Chapter 8 External/Soil Abatement EXTERNAL/SOIL 8 ABATEMENT In this chapter you will learn about: Protecting yourself on an outdoor or external abatement job; Steps in an external abatement setup job; Abatement methods taken outside; and, How lead exposure from soil can be controlled. Outdoor or External Abatement Abating lead paint on the outside of a house is not very different from inside work. This chapter explains some of the differences when you do outside work. Remember that when you do outside work you must still... wear a suit and respirator. decontaminate. use water and HEPA vacuums. bag up the waste. re-paint. Center To Protect Workers Rights 273
External/Soil Abatement Chapter 8 take clearance samples and everything else you do to keep lead dust out of the air and keep dust from spreading. 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 rip off 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 Four Abatement Methods Outdoors After external or outdoor setup there are the four abatement methods: enclosure; removal; encapsulation; and replacement. Outdoor enclosure means putting up airtight siding. This is by far the best method. It makes the house cheaper to heat and cool, and it controls the lead problem. Outdoor removal means wet scraping, using strippers, needle guns, or blasting (not allowed in many states). Outdoor encapsulation is just like indoor encapsulation. Replacement does not apply outdoors except in historic restorations. Outdoor Setup 274 Center To Protect Workers Rights
Chapter 8 External/Soil Abatement On all outdoor jobs, you should put down 10' of poly for the first story and 6' for each extra floor. For a 2-story building you should put down 16 feet. For a 3-story building you should put down 22 feet (or go to the curb), and so on. Some states require less poly (for example, Maryland calls for 3 feet per floor). You may need extra poly to cover up bushes or trees near the house. Put extra duct tape on the poly under ladders or scaffolds. Tape the poly to the base of the building. Use 2x4s to hold down the poly on the ground. Put boards under every edge of the poly so that water will collect in a low spot. Set up a pump to move the water to a 55 gallon drum. Watch out for doors and walks that people need to use if indoor work is being done at the same time. Residents should leave the building and all windows should stay closed. (They must leave the building on HUD projects.) Put up warning tape or fences where the poly ends. Put lead warning signs on the tape and on the building. Outdoor Enclosure Outdoor enclosure means vinyl or aluminum siding with all of the seams silicone caulked. Sheet metal is used on moldings and the outside of windows. You will probably have to do some wet scraping to remove loose paint before putting up the siding. Rotten wood 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 paint from the outside of a building. Some states allow water guns or hydro-blasting as long as the water is collected. Some allow abrasive blasting as long as a vacuum is attached. All of these methods are very expensive, create a lot of waste, and require special blasting respirators. Water from water guns is hazardous waste unless the water is filtered to state and federal EPA Center To Protect Workers Rights 275
External/Soil Abatement Chapter 8 standards. SpongeJet abrasive blasting technology, referenced on the last chapter, shows promise with external removal, especially in historical preservation and masonry work. Scrape the lead paint right into a container. Don't let it fall to the ground or onto the ladder or scaffold. Removal work should stop on very windy or rainy days when you can't control the lead dust. Outdoor Encapsulation Outdoor encapsulants are the same as indoor encapsulants, but they have some brands made to handle the extra wear and tear of weather (i.e., Global Encasement, Inc. and Fiberlock Technologies, Inc). Check that the paint is designed for the material you are painting (masonry, cement, wood, etc.). You will probably have to do some wet scraping to remove loose paint before putting on the encapsulant. You may need to wait for a dry day for the building to dry out before you can paint. CONTROLLING LEAD EXPOSURE FROM THE SOIL Yards, Playgrounds, and other Soil Areas Yards, playgrounds, parks, parking lots, sports fields, abandoned target ranges, and empty lots sometimes have a lot of lead in the dirt (soil). Lead paint on the outside of buildings slowly wears off and the dust ends up in the soil. Lead dust can come from a deleading job next door or bridge work nearby. Some lead also came from cars that used leaded gasoline and from factories that use lead. Many parks and yards near battery or radiator factories or smelters (metal processing) have lots of lead in the soil. Is lead in soil always a problem? 276 Center To Protect Workers Rights
Chapter 8 External/Soil Abatement Lead in soil can be a problem if children play in it. Bare soil without grass growing on it is a problem because lead dust can get on children's hands and get into the air. Pets can bring lead dust into 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 started there. 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 do not say soil has to be tested, so you may not do much outside work on 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 high levels of lead that children play in should be abated. Abatement is a permanent control the lead will never be a problem. Areas with medium levels of lead that children do not play in may not need to be abated. Instead, the risk assessor may ask for signs, move play equipment, or other interim controls. These do not get rid of the lead, they just keep children away. Lead in soil should be tested again after exterior lead paint is treated. Scraping lead paint on the outside of the house or putting up siding (enclosure) can add paint to the soil. Work should be done from the inside out treat paint inside, then treat paint 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 (for example, a sand box, under swings, and near the porch). Each sample is about 2 tablespoons of soil or the amount in a film canister. The lab tests the soil and sends back a report. Each test costs $5-$15. The inspector should sample bare soil in all outdoor: sand boxes; Center To Protect Workers Rights 277
