by Franklin Associates because there are
no dependable figures or disposal practices at the national level. (Lambert. 1992) Some of the
factors that ma ce estimation difficult include the following:
• popu’ation and ernployrrtent in the area
• the overall level of economic activity
• the extent of road . or bridge•related consauCtjofl, renovation, and demolition
• exaaordinary projects such as urban renewal, hurricanes, storm damage. fires or
disasters
• records of actual CID disposal at landflhls and other disposal sites
• past and future u’ends in C/D activity. (C.T. Donovan. 199Gb)
Due to concerns about occupaQonal exposure to lead, the Occupational Safety and Health
Adm.inisu ation (OS HA) promulgated an interim final regulation on May 4. 1993 requiring that
demolition conuactors and others place greater emphasis on programs designed to minimize and
prevent occupational exposure to lead. The effective date of this regulation was June 3. 1993.
Training progran medicai surveillance, respiratory protection. equipment and personnel
deconcaminadon and exposure monitoring must be addressed during the performance of any
work involving the disruption of ‘ urfaces v hi h may result in the generation of airborne Lead
concenuations. The new regulation will require serious beha ior modifications for conuactor
and con actor employees alike.
Currently. LBP debris generated from GD projeLts is not managed consistently throughout the
coun y. This is due in large p.irt to an JbcenLe of e tab1ished protocols for sampling the debrt .
and to a lack of krio led e that th material betn generated may in fact be hazardous. As .1
re ult. this material is curren: 1 betn e:ther burned a an energy source or IandfiUed ( ithOut
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pre e: eflt). BLrnrng can 2er erate e ue for the con : :or re c b1e rc : moljuon,
and Lir 91ifl2 in either municipal SOi:C . aste (MSV ) lai c: ils or CD landti: : a proje : cost.
Manag:ng the LBP debris as a hazar us aste is a much .g ier proje z co L a : s therefcre not
often considered as an option. This approach is not in compliance ith hazar cus waste
regulations.
Several demolition conuactors have stated that demoLiuon is not economically %Lable without the
revenues generated from the sale of materials for either recvclins or burning as an energy source.
The economics of demolition projects ill change significantly if some CID debris containing
LBP is de:errn.ined to be a hazardous asce. requiring more costly methods for management.
tiansporz.auo :eatrrtent. St -ge. and disposal. - Potential ad’. se results include decisions to
continue to us.: ouildings pre iously planned for demolition. Such use will leave LBP in place.
both in arid on buildings, where it i1l continue to pose a health risk to those children and adults
within the building, or nearby. (Spittler. 1992)
The demolition indusuy fears that nev regulations will over-regulate LBP making it the
“asbestos of the 90s.” Over-regulation may close aU avenues to recycling and reuse and increase
demolition costs considerably. With promulgation of new regulations, perceptions about LBP
risks could further increase. This perception change could have a significant impact that closes
doors to recycling arid municipal landfill disposal. (Taylor. 1992) Currently. the Lack of C/D
capacity in landfills and the cost of legal disj,osal has led to increased incidents of illegal
dumping activities throughout the northeast U.S. (Lambert. 1992) These problems could
conthbute to increased risks to human health and the environment from debris containing LBP.
EPA Region I is aware of these potential ramifications arid has commissioned this report to
investigate the issues and recommend protocols for management of who1e-sti .iccure debris
contaminated with LBP.
EPA ’s integra soud waste management suategy snesses source reduction, recycling.
combusuon. zandftuing as the ordered hierarchy of waste management options. Because
C(D debris containing LBP already e ists in the form of whole suuctures awaiting demolition.
the method to achieve source redui.tion is limited to effective waste identification and
segregation. Recycling and burn ln2 are two management options v 1 ith significant potential for
C/D debris containing LBP. The List liernaove. landfiUing. is the least preferred option for non-
hazardous debris.
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3.0 REGULATIO\S A\D REQURE\IE\TS CO\cER’ 1 r (; - [ i L)F k?
3.1 ERVffW
Re2ulauon of waste management within the Lnited States begins at the federai level with the
Resource Conser ’auon and Recovery Act (RCP..A). The aspects of RCRA relevant to lead-based
pa. nt (LBP) debris management are: (1) hazardous waste management. Subtitle C: and solid
V. aste management. Subtitle D Additional aspects of federal regulations pertaining to waste
management incLude the health and safety of workers, as regulated by the Occu?auO nal Safety
artd Health Adminisuation (OSHA): the impact of waste burning on air quality, as regulated by
the Clean Air Act: and regulations specific to buildings managed by the U.S. Depr eit of
Housing and Urban Development (HUD). Regulations promulgated at the federal level may be
made more s ict by the indi iduaL states, and states may also promulgate regulations where none
e isc at the federal level, as discussed in Section 3.3. Section 3.4 discusses additional conditions
that commercial waste handlers may impose on their customers.
Under RCRA. waste generators are required to determine whether or not their waste is a
hazardous waste. If it is a hazardous waste, the waste must be uansported by a RCRA•permitzed
ansporter to a RCRA-permitted eatment. storage and disposal facility. The management of
hazardous wastes is oudined in Subtitle C of RCRA. and is discussed in Section 3.2.1 of this
report. If the waste is determined not to be a hazardous waste, it is not as sthngently regulated
and is managed under Subtitle D of RCRA. as discussed in Section 3.2.4.
3.2 FEDERAL REGtQATORY REOUTREMENTS
3.2.1 RCRA SUBTITLE C
Subtitle C of RCRA governs the management of hazardous waste. The regulations specifically
detail how to dete se whether a waste is hazardous. and once this determination is made, how
to legally transport ueat. store nd di po e of the waste. This settion presents a hazardous waste
regulatory overview: haza.rdou w .i ’ te mamigement issuc are discussed in Section 8.0.
Generators of waste are required. under 4k) C.F.R. Part 262. to identify whether or not their waste
is a hazardous waste, using the ericeru defined in 40 C.F R. Part 261. If the waste is hazardous.
it must be ansported according to 4( 1 C F.R Part 263 to a aeatment. storage and disposal
facility. Generators must compk ith the Lind di po al re’ icc1on requirements found at 40
C.F.R. Part 26S.
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3.2.1.1 Hazardous SSaste Determination
Under RCRA. a waste is haz3.rdous :1 .t is either a listed haz dous ‘. a e or if.: thibit cne of
the four charac:eflStlCS ( g’iitabiIity. c rrosivity. reactivity and toxlc itv of a hazardous v.a te.
Upon reviev . ing the criteria in 40 C.F.R. Part 261. it can be deterrruned that LBP demolition
debris is not a listed hazardous ‘baste nor is it excluded from regulanon.
LBP debris is subject to evaluation against the RCRA hazardous asce characenstics. including
the toxicity characteristic. The generator of the waste is responsible for making this
de’ rnination. A generator may make this determination based either on kno’ . ledge of the
mz.. .ial used in the waste or the results of the Toxicity Characteristic Leaching Procedure
(TCLP). Generators should retain records to support both hazardous and non-hazardous waste
determinations they make, since the generator.is liable for civil penalties and other sanctions if
the waste is improperly classified.
3.2.1.2 Toxicity Characteristic Leaching Procedure
The Toxicity Characteristic Leaching Procedure is intended to simulate the conditions that
hazardous waste is exposed to in a landfill. The U.S. Environmental Protection Agency (EPA)
developed the regulatory levels for hazardous constituents using health-based concen ’ation
thresholds and dilution/attenuation factors specific to each chemicaL A concenu ation threshold
indicates how much of the chemical adversely affects human health. while the
dilution/attenuation factor indicates how easily the chemical coulc o or leach into
groundwater. The level set for lead was determined by multiplyir. health-based number by a
dilution/attenuation factor of 100.
TCLP is an analysis performed on an exu act from a representative sample of the waste. If the
exuact from L.B?debris contains lead contaminants at the concenu’adon equal to or greater than
5.0 mg/i... the i iiite is hazardous for the toxicity characteristic of lead. For a further discussion
of this testing pIócedure. refer to Section 6.0.
3.2.1.3 Land Disposal Restrictions
NOTE : The following discussion presents a brief summary of the select subset of the Land
Disposal Resuictions (LDRs a they apply to hazardous debris exhibiting the toxicity
characteristic for lead. The reader should refer to 40 C.F.R. Part 268 for a complete description
of all applicable LDR requirements.
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- The [ 984 Haz -:cus md ScUd W : Amed ents F-P \ S \ . - --
EPA :c : .e Cp re4ulations ‘:: v .ould impose. on a 7nasea cheduLe. cejcme’t .. -
listed ar.: h -ac:e suc haz ous wastes prior to thea land disposal. EPA de. .
scandar: e:t er ti c Oncen ation levels or methods oi eatment that ub canuali
diminish e toxicity of wastes or reduce the li.kelihccd that hazardous consututents from v a es
will nugra:e from the disposal site. These ‘eatment standards arid applicable regulations are
found at 40 C.F.R. Part 268. Land Disposal Resnicuons (LDR).
Land dl3posai includes any placement of hazardous waste in a landfill. surface impoundment,
v.aste pile. injec on ell. land u’eatment facility, salt dome formation, salt bed formation or
underground mine or cave. Tne reader should note, however, that regardless of ‘ here e as:e
is being sent (landfill. recycter. incinerator. etc.). generators must prepare the applicable LDR
notifications and/or certificanons to accompany the waste.
Prohibition of Land Disposal of Hazardous Debth : 40 C.F.R. Section 268.35(e)(l ).prohihits the
land disposal of hazardous debris, effective May 8. 1993. On May 14. 1993. EPA amended the
prohibition effective date to May 8. 1994. 58 Federal RegIster 28506 provides a complete
discussion on why the extension was granted and ser.s out the legal requirements that a generator
must meet to benefit from this extension. These requirements include documenting good-faith
efforts to locate ueatment capacity for this waste s ’eam and, to the extent that ueatment capacity
for this s ’eam is available during the extension period, it must be used.
Hazardous Debris Treatment Standards : The ueatrnent standa.rds for hazardous debris ‘ere
published in the Federal Register (FR) on August 18. 1992 and codified at 40 C.F.R. Section
268.43. (See 57 FR 37194-37282). Hazardous debris that is contaminated with a listed
hazardous waste or that exhibits a hazardous characteristic must be u’eated prior to land disposil.
using specific e enc technologies that either exu ’act. desuoy or immobilize the hazardous
contarrünants in/áthc debris. The rule defines both the terms debris arid hazardous debris. (The
requirements for managing non ’hazardous debris are discussed at Section 3.2.4). The
definitions are:
“Debris means solid micenil exceeding 60 mm (2.5 inch) particle size that is
intended for dispo . l nd thic is: 1 a manufactured object: or-2) plant or animal
matter: or (3) nacur I geologic material. However, the follov trig materials are not
debris: 1) any matertil for v htch a specific aeatmenc standard is provided in Subpi.rt
D. Part 26& 2) process re idu.ils such as smelter slag and residues from the ueatrneit
of waste. ‘ aste ater. lud e . or air emission residues: and 3 intact containers or
hazardous asce th.u are not ruptured arid that retain at Least 75% of their original
.olume A rruxture f debris chat has not been n’eated to the standards pro ided by 4
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C F R. Section 268 5 and other mater:aI i s bje : : re ui :iCn ebrs the
r Xflh1C1S comprisec :idebns. b’. ‘.olum . based on ‘ .i a ‘nspe :ion
C.F.R. Secnon 268 .
Ra:ardous Debris means debris that contauis a hazardous v. a te 1i ted in Subpart D
of Part 261. or that e’thibits acha.raczeristic of hazardous waste tder.tified in Subpart C
of Part 261 ‘ (40 C.F R. Secuon 268 2h ).
Examples of solid cons uczion and demolition (C/D) materials that are debris. if intended for
discard and if their particle size is 60 mm (2.5 in.) or greater, include. wood. sheett ock. glass.
concrete (excluding cementiuous or pozzolanic stabilized hazardous waste). masonry and
refractory bricks. non incact containers (e.g.. crushed industhal equipment). tanks, pipes. valves.
appliances. or industhal equipmerit scrap metal (as defined in 40 C.F.R. Secnon 2 6l.1(c)(6)):
tee’ stumps and other plant matter: rock (e.g.. cobbles and boulders): and paper. plastic, and
rubber.
Although EPA is classifying mixtures that are predomiriaridy debris as debris, this does not mean
that debris can be deliberately mixed with other waste in order to change the eau ient
classification. Such mixing is impermissible dilution under 40 C.F.R. Section 268.3. since it is a
substitute for adequate eatrnent. In addition, in such situations where debris is used merely to
dilute the prohibited waste, the mixture would remain subject to the most suingent eaa’nent
standard of any waste that is part of the mixture.
EPA has specified 17 Best Demonsuated Available Technologies (B DAT) to ueat hazardous
debris, with the choice of technology left up to the generator and/or eeater managing the waste.
BDAT includes one or more of the foLlowing families of debris u’eatment technologies:
exu action. desn ’uction. or immobilization. The u eatrnent must be conducted according to
specified performance and/or design and operating standards. If the debris is eated to LDR
standards using an approved extraction or desu icuon technology, the waste will not have to be
managed as a hazardous waste, as long as it no longer exhibits any hazardous characteristics:
however, if th ris is merely immobilized, the contaminants remain with the debris, and the
immobilized d i must continue to be managed as a hazardous waste.
In summary. it is the responsibility of the generator of the LBP C/D debris to sample the waste to
determine whether it is hazardou.,. by submitting it for TCLP analysis. If the waste fails the
TCLP test, the debris must be m.in ged is hazardous waste. If the waste is to be landfilled. it
must be treated to regulatory stand jtds before landfiLling. If an extraction or destruction
treatment method is used. and subsequent TCLP testing shows the material is no longer
hazardous, then the material may be managed as non ”hazardous waste. If the material is still
I U
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1rec ..re funhe eatrr e : I e n ’acnon and de tion :e. OiC2 j •a ! the
c r s ‘.;il re reir , obtlizat:cn ue:trre .t and subseque dK o aL a Z Ct • i e ma
Subt:t .e C iaidfiU. R stdua1s c e;ated 5 the eatment o haza ou de r re to the
LDR de: rrat1Ort a d mana ernenz for the constituent ‘ . hti.h .aused the debris to ce
con
3.2.1.3 Household Hazardous Waste Exclusion
Currently. astes ger erated during the con ucuon, remodelinQ or demolition of a household are
not subject to the household hazardous asze exclusion. discussed below.
The regulations at 40 C.F.R. Section 261 .4ib( I) state that waite generated at a household is
excluded from regulation as a hazardous a.jte. The Agency has stated that household waste has
to be generated by individuals in their homes and the waste s eam must be composed primarily
of materials found in the waste generated by c nsumers in their homes. (49 FR 449i S.
o ember 13. 1984). EPA does not distinguish bet een waste generated by a homeowner and
waste generated at a household by a person other than the homeowner. (54 FR [ 2339. March
24. 89
EPA has previously determined chat lead-contaminated paint chips resulting from snipping and
re-painting of residenci3i walls by a homeowner or cona’actor (as part of routine household
maintenance) would be part of the household waste s eam and not subject to RCRA Subtitle C
regulations. EPA Monthly Hocline Report. March 1990. Question 6,
EPA’s current interpretation of the scope of the household waste exclusion states that any
generated at a household from building construction, renovation, and demolition, with the
exception of those wastes generated from routine residential maintenance. are solid asces
subject to the requirements established under RCRA. (39 FR 44978. November 13. 1984. EPA
Headquarters’ Office of Solid Waste is currently revisiting this issue. My change to the current
int erpretation wilibepublicized by EPA.
3.2.1.4 Recycle Scrap Metal E ceptiun
Hazardous that are recycled are subject to the requirements for generators. ansporters.
and storage facilities of 40 C.F R. Se .tion 261.6. However, wrap metal that is recyclable is not
subject to hazardous waste re u) cion under the following parts of RCRA regulations: 40 C.F.R.
Parts 262. 263. 264. 263. 266. 2M. 27 und 124. and 3010. Tanks, equipment. duct ork. I-
beams. and other scrap rrtecal dcrnoli ion -ebrt that is recyclable may be affected by this
excepdon.
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3.2.2 CLEAN A ACT
lnhalat on of lead. either from 3USt or an errLiss lon from a facilit . IS ari e .po Ur concern to
human health and the environment. Because of this concern, the amount of lead a!lo able in the
atmosphere is regulated. The regulators basis for aLr pollution abatement in the United States is
the 1993 Clean Air Act (CAA, and its amendments. The CAA provides for t’ o kinds of
national ambient air quality su.ndards. Primary ambient air quality standards are those requisite
to protect public health with an adequate margin of safety. Secondary ambient air quality
standards specify a level of pcllur.ant concenaadons requisite to protect the public welfare from
any known or anticipated adverse effects associated with the presence of such air pollutants in
the air. Secondary standards are based on damage to crops. vegetation, wildlife, visibility.
climate, and on adverse effects to the economy. Thus an air quality standard is a level to u.hich a
pollutant concenn ’ation should be reduced to avoid undesirable effects.
The Clean Air Act requires each state to adopt a plan that provides for the iinplerrientanon.
maintenance, and enforcement of the national air quality standards. Emission reductions will
abate air poUution. therefore the states’ plans must contain legally enforceable emission
limitations, as well as schedules and timetables for compliance with such limitations. The
con ol su ’ategy must consist of a combination of measures designed to achieve the total
reduction in emissions necessary for the attainment of the air quality standards.
Currently. the CAA’s primary and secondary standards require that not more than an average of
1.5 pg/rn’ of lead may exist in the atmosphere averaged over a 90-day period. Furthermore. lead
emissions may also be a component of respirable particulate matter in the atmosphere.
Currendy. not more than 450 ).J.gJm of particulate matter less than tO pm (dust small enough to
be inhaled into the deepest portion of the lungs) may be in the atmosphere. averaged over an
eight-hour wor&dty. Based on these criteria, dust emissions on demoLition projects and stack
en issions frot prni.rg facUlties are regulated for lead, and therefore are LBP issues.
3.2.3 OSHA
Regulations designed to proce t and promote maximum employee and environmental health and
safety protection for consa uction projects involving potential exposures to lead are still in
regulatory evolution. A fe’ . sUes. su h as Maryland and Massachusetts. have enacted
legislation which effectively nurrors the general indusay lead standard issued by the
•Occupauonal Safety and Heahh Adminis ation (OSHA. 29 C.F.R. Section 1910.1025). for
application in consa-ucuon prcje ts. SULh as demolition. s ucture renovation, and LBP
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abaterne : fte Lead-Based Paint H:z: Reduction Ac:. adopted in i 9. direc:ec OSH.A to
enaLtan sz .ndard to a re s the health inc safet. sue rn’.ol.ec ith p0(e tia! jej
exposures du:ng COnS UCt1Cn aCU’.itieS.
An inte rThai r’ . le published on \la 4. 1993 ith an effecu e date of June 3. l’93 amends
the OSHA standards concerning emplo’ ee protection requirements for conStruction workers
exposed to lead (29 C.F R. Section 1926.62). All construction work excluded from coverage in
the general indus y standard for lead by 29 C.F.R. Section 19l0.1025(a)(2) is covered by this
standard. Construction work is defined as work for construction, alteration and/or repair.
including painting and decorating. It includes but is not limited to the following:
1 Demolition or saI age of structures where lead or materials containing lead are
present.
2 Removal or encapsulation of materials contaiiiirig lead.
3 New cons uction, alteration. repair. or renovation of s Ctures. substrates, or
portions thereof. that contain lead, or materials containing lead.
4 Installation of products containing lead.
5 Lead contaminarioniemergency cleanup.
6 Transportanon. disposal. storage. or containment of lead or materials containing lead
on the site or location at which construction activities are performed.
7 Maintenance operations associated with construction activities.
In light of this interim final rule, demolition contractors must place greater emphasis on
programs designed to minimize and prevent occupational exposure to lead. Training programs.
medical surveillance, respirator protection. equipment and personnel decontamination, and
exposure monitoring must be addressed during the performance of arty work involving the
disruption of suz es which may result in the generation of airborne lead concentrations. The
new reguIation will require serious behavior modifications for contractors nd contractor
employees alike.
Prior to the promulgation of this interim final rule, agencies and organizations have required
limited degrees of worker prottLrlon during batemenc. The HUD Abatement Guidelines specify
worker safety requirements for HI. D ‘SItes. Other agencies. such as Rocky Mountain Arsenal and
the U.S. Army Environmental H iene Agency. require that site-specific health and safety plans
be developed for theu facilities The Denver Housing Authority requires the use of protecu e
-------
u :s a d respirators du ,r ng cutung cperazions These gu:ce:.nes ‘.‘ii! d b’. the
r.c’. OSHA regulanon.
3.2.4 RCRA SUBTITLE D
Subude D of RCRA establishes a frarriework for federal. state. and local go e rimenc cooperation
in con olling the management of non-hazardous solid as:e. The federal role in this
arrangement is to establish the overall regulatory direction by providing m.inirnum nacion ide
standards for protecting human health and the environment, and to provide technical assistance to
states for planning and developing their own environmentally sound waste management
practices. The actual planning and direct impLementation o f solid v aste programs under Subtitle
D. ho’ . ever, remain lar eLv state and local functions.
Under the authority of Sections l008(a)(3) and 4004(a) of Subtitle D of RCRA. EPA first
promulgated the Criteria for Classification of Solid Waste Disposal FaciLities and Practices.
regulations found in 40 C.F.R. Part 257. on September 13. 1979. These criteria establish
minimum national performance standards necessary to ensure that no reasonable probability of
adverse effects on health or the environment” will result from solid waste disposal facilities or
practices. Section 1008 directs EPA to pubLish guidelines for solid waste management, including
criteria that define solid waste management practices that constitute open dumping and are
prohibited under Subtitle D. Section 4004 further requires EPA to promulgate regulations
containing criteria for determining which facilities are open dumps. or those that fail to satisfy
any of the Criteria.
On October 9. 1991. EPA promulgated revisions to 40 C.F.R Part 257. and added Part 258.
These revisions were passed in response to HSWA. Part 258 sets forth revised minimum federal
criteria for municipal solid waste (MSW) land lIs. including location res tctions. facility design
and operauntaileria. groundwater monitoring requirements, corrective a tion requirements.
financial ass rnce requirements. and closure and post-closure care requirements.
amendments to Part 257 were made to make it consistent with the new Part 258. N
monofills are not specifically defined under RCR..’ : howe er. C/D wastes co-dispos .
household aste will be regulated under Part 258.
The cffecthe date of Part 258 is O ..robcr 9. 1993. MSW landfills that receive wastes on or after
that date must comply with all requirement. (with the exception of the Financial Assurance
requirements effective Apnl 9. 199-hi or they will be considered open dumps which are
prohibited. Existing MSW l3ndfills that do not meet specific requirements (e.g . pet a.ining to
-------
pia : . urisc.able ar as. au-cr: . and u e ts have e i “e Pt .i C ..‘c ure
c:: thr e2n October 9. 1996 T nac:rre-.: of these re ulauon rr a r , , ‘izr L :
u :ro err t to some MSW lan s. will li.k y resu! n a reduLucn tn ‘ lS’ . ar. :
3.3 ST TE REGULATORY REOU EME\TS
Be!ow is a summary of information regarding individual states’ waste management pra tice for
CiD debris. Definitions of solid waste and C. ’D waste vary widely from state to State. as do the
requirements for permitting a C/D waste proc:ssing facility. This information is curre.ic as of
May. 1993 and readers should contact state agencies due to the dynamic state of this ISSUC.
3.3.1 NEWMOA STATES
The Northeast Waste Management Officials’ Association (NEWMQA) is a non-profit interstate
association whose membership is composed of the hazardous and solid waste program director’
for state environmental agencies in Connecticut. Maine. Massachusetts. New Hampshire. New
Jersey. New York (hazardous waste only). Rhode Island. and Vermont. NEWMOA was
established by Governors in the New England states to serve as an official interstate regional
organization. An overview of NEWMOA state CiD generation races, definitions of C/D waste.
requirements for wood reuse, and CJD landfill re uirerrtents is included in Table 3.1. This table
was taken from a recent study de% eloped for NEWMOA. The report is entitled Cons uction ind
Demolition Waste Disposal: Management Problems and Alternative Solutions, and was
finalized in December. 1992.
3.3.1.1 Connecticut
“Bulicy” waste is defined as ‘iandclearing debris and wastes resulting directly from demolition
activities other than clean fill.” Bulky wastes are classified as special wastes which require
special handling compared to other non-hazardous solid wastes. “Clean fill” is defined as
“natural soil. roct brick. ceramics. concrete. and asphalt paving fragments which are virtually
inert and pose neither a pollution threat to grQund or surface waters nor a fire hazard.” Areas
which are solely for the dispo il of clean fill are exempt from the provisions of the regu1ation
go%erning solid waste facilities. cr Regulations Chapter 446d. Section 22a .209)
Transporters of bulky wastes are not required to have a special permit. Disposal at bulky wa ce
landfills is limited to bulky w ,i ce be , .au e the cover frequency and groundwater separation
distance are less than for MSW làndfi(l (CT Rei ulations Chapter 44f,d. Section 22a209)
However. buL¼y wastes may be ccn rrun led with municipal solid wastes at MSW facilities.
