What Does CalTrans want?
The special conditions require a plan to control exposure to people
or spills into the environment. The plan must address disposal methods
and testing the hazardous waste that is created by the
project. According to CALTRANS Requirements, the Lead (or other
hazardous material)
Compliance Plan must be approved by a Certified Industrial Hygienist
(CIH).
How do I Hire a CIH to do My ADL or Lead Based Paint Plan
Easy just fill out this form
and send it to Dan Napier,CIH.
He will write a plan that meets your
needs and that meets CalTrans requirements.
Is this the same as a Storm Water
Runoff Plan?
No it is not a Storm Water Pollution Prevention Plan
(SWPPP), for that go to Clearwater Service Or
Email them at cws@clearwaterservice.com. By the way they call
it a “swee pee”.
Can I get a CIH any time I want?
Well, no. There only about 5000 CIH's
in the entire world. There are several hundred in
California, many work for companies, or agencies. There are many that
can help you, us for
example. Find a CIH
you like and stick with them, in the long run they will be able to
protect
you and your company from excess costs, citations and problems with
your Safety & Health
program (IIPP).
Do I have to fill out any special forms?
Yes you must notify Cal-OSHA for your lead jobs. Here is the
notification form.
You can fill it
out online and print it, but you cannot save it.
Does CALTRANS deal with Lead any differently than anybody else?
Well they do have special arrangements with the California
Department of Public Health,
(CDPH.)
They can put some lead contaminated soils back in road beds, under
certain conditions. They can do some leachate testing using DI water
instead of acid. All of this is very esoteric and
should be discussed with your CIH who can discuss the finer points with
the CALTRANS
Resident Engineer RE.
What is Lead Air monitoring?
Air monitoring is a measure of the lead or metal in the air for the
entire work shift (it should be
eight hours), it is reported in µg/m3 or micrograms
per cubic meter of air. The OSHA number is
30µg/m3 (Action Level) with 50 µg/m3
for the PEL (Permissible Exposure Level.) Anything
above 30 triggers personal protection, blood testing and a whole host
of requirements. There is
no connection between the ADL in soil and air monitoring. However the
air monitoring results
taken when good dust control methods are in place maintain the Lead in
Air well below the 30
µg/m3 threshold.
I tested the air and found No Lead, why do I have to keep testing?
Good news, you may not need to keep on testing. A properly qualified
CIH can help you to test
and submit documentation that you do not need to do air monitoring
tests for the next twelve
months.
What are all the Lead tests about anyway?
The person who is accepting the waste is the one who will tell you
what tests to conduct. It may
vary, even in the same state. So ask the landfill before you waste your
good money on the wrong
test. Your CIH will be able to help you with these complex questions.
STLC Soluble Threshold Limit Concentration (WET Test or Waste
Extraction Test) See
California Title 22§66700 (milligrams/liter) This test takes
several days to complete.
TTLC Total Threshold Limit Concentration (Wet Weight
milligrams/kilogram mg/kg (or PPM
the same thing) This test can be completed in about 2 hours, 1.5 Hours
extraction in Strong acid,
this is a fast test.
TCLP Toxicity Characteristic Leaching Procedure See Federal Code 40
CFR 136, this is in
mg/liter. It will take several days to complete.
TCLP (40 CFR 136) is the Federal Method, 18 hours of extraction with
acetic acid at different Ph
solutions depending on the Ph of the original material. The STLC
(California Title 22 § 66700) is
a 48 hour extraction. Generally the California method results in a
slightly higher level of lead,
but both are very similar. If anything the STLC can be used instead of
the TCLP for anything in
California, If the disposal is in another State, use the TCPL or
Teeclip test.
The tests extract the metal from the sample, or try to dissolve the
material and cannot be done
twice with the same material, the minimum amount of material is at
least 50 grams for each test,
so if you want to do both tests the sample size needs to be 200 grams
about ½ a pound of
material.
What all this means is that you have to have your load waiting to be
disposed of for a minimum
of three days for California Waste, and at least two days for Federal
waste. Do not think you can
have a truck load ready, conduct the test, read some readout and send
the driver off. You will
have to load the bin, do the test wait for the material to be at the
lab more than 18 or 48 hours,
and then get a fax from the lab after all the Quality Control checks
have been made. Extraction
is only one part of the analysis and the law specifies how long. You
cannot order the lab to give
you immediate turnaround for STLC that immediate turnaround would still
be 48 hours, minimum. The folks in the lab need time to run the sample,
type it have lunch etc.
The magic number for California is STLC lead 5 mg/liter for lead compounds or organic
Seventeen Metals STLC 5 TTLC 1000
The magic number for Federal TCLP for lead is 5 mg/liter
TCLP Eight Metals As 5 Ba 100 Cd 1 Cr 5 Pb 5 Hg 0.2 Se 1.0 Ag 5
Do the TTLC first, if it is below 1000, and above 10 times the STLC
but below you must do
STLC if above the STLC it is hazardous, if below it is non hazardous.
If TTLC is less than 10 X the STLC it is automatically non
hazardous. eg Lead 45 is less than
10X5 or 50, therefore non-hazardous.
How fast can I get results?
That depends on the test, air monitoring can be returned the next
day, but the cost is pretty steep.
Tests for hazardous materials require a "Leachate" test and that
requires that the laboratory soak
the test material for 48 hours as part of the analysis. Again you need
to get information from
your CIH and the Laboratory to be able to plan these projects. CALTRANS
has a special
agreement with CDPH and they can do the leachate test with DI water
rather than acid.
Who Can Help me Dispose of the Waste?
Pete Timmerman at 925-457-3781 or email him at gotlead@sbcglobal.net. Pete
will handle the
waste characterization, (Profiling) and get the waste samples to the
appropriate lab. Coordinate
the pick-up with the waste hauler. Generally, coordinate with CalTRANS
and answer their
questions and comments.
Where can I get Hazardous Waste Bins?
Start with Sean Kelly at BDC 800-221-4232. All you need is a DOT
approved container, so you
can use barrels, or super sacks. You are not limited to roll off bins.
Does lead really cause Childhood Intelligence disorders?
After all he effort to remove lead we do not have a single incidence
of improvement in
intelligence in the studied populations. There is a very thoughtful
study that has a possible
explanation. Read the information.
Is there any good information about the OSHA rules about lead?
The OSHA home page is a good
starting point, as is the California CDPH
Lead information
page.
REV 7/3/2008 DN