External/Soil Abatement Chapter 8 areas where children play (like yards, playgrounds and empty lots); near the edge of the building (where paint dust can fall 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 reducing activities, including interim controls and/or abatement. In areas where children are less like to gather, lead soil levels over 1200 also requires the implementation of hazard reducing activities, including interim controls and/or abatement. Check the table later in 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 old soil underneath and the new soil on top. Watch out for pipes and other utility lines when you dig. Watch for wind and rain that can blow soil out of the area. They should take their shoes off when going inside. Sweep up sidewalks and porches at the end of every day. The removed soil may be hazardous waste. Drivers who carry hazardous waste need a special license. Trucks that carry hazardous waste need special tarps, cleaning, and may need a special license or tag. Leaded soil can be treated, but this is so expensive that it is not usually done. For areas with less than 1,500 ppm the soil on top can also be plowed into the soil underneath with a roto-tiller. Vegetables should not be grown in this soil. 278 Center To Protect Workers Rights
Chapter 8 External/Soil Abatement Paving over the soil with concrete or asphalt is less expensive than removing it. But residents may not want a concrete back yard. Paving in playgrounds needs to be covered with wood or rubber. 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 not perfect. They always need to be checked (monitored) to make sure they are still working. Here are 6 different kinds of interim controls for soil with lead in it: 1. Cover the soil. Plant grass or ground cover (may not work if people walk on it or it's shady). Sprinklers may be needed. Put down Astroturf or rubber playground mats. Cover the ground with 6-12 inches of bark or gravel (not in flood areas). 2. Put up barriers to keep kids out. Put up fences. Build a deck over 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 and benches. 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 their kids away and wash hands before eating or drinking. 6. Stop sources of lead. Find out where lead is coming from (for example, battery factory) and stop it. Interim controls have to be checked about once a month to be sure they are keeping lead away from kids. For example, if the new grass doesn't grow, it has to be re-planted or fenced in. If the gravel gets washed away, more has to be put down. Center To Protect Workers Rights 279
External/Soil Abatement Chapter 8 Areas of Concern Bare Soil Concentration Recommended Response Activity Areas expected to be used by children, including: residential backyards; daycare and school yards; playgrounds; public parks; and other areas where children gather. 400 ppm Interim controls to change use patterns and establish barriers between children and lead contaminated soil, including: planting ground cover or shrubbery to reduce exposure to bare soil; moving play equipment away from contaminated bare soil; restricting access through posting, fencing, or other actions; and control further contamination of area. Monitor condition of interim controls. Public notice of contaminated common areas by local agency. and/or Abatement of soil, including: Areas of Concern Bare Soil Concentration removal and replacement of contaminated soil; and permanent barriers. Public notice of contaminated common areas by local agency. Recommended Response Activity Areas where contact by children is less likely or infrequent. 1200 ppm Interim controls to change use patterns and establish barriers between children and lead contaminated soil, including: planting ground cover or shrubbery to reduce exposure to bare soil; moving play equipment away from contaminated bare soil; restricting access through posting, fencing, or other actions; and control further contamination of area. Monitor condition of interim controls. Public notice of contaminated common areas by local agency. and/or Abatement of soil, including: removal and replacement of contaminated soil; and permanent barriers. Public notice of contaminated common areas by local agency. 280 Center To Protect Workers Rights
Chapter 8 External/Soil Abatement Key Facts: External (outdoor) Abatement & Controlling Lead in Soil Outdoor work can expose you to lots of lead dust the wind won't keep you safe. Use the same protections you do for an inside job. Put poly on the ground to keep lead dust off grass, trees, and other structures and to collect water and waste. Weight it down so that wind won't blow it away. Putting up caulked siding (enclosure) is the best method it lowers heating and cooling costs for the house, exposes you to less lead, and makes less lead waste. If you scrape paint outdoors, scrape it right into a can, don't let it fall onto the poly. Removal is very expensive. If the soil is hazardous waste, the trucks need special cleaning and licenses and the truck drivers need special licenses. Planting grass, covering with 6" of mulch or gravel, or putting up fences are interim controls. Interim controls have to be inspected forever to make sure they are working. Once a month is a good schedule. Center To Protect Workers Rights 281
External/Soil Abatement Chapter 8 For More Information These publications have more information on the topics covered 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. Prepared by the Battelle Memorial Institute. EPA 747-R-98-001a. (February 1998). EPA. Sources of Lead in Soil: A Literature Review. Vol. 2. Prepared by the Battelle Memorial Institute. EPA 747-R-98-001b. (June 1996). Lead: Identification of Dangerous Levels of Lead; Final Rule. Federal Register. 40 CFR Part 745. EPA. (January 5, 2001). Interim Control: Recycled rubber tire pieces as ground cover in a park. 282 Center To Protect Workers Rights