36C24118R0072-00001005.pdf

STATE OF CONNECTICUT

DEPARTMENT OF

ENVIRONMENTAL PROTECTION

79 Elm Street Hartford CT 06106-5127 www.ct.gov/dep

Gina McCarthy, Commissioner Bureau of Materials Management & Compliance Assurance

Guidance for the Management and Disposal of Lead-Contaminated Materials

Generated in the Lead Abatement, Renovation, and Demolition Industries

November 4, 1994 Revised November 21, 2005

Updated May 18, 2007

The Department of Environmental Protection is an equal opportunity/affirmative action employer, and its programs and services are offered without regard to race, color, religion, national origin, age, sex, or disability. In conformance with the Americans with Disabilities Act, the DEP makes every effort to provide equally effective services for persons with disabilities.

Individuals with disabilities needing auxiliary aids or services for effective communication should call 424-3035 or TDD 424-3333.

~ Printed on recycled paper: at least 20% post-consumer content

PREFACE

DEP has based this guidance on data which is currently available regarding wastes which contain lead-based paint. However, it is possible that as this guidance is implemented and more and more sampling of lead-based paint wastes is performed, additional and more significant data trends may emerge which may justify significant changes in this poli~y. In particular, large-scale sampling of whole-building demolition debris may reveal that this particular material is non-hazardous an overwhelming percent of the time, thus justifying an across-the-board "knowledge of process" exemption by DEP.

Toward this end, DEP is requesting any and all sampling results on demolition debris in Connecticut. To be useful to us, however, these sampling results should be accompanied by the following information:

i. the town and street address of the building demolished.

2. the type of building (i.e., its use and materials of construction).

3. the age of the structure.

4. were any portions of the debris recycled or reused in any way?

5. was lead screening performed prior to sampling, or was lead known to be present for some other reason?

6. a description of how the samples were taken.

All such data should be sent to DEP at the following address:

Lead Data Coordinator Waste Management Bureau Waste Engineering & Enforcement Division Department of Environmental Protection 79 Elm Street Hartford CT 06106-5127

Also, in a related matter, the United States Environmental Protection Agency (EPA) is considering deferring the regulation of architectural debris containing lead-based paint to the Toxic Substances Control Act ("TOSCA").

Appropriate management standards for such materials are being researched by EPA, and, if incorporated by DEP, could result in reduced regulation of these materials.

DUE TO THE ABOVE, THIS GUIDANCE DOCUMENT IS SUBJECT TO CHANGE AT ANY TIME

WITHOUT NOTICE.

Interested persons should monitor DEP and EPA publications for further developments in these and other areas related to the management and disposal of lead-based paint debris.

NOTE: the term "whole-building demolition debris" as used here refers to debris from the removal of entire structures, after appropriate recycling/source reduction has been conducted. See Section VI.D. below for more information regarding recycling options and requirements.

ACKNOWLEDGEMENTS

This document was written by Ross Bunnell of the Waste Engineering and Enforcement Division, with considerable input and assistance from the following persons:

* George Dews, David Sattler, and John Berg of the Permits Section of the Waste Engineering & Enforcement Division.

* Thomas Pregman, Charles Atkins, John England, and David McKeegan of the Solid Waste Section of the Waste Engineering & Enforcement Division.

* David Nash, Director of the Waste Engineering & Enforcement Division.

* Lynn Stoddard and Earl Beebe of the Planning and Standards Division.

* Gregory Piontek, Director of the PCB, Underground Storage Tank, and Marine Terminals Division.

* Elsie Patton, Betsey Wingfield, and James Crier of the Water Management Bureau.

* Susan Amarello of the Air Management Bureau.

* Paul Balavender, Counsel to the Commissioner.

* Robert Moore, Deputy Commissioner.

* Edith Pestana, Narda Tolentino, and Leslie Cole of the Connecticut Department of Public Health and Addiction Services.

ii.

TABLE OF CONTENTS

II.

III.

IV.

Section Number and Title Page

PURPOSE

SCOPE

APPLICABILITY

CHARACTERI2ATION

A. Important Note

B. Assessment for Hazardous Constituents Other than Lead

C. Characterization of Lead Contamination

i. The Required Analytical Test -- the TCLP

2. Strategies for Sampling and Characterization

a. Screen, Sample and Segregate

b. Screen and Segregate

c. Composite-Sample and Demolish

d. Remove, Cut and Sample

e. Screen and Calculate Lead Concentration

f. Demolish and Test ................................... ~...

D. Use of Combined Sampling Strategies

E. Recordkeeping

F. General Trends ........................... , HANDLING REQUIREMENTS.., A. An Overview of Handling Requirements Other than

I.

...12

...13 for Waste Disposal...16

DEP’s Water Management Bureau

OSHA (the Federal Occupational Safety & Health Administration...18 iii.

VI.

