David S. Kosson1 and Hans A. van der Sloot2 1Vanderbilt University

2Hans van der Sloot Consultancy

Overview/Update Regarding LEAF Methodology and its Application to Beneficial Use in the United States and Europe

May 29, 2014

Current Status in US

• LEAF Test Methods

Methods 1313, 1314, 1315, 1316 – posted to SW-846, Aug. 2012

Modified methods for application to organic contaminants - future

• Methodology for Evaluation of Beneficial Use of Coal Combustion

Residues in Encapsulated Uses – Feb. 2013

• Leaching Test Relationships,

Laboratory-to-Field Comparisons and Recommendations for

Leaching Evaluation using the Leaching Environmental Assessment

Framework (LEAF) – 2014 (June?)

• Guidance on Selection and Use of LEAF Methods – pending

• Regulations for Disposal of CCRs – pending

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Current Status in US

• Detailed Methodology and Examples for Use of LEAF for

Source Terms – on-going, beginning late 2015 Contaminated site remediation

Mining site reclamation using coal fly ash

Use in road construction

Evaluation of treatment processes

Disposal evaluations

• LeachXS Lite Version 2 available – Oct. 2014

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Methodology for Evaluating Encapsulated

Beneficial Uses of Coal Combustion Residuals US EPA, Office of Solid Waste and Emergency Response, Sept. 2013

Evaluation methodology for determining whether environmental

releases from encapsulated beneficial uses of CCRs are comparable to

or lower than those from analogous non-CCR products, or are at or

below relevant regulatory and health-based benchmarks for human and

ecological receptors, during use by the consumer

Example applications: cement & concrete, bricks, gypsum wall board,

filler in plastics or rubber, etc.

5 Step Process:

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1. Literature Review

2. Comparison of

Available Data

3. Exposure Review

4. Screening

Assessment

5. Risk Assessment

Step 1 – Literature Review

• Existing evaluations, technical standards, previous determinations,

regulations, leaching data, etc.

If the review finds a given voluntary technical consensus standard or

other type of existing evaluation to be of sufficient applicability and

quality to demonstrate that releases from the CCR beneficial use under

evaluation are comparable to or lower than those from an analogous

product, or are at or below relevant regulatory and health-based

benchmarks, then no additional evaluation is necessary.

• Collect data on the COPCs present in and released from the CCR

beneficial use product under evaluation that were not sufficiently

addressed by existing evaluations.

Identity of the COPCs, the range of COPC concentrations that may be

present in the CCR and beneficial use product, and the rate at which

the COPCs may be released into the surrounding environment.

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Step 2 – Comparison of Available Data

• Determine whether COPC releases from the beneficial

use product are comparable to or lower than those from

an analogous product.

• Requires that the beneficial use product and analogous

product have at least one COPC and corresponding

release route in common.

Must consider all applicable COPCs and release routes

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Step 3 – Exposure Review

• Development of a conceptual exposure model for each

COPC and corresponding release route carried forward

from the previous steps.

Qualitatively illustrates the components of a complete exposure pathway

Human and ecological receptors considered

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Step 4 – Screening Assessment

• Comparison of the COPCs, carried forward from previous steps, to

appropriate regulatory or health-based screening benchmark

• Conservative data and assumptions on environmental conditions

present, fate and transport of the COPCs, and/or receptor

exposures

• Selection of screening benchmarks

• COPC concentrations at the point of release may be used in place

of the concentrations at the point of exposure and compared directly

to applicable screening benchmarks

Step 5 – Risk Assessment

• Applied only to remaining COPCs and pathways/receptors

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Coal Combustion Residual Beneficial Use Evaluation:

Fly Ash Concrete and FGD Gypsum Wallboard US EPA, OSWER, Feb. 2014

Use of fly ash in Cement and Concrete

• Considered exposure to dust, exposure to ground water

and surface water

• Use of LEAF Method 1313 & 1315 results for initial

screening

• Use of LEAF Method 1315 results as source term for risk

assessment Evaluation of representative locations and release scenarios

Intermittent wetting based on cycling of single and multi-day precipitation

events assumed as 1 and 2 day cumulative release from concrete.

