This guide provides information regarding handling, testing, and disposal of solid debris generated during preparation of surfaces previously painted with lead-containing paint.
This guide is based on federal regulations only. State or local regulations may be more restrictive and must be investigated. States or other local jurisdictions may have requirements which are stricter, such as requiring other analytical procedures or regulating other metals. Nonhazardous waste containing lead is also regulated in some states.
This guide does not cover removal of the coating from the structure or containment of the debris. These activities are described in SSPC-Guide 6. 1.4 While this guide is written primarily with reference to removing lead-based paints, other elements as presented in Table 1 may also cause the debris to be classified as a hazardous waste.
This guide does not cover disposal of water from methods of cleaning.
Wastes not discussed in this guide should be handled in compliance with all applicable regulations.
This guide is intended to be used by facility owners, specifiers, or contractors.
GENERAL: Surface preparation debris may include old paint, spent abrasives, corrosion products, dirt, dust, grease, and salts. Constituents such as lead, cadmium, chromium, or other heavy metals may result in the waste stream being classified as hazardous waste, requiring special handling and disposal. Special handling and disposal may also be required for non-hazardous wastes under certain circumstances. It is important to note that the surface preparation debris is not classified as hazardous waste until tested, although it must be regarded and handled as a hazardous material until shown to be non-hazardous.
OUTLINE OF PROCEDURE: The major activities covered in this guide are as follows:
1) Site Procedures Prior to and Including Classifying Waste (Section 5): These include collecting, packaging, transporting to a temporary storage area, as well as temporary storage, sampling, testing, and classifying waste.
2) Procedures for Disposing of Hazardous Waste (Section 6): The generator must obtain an EPA ID number and determine the disposal options. For disposing of waste offsite, the generator must select a TSD (treatment, storage, and disposal) site, select a waste hauler, prepare a manifest, ship the waste, and prepare a biennial report. For treatment of waste on-site, in accumulation containers, the generator must determine the time allowed for treatment, select a treatment method, prepare and submit a waste analysis plan, treat the waste, and verify that it is nonhazardous and can be disposed of at a non-hazardous site.
Procedures for Disposing of Non-Hazardous Waste (Section 7): The generator must identify any state or local requirements or restrictions, select a non-hazardous disposal facility, and ship the waste to the facility.
Commentary (Section 8): In addition, the guide provides an extensive commentary section discussing regulations, testing and sampling procedures, and other important considerations.
