I am tracking demolition waste from several structures that were removed to make room for my current LEED project. These structures contain several reports stating materials such as lead, PCBs, and asbestos. Most gov websites claim that PCBs are not considered a hazardous material if it is below a certain concentration. The owner of the facilities specifically denied that PCB testing occur during the demolition survey. Therefore much of the demolition waste was treated as hazardous materials (40% or roughly 4000 tons of demo waste) and was not able to be recycled with the rest of the structure.
Am I in the right to classify this ~4000 tons as hazardous material and not track it with the rest of my Construction Waste Management materials?
William LaRose
July 30, 2019 - 4:39 pm
Note: Asbestos was abated prior to demo.
Debra a. Lombard
Construction Administrator/ LEED APBywater Woodworks, Inc.
47 thumbs up
July 31, 2019 - 9:46 am
i believe you'd need state required documentation for all of that weight of haz waste showing it was properly sent to a state licensed haz waste facility even if it was done prior to demo.
I'd suggest emailing leedcoach@usgbc.com as they are very helpful with projects registered for certification and will answer ?s for free.
Debra
Tiffany Beffel
Managing PartnerInnovative Workshop Consulting
LEEDuser Expert
22 thumbs up
October 21, 2019 - 4:51 am
William, just curious if you were able to get some direction from LEEDcoach per Debra's suggestion? Per the reference guide as it currently stands for this credit, calculations should exclude hazardous waste, land-clearing debris, soil, and landscaping material. So all waste for your project deemed as hazardous would not get factored into credit calculations. You bring up an interesting point about the PCB's. USGBC's definition of hazardous materials includes "any item or agent (biological, chemical, physical) that has the potential to cause harm to humans, animals, or the environment, either by itself or through interaction with other factors" (https://www.usgbc.org/glossary/39#letterh). I would argue that PCB's of any concentration are a hazardous material based upon what they have been proven to cause. The Environmental Protection Agency has a significant amount of resources on the topic as well, if you are interested. My suggestion would be to include the PCB's as a hazardous material along with the others you have identified and not factor it into your calculations. On another note, if any of that hazardous material was found in the ground/soil or contaminated the ground/soil during demolition, you should look at credit requirements for High Priority Site (https://leeduser.buildinggreen.com/credit/NC-v4/LTc3#tab-credit-language) if any remediation is required.