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European developments in use of LEAF based methods and associated

regulatory developments

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Same basic testing approach in different fields

Standardisation in CEN/TC351 – Harmonisation of methods for CE marking of Construction Products

Test

Soil, sediments,

compost and

sludge Waste Mining waste Construction products

pH dependence test ISO/TS21268-4 PrEN14429 PrEN14429 PrEN14429#

PrEN14497 PrEN14497

EPA 1313 * EPA 1313 EPA 1313 EPA 1313

Percolation test ISO/TS21268-3 PrEN14405 PrEN14405 FprCENTS 16637-3

NEN7373 NEN7373

EPA 1314 * EPA 1314 EPA 1314 EPA 1314

Monolith test PrEN15863 FprCENTS 16637-2

NEN7375 NEN7375

EPA 1315 * EPA 1315 EPA 1315 EPA 1315

Compacted granular test NEN7347 FprCENTS 16637-2

EPA 1315 EPA 1315 EPA 1315 EPA 1315

Redox capacity CEN/TS 16660

Acid rock drainage EN15875

Reactive surfaces

ISO/CD12782

parts 1-5

Vienna

Agreement

* EPA methods included in SW846 & based on NEN 7348 # Not yet adopted in CEN/TC 351 (very relevant for CPR)

Matrix

Development of Standards and Materials Covered

From: CEN Guide on validation tasks in the process of

standardisation of environmental test methods,

April 2008, ENV TC 215rev, supported by SABE

Resolution 06/2008 - Validation policy

This is the status today:

- CEN/TC351 Robustness work completed

(TS-2 and TS-3). Preparation for

intercomparison validation. Eluate and

content analysis will run in parallel.

- US EPA Intercomparison validation

finalized (pH dependence, percolation ,

monolith, CGLT)

- CEN/TC292 in the process of adopting

EPA validation results to upgrade TS to

EN’s

Steps in validation

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Construction Products Directive (EU CPD Directive 89/106/EEC)

Construction Products Regulation (EU CPR Directive 305/2011)

European Landfill Directive (EU LFD)

End of Waste regulation (EU EoW)

Waste Catalogue (EU WC)

Hazardous Waste Directive (EU HW)

REACH Regulation

Soil Quality Regulation – Fertilizer use

Groundwater Directive

Regulatory context

With multiple regulations : preferably not multiple testing and multiple impact judment

approaches for the same material or product

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EU Landfill Directive

EU wide criteria for waste established in 2002 Since 2002 no EU wide criteria for stabilized/solidified waste, only national regulations Since 2 years discussions to come to methods (established in CEN/TC292 Waste) and criteria for stabilized/solidified waste (Technical Adaptations Committee of Directorate General of Environment)

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Hazardous Waste Directive – Waste List

Proposal by the European Commission to align Classification, Labelling

and Packaging (CLP) Directive with the List of Wastes and Annex III of the

Hazardous Waste Directive (HWD) has resulted classification of “wastes”

frequently considered for beneficial use as hazardous.

This will have major consequences for the reuse/recycling policy currently

practiced in EU and EU member States

The main reason is the use of Total Content for lack of a precise

description of the chemical form of substances in, for instance residues

from thermal processes. The leaching tools constituting LEAF provide

means to overcome this problem (in discussion). EU Commission has

now provided a decision on all HP’s with the exception of HP14

(Ecotoxicity).

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End of Waste

Develop criteria for waste destined for beneficial use

For some waste types separate criteria already established (e.g iron scrap)

Original intentions to come to EU regulations on End of Waste for aggregates proved not feasible. Propositions have been made to resolve the issue (2012).

So far European Commission through its Joint Research Centre has not come yet with new proposals.

Issue is becoming more and more important as more and more wastes are considered for beneficial use applications

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Construction Products Directive/Regulation

- The Construction Product Directive (CPD) as of July 2013 replaced by the Construction Product Regulation (CPR). The CPD only covered CE marking for service life

- Construction Product Regulation covers in addition to CPD recycling/reuse and End of Life aspects of products

- Technical specifications are covered by Product Technical Committees

- Environmental and Health aspects are addressed by CEN/TC351, where currently discussions are ongoing about a harmonized leaching test covering coarse granular materials (slags)

- For specific products “Dossiers” are developed to facilitate decisions on WFT (without further testing) and FT (further testing) either for individual substances, a group of substances or a specific product type

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Thank you

for your attention and invitation to

participate in this workshop!

Questions?

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