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I.
TABLE 3 -1
NEWMOA STATES CID DEBRIS MANAGEMENT SUMMARY
NswU.mpchfre New Jer s ey
(IL ) . .t
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MS W issue k I be us pried by
199$ ( ci eab mu ipeluy
6Opesceue lubeusycied
(c v essh cci uep
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NJ D€PE kv uaisp.n acid
ditpo ssl of CID —
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a ssu1its aiiauc, ce
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(JO l 1 5 1 ( 1 err C %eI11 1 4 lia II ,
prnaul.ag p.scss
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5C4 l5bk iCUC 111411
hrnl .I,ng aileliel Io..l
f l oil botl seurI. ,i,.u- ,
and Ilk I . w.usl $1103111
sl u-riiau-k . i , .llc,l as 1 aluIu
I.s .f.iug Riding shuagks
•Inulauu.a OllOhilif Silk I
IIIA%IIII) MsJ flI ,Nia
s.,il .111.1 1&41C 4441 IlgicI
Ak., sh,egjdc .J hues Is Id i
•iSlit•I ,a ,,, , 4 VjL) p
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M.u ,agrinrpj
I. ‘ ‘iii . 1 OjsI •. II,lu-,l
Coonecikui
0 Gs.asds. 01 0 4 kw%1/ferso&ys
M
i C/U
4 (kbur
5 56.000 $Ol3
RhniI. IdonS
20.000
£10 issue is 103 1 1J wllte gCn .I
sued (m. the rezing ..I tillIbJIlIgs
c i ba busi iu s lures
Qiuready ail IandOIh arc unlined
New lt$ Liiiins 1t 4 1 use
doubk hse,g sod less hoc
col i lylisms 1w P45W
Iwil ( lh buS ens fry C l) I.iudhihls
C/U it sIk wrd lube curnnu ,ngkd
soib MSW
No specd ics USI w id hippiuug
a4l Noveagd . ,lained (hI
pissed c v pressau Bussed
wood
4 Iyvigu s —oudca sbe
sued a wok I ( c v
lppbesics Lujbuay
SlidiM. Rsduiy
N _ d.s Iaiçect.sas
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lu-iS 1)UCO1 Isi I Is
Muuai ,u kahsepisP
sit ths.wgP psal . *Iisas
pa kel
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rodectice spiN. sti (u 1 (cd
kMLuIS i bMb s sIe sII e t
10 14 1C 1 hItS
(.W & SW viusog
Senae rhplncaccvt as 1 1 5W
Laillills ockie sa.scs grmmcd
Nce-cbem alIy utised
be
puxeased øciac$h c*, wg kg
reuse
Ckau.a9p vu-sued wpss
i UOd assu be sea so
used I iBs a tug
GW&
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l tdl s
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1 5.4 i& IJ CI hCs4UIltd
NI. 554. Its . , .u.J
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t ts perrruSS’° :o bu.r e: c ed ‘. ccd (e.g . bulk’. v.ocd ::.e:s in
pe utted cod bu i facüi es. : ated ood (e 2 . painted a r.ed and
de olitiOfl ‘hood are excluded (C1 RegularionS Chapter S .uon -:
3.3.1.2 Maine
Maine defines CID debris as debris resulung from “consttucuon. remodeling. repa.Lr and
demolition of snuctures.” and includes but is not limited to “building materials, asphalt. wall
board. pipes. metal conduits. mat esses. household furniture, fish nets. rope. hose. vitre and
cable. fencing. carpeting. and underlay.” CiD debris does not include asbestos or other special
wastes. Transporters of /D U. aste are regui.red to have a special License. (ME Re3uladon 06.
096 Chapter 400)
Other wastes from demolition activities may be classified a.s Inert fill” which is defined as ‘ soi1
material, rocks. bricks. and cured concrete which are not mixed with other solid or liquid waste’
and which are not derived from an ore mining activity.” (ME Regulation 06-096 Chapter 400)
Maine regulations are identical for C/D debris and inert fill. If the Landfill is smaller than six
acres, neither liners nor leachaic collection systems are required. For Landfills greater than six
acres, the regulations for MSW landfills appLy. The regulations also allow the disposal of C/D
debris on the same parcel of land where the waste was generated when the solid waste boundary
encloses an area of less than one acre. (ME Regulations 06-096 Chapter 4.04)
3.3.1.3 Massachusetts
Massachusetts defines C/D debris as “building materials and rubble resulting from consauction.
remodeling, repair, or demoLition of buildings. pavements, roads or other structures.” C/D debris
includes “co ete, bricks. lumber. masonry. road paving materials. rebar. and plaster. ’ C/D
landfills mu ply with the same regulations as MSW landfills. The state also requires that
C/D debris bsiecycled. if possible. The state Licenses local government to ensure that proper
disposal requirements arc met. Transporters of C/D waste are not required to have a special
License. (MGL 310 CMR 16)
C/D debris regulations in via hu ct . New Jersey. and MaryLand are among the most suict
regulations in the coun y Ma 1Lhu ett Is considering closing tis MSW landfills to C/D
wastes. (Taylor. 1992)
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3.314 \ew Hampshire
N .’ . Hampshire defines CD debrLS as on- u: ctbIe buildin rn icer: .!s a j
is solid asce resulting from t.hecons ’uc on. remodeLing. repair. or e
s ucru.res arid rc is. ” CID debns tnc udes but is not lirruted to “bricks. concrete, and other
masonry materiaLs, wood, v.all COVerln2s. plaster. dry wall. plumbing. fixtures, non-asbestos
insulation or roc ing shingles. asphaltic pa ement. glass. plastics that are not sealed in a manner
that conceals other wastes. eiecthcal v.iring. and components containing no hazardous liquid and
metals that are incidental to any of the above.” (NH RSA 149-M) Each town is required to
provide a site for C/D waste. Burning of C/D asce other than wood and fair’ :rnass is
prohibited.
3.3.1.5 New Jersey
New Jersey defines demolition waste as “waste generated from razed buildings, factories and
building s ’uctures. including sueets. roads, and fences.” (NJ Adminisu’adve Code Title 7
Chapter 26) Demolition wastes and cons ’uction wastes are both classified as bulky wastes.
Operating permits are issued for a’anspori- ‘on and disposal of C/D waste.
The New Jersey Recycling Act, passed in 1987, designates recovery targets for each municipality
arid each county to achieve the maximum feasible recovery of recyclable materials from the
municipal solid waste sn’earn. Each municipality has a target of 50 percent recycling by
December 31, 1995. Each county has a rget of 60 percent recycling by December 31. 1995.
(NJSA 13:IE-99. 13.) CiD waste can be recycled and is included in county solid waste recycling
plans. A number of processing facilities operate in New Jersey receiving source-separated non-
chemically u’eated or painted wood waste, concrete, asphalt. brick, cinder block, asphalt-based
roofln scrap, and stone. (Lambert. 1992b)
3.3.1.6 RhodeLiland
Rhode Island def és demolidon waste as “solid waste generated from the razing of buildings
and other built sm ctures.” (RJGL. Section 23, Chapter 18.9) All Rhode Island landfills are
currently unlined. Therefore new draft regulations require double liners and leachate collection
systems for MSW. C/D debris is a1lov ed to be commingled with MSW.
3.3.1.7 Vermont
Vermont defines GD debris as “non-re ’ clable v aste from building material, road rubble and
bulky vegetation.” which weludes ood. pbster. sheeu ’ock. rolled asphalt roofing. roofing
-------
sh rigies. insula on. floorn2. br.c . a on.:. and morar. g!ass. soil ard itone. a d r e (VT
Sci :d Waste Management P ani
3.3.2 OTHER STATES
Other states outside of the EWMOA consortium were also contacted for iriforrnauo . These
states were selected based on previous involvemern in LBP abatement issues. Comprehensive
information on state waste management was not gathered: therefore, the following information is
presented for general considerations.
3.3.2.1 Kentucky
Kentucky requires LBP debris testing only if there is reason to believe the waste is hazardous (as
in the case of abatement wastes), If the TCLP results are above 5.0 mg/L for lead, the waste is
hazardous. If the results are below 5.0 mngfL. but lead is still present, the Waste is non-
hazardous, but landfill operators may call it a special waste and charge more for its disposal.
(Adams, 1992)
3.3.2.2 Maryland
Maryland has s ict req uirements regarding LBP based on volume; however, most abatements are
residential and the volume of disposed debris does not fall under state regulations. (Wojtowycz,
1992) State regulations address limited demolition only, (e.g., replacing a window) and require
testing of debris from nonresidential or multi-unit buildings (e.g., apar ent buildings) for
disposal as small quantity generators. Debris from single-family units is not required to be tested
and is disposed in a municipal solid waste landfill. State regulations do not address full-scale
demolition (e.g., wrecking ball or bulldozer). (Guyaux, 1992)
Regulations de lead-containing substances as paint, plaster, or other surface coating miterial
containing morithan 0.5 percent lead by weight calculated as lead material in the dried solid, or
more than 0.7 mgfcm 2 by X-ray fluorescence (XRF). Waste disposal must comply with
applicable hazardous waste regulations. (Maryland, 1988)
3.3.2.3 New York
In New York, waste disposal is conducted in accordance with applicable solid or hazardous
waste regulations depending on waste identification. Some state regulators are concerned that
the large number of HIJD and state agency abatement and demolition initiatives in the next five
years will generate huge volumes of debris that will exceed available capacities of hazardous
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d ;o ai :n e .A a proach is o har.c. the d :r s 3s a ii ’ ‘ sal ‘asce with
disposal in Subut .le D acUit s in compliance v ,ith P t 2 ‘ !a::cr. f -i .
is contingent upon a federal c :errn ar1cn that tr.e d r: .:- be :assified a
(\adler, 1993)
3.3.2.4 Ohio
Ohio is in the process of de e!oping C/D debris regulations, with new regulauons currently on
hold. C/D debris is cuz-rentl exempt from solid waste regulations and is only regulated through
the state’s air pollution program. Some local health depar:.-nents are more snict than others about
regulating LBP. (Odgen, 199 and O’Connell. 1993)
3.3.2.5 Penn.sylvania
Pennsylvania defines GD wastes as “solid waste resulting from the cons uction or demolition of
buildings and other sm.lctures. including, but not limited to. wood, plaster, metals, aspha1 c
substances, bricks, block and unsegregated concrete.” The term does not include
“uncontaminated soil, rock, stone, gravel, unused brick ar.d block, and concrete” if they are
separate from other waste and are used ,as clean fill. (PA Code Title 25, Chap r 271)
CID wastes from residential, municipal. commercial, or institutional s uctures are regulated as
municipal wastes. CiD wastes from indus ial, mining, or agricultural s ucmres are regulated as
residual wastes that are handled as municipal wastes. If CD waste is disposed in a MSW landfill
or combusted in a MSW incinerator, no prior testing of the waste is required. isposal of C/D
wastes in unlined CID landfills is infrequent and waste characterization is required. (Roof. 1993)
Reuse of CID wastes is subject to the municipal solid waste approval process. which requires
characterization. The state has recently made a determination that reuse of waste wood
cori taining LDP as mulch is not permitted. (Roof. 1993)
3.3.2.6 South Carolina
The South Carolina Solid Waste Management Act of 1991 required the establishment of separate
regulations for MSW, GD. and indusnial wastes. Regulations governing GD landfills were
promulgated on July 23, 1993 and define any waste in contact with LBP as unacceptable for
disposal at C/D landfills. Liners are not required at new GD landfills, hence the definition of
certain wastes as unacceptable
Large quantities (e.g.. dump c’uck loads) of wastes in contact with LBP are considered to be
special wastes, arid each MSW landfill must have an appro cd Special Waste Authorization and
20
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LrnplemeitaflOfl Plan (SWALP ii spec:al ‘ . astes ‘. ill be accepted at that facilir. (Ker..ney. 1993)
The provisionS of the SW.AIP v ica!1v iiclude both hazard c a acterz:non b t. e g rerator a id
per.odic veriflcaflofl by the MSW land il ope acor (Kennev. 1993) Small qua nes of LBP
debris (e 2.. single pichp m.ick loads) senerated by renovation or dernolidon of small s uctures
(e.g.. barn or tool shed) may be considered to be household waste and are not subject to generator
characterizadon requirements. (Kennev. 1993)
The commercial burning of eated wood is allowed only at faci1i es permitted to dispose of
hazardous waste, including cement i1ns permitted under the Boiler and lndustiial Furnace rule.
(Kenney 1993) Homeowners may burn natural scrap wood, such as ee stumps. on the property
where it was feUed. However, wood products “made by mann can not be burned by private
cinzens. (Ohlandt, 1993)
3.3.2.7 Washington
Seattle is developing a constiuctlon waste recycling guide that discusses types of waste
generated, available waste management facilides, and capacity limitadons. In the Seattle area,
none of the recycling facilides will accept wood containing LBP; it all goes to landfills. (Grave
de Peralta, 1993)
3.4 COMMERCIAL FACILITY REOUTREMENTS
In addidon to federal, state and local LBP debris requirements. commercial waste management
fadilides (e.g.. landfills, eaunent and recycling facilides, transporters) may require their
customers to comply with addidonal condidons. Commercial facilides need sufficient waste
analysis data to support technical waste management decisions and to avoid potendal liability
issues. (Knapp. 1993) Hence, these facilities may prescribe addidonal sampling and analysis
requirements for LBP debiis.
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4.0 GENER.ATIO OF CD DEBRIS
4.1 SOTRCES
Cons uc:cn and derrioli on (C/D) debris containing lezd-based paint (LBP) is g e:ated by
federal. s.are and local agencies, and by the private Sector. Reliable data are not a atlable to
predict the quantity of LBP debris generated, to deterrrijiie the portion of this debris that is
amenable to recycling or burning, nor to determine the economic viability of demolition projects.
The following limited information is available.
4.1.1 PRIVATE SOURCES
LBP is found in private residences located mostly in cities known as the “Lead Belt.” which are
older homes consm.icted in the early 1900s, mostly located in the northeast and midwest U.S.
(Lambert. 1992) In the New England area, LBP was frequently used in the Cons uction of
utilities and interior/exterior finish of houses. Debris components include lead pipes, painted
woodwork, furniture, utilities, and painted exteriors including siding, shingles, doors, and sashes.
(Higgins, 1993) LBP is also found in newer suUctures, because paint containing high levels of
lead was in widespread use through the mid- 1970s. Large snuctures such as hotels are major
sources of debris containing LBP.
Other private sources of debris containing UP include izidus ia] facilities such as factories,
warehouses, mills, refineries, and other complexes undergoing renovation or demolition. These
facilities will typically have higher percentages of non.permeab!e components such as tanks,
drums, and s uctural steel that may be coated with LBP for rust-proofing. The high salvage
values for these components make them s ong recycling candidates.
4.1.2 STATE/LOCAL SOURCES
State and munici J facilities include properties such as civic buildings, hospitals, schools, and
police and fire departments. Many of these facilities, together with public housing projects, are
older, arid are potential sources of LBP. State and local governments are under increasing
financial pressure, and therefore have been selling properties as a means of generating additional
revenues, the sale of which may include the demolition of unwanted buildings. Agir ainted,
nonperrrieable snuctures that will require demolition are also common, such as bric Mater
tanks and fuel tanks.
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4.1.3 FEDERAL SOURCES
Federal facilides include Civic properties. U.S. Depr.rnenc of Defense (DOD) pro ertjes and
U.S. De;ar -nent of Energy (DOE) properties. DOD properties are the major SOurc of C/D
debris. g erated asa result ci the Base Realignmerc and Closure (BRAC) which is reducing and
eIiminad existing military bases. As these bases a e reduced, buildings are being demolished
requiring disposal of the waste debris.
Sources of LBP at DOD facilines include painted military equipment. machinery, army barracks,
and housing units. It has also been reported that excess ship paint, with high lead concen adoris,
not used on ships had been instead used on military hardware. The DOD also used exu a
battleship paint on government furniture through 1974 (Burkle, 1992). Other sources of LBP in
military buildings can be found in glazed glass and window areas. The DOD estimates that
billions of square feet of World War [ I barracks contain LBP.
DOE activities are another major federal source of demolition debris that may contain LBP. The
decontamination and decommissioning of DOE facilities will generate large quantities of debris.
Unlike residences and office buildings, manufacturing facilities contain debris types such as
tanks and steel work. These less-permeable debris components are suong candidates for
recycling due to their high salvage value.
4.2 TYPES AND OUA 1TF!ES
The quantities of C/D waste reported in various locations across the nation vary widely, ranging
from 0.12 to 3.52 pounds per capita per day (pcd). A 1988 U.S. Environmental Protection
Agency (EPA) Report to Congress on solid waste disposal estimated approximately 31.5 million
tons per year of C/D waste based on an average generation rate of 0.72 pcd. (EPA. 1988)
However. morn ent studies have suggested that this value is underestimated and that it is not
possible to relia estimate CiD generation rates due to the large number of variables associated
with C/D waste generation. In fact, in the 1990 and 1992 updates of the EPA report
Characterization of Municipal Solid Waste in the United States, CID generation rates were not
included by Franidin Associates because there are no dependable figures or disposal practices at
the national level. (Lambert, l9 2) Some of the factors that conuibute to variability include the
following:
• population and employment in the area
• the overall level of economic activity
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• the extent of road- or bnd2 -related conSfluctlon. rerrnvauon. and derr c1i on
• ex aordinary projects such as urban renewal, hurricanes. swrrri damage. tires or
disasters
• records of actual CID disposal at landfills arid other disposal sites
• past and future uends in C/D activity. (C.T. Donovan, 1990b)
This significant rate of generation. coupled with the declining availability of landfill capacity,
creates a growing disposal problem that can only be solved through recycling, reuse, and burning
options.
It is estimated that C/D debris comprises 14 to 25 percent of the total waste steam in any given
state, depending on the majority of the development density, urban or rural in makeup. (Fowler,
1991) The C/D wastes include discarded building materials and rubble from the consmicdon
renovation, repair and demolition of buildings, bridges, roadways, retaining walls, and other
s ucrures. (Lambert, 1992) Lead may’be found in CID waste sites receiving debrL in areas
(northeast. midwest) where the use of LBP was common until 1974.
A study on the composition of C/D waste in Vermont revealed that wood comprises 25.6 percent
and metal comprises 5.1 percent of total C /i) waste in the stare. In Rhode Island, wood in C/D
waste comprises 13.3 percent of total landfill waste. Table 4-1 presents the findings of the study.
(Fehrs, 1993)
TABLE 4 - i
WASTE COMPOS1TIO 4 (PERCENTAGE) IN C/I) DEBRIS
W M Tvi e V rmnnt Rhnd Tcbnd
Metal 5.1 5
Wood 25.6 133
Asphalt NR 47.1
Concrete 14.2 16
Ash 91 NR
Miscellaneous 45.9 18.6
Source: (Fehr5. 1993)
A waste composition study commissioned by the Toronto Works Deparniient in 1991 evaluated
the composition of demolition wastes and combined CfD wastes delivered to the local landfiljs.
Recycling rates ere not considered, arid the data did not account for any material removed at
the demolition site for recycling or reuse. The composition analysis is presented in Table 4-2.
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TABLE 4-2
C WASTE COMposmoN (PERCENTAGE) [ N METRO TORONTO
Wa r T flernnlitipn On Cpnibined C/fl
Wood 51.8 34.8
Rubble, A gregaze,
Ceramics 24.7 24.1
Building Materlais 7.9 16.6
Ferrous Metals 4.7 7.3
Paper. Paperboard 0.7 . 7.8
Glass 0.0 2.8
Plastic 0.7 2.5
Fines 8.7 1.9
Miscellaneous 0.8 2.2
Sowte: Meiropolitan Toronto Waste Composition Swdy, 1991
(excerpted in Gershmaji, 1992)
Note: AU fleures are based on percen e weieht
A major future source of demolition debris containing LBP will be deficient steel bridges
requiring replacement. Based on the National Bridge Inventory, 185,928 of the 208,505 steel
bridges carrying public roads are covered with LBP. Approximately 103,191 of the 208,505
bridges are classified as deficient and eligible to receive federal replacement funds. (Ca.rlson.
1993)
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5.0 SAMPLE COLLECTION
Sampling heterogeneous solid waste is an important step tn evaiuatin2 thsposai opoons for
COnStrUC On arid demolinon (CID) debris. There are a variety of approaches cu. entiy in use for
collecting representauve samples so that appropriate management decisions can be made. n
this section of the report. current approaches for sampling permeable componenr.s of buildings
and demolition debris are summarized. Using these techniques. and incorporanng knowledge of
U.S. Environmental Protection Agency (EPA) sampling protocols for other types of media, this
information is synthesized and expanded to evaluate the sampLing options for pemieable debris
- that will best produce quality represe itative data.
Section 5.1 presents the current approaches being used. Section 5.2 presents six hypothetical
sampling approaches and compares the reLative cost and confidence level of each hypothetical
approach. The information presented in Section 5.1 and 5.2, current and hypothetical sampling.
approaches. respectively, was used to develop recommended sample collection protocols, which
are presented in Section 5.3.
For the purposes of making hazardous or non-hazardous determinations regarding buildings and
demolition debris, these sampling options assume no other hazardous materials are present (e.g.,
asbestos, polychiorinated biphenyls) and that lead-based paint (LBP) is the only “hazard of
concern.” It is also assumed that metal components of the structure (e.g., I-beams, piping,
ductwork, siding, flashing. metal window frames) and any other non-permeable components will
be se egated and recycled or reused for their salvage value. Therefore, this section will not
address sampling these non-permeabLe components.
ft is important to understand that, when developing sampling options for buildings and
demolition debris, suucnires can vary widely, ranging from small and simple structures such as
family dwellings tomedium-sized smictures such as office buildings, to large and more complex
structures such as Lndusirial facilities. Therefore, sampling protocols should be able to
accommodate a wide variety of structures.
Data quality objectives (DQOs) are an important aspect of any sampling protocol and must be
carefully reviewed prior to planning and execL ig a sampling event. When trying to determine
sampling options, some of the following quest s must be answered to clarify the DQOs:
I What sample collection method sh. 4 be employed to adequately characterize a
building (containing components with LBP coatings) as a hazardous or non-
haz.ardous waste?
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2 Does at samp: :oUec on method result in data repr sentadve of the material.s to be
disposed or rec c ed after dismanüing or demolinon, uch may L”.clude unpainted
components as ‘ .eU as painted components?
3 Is that sample col .lecuon method cost effective?
4 How w J1 the sample be (physically) collected?
5 At what frequency (how many) should samples be coUected?
6 Will the samples be composite or grab samples?
7 Will the location of the samples be selected randomly, by best professional
judgemenc., or on a grid pattern?
8 What rype of quality conn ol samples should be collected and at what frequency?
The current analytical method being used to make hazardous or non-hazardous determinations
for demolition debris is the toxicity charactertstic leaching procedure C1CLP), which is discussed
in Section 6.1. The TCLP method has a regulatory threshold of 5.0 mgfL for lead. It has been
questioned by some whether or not the TCLP method is representative of actual landfill
conditions for solid waste or demolition, debris. (Rupp, 1992) Despite this question, the TCLP
method is the prescribed analytical method at this time. For the purposes of this section, the
reader should assume that TCLP will be the analytical method used and that the sample will be
prepared according to the preparation technique required by the method or the laboratory.
5.1 CURRF NT APPROACHES TO SAMPLING cm DEBRIS
This section summarizes the available sampling techniques based on a comprehensive
information gathering effort for this topic. Seven approaches to sampling LBP debris were
identified as being in use or under development. Table 5 -1 briefly compares and summarizes key
(actors associated with each method. A detailed discussion of each method follows.
5.1.1 U.S. ARMY ENVIRONMENTAL HYGtENE AGENCY
The U.S. Army Environmental Hygiene Agency (AEHA) developed a sampling protocol for
building demolition debris and buildings painted with LBP in October of 1992. (AEHAI 1992)
Problems associated with the disposal of consuucdon debris, particularly debris “contaminated”
with LBP, and the lack of specific regulatory guidance prompted the AEHA to develop their own
sampling protocol Development of this protocol was funded by the United States Army
Environmental Center (USAEC) and AEHA is seeking “approval” of the protocol by EPA.
(Hauschild, 1992) EPA’s Offlce of Solid Waste and Emergency Response (OSWER) has
27
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TAIILI S — I
COMPARISON OF KNOWN SAMI 5 UN( AI’I UOACIWS
Shmp lc
T m
Di pi i ul (Icloic Dcoulitinn.
ddcrmIflatiofl of
WhOICWIIeIUrC
ttchrii ___________________
iL ii, ci i i iii iii .iiiI ly ‘‘ii
lMit ih1. X 14 1: :Vi t .iiiJ
c Iiiuuiic iii p... flIt .1 III I .i. i_
nat Iflh. I hr . •nn’.t
A nnrondi
Purpose
Sample Sample
Number 1oea lrnn Mel hod
AGIIA -
Developed (iw
dcmoIit osd$çj ,
s 1 irc
pcrmcabli laid-
bued painted
cons*rijciion
material: wood,
hrig k. cement mu
pl after/will howl.
