SSPC-Guide 7

July 9, 2015

SSPC: The Society for Protective Coatings

Technology Guide No. 7
GUIDE TO THE DISPOSAL OF LEAD-CONTAMINATED
SURFACE PREPARATION DEBRIS

1. Scope cadmium, chromium, or other heavy metals may result in the

waste stream being classified as hazardous waste, requiring
1.1 This guide provides information regarding handling, special handling and disposal. Under certain circumstances,
testing, and disposal of solid debris generated during special handling and disposal may also be required for
preparation of surfaces previously painted with lead-containing non-hazardous wastes. It is important to note that surface
paint. preparation debris is not classified as hazardous waste
until tested, although it must be regarded and handled as a
1.2 This guide is based on U.S. federal regulations only. hazardous material until shown to be non-hazardous. Certain
States or other local jurisdictions may have requirements that waste streams, such as waste materials from chemical
are stricter, such as requiring additional analytical procedures stripping, may also be subject to hazardous waste regulations
or regulating other metals. Non-hazardous waste containing because they are ignitable (D001), corrosive (D002) or reactive
lead is also regulated in some states. (D003).

1.3 This guide does not cover other waste streams such 2.2 OUTLINE OF PROCEDURE: The major activities
as discarded tarpaulins and personal protective equipment covered in this guide are as follows:
that may be contaminated with lead and must be tested to
determine proper disposal. 2.2.1 Site Procedures Prior to and Including
Classifying Waste (Section 5): These include collecting,
1.4 This guide does not cover removal of the coating from packaging, transporting to a temporary storage area, as well
the structure or containment of the debris. These activities are as temporary storage, sampling, testing, and classifying waste.
described in SSPC-Guide 6.
2.2.2 Procedures for Disposing of Hazardous Waste
TABLE 1 (Section 6): The generator must obtain an EPA ID number
TOXICITY LEACHATE LEVELS FOR METALS and determine the disposal options. For disposing of waste
(40 CFR 261 – as of October 1, 2013) offsite, the generator must select a TSD (treatment, storage,
EPA and disposal) site, select a waste hauler, prepare a manifest
Concentration Hazardous (see Figure 1), ship the waste, and prepare a biennial report.
Element
mg/L Waste
For treatment of waste on-site, in accumulation containers, the
Designation
generator must determine the time allowed for treatment, select
Arsenic 5.0 D004
a treatment method, prepare and submit a waste analysis plan,
Barium 100.0 D005
obtain EPA approval, treat the waste, and verify that it is non-
Cadmium 1.0 D006
hazardous and can be disposed of at a non-hazardous site.
Chromium (total) 5.0 D007
Lead 5.0 D008
Mercury 0.2 D009 2.2.3 Procedures for Disposing of Non-Hazardous
Selenium 1.0 D010 Waste (Section 7): The generator must identify any state
Silver 5.0 D011 or local requirements or restrictions, select a non-hazardous
disposal facility, and ship the waste to the facility.
1.5 While this guide is written primarily with reference
to removing lead-based paints, other elements as presented 2.2.4 Commentary (Section 8): In addition, the guide
in Table 1 may also cause the debris to be classified as a provides an extensive commentary section discussing
hazardous waste. regulations, testing and sampling procedures, and other
important considerations.
2. Description and Definitions
2.3 DEFINITIONS
2.1 GENERAL: Surface preparation debris usually
Beneficial Reuse: Use of a waste material as a raw
includes old paint, spent abrasives, corrosion products, dirt,
ingredient for another process to reduce or eliminate a waste
dust, grease, and salts. Constituents such as lead, arsenic,
stream.
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July 9, 2015

FIGURE 1
HAZARDOUS WASTE MANIFEST

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) � � � � � Form Approved. OMB No. 2050-0039
4. Manifest Tracking Number
UNIFORM HAZARDOUS 1. Generator ID Number 2. Page 1 of 3. Emergency Response Phone
WASTE MANIFEST
5. Generator's Name and Mailing Address Generator's Site Address (if different than mailing address)

Generator's Phone:
6. Transporter 1 Company Name U.S. EPA ID Number

7. Transporter 2 Company Name U.S. EPA ID Number

8. Designated Facility Name and Site Address U.S. EPA ID Number

D
Facility's Phone:

I
9a. 9b. U.S. DOT Description (including Proper Shipping Name, Hazard Class, ID Number, 10. Containers 11. Total 12. Unit
and Packing Group (if any)) 13. Waste Codes
HM No. Type Quantity Wt./Vol.
1.
GENERATOR

2.

O
3.

V
4.

