external/soil abatement - cpwr 8.pdfchapter 8 external/soil abatement center to protect workers’...

Chapter 8 External/Soil Abatement

Center To Protect Workers’ Rights 273

EXTERNAL/SOIL 8 ABATEMENT

In this chapter you will learn about:2 Protecting yourself on an outdoor or external

abatement job;2 Steps in an external abatement setup job;2 Abatement methods taken outside; and,2 How lead exposure from soil can be

controlled.

Outdoor or External AbatementAbating lead paint on the outside of a house is not very

different from inside work. This chapter explains some of thedifferences when you do outside work. Remember that when you dooutside work you must still ...

» wear a suit and respirator.

» decontaminate. » use water and HEPA

vacuums. » bag up the waste. » re-paint.

External/Soil Abatement Chapter 8

274 Center To Protect Workers’ Rights

» take clearance samples and everything else you do tokeep lead dust out of the air and keep dust fromspreading.

What's different about outside work?When you are doing lead work outside, you also need to think

about:

» keeping lead dust off the sides of the building, bushes,and the ground;

» wind and rain that can wash away lead waste and ripoff poly;

» locking up the waste every night;» keeping neighbors out of the work area; » using ladders or scaffolds safely; » collecting water before it runs downhill; » keeping workers from tracking lead dust on

sidewalks; and» keeping doorways clear if workers need to get into the

building.

Setup and the FourAbatement Methods – Outdoors

After external or outdoor setup there are the four abatementmethods: enclosure; removal; encapsulation; and replacement.Outdoor enclosure means putting up airtight siding. This is byfar the best method. It makes the house cheaper to heat and cool,and it controls the lead problem. Outdoor removal means wetscraping, using strippers, needle guns, or blasting (not allowed inmany states). Outdoor encapsulation is just like indoorencapsulation. Replacement does not apply outdoors except inhistoric restorations.

Outdoor Setup



On all outdoor jobs, you should put down 10' of poly for the firststory and 6' for each extra floor. For a 2-story building you shouldput down 16 feet. For a 3-story building you should put down 22feet (or go to the curb), and so on. Some states require less poly(for example, Maryland calls for 3 feet per floor). You may needextra poly to cover up bushes or trees near the house. Put extraduct tape on the poly under ladders or scaffolds.

Tape the poly to the base of the building. Use 2x4s to hold downthe poly on the ground. Put boards under every edge of the poly sothat water will collect in a low spot. Set up a pump to move thewater to a 55 gallon drum.

Watch out for doors and walks that people need to use if indoorwork is being done at the same time. Residents should leave thebuilding and all windows should stay closed. (They must leave thebuilding on HUD projects.) Put up warning tape or fences wherethe poly ends. Put lead warning signs on the tape and on thebuilding.

Outdoor Enclosure Outdoor enclosure means vinyl or aluminum siding with all of

the seams silicone caulked. Sheet metal is used on moldings andthe outside of windows. You will probably have to do some wetscraping to remove loose paint before putting up the siding. Rottenwood has to be replaced before siding is put up. On some jobs,Tyvek® is used for a vapor barrier under the siding.

Outdoor Removal Just like an indoor job, you may do wet scraping or use

strippers, heat guns, or needle guns (on metal) to remove paintfrom the outside of a building. Some states allow water guns orhydro-blasting as long as the water is collected. Some allowabrasive blasting as long as a vacuum is attached. All of thesemethods are very expensive, create a lot of waste, and requirespecial blasting respirators. Water from water guns is hazardouswaste unless the water is filtered to state and federal EPA



standards. SpongeJet abrasive blasting technology, referenced onthe last chapter, shows promise with external removal, especiallyin historical preservation and masonry work.

Scrape the lead paint right into a container. Don't let it fall tothe ground or onto the ladder or scaffold. Removal work shouldstop on very windy or rainy days when you can't control the leaddust.

Outdoor Encapsulation Outdoor encapsulants are the same as indoor encapsulants, but

they have some brands made to handle the extra wear and tear ofweather (i.e., Global Encasement, Inc. and Fiberlock Technologies,

Inc). Check that the paint is designed for the materialyou are painting (masonry, cement, wood, etc.). Youwill probably have to do some wet scraping to removeloose paint before putting on the encapsulant. Youmay need to wait for a dry day for the building to dryout before you can paint.