Rckiic I.)cmu moo.
.
Number of sample
huikiings is statistically
dciermincil. Sin Io
cniuposltc sample per
buikii ng.
I aniLviuIy elcucd.
( IIc-InLlI dill ha
coring thr .ui h entire
s .h sraic. riillcc. ihill
cioting. and dust in
dicposalilc sample
cnnhlincr
l)cvcl,i 1 itl Ii .. nuu.u.i.u .
iiuiilnr SIIiILlIIIC lIun in ii c
c 5hIiIl 1 .liiiii in lieu s.f Us
sampling bccum.c sul(icicni
late is ons Icrc&$ in he
.wu .Iuhk
l) IIA
L)cvchpcd nw bilk
material from lead
abatement projects.
After I)cinailiiuw.
()uc TCLl’icu pc i 1usd
of Ws Ic. (i.e.. 60 1K) kg
of waste).
AIIisndssieI
removed (ruin the
abated sivueturc.
S w lu4 . .s.ut . ,s.il nil.
picec . CuslksI
sawulsisi.
Msit. l,l. .ps . .ss.iy I . ..
.applu.ulsk liii ds.nu. .lsii . .ii
pruijecis
(MA
Dcvctupcd For i .
future usc stnieswcs
Specific foi porous
maictialsooly.
ftcfisrc t)cmoli*iim. Uptu SO ilic 1uuts PC I
composite sample.
.
livenly paectl
systematic grid
w/uniFnrmty si cd
aliquol grid sites.
Cusru.ig wilts s.uh k-
lipped or diurnood-
tipped drill bus
dcpcrnhng on sample
uusairus. Cnislictl using
i w crusher
l’ .sIlku .I tslslIiI .I ii iki,i .Is .I
analysts cit .alicinativc.. 11)1
building lcunsng or
if ciii future u SC Sit ul ilulILs
C1’A Kcguuui VII
1)cvclnpcit Fir
pcrmcsblc matrices.
,i . u1 ((3f y
contaminant.
ftcfuirc unit After
Ucunoliiinn.
Cuunpos.tc auuptc (mu.
buiWing with an anal
esleni of 2500 sq. (cc l.
Risu,( IO’ .
Windowsills 10%
Auic 10% Molding
IO’L floors 20%
IIVAC 20%
J3zicrior 10%
Interior 10%
New 1/1-i .. lull hit
(iii most coInponecils.
3/&-in carhusk ha ( v
conurcic. Ciu lle i.l wail.
linnil-helul Vacutirn.
l)cvs.hspc .l iii .lsisuusiutt
sh rnui,vcs br dc,isssIuiuini
smut disposal iii St it hues
sluicil liii ian luulsuic
occup.um.y
Iuudcpcuuulcnt I ‘ unsy
l)ispuaal
ulcIe,,niflattIlflI of
‘w bole. ZUUCII IrC
ikbrls.
After Dcu .iuhiiumn.
Non.spcuuIuc
(rqircscnialivc wclg ltlcu
sample).
Kauduimly .cki lcu$.
Nuio -slucsi1u .
M.uss wc,t:luuu tilL l( suiii. I.
I CI SI IIICSLfltfluIifli Sit (IlL!
l)eiuuulutuinCuotr.u. luir
Uspusul
ukiermin u ljiwl.
Nusuu -bl .ccbf ic.
Non- spcs i1s .
Non-spce ul uc.
1/Xiau. 1 uuintti lIui .sisgts
efluliC uds tiiuIc
‘)IPX. eu,su,suu .uiuuujs ..ani I iii
I d P
XKfrcidi’tg of all
painicd sul(accz.
Non-s pc i.uf a c.
flassd uii t1ntt4%u 1 1
XHF dcvusc
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re’. ev .ed ar.d comrne ted on AEHAs sampLing protocol. Wiie c: ipp-:. . cr
ceriving the rozocoI. OSWER azeed with many e!eme.lts of AE .
AEH.As sampling protocol is b ed on charactenzuig a large number of buiithngs s c i as th e
at an Arms base. AEHA looks at a “popula on’ of similar buildings and szausnca.i.i deterrr. .z
the number of buildings to be sampled from that population. The derived number of buildings
are then randomly selected for sampling. The objective is to obtain from each selec:ed building
one composite sample which should consist of the appropriate propornons of all materials, both
painted and unpainted, represented within the suucture.
Non-permeable building components such .a.s glass. screen, aluminum siding. metal duct work.
and utility equipment are not sampled. These components are segregated and disposed
separately or recycled. In general. the most commonly sampled components are those permeable
mathces such as wood, brick, cement and plaster/wallboard that are likely to have LBP-coated
surfaces.
Each homogeneous building component within the s ucture, both pa:inted and unpainted, is then
identified. The number of subsamples taken from each homogeneous building material is
determined by the proportional surface area of the material based on estimated square footage.
The total estimated areas of each homogeneous building material are then compared to one
another in order to establish ratios. The rados will determine the number of subsamples (volume
of subsample material) to obtain from each individual area; Generally, 20 to 30 subsamples are
necessary to make up one I 10.0-gram sample (voLume required for TCLP analysis).
Each subsample is collected using a one-inch drill bit by coring through the entire subs ate
(where feasible) and collecting the sampled material into a disposable container. After
compositing.based on ratios defined by estimated surface area, sample material is n ansferred to
a clean plastic big, labelled and shipped to a certified analytical laboratory for TCLP analysis.
Analytical resuthire statistically analyzed to assessthe variability among the s uctures and the
overall normality of the lead disuibution. If the analytical results do not indicate a normal
disuibution, AEHA u ansforrns the data according to EPA guidance SW-846, November 1986.
Test Methods for Evaluating Solid Waste (Volume II), 3rd Edition. Aft r normality has been
achieved through an appropriate u ansformadon. the 80 percent confidence inter val.is calculateJ
and compared to the regulatory threshold of 5.0 mg/I.. for Lead, similarly ansforrned. as
appropriate. Note that dunng th&.r review of the AEHA protocol. OSWER indicated that thu
uansformations are not recomrr.er ded (EPA. l993a) The AEHA agrees that data ansforrria cr
-------
ma” not e an efltire y valid a proach. hc’.;e’ .er. the AEHA his also noted that e’. n a
percent confidence nrerval of the raw data is not si nsc .ally valid due t : e non-
normal data dis ibuuon. While neither accroach ma . be entirely appropnate. the AEH.A
considers the use of oansformations as acceptable if data normality can be achieved. (Hauschiid
1993b ., AEHA’s interim final report presents data acquired using this protocol. The conclusions
and recorrirnendanons from this interim final report are excerpted in Section 11.3.1
5.1.2 DENVER HOUSING AUTHORITY DENVER, COLORADO
The Denver Housing Authority CD HA) determined the riced to develop a procedure for sampling
btdk materials removed from structures during LBP abatement procedures. Though the
procedures developed were specifically designed for use in abatement projeCtS the
methodologies may be applicable for demolition projects. As conveyed in a letter from DMA to
the U.S. Department of Housing and Urban Development (MUD) Office of Public Housing, state
hazardous waste regulations specifically state that “all material abated wili be tested for toxicity
by TCLP. All material reported to leach lead at (5.0 mg/LI or above is hazardous id will be
treated and disposed of as such.” (Ward, 1991 b)
The DHA in conjunction with EPA Region VIII and the Colorado State Department of Health,
Hazardous Waste Management, developed a procedure for TCLP testing of abatement wastes
that in effect uses a load averaging method for sample collection. Note that this method applies
to debris after abatement has occurred, in contrast to the AEHA approach, which samples whole
structures prior to demolition.
The DHA inethod requires one TCLP test per load a! waste (load equal to not more than 6,000
kilograms). EPA Region VIII recommended that DHA follow the sampling protocol similar to
that used in niiüng waste, which requires the calculation of given proportions of the items
contained in the load and reduction of the particle size so the material can be accurately
measured and d1 o1ved during the analytical process.
DHA’s method requires that a cutting area be set up to saw bulk materials into pieces. DMA
requires specific safety procedures for worker protection which vary depending on whether the
cutting area is set up inside a building or outside. Bulk materials are segregated. and like items
are placed together. The volume or weight of each group of items to be sampled is recorded.
The items are cut into lengths using a circular saw. Sawdust from the cutting operation for each
pile is collected and saved in sample containers (approxirriatelY 100 grams of each representative
material is collected).
30”
-------
After alcuIaung the percentage of eac .1 the represented atenals b v eight or ‘volume in the
aste :Jes. the sawdust is measured usuig a graduated cylinder or gla ; beaker to orrelare with
recorded volumes or weights to get a properly proportioned sample. The measured sawdust from
each material is placed in a sample container and submitted to a Laboratory for TCLP analysis.
Other EPA reviewers have evaluated this approach. A representative from EPA Region I
Environmental Services Division (ESD) agreed that this approach was “rational.” (Spinier.
1992) A representative from EPA’s Environmental Monitoring Systems Laboratory - Office of
Research and Development (EMSL-ORD), Las Vegas, Nevada, agreed that in terms of obtaining
a “meaningful” sample, bHA’s approach was “not bad.” (Vincent, 1992) -
5.1.3 ROCKY MOUNTAIN ARSENAL - NO FUTURE USE STRUCTURES
Rocky Mountain Arsenal (RMA) - No Future Use Structures Sampling and Analysis Work Plan.
prepared in July. 1991 by Greystone Environmental Services, Inc. (Greystone Environmental
Services, 1991) presents options for sampling buildings based on history of use. Although this
report does not specifically address LBP as a potential contaminant, this procedure is relevant for
structure sampling protocols.
A panel of 12 accomplished specialists was assembled to provide guidance and support for RMA’s
effort. One assumption made by the panel was that the primary assessment criteria would include
use of the TCLP (modified or expanded listi for ultimate disposal/remediation decisions. The
panel devised a sampling protocol that assumed all process equipment and piping wOuld be
removed from the building prior to demolition due to no future use status. The RMA protocol is
for porous materials only. Non-porous materials were not sampled as these materials tend not to
absorb chemicals.
Muld-aliquot s pIes consisting of various smicture mathces are collected on an evenly spaced
systematic grz p*uern (based on volume and excluding interior Space) to provide representative
composites of the mathces comprising that structure’s interior. The approach involves
subdividing structures into uniformly-sized aliquot giid sites of 10 cubic yards or less within a
volume of 500 cubic yards or less. The grids are distributed throughout the entire structure’s
interior. Each 500-cubic-yard grid represents one composite sample. To collect a representative
composite sample from the grid, each sampling grid is subdivided into 50 individual aliquot grid
sites representing. at most, 10 cubic yards. An aliquot is collected from the interior of each
aliquot site. Upon completion of sampling. aliquots are composited into a single sample -
containing a maximum of 50 aliquots. For each structure larger than 500 cubic yards. moreihan.
-------
one composite sample IS collected. For example. a sn ucture ‘ . hxch is 660 cubic ‘ards in size s
represented by two Composite samples. each represenung apProxImately 330 cubic yards For
smicrures which are less than 500 cubic yards. grid sizes are altered so that a rrunirriurn o :c
aliquoc.s represent a Composite sample (e.g.. I aliquot grid site is less than 10 cubic yardsi
Each sample maoix is physically collected using power drills with carbide-tipped drill bits and
coring devices with diamond cores. The choice of cools is based on the depth and type of
material within an individual snhlctiire and professional judgement of the sampling personnel.
Collection of drill cuttings is accomplished by the use of a hand-held vacuum cleaner or an
industhal-grade vacuum cleaner depending the type of mathces being sampled and the
required sample depth. The vacuum cleaner fiber filter (hand-held vacuum) or the iacuum
cleaner bag (large vacuum) is dedicated to each composite sample and each aliquot mauix being
collected to minimize the potential for cross-contamination. Aluminum baking pans, or
equivalent, are utilized for the collection of drill cutthtgs from locations where a vacuum cleaner
is not effective.
Concrete cores are crushed using a Jaw Crusher. Aliquots to be homogenized and composited
are collected from the Jaw Crusher receptacle and placed within a plastic bag for homogenization
and eventual compositing.
5.1.4 EPA REGION V I I
A debris sampling method for permeable mathces was developed by EPA Region VU to determine
altexnatives for demolition arid disposal of smictures slated for no future occupancy. (Keffer,
1990a) AriEPA Region VU staff member was also on the R.MA panel of specialists and had
significant input to the sampling technique developed for RMA. This method is not specific for
LBP contamination.
As at RMA, wu aliquot composites are collected by a powered hand drill and a portable
vacuum. To ens ie adequate sample volume, a range consisting of 20 aliquots (equal to no less
than 4 ounces) to 50 aliquots (equal to no more than 8 ounces) is collected. Aliquot sample
locations are collected at a frequency of I per 10 cubic yards (as debris) or I per 200 square fcct
(as built). Single composite samples are taken from sm.ictures with an areal extent of 2,500
-------
square feet or less. For lar2er structures multiple samples must be collected. The opumaj
f dismbuuon c .thquot.s is as follows:
Sample Matrix Percent Distribution
Roof 10%
Window sills (e’tenor) 10%
Attic or crawl space structare members 10%
Ground floor moldings at floor surface 10%
Floors 20%
HVAC ductwork 20%
Exterior walls 10%
Intenor walls 10%
Samples are collected by drilling through the entire bui1din material with new 1/4-inch drill bits.
A 3/S-inch carbide drill bit is used for concrete (with the objective of generating no more than a
single sample volume). Drill cuttings arid associated dust are vacuumed with a portable hand-
held vacuum. At the completion of sample collection, the entire contents of the vacuum head.
including the fiber portion of the vacuum filter, are packaged in a certified clean 8-ounce wide
mouth glass jar and sealed for transport to the laboratory for analysis.
5.1.5 INDEPENDENT LABORATORY. LOUISVILLE, KENTUCKY
This laboratory samples whole-structure debris with LBP coatings and analyzes lead by the
TCLP method for disposal determination. (Schmidt, 1993) Due to the fact that there are no
current regulatory guidelines, they perform these jobs on a case-by-ca.se basis using “good
common sense” to get representative samples of the various building components.
One method is to separate the components by type and either analyze separately and adjust the
results based on proportion by weight, or collect a weighted composite sample. LI possible. a
piece of debris is broken off to represent the entire thickness of a substrate, then it is crushed and
collected as a sample. If it is not feasible to sample the entire thickness of a substrate, some
known pomon ofthe substrate is sampled and the resulting lead concentration is calculated over
the entire subsb thickness. When using this approach, assumptions are made about the
homogeneity of the lead distribution through the substrate, and about the depth to which the LBP
has penetrated.
5.1.6 DEMOLiTION/LEAD ABATEMENT CONTRACTOR - PEABODY,
MASSACHUSETTS
This contractor uses a 3/8 -inch punch to generate a 3/8-inch-diarrieter by 3/8-inch-length core.
The sample is collected by punching through the entire substrate to obtain a sample
33
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represent2ti e of hat :s to be disposed. (Higg:ns. 1993) This 3 /8-inch size ‘as selected
because it v ’ iil lit through a 3 S-inch screen reCuLred by laboratories for TCLP method
prep anon. The con ac:or assumes that these plugs are rot further processed ‘ground) by the
laboratory and therefore the paint remains intact on the surface, unlike drilled Cores or sa dust
from cross-cuct ng methods.
This corleactor has seen many TCLP (lead) threshold exceedences for abatement debris. En
estimation. 90 percent of exterior components fail including, but not limited to. exterior siding,
doors and window frames. (Higgins, 1992 and Hisgins, 1993) The çon actor believes that it is
the sampling technique and not necessarily the selected sample location that affects the Outcome
of TCLP results for Lead.
5.1.7 CONNECTICUT DEPART yr OF ENVRONMEN ’r u PROTECTION
The Connecticut DeparuTient of Envjronnien a Protection (CT DEP) is developing an approach
that will rely primarily on portable X-ray fluorescence (XRF) readings to support sampling,
segreg tion, and disposal decisions during whoie-su ucture demolition. The approach.under
developn cu t1 includes the following steps:
1. Characterize painted surfaces using a portable deep pene ating XRF device and
select the average, or perhaps the highest, XRF value.
2. Estimate the painted surface area.
3. Determine the product of the painted surface area (2) and the XRF concen ation (1)
to yield the mass of lead in the stiicture (safety factors may be recommended to
provide conservative estimates of total lead ma.ss due to potential error in surface area
determinations and XRF readings).
4. Estimate the mass of the smzcuire to be disposed using average densities and
estimated volumes of building components (e.g.. wood, concrete, brick, plaster).
5. Detàüijnc the estimated lead concentration in the su-ucture using the estimated lead
mass , .(3) divided by the estimated building mass (4).
6. Compare the estimated lead concentration in the structure (5) to a “recognized value”
(e.g., 50 mgfkg total lead which represents a dilution factor of 10 compared to the
TCLP method limit of 5 mgfL).
7. If the estimated lead concentration is higher than the “recognized value,” then handle
the building as a hazardous waste or perform more sampling, and possibly
segregation, prior to demolition.
8. If the estimated lead concentratjon is lower than the “recognized value,” then handle
the building as a non-hazardous waste. (Binrtell. 1993)
3.1
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Informanon may be obtained b concacung the Waste Englneerin2 and Enforc ent Di’ i ion of
the CT DEP at (203) 566-4869
5.2 HYPOTHETICAL SAMPLING OPTIONS ANALYSIS FOR PERMEABLE
DEBRIS
When evaluating the potential options for sampling permeable components of buildings and
demolition debris containing LBP. the interests of the various parties that may be involved,
including homeowners, demolition contractors. recyclers, landfill operators and federal, state,
and local agencies. should be considered.
To protect human health and the environment, a conservative approach is used in making
determinations about the hazardous/non-hazardous status of demolition debrisand the regulatory
threshold which determines its fate. However, rigorous procedural requirements and
conservative regulatory thresholds can actually increase exposure problems by providing
regulatory and economic impediments to demolition or abatement. Any procedure yielding
results that frequently exceed the regulatory threshold will increase the amount of debris sent to
Subtitle C facilities, decreasing the remaining capacity and increasing the cost of demolition.
High demolition and disposal costs may result in buildings containing LBP being left
undemoLished. Instead of managing the LBP debris, the LBP coatings and surrounding
contaminated soils would be left available to the public. (SpinIer, 1992)
The besrcombinadon of environmental protection and cost-effectiveness is accomplished with
approaches that segregate lebtis components and confirm hazardous determinations by TCLP
analysis. This strategy tends to maximize the volume of non-hazardous material available for
recycling and minimize the volume of hazardous waste. Screening tools such as X-ray
fluorescence and chemical lead screening devices should be considered to support the
segregation of nents prior to each TCLP sampling event. See Section 5.3.1.3 for a
discussion of these screening devices.
Sections 5.2.1 and 5.2:2 describe a matrix of hypothetical options for whole-structure sampling
approaches (prior to or post-demolition) as outlined in Table 5-2. These options assume that all
valuable and easily salvageable components. and all non-permeable (metallic) components have
been removed from the structure prior to sampling, and that noother potential hazards, such as
asbestos, exist. The hypothetical options are very general. but they present a variety of
approaches to accomplish representative sampling.
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TABLE 5.2
HYPOTIfETIC L OPTIONS FOR SAMPLING PERMEABLE DEBRIS
HYPOTHETICAL OPTIONS FOR SAMPLING PERMEABLE DEBRIS AFTER DEMOLITION
.*
D mantle!DemotiTh
Se re ate LVisuaI)
Hazard DeteruhinadoD
1An slvtfeafl
Handling
flkpnc L(Reevc l e
1.
• D’stnantle all permeable
components separately
.
Pb-painted wood
• Clean wood
• Other
• Each homogeneous p’le
(N samples)
H 2 dflUS
• Handling
sTransport
• Recon s
•TSD
Non.Hazardnus
T
. Dismantle permeable
UP-covered components
only: Demolish
rernainderof permeable
components no
se ratiori
• Pb-painted permeabLe
debtis
• All other permeable
materials
-
• Pb-piles (N samples)
• Heterogeneous pile
(L sample)
• Handling
• Land Disposal
‘Recycling
• Burning
3.
• Demolish permeable
components in enare
smicnn’e (no se e arion’,
• All permeable inarerials
(no segregaflon
possible
• I etetogeneouS pile
(I sample)
—
HYPOTHETICAL OPTIONS FOR SAMPLING PERMEABLE DEBRIS n coREDEMOLmON
#
Hazard Determinadon
(Sampling) 11 n lvthiJ1
Di mantI memol l sh
Handling
Dkpnc al1R vcle
4.
• Each homogeneous
peniablecomponent in
su ucw( he*herorno
it con ã LEP)
• Nsasnp!eSOfperTfleable
components
• Dismantle Pb components
in exceedence
• Demolish remaizidet(no
segregation)
Haz rdnu
• Handling
• Transport
• Records
•TSD
—
5.
6.
• Pb-painted permeable
components
Subsamples for all other
permeable components
• SubsampksC rall
permeable components
• Pb permeable
component samples
.
• Composite of all other
permeabLe components
(I s sn le
• Compostieo(aJl
permeable components
Dismantle Pb components
in exceedence
• Demolish remainder (no
segregation)
-
DemOlisheit eSWUcCU
(no segreganon)
Non.H zardous
Handling
• Land Disposal
• Recycling
-•
(1 s rrwle
.
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These hypocheucal approaches all requLre e sampler to make decist is regarding to
representauvely Sample and create compos 1 te samples from one or more waste pile
SW-846 Test Methods for Evalua ng So1i a Waste presents EP\’s accepted approach to the
challenge of sampling and composiung samples from waste piles. Inherent in this approach is
some element of diluuon due to the fact that wastes pdes can never be totally homogeneous and
that it is technically and economically infeasible to sample the entire waste pile. SW-846 accepts
and recommends the analysis of composite samples and if necessary. reanalysis of recomposite
samples to determine the variation of waste composition over time and space.
It is important to note that disposal requirements are often determined by local and state disposal
regul tions. Additionally, recycling options are usually determined by local markets (availability
and profit margin). Sampling options and protocols should give results that are “meaningful for
ma ng the determinations necessary to manage demolition debris in compliance with local
applicable or relevant and appropriate requirements (AR.ARs). A brief discussion of each
hypothetical option follows.
5.2.1 SAMPLING PERMEABLE DEBRIS AFTER DEMOLITION
The first three hypothetical options assume that the permeable components of the s ucture will
be sampled after demolition with the clear advantage that the analytical data presented would
represent the load that is to be managed.
5.2.1.1 Dismantle and Sample Each Building Component (Option 1)
This option assumes the owner/cona actor will dismantle all building components separately.
Each material would be segregated and placed in separate piles (e.g., painted wood, painted
wallboard, clean wood). Each pile would be sampled and the sampled material prepared for
analysis. A corresponding hazard determination would be made for each pile.
One pending aj don is, will disposal facilities require analytical data for all solid wastes to
ensure that thefare non-hazardous? For instance, will a municipal solid waste landfill operator
require data for the unpainted (clean) wood? The answer may vary from state to state and could
affect the extent to which dismantling and Sampling of unpainted building components would
actually be necessary.
- 37
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5.2.1.2 Dismantle and Sample Each Lead Component/Demolish Other Components and
Sample Composite ‘Option 2)
This option assumes the owner:conuactor wdl dismantle all permeable building components
coated with LBP prior to demolishing the remainder of the sttucture. Each building material
coated with LBP would be segregated and placed in separate piles (e.g.. painted wood, painted
wallboard, painted wooden window frames. painted concrete). Each pile would be sampled and
a hazard deterrrtinadon made for eveiy type of painted waste.
Debris from demolition of the remainder of the s ucture (all unpainted surfaces) would be
sampled (one composite per load made up of subsamples from each represented unpainted
surface) only if the disposal, recycling, or burning facility requires data for all solid waste,
including the waste determined to be non-hazardous by generator kiowledge.
5.2.1.3 Demolish All Components and Sample Composite (Option 3)
This option assumes the owner/conu actor will demolish the entire suuCturC v 1 ithoutdismant1ing
or segregating any permeable building components. All non-permeablç building components are
assumed to be removed prior to sampling. In order to determine disposal requirementsor”
recycling options, one composite sample would be taken per load of permeable debris. This
option would only be recommended if careful screening procedures have been conducted and
there is a high confidence level that potentially only a small fraction of the entire su ucture would
be identified as a hazardous waste.
5.2.2 SAMPLING PERMEABLE DEBRIS BEFORE DEMOLITION
The final three hypothetical options assume that the permeable components of the sttucture will
be sampled prior to demolition. Sampling a building prior to dismantling or demolition may give
a better undersDnding of the applicable disposal options an owner/contractor will face before
rerpoving con Q ents or applying the wrecking ball. This approach may also eliminate the
potential for con minating an entire load with a potentially hazardous building component, by
segregating the components likely to cause e, ceedence of the TCLP threshold for lead.
5.2.2.1 Sample Each Component (Option 4)
This option assumes the owner/contractor will take a composite sample of each homogeneous
permeable building material within the structure. Those materials in exceedence of the
reguI tory threshold would b .disrnantled and managed as a hazardous waste. The remaining
-------
snucture would be demolished and managed as a non-hazardous waste rot recvc ing. bur g. or
dispo a1.
