The Resource Conservation and Recovery Act (RCRA). RCRA classified solid waste management facilities and practices, required states to develop comprehensive state plans for solid waste management (Dufour, op. cit., p. 99). RCRA also emphasized the growing landfill capacity problem and the need to develop approaches to handling wastes. In the preamble of RCRA, attention was called to the vast quantity of recoverable materials that are placed in landfills and to the fact that the recovery or conservation of many of these materials would benefit the United States by reducing projected landfill capacity require­ments, retaining and expanding our national resources, and reducing the country’s depen­dence on foreign resources.

In reference to recycled materials, Section 6002 of RCRA requires that federal, state, and local agencies receiving funds from the federal government must procure supplies and other items composed of the highest practical percentage of recovered or recycled materials, consistent with maintaining satisfactory levels of

• Product quality

• Technical performance

• Price competition

• Availability

Also, under RCRA, specifications cannot be written to discriminate against materials with recycled constituents. In addition, EPA was authorized to prepare guidelines for recy­cling, and resource recovery guidelines addressing procurement practices and information on research findings about the uses and availability of recycled materials. Guidelines cov­ering coal fly ash in portland cement, recycled paper, retreaded tires, building insulation, and rerefined oil have been developed. While not specifically required by EPA, the guide­lines encouraged most state highway programs to prepare specifications allowing the sub­stitution of fly ash in concrete.

Intermodal Surface Transportation Efficiency Act (ISTEA). ISTEA authorized DOT to coordinate with EPA and state programs in developing information on the economic savings, technical performance qualities, and environmental and public health threats and benefits of using recoverable resources in highway construction. TEA-21 provided technical corrections to ISTEA. ISTEA specifically calls out requirements for the per­centage of asphalt pavement containing recycled rubber from scrap tires.

In addition, state legislation has been developing to promote both research into the per­formance and viability of recycled materials and the procurement of such materials. Many have established mandatory recycling laws and most have used wastes or waste by­products in their highway programs.

Given the vast amount of building materials required to construct and maintain the trans­portation infrastructure in the United States, the country’s highway system represents a tremendous opportunity for the beneficial use of reclaimed and recycled resources. However, the reclamation and reuse of waste material must be done in an environmentally responsible manner.

The handling, disposal, and reuse of solid waste is regulated by a number of environ­mental statutes. Increased cost of complying with these requirements has increased the appeal of recycling and resource management. Because solid waste material is not as uni­form as raw materials, the characteristics, performance, cost of preparing, and application of solid waste vary with the source and type of the material. Results in highway applica­tions vary considerably and depend on such parameters as climate, composition, material handling practices, and construction procedures. Factors to be considered when recycling a waste to a highway construction end use include the following [National Cooperative Highway Research Program (NCHRP), Transportation Research Board, Synthesis 199, Recycling and Use of Waste Materials and By-Products in Highway Construction: A Synthesis of Highway Practice, Washington D. C., 1994]:

Environmental Threats and Benefits. Along with the considerable environmental bene­fit of reducing the landfill burden, potential threats to the environment caused by the use of

recycled material must be considered and compensated, mitigated, or otherwise overcome before use of recycled material is feasible.

Regulatory Requirements, Guidelines, and Restrictions. The federal and state legis­lation and guidance regarding recycled materials reflect reduced landfill capacity in the United States and the recognition that there is a net benefit to producing resources from waste. The federal government as well as some states now have recycling mandates in place. Permits are often required when conducting recycling activities, and/or when creat­ing an authorized disposal site in using certain wastes as embankment fill. If the recycling activity falls under the RCRA classification of “use constituting disposal,” additional reg­ulations apply.

Economic Cost and Benefit. Economic considerations are often the driving force behind recycling efforts on the county and city level, because of the increased landfilI costs and increasingly limited capacity. Recycling for highway departments may become more attractive as budget cuts increase and the price for recycled waste materials decreases. In some cases, recycled materials extend the service life of highway components, making the life-cycle costs of using such materials attractive.

Engineering Properties and Technical Performance. Because of the variability of the composition of waste materials, performance results for end products may vary signifi­cantly, requiring careful evaluation before identifying suitable applications for their use. The primary question is “does the performance of the material compare favorably with the same material constituted from raw materials?” In some instances, the use of waste material has consistently improved performance. For instance, silica fume use in portland cement results in higher compressive strength and higher resistance to corrosion of steel reinforcement due to the increased density and reduced porosity of the resulting concrete. (“Silicon,” Minerals Yearbook, U. S. Bureau of Mines, Washington, D. C., 1989.)