CONTROLLING LEADEXPOSURE FROM THE SOIL

Yards, Playgrounds, and other Soil AreasYards, playgrounds, parks, parking lots, sports fields,

abandoned target ranges, and empty lots sometimes have a lot oflead in the dirt (soil). Lead paint on the outside of buildings slowlywears off and the dust ends up in the soil. Lead dust can come froma deleading job next door or bridge work nearby. Some lead alsocame from cars that used leaded gasoline and from factories thatuse lead. Many parks and yards near battery or radiator factoriesor smelters (metal processing) have lots of lead in the soil.

Is lead in soil always a problem?



Lead in soil can be a problem if children play in it. Bare soilwithout grass growing on it is a problem because lead dust can geton children's hands and get into the air. Pets can bring lead dustinto the house. Soil with grass growing on it is not a big danger.But a grassy area can become a problem if a new garden is startedthere.

EPA says that bare patches more than 2 square feet (about 1 ½'on each side)should be tested. As of June, 1997, EPA and states donot say soil has to be tested, so you may not do much outside workon lead jobs.

Does All the Soil have to be Removed?A lead inspector may test the soil and decide whether it needs

to be removed or paved (abated). Bare soil with medium to highlevels of lead that children play in should be abated. Abatement isa permanent control – the lead will never be a problem.

Areas with medium levels of lead that children do not play inmay not need to be abated. Instead, the risk assessor may ask forsigns, move play equipment, or other interim controls. These donot get rid of the lead, they just keep children away.

Lead in soil should be tested again after exterior leadpaint is treated. Scraping lead paint on the outside of the houseor putting up siding (enclosure) can add paint to the soil. Workshould be done from the inside out – treat paint inside, then treatpaint outside, then treat soil.

How does the inspector test the soil?The inspector will send at least two samples from the top ½inch

of bare soil to a lab. Each sample may have three areas in it (forexample, a sand box, under swings, and near the porch). Eachsample is about 2 tablespoons of soil or the amount in a filmcanister. The lab tests the soil and sends back a report. Each testcosts $5-$15.

The inspector should sample bare soil in all outdoor:» sand boxes;



» areas where children play (like yards, playgroundsand empty lots);

» near the edge of the building (where paint dust canfall – drip line);

» vegetable gardens; » places where pets sleep; and » pathways where people walk (for example, if there is

no sidewalk), dirt roads, etc.

At what level of lead in the soil does it become a concern?A lead level for soil of 400 parts per million (ppm) in areas that

children gather in requires the implementation of hazard reducingactivities, including interim controls and/or abatement. In areaswhere children are less like to gather, lead soil levels over 1200also requires the implementation of hazard reducing activities,including interim controls and/or abatement. Check the table laterin this chapter.

What is Soil Abatement?Abatement means removing the soil or paving it over. For

removal, the top 6-12 inches of soil are dug up and thrown out.New soil is brought in. Sometimes a liner is put between the oldsoil underneath and the new soil on top. Watch out for pipes andother utility lines when you dig. Watch for wind and rain that canblow soil out of the area. They should take their shoes off whengoing inside. Sweep up sidewalks and porches at the end of everyday.

The removed soil may be hazardous waste. Drivers who carryhazardous waste need a special license. Trucks that carryhazardous waste need special tarps, cleaning, and may need aspecial license or tag.

Leaded soil can be treated, but this is so expensive that it is notusually done. For areas with less than 1,500 ppm the soil on topcan also be plowed into the soil underneath with a roto-tiller.Vegetables should not be grown in this soil.



Paving over the soil with concrete or asphalt is less expensivethan removing it. But residents may not want a concrete backyard. Paving in playgrounds needs to be covered with wood orrubber.

What are Interim Controls for Soil?Interim controls are ways to keep kids away from soil that has

some lead in it. Interim controls include covering soil with gravel,planting grass, and putting up signs. Interim controls are notperfect. They always need to be checked (monitored) to make surethey are still working.