5.2.2.2 Sample Each Lead ComponentlComposite Other Components
(Option 5)
This opuon assumes the owner/contractor will take a composite sample of each homogeneous
permeable building material coated with paint. AU other permeable materials would be
quantified and a weighted composite sample taken. Those materials in exceedence of the
regulatory threshold would be dismantled and managed as a hazardous waste. The remaining
structure would be demolished and managed as a non-hazardous waste for recycling or disposal.
5.2.2.3 Composite All Components (Option 6)
This option assumes the owner/contractor will collect a weighted composi all permeable
building materials within the structure. If the result is in exceedence of the regulatory threshold,
the entire structure would be managedas a hazardous waste or a different sampling approach
would be undertaken to segregate the building components causing the exceedectce. If the
results are below the regulatory threshold, the entire structure is managed as a non.hazardous
waste for recycling, burning, or disposal.
5.13 RELATIVE COST AND CONFIDENCE LEVEL OF HYPOTHETICAL
OPTIONS
Table 5-3 presents a comparison of the six hypot tical options, evaluating relative costs ranked
by High, Medium, or Low for disposal/recycling, demoli on/dismanthng, sampling, and
analysis. This is a relative ranking, and actual costs would be determined by a suite of other
variables including but not limited to: salvage value of building components, local recycling
markets, state disposal restrictions, structure size, percent of components within a structure
coated with LBP aILd the lead content of the paint (tc levels) c rious components within
the structure. Fru high to Low, these activities are a....Acipated to .ect demolition project costs
in the following order:
o disposal/recycLing (driving force)
• demolition/dismantling
o sampling
• analysis
39
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Table 5-3 could be used as a tool for esrnnariflg (he retarive cost (mpacts to demolmon :rojects
based on job-spec fic Lrtrcrmauon and local requirements.
TABLE 5.3
ANALYSTS OF HYPOTHETICAL OPTIONS
Disposat/ Demolitionl
Recycing Dismantling Sampling Analysis Confidence
Options Costs Costs Costs Costs Ltvel
\MPL1NG
AFTER
DEMO
I
L
H
H
H
I
2
MorL
M
M
3
— 3
HorM
L
L
L
5
SAMPLING
BEFORE
I3EM :
‘
-
4
S
L
MorL
M
M
H
M
H
M
2
4
6
HorM
L
L
L
6
Notes:
Cost Impacts Confidence Level
= Low• M = Medium H = High Highest = 1 Lowest 6
Cost impacts to projects from highest to lowest:
F nk
L DisposalIR c1lng costs (driving force)
2. Demoli on nant1ing costs
3. Sasnplingcos
4. Analydcalcosts
Confidence level, for the purposes of this table, means confidence in the representariveness of the
hazard determination. Sampling each homogeneous building component after dismantling all
components within the suucture (Option 1) was ranked with the highest confidence level because
each homogeneous building component would be tested to make a l azardous determination:
-------
Op ucn 4. sampling each homogeneous builcing component before dernoltuon .as also ranked
hi ’ l v.ith respect CO confidence I c ’. eL The selecuon of a sampkng approaLh must balance
conñdence ui the process v.ith costs and other factors such as technical tmplementabthtv and
generator knowledge. These factors have been considered ui the development of recornrriended
sampLing protocols which are discussed in Section 5.3.
5.3 RECOMMENDED SAMPLE COLLECTION PROTOCOLS FOR PERMEABLE
DEBRIS
Following an in-depth analysis of the existing protocols presented in Section 5.1 and the six
hypothetical options described in Section 5.2. four recommended sample collection protocols
were developed for permeable debris. These protocols discuss planning (Section 5.3.1),
screening (Section 5.3.1.3). sampling (Section 5.3.2). and quality assurance/quality control
(QA/QC) (Section 5.3.4).
The increase in solid waste quantities, the tightening land disposal requirements, and rising
disposal costs all result in the need to segregate and treat hazardous debris and to find
alternatives to land disposal (e.g., recycling, reuse, burning) for non-hazardous debris to the
maximum extent possible. In recolnition of these factors, demolition projects should be
performed in two basic ways: (a) manual segregation, sample collection and hazard
determination, dem9lition, and management: or (b) demolition, mechanical segregation, sample
collection and hazard determination, and management
There are two major goals that must be satisfied by any sample collection methodology. First, the
sample(s) must be meaningful, representing the total volume being managed (e.g.. are the DQOs
specified for the demolition project met). Second, the samples should aid in the segregation of
materials that are hazardous, therefore reducing treatment or special disposal requirements which
are required forhazardous wastes. Based on current information from established sampling
protocols, analylis of hypothetical sampling approaches. and knowledge of EPA sampling
protocols for other types of media, this section offers a recommended approach for sample
collection of permeable whole-structure demolition debris.
These sampling protocols a - ime that LBP is the only “hazard of concern” because all other
potential hazards (e.g., asb s, polychlorinated biphenyls) have been removed from the
structure prior to sampling. LS assumed that non-permeable components of structure (e.g., 1-
beams, metal ductwork) ill be segregated and recycled or reused for their salvage value and
-------
will not : sampied. Therefore, these protocols do ot address sampilrg of flOl-pem-ieable
debns.
The selec on of approach is sire-specific and will depend on the fol1o ing factors:
• size of snucrure
• contents of suucture
• availability of mechanical processing facilities
availability of recycle markets
• stateilocal landfill capacity and limitations
• economics of the above
While this protocol does not make site-specific decisions, it presents four sampling approaches
that acCommodate most situations. Three of the approaches describe sampling permeable debris
components before demolition (Section 5.3.2.2) and the fourth describes saznplingpern able
debris aftér demolition (Section 5.3.2.4). Composite sampling is inherent in these approaches
and is discussed in Sections 5.3.2.1 and 5.3.2.3. A brief summary of the four options is
presented in Figure 5 -1.
5.3.1 PLANNING
Planning a demolition project is an important first step in evaluating the level of effort tequired
to manage the demolition wastes that will be generated.’ Building inspection and evaluation of
building materials (surfaces) using screening tools is highly recommended to guide the
owner/connactor in making accurate and cost-effective determinations for management of
demolition wastes.
5.3.1.1 ReàVth
Locate blueprints and building specifications to determine age size, type of building materials
(subs ate) and building Layout Determine feasible options for recycling any materials within the
suucture. Become knowledgeable of local and state disposal requirements (e.g.. what kind of
manifests or data are needed to submit waste to a disposal. recycle, or burning facility).
-------
FIGURE 5 -1
SUMMARY OF RECOMMENDED SAMPLING APPROAChES FOR
PERMEABLE DEMOLITION DEBRIS
R . iiuiii.ilc - Rccininended when die high-risk (+) comprncnts arc
expected 10 he characteristically hazardous.
- l xpcct to prove that twnpositc — is non-haztirdinis and
keep Composite + segregated to redt e hazardous
- VUlt i l li c.
Risk — None.
Before Demolition - Case 3
Rationale - Recommended when screening indicated the absence of
or low levels of tend on all components.
flbncuiu - Single TCLt analysis.
Risk - If cuinre building tests lia,a,diitis then resampling/analysis
mUst occur.
J Composite 1
Ratioti k — Rectniiinemkd when die col lie shut line us n. i eAh)et 1t tl to 1k
characlersshicahly hazardous even lluwgh sluuic t inngiouienls li ul
high-risk screening resuulis.
Benefit — fl*fICCI to pmvc thai Composite — is iuin-hi,u,.irtlni’s .uuni hop . it’
prove that Composite—All is min—liai.uitltnis
Risk - If Composite-All tests hazardous. reanalysis (per (‘.i’.e is
required to iktcmiine hazardous fraction.
Risk
Ilctotc l)cniolilion - Case 4
Recommended when the entire structure is not cxpe& icit to he
characteristically hazardous and few/no coniponeols h.id lii h-risk
screening results. Also receimincmkil wlicui us uiioue k.is,Iik
1 indlor cost—effective in process or scgrcg.iie i . H up. oucuius lolk )WSii
demolition.
Single TCLP analysis. Simplified sampling if pci I . brined tn !I i ll
basis.
II entire building tests ha,artttutis and res unpliuig (tOes fli hi t lh1ub e
result, may he Forced to segregate asid ucs.iniplc t.i I eiII Ii e
structure as hazarihitus.
o.site of permeable components represented wuihiui the entire structure pru)r (0 cklflh)ItIHm
Before Demolition - Case I
Composite
+
‘I
I Composite
I —
j ilk.
p *
)ernolilion - Case 2
Rationak -
Benefit
+ j, Composite of permeable components that indicate high presence of lead (high-risk components) liawtl on screcnuiig pu on 1(1 (ICOII 1 1 1 *4
—— Composite of permeable components that indicate low/no presence of lead (low-risk components) based on screening prior to ulegulOjIpu)Ji
a a
A li
i’iIc t. ,., .jKb iiC friiiii pile of pcruiie.ihlc L’mnlp.ineuus from kniol slk d structure.
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5.3.1.2 Building Inspection
Inspect the endre builthng from roof to basement or cra’ l space. Note valuaDle. recyclable,
reusable and easily sal ageable materials. Where feasible, remove components withij the
s ucture that have salvage value. Quantify the total square footage of each homogeneous
permeable building surface within the suucture and on the exterior. Carefully delineate between
the surfaces that are coated with paint and the surfaces that are not (e.g., wallboard coated with
paint and plain wallboard should be considered as two separate homogeneous materials). Since
the fate of the building is dismantling or demolition, the inspection should be desu’uctive to
ensure an accurate calculation of all types of surfaces (e.g.. peel off small areas of wall paper or
wall paneling, remove a section of floor tiles to inspect the original floor) to find all paint-coated
surfaces.
The building inspection will require careful documentation to aid in planning a sampling s ategy
to satisfy the ultimate disposal, recycling. ør bwning facility.
5.3.1.3 Use oC Lead Screening Procedures During Building Inspection
It is highly recommended that lead screening procedures be used during the building inspection
to identify the presence or absence of LBP surfaces. This information may be useful for
determining whether additional composite samples should be taken and for grouping suixcturaL
component types depending on the detection of lead. Screening results will give the demolition
conu aetor an opportunity to segregate high-risk components (those components likely to have an
influence on the outcome of TCLP). Separation of hazardous components may prove a cost-
effective measure when disposal is required, unless the entire structure or mass of debris can be
classified as clearly non-hazardous ba.wd on representative samples. (EPA, 1993a)
Two approache& lead screening are currently being used: chemical tests kits and X-ray
fluorescence ( P) detectors. Chemical test kits are small, inexpensive devices that indicate the
presence of leadb a color change when they have been applied to surfaces such as paints,
metals, ceramics, dusts, and soil. Most test kits contain a chemical (either rhodizonate or sodium
sulfide) that changes color in the presence of lead. This type of screening device is very simple
to operate arid inexpensive to use. The level of quantification is not reliable and does not predict
lead leaching levels (as the TCLP method does); however, chemical test kits are potential lead
screening tools for indicating the absence or presence of lead.
Note that federal agencies do currently recommend using chemical test kit resulr.s as dje sjs
for making decisions about abatem nc of lead itt paint. soil, or dust. This recommendation
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should also be considered for demolition wastes Several chemical test kit evaluations ate
underway. After the evaluations are completed updated inforrnanon will be available through the
National Lead Information Center (National Lead Information Center. 1993) Also refer to the
U S. EPA Office of Pollution Prevention and Toxics study described in Section 1132.
XR.F detectors have a range of precision and depth of effective results. Some “shallow” surface
probe XRFs evaluate only the top few layers of paint with high precision and accuracy. focusing
on the amount of lead immediately accessible to affect human health. Unfortunately,these
“shallow” XRFs will not necessarily detect LBP that is covered by multiple layers of non-leaded
paint. Other “deep” surface probe XRFs detect the presence of lead through paint layers and into
the subs ate itself. This type of XRF tends to indicate false positives due to other lead sources
such as wiring or metallic structural components. XR.F detectors can be both portable and lab-
based. While XRFs can provide quantification of total lead, those results do not correlate with
TCLP values. XR.Fs also require both frequent calibration and user training, which has a greater
impact on the use of portable detectors than the use of lab-based detectors. Despite these
potential drawbacks, XRF is a viable lead screening tooL
Due to the limitations associated with lead screening devices, they are not recommended for use
in identifying particular structural components as hazardous or non-hazardous wastes, nor for
serving as the sole source of demolition debris management decisions; however, they can
indicate the absence or presence of lead. These tools should only be used for preli.minary
screening to aid in sampling design.
5.3.1.4 :sampling and Analysis Plan/Quality Assurance Project Plan
In order to properly plan a sampling event, the sampling team should document in advance a plan
for collecting samples representative of the waste su eam. Types of information that should be
included are the required quality assurancefquality control samples to be collected, and standard
operating proce es for sampling and building demolition. Information and guidance for
quality assuranceprocedures can be found in EPA SW-846, Test Methods for Evaluating Solid
Waste, Volume IA, Chapter 1, and QAMS-005/80 - Interiln Guidelines and Specifications for
Preparing Quality Assurance Project Plans. 1983 (EPA-600/4-83-004). Note that these guidance
documents are general in nature and that contractors must develop specific plans to address
issues related to whole-structure building sampling events.
. 15
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Job Hazard Analysis
Once the plan for Sampling arid demolition has been established, a job hazar: na1ysts sr .ould be
undertaken and a health arid safety plan should be prepared. Appropriate me ods for the
protection of worker and public health and safety should be implemented. This protection may
range &om a simple requirement for the proper use of hard hats and safety glasses, to a more
rigorous health and safety program requiring air sampling, respiratory protection. and
containment with negative air as well as employee blood-lead Level monitoring.
In light of recent Occupational Safety and Health Adminisu acion (OSHA) activities concerning
occupational exposure to lead, arid the application of the provisions of 29 C.F.R. Section
1910.1025 to the construction indusiry. which would include demolition activities, demolition
conuaccors must place greater emphasis on programs designed to minimize and prevent
occupational exposure to lead. Training programs, medical surveillance, respiratory protection,
equipment and personnel decontamination, and exposure monitoring must be addressed during
the performance of any work involying the disruption of surfaces which may result in the
generation of airborne Lead concentrations. The new regulatory, requirements 1 which became
effective onJune 3, 1993, will require serious behavior modifications for con ’acrors and
conu actor employees alike.
5.3.2 RECOMMENDED OPTIONS FOR SAMPLING APPROACHES
Four approaches are recommended for sampling permeable demolition debris. Three of the
approaches assume the debris will be sampled prior to demolition and the fourth approach
assumes the debris will be sampled following demolition. The selection of approach for a
specific sire may depend on the following factors: size of str ucture: contents of strucvire;
availability of mechanical processing facilities; availability of recycle markets: state/local landfill
capacity and limitations; and economic factors. Detailed discussions of the four approaches and
the concept of d 3i osite sampling follow. Figure 5 -1 summarizes the four recommended
options. This s n also presents a discussion on composite sampling, which is integral to the
four recommende4 protocols.
5.3.2.1 Composite Sampling
Composite sampling is recommended f r mul i-tomponcnt buildUigs requiring demolition. This
recommendation is based on C rrent sampling approaches and EPA-approved sampling methods.
Compositing can be performed in different ways. arid may be repeated or reconfigured in
.L6 ’
-------
attempts to better represent tne waste r der evaluation. Therefore, the COflff3C:Dr should
cons ider collecting excess sample vokr e for contingencies
To ensure that (CCOfllpOSiU.ng can be one at a later date, it is essential to collect enough sample
volume in the Field so that, under normal circumstances. enough component sample will remain
followuig composiung to allow for a different composite scheme or even for an analysis of the
individual component type samples themselves. Then, if after reviewing the data, any questions
arise, the samples can be recomposired in a different combination, or each component sample can
be analyzed separately to determine better the variation of waste composition over time and
space or to determine better the precision of an average number. The fact that this recompositing
of samples can occur without the need to resample often results in a substantial cost Savings.’
(SW-846 Test Methods for Evaluaung Solid Waste. EPA. 1986c)
If the sampling event is well planned. and lead screening procedures are used, additional sample
volume collection (insurance) may not be necessary. If there are some uncertainties about the
sample composite scheme, collection df additional sample volume will require an initial
additional labor expenditure to collect and reserve the exna sample volume; however, this
approach may result in cost savings if samples require reanalysis and remobili2ation costs are
avoided.
5.3.2.2 Before Demolition . Sample Collection from the Structure
All permeable building components should be sampled, with wood, brick, cement, siding, and
plaster/wallboard being the most common components. Non-permeable building components
such as glass, screen, aluminum siding, metal duct work, bulky process and utility equipment,
steel tanks and-I-beams should be segregated and managed separately as many of these materials
tend to have high salvage values. These types of materials should not be included in a sampling
scheme, because they are difficult to sa—,Le due to their high-density characteristics. Sampling
these materials would not be cost-effecu e due to the labor and equipment intensity required to
drill through the ábsuate. In addition, scrap metals are exempt from regulation as hazardous
wastes if they ale recycled. (40 C.F.R. Section 26l.6(a)(3)(j i)).
To make an estimate of the “whole-suiicnire” permeable waste su eam prior to demolition, it is
recommended that the owner/conaactor. based on preliminary lead screening results or
knowledge of the su-ucture, select one of the three recommended compositing options (Table 5-
4):
Case I - A composite sample of all permeable high-risk components that indic te the
presence of lead (composite + : and a composite of all permeable low-risk
-------
amponents that . dicate the absence. or IcA levels of lead ( orn:C ite , This op on
is recommended . hen the o’. ner!con actor suspects that the hig - sk C: ;crenrs
‘. dl be charac:ensncallv hazardous due to :cx:ciry
Case 2 - A composite sampLe of all permea ie low-nsk compone t..s that incica the
absence. or low levels of lead (composite -,: and a composite of aU perrneabie
components within the enn.re suucture (corricosite-all). This option is recommended
hen the owner/conuac:or suspects that the enare snucrure is not characer.sncally
hazardous due to toxic:ty. but has detected lead in some high-risk screening results.
Case 3 A composite sample of all permeable components within the entire suucture
(composite-all) only. This option is recommended only if screening indicates the
absence of, or low levels of lead on all components. The risk here, however. is that if
the TCLP result exceeds the regulatory threshold, the owner/con actor would be
unable to identify arid segregate the components. causing exceedence based on
analytical results. Therefore, the snucture would have to be reanalyzed. or managed
entirely as a hazardous waste.
TABLE 5-4
SAMPLE COLLEC11ON FROM THE STRUCTURE
OPTIONS FOR COMPOS1TING
Component Category
Case 1
Ca se 2
Case 3
Composite +
Composite i-
—----
Composite-
Comoosite-
Composite
.
Composite ALL
——--
Composite AU
Composite All
Notes:
+ : Permeable components that indicate presence of lead (high-risk components)
based on screening
- : Permeable components that indicate absence of. or low Levels of lead (low-risk
components) based on screening
All : Permeable components represented within the entire snucture.
The total axea.&orn which one single composite sample is collected should be limited to 2.500
sq’zare feet. Li gc areas will require the collection of an additional composite. For instance, if
the area of bm e ñg components requiring management is 4.000 square feet, it is recommended
that two composite samples be coliected representing 2.000 square feet each.
The proporuonal surface area, of each homogeneous building material to be composited should
be determined based On estimated square footage. The total estimated areas of each
homogeneous building material should be compared to one another to establish ratios. The ratios
will determine the weight or vQlume of subsample material required from each homogeneous
building material to make up the appropriate percentages within the composite samples collected.
43
-------
For ac composite sample that ; se :s a differeflt sucse of pe— a le bu:.:. g r :cnents.
a a1 . auon of the propoitcnal s ,._face 2.rea for each u idi idual su: : is rec_: Su T:.ent
subsample material should be coi .e;:ed from randomly selec:ed Loc:: ns of nomc e eous
budding materai to ensure enough volume for the composite sample’ s and any QAJQC samples
required.
5.3.2.3 Evaluation of Composite Sample Results
Table 5-5 presents a math.x of the possible TCLP outcomes for different compostnng s ategies ,
and th recommended corresponding action items. In recognition of the national solid waste
dilemma. and EPA’s su ategy of minimizing landfdling. it is important to segregate hazardous
wastes from non-hazardous wastes to the maximum degree possible. Devising a composiung
su acegy that uses screening tools to aid in component categorization is an attempt to segregate
the hazardous wastes. Screening results from components that indicate no/low lead content on
the surface. yet are determined to be hazardous by TCLP, wouid be an unexpected outcome.
Decisions for resampling and/or management of these components would be required.
5.3.2.4 After Demolition - Sample Collection from the Debris Pile
As an alternative to segregating the structure prior to sampling, the suucture can be demolished
first and the resuldng debris pile can be sampled, tested and managed as a single waste. The
debris pile can also undergo a combination of manual and mechanical processing (e.g., sorting.
chipping. grinding, flotation) to create segregated waste piles prior to sampling and management.
This approach is recommended when the entire structure is not expected to be characteristically
ha.zardozs and few or no components had high-risk screening results. This approach is also
recommended for cases where it is more feasible or cost-effective to process or segregate
components following demolition.
This sampling approach is applicable to permeable debris only. Non-perrnable building
components such as glass, screen, aluminum siding. metal duct work, bulky process and utility
equipment, steel ranks and I-beams should be segregated and managed separately, as many of
these materials have high salvage values.
The following approach for sai pIing waste piles was extracted from SW-846. Test Methods for
Evaluating Solid Waste. Vol. 11. Ch. 9. p. 77: “In waste piles, the accessibility of waste for
sampling is usually a function of pile size, a key factor in the design of a sampling strategy for a
wastepile. Ideally, piles containing unknown wastes should be sampled using a three-
dimensional simple random sampling strategy. This strategy can be employed only if all points
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it i the : e can be ac:esse: En sucri eases. the tie sh ou1d e ::. ded in:: a three-
dirre sicnaI d Syste i. the rd sections assigned nu ±&s. ar. • e sampl! :oir :
us in2 random-nur ber .ables or random-numcer zenerators [ r sampi. S im : o
cer . .i.r1 pcrcns of the pile, then the colIec ed sample i1l be representative 0fl1/ of those
poz- cns. unless ie ‘ asze is k o ’n to be homogeneous.’ (EPA. IcS6c)
TABLE 5-5
EVALUATION OF COMPOSiTE RESULTS
TCLP OUTCOME
Case I
Corn osite
Hazaraous
Hazardous
Non-hazardous
Non-hazardous
Corn osite-
Non-hazardous
Hazardous
Non.hazardouS
Hazardous
Acüori Item
Expected result.
Screening results
were validated,
Treat Low-risk
components as.
non-hazardous.
Treat high risk
components as
hazardous,
Unexpected result.
Screening results
were not validated
for low-risk
components,
Re nal ze low-risk
composite and/or
individual low-risk
components, or
eat whole
s ’ucture as
hazardous.
Screening results
for high-risk
components
indicated total
lead, not leachable
lead.
Treat whole
sa’acture as non-
hazardous.
Unexpected
results,
UiCOflSiSteflt With
screening.
Reanalyze [ ow-risk
composite and/or
individual low-risk
components.
Case 2
Comvosite All
Hazardous
hazardous
Non-hazardous
Non-hazardous
Composite-
Non-hazardous
Hazardous
Non-hazardous
Hazardous
Acdon Item
. .
Unexpected result
for composite of
all components.
Screening results
for low-risk
components were
validated.
Low-risk
components are.
non-hazardous.
Reanalyze high-
risk composite or
individual high-
risk components as
in Case 1.
Unexpected
results for low-risk
and ali
components.
Reanalyze
individual
components. or
eat whole
s ucture as
hazardous.
Expected result.
Treat whole
su,icture as non-
hazardous.
Unexpected
results for low-risk
components.
inconsistent with
screening.
Recomposite. or
reanalyze
individual
components.
50
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TABLE S-S
Continued
Case3
on.hazardOus
Non-hazareous
Com osLte All
}- azardous I
Hazardous
result.
result.
Acuon Items L expected Cnexpected E pccted
Expected
results, if results, if Screening results Screening results
screening indicated screening indicated were validated, were validated.
lcw risk. low risk. Treat whole Treat whole
Recomposite, or Recomposite, or su’ucture as nor ’- s ’ucture as non-
reanalyze reanalyze hazardous. hazardous.
individual individual
c:rnponents. or components. or
teat whole u’eat whole
s ’ucture as su’ucture as
hazardous. hazardous.
Notes: -
Composite All : composite sample of all permeable cornpon.ents
C3mposite + : composite sample of permeable high risk components (based on
screening)-
Composite - : composite sample of permeable low risk componen (based on
screening)
Hazardous : > 5.0 mg/i for lead
Non-hazardous <5.0 nw/I or lead
“In cases where the size of a pile impedes access to the waste, a set of samples that are
representative of the entire pile can be obtained with a minimum amount of effort by scheduling
sampling to coincide with pile removal. For the number of mickloads needed to remove the pile
should be estimated and the uckIoads randomly chosen for sampling.” (EPA, 1986c)
To make a ha determination of the debris pile, it is recommended that one composite sample
be analyzed fot .thC -load. Defining Load in terms of maximum weight or volume varies among
other established protocols. For example. the DMA uses 6,000 kilograms as a maximurn weight
per load of abatement waste. EPA Region VU recomm ends one composite sample per 500 cubic
yards or less of demolition debris (made up of no more than 0 aliquots). It is recommended that
a limit of 500 cubic yards or less be placed on the size of the pile represented by one composite
sample.