14. Special Handling Instructions and Additional Information

15.� GENERATOR’S/OFFEROR’S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged,
� marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations. If export shipment and I am the Primary
� Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.
� I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true.
Generator's/Offeror's Printed/Typed Name Signature Month Day Year

16. International Shipments

TR ANSPORTER INT'L

Import to U.S. Export from U.S. Port of entry/exit: _________________________________________________________

Transporter signature (for exports only): � � � � � Date leaving U.S.: �
17. Transporter Acknowledgment of Receipt of Materials
Transporter 1 Printed/Typed Name Signature Month Day Year

Transporter 2 Printed/Typed Name Signature Month Day Year

18. Discrepancy
18a. Discrepancy Indication Space
Quantity Type Residue Partial Rejection Full Rejection

Manifest Reference Number:

DESIGNATED FACILITY

18b. Alternate Facility (or Generator) U.S. EPA ID Number

Facility's Phone:
18c. Signature of Alternate Facility (or Generator) Month Day Year

1.
19. Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems)
1. 2. 3. 4.

20. Designated Facility Owner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a
Printed/Typed Name Signature Month Day Year

EPA Form 8700-22 (Rev. 3-05) Previous editions are obsolete. DESIGNATED FACILITY TO DESTINATION STATE (IF REQUIRED)

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Generator means any person, by site, whose act or 40 CFR 265 Interim Status Standards for Owners
process produces hazardous waste or whose act first causes and Operators of Hazardous Waste
a hazardous waste to become subject to regulation.1 (The Treatment, Storage, and Disposal
EPA considers both the owner and the contractor to be co- Facilities
generators.) 40 CFR 268 Land Disposal Restrictions
49 CFR 172 Marking, Labeling, and Placarding
Landfill - Subtitle C: A landfill permitted in accordance 49 CFR 173 Packaging
with Subtitle C of the Resource Conservation and Recovery 49 CFR 178 Containers
Act for the disposal of hazardous waste. ,
3.3 U.S. ENVIRONMENTAL PROTECTION AGENCY
Landfill - Subtitle D: A landfill permitted in accordance (EPA):
with Subtitle D of the Resource Conservation and Recovery SW 846 Test Methods for Evaluating Solid
Act for the disposal of non-hazardous waste. Wastes3
Method 1320 Multiple Extraction Procedure4
Manifest: The shipping document U.S. EPA Form 8700- Method 1311 Standard Toxicity Leachate Procedure
22 and, if necessary, U.S. EPA Form 8700-22A, originated
and signed by the generator, transporter, and disposal firm to 4. Procedures Prior to Waste Collection
provide a paper trail for handling and disposal of hazardous
waste. It must accompany the shipment to its destinations 4.1 PLANNING: Surface preparation debris is a waste
and must be signed by the transporter and disposer and then generated by the need to maintain structures by removing and
returned to the generator to keep on file. replacing existing coatings. In planning maintenance painting,
one must take into account the regulations, restrictions, quality
On-Site: The same or geographically contiguous property, of protection, and economics of the entire operation. Activities
which could be divided by a public or private right-of-way, range from condition assessment, to selecting a maintenance
provided the entrance and exit between the properties is at a option, to containment and disposal of waste. Considerations
crossroads intersection, and access is by crossing as opposed and procedures for planning maintenance painting programs
to going along the right-of-way. Noncontiguous properties are given in SSPC-PA Guide 5.
owned by the same person but connected by a right-of-way,
which the owner controls and to which the public does not 4.2 FACTORS AFFECTING WASTE: The quantity of
have access, are also considered on-site property. the waste generated and the concentration of lead and other
composition factors are affected by the method used to remove
3. Referenced Documents the existing coating. Abrasive blasting with non-recyclable
abrasive produces the greatest volume of waste. Significantly
3.1 SSPC STANDARDS AND PUBLICATIONS: less waste is generated using recyclable abrasives. Non-
blast-cleaning methods such as hand or power tool cleaning
PA Guide 5 Guide to Maintenance Painting generate the least amount of waste.
Programs
Guide 6 Guide for Containing Debris Generated 4.3 REMOVING AND CONTAINING LEAD AND OTHER
During Paint Removal Operations
PAINT: Methods for removing existing paint and preventing
SSPC PCG Protective Coatings Glossary
the paint from contaminating the environment are described
in SSPC-Guide 6.
3.2 CODE OF FEDERAL REGULATIONS:2