4. Connecticut’s Department of Public Health and Addiction Services

(DPHAS)

5. The Requirements of the State Fire Marshal’s Office, Division of Fire, Emergency and Building Services

Plastic Sheeting/Disposable Clothing/PPE iv.

2. Connecticut-Regulated Waste

3. Non-Hazardous Solid Waste

C. Disposal of Non-debris Waste

i. Contaminated Soil

2. Wastewaters

3. Dry Decontamination Residues

4.

DISPOSAL

A. Important Note

B. The Three Basic Classifications of Waste Which Can Be Generated.

i. Hazardous Waste

¯ o °29

¯..29

¯ o .3,0

¯ o .3,1

¯..31

¯..31

¯..32

Residential Sites and the "Household Hazardous Waste" Exemption

I. Residential Lead Removal Work Done by "Do-It-Yourselfers."

2. Residential Lead Removal Work Done by Contractors

6. Certain Local Requirements

B. Determining Hazardous Waste Generator Status

C. Requirements for Non-Handlers

D. Requirements for Conditionally Exempt Small Quantity Generators (CESQGs)

E. Requirements for Small Quantity Generators (SQGs)

F. Requirements for Large Quantity Generators (LQGs)

G. Requirements for Treatment, Storage and Disposal Facilities (TSDFs)

Requirements for Hazardous Waste Transporters

5. Spent Solvents, "Peel-Away" and Other Chemical Wastes

Recycling Options and Requirements

i. Scrap Metal Recycling and Architectural Salvage

2. Recycling of Building Debris for Lead Values

a. On- and Off-Site Recycling of Non-Hazardous Building Debris

b. On-Site Recycling of Hazardous Building Debris

c. Off-Site Recycling of Hazardous Building Debris

FIGURES

Figure i: A Flow Chart Illustrating a Suggested Sampling Regime Which Could be Used for Most Lead Removal Projects.

Appendix i:

Appendix 2:

Appendix 3:

Appendix 4:

Appendix 5:

Appendix 6:

Appendix 7:

APPENDICES

Contacts to Call for Further Information.

List of Treatment, Storage and Disposal Facilities (TSDFs)

EPA Memorandum, "Lead-Based Paint Residues and Lead Contaminated Residential Soils in Private/Public Housing Units," dated November 20, 1987.

List of Transporters Permitted in Connecticut.

Connecticut-Regulated Waste.

List of Lead Recycling Facilities.

Useful References.

This page intentionally left blank.

I. PURPOSE.

This document is intended to assist lead abatement contractors, renovation contractors, demolition contractors, homeowners, and other interested parties in complying with DEP’s waste management regulations as they apply to the characterization, handling, storage, transportation, and off-site disposal of lead-contaminated building materials, and certain other related wastes. While this document was prepared primarily to address materials contaminated with lead-based paint (LBP), these guidelines may also have some applicability to other types of lead contamination.

II. SCOPE.

The types of activities which could be impacted by this guidance include:

Removal of the Lead Contamination from the Surface of a Material (i.e.

by chipping, sanding, scraping, chemical treatment, etc.);

Lead Abatements of housing units, including those being conducted voluntarily as well as those being conducted in response to a directive by a State or local health official.

Renovation Activities (i.e., the removal and replacement of selected building components such as windows, doors, trim, baseboard, wallboard, siding, etc.);

Whole-Building Demolition (i.e., the wrecking and removal of all or a large portion of a structure which contains lead-contaminated materials); and, Disposal of Contaminated Soil (created, for example, as a result of the normal weathering of a lead-contaminated surface, or by an improperly-conducted lead abatement).

This guidance document is primarily intended to provide assistance in the waste management aspects of these types of projects (i.e., characterization, handling, storage, transportation, and off-site disposal). As a result, this document does no__t provide in-depth ~uidance for numerous other possible concerns which may exist. For example, this guidance does not address worker protection requirements. It does not describe the proper procedures for conducting household lead abatements. It does not provide guidance on soil or groundwater cleanup standards. It does not comprehensively address the on-site disposal of wastewaters or other contaminated materials. It does not comprehensively address the requirements which must be met if there are air releases from a work site. It does not describe in great detail the requirements of the State Fire Marshal’s Office for demolition contractors.

And, it is not a comprehensive guide to the many local requirements which may apply. Persons engaging in lead removal activities should take great care to ensure compliance with the requirements of any other applicable local, State or Federal regulatory programs. For additional, limited information on some of these topics, the reader should refer to Section V.A. below.

III. APPLICABILITY.

This guidance would apply to anyone generating lead contaminated materials in the State of Connecticut, including:

* Individual homeowners ("do-it-yourselfers"), Contractors employed by individual homeowners, landlords, or commercial or industrial clients to perform lead removal at residential sites, and

Contractors and commercial or industrial property owners generating lead-contaminated debris as a result of routine maintenance or one-time cleanups at non-residential sites.