One potential disadvant.ige to the ‘pile” approach is that, depending on the result of the hazard
determination, the entire debris ptle (or mick load) may be subject to management as a hazardous
waste. An alternative tc ebris sampling being used in some areas of the counTy. including New
-------
Enoland s -e use c a debrs - c ssino facility tc .irther se - °ate the d 0flS “alized
equiprr e . cludu grinders. s :eening devices. ar.: flouncn devices. are require :o ort and
segre are de:ns. These types equipment are usually locate at a fixed processu facility.
although mc:i e equ::ment is also available. Tes r.z of each debris component should be
performed. if required. prior to further management (e.g.. recycling, burning, disposal). State
perrnit .ng requirements for such facilines vary (see Table 3- I ).
5.33 SAMPLE COLLECTION METHOD
Prior to coliecdng samples from each qf the homogeneous permeable building materials, it is
recommended that the volume of an aliquot from each type of subsuate be calculated (e.g.. 114-
inch diameter drill bit multiplied by 4-inch substt’ate) to determine how many aliquots of each
material will be required to make up a 110.0-gram sample for TCLP analysis (in addition to
material representadon requirements). ft is recommended that excess sample be collected to
allow for reanalysis. .
Samples should be collected using a 1/4-inch to 1-inch drill bit by drilling through the entire
subsu ate. A 3/8-inch carbide drill bit should be used for concrete. Drill cuttings arid associated
dust should be collected by allowing them to fail into a disposable sample container such as an
aluminum pan. The remaining sample dust and cucongs should be vacuumed using a hand-held
vacuum to ensure coUection of the entire substtate thickness. Sufficient substtaze material from
each homogeneous area should be collected to conthbute the appropriate volume to the
composite sample.
The vacuum cleaner fiber filter should be dedicated to each homogeneous subsample group
(homogeneous building material) to minimize cross contamination. Non-dedicated sampling
equipment. such as drill bits and the head of the hand .held vacuum, should be decontaminated
between sampling of each homogeneous subsample group. Sainpling personnel should
decontaniinare uipment by first brushing the excess material from the equipment and then
washing using tap water and soap. This should be followed by a final rinse with distilled water.
52
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O e the appropriate volume each hc cgeneous 5uilduig - :: u1 .:s bet-. U :ec. :he
rr ::enal should be :ansferred a certified-clean “:de-rnout . 2las a ha: ou s or
rricre to ac omrnodate sufficie .t mass for duplicate analyses.
5.3.4 QUALITY ASSURA CE/QtJALrFY CONTROL S. MPLES (QAQO
The QAJQC data obtained from field duplicates. ririsate blanks and math.x sptke. ma ix spi.ke
duplicates (MS/MSDs) should be reviewed to ensure that the precision and accuracy of the
analytical results meets or exceeds the DQOs for the sämplinz event. QAIQC data should be
reviewed by a chemist to determine data quality and to identify specific problems that may
interfere with data usability.
EPA QA/QC sample requireme tts can vary from region to region. En general. there are two
kinds of QeVQC samples, field and analytical. Field duplicates and rinsate blanks are considered
field QAJQC because they pros ide a check on field sampling techniques and decontamination
procedures. respectively. MSAISDs would be considered analytical QA/QC because they allow
the laboratory to check the precision of analytical equipment and analytical processes. General
information and guidance for Q.’VQC sampling and analytical procedures are found in EPA SW -
846, Test Methods for Evaluating Solid Waste, Volume IA, Chapter 1. (EPA. 1986c) A
recommended QA/QC sample schedule is as follows:
• Field Duplicate: 10% (minimum of 1)/sample event.
• Rinsate Blank (if equipment deconcaminad’on is required): 1/sample event.
• MS/MSD: 5% (minimum of 1)/Laboratory batch/sample event.
A field duplicate should be taken to check the quality and consistency of collecting and
ansferring the subsample material to a sample container. These steps should be duplicated
using the same ff Id sample collection technique to produce a field duplicate. It is recommended
that drill holes b tie adjacent to one another and the frequency of collection for each subsuate
be identical for field duplicate preparation. A rinsate blank is collected by pouring analyte- free
water over equipment that has been decontaminated between sample points (homogeneous
subsuates) to check the thoroughness of decontamination procedures. Note that it may be more
cost-effective to use dedicated sampling tools (e.g., drill bits) for each homogeneous subsuate.
This method would minimize cross-contamination and would eliminate the need for a rinsate
blank, thus reducing the cost of analysis. The required volume for a MSIMSD sample is usually
laboratory- arid methcd.specitic. The MSIMSD is prepared by the laboratory using the TCLP
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ex act as part of the laborz:::- .squai . conc lpr: rarn The Iabora rv oulc -. d:o 5e
contacted to de:errrune .f ac. :onal sar :Ie vcturne ‘ ouId e equi.red
5.3.5 SUMMARY OF RECOMMENDED SAMPLE COLLECTION PROTOCOLS
The recommended sample c: iecnon protocols onsisc of the fo [ [ owin components.
1. Plan the sampling .n detail irtcludin2:
- Reseo. :h the suucture
• Lrispec: the suiicrure
- Perfcr i lead screenirt2 on all sn ucture components
• Deve cp Sampling arid Analysis Plan! Quality Assurance Project Plan
• Perfor n Job Hazard Analysis and Develop Health and Safety Plan
2. Remove non-per eable components from the s ucture for recycle, reuse or other
salvage purposes.
3. Select a sampling approach for permeable components based upon screening results.
Deterrrune subsart oles to be composited and timing of sampling (before or after
demolition). Recommendations incLude:
- Before De nolidon
Case I - analysis of composite of all permeable high-risk components that
indicate the presence of lead analysis of a composite of all permeable low-
risk components that indicate the absence or low levels of Lead. Case 1 is
recommended when the high-risk components are suspected to be hazardous.
Case 2 - analysis of a composite of all permeable Low-risk components that
indicate the absence or low Levels of lead an analysis of a composite of all
permeable components. Case 2 is recommended when the presence of lead
has been detected in some components. but the entire s ’ucture is suspected to
be non-hazardous.
Case 3 - analysis of a composite of all permeable components. Case 3 is
recommended if all screening results indicated the absence or low levels of
Lead.
c - After Demoidon - analysis of one or more composites of the permeable
debris pile, collected randomly.
4. Perform sampling including QA/QC samples. Use 114-inch to i-inch drill bits. Drill
through the entire ubsnate or pile arid collect the drill cuttings and associated dust-
s. Evaluate sampling results to make a hazardous determination for each set of building
components represented by a composite sample.
6. If sample results are unexpected (e.g.. composite of permeable low-risk components
exceeded 5.0 mg/L ii TCLP). use the rationale in Table 5-4 to determine whether
additional samptin and analysis is warranted.
54
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6.0 S \1PLE ANALYSIS
Laborator. analysis cf ons uc:on and ce oliuon CD) debris samples presumed to conu.tn
lead-based paint (LEP) is required to de:er rune he:her or not the waste debris is hazardous.
According to 40 C.F. . Parz 261. de:errrur.a:on of the hazardous charactens c of toxicity
requires analysis of the waste by a method known as the Toxicity Characterisdc Leachm
Procedure (TCLP).
6.1 TOXICITY CHARACTERISTIC I..EACHr r, PROCEDIJR
The TCLP method is designed to determine the mobility of both organic and inorganic analytes
present in liquid, solid and rnulupha.sic wastes. It is intended to sin u1ate the conditions in a
landfill environment, and is defined in 40 C.F.R. Part 261, Appendix il. Method [ 311.
The TCLP method requires that the sample be reduced in particle size so that all partcles fit
through a 9.5-mm (0.375-inch) screen. The TCLP method also requires a subsample to be
reduced to approximateLy 1 mm or less in pardcle size for the determination of the appropriate
ex action fluid (I and Ii). This reduction in particle size may be accomplished by either ci rnng,
crushing, or grinding.
ecause the particles must fit through the screen, an issue currently unresolved in the waste
management community is whether to send the laboratory (1) a sample of powdered material
having the smallest particle size obtainable, (2) a sample of particles as large as possible that still
fit through the sieve, or (3) large chunks of material that the laboratory will reduce in size. At
issue is whether or not surface area is a factor in determining TCLP Lead concenu’a ons. (Nadler,
1992) Substannal data was not found to verify this possibility; however, conflicting sample
collection methodologies are currently practiced as discussed in Section 5.0.
Recognizing thazthe screen size used with the TCLP method is 3/8 inch (0.375 inch), and
believing that collecting as large a sample as is allowable will yield the lowest possible TCLP
lead result, a demolition/lead abatement con actor from Massachusetts collects samples using a
3/8-inch-diameter core. (Higgins. 1993) Howeyer, this con actor cannot substantiate whether
or not this has systcmadcally reduced the TCLP result.s. The Denver Housing Authority (DHA)
takes the opposite approach based on apparent field experience. The DHA used to send solid
pieces of wood for TCLP anal .ysis but now sends sawdust samples. and indicates that the sawdust
samples are yielding lead results Lower chart the results for larger wood chunks. (Ward. 1993)
Preliminary discussions i . irh t boratory persorrtel indicate that the lower results obtained from
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the s:.;c.ist sarriples may : a res it :f : e fIne . ood par:tc!es ess ’.:ia1ly d ss:i. n into the
ex::; r.: solution along .::n the Deailed study of this phe cmenon re riec s aj-v to
subs:ann te or refute this su esricn,
The L.S Environmental Protection Agency (EPA) Office of Research and Development.
Environmental Morntoruig Systems Laboratory suggested that leaching large chunks of debris,
rather than grinding the sample. would be more representauve of actual landfill condinons:
however, this process would be ui conrlict with TCLP methodology. (Rupp. 1992) Others agree
with this posi on. and suggest that the sample should reflect disposal conditions. The contention
is. if the material to be landflhled is predominantly fines, then fines should be collected and
sampled. and if the material to be laridñlled is predominantly chunks, then chunks should be
collected and sampled. (Sandberg. 1993)
EPA continues to evaluate levels of lead and other metals as determined by TCLP analysis. EPA
is also evaluating new dilution attenuation data, which may have an effect on future TCLP ac o ’n
levels. (Topping. 1992)
6.2 SYNTHETIC PRECIPflATIOT i LEACHING PROCEDURE
The use of the TCLP method as an indicator of the potential for lead to leach from land ils is
considered by some regulatory personnel to be “technically unsound” because this artificial
mobilization is effected by the organic ex actant: acetic acid. Acetic acid solubilizes lead as
lead acetate, which is the only soluble form of lead, when normally only dilute mineral
(inorganic) acids exist in landfills. (Spittler, 1992) For this reason and others, EPA is testing a
new leaching procedure, the Synthetic Precipitation Leaching Procedure (SPLP), Method 1312,
also biown as the acid rain test. The major difference between the two methods is that the TCLP
method uses an organic acid (acetic), while the SPLP method uses an inorganic acid which is
similar to the acids in natural precipitation (rain, snow and fog).
In an EPA back ound comparison study of lead levels from the U.S. Depamrient of Housing
and Urban Development (HUD). lead abatement wastes were an order of magnitude less when
analyzed with the SPLP method than with the TCLP method. This study, exnacted in Table 6-1.
found that for the nine samples analyzed by both methods, TCLP results were greater than SPLP
results by a range of 2 to 35 times (Topping, 1993) Total lead measurements are also provided
for comparison purposes.
56
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TABLE6.L 1
DATA COMP4RING SPIP AND TCLP METHODS
Sample # SPLP TCL? Toui Analysis
Method 1312 Method 1311 Method6OIO
- (m flJ (mg/L) (mgj )
1 0.114 0.803 1090
2 0.152 2.55 1260
3 0.0323 0.501 71.7
4 2.00 11.3 3310
5 0.o l Otj oo lo(J 173
6 0.165 2.36 132
7 0.131 0.258 . 393
8 0.085 2.15 78.9
9 0.132 4.73 995
Source: (TopplnQ , 1993)
These limited data indicate that lead leachability is s ong1y dependent on the leaching acid. and•
it raises the question of what is the best method to determine whether a waste is characteristically
hazardous by toxicity. Further study is requixed on this issue, because potentially subscannaily
reduced quantities of CID debris would be determined to be hazardous if the TCLP method were
replaced by the SPLP method, without changing the action levels.
The State of New York is currently directing conuactors to perform SPLP analysis for soil
leachate analysis when the soil will remain on the facility property. In con ’ast, soil that will be
excavated and relocated off the facility property will be subject to TCLP analysis. This
compound approach could be confusing and may require increased analytical costs. The TCLP
standard is evidently thought to be too low by some, including the State of New York. If
appropriate, the TCLP action levels should be raised, or the TCLP should be replaced, but it is
not recommended to implement multiple analysis methods for different circumstances.
6.3 SCRFENING Tool _ S
Screening toots miy be employed to estimate which materials are more likely than others to test
as hazardous. Screening tools may not be used in place of TCLP analysis, nor will they
accurately predict the TCLP results. The primary function of screening tools is to distinguish the
materials likely to contain LBP, from those that likely do not. This screening can then be used
to assist in the segregation of maenais. effec ng hazardous waste minimization. Currently two
screening tools are available X-ray fluorescence (XRF) detectors and chemicaj test kits.
An XRF detector is commonly used in environmentai investigations, such as LBP
invesdgations, to screen for the presence or absence of metals in the media being measured.
p .
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XRF detectors can be used both in the field and in the laboratory fri the case of LBP
in e ugauons. the XRF insmiment irradiates the paint on the uriace. causing lead in :he paint. if
present. to fluoresce. emitting a characteristic frequency of radiation. the intensity of hich is
measured by the detector and related to the amount of lead in the paint. XRF has been used in
the past as a screening tool to indicare the presence or absence of lead in paint. (Drosdz. 1992)
Other studies. which have attempted to correlate XRF measurements with TCLP measurements.
have not been successful in establishing an accepted correlation. (Cox. 1992)
Data from one XRF/TCLP study prepared for EPAs Office of Solid Waste in 1990 are shown in
Table 6-2. The data are arranged in order of decreasing TCLP exu act concenti at ion. The report
suggests that debris was generally found to be hazardous only if the lead level in the paint, as
measured in the laboratory by Atomic Absorp on Specuomeuy (A.AS). exceeded approximateLy
4.0 mg/cm 2 . The usefulness of the AAS data here is to demonsu ate the degree of confidence in
field XRF measurements, which varies between studies, and is rather low in this study. Total
lead levels are also provided for comparison purposes. In this study, measuiements of the paint
TABLE 6.2
COMPARISON OF FIELD AND LABORATORY LEAD DATA
Field Measurerneni Laboratory Measurements
Sample XRF AAS I C.. ? Total
* (mgJcm 2 ) (mQ/cm 2 ) (mqfL) (mg/kg)
1 3.4-5.1 5.9 21 94800
2 9.3 6.1 13 103000
3 5.3 9.7 12 50400
4 19.4 9.4 10 171000
5 19.4 9.4 95 174000
6 3.9 2.8 5.4 24300
7 6.2 8 48 96500
S 0.86 6.8 4.5 32700
9 0.72 5.3 4.1 5360
10 0.028 8.2 3.4 580
11 2.8 4.6 2.5 40400
12 3.9 4.8 2.3 43800
13 0.38 N/A 2.1 21700
14 3.4 .7 1.2 98200
15 - 2.9 4.8 1.0 27400
16 0.54 3.1 0.9 6240
17 2.2 3.7 0.8 20400
18 1.1 3.1 0.4 15300
19 0.016 3.1 <0.3 670
20 0.12 N/A <0.3 2430
Notes: XRF: X .ray fluoresce c . AAS atomic absorpuOn spec ometry
Source: (Cox. 1992
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lead levels by field XRF were poorly correlated with TCLP results. The data show that XRF i
not a good uidicator of TCLP or total lead levels, and that XRF results tend to be greater than
TCLP results when each is compared to the relevant threshold Level. em.ng in favor of increased
hazardous waste dezerrrunanons. (Cox, 1992)
In addidan to the study mentioned above, a separate study completed by the U.S. Army at Fort
Devens attempted to correlate XRF with TCLP data.. In this study, the Army also found no
correlation between XRF measurements in the field with TCLP results in the laboratory.
(Josephson. 1992)
The Louisville Housing Authority (LHA) also attempted to develop guidelines relating TCLP
and XRF measurements. They hypothesized that in order to get a TCLP reading above the
toxicity Limit, the XRF reading must be “high” and the subs ate must be IthinN or “not dense.”
LHA also concluded that surface lead (XRF) and total lead results do not correlate. (Adams,
1992)
The Denver Housing Authority has hundreds of data points currently being entered into an
e1ec onic data base. One goal of DHA is to a empt to develop a correlation between XR.F and
TCL.P data from abatement projects. (Ward, 1993) However, these data are not available for
review at this time.
While XRF may be able to confirm the presence of LB? , it cannot be used to determine whether
the UP will fall the TCLP analysis. Therefore, it is recommended that the use of XRF as a
screening device be limited to detennining the presence or absence of LBP. XRF ins ument
criteria should be determined prior to selecting a specific detector, because various models of
XRF insuumenution h’ave different sensitivities to UP.
Chemical te3t kiu are small, inexpensive devices that indicate the presence of lead by a color
change when they have been applied to surfaces such as paints, metals, ceramics, dusts, and soil.
Most test kits contain a chemical (either rhodizonate or sodium sulfide) that changes color in the
presence of lead. This type of screening device is very simple to operate and inexpensive to use.
The level of quantification is not reliable and does not predict lead leaching levels (as the TCLP
method does); however, these test kits axe potential lead screening tools for indicating the
absence or presence of lead.
Note that federal agencies do cu.renriy recommend using chemical test kit results as the basis
for making decisions about abatement of lead itt paint, soil, or dust. This recomniendanon
C—
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s ou1d also be Considered for derroLinon astes. Several cherrucal tes kit evah anons are
underway. Alter the evaluanons are comple:ed. updated uifromanon ill be a aiiable through
the Nadonal Lead [ nforma on Center. (Nadonal Lead [ .nforrnadon Center. 1993)
The EPA Office of Poflunori Pre’.ennon and Toxics (OPPT) is conducung one such study
comparing results from various technoLogies for field measurement of lead in LBP.
(Schwemberger, 1993) The results of the study will be considered by HUD in the development
of guidelines for abatement of federally assisted housing. The ongoing OPPT study evaluates the
variability in common LBP field measurement techniques, including six lead test kits and nine
portable XRF ins uments. Painted surfaces in houses in Denver and Philadelphia are being
tested using both types of field measurement devices. Con±irmanon samples are being analyzed
at fixed-based laboratories using standard anaiy cal insnuments. The following painted surfaces
are being analyzed in each house: metal, wood, concrete, brick, drywalL and plaster. The study
is ongoing at this nine.
6.4 RECOMMFNDEI) SAMPLE ANALYSTS PROTOCOL
Currently, the federal Resource Conservadon and Recovery Act (RCRA) requires analysis of
hazardous waste toxicity using the Tap method. This method should be used for analysis of
LBP.
Available data suggest that neither XRF nor chemical test kits should be used to determine
whether a sample will pass or fail the TCLP. test. These screening tools ale only potendally
useful for determining the absence or presence of total lead. Where lead is posinvely ideminfied
using XRF or a chemical test kit, a sample should be collected for laboratory analysis by T P.
Note that federal agencies do c urrent1y recommend using chemical test kits as the basis for
making decisions about abatement of lead in paint, soil, or dust. This recommendadon should
also be considered for dernolidon wastes.
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7.0 MANAGEMENT OF NON -HAZ.ARDOUS C D DEBRIS
Seve iI le2id.mate manageT ent opuorts currently exist for ccrnponenr.s of cons c:r :-
derr oliuon (C1D) debris that have been deterrn.ined to be non-hazardous. The o ccris tr.c:ude:
• landfilling in a Subtitle D, municipal solid waste (MSW). or C/D Landfill
• combustion in energy recovery facilities
• recycling various C/D debris components into other products. such as fill rn :erial.
road base or landscape mulch
The SCLCCtiOfl of a specific management option is typically an economic decision made b’ . the
demolition con actor based upon factors such as debris quantity and composition; and the
a’. ailabiLity, location, regulatory requirements, and cost associated with the management option.
Landfihling is currently the most commonly selected approach. However, due to decreastng
landfill capacity. sharply increasing costs, and changing regulatory requirements, the viability of
landfilling for C/D debris is rapidly decreasing. The combus on of wood debris is gaining in
popularity because it generates revenue for the demolition con accor through the sale of waste
wood to combustion and waste-to-energy facilities. Burning debris is an alternative to burning
more expensive fossil fuels and virgin wood. Concerns about emissions and uncertainties about
C/D wood debris generation rates have impeded growth for this management option. The
recycling of various C/D debris components is also occurring on a small scale, but this approach
offers a large expansion potential if stable markets can be established for the recycled products.
Unfortunately, a growing percen ge of C/D debris is not managed using these three opuons.
Some 4orthea.st Waste Management Officials’ Association (NEWMOA) states have reported
incidents of illegal disposals creating potential human health and environ.merital risks. (Lambert.
1992) The development and use of a protocol for non-hazardous C/D debris may reverse that
uPend.
Discussions of three legitimate management options and related benefits and drawbacks follow.
A recommended protocol for managing arid handling these non-hazardous wastes is also
presented.
7.1 LANDFILLING
Landfilhirig of non-hazardous CID debris in MSW or C/ I D landfills, a once common practice. is
facing significant environrnenul. econorruc. and capacity problems. A major environmental
6t
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concern is leachate generation Major waste hauling’disposal firms have published re:orts on
environmental releases from C D landElis concludln2 that liners, leachate collection 3vstems and
similar conc ols are Warranted. 3r ckner, 1992) Some states ha e banned the dispcsal of C/D in
MSW lar dfills due to this leac a:e concern. Other states have promulgated sthct C/D landfill
re2ulaflons. sirrular to those fcr MS\V landfiLls. Liners and leachace collection syster s are now
required for CID landfills in the states of Massachusetts, New Hampshire. and New Jersey. In
Connecucut and Ma.ssachuset.s. C/ID landfills must meet oundwacer testing and surface water
monitoring requiremenr.s. (Lambert. 1992)
Table 7-1 presents the results of a survey of state solid waste regulatory agencies conducted in
the Spring of 1992 focusing on regulatory requirements for MSW and C/D landfills. The
majority of the states have less sninigent requirements for C/ID landfills than MSW landftus:
approximately 84 percent of the states do not require C/D landfills to meet MSW landfill
reguladons, 86 percent of the states have separate reguladons for CJD landfills, and landfill
exclusions are anted to C/ID wastes in 64 percent of the stares.
TABLE 7-I
NATIONAL cm WASTE REGULATORY OVERVIEW
No. of perrnined MSW landfills 5.654
No. of C/ I D waste !ar dfdls 1,807
No. of C/D waste r cycl processing facilioes 113
STATE C/I) WASTE LANDFILL REGULATIONS
YES NO NR
• Must m t MSW landfill regulations 8 42 0
• Have separate regulasion. 43 5 2
• Have C/D waste landfill exclusion 32 14 4
• Siai that require permits f
C/D proCessing f diu 30 15 5
Source independendy compiled through contacts with state solid waste regulatory a8encies
bvGershn.Bric er& B zton. Inc. (GBB . 1992
Landfill dpping fees have risen subscandally in response to the increasing landfill cons ucdon
and operation requirements and decreasing available capacity. Fees of $50 to S60 per ton are
commonplace in states such as Florida. where the high groundwater table severely res icts
landfill siting. (Demolir:on l 92) Some New Jersey counties are paying dpping fees of
S130 per ton to nansport and spose GD debris to in-state or out-of-state landfills. (Lambert.
L992)
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Landfi.U catacity is rapidly shrlnkin2 for all wastes, and bulky CID de mc::
volume per mass than municipal solid wastes. Tnerefore the banning or hrruwg ::C ID
in 1anc .lls is a owirig Approximately 5.600 MSW and 1,800 CD :
curenily c st in this coun v. (Brickrter, 1992) These numbers are rict likely to r ’-. :
pace. S icter requirements for new landfills defined by the October 9. 1993 effe : e date i cr
Solid Waste Disposal Facility Criteria (40 C.F.R. Parts 257 and 258) will res icr e siorig of
new MSW landfills. This federal requirement will affect all states because the feceral Resource
Conservation and Recovery Act (RCRA) required that by April 9, 1993 states must have
adopted arid implemented a permit program to ensure that MSW landfills are in compliance with
Part 258. CiD wastes are not defined in the federal regulation but are expected tc e ad±’essed
by each state.
