Knowing The Hazards

The demolition process and mixed C&D plant operations can each involve encountering hazardous materials. Handling them unsafely can harm health and profitability.

At a 2010 C&D Recycling Forum, which was Oct. 3-5 at the Sheraton Inner Harbor in Baltimore, a session titled “Hazards of the Job” allowed attendees to hear from three speakers offering advice on common hazards that can yield uncommon problems.

Combined, the series of presentations offered contractors and recyclers an overview of hazardous materials that can surface as well as advice on how to properly handle these materials.
 

THE COOL SIDE
Melissa Fiffer of the U.S. Environmental Protection Agency (EPA) offered an overview of the agency’s requirements when recyclers and demo contractors encounter refrigerants. Many of these are aimed in particular when addressing units made before 1995, when more hazardous refrigerants were used. Fiffer alerted attendees that:

• The Clean Air Act prohibits intentionally venting refrigerant when disposing of refrigeration and AC equipment (per 40 CFR Part 82 Subpart F). The reason is that many refrigerants used in the United States are ozone-depleting.
• Also, the Resource Conservation & Recovery Act and Toxic Substances Control Act require proper management and storage of universal waste, such as mercury, used oil and PCBs, per (40 CFR Parts 273, 279, 761).

Refrigerator units themselves can contain a range of secondary commodities, she noted, some of them highly desirable. The average pre-1995 refrigerator contains 140 pounds of metal, 20 pounds of plastic and 3 pounds of glass. This opportunity is countered by the presence of up to 8 ounces of potentially contaminated used oil; 1 pound of CFC-11 foam insulation; traces of PCBs in the capacitor; up to 8 ounces of CFC-12 refrigerant; and a mercury switch.

Fiffer concluded by saying that not only does illegally venting or disposing of refrigerants carry with it the disincentives of potential fines and being harmful to the environment, but it means passing up on the opportunity to make money by selling recovered refrigerant to an EPA-certified reclaimer.

Presenter Glenn Roof of Rapid Recovery, Peoria, Ariz., offered the viewpoint from such a reclaimer and provided attendees a look at the numerous types of units that contractors or recyclers may encounter that require treatment.

Examples included dorm-sized refrigerators and drinking fountains with attached coolers. Roof noted that Rapid Recovery (www.raprec.com) uses a device called a “buzz box” that drains and cleans the units.

Roof also provided examples of enforcement actions that have been taken against recyclers and other handlers of obsolete equipment:

• In July of 2010, the City of Tacoma was fined more than $500,000 for improperly venting during its refrigerator appliance disposal service;
• In October of 2009, five Cleveland scrap recycling companies were cited for improperly venting while processing scrapped appliances;
• Also in October of 2009, Chicago area scrap company Metal Recycling Systems was fined $30,000 and forced to change its procedures. The company was cited for failing to recover or to verify recovery of ozone-depleting refrigerants from small appliances that it had accepted and processed.

Roof said that Rapid Recovery, which operates from 23 locations, may pay as much as $1.70 per pound for refrigerants such as R22.

The company’s most crucial service though, he noted, was in helping recyclers and demolition contractors ensure that their documentation was in order for the handling of refrigerants.

THE ASBESTOS SCENE
Tony Nocito of ABCOV Inc., New York, provided an overview of his company’s process to convert asbestos to a non-hazardous material with a different fiber structure.

Nocito said the process offers those wishing to dispose of asbestos an alternative to bagging it and taking it to landfills, or “bag, tag and store,” as Nocito called it. Nocito warned that those who have sent asbestos to landfills in such a way may yet face potentially responsible party (PRP) problems should those landfills ever cause future environmental problems.

While asbestos is now less commonly used by the building industry, demolition contractors often still encounter it.

Nocito told C&D Recycling Forum attendees that asbestos was formerly used in fireproofing products, electrical insulation, chemical filters, other building materials including some cement products, and vehicle brake linings.

Most demolition contractors have had experience with asbestos, and many have started asbestos abatement divisions to their companies. But for those less familiar with asbestos, or who would prefer to leave the work to another company, Nocito advised:

• It is always best to leave asbestos alone; it’s usually safe unless it’s damaged or disturbed.
• The best way to deal with damaged material is to limit access to the area and not disturb it. Check with local health, environmental, or other appropriate officials to find out proper handling and disposal procedures.
• Do not attempt to remove asbestos without using a licensed contractor who can safely remove the asbestos.

Under the regulation, beginning April 22, 2010 contractors performing renovation, repair and painting that disturb lead-based paint in homes, childcare facilities and schools built before 1978 must be certified.

Nocito said the ABCOV process (www.abcov.com) complies with CERCLA (the Comprehensive Environmental Response, Compensation, and Liability Act) and offers these advantages:

• permanently destroys all six forms of asbestos found in asbestos-containing material;
• allows secondary hazardous and mixed wastes to be treated and stabilized;
• incorporates proven, commercially available and reliable equipment;
• can be modular and transportable or it can operate from a fixed base; and
• can be scalable to meet a customer’s needs.

There is even a recycling aspect to the process, said Nocito, in that converted asbestos can be used for landfill cover, as an additive to concrete, in roadbed material and in other applications.
 

YET MORE SCRUTINY FOR LEAD
Scott Knightly of EnviroVantage (www.envirovantage.com), based in Epping, N.H., provided an overview of the history of lead-based paint regulations and requirements, including new regulations that have taken effect in 2010.

The EPA’s new Lead RRP (Renovation, Repair and Painting) regulation was enacted in 2008 to require lead-safe work practices and other actions aimed at preventing lead poisoning, Knightly told attendees.

Under the regulation, beginning April 22, 2010 contractors performing renovation, repair and painting that disturb lead-based paint in homes, childcare facilities and schools built before 1978 must be certified.

Demolition contractors are among those who need to be aware of the RRP regulation, said Knightly, because:

• they demolishing buildings, in whole or in part;
• they may taken projects that involve working on college properties;
• they may be part of projects at churches, which often have classrooms and preschool programs; and
• they may work on school properties.

Knightly said contractors accepting work at these types of properties should:
• ask if there is a lead inspection report;
• ask if there are children living on the property;
• find out the age of the property; and
• involve a consultant if you are not aware of the effects on your project.

Parties in violation of the new RRP regulation can be penalized with fines up to $37,000 per violation, depending on the potential harm to people’s health, said Knightly.

While many of the regulations apply to demolition contractors, but should air measurements at a mixed C&D recycling plant indicate lead is present, the plant operator may have to provide further ongoing documentation.

Knightly said providing training and conducting TCLP tests that indicate the minimal presence of lead may be a preferred way for mixed C&D plant operators to “immunize” themselves from scrutiny.