The specific requirements that would apply to each of the different types of generators above vary significantly. See the following sections for complete details. In particular, since they are the least reKulated of the above-listed cate£ories, individual homeowners doinK the removal work themselves should skip directly to Section V.I. below for information relatinK specificall7 to them.

Those from either of the other two categories listed above should continue reading for instructions on the proper management of their waste materials.

IV. CHARACTERIZATION.

The first and most important step in any lead removal project is to assess the site for the presence of hazardous waste constituents and to characterize the materials that will be removed in order to determine proper disposal.

This section has been confined primarily to the characterization of lead-contaminated building debris, since their characterization presents the greatest challenge. Although other materials may be generated at a lead removal work site (such as decontamination residues, dust sweepings, personal protective gear, contaminated soil, etc), their characterization is not as difficult, and may be done in accordance with standard characterization methods developed for industrial wastes and contaminated soils. See Section VI.C., "Disposal," for information concerning some of the non-debris wastes which can be generated.

A. Important Note.

It is crucial that all generators of building debris use best efforts to obtain the information and conduct the analyses described in this section.

Failure to do so may result in that waste being improperly disposed, which would be a serious violation of State and federal law (see also Section VI.A. below regarding the importance of ensuring proper disposal).

B. Assessment for Hazardous Constituents Other than Lead.

In order to properly characterize the building materials being removed, it is necessary to first determine whether or not hazardous constituents other than lead are present at the site. This is especially important for industrial or commercial sites which may have used hazardous chemicals for manufacturing, wastewater treatment, maintenance, or other purposes.

Pesticides, asbestos or polychlorlnated biphenyls (PCBs) may also be present at some sites, complicating characterization issues. Another possible concern is chromium contamination, which could be present if lead chromate (red) primer was used at a site. This primer was most commonly used on steel and other corrodible metals.

Sources of information which can be used in assessing a site for non-lead-based contamination include:

i. A physical/visual site inspection.

2. Process, purchasing, and inventory records.

5. Material Safety Data Sheets (MSDSs).

4. Past and present owners, supervisors, and employees.

Town land records regarding past ownership and usage.

6. Files maintained by DEP’s Waste and Water Management Bureaus.

Analytical data (obtained either with field monitoring equipment, or through samples taken to a laboratory for analysis).

If a review of such information indicates that contaminants other than lead may be present at the site, then any materials removed will have to be assessed for the presence of these additional contaminants, as well as lead, in order to determine their proper disposal. Since this is not likely to happen in the majority of lead abatement, renovation or demolition projects, and since it would be difficult to des4ribe here all the different ways that such a situation could be handled, we will forego any further discussion of it here in this guidance. Instead, DEP recommends that anyone in this situation who has uncertainties about how to proceed should contact the Waste Engineering and Enforcement Division for assistance (see Appendix 1 for a listing of DEP contacts).

C. Characterization of Lead Contamination.

If an assessment conducted in accordance with the previous section indicates that contaminants other than lead are no__!t present at the site, then the remaining characterization work can focus solely on lead. The remainder of Section IV describes procedures for characterizing building debris with respect to lead content.

i. The Required AnalTtical Test -- the TCLP.

Lead-containing debris not contaminated with other hazardous wastes is either classified as hazardous waste or solid waste, depending on its lead content. The required analytical test to determine which of these classifications is appropriate for a given quantity of lead-containing debris ms the Toxicity Characteristic Leaching Procedure, or "TGLP" (Regulations of Connecticut State Agencies Section 22a-449(c)-101(a)(1), incorporating 40 CFR 261.24). The TCLP nest subjects a 100-gram sample of a waste material to simulated landfill leaching conditions, and assesses the ability of the sample to leach out lead in this environment. The debris is classified as hazardous waste if the TCLP sample result is greater than or equal to

5.0 milligrams per liter (mg/l) of lead. The debris ms classified as solid waste if the TCLP sample result is less than 5.0 mg/l. See Section VI. below for definitions of solid and hazardous waste, and for a description of the disposal requirements for each of these materials.

There are many laboratories in Connecticut which can analyze samples for TCLP. DEP has a listing of these laboratories, copies of which are available free of charge. See Appendix 1 for a list of DEP telephone numbers to call to obtain a copy of the list. Also.

laboratories may be found in the Yellow Pages under "Environmental and Ecological Services" and "Laboratories - Analytical."

While the TCLP is the prescribed analytical test to determine if debris is hazardous or not, other techniques can be used to supplement or, in one case, in lieu of TCLP sampling. These include:

the use of laboratory methods other than the TCLP as screening tools. Possible methods include x-ray fluorescence (XRF), atomic absorption (AA), and inductively coupled plasma atomic emission spectrometry (ICP-AES).

the use of ~ortable x-ray fluorescence (XRF) instruments to identify lead-contaminated surfaces in the field. Most portable XRF units display a numerical value, expressed in milligrams per square centimeter (mg/cm-), which indicates the amounn of lead present in the material being screened. It should be noted that different XRF units vary in the depth to which they detect lead.