The future of landfil]ing a ,s a management option for non-hazardous CiD debris is very limited
due to significant environmental, economic, and capacity problems. Athough lar.dfiuling is
currently the first choice of most demolition conu ’actors, itis the last c . e in the U.S. -
Environmental Protection Agency’s (EPA’s) integrated solid waste management s tegy, and
other alternatives such as burning and recycling are more viable for managing non-hazardous
C/i) lead-based paint (LBP) debris.
7.2 BURNING
The use of waste wood for fuel provides potential opportunities for increasing rene.’. able energy
use, alleviating the solid waste disposal problem, and reducing fuel costs. Several facilities in
the U.S. currently combust waste wood as all or part of their fuel sueam, and interest from other
power producers and indus ies is growing quickly. Conversely, there are major technical arid
environmental issues that require more study to determine the effecr.s of Surriing eated wood
either exclusively or with other wastes. The lead released through air pollution cone ’oI devices in
the ash is a signifcant concern and requires more research and evaluation. In addition to the
technological ques ons, public perception is another important factor to consider ith respect to
this emerging technology. Many developers attempting to permit recycled wood combustion
facilities are receiving suong public opposition.
Conceptually, the process of segreganng and chipping non-hazardous “.ood debns and burning it
to produce process steam and elec icity is a viable management alternative with de:e dable
product markets. Whether burning should be defined as “recycling” elicits different opinions.
Some stares such as New Jersey do not consider this approach to be ue recycling. : T 1g the
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econor _ tncen VCS assoc:a d ‘. ifl it. In con ast. the EPA-funded Recycling . :visory
Comirü: e of the National RecycLi ig Coalinon considers wood chip ccmbusrtor. f:r energy
produc::n a vital re ise of a asze product. (Brickner. 1992)
RegarcI ss of the de rudon. th::e are marty advantages to burning non-hazardous ‘ .ood debr-.s
inc1udL g the follo irtg:
• reduces reliance on fossil fuels
• increases use of waste products
• reduces utilization of landfill capacity
• reduces reliance on virgin wood
• reduces sulfur dioxide emissions of coal during during cofiring
• lowers energy costs, compared to fossil fuels
• provides a plentiful energy source
The ma rity of the C/D wood that is currently burned in power plants or energy recovery
facilities is unn eated or clean wood. The combustion of uri eated non-hazardous wood does not
present significant environmental concerns. However, the combustion of non-hazardous C,’D
debris that contains wood that has been ueated or coated with paint, varnish, stain, preservatives,
plaster and laminating agents has the potential to release contaminants through both air emissions
and the ash. The sources of contaminants are the constituents (i.e., metals) used in the
manufacniring of the paint.
Paint typically comprises less than 0.1 percent by weight of a painted piece of wood, and only a
fraction of that percentage is made up of metals. (Grasso, 1990) Some power plants are
requiring “cerri cation” from demolition con actors that the lead content in non-hazardous
wood debris is below specific levels or is not present at all, prior to accepting this waste.
(Taylor, 1992) tails concerning the information required in the certification were not
available.
An efficient particulate con l system at a wood-fired facility could reduce metal emissions
from paLtted wood combustion to levels below regulatory limits. (Grasso, 1990) Further study
is recorr.rnended on a range of eated ocd samples to verify the effectiveness of the
combustion process and particulate connol system.
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Wood pr:cessing units such a.s hoggers and chippers may rerno e much of : e a : c - -
coao.ng. depending on the teve of abscrpnon into the wood surface. (Feh.rs. 199.; l-
this remo ’ .aI will largely be a f cnon of the mechanical design of the prcce . .
Unless the screen size is relat ’.ely small and the wood passes through the grmdir z me: ! ni m
multiple :rnes. the paint may remain on the surface. Additional study is warranted to de:emrr e
the effec: .eriess of these processing units. and to evaluate whether they further reduce
contaminant levels in wood feed stocks, thereby decreasing Lead levels in air errussions and ash.
Regulatory issues are particularly compLex with respect to combustion of wood debris. Concerns
include the following:
• Non-anainrnent pro’. isions and New Source Performance Standards resulting from the
Clean Air Act Amendments will affect siting and permitting of new waste wood
combustion facilities. (NYSERDA, 1991)
• The ncineration st.atus of waste wood boilers (in New York and other states) could
be an impediment to the development of wood energy. (NYSERC . 1991)
• Characterization and classification of specific waste wood types for use as fuel are
required. (NYSERDA, 1991)
• Options for ash uses such as compost and soil amendment products require
evaluation. (NYSERDA, 1991)
Despite the regulatory and technical issues to be resolved, there is a growing acceptance among
state energy planners that waste v ood fuel can be an important component of an overall
renewable energy supply s ategy. Table 7-2 presents a sampling of eight states that ha e
developed wood energy policies.
Cement lns also offer potential options for burning C/i) wood debris, both non-hazardous 3rd
hazardous. Refer to Section 8.3 for a discussion of this approach. which is in sporadic use
because many cement kilns are configured to burn liquid fuels rather than solid fuels.
Further technical studies and regulatory decisions are required before the burning of both
un eared and n eated (painted) non-hazardous wood debris is a commercially viable debris
management option. The viability of burning wood debris is subject to furuie regulatory
changes.
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7.3 RECYCLING
Rec c ing offers the most promising furure for non-hazardous C/D debris management. ..
vane y of recycling options fcr non-hazardous C/D debris are currently in use with varyir1
degre:s of success. While re yc1ing options offer clear economic advantages for whole.s uc e
Table 7-2
SUMMARY OF WOOD ENERGY POLICIES IN STUDIED STATES
State Energy PoLicies CA CT NC NY VT VA WA WI
Current !c of total
dec. generation from
aLl typesof woods 1.9 <1 <1 <1 23 1.4 <1 0.6
of total state
indusuial energy
consumption <1 NA NA 14 <1 12 32 71
State policy specifically
supports clean waste
woodcombusuon I I I I I I
State policy explicitly
recognizes wood from the
waste s m as a viable
fuel source
State policy wants the
combusuon of wood for
fue ltoincrease I I I I I
State-level finan&I
incentives exist for
using oodasfud I I I I
Source: NYSERDA. 1991
demolition projects, they are highly dependent on the stability of the market for the end-use
product. Several recycle options follow:
Shredded Wood
- Landscape mulch (only unueated clean wood can be used tn many states)
- Buiking agent for MSW and sludge compos ng
• Top sod addithe
- Daily landfill cover
- Fiber m t.s used to improve seeding and vegeta on growth
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• Mar.ufacared buiidtng product.s (e g aruc e card. pre s oar
• Malleable wood products (Bosron G ’ob ’. l993
- Wood fiber for pass seed stabilizer (Bosro.’t Gio . l99
- Other thermo-rnechanically re ned cer produc for use - rrolc .
pressed, or woven items Barthelrries, 1992)
• Scrap Metal
- Recovery and reuse
• Concrete, Brick. Cinder Block, Stone, Glass, Plaster, Shee cck, Tile, Asphalt
Roofing Materials
• Crushed forfi.Ll
- Crushed for road base
A key technical factor inherent in any of these recycling options is the effectiveness of the debris
sepazaoon techniques in providing a feedstock with high purity. Separation cart be performed at
the demdioon sire or at an offsire processing facility. Equipment requirements can vary from
simple chippers and hoggers to a process train. A detailed analysis of debris processing
equipment i beyond the scope of this study. Examples of the processing systems available for
use include the following:
• conveyors • magnetic separators
• sorting stations • flotation tanks
• classification screens • air classifiers
• chippers and hoggers • hammer mills
• crushers and shredders • vibrating screens (Brickner, 1992)
Without well-developed markets, C/D debris recycling will not be successfuL Mditional market
research should be sponsored to evaluate potential products and markets, such as research on
wood fibers for use in agrirnats, furniture and other applications, which is sponsored by the uS.
Deparurient of Agriculture.
In addition to economic issues, developing regulatory requirements may also act as impediments
to recycling success. As new products are considered for development, it is recommended that
regulatory evaluations be performed in advance at federal and state levels to iden fy potential
impediments. This identification could result in early petitions for waivers or other regulatory
relief if the process and end product appear to be environmentally sound. LUcewise. early
• decisions could be made to abandon the research in unresolvable situations.
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7.4 HANDLING
No specific storage, manifesnng. cackaging. or ansportadon requLremeflts ui addition to state or
local requre:TefltS are recomrnerded for non-hazardous CID debris. Note that some states (e.g..
Virginia) require that open uck loads of any material be covered.
7.5 RECOMMENDED M NAGEMENT PROTOCOL FOR NQN
HAZARDOUS CI’D DEBRIS
The recommended protocol for management of non-hazardous C/D debris is as follows:
I ldenri.fy non-hazardous debris through screening and quandfica on as described in
Secdon 5.0
2 Se egate the debris into the following categories through manual or mechanical
processing:
• wood
-metal
- concrete, brick, cinder block, stone, glass. plaster. shee ock. 1e, asphalt
roofing materials
- other
3 Select recycle markets for each type of debris category based upon cost-effecdve.
available, and reliable processing facili es.
4 Incinerate the wood debris in a waste-to-energy facility or use the wood as fuel in a
con olled burner. (Note: The viability of this oprion is subject to future regulatory
changes.)
S Select disposal of debris in a Subdde D landfill only if all other opdons are not
viable.
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8.0 MANAGEMENT OF HAZARDOUS CID DEBRIS
Hazardous COnSuUCtiOn and :errioL:Qn (CJD) debris is that debris which exce c th
Cha.racerscc Leaching Procedure (TCLP) standard for lead or other hazardous c3mpour.
(characterisuc hazardous wa..s:e), or contains a listed hazardous waste. Managerr ent of hazardous
wastes is sthctly regulated b the U.S. Environmental Protection Agency (EPA) under the
Resource Conservation arid Recovery Act (RCRA). Section 3.2 provides an overview of federal
regulatory requirements for hazardous C/D debris.
This section provides addinonal information on hazardous waste generator status which affects
hazardous waste management requirements. Information on eatment alternatives arid disposal
requirements for hazardous debris follows. The best dernonsu ated available technology (BDAT)
standards for management of debris promulgated under the R.CRA Land Disposal Res ictions
(LDRs) are discussed, and other options such as burning in cement kilns are mentioned.
Hazardous waste handling issues are also discussed and a recommended protocol for
management of hazardous CiD debris is provided.
8.1 GENERATOR STATUS
RCRA defines a hazardous waste generator as any person (including individuals, companies, arid
government agencies), by site, whose act or process produces hazardous waste. In the case of
hazardous lead-based paint (LBP) CID debris, the generator may be the owner of the building or
the demolition con actor. If the demolition con act does not require the conu ac:ar to manage
the waste, then the owner is t e generator. If the con actor is required to manage the waste, then
the owiter and the con ’actor are called cogenerators. An owner cannot conuact away the
responsibility and liability for safe management of the demolition waste. Federal categories are
discussed below. States often have more sningent regulations than those presented.
The federal ha.zardoi$ waste regulations distinguish three types of generators:
I Those that generate no more than 100 kilograms (about 220 pounds) of hazardous
waste per month are known as ‘conditioriaUy exempt small quantity generators.”
These generators are required to dispose their wastes according to state regulations.
which, in most states, means that they must label their waste and take it to a licensed
solid waste disposal facility. However, some states require that even smaLl quantities
of hazardous waste be disposed at a licensed hazardous waste disposal facility. To
qualify for disposal under the guidelines of this category, the generator must never
accumulate more than 1.000 kilograms of waste on site. When this limit is exceeded,
the generator irrtrred atety becomes subject to all the requirements pera.ining to a
small quantity genierator.
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2 Those that generate more than 100 but less than 1,CCO kilograms of hazardous waste
per month are known as ‘small quantity generators.’ These generators must comply
with EPA hazardous waste regulations for accurriulanon, ueatment. s rage , arid
disposal of hazardous wastes. For this catezory, the aeneracor may ac:umulace up to
6.000 kilograms on site for 180 days (or 270 days if the disposal site is more than 200
miles away).
3 Those that generate more than 1,000 ki.lo ams of hazardous waste per month are
known as ‘large quan ty generators.” These generators must comply with all EPA
hazardous waste regulauons, which include regulations for accurriuladon. u caunent,
storage. and disposal of hazardous wastes, as well as re:ordkeeping arid repor ng.
The generators can store any amount for 90 days; when this time period is exceeded
the generator is automatically considered a storage (acUity, which recujres additional
permitting.
Small and large quan ty generators must obtain an EPA identification number for each
demolition site. These numbers are used by EPA to ack hazardous waste acdvities nationwide,
including nansportation, eatrnent, storage, and disposal of the waste.
8.2 TREATMENT
EPA’s LDRs require hazardous debris to be u’eated prior to land disposal, using specific best
demonsnated available technologies from one or more of the following families of debris
eamient technologies:
• Exuaction
• Desmiction
• Immobilization
As an alternative to using specified technologies, hazardous debris may continue to be handled in
accordance with the contained-in” policy. Under this policy, the debris may be eated and land
disposed if itno longer “contains” a hazardous waste. However, a case-by-case EPA regulatory
determination is required with this alternative. This alternative is not an efficient regulatory
s ategy for gena zors with multiple large quantities of debris.
The result of performing eatnierit in compliance with BDAT would be two-fold. Not only
would the debris no longer be prohibited from land disposal, but EPA would consider the eated
debris to no longer be or contain a hazardous waste, provided a des uction or ex action
technology is used for each deb s type/contaminant CC.. . inadon and provided that the U ’eated
debris does not exhibit any hazardous characteristics. Such eated debris could, therefore, be
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reused. recycled burned, ordispc ed :n a Subnde D facility, Table 8 -1 shows the catewries
and technologies acceptable as BDAT for hazardous debris.
TABLE 8-1
ALTERNAfl’ £ TRE TMENT STANDARDS FOR HAZARDOUS DEBRIS
A. Exuac on Technologies
1. Phvstcal E acuon
- a. Abrasive Bla.snng
b. S:arificanon. Grinding, and Planing
c. Spalling
d. t ’cratorv Finishing
e. High Pr .ssure Steam arid Water Sprays
2. Chemical Exuacoon
a. Water Washing and Spraying
b. Liquid Phase Solvent E. uac on
c. Vapor Phase Solvent Ex x on
3. Thermal ! uact1on
a. High Temperanire Metals Recovery
b. Thermal Desorp on
B. Deswucdon Technologies
I. BioIogic l Desmicuon
2. Chemical Desuucdori
a. Chemical Oxidauon
b. Chemical Reduc on
3. Thermal Desuuction
C. Immobilization Technologies
1. Ma roencapsularior i
2. Microcncapsulation
3. Sealing
Source: 40 C.F.R.. Section 268 L5 Table I
The BDAT tecI nologies for hazardous debris specified in Table 8-1 offer the generator arid/or
neater managing the waste a number of technology op ons, all of which are widely used
eaunent methods. Hazardous debris must be eated by one of the specified ueauncnt
technologies for each contaminant subject to u ’eauiient.
Residuals generated by the eatmer c of hazardous debris are subject to the numerical eatrnent
standards for the waste contaminating the debris. Also, layers of debris removed by spalling are
hazardous debris that remain subjc t to the n ’eatment standards.
Specific performance and/or design and operadng standards have been specified for various
BDAT technologies. The physical e’u ’action technologies hich would be applicable to LBP
debris have the following u ’eatmer.: st andards. listed in Table 8-2.
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TABLE 8.2
APPUC ABLE TREATMENT ST \DARDS
FOR PHYSICAL EXTRACTION
Dehris Type Standard
Glass. Me ai. Plasuc. Rubber Treaime!lt o a c!e n debr.s surface
Wood. Brick. Cloth. Concrete Removal of at least 0.6 cm of the surfac:
Paper. Pavement. Rock layer. u eaunent to a clean debris surface.
Soure: 40 C.F R. Section 268 45. Table I
The LDRs for ha rdous debris define a clean debr. surface as “th face, when viewed
without magnificadon, shall be free of all visible contaminated soil and hazardous waste except
at residual staining from soil and waste consisd.ng of light shadows, slight s eaks, or minor
discoloradons, and soil and waste in cracks, crevices and pits may be present provided that such.
sairiing and waste and soil in cracks, crevices and pits shall be limited to no more than 5% of
each square inch of surface area.” Other performance and/or design and operadrtg standards for
other technologies are also defined in Table 1, 40 C.F.R. Secrion 268.45.
The basic technical principle inherent in all physical ex action technologies is that the majority
of the contaminants reside on the surface of the debris manix, and are only shallowly absorbed
into the ma i.x; therefore, the exuacdon of the surface layers through physical abrasion will
remove the majority of the contaminants. This same principle is a side benefit of the size
reducdon techniques of chipping and hogging that precede both wood burning and most
recycLing opdons. ‘imilarly, abatement techniques Like sand blasdng and experimental methods
such as carbon dii .. .de pellet blasdng, which is being researched by the EPA Risk Reducdon
Eflgineering Laboratory (Burkie. 1992), are based upon the same principle.
If the eatment process is effecdvc and the eated debris does not exhibit any hazardous
c iaracterisdcs, then the debris would be classified as non-hazardous. It is possible that a non-
hazardous classificañon could minimize concerns of waste wood markets (e.g., burning,
recycling) regarding potendal residual toxicity due to the presence of LBP, thereby opening those
markets to eated wood debris. Note that the residuals from BDAT technologies must be
managed as hazardous wastes.
The rigorous regulatory requirements for eatrrient of hazardous debris are associated with
significant costs and management requirements such as manifesdng. repor ng and
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recorc. eeplng. Therefore, the .ciurre ci hazardous debris generated should be rrJr .:n-z d
Proper se reganon of materials and uea:rnenc uSi ng BDAT i1 conmbu:e to mee r. :nis goal.
8.3 BURNPIC
The bu. ning of hazardous C/D debns contaminated with LBP in a RCRA-perrnitted facdicv
could offer economic advantages over eatment and land disposal. The regulatory recuirerrients
governing each burning facility will determine allowable contaminant levels in incoming fuel,
and will also correlate to tipping fees. in addition to RCRA-perrnirted incinerators, cement kiins
and lead smelters are other potential markets. Burning for energy recovery is subject to the LDR
requirements found at 40 C.F.R. Parr 268.
8.3.1 CEMENT KILNS
Cement ki.Lns are a potential op non for burning C/D debris, both non-hazardous and hazardous.
Cement kilns are currently operating under interim status compLiance conditions regulated by the
Boiler and Lndus ial Furnace Rule 40 C.F.R. Part 266, Subpart H. Each facility will be panted a
permit by EPA on a case-by-case basis reflecting facility-specific operating specifications,
including acceptance of wastes as fuel substitutes. A number of cement kilns are currently
accepting some type of hazardous waste as an economic fuel substitute. The vast majority of
these wastes are liquid hazardous wastes, therefore conversion ma ’ be required to accept solid
fuel. One waste broker indicated that some cement kilns are using leaded debris for fuel and are
not experiencing regulatory emission compliance problems unless the lead levels are “exuemnely
high.” (Fritsky, 1993) Materials that are burned for energy recovery are subject to the Part 268
LDR requirements.
The presence of metals in cement kiln fuel or raw material feed is not typically an environmental
problem because many metals will volatilize and condense within the kiln and be bound into the
clinker (cement kiln product). Volatile metals such as lead are more likely to volatilize in the
1dm and condense ou ide of the kiln in the ductwork of the air poUutior i con ol device (APCD).
Lead that remains in a particulate form, is collected in the highly-efficient APCD. Cement kiln
dust (CKD) typically is highly alkaline and metals bound into the CKD are very insoluble. If the
CKD generated when burning waste-derived fuel does not exhibit toxic concenu ’ations compared
to health-based limits (TCLP levels for metals) or if the CKD is demonsnated not to be
significantly different from residue generated when burning conventional fuel, the CKD meets
the Bevill exclusion (4.0 C.F.R. Section 266.112) and is considered to be a non-hazardous waste.
If the CK.D does not meet the Bevill exclusion, due to toxic metal concenaadons or other
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haz:rdous characteristics, it ma. :e recycled at a metal recover, fac i ; or ae2 : ard disposed
as a hazardous waste.
8.3.2 OTHER BURNING F.ACILITIES
Hazardous wood debris con .rrnrzted with LBP may be a potential su plement2J fuel source for
other manufacturing facilities, ç _dcuJarly those that process heavy metals and are equipped with
APCDs to capture metal pardcu!ates. Demolition connactors are investigating regulatory and
econorriic issues associated with sending lead-painted CID wood debris to lead smelting
faciLities. No in.formation was a’. ailable regarding arrangements currently in place.
8.4 RECYCLING
Hazardous wastes that are recyced are subject to federal hazardous waste regulatory
requirement. and state recycling regulations, where they apply. Generators are regulated by
federal regulations in 40 C.F.R. Part 262; uansporters are regulated in 40 C.F.R. Part 263; and
hazardous waste recycling facili es are regulated in 40 C.F.R. Part 264.
Refer to Section 7.3 for a discussion of various potential recycling options for C/D debris.
- Metals recovery facilities are one possible market for hazardous lead-contaminated debris,
particularly for the small particles or fines resulting from physical cx action processes. The
ability of recycling facilities to accept hazardous debris is currently decided on a case-by-case
basis with the exception of scraç netal recycling which is not subject to hazardous waste
regulations: Further invesdgaticri is required to determine the extent or potential of recycling
hazardous LBP debris.
8.5 HANDLING
The accumulation of hazardous waste at a generator’s facility is regulated under RCRA, by 40
C.F.R. Section 26234. The hazardous waste may be accumulated on site for 90 days or less
without a permit provided:
1 The waste is placed:
- in containers. complying with 40 C.F.R. Part 265 Subpart I
- in tanks. complying with 40 C.F.R. Part 265 Subpart J
- on drip pads. c mplyin with 40 C.F.R. Part 2.65 Subpart W
- in conuinmer.: buildings, complying with 40 C.F.R. Part 265 Subpart DD
2 Each container is mar. d with the date upon which accumulation began
3 Each tartk or container is labeled or clearly marked with the words “Hazardous
Vaste’
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4 The following volumes are not exceeded:
• 100 kg for a conditionally exe ipt small : annrv gererator
• 1,000 kg for a small quantity generator
- 6,000 kg for ocher generators
Generators of hazardous waste are required to comply with ±e foUowing federal re2ulacorv
requirements:
Generator Standards, 40 C.F.R. Part 262
• hazardous waste determinations
- EPA identification numbers
- manifest requirements
- pre-aansport requirements (packaging, marking, labeling, placarding and
accumulation time)
- record-keeping and reporting requirements
- hazardous waste export and import requirements
Land Disposal Res ictions, 40 C.F.R. Part 268
Transportation of hazardous v.aste is regulated by Deparuneric of Transportation regulations 49
C.F.R. Parts 171 through 179. EPA has adopted these regulations which apply to both interstate,
and innstate ansportationof hazardous waste in 40 C.F.R. Part 263.
8.6 RECOMMENDED PROTOCOL FOR HAZARDOUS cm DEBRIS
The recommended protocol for management of hazardous C ,’D debris contaminated with LBP is
as follows:
I Minimize the volume of hazardous debris through se egation and testing.
2 If the volume of ha.za.rdous debris is small, select exn action or des uction eauT1ent
technologies appropriate to the mathx that is contaminated. Treat the debris in
compliance with required performance or design and operating standards for that
technology.
3 Test the eazed debris using the TCLP to determine whether it exhibits the hazardous
characteri fc of lead toxicity.
4 If the eated debris is not characteristically toxic, eat it as a non-ha.zardous waste.
Refer to Section 7.0 for recommended protocols for management of non-hazardous
debris.
5 If the ueated debris still exhibits the toxicity characteristic, re eat and retest it, or
dispose of it in a Subtitle C disposal facility.
6 Manage the residuals generated by the eatment of hazardous debris as hazardous
y es If appropriate arid technologically feasible, recycling at a metals recovery
facility may be an option.
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7 if technologically feasible and in compliance with RCRA Subdcle C regula ons.
consider burning or reuse management op ons such as cement kilns or metals
recovery faci1i es for large volumes of hazardous C/D debris.
8 Comply with all applicable storage, manifes ng, packaging, labeling, marking,
placardthg, uanspor a on, recordkeeping, and repordng requirements.
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9.0 LEAD EXPOSURE
Conc m over proper management and disposal of lead-based paint (LBP) is :o the fa: that it
c:uses de irnental effecs to human health and the environment. This secuon discusses human
health and envuonmental effect.s om lead exposure. Tne fate and ansporLat on of lead in the
ens. ironment is described. accorthng to the lead species present and the charac: rsncs of the
media within which the lead exists. Also described is information resarding leads leachabilicy
from landfills a nd combustion ash, and emissions of lead from waste burning facilities.
9.1 HUMAN HEALTH EFFECTS
Exposure to lead may result in numerous human health effects and toxicological symptoms.
Variations in exposure levels produce a wide variety of human health effects. Current research
suggests that toxic effects may result from lead exposure levels considerably lower than
previously recognized. (56 FR 22096) Lead exposure levels axe typicaliy evaluated from the
lead content of blood.
During the past decade, reduction in the environmental sources of lead (virtual elimination of
leaded gasoline and voluntary removal of lead solder from food cans) has been at ibuted to the
decrease in childrens’ average blood-lead levels from approximately 17 micro ’arns per deciliter
(j.Lg/dl) to between 4 and 6 .ig/dl. The Centers for Disease Con ol set the standard for blood-
lead level poisoning at 10 jig./dl.
