Fact Sheets and Information Papers

Waste Characterization of Lead Paint-Containing Wastes

January 2001

Federal regulations mandate that solid waste generators determine whether their wastestreams should be classified as "hazardous wastes." Wastes that are deemed hazardous must be properly stored, treated and disposed in accordance with the Federal Resource Conservation and Recovery Act (RCRA). One of the characteristics that defines a hazardous waste is the amount of certain toxic constituents (e.g. metals like lead) that can leach from the waste. The RCRA defines the analytical method to be used to evaluate the waste and also stipulates the allowable limits for a constituent (e.g. lead) to leach.

The following Table describes various types of debris that are commonly "contaminated" with lead-containing paint. The discussion assumes that lead-containing paint has been previously identified (either through direct laboratory analyses, XRF testing, spot-tests, or historic knowledge). If NO information is available regarding the existence of lead in the painted surfaces, screening with one of these methods (i.e., direct lab analyses, XRF, etc.) is recommended to provide information for worker protection and may reduce the need for expensive waste characterization analysis (known as the Toxicity Characteristic Leaching Procedure or TCLP).

In the Table, a suggested waste characterization code is provided for each type of waste: HW = hazardous waste (as per RCRA 40 CFR 261.24); and SW = non-hazardous waste. These suggested waste characterizations are provided as a tool to assess your operation's wastestream and determine when analyses may be warranted or when enough information is available to characterize your waste based on "generator knowledge." Note that the information is based on general industry-based findings and that these are general guidelines only -- there may be exceptions to the waste characterizations listed based on your specific waste, the type of paint, concentration of lead in paint, and type of matrix.

Also, keep in mind that when waste is deemed to be SW (i.e, non-hazardous) some limited sampling and TCLP analysis for lead may be warranted for "liability's sake." * Classifying waste as HW without sampling and analyses, on the other hand, may be overly conservative and costly as a result of classifying some non-hazardous wastes as HW. While HW disposal is more expensive than regular SW disposal, the costs of sampling and analytical analyses (such as the TCLP for lead) do add up. A cost analyses may be beneficial to determine the most practical approach for your individual needs. *(NOTE: For whole building demolition debris, waste there is ample data available for use as "generator knowledge" that supports the characterization of this waste as SW (i.e. non-hazardous). See the report referenced below).

Finally, keep in mind that these suggested guidelines are all based on FEDERAL regulations. Individual States and localities may have more stringent requirements and therefore should be consulted when determining waste disposal practices.

Reference: USAEHA Interim Final Report, Lead-Based Paint Contaminated Debris - Waste Characterization Study No. 37-26-JK44-92, May 1992 - May 1993.

POC: Matt Walter, 410-436-3651; Hazardous and Medical Waste Program
U.S. Army Center for Health Promotion and Preventive Medicine
Aberdeen Proving Ground, MD 21010-5422

WASTE TYPES AND TYPICAL CHARACTERIZATIONS

(1) Whole Building Demolition Debris. Consists of all building components (painted and non-painted) to include wood, brick, cement (foundations), plaster, drywall, etc. that are torn down during demolition and collected for disposal. Waste characterization is based on analyses of samples that are "representative" of the waste. Therefore, proportionate quantities of the various structural components can be obtained (e.g., by coring or drilling through the materials) and combined for analyses in accordance with the TCLP requirements.

 

SW

 

 

 

(2) Partial Demolition (Building Renovation). May consist of a variety of components (painted and non-painted)such as those in whole building demolition debris, but does not entail entire building/structure. Same sampling procedures as discussed above may be used. A second option involves careful predetermination and characterization of the individual components to allow for special waste handling and segregation procedures during the operations. Careful segregation is more feasible for renovations/partial demolitions than for whole building demolition and may reduce the volume of hazardous waste. Where segregation is not practical for a particular operation the overall "representative" sample approach should be used. A cost analyses may be beneficial to determine waste management practices.

 

SW/HW/both

 

 

 

(3) Unique Components. This category includes discrete components that have been removed for abatement or maintenance purposes. Such components may include baseboards, window frames, doors, etc. Particularly where the components come from similar structures, some minimal sampling may be beneficial, particularly where the concentrations of lead in the paint are not deemed to be extremely high (??). Sampling should include the substrate (e.g., wood) and therefore be consistent with the "representative" approach. Usually, the proportion of paint to overall mass of the waste is sufficient to result in a relatively "high" TCLP concentration, therefore resulting in a hazardous waste.

 

HW

 

 

 

(4) Contaminated Media/Items. The category encompasses everything from the paints chips/scrapings to solvents to personal protective clothing and other items that are "contaminated" with dust or paint chips/residues. Some of items are listed below with associated discussion and waste characterizations.

 

 

 

 

 

- Paint chips/scrapings. Contain and collect. Should be handled, packaged, and disposed as a HW.

 

HW

 

 

 

- Blast grit. Since there are different types of grit material and degree of contamination will vary, limited sampling is recommended.

 

HW/SW

 

 

 

- Solvents. These may be hazardous for constituents other than lead, specifically for RCRA "listed" compounds. The Material Safety Data Sheets (MSDSs) or other product information should be referred to for more information. "Listed" compounds are HWs regardless of lead concentrations. For otherwise nonhazardous solvents, the concentrations of lead must be established after use for ultimate waste characterization. Some solvents may be able to be distilled/recycled. While the "cleaned" solvent would not be a HW, any sludge or filters used for recycling purposes are probably HWs (see below.)

 

HW

 

 

 

- Caustic Pastes. Due to different compounds and different paints, minimal sampling and analyses is suggested.

 

HW/SW

 

 

 

- Water. Water may be used during blasting, decontamination, rinsing, etc. Due to the different uses, minimal sampling is recommended. Whenever possible, recycling of water is recommended; filters used in recycling may be HW (see below).

 

HW/SW

 

 

 

- Filters, sludges, etc. From air filters, water filters/recycling, or solvent reclamation operations, these items are usually very "concentrated" wastes that are high in lead and therefore a HW.

 

HW

 

 

 

- Plastics, tarps, PPE. To the degree possible, these items should be reused. At the end of an operation or when disposal of these items is otherwise necessary, best management practices include proper containment (i.e., drumming) handling and disposal. In general, it may be most cost efficient to classify these wastes as a HW without sampling.

 

HW

 

 

 

- Soil. Soil that is "contaminated" with lead may [based on a health risk assessment and/or EPA Office of Solid Waste and Emergency Response (OSWER) Lead Clean-up levels of 500-1000 ppm] may have to be removed from a site and properly disposed. Similar to other materials previously discussed, the waste characterization of this removed soil will depend on a TCLP analyses for lead. Limited sampling is recommended to characterize the waste soil.

 

HW/SW

 

 

 

Back to Fact Sheet Index