~s a result, for porous materials (which may have absorbed lead beyond the immediate surface), and for assessing lead-based paint (where there may be multiple layers of paint), deep-sensing XRF should be used to be sure of detecting all the lead that might be present in the debris.

the use of chemical spot testers, most of which utilize some type of colorimetric technique to indicate the ~resence of lead contamination. Although these nesters are inexpensive and easy to use, they do not quantify the amount of lead present, and may react to metals other than lead, thus producing "false positives." In addition, they only provide information about the outermost surface of the material being tested (not the underlying layers), and may be ineffective for darkly colored surfaces. Also. the Department of Public Health and Addiction Services’ Lead Poisoning Prevention Regulations do non allow the use of these nesters in state-ordered lead abatements. As a result of these problems, use of these spot testers is generally not recommended. However, there may be some usefulness with these spot ~esters for preliminary waste-screening purposes, prior to portable XRF or laboratory analyses.

the hazardous waste regulations specifically allow the use of "knowledge of process" in lieu of analytical sampling in order to characterize a waste (Regulations of Connecticut State Agencies Section 22a-449(c)-102(a)(1), incorporating 40 CFR 262.11(c)(2)). "Knowledge of process" is usually applied in industrial situations where the chemical constituents of a waste stream can be calculated using information known about the feedstocks and processes which generate the waste. However, this alternative may be utilized in any situation in which specific and reliable information is known about a waste stream which justifies foregoing TCLP analysis. As a result, this approach could have some limited applicability in the characterization of building debris. For example, if a wooden floor was being removed from a lead-acid battery manufacturing plant, and data were available on the concentrations of lead in the battery electrolyte, it might be possible to show through a simple calculation that the sections of the floor which had been saturated by spilled electrolyte would have retained enough lead to be hazardous waste (thereby avoiding the need to take a TCLP sample).

A similar ap’proach might also be taken in a different case to demonstrate that a certain debris was non-hazardous without taking a TCLP sample. However, greater care must be exercised when using knowledge of process to demonstrate that something is non-hazardous, since any errors or oversights could result in that material being disposed of improperly (see Section IV.A., "Important Note," above). An outline of one method which could be used to conduct such a determination is presented in Section IV.Co2.e.

It should be noted that only method d. above can actually be used i_Kn lieu of TCLP sampling. Methods a. through c. can be used to provide direction as to where TCLP samples should be taken, or to reduce the number of samples that must be taken at a given site, but they cannot be used to totally replace TCLP sampling.

2. Strategies for Sampling and Characterization.

There are a number of possible strategies which may be employed to assess lead-contaminated debris while minimizing analytical and eventual disposal costs. However, DEP believes that, to be truly valid and adequate, any such strategy must have the following features: i.) the use of laboratory and QA/QC procedures which are in accordance with EPA guidance SW-846 (Test Methods for Evaluating Solid Waste Physical and Chemical Methods), or which are generally accepted good practice; 2.) the application of a logical and documented sampling regime which will ensure that the samples taken are truly "representative" of the waste being disposed of, and 3.) the use of field screening only as appropriate to provide direction in characterization efforts and to minimize the number of TCLP samples which must ultimately be taken to properly characterize the waste.

While it would be impractical here to enumerate every such strategy which would meet the above requirements, there are nevertheless several strategies which stand out in particular, as a result of their effectiveness, their convenience, or their ease of use. These strategies are listed in subparagraphs a. through f. below. Which of these strategies would prove best in a given situation will depend on available technical resources, time and financial constraints, the relative size of the removal project, and the general nature of the project. The costs for each strategy can also vary significantly from one project to the next. Persons conducting these kinds of projects are advised to compare costs and carefully consider which method would be best for their particular situation. Or, if another method not listed here seems more appropriate, persons may submit alternative sampling proposals for review and approval by DEP. Such requests

"should be mailed to: The Waste Engineering & Enforcement Division, Waste Management Bureau, Department of Environmental Protection, 79 Elm Street, Hartford CT, 06106-5127.

It should be reiterated that these strategies are primarily intended for building debris rather than decontamination residues, dust sweepings, personal protective gear, contaminated soil, or other non-debris wastes. The sampling of these non-debris materials can typically be conducted in accordance with the traditional methods used for industrial wastes and contaminated soils, and do not present the same difficulties as sampling whole or partial structures, which may be heterogenous in nature and physically difficult to sample. See Section VI.C. below for more information regarding non-debris wastes which may be generated.