Children and unborn fetuses are especially vulnerable to toxicological effects from lead
exposure. Symptoms such as anemia, mental retardation, and encephalopathy (brain rumors) are
associated with high lead blood levels (>40-60 ig/dl) and death may occur with ex emnely high
lead concen ations (>100 igfdI). Toxicological effects from lower levels of lead may include
slight increases in the blood pressure of adults and subtle deficits in attention span, hearing,
learning ability, herne synthesis and vitamin D metabolism in children. Exposure to lead is also
associated with reproductive effects in men and women, and with decreased birth weight and
decreased physical and mental development n newborn children. (56 FR 22096)
The biological basis of lead toxicity is its ability to bind to ligating groups in bi-molecular
substances crucial to various physiological functions, thereby interfering with these functions by.
for example. competing with native essential metals for the sites, inhibiting enzyme activity, and
inhibiting or other.vise altering essential ion n’ansport. (Seinfeld. 1986)
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A1thc gh most research has fccused on lead exposure in ch.ilc.ien. health risk s áes for adu.lr.s
show that ingested lead is stored pnrnanly in bone tissue. Mcbthza cn of lead frQ bone ossue
may cccu.r during periods of s ess or greater metabolic reqw.emenr.s for calcium, such as during
pregnancy or in individuals suffering from osteoporosis.
9.2 ENVTRONMEYrAL EFFECTS
Toxicological effects from lead are frequently reported for both small and large animals.
Sources of lead for animal uptake include ingestion of lead wastes, LBP. spent lead shot, fishing
sinkers, and contaminated forage near lead smelters. Lead poisoning is the most frequently
diagnosed toxicological problem in veterinary medicine. Lead poisoning has been reported for
all domestic species arid several species of zoo animals.
High concentt adons of lead can affect certain plants causing inhibited rates of photosynthesis,
reduced growth, and variation in species composition. Soil microbial ecology can be affected by
high soil lead levels. Some dethmental effects include reduced rates of mineralization of soil
organic matter, lowered nuuient levels, and changes in soil properties such as lower organic
matter content. (56 FR 22096)
Microbial processes have been affected by the interaction of soil type arid lead concen adon
(Dragun, 1988). Table 9-1 presents results from several studies that examined the interaction of
soil type and metal concenu ation on microbial processes. For soils with increa.sirig sorptive
capacity (sandy loam> loamy sands), respiration was not inhibited by tt ’eamients consisting of
increased levels of lead. Also, soils with increased levels of organic material (hurnic acids arid
compost) did not show reduced microbial respiration with high lead concenaadons.
9.3 ENVIRONMENTAL FATE AND TRANSPORT
The following ph ical and chemical properties of lead were obtained from the Toxicological
Profile for Lead (ATSDR, 1988) and the priority pollutant-related information for this metal
(EPA. 1979). unless referenced otherwise.
Lead can occur in three oxidation states (0, +2 and +4) with the plumbous (+2) valence dominant
in environmental chemisay. (Allo .ay. 1990) Lead is persistent itt the envirorunenc and,
therefore, has a long residence time relative to most other pollutants. Lead accumulates in soils
and sediments because of its low solubilicy and resistance to microbial degradation. Lead is
poisonous. and its bioaccurnuladon .‘ .ichin the food chain and severe toxicity associated with
‘0
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human u esaon are important. No sizruñcant evidence has shown .r at lead has an es e :aj role
in me abohsrn.
TABLE9-I
EFFECTS OF LEAD LEVELS IN SOIL ON MICROBIAL . CT1V [ TY
SOfl LEAD ORGANIC f VUCROB(AL ECOLOGICAL SCLRCE
TYPE CONC k V ND .NT PROCESS EFFECT
(u ft. )
Loamy sand. Not
pH 5 10 Applicable Respuauon 6% Dec re3. 1
Loamy sand.
pH 5 100 — Respiration 25% De aSe 1
Sandy loam.
pH 5 1000 Respiration None 3
Silt loam.
pH 6.8 1000 .- Denith ca tion Retardation 2
Sandy loam.
pH 5 10.000 — Respiration Retardation 3
Sandy loam,
pH 5 15,000 2% Hurnic acid Respiration None 3
Sandy loam.
pH 5 20.000 4% Compost Respiration Initial Re rdation; 3
none after 20 days
Sources cited-
1. Cornfield. 1977:
2. BoUag and Barabasz. 1979;
3. Debcsz et al.. 1985.
Metallic lead is stable in dry air; however, in moist air, it quickly forms lead monoxide which
a ansforms into lead carbonate through a reac on with carbon dioxide in the a nosphere. In
general, the chemical properties of the inorganic lead compounds are similar to those of other
alkaline earth metalL The lead rd ate, chlorate, and acetate salts are water soluble; the chloride
is slightly solubl and the sulfate, carbonate, chromate, phosphate, and sulfides are reladvely
insoluble. The chromate, carbonate, niu’ate, sulfide, and phosphate salts are soluble in acid, and
the chloride is slightly soLuble in acid. (Wea.st, 1985)
Lead typically forms complexes of low solubility with the major anions of natural environmental
systems. Table 9-2 lists the solubilicy product constants (Ksp) for eleven lead minerals. The
listed values are negadve 1o arithms of the Ksp and the very large values indicate low solubility
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for :r.e ‘.arious minerals. Trie hydroxide, carbonate, sulfide, arid sulfate (less ccr . only
avauacie) compounds may ac: as solub iiry conn ’ols.
TABLE 9.2
SOLUBIL1TY PRODCCT CONSTANTS FOR LEAD UNERALS
MNLU L pK Lb
PbC1 4.80
PbCO 13.48 (18°C)
PbO 1532
Pb0 65.50
Pb(OH)i 19.90
Pb 4 0(P0 4 ) 2 65.17
Pb (PO 4 ) 60
Pbi(P04 5 C 1 84.40
Pb 5 (PO QH 76.80
PbS 27.47(18°C)
PbSO 4 7.97(18°C)
Notes:
a = neganve logarithm of the solubiiity product constant
b = at 25°C. unless specified other ’ise.
Source: Dra2un. 1988
The ansport of lead s influenced by the speciation of the ion. One method for estimating the
speciation of the lead ion is the exarrtinadon of hydrogen ion concenuadon and
oxidation/reduction potential (ORP) for a particular system. The hydrogen ion conceri ation is
recorded by pH elecncde measurements and the ORP is determined by a platinum elecuode and
reported as Eh. The unit.s of Eh are volr.s or, more commonly, millivolts. Foilowing
me3.srements of Eh and pH. an estimate of the ionic species can be made using Eh-pH diagrams.
In conjunction with ionic species information from Eh-pH diagrams. mobility of lead in soils and
groundwater is determined by the potential for adsorption. Estimates of adsorption are based on
the adsorption coefficient or dis ibution coefficient (K iJ. The 1(4 for lead is an experimentally
determined value (fliLlg) which is defined as the ratio of the concenn ation of lead adsorbed onto
soil surfaces (J.Lg Pb per g soil) divided by the concenu ation of lead in water (j.ig Pb per rnL
water). For lead, the observed range of 1 ( 4 is 4.5 to 7,640 mL/g. Following a logarithmic
ansformation of the data, a mean of 4.6 and standard deviation of 1.7 were reported for the
Logarithms of the observe ‘ues. (Dragun. 1988) Assessment of potential groundwater
contamination is conside values of K 41 that are < 5 mUg and typically for 1(4 <1 mL/g.
The observed range for k s values further supports the high degree of soil adsorption for
lead.
so
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Lead s f:u d in soils, rocks, sed :rrie :s. surface water and grou dwate: k. a; . ‘
of 16 lead aie reported for soil evels ran in2 from 15 o 25 m k Burau. :
typical r:rige for Soil lead values is frcm 2.0 to 200 mg/kg with eco-eme :S Y0
mg/kg ( ragurt. l9S8 i .Atrnosphe:ic eposidon of lead onto the soil su.rf c ii source
of anthr pogenic lead: however, rese rch indicates that nearly constant values for leac -e found
below the 5 cm depth. (Ward et aL. 1975) Lead is considered a e -ace e1e enr in g r arer
with natural concen a ons of <15 g .’L. (Dragun. 1988) Lead exists pri .rriarily as the civalent
cadon in most unpolluted surface waters arid becomes sorbed onto pardculate phases. In
polluted surface waters, the chemical form of lead may be markedly altered by organic material.
Wong er al. (1975) reported the producdon of cea’amethyl lead ((CH 3 ). Pb) by r CrCorg._ i s i tt
lake sediments from inorganic and organic lead compounds. Air analysis of flasks containing
anaerobic lake sediments indicated tenamethyl lead was produced and could be ola .ize . . Tl e
kinedcs of de adadon of te amethyl Lead in aerobic waters are uncertain and this compound is
probably not stable in oxidizing environments. Biomethyladon of lead represents a n thanicm
for the rein oducdon of lead from bed sediments into the aqueous environment or aunosphere.
Sorpdori of lead appears to dominate the fate of lead in the environment. In aquadc and esruari.nc
environments, lead is accumulated within bed sediments apparently due to sorpdon phenomenL
(Helz et ai. 1975 and Valeila et a!.. 1974) Variadon in sorpdon mechanisms has been aruibuced
to parameters such as geological set ng, pH, Eh, liga.nd availability, dissolved and pardculate
iron concen -adons. salinity, sediment composidon. arid iriidal lead concen adon. Compiexadon
of lead by biogenic ligands can be significant in polluted waters and therefore may ha. e a
significant effect on the face of lead in aqua c environments. No evidence has been repcrted
describing the photolysis of organo-lead compounds in natural waters.
Bioaccumuladon of Lead has been shown for a variety of organisms. Microcosm studies suggest
that lead is not biomagnifled. Lu cc aL (1975) studied the fate of lead in three ecosys erns
differing only in their soil subsnate. The ecosystems contained algae. snails, mosquito larvae,
mosquito fish, and microorganisms. Lead was concenu-ated most by the mosquito larvae and
least by the fish. Body burdens and aqueous lead concen adons appeared to be s cn ly
correlated with the soil cherr cai properties of organic matter content and cadon exchange
capacity.
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The photolysis of lead parnc es from automobile exhausts indicates the cofv.e sion from halide
saks (PbBr2, PbBrCI, etc.) to ‘cdes. carbonates, and sulfates. (Kabat .a-Pendi2s a d Per dias ,
1984)
fri summary, the dominant mechanism con o1ling the fate of lead appears to be Sorption.
Precipita on of PbS 04, PbCO , and PbS. and bioaccumulation may also be Important. The
mobility of lead is inversely affected by pH levels with increasing mobility reported as pH
decreases. In alkaline and near-neu al environments, immobilization of lead by sorpoon and
precipitation may occur relat e1y quickly.
9.3.1 LEACHABEL1TY FROM LANDFILLS
Data on the leachabiiiry of lead from landfills indicates that while lead may leach from landfills,
it becomes heavily diluted in ground acer. In addition, lead is very immobile in soils. Data on
lead’s lack of mobility in the environment as presented in Section 9.3. This section presents data
on the small amounts of lead that may become mobile from both municipal solid waste (MSW)
landfills and from cons uction/demolidon (CID) debris landfills. Although the cons uction
requirements and geologies were not accounted for, one study found that the leachate from the
MSW landfills is ten times more concen ated than leachate from CiD landfills. (Lambert, 1992)
Data on lead leaching from CiD landfills is available from a study conducted in 1982 by the
Connecticut Department of Environmental Protection. This study collected leachate data from
five bulky waste landfii .Ls. Connecticut defines bulky waste as land clearing debris and waste
resulting directly from demolition activities other than clean fill. Lead in leachate was found in
the range between 0.04 mgfL and 0.1 mgfL, with an average of 0.056 mgfL. The Safe Drinking
Water Acts Maximum Contaminant Level (MCL), a level for which compliance is normally
required, is 0.05 mgfL , for lead. The report concludes that: (I) the average from these five
landfills should be representative of typical demo1i on landfill sites where leachate is produced
and collected; and.(2) demolition landfills are not totally innocuous and can have adverse effects
on adjacent surface water or groundwater (Lambert. 1992). It is relevant to note that the lead
values represent steady-state leachace s ength from unsaturated lysimeters, prior to dispersion
and dilution in the aquifer.
MSW landfills are different fr in C/D landfills in that MSW decomposes much more than CID
waste. The composition of lea haie from v1SW will be highly dependent upon the stage of
decomposition and the materi:!stha: are contained within the MSW landfill. It is therefore
dlfficult to generalize as to the art u ai contaminant concenn ations that leachate will contain.
3 :
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Re:orted 4S Ieachate cor ce :::ons fcr lead vary from non•de:ec:ed o 6 6 maL . s dv
dcr,e in Wis:onsin with 46 sampi s found that MSW leachate concennations for c: 4
be een ncr..de:ected to 1.2 rn;L. (Robinson, 1986) By comparison, the ‘ 1SW ‘ aiue
is r o orders of magnitude higher than the MCL for lead.
Lead has leached from both C/D landfifls arid MSW landfills in concenn’auons h:s c: the
MCL for lead. Groundwater with Consutuent concen arions beyond the MCL ncn’riaU reçui.res
corrective ac on.
9.3.2 LEACHABIL1TY FROM COMBUSTION ASH
Wood ash c ntairis the oxidized rn .nerals from the wood, as wtU as noncombus b!e ma enaJ
such as dirt and any unburned carson. The single major constituent of both demcii on wood ash
and natural wood ash is silicon dioxide, or din, averaging 41 percent for demolition wood and 35
percent for natural wood. The second most concencaced mineral in both types of ash is calcium
oxide, averaging about 16 percent by weight for demoLition wood and 23 percent for natural
wood. Calcium oxide, along with ocher oxides (e.g., alurrtjniurri, iron, magnesium, pcu.ssium and
sodium) is primarily responsible for the widely recognized alkalinity of wood ash. These
minerals are typically present in large percentages, and as a result, wood ash is often used as a
liming agent for land application. Demolition wood ash and whole u ee chip ash exhibit very
similar compositions. The main differences between the two are due to the increased amount of
dirt often found in demolition wocd. as ‘ e1l as higher amounts of sulfur- and titanium-containing
non-wood materials. (Grasso, 1990)
When heavy metals were analyzed from wood ash, the metal present in the highest
concen ’adons in demolition wood ash was titanium. Lead was present in the second highest
average concenu’ation. The main sources of both of these metals is paint. Other sources include
different coatings and impregnates. If the demolition wood is burned together with another fuel
(e.g.. whole ee chipsor bioma.ss), then the metal concenn ’ations in the ash will be reduced.
Metal concen añons in combustion ash from a study on the composition of recycled wood fuel
are shown in Table 9-3. (Grasso. 1990)
TABLE 9.3
LEAD CO CENTR , TIONS IN COMBUSTION ASH
(mgfkg)
\tuumum Maxunum Avemge
Virgin iood 16.6 36 23
Demo [ icion wood 22 0 33.000.0 6.261.O
Source’ (Grasso 19Cs
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Ash from wood waste CombUStion is a solid waste arid is subjec: to a hazardous ‘ aste
de:errru.rianofl. New York Sr.ate requires waste characterization of the ash gerie ated from
burnln2 solid waste. refuSe-deri\ ed fuel, and household waste, regardless of whether ener2v
recovery is provided. (Yew York Solid Waste Management Facdiry Rules Section 360-3 5) En
addidon to specific disposal requirements for hazardous waste ash, the state has specified
disposal criteria for non-hazardous bottom ash and fly ash. The ash from burning clean waste
wood is regulated as a solid waste. (NYSERDA, 1991)
In a study on dernolidon wocd. EP Toxicity and T P tests were performed for metals on four
composite ash samples resulting from the laboratory combusdont of 100 percent dernoliton wood.
Lead was present at less than the federal level using the EP Toxicity test, and in exceedence of
the maximum acceptable limits for TCLP. (Jana et al., 1991) A different study of leachabiliry of
metals from .MSW ash found that lower levels of metals were leached when the ash was
monofi.Ued, as compared to codisposing the ash with unti eated MSW. (Francis and White, 1987)-
A possible explanadori for this may be that ash from incinerators with scrubbers may exhibit
higher buffering capacity because of the lime used in the scrubbers. This buffering capacity
would not be depleted in monofllis, but would be depleted in the presence of acids normally
found in MSW landfills.
9.3.3 AIR EMISSIONS
Air emissions of lead are more of a problerrr at a dernolidon site than at -iing facility, due to
effecdve air polludon con ol equipment. Studies have shown that with an efficient par culate
conwol system, a recycled. wood-fired facility can easily reduce metal emissions from painted
wood combusdon to a level below regulatory limits. Even if a facility burned 100 percent eated
wood, metal emissions could be maintained below regulatory limits with convenidonal par culate
collecdon devices. (Gra.sso, 1990)
Atmospheric lead is a localized problem, and therefore all acüvides regarding demoidon of LBP
materials should seek to minimize the dust created. reritly, the Clean Air Act’s primary and
secondary standards require that not more than an e of 1.5 j.Lg/n ’i 3 of lead may exist in the
atmosphere averaged over a 90-day period. Furthe . Lead emissions may also be a
corr onent of respirable particulate matter in the atr. phere. Currend , not more than 450
.LgJm 3 of particulate matter less than 10 j.im (dust small enough to be inhaled into the deepest
portion of the lungs) can be in the atmosphere, averaged over an eight-hour workday.
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10.0 RECOMMENDED PROTOCOLS
Tne maJor fi.ndirigs arid reccm nded protocols for sample collecnon. sample ara ;.;
hazardous consm .icuonJdemch: n (C/D) debris mana2errlent. and hazardous CD e rs
management are presented L i i the foliowing sec ons.
10.1 SAMPLE COLLECTION
Secrion 5.0 presents a detailed c scussion of recommended sample collecdofl protocols for
permeable debris. Non-permeable building components such as glass, screen, aluminum siding.
metal ducwork, bulky process arid utility equipment, steel tanks, and I-beams should be
se egated and managed separa::ly due to their high salvage values. The recommended san1pi
coflecdori protocols for perrriea ie debris consist of the following components:
I Plan the sampling in detail, including:
- Research the suiicrure
- Lnspectthes ucture
- Perform lead screening on all suiicvure components
- Develop Sampling and Analysis Plan/Quality Assurance Project Plan
- Perform Job Hazard Analysis and Develop Health arid Safety Plan
2 Remove non-permeable components from the s ucture for recycle, reuse or other
salvage purposes.
3 Select a sampling approach for permeable components based upon screening results.
Determine subsamples to be cortiposited and &ning of sampling (before or after
demolidon). Figure 10-1 summarizes the four recommended approaches.
Recommendadons include:
- Before Dernolidon
Case I - analysis of composite of all permeable high-risk components that
indicates the presence of lead analysis of a composite of all permeable
low-risk components that indicates the absence or low levels of lead. Case 1
ii recommended when the high-risk components are suspected to be
hazardous.
Ose 2 - analysis of a composite of all permeable low-risk components that
indicates the absence or low levels of lead and analysis of a composite of all
permeable components. Case 2 is recommended when the presence of lead
has been de:ected in some components but the endre suucture is suspected :o
be non-hazardous.
Case 3 - analysis of a composite of all permeable components. Case 3 is
recommended if all screening results indicated the absence or low leveLs of
lead.
After Demc:: on - analysis of one or more composites of the permeable
debns pile. c:l1ec ed randohily.
85
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R .suinnak Recommended when the high—risk (+) components arc
c* )eclctl en I characteristically Isazartlutis.
l lcneli e - l’.pcce in prove that composite — is non-hazardous arnl
keep Cius ps 5 stc + segreg ied In reduce lsa ardouss
vmsitse sie_
Ri L - Ni smic.
Rationale — RecohIImI!flmIcgl wiscus else entire Is uutiuure I . punt e X 111.1 i i In he
cis.sraclerusiucally iu.I,.Ir4iinss even slutnugis ‘ I )u)Ic Cnuuipousrusl’ Ii.sti
luigh-ru k scrccning resusIp .
flcncl u e — l peci iii prove lihul Ct npo iie — IS ii n—lu. artluu anti lii )j)C hi
)1OVC Iluit Coniposuec—Ali is nuiuu-li,uianiun,. .
Risk — If oinpnssuc . . hazardous, rean.uiy . .s (per (‘.usc I) s ’
required to tide. inane luazartliu.ss fraci uius s.
Before Deniolit ion - Case 4
niposi
Rationale — Rccms,iuiicntlcii fl e entire s,u tuci ii i c i’ mit c pt- icti It, l)C
cha,.. ucrisi icahly hazardous and few/no coinponeni . I i.uii hugh -r. k
screening results. Also recommended whcn ii a niure ic ,i il)Ic
and/or cost-effective io process or se rcg 1 flc Colulpu nueiui ‘ I ills w .up
deniohiuion.
Single TCLP analysis. Simplified sampling if performed tin u ul
basis.
- — If entire building tests haiardosms and ue’ ampl ing misses ni n eis.in-
result, may i forced in scgrcg.sle anti s es.umi mule I II iii ii S\t• eisa SI i
structure as hazardous.
Coniposite of permeable Components that indicate high presence of lead (high-risk coniponems) b 4 sscd on screcuuhug pu miur iii tIciuii hiisisis
Composite of pcrmeiihk csumpm)nen ls that indicate luuw/no prescuLe mar lead (low-risk conuponeulis) h.uscd no cn enun it) tieuuui ihiliguiu
Ciumuupsisite 4 )1 p& ’rIuIeuI)k tIuuuipsIi%eflis represeiuiesi wuulsuui the Cflhii . pr r in tkihU)lhlitHi
( uuipi i%1iL FISPISI P 1 ’ II I 1k1 1 1 1e.uhiIe IlihulJk ulieflis 1 S ifl ti uiisilusIi lure.
Before Demolition . Case I
I
FIGURE 10.-i
SUMMARY OF RECOMMENDED SAMPLING APPROAChES FOR
PERMEABLE DEMOLITION DEBRIS
Composite
+
— — — — — — — — _ —
I
I Composite
J 4.. -
Before Demolition - Case 2
Composite
Composite
All
Before Demolition . Case 3
All
U .sussun.sle — Keco,uu, enikd when screening sruiucmsicd the absence of
or low levels 1)1 lead Ofl all components.
• Sing lcTCLPunu lysis.
- If entire building tests hazardous then rcsamphing/analysis
must occur.
Benefit
Risk
key:
— —
—
[ Al J
I
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4 Perform sampLing inciuding QAJQC samples. lJse 1/4-inch to 1-ir.c 5 z D :J
through the enare su s ate or pile. and collect : e drill cuttings and sscc:atec d.st
5 Evaluate sampling results to make a hazardous de:errrunauon for eac e: ot cui : :.
components represented by a composite sample.
6 If sample results are unexpected (e g.. c3mposite of permeable Lownsk Compor.ent.s
exceeded 5.0 mg.il_ in TCLP). use the rationale in Table 5-4 to deter ne whether
additional sampling and analysis is warranted.
10.2 SAMPLE ANALYSIS
Waste generators are required to determine whether or not their waste is hazardous. A was:e
may be hazardous because it is a listed waste or because it exhibits a hazardous characteris c
Lead-based paint (LBP) is not a listed waste and of the four hazardous waste characteristics, the
one applicable to LBP is toxicity. Toxicity testing requires analysis of the waste using the
Toxicity Characteristic Leaching Procedure (TCLP).
Screening methods such as X-ray fluoresence (XRF) or chemical test kits should not be used to
quantify lead levels, because the results are subject to equipment limitations and do not correlate
to TCLP levels. However, these screening tools are options for determining the absenc: or
presence of lead to support the sampling process during demolition planning.
Note that federal agencies do flQL currently recommend using chemical test kit results as the
basis for making decisions about abatement of lead in paint. soil, and dust. This
recommendation should also be considered for demoLition wastes. Several chemical test kit
evaluations are underway. After the evaluations are completed, updated information will be
available through the National Lead l.nforrriation Center. (National Lead Information Center.
1993) Also refer to the U.S. EPA Office of Pollution Prevention and Toxics study described in
Section 11.31.
Additional informati on on sample analysis is discussed in Section 6.0.
10.3 NON-HAZARDOUS CD DEBRIS MANAGEME t
Section 7.0 presents a detailed discussion of management options for non-hazardous C/D debris
including Iandfilling, burning and recycling. The recommended protocol for management of
non-hazardous C/D debris is as follov s:
I Identify non-hazardcus debns through screening and quantification as described in
Section 5.0.
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2 Segregate the debris :.:c the foiic wing cate2orles through manual cr mechanical
processing:
• wood
• metal
• concrete. bric.. cinder bicck, stone, glass, plaster. shee ock. die, asphalt
roofing materais
• other
3 Select recycle marke .s for each type of debris category based upon Cost-effecdve,
available, and reliable processing facilides.
4 Lncinerate the wood cebris in a V. aste-to-erlergy facility or use the wood as fuel in a
con o lied burner. (Nate: The viability of this opdon is subject to future regulatory
changes.)