Here are 6 different kinds of interim controls for soil with leadin it:

1. Cover the soil. Plant grass or ground cover (may not work ifpeople walk on it or it's shady). Sprinklers may be needed. Putdown Astroturf or rubber playground mats. Cover the groundwith 6-12 inches of bark or gravel (not in flood areas).

2. Put up barriers to keep kids out. Put up fences. Build a deckover the soil. Plant thorny bushes. Leave walkways to doors.

3. Fix erosion problems. Flatten out soil. Dig channels for rain.Put up fences to block wind if it is a problem.

4. Set up different play areas. Move playground equipment andbenches. Build a playground nearby.

5. Share information. Put up signs telling people to stay out.Tell families about the lead problem. Ask them to keep theirkids away and wash hands before eating or drinking.

6. Stop sources of lead. Find out where lead is coming from (forexample, battery factory) and stop it.

Interim controls have to be checked about once a month to besure they are keeping lead away from kids. For example, if the newgrass doesn't grow, it has to be re-planted or fenced in. If the gravelgets washed away, more has to be put down.



Areas of Concern Bare SoilConcentration

Recommended Response Activity

Areas expected to beused by children,including:

º residentialbackyards;

º daycare andschool yards;

º playgrounds;º public parks; andº other areas where

children gather.

400 ppm Interim controls to change use patterns andestablish barriers between children and leadcontaminated soil, including:

º planting ground cover or shrubbery to reduceexposure to bare soil;

º moving play equipment away from contaminatedbare soil;

º restricting access through posting, fencing, orother actions; and

º control further contamination of area.

Monitor condition of interim controls.Public notice of contaminated common areas bylocal agency.

and/orAbatement of soil, including:

º removal and replacement of contaminated soil;and

º permanent barriers.

Public notice of contaminated common areas bylocal agency.

Areas of Concern Bare SoilConcentration

Recommended Response Activity

Areas where contact bychildren is less likely orinfrequent.

1200 ppm Interim controls to change use patterns andestablish barriers between children and leadcontaminated soil, including:

º planting ground cover or shrubbery to reduceexposure to bare soil;

º moving play equipment away from contaminatedbare soil;

º restricting access through posting, fencing, orother actions; and

º control further contamination of area.

Monitor condition of interim controls.Public notice of contaminated common areas bylocal agency.

and/orAbatement of soil, including:

º removal and replacement of contaminated soil;and

º permanent barriers.

Public notice of contaminated common areas bylocal agency.



Key Facts: External (outdoor) Abatement &Controlling Lead in Soil

Outdoor work can expose you to lots of lead dust – the windwon't keep you safe. Use the same protections you do for aninside job.

Put poly on the ground to keep lead dust off grass, trees, andother structures and to collect water and waste. Weight itdown so that wind won't blow it away.

Putting up caulked siding (enclosure) is the best method – itlowers heating and cooling costs for the house, exposes youto less lead, and makes less lead waste.

If you scrape paint outdoors, scrape it right into a can, don'tlet it fall onto the poly.

Removal is very expensive. If the soil is hazardous waste, thetrucks need special cleaning and licenses and the truckdrivers need special licenses.

Planting grass, covering with 6" of mulch or gravel, orputting up fences are interim controls.

Interim controls have to be inspected forever to make surethey are working. Once a month is a good schedule.



&For More Information

These publications have more information on the topicscovered in this chapter.

EPA. Agency Guidelines on Residential Lead-Based Paint, Lead-Contaminated Dust, and Lead-Contaminated Soil. (July 1994).

EPA. Sources of Lead in Soil: A Literature Review. Vol. 1. Preparedby the Battelle Memorial Institute. EPA 747-R-98-001a.(February 1998).

EPA. Sources of Lead in Soil: A Literature Review. Vol. 2. Preparedby the Battelle Memorial Institute. EPA 747-R-98-001b. (June1996).

“Lead: Identification of Dangerous Levels of Lead; Final Rule.”Federal Register. 40 CFR Part 745. EPA. (January 5, 2001).

Interim Control: Recycled rubber tirepieces as ground cover in a park.

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