Screen. Sample. and Segregate. The most straight-forward strategy is to screen the building components to be removed using a field method such as portable XRF. For those components which field screening indicates are lead-contaminated, representative samples would be taken and sent for TCLP analysis. Those materials which fail the TCLP test (i.e. have lead concentrations over 5.0 mg/l) would be segregated for removal as hazardous waste. The remainder of the materials to be removed would be removed a~ solid waste.

There is one aspect to this strategy which merits some forethought and caution: deciding how to collect truly representative samples can present a significant practical and technical challenge. The most conservative approach would be to sample every individual component. Although this might be acceptable in some projects, in others it could result in excessive and unnecessary sampling. An alternative would be to sample each similarly-contaminated surface, such as each room or each type of component (baseboard, trim, siding, etc.). This alternative would be especially useful and more appropriate in large projects with many similar components (such as a large apartment building or a housing complex).

Whatever methodology is used, care should be taken to ensure that the sample taken has a degree of surface contamination which is truly representative of the portion of the debris which it is taken to represent. For linear components (i.e., trim, baseboard, windowsills, etc.), the sample should consist of a full cross-sectional piece of the component. For non-linear components (such as windows), the sample should contain proportionally the same amounts of materials as the whole component (i.e., for a window, the proportional amounts of glass, wood, metal, paint, and glazing compound as are in the whole window).

Screen and SegreKate. This is a variation on the above method which offers cost savings on TCLP testing, but may increase the amount of material which will have to be disposed of as hazardous waste, thereby possibly increasing disposal costs. This strategy entails using field screening to identify lead-contaminated components. All such components would then be removed and segregated for disposal as hazardous waste, without any additional sampling or analysis. The remainder of the debris which was determined through field screening not to contain lead would be disposed of as solid waste.

DEP recognizes that this method appears to bypass the regulatory-required TCLP analysis. However, since the lead-containing materials will be disposed of as hazardous waste, DEP feels that this method is adequately protective of the environment, and, since it may result in significant cost savings in some abatement projects, that this approach is justified. DEP also feels that the current literature on lead concentrations in debris indicates that a large portion of selected lead-contaminated components fail the TCLP (see Section IV.C.4., "General Trends," below), and that this approach may often turn out to be nearly the same in result as the previous, more sampling-intensive strategy.

Composite-Sample and Demolish. This method utilizes composite samples to assess the lead content of the entire quantity of debris to be removed. First, the different building components to be removed (e.g. foundation, structural, siding, roofing, drywall, trim, windows, doors, insulation) are identified. Then, aliquots or "sub-samples" are collected of each of these components using a power drill, or by removing portions of each building component. These aliquots must be carefully selected to ensure that the resulting composite sample will be truly representative of all of the material being removed. The aliquots are then mixed together in proportion to their percent by weight in the total quantity of debris being removed. The resulting weight of this composite sample is not important, except that it must equal or exceed the 100-gram minimum sample weight specified for the TCLP test. The composite sampls is then sent for TCLP analysis. This composite sample, if taken and mixed properly, should be representative of the whole structure.

The number of composite samples collected should be no fewer than one per structure, or one per 2500 square feet of floor space, whichever results in the greater number of composite samples. If the composite(s) all come back with lead concentrations below 5.0 mg/l, then the debris may be disposed of as solid waste. If any samples come back which are not below 5.0 mg/l of lead, then either:

i.) the portion of the structure represented by that sample must be disposed of as hazardous waste, or

2.) that portion of the structure must be reassessed by some other method, such as identifying the lead-containing components and removing them for disposal as hazardous waste.

Because of the undesirability of dealing with these two possibilities, this method is best used in situations where it is stron£1v expected that the entire quantity of debris, taken as a whole, will not fail the TCLP. Use of this method in marginal cases is not recommended, since it is likely to increase sampling and analysis costs without ultimately reducing disposal costs.

The above description constitutes only a brief outline of this method. For further details on this characterization method, consult documents number 4 and 8 listed in the list of useful references in Appendix 7.

Remove, Cut, and Sample. This method was developed by the Denver Housing Authority for use in lead abatement projects in residential structures. The method involves several steps.

First, like items (i.e., trim, baseboard, siding, windows, doors, etc.) are removed from the structure and placed together. Next, the volume or weight of each group of like items is determined, and recorded. Then the items are cut into 33-inch lengths using a circular saw, table saw, or handsaw. During this process, the saw cuttings from each group of like items are carefully collected, containerized, labelled, and set aside for later compositing. After sawing, the like items are placed in 55-gallon drums or similar DOT-approved containers. Care is taken to ensure that only like items are placed in the same containers.