5 Select disposal of debrs in a Subdde D landfill only if all other opdons are not viable.
10.4 HAZARDOUS C/P DEBRIS MIN AGEMENT
Secdon 8.0 presents informadon cn management requirements for hazardous GD debris,
including generator status, n ea enL burning, recycling, and handling. The recommended
protocol for management of hazadous CiD debris follows:
I Minimize the volume of hazardous debris through sc egadon and testing.
2 if the volume of haza ous debris is small, select ex action or des uction ea nent
technologies appropriate to the ma ix that is contaminated. Treat the debris in
compliance with requLed performance or design and operating standards for that
technology.
3 Test the n eated debris using TCLP to determine whether it exhibits the hazardous
characteristic of Lead toxicity.
4 If the eated debris dces not exhibit the toxicity characteristic, neat it as a non-
hazardous waste. Refer to Section 7.0 for recommended protocols for management of
non-hazardous debris.
5 If the created debris sdlI exhibits the toxicity characteristic, re eat and test it. or
dispose it in a SubdUe C disposal facility.
6 Manage the residuals generated by the eam ent of hazardous debris as a hazardous
waste. If appropriate d technologically feasible, recycling at a metals recovery
facility may be an opcon.
7 If technologically feas: Ie and in compliance with RCR.A Subtitle C regulations,
consider burning or re se management options such as cement kilns or metals
recovery facilities for urge volumes of hazardous GD debris.
8 Comply with all appl 2bLe storage, manifesting. packaging, labeling, mar ng,
placardins. uansporu: n. recor±keeping. arid reporting requirements.
0, :
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11.0 CON1T UED PROGRESS
This re;ort represents a Snap-shot’ in .rrIe of the state of the issues regarding m :g — -:
whole-snucure demolinon debris conuinmg lead-based paint (LBP). Recommended protocols
have been developed and presented for such important ac vi es as sample coUec cn. sample
analysts. non-hazardous cons ctiori/demohuon (CID) debris rna.nagemenL and hazardous CfD
debris management. The use of these protocols by con actors performing demolidon for federal.
state, municipal. and private c!.ierits will improve consistency arid compliance with applicable
reguladons. Use of the prococ ls will also result in the generadon of additional data to further
refine the protocols and con cute to our collective knowledge base in this area.
Continuous improvement wilt also arise from a unified effort involving the interested and
affected parties to share inforrr.ation. investigate and evaluate alternative methods, and develop
s ategies for improved approaches to this complex issue.
This section of the report presents a general three-step approach for ma ng continued unified
progress in addressing this asie management challenge (Section 11.1). Recommendations for
continued progress in technicaL economic, and regulatory areas are discussed in Section 11.2.
Section 11.3 summarizes a number of ongoing studies that will yield other relevant information.
11.1 GENERAL APPROACH
The first step in the general thie-step approach for continued improvement in the management
of whole•s ucture demolition debris con ining LBP is to identify and receive committed
participation from interested nd affected parties. Participants may include but are not limited to
the following:
Federal Regulatory Agencies
• U.S. EPA Regions I through X. including laboratories
• U.S. EPA Office of Solid Waste
• U.S. EPA Office of Pollution Prevention and Toxics
• U.S. EPA Office of Research and Development
• U.S. Depar tent of Housing and Urban Development (HUD)
• U.S. Occupational Safety and Health Adminisn ation
• U.S. Depar ncnc of Agriculture (Forest Products Research Laboratory)
State Regulatory Agencies
• State Solid Waste Azencies
89
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Depar .nent of Defense
• U.S. Army E ’.ironmental Hygiene Agency
• U.S. Navy
• U.S. Air Force. Armsu ong Laboratory. Brooks Air Farce Base
Depar nent of Energy (DOE)
• Waste Manasement Representatives at DOE Headquarters and FaciLities
Cori actors
• Demolition Indus y (e.g.. National Association of Demolition Con actors)
Industiy Groups
• Solid Waste Management Associations (representing waste-to-energy facilities and
landfills)
• Lead Recycling Endusny (e.g., Lead Indus ies Association)
• Cement Kiln Lridus y (e.g.. Cement Kiln Recycling Association)
Other Involved Organizations
• American Society for Testing and Materials
• National lnstinite for Standards and Technology
The second step in the improvement process is for the interested and affected parties to recognize
and accept the major goals of the developing LBP C/D management stiategy including the
following:
• Protect human health and the environment from risks posed by sampling, testing,
handling, managing, recycling, burning, ueadng and disposing C1D debris containing
LB P.
• Develop more cost-effective and reliable methods to manage C/D debris.
• Minljjfze the volume of wa.ste determined io be hazardous.
• Increase the volume of waste being recycled and reused.
• Increase the volume of waste converted to energy through burning.
• Increase the volume of hazardous wastes being u eated and decrease the volume of
hazardous wastes being d sposed.
The third step in this process is to continue to evaluate current practices through the assistance of
the “experts” in this issue. These e’ perts are persons who are currently involved in the
on
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management of whole- uct’ .re e:noLt:on debns : ntaIni.ng LBP and ‘Aho have ch rroS(
relevant in orTTlaUon to con ± :e :o po Lble solu:cns. Curre t debris mana e e praLriLe
such as sampling. teswig. rec .c..r g. re e. bUlTnfl2. eat.-r.e t. and dispo il hculd e ‘. aJua:
in the icilowing detailed areas.
• cost
• demonsnatcd penforrria.nce
• availability
- • environmental risk
• technical resu-ic cns
• regulatory res cuons
• regulatory and insticuuonal impediments
• available data
Effective and wide-reaching data collection snategies should emphasize the benefits of
teamwork by all parties invoked (regulators. generators. connactors, recyclers. eatrnent
facilities. etc.) in addressing this wue. Contacts with the following types of organizations are
recommended to maximize the communication networks existing within these organizations:
• Magazines specializing in recycling and demolition may print letters, articles, and
informal informauon requests.
• National and regional organizations may solicit information from their members in
periodic newsletters. The organizauons may be willing to assist in the nterpretauon
of the information. Examples of cognizant organizations include the following.
- Nationa.l Solid Waste Management Association
- National Governors Association
• Association of State and Territorial Solid Waste Management Officials
- Solid Waste Association of North America
- National Asso iauon of Demolition Conuactors
11.2 RECOMMENDATION’S FOR CONTP UFD PROGRESS
Additional infromation will cr: e t :mprove the current management approach. specLfically
in the technical. econormc. a- r . ireas. Recommendations for continued pro ess in
these three areas foUow
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11.2.1 TECHNICAL
Continued progress in he following technical areas is recommended.
• Gather and e’. aluate data compai-ng to’uciry characterisoc leaching procedure
(TCLP) and s ritheuc precipitation leaching procedure (SPLP) for lead-contarrunated
materials. Deterrrune appropriate protocol to predict potential leaching.
• Gather and evaluate data regarding dilution/attenuation factors for lead. Determine
effect on definition of characteristically toxic wastes.
• Perform research on new products and uses for recycled materials such as wood fiber
products and patented cold mix asphalt.
• Perform leachate studies to quantify risks (if any) associated with various
management options. including but not limited to the following:
- CfD landfill disposal
- MSW landfill disposal
- landscape mulching
- wood fiber applications (agrirnat)
- burning (bottom ash, fly ash, emissions)
• Quantify human and environmental exposure risks during demolition.
• Develop protocols for demolition activities to protect human health and the
envror intenL
• Improve lead screening tools to identify absence or presence of lead and to facilitate
segregauon of hazardous versus non..hazardous debris (e.g.. X-ray fluorescence
(XRF) and chemical test kits).
• Quantify eff ctivertess ofchippers/lioggers in removing LBP from debris wood. Test
wood chips and fines for toxicity.
• Investigate variability in analytical results due to sample collection and preparation
methods, including drills, saws, punches. arid other devices.
• Gather and compile available analytical data from demolition and abatement projects
to assess correlations between leachable lead levels arid total lead levels. Also
consider relevant factors such as substi ace type. paint thickness and lead content of
the paint.
11.2.2 ECONOMIC
Continued progress in the foIl .ing economic areas is recommended:
• Evaluate appropria ne s of increasing landfill tipping fees for non-hazardous debris
to discourage iispo iI
U,
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• Evaluate appropria:eness of establishing .Lrchar es on bu_’mn VLgin rna:eriij , 2s
opposed to recyclec materials, to encourage ac:e r1ce of CD debris for ‘ . as :e-to-
energy conversion.
• Modify technical specificanons. procurement polic :es. arid price preferences for
materials for consmicuon projects (high’ . ays. buildings. etc.) to increase use of
recycled materials.
• Perform market research for recycled products. Consider the following:
- gertera on rates
• end use markets
- tax credits
• sales and property tax exemptions
• grant proposals for en epreneurial business
11.23 REGULATORY
Con nued progress in the foLlowrng regulatory areas is recommended:
• Determine applicability of an exemption for recycled hazardous LBP debris under the
Requirements for Recyclable Materials, similar to current exemption of scrap metals.
40 C.F.R. Section 261.6(a)(3)(iii).
• Determine applicability of an exclusion for hazardous LBP debris similar to the
current exclusion for arsenical- eated wood or wood products. 40 C.F.R. Secnon
261 .4(b)(9).
• Evaluate available data and determine appropriateness of modifying lead toxicity
characteristic levels based on dilution attenua on factors.
• Quantify. evaluate and eliminate siting impediments for CiD debris reprocessing
facilities.
• Institute waste bans in all szates resuicting Iandfihling or incineration of recyclable.
reusable, or compostable wastes.
• Evaluaxe ihconsistencies among state/local requirements to prevent the legal or tlle ai
dispouIof one state’s wastes in another state due to Less suingent requirements. The
North sz Waste Management Officials Associauon (NEWMOA) report addresses
this subject for NEWMOA states. Areas to be addressed include but are not limited
to the following for landfills, reprocessing faciliucs and thermal desuuction units
- definitions
- management standards
• disposal Limitanons
• penalties
- enforcement approaches
• Investigate regula: re Q-1cuons on recycling of secondary lead waste (e.g
baghouse dust resuiting from burning GD debris).
43
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11.3 f) GOING STUDIES
A nurrcer of studies are being cond.::ed by various organizations re aced to th nagerre t of
dernoi::Ofl debris containing LBP A brief summary and a suggested contaCt are ;resented for
each sr dy.
11.3.1 U.S. ARMY ENV ONMENTAL HYGENE AGENCY
- The 1..S. Army Environmeritai Hyg:e’ie Agency (AEHA) performed a study to .ssess the waste
charac:eristics of debris that is contaminated v 1 ith LBP. The study focused On t e debris
generated from the dernoliuon of Arr iy WWTI-era smicrures but also addresses ether waste items
such as those resulurig from abatemeflt and renovation activines. The report a.sscctated with this
study is entitled “U.S. AEHA Interim Final Report. Lead-Based Paint Contaminated Debris-
Waste Characterization Study No. 7-26-JK4.4-92. May 1992- May 1993.”
The conclusions of this study fot1ow
a. Characterization: Whole-Building Demolition Debris . The findings showed that
(statistically) whole-building demolition debris (e.g., Army WV/U-era s uctures) can
be characterized as non-hazardous waste so long as certain assumptions/a.ssertions are
made:
(1) Other hazardous components such as asbestos or PCBs (from light ballasts
and roo ng c.lrs are not present/or are removed and disposed separately-
(2) Metals components su h as ductwork, furnace/boilers. piping. or siding are
removed to the extent feasible as scrap materials for reuse/recycling.
(3) AU remaining material (i.e., all those materials that v.ere included in the
sampling process such as both painted and unpainted wood components.
brick, concrete. foundauon material) must comprise a single wastes earn at
the point of generation (when the building is demolished). This wastes ’eam
must be handled as a single. discrete wastes eam and disposed of all
together.
b. Characterization: Sma1l . cale Debris . Debris that is generated during renova on.
maintenance, or abatemer t acnvines such as paint chips. blast gitlrr.edi: r personal
protecñve equipment i more likely to be characterized as ‘hazardous” due to the
concen ated mass of LBP For these types of wastes, hazardous waste generation can
be minimized throi. h ‘ .‘a segreganon techniques. For some wases. cost sa ings
can be achieved —. irruzu g sampling and analyses.
c. Dtsposal .
(1) Non-h2 ‘ -.. ‘ \ . a te. While disposal in a C/D debris !and ll may be
apprc j i , y ine cpensive at this time. generatcrs should
cons r r - :- un’, thai offer more than an “out-of-sight. out-of-mind”
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solution 1.n fact. new/impending res ictions on C/D de: s la :s m.iy
force the cost of this disposal option to greatly u icreaSe Other :“ may
be less e pensi e andJor more environmentally acceptae State acd.ir
local regulatory invo1 ernent will be necessary when a S5ing •ae
feasibility of such alternatives.
(2, Hazardous Waste. The volume of LB P-related haaardCuS waste saould be
rruni.rnized to the extent most feasibly and economically ossible. Tnis can
be done through careful assessment of operadons and segegauon of
wasresa eams as well as separation of contaminated iterr.s or removal of
LBP.
(3) Recycling. Many items such as metal ductwork. piping. and siding can be
salvaged from buildings that are to be demolished for recycling/reuse.
Recycling can provide econorruc gains in addinon to the eflvironrreical
benefits associated with a reduced wastesueam.
Recomrriendadons presented in this study are:
a. ldendfy whole-building demolidon debris wa.stesu eaIn popu .ladons that meet the
descriptions discussed in this report.
b. Characterize such waste as non-hazardous, pending concurrence from state and local
agencies.
c. ldend.fy other sources of lead-paint-containing waste and debris. Determine
appropriate waste segregation and management procedures based on cost-analyses
and findings discussed above
d. Evaluate the potendal for environmental media (e.g.. soil) conraminadon at
demoLidon sites, specifically with regards to future-use scenarios and human health-
risk
e. Develop SQPs for demoLidon site operauons to minimize environmental
contaminauon amid health hazards.
f. Assess current disposal procedures for demoiidon debris. Correct deficiencies/make
amendn ents to con acts and/or SOPs with regard to final desdnadon, liabilities, and
conuoL
g. EvaI ze disposal opdons and alternatives with regards to environmental arid other
regulaxrny requirements, cost, and other benefits/disadvantages.
Veronique Hauschild at the U.S. Army Environmental Hygiene Agency may be contacted for
more informa on at (410) 671-2953.
11.31 U.S. EPA OFFICE OF POLLUTION PREVENTION AND TOXICS
The U.S. EPA Office of PoU ncn P e ention and Toxics (OPPT) is conducthig a study
comparing results from various e hnologies for fleld measurement of lead tn LBP.
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‘. en berger. 199 3.i The :esulr.s :f the stud> . ‘ill be c ristdered b . HLD : ‘. - e ’.e cpment
of for abatement of federally assisted housing.
The ngou1g study evaluates the vartabijicy in cornsnon LBP eld r easureme : :ecnniques
including six brands of lead test kits and nine types of portable XRF ins iiments. Painted
surfaces in houses in Denver and Philadelphia are being tested using both types oi field
measurement devices. Confirma on samples are being analyzed at fixed-based laboratones
using standard analytical 1nw uments. The following painted surfaces are being analyzed in each
house: metal, wood, concrete, brick, drywall, and plaster.
The field phase of the study is scheduled to e ‘id through October 1993 with a draft report
scheduled to be completed by February 1994. For more information regarding this study, contact
John Schwemberger, U.S. EPA Office of Pollution Prevention and Toxics,
‘)2) 260-7195.
11.3.3 U.S. AIR FORCE ARMSTRONG LABORATORY
The Department of the Air Force Armsuong Laboratory at Brooks Air Force Base, Texas, is
developing a LBP procedural guide for installation engineers tasked with abatement/disposal
diagnosis of LBP in the Air Force. (Fisher, 1993) Further information is available from Lt.
Catherine Fisher, Arms ong Laboratory, at (210) 536-3305.
11.3.4 CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION
The Connecticut Department of Environmental Protection (CT DEP) is preparing a brief question
and answer (Q&A) guide on the subject of LBP swucture sampLing, characterization, and
assessment. (Binneil, 1993) The Q&A guide will include a waste characterization approach
that will rely primarily on portable XRF readings to support sampLing. segregation, and disposal
decisions duringwholc’s ucture demolition. The approach under developmei t currenriy
includes the folio ring steps:
1. Characterize painted surfaces using a portable deep peneuating XR.F device and
select the average, or perhaps the highest. XRF value.
2. Estimate the painted sui-face area.
3. Determine the product of the painted surface area (2) and the XRF concena ’auon (1)
to yield the mass of d in the su ’uctu.re (safety factors may be recommended to
provide conser au timates of total lead mass due to potential error in surface .ire.i
determinations and \RF re2dlngs).
‘Th
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4. Estimate the mass of tne stiucure to be disposed using average e sitie a-d
esdniated volumes of building components (e.g.. wood. concrete. cr.Lk.
5 Determine the estimated lead concen atiOfl in the sa’ucture using [ e d
mass (3) divided by the esurriated building mass (4)
Compare the estimated lea.d concen ation in the stiuicrure (5) to a “recogru.z d value
(e.g., 50 mg/kg total lead which represe s a dilution factor of (0 compared to the
TCLP method limit of 5 mg/i..).
7. If the estimated lead concentiadon is hizher than the “recognized value.” then handle
the building as a hazardous waste or perfoim more sampling, and possibly
segregation, prior to demolition.
8. If the estimated lead concenu’adon is lower than the “recognized value,” then handle
the building as a non-hazardous waste. (BinnelL 1993)
Information may be obtained by contacting the Waste Engineering and Enforcement Division of
the CT DEP.at (203) 566.4869.
11.3.5 EPA/BUD TITLE X
EPA and HIJD are also working on other lead abatement issues according to mandates in the
Title X legislation.
97
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York State Roundcable on Waste Wood Processiriz and CombustiOn for Fuel - Final
Report September 3. 1991.
New Yc’ tate Energy Research and Development Authority (NYSER.DA).
Procee : Df the Second Lnternauonal Conference on Municipal Solid Waste
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New York State Energy Research and Development Authority (NYSERDA). Wood
Products in the Waste S earn. Characteriza on and Combustion Emissions. Draft
Final Report.
New York Times. New View Calls Environmental Policy Misguided. March 21. 1993.
O’Connell. ft. arid Rothchild, E. Ohio Environmental Protection Agency. Personal
communication with Karen McCluskey of CDM Federal Programs Corporation,
Fairfax, VA. February 23, 1993.
Ogden. I. Ohio EPA Solid Waste Depar ient Personal communication with Tara
Taft of CDM Federal Programs Corporation. Boston. MA. October 27. 1992.
OhlandL I. South Carolina Deparuitent of Health and Environmental Conu o1. Solid
Waste. Personal communication with Tara Taft of CDM Federal Programs
Corporation. Boston. MA. October 30. 1992.
Ohlandt. J. South Carolina Department of Health and Environmental Conu’ol. Solid
Waste. Personal communication with Joan Knapp of CDM Federal Programs
Corporation. Fairfax. VA. August 27, 1993.
Pacdlle.-M. Lead Paint Measure Should Ease Fears of Cleanup Cost. Wall Suect
JournaL October 13. 1992.
PaIerTnini, D. Palerrnini Associates. Personal communica on with Joan Knapp of
CDM Federal Programs Corporation. Fairfax. VA. January 27. 1993.
Palerrruni. D. Palerrnini Associates. Personal communication with Karen McCluskey
of CDM Federal Programs Corporation. Fairfax. VA. February 8, 1993.
Patterson. J. I erria: ona1 \teuls Reclamation Co. Personal communication with
Karen McC1uske c CDM Federal Programs Corporation. Fairfax, VA. February 17.
1993.
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Pearce. M. EPA Office of Poiluuon Prevermon and Tox cs Perscr 0rr rnun: a )n
with Joan Knapp of CDM Federal Programs Ccrporaoon. Fairfax. ‘ v.A. October 6.
1992.
Pearce. M. EPA Office of Poilution Prevermon and Toxics. Personal COmmurucauon
with Joan Knapp of CDM Federal Programs Corporauon. Fairfax. ‘v A. Octoce 9.
1992.
Perrault. 1. New Hampshire Department of Environmental Services. Personal
comrnun ca on with Tara Taft of CDM Federal Programs Corpora Ofl. Boston. MA.
September 17. 1992.
Peterson, J. New York State Energy Research and Development Authority. Personal
communication with Joan Knapp of CDM Federal Programs Corporauon. Fairfax. V -\.
September 10. 1992.
Pregman. T. Connecticut Department of Environmental Protection. Personal
communication ich Joan Knapp of CDM Federal Programs Corporation, Fairfax. VA.
August 27, 1993.
Rhode island Department of Environmental Management. Division of Air and
Hazardous Materials. 1992. Rules and Regulations for Solid Waste Management
Facilities. Regulation DEM-DAHM-SWO3-92.
Rigenhagen. R. Rom.ic Chern.ical Corp., Solid and Hazardous Waste Recycling
Services. Personal cornmuriicadon with Karen McCluskey of CDM Federal Programs
Corporation, Fairfax. VA. February 17, 1993.
Riltopwood, E. U.S. Air Force Armsti’ong Lab. Personal communication with Karen
McCluskey of CDM Federal Programs Corporation, Fairfax, VA. March 16. 1993.
Robinson, W., editor. 1986. The Solid Waste Handbook. John Wiley & Sons.
Ro [ niaszek, R. B.ucher, Myers, Polniaszek. SilJey Associates. Inc. Personal
communication with Tara Taft of CDM Federal Programs Corporation. Boston, MA.
October 22. 1992.
Roof. 1. Pennsylvania Department of Environmental Resources. Personal
commu ca on with Joan Knapp of CDM Federal Programs Corporation, Fairfax, VA.
August3? 1993.
Rothschild, E. Ohio EPA Hazardous Waste Department. Letter to Schmaltz, Sr. Re:
Disposal of University of Cincinnati Wastes. October 18, 1991.
Rothschild. E. Ohio EPA Hazardous Waste Department. Personal communication
with Tara Taft of CDM Federal Programs Corporation. Boston. MA. October 29,
1992.
Rothschild. E. Ohio EP.; Hazardous Waste Department. Personal communication
with Tara Taft of CDM Federal Programs Corporation. Boston, MA. January 12.
1993.
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Rupp. G. Lmver zy of \e’. ada Las Vegas Personal cormrnunication ‘.‘ith Joan Knap
of CDM Federal crams Corporation. Fai.rfax. VA September 24. 192.
Sandberg. W P:ce Lab. [ r.c Personal ccrr.muruc n with George DeLullo of CDM
Federal Pro ams Cor ora cn, Golden. CO. Jariu...-; 29. 1993.
Schmidt.. K. Lab Dtrectcr. Me o Lab Surfaces. Per ona1 communiCa:ort with Susan
Collagan of CDM Federal Programs Corpora cn. Boston. January 21. 1993.
Schwernbcrger. I. U.S. EPA Office of Pollution Prevention and Toxics. Personal
comrriuriica on wth Joan K. app of CDM Federal Programs Corporauori. Fairfa.x. V.A.
August 30, 1993.
Seattle Solid Waste Depar ent. Personal communicadon with Joan Knapp of CDM
Federal Pro grams Corpora on. Fairfax. VA. January 27, 1993.
Seiler. F.A. 1987 A Rzsk.Weighred Strategy’ of Statistical Sampling. Journal of the
Institute of Nuclear Materials Management. 16:129-133.
Seirifeld, J. 1986. Atmospheric Chemis y and Physics of Air Polludon. John Wiley
& Sons.
Seymore, B. South Carolina Department of Health and Environmental Con l.
Personal commuriica on with Tara Taft of CDM Federal Programs Corporauon.
Boston, MA. October 29. 1992.
Seymour, M. Pic Tech. Personal communication with Karen McCluskey of CDM
Federal Programs Corpora on. Fairfax. VA. January 27, 28, 1993.
Shafer. C. Rhode Island Department of Environmental Management, Division of Air
and Hazardous Materials. Personal communications with Tara Taft of CDM Federal
Programs Corpora on. Boston. MA. September 17. 1992.
Smith. J. Housing Authority of Savannah. Personal communication with Tara Taft of
CDM Federal Programs Corporanon. Boston. MA. October 22, 1992.
Spittler, T. EPA Region 1. Bibliography of literature collection of Thomas Spittler.
Topic: Lead Risk.
Spirtler,.T. EPA Region 1. Personal communicanon with Joan Knapp of CDM
Federal Programs Corporation. Fairfax, VA. September 28. 1992.
Swartzbaugh. J. et al. Rernediaring Sires Contaminated with Heavy MeraL . Hazardous
Material ConuoI. November-December 1992. pp. 36-46.
Taylor. M. Demolition A e ‘ .lagazirie. Personal communication with Joan Knapp of
CDM Federal Proararri. Fa ..-fa. . VA. October l 1992.
Topping. D. EPA Offlce of Solid Waste. Personal communication, with Joan Knapp
of CDM Federal Programs corporation. Fa irfax. VA. September 16. 1992.
Topping. D EPA Office f Solid Waste. Personal communication with Joan Knapp
of CDM Fedemal gra s C roracion. Fairfax. VA. January 2. 1993
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