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Scrap Lead Disposal
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Overview
Lead is found and/or utilized
throughout the College. The two main sources of scrap lead are
from construction projects (e.g., old piping) and radiation
shielding materials (e.g., bricks). Lead is a toxic heavy metal
and in most cases regulated as a hazardous waste. However,
through a federal exemption for scrap metal recycling, the New
York State Department of Environmental Conservation allows the
recycling of lead via approved scrap metal recyclers. This
exempts the College from certain hazardous waste regulations
regarding lead wastes, so long as they are recycled
appropriately. As such, all scrap lead must be managed in
accordance with this Update and recycled via Environmental
Health and Safety’s approved scrap metal recycler.
Applicability
This Update applies to all
College employees and contractors working on behalf of the
College who require the disposal of scrap lead. Other types of
lead wastes not addressed in this Update must be managed as a
hazardous waste in accordance with the College’s waste disposal
procedures.
Responsibilities
Generators ensure that
all scrap lead is disposed in accordance with this Update.
Generators must refrain from using lead articles for purposes
other than their intended use (e.g., lead bricks as door stops).
Project Managers ensure
that all scrap lead generated from renovation and/or other
projects within College facilities (e.g. demolition phase) are
collected, stored, and managed in accordance with this Update.
Contact EHS prior to all projects generating scrap lead to
further discuss management procedures.
Contractors ensure that
the disposal of scrap lead is disposed in accordance with this
Update and coordinate its disposal with their Project Manager
and EHS. Under no circumstances shall a contractor remove scrap
lead from a work site without first receiving approval from EHS.
Environmental Health and
Safety (EHS) maintains appropriate permits and
recycling/disposal records, provides training and information to
the College community, and coordinates collections with the
external recycler and Project Managers, as necessary.
Radiation Safety surveys
all scrap lead utilized as a radiation shielding to ensure the
items do not contain radioactive contamination.
Procedure
SCRAP LEAD FROM RADIATION
SHIELDING MATERIALS
Lead utilized for radiation shielding materials may be in
the forms of bricks, foils, radioactive material shipper
packaging, and patient vests during x-raying. Any lead not
utilized for its intended purpose must be disposed in accordance
with this Update. The disposal of these scrap lead materials
must be managed as follows:
- Generator labels /
identifies scrap lead items with the words: “Scrap Lead for
Recycle (DEC C7 Scrap Metal Exemption)”
- Generator contacts the
Radiation Safety Office (x66964) to have the scrap lead
surveyed to ensure no radioactive contamination exists. Any
scrap lead found to contain radioactive contamination must
be decontaminated in accordance with Radiation Safety’s
protocols.
- Radiation Safety labels
each of the items which certify that the lead materials do
not contain any radioactive contamination. EHS will only
collect scrap lead materials which contains this label.
- Once the scrap lead has
been certified by Radiation Safety as having no radioactive
contamination, the generator completes an on-line Chemical
Collection Request Form available at EHS’ website with the
following statement added to the Comments field: “Scrap lead
was surveyed by Radiation Safety and no radioactive
contamination was observed.”
- EHS collects the scrap
lead from the generator and recycles the lead with an
approved scrap metal recycler.
SCRAP LEAD FROM CONSTRUCTION
PROJECTS
Scrap lead associated with construction projects may include old
piping and other related wastes/debris. Project Managers must
contact EHS to coordinate scrap lead management, collection,
storage, and recycling. Under no circumstances can scrap lead
be removed from the College without EHS’ approval. At a
minimum, scrap lead from construction projects must be managed
as follows:
- Project Manager notifies
EHS during the project’s pre-bid phase that scrap lead will
be generated.
- EHS will provide the
Project Manager with the EHS-approved scrap metal recycler
information to establish an account for the project.
- Scrap lead must be
collected and stored in a secure manner to prevent
unauthorized access and migration of lead contamination.
Scrap lead is labeled / identified with the words: “Scrap
Lead for Recycle (DEC C7 Scrap Metal Exemption)”
- Scrap lead generated at
the College must be recycled by the EHS-approved scrap metal
recycler.
- Project Manager provides
EHS with copies of shipping documents.
References
6 NYCRR Parts 370 through 374
and 376 – hazardous waste disposal 6 NYCRR 371.1(c)(7) – prior
notification for scrap metal exemption
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