When all the items have been cut to size, a composite sample is made up, in a similar manner as in the previous method. That is, the saw cuttings obtained from cutting each group of like items are combined in proportion to their percent by volume or weight of the total amount of material being removed. In making this composite, amounts of each group of saw cuttings are selected so as to make up exactly a 100-gram composite sample (this is to allow the possibility for further analysis of the individual samples if needed later--see option 2.) below). The composite sample is then sent for TCLP analysis. If the result is under

5.0 mg/l of lead, then the entire quantity of material may be disposed of as non-hazardous solid waste. However, if the TOLP result is greater than or equal to 5.0 mg/l, then either:

i.) the entire quantity of material must be disposed of as hazardous waste, or the individual samples retained for each group of like items may be individually TCLP-sampled to determine if any of them may fall below the 5.0 mg/1 limit. Any materials which this additional TOLP sampling indicates are below 5.0 mg/l may be disposed of as non-hazardous solid waste, thereby reducing the amount of hazardous waste which must be disposed of.

Several important issues should be mentioned regarding this method. Firstly, although not required by this method, field screening may be used before removal in order to limit the procedure only to those materials which are lead-contaminated.

This use of field screening would likely reduce the amount of work required to obtain the samples, but may ultimately increase the likelihood of producing a composite which fails TCLP testing. Secondly, because of the labor-intensive way which the removed materials must be handled, this method lends itself best to household lead abatements and other projects which involve the removal of a fairly small number of selected building components. It should also be noted that the sawing lead-painted building components presents a significant lead dust hazard and must be conducted in a manner which will not result in soil contamination, or exposure to workers or residents.

Screen and Calculate Lead Concentration. This is a "knowledge of process" technique which uses known data to calculate the concentration of lead in the entire quantity of debris to be removed. This method is primarily intended for use in situations where the source of the lead contamination is lead-based paint (LBP), although it could conceivably he used in characterizing other lead-contaminated materials in which the lead is confined mostly to a consistent and distinct outer layer. The method involves the following steps:

2.)

4.)

use a field screening technique to determine those components which have LBP on them.

record the dimensions of the LBP-coated surfaces and calculate the total painted surface area (in cm ) on the components to be removed.

collect samples of the paint on the surface of the components to be removed, and submit them to a laboratory to determine the average weight percent of lead in the LBP, the average paint ~ickness (in cm), and the average paint density (inmg~m).

estimate the mass (in kg) of the components to be removed, Traditional engineering and/or demolition industry methods may be used in determining this estimate.

5.) determine the mass-concentration of lead in the debris as follows:

Area in cm ! *’:’~ Thickness in cm)

Mass of LBP ~Average Paint %--IVolume of LBP in mg ) ~ ~ Density in mg~m3J~ ~ in cm3

(Mass of ~ead)~Avorage Z) in LBP in mg ~--~ ~Lead in LBP ~ ~in mg

Mass Conc. of Lead %~ Mass of Lead in LBP in mR in Structure in mg/kg] Estimated Mass of Structure in kg

6.) Hazardous/non-hazardous determination:

Is this Mass Concentration < i00 mg/k~?

If Ye%: The debris may he disposed of as solid waste.

If No: The entire structure must either be re-evaluated using one of the methods a.

through d. or f. in this section, or it must be disposed of in its entirety as a hazardous waste.

The i00 mgikg value used in the Yes/No test above represents the lowest possible mass analysis concentration which could leach out greater than 5.0 mg/l in a TCLP test. This is due i0

7.)

to the 20:1 dilution ratio of the TCLP test protocol, and also assumes that 100Z of the lead in the LBP sample will leach out. Althou~h in reality a given LBP sample will rarely leach out 100Z of the lead it contains, this assumption is the only one that can be safely made in lieu of actual TCLP results~ in addition, the worst-case assumption adds a "safety factor" to compensate for possible errors in the LBP data or the estimated mass of the structure bein~ removed.

If the average lead content, average paint thickness, or average paint density numbers for a given project vary widely from one part of the structure to another, it may be appropriate to conduct separate "mass of LBP" or "mass of lead in LBP" calculations for each portion of the structure with similar values. The individual results for the different portions of the structure could then be summed before dividing by the mass of the entire structure. This would be appropriate, for example, in a case where the interior of a ~iven structure was painted with only two, thin coats of low-lead LBP, but the exterior had been painted with five, thick coats of high-lead LBP. As a simpler alternative, the highest numbers found in each category could be used for the entire structure~ if the calculation passes the 100 mg/k~ test even with the highest values, there is no need to ~o through the additional effort to weight the different portions of the structure in this manner, since the result can only be lower.

There is a short-cut variation of the above method which may be useful as a quick screening tool, to direct TCLP-samplin~ efforts, or to confirm non-hazardous characterization of materials with low levels of lead contamination. This short-cut variation uses numerous field XRF values and the painted surface area directly to calculate the "mas9 of lead in LBP" value, as follows:

in LBP in m~ J ~ ~value in mg/cm- ~~%~Area in cm ;

The calculation then proceeds from this point as outlined in subsection 5.) above. This variation on the method bypasses the need to take physical samples of the paint for laboratory analysis and provides a rapid means for determinin~ if a structure is likely to fail TCLP or not.