Construction Materials Shortages and Alternative Resource Availability. Millions of tons of aggregate are used each year in the construction of highways. Resources from exist­ing quarry mining are being depleted and the new sources are often not used because of restrictive regulation and preferred uses of the land. In areas experiencing shortages, recy­cling construction materials, waste minerals, and other products into aggregate is more cost-effective than shipping aggregate from distant quarries. Steel is one of the most widely recycled materials used in highways. Steel reinforcement can be composed completely of recycled scrap steel, and steel girders can contain as much as 25 percent recycled scrap steel. Recycling scrap steel greatly reduces reliance on foreign sources for raw materials in the steel industry. (NCHRP Synthesis 199, p. 6.)

The following steps have been developed for managing lead-based paint removal projects based on procedures in Trimbler’s Industrial Lead Paint Removal Handbook.

Initial Project Evaluation. In the initial project evaluation, the owner or specifier must determine whether the coating contains lead-based paint either by reviewing earlier plans and specifications for the structure or by sampling and analysis.

Prebid Assessment of Paint Removal Methods and Debris Generated. The owner or specifiers should estimate how much waste will be generated by methods evaluated to be appropriate to the size and circumstances of the project. Designing a testing program to evaluate the toxicity of waste generated may be appropriate for large paint removal projects.

Understanding the Regulations before Preparing the Specifications. The regulations regarding air quality, water quality, soil cleanup, unauthorized releases, worker protection, and hazardous waste generators should be thoroughly understood. How these regulations are enforced should be discussed with both state and local officials.

Preparing the Project Specifications. Both painting and lead removal requirements should be addressed in the specifications. These should identify the methods for surface preparation and the coating system to be applied. The relevant regulations, the degree of containment, and the evaluation of performance criteria should all be specified.

Developing a Worker Protection Plan. Prior to start-up, the contractor should provide a worker safety plan that addresses exposure monitoring, the compliance program, the respiratory protection program, personal protective equipment, housekeeping issues, hygiene facilities and procedures, medical surveillance, employee removal for exposure to lead, employee training, signage, record keeping, and employees’ right to observe and review monitoring information.

Preparing Environmental Protection Monitoring Plans. The procedures developed to verify environmental protection should include high-volume air samplers, tests for visible air emissions (opacity), personal air quality monitors, measurement (and reporting requirements) of unauthorized releases, and pre – and postproject soil quality and water quality sampling.

Developing Procedures for the Control and Handling of Hazardous Waste. Assuming that hazardous waste is to be generated, plans should be developed for identifying the waste, obtaining a hazardous waste generator identification number from the EPA, prepar­ing for proper notification and certifications with each shipment, preparing waste mani­fests, packaging and labeling waste, implementing contingency plans, conducting waste treatment and analysis for on-site handling, and record keeping.

Designing a Containment and Ventilation Plan. The contractor should develop detailed plans to select appropriate support structures and containment, address ventilation and other worker safety issues, provide emissions control, achieve water and soil protection and debris recovery, and verify the integrity of the containment structure.

Monitoring the Project. The project manager should develop a plan to monitor the ade­quacy of all of the control measures; visually monitor the project regularly and use approved testing methods to evaluate adequacy of controls; regularly monitor the ventila­tion system and the integrity of the containment; regularly examine waste storage facilities, and the handling and transportation methods and procedures; and verify worker protection and hygiene procedures. OSHA standards must be observed. Figure 1.2 illustrates a deci­sion tree to aid in the management of lead paint removal.

Specifications for scraping or blasting lead-based paint from structures should be written with worker safety and environmental issues in mind, so that qualified contractors who can adhere to a high level of quality and compliance are selected for the project. These specifi­cations should

• Describe the extent of surface preparation and the degree of containment required and let the contractor propose how to accomplish this.

• Identify key health and safety and environmental regulations to ensure that the con­tractor is aware of these regulations and plans compliance strategies in the bid.

• Clearly state that the paint to be removed is lead based. The highway department should have had the paint tested prior to contract bid if there is any doubt whether the paint is lead based. The cost differential is too great to make the assumption or let a contract with the lead concentration factor as an unknown.

• Specify how the waste is to be treated, tested, handled, and disposed of.

• Identify the worker protection standards and requirements that the contractor’s health and safety plan must meet at a minimum.