The previous paragraph re~arding structures with widely differin~ lead contents also applies to this method.

Therefore, if XEF readings vary significantly from one part of the structure to another, then the mass of lead in each should be calculated separately and then summed before ii dividing by the mass of the structure. Or, in the alternative, the highest readings can be used for the whole structure, and compared to the i00 mg/kg standard in the "worst case" approach discussed above.

NOTE: Since both the main method and the short-cut variation described above involve an assumption that 100Z of the lead is leachable, they tend to be very conservative. As a result, these methods are generally only useful in situations where the material being disposed of has low levels of lead contamination.

In particular, the short-cut approach in subparagraph 7.) above will generally only produce a non-hazardous result if ~verage XEF values are fairly low (i.e., lower than 10 mg/cm or so).

Sites with moderate to near-hazardous levels of lead are likely to fail by this method and require some kind of TCLP sampling in order to obtain a definitive characterization of the material.

Demolish and Test. This method entails simply demolishing the structures to be removed, and obtaining representative samples of the debris to Be sent for TCLP analysis. At least one sample should be obtained per container (e.g. roll-off) of debris generated. Each such sample should consist of several randomly-selected aliquo~s, so as to ensure that the sample is truly representative of the entire quantity of debris in the container. Any containers for which TCLP lead concentrations equal or exceed 5.0 mg/l must be disposed of as hazardous waste.

Those containers with TCLP lead concentrations below 5.0 mg/l would Be classified as solid waste.

Although this method can be successfully used to characterize lead-containing debris, DEP strongly recommends using one of the other methods which involve characterizing the waste before removal, for the following reasons:

i.) high risk (lead-containing) components, which could cause the entire quantity of debris to be hazardous, cannot be easily identified, sampled or segregated after being removed and containerized. As a result, there is the risk of greatly increased disposal cost brought about By this inadvertent and, for all practical purposes, irreversible mixing of the hazardous and non-hazardous portions of the debris.

due to the physical nature of the debris (i.e., often tough, fibrous, and heterogeneous in nature), it is difficult to obtain truly representative samples of building components after they have been removed and containerized. This problem, in turn, increases the likelihood of both false positives (i.e. characterizing material as hazardous when it in fact is not) and false negatives (characterizing a material as non-hazardous when it is actually hazardous).

once the debris is removed, it becomes a waste, and as a result, must be managed in accordance with DEP’s waste management regulations (see Section V. below for the exact requirements that would apply); storing the materials on-site in this state pending laboratory analysis and/or finalization of off-site disposal arrangements makes compliance with the waste management regulations more difficult and time-consuming, and increases the likelihood that a violation will occur. This approach also creates time delays while samples await TCLP-testing.

D. Us~ of Combined Sampling .StrateEies.

Each of the strategies in the previous section can be used separately in characterizing a given quan£ity of waste. But in many cases, these strategies can be combined to develop a broader sampling regime which may be more efficient or more effective than any single sampling strategy in characterizing lead-contaminated debris.

Figure 1 provides such a sampling regime in a convenient, flow-chart form, and is sufficiently broad in scope as to be useful in a wide variety of projects involving disposal of lead-contamlnated debris.

This flow chart is organized as follows:

The flow chart begins with an assessment as to whether any constituents other than lead are present (as described in Section IV.B. above), and then proceeds directly to lead screening. If lead screening should reveal the presence of lead, the flow chart then asks whether consideration should be ~iven to the "Screen and Segregate" method (i.e. Section IV.C.2.b. above). This would be particularly appealinE in cases where lead contamination is limited to a small ~umber of building components (which can be easily and economically disposed of as hazardous waste), or in projects where time constraints do not permit additional analysis.

The flow chart then prescribes TCLP sampling of the individual components which screening indicates are lead-contaminated. If all such TCLP samples test below 5.0 ppm lead, the entire quantity of debris may be disposed of as non-hazardous solid waste. If any components fail TCLP, the flow chart offers the option of pursuing the "Screen, Sample and Segregate" method (i.e., Section IV.G.2.a.

above). As above, this would be particularly appealing in cases where the number of components failing TCLP was small, or where time constraints limit the ability to conduct additional analyses.

NOTE: as an alternative to taking TCLP samples of individual components, the flow chart allows the user to proceed directly to Options A through C (see item 3. below). This bypass of TCLP sampling is denoted with a broken line to indicate its optional nature. The

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-fr ee p o~ on s an d di sp os e of th em se pa ra te ly a s no n-ha za rd ou s so lid w as te user may wish to select this bypass in cases whoro it is highly suspected that a large numbor of components will fail TCLP, or when tho user fools confidont that one of tho methods in Options A through C will result in a characterization that is acceptable from a disposal cost standpoint.

The last part of tho flow chart requires the user to select one of three options (i.e., Option A, B, or C) to determine if the debris is hazardous or non-hazardous. These options correspond, respectively, to the "Screen and Calculato," "Composite Sample and Demolish," and "Remove and Cut" methods~doscribed in Soctions IV.C.2.c., d., and o.

above. The user is advised to consider these three options carefully before selecting which one to use. Each of these options have certain advantages and disadvantages which will affocttheir desirability in a given lead removal project. In particular, depending on how the debris is handled and stored, Option C will limit possibilities for segregation after cutting and removal. Also, Option A allows the user to use Options B or C as a back up method if this method yields a "hazardous" versus a "non-hazardous" result. This is an important provision since Option A involves very conservative assumptions which may yield a "hazardous" result for a material which is actually non-hazardous.

This sampling regime is not tho only one which could be used. Tho reader may wish to develop a different flow chart which is better suited to his or her individual noods. However, any such regime should use approved analytical methods, such as those in Section IV.C. above, should be logically and technically sound, and should never produce a "non-hazardous" result for a material which is actually hazardous waste.

E. Recordkeeoin~.

An important part of the characterization process is recordkeeping. The property owner or contractor with the responsibility for disposing of the waste should carefully document any and all characterization activities, and should retain these records for at least three years after completion of the project. By retaining these records, the generator of the waste will have documentation of the characterization of the waste if inspected by DEP and will also be prepared in the event that problems arise at the ultimate disposal facility. Additional recordkeeping requirements may apply in certain cases. See Section V., "Handling Requirements," for additional information.

F. General Trends.

Despite the wide variety of lead-contaminated materials which can be generated during lead removal, renovation, or demolition projects, a few general trends emerge:

Highly concentrated wastes, such as pure LBP chips, lead paint stripping wastes, HEPA vacuum filters, etc., almost always fail the TCLP for lead.

Moderately-contaminated materials, in particular individually selected components such as trim, baseboard, and siding, are fairly evenly split regarding TOLP results. A review of data by DEP shows that anywhere from 50-90 percent of selected components fail the TCLP for lead. This means that anywhere from 10-50 percent do no__t fail the

TGLP.

Low-contamination materials, such as whole-building demolition debris, usually do not fail the TCLP for lead. However, there is the possibility that in some cases even these materials may fail the TCLP, requiring disposal as hazardous waste. In one theoretical scenario considered by DEP, a light, steel-framed warehouse with no internals and no slab, painted inside and out with several coats of LBP, could easilM fail the TCLP, taken as a whole. Although this is clearly a worst case scenario, the example nevertheless indicates that such an outcome is indeed possible. As a result, even these materials must be properly characterized to prevent improper disposal. See Section IV.A., "Important Note" above, regarding the importance of proper characterization. See also the Preface of this document regarding DEP’s request for sampling results of whole-building demolition debris.

V. HANDLING REQUIREMENTS.

This Section discusses the requirements associated with the removal, handling, and on-site processing and storage of lead-contaminated debris. Section V.A.

provides an overview of the non-waste-management requirements which may apply to such projects. The remainder of this Section is devoted solely to the waste management-related issues involved, and in particular, those requirements related to the handling of any hazardous wastes which may be generated.

Although there are a number of non-hazardous wastes which may also be generated during such projects, the handling requirements associated with such materials are for the most part limited to ensuring proper disposal, and such requirements are discussed in detail in Section VI. below.

A. An Overview of Handlin~ Requirements Other Than for Waste Disposal.

As indicated in Section II above, this guidance was intended primarily to address the waste management issues associated with lead-contaminated debris. However, the handling of these materials can also be regulated by a number of regulatory programs other than DEP’s Waste Management Bureau.

Although it is not practical here to provide comprehensive information regarding each of these programs, the following paragraphs serve as an effective outline of the requirements involved, so that the reader may be aware of which ones may apply to a particular project, and to assist the reader in obtaining additional information.

In addition to DEP’s Waste Management Bureau, projects generating lead debris could be regulated by the following regulatory agencies or programs:

DEP’s Water Management Bureau, if wastewaters are generated or disposed of on-site. Lead removal projects may be regulated under the Water Management Bureau’s water discharge permitting program, if they involve discharge of wastewaters to the ground, on-site septic systems, storm drains, or sewage systems. In particular, activities such as power-washing, rinsing of "Peel-Away" or other chemical paint stripping agents, and personnel and equipment decontamination can all generate contaminated wastewaters that would require a permit if discharged on-site. Depending on the nature of the on-site activity and the associated wastewater discharge, the required permit may be in the form of: I.) an individual permit with site-specific effluent limitations, conditions, or other specified constraints; or 2.) a general permit (a greatly streamlined type of permit issued to a broad class of permitees who meet certain qualifying criteria and who follow certain procedures for registration and operation specified in the general permit).

For sites which may have brief,…