40 CFR 260 Hazardous Waste Management 5. Site Procedures Prior to and Including
System: General Classifying Waste
40 CFR 261 Identification and Listing of Hazardous
Waste The following procedures are required of the waste
40 CFR 262 Standards Applicable to Generator of generator prior to determining if the waste is hazardous.
Hazardous Waste Although the surface preparation debris is not classified
40 CFR 263 Standards Applicable to Transporters as hazardous waste until tested, it should be handled as a
of Hazardous Waste hazardous material until it is proven non-hazardous.
40 CFR 264 Standards for Owners and Opera-
tors of Hazardous Waste Treatment, 5.1 COLLECT WASTE: Proper collection of the surface
Storage, and Disposal Facilities preparation debris is one of the most important steps in
3
1
US Environmental Protection Agency (EPA), 1200 Pennsylvania Avenue, NW,
The definition is taken directly from 40 CFR 260.10. Washington, DC 20460; or online at <http://www.epa.gov/epawaste/hazard/
2
CFRs may be obtained online at testmethods/sw846/index.htm>
<http://www.ecfr.gov/cgi-bin/ECFR?page=browse> 4
Available online from: <http://www.epa.gov/epawaste/hazard/testmethods/
sw846/pdfs/1320.pdf>

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handling the debris. Precautions to prevent release of the ground that is not subject to flooding (40 CFR 264.18). A fence
removed lead-containing paint into the air, water, or soil should enclose the area, and prominent warning signs should
must be taken when transferring the debris from the work be displayed around the perimeter. If the same storage site is
area to the storage containers. Collection of the potentially also used for equipment and supplies, the waste containers
hazardous debris should be carried out frequently, typically at should be segregated within the site. All the waste debris
least once per day. Samples of material for analysis should should be placed in an assigned area within the secured site
be taken during collection, as described in Section 5.6. When and surrounded with a temporary “fence” of ribbons or thin
containing disposable abrasives, collection may be done less rope. Identification and warning signs should be posted where
frequently as long as the debris is not permitted to escape the material is being stored, and all drums must be placed on
from containment. Whether collection is carried out using pallets or dunnage to prevent corrosive attack from moist soil.
mechanical devices, vacuuming systems, or hand tools, it is Drums should be stored in rows no more than two wide and two
important that the workers be fully protected against breathing, high, with a minimum 1-meter (or 36-inch) wide aisle between
ingesting, or contacting any of the debris. rows. The containers must be arranged so that the labels are
visible at all times. The site must be adequately protected
5.2 PACKAGE AND LABEL WASTE: The lead-containing from vandalism or unauthorized access by the public (40 CFR
spent blast media, or other debris, including containerized 264.14). The waste storage area must be inspected weekly
waste that is being collected for analysis must be stored in a to ensure all wastes are secure, containers are not leaking;
manner that will not allow entry of any hazardous material into all labels are attached, legible and visible without having to
the environment. Leak-proof drums, or leak-proof portable bins move the container; the storage area is properly arranged; and
are generally acceptable. Containers need to meet the DOT no hazardous waste has exceeded its maximum accumulation
requirements (49 CFR 178) for transporting the waste off-site. time (see Section 5.5). It is good practice to cover the ground
The lids of the drums, or the covers of the bins, must be firmly in the waste storage area with a tarpaulin such that if there was
secured. The containers must be kept out of flood plains or a spill, the waste does not touch the environment.
areas where run-off may occur. Weather resistant labels using
indelible ink warning of the potential hazards associated with 5.5 ACCUMULATION TIME AND REQUIREMENTS
the material must be placed on the containers. The containers
should be marked with the contents, tare weights of the 5.5.1 Accumulation Time: Hazardous waste can be
containers, and the origin and date of collection of the material. accumulated on-site for purposes of collecting enough waste
Marking and labeling requirements are contained in 49 CFR to make transportation more cost effective. The length of time
172. The containers should be keyed to the samples taken. hazardous waste can remain in on-site storage is primarily
dependent upon the amount of waste generated.
5.3 TRANSPORT WASTE TO TEMPORARY STORAGE
AREA: The filled containers can then be moved to a temporary 5.5.1.1 Large-quantity generators produce 1,000 kg (2,200
holding area at the work site. During the moving operations, lbs) or more of waste per month. For large-quantity generators,
normal precautions must be taken to prevent damage that the accumulation period is a maximum of 90 days. A one-
would result in spillage of contents or entry of water into time, 30-day extension can be granted at the discretion of the
the containers. Transportation of hazardous or potentially Regional U.S. EPA Administrator on a case-to-case basis.
hazardous waste to a temporary storage area on the job
site can be performed by the generator. On-site transport by 5.5.1.2 A small-quantity generator who produces greater
the generator is allowed even if a road bisects the property than 100 kg (220 lbs) but less than 1,000 kg (2,200 lbs) per
provided the access to the two sections of the property only month may accumulate waste on-site for a maximum of 180
requires driving the vehicle across the road. Transportation days provided the quantity of waste on site does not exceed
directly to a temporary or permanent off-site storage area must 6,000 kg (13,200 lbs). If the waste is to be transported over
be done in accordance with 40 CFR 263, unless the owner 200 miles for treatment or disposal, the time is extended to 270
has other arrangements with state and/or local regulatory days. The Regional U.S. EPA Administrator can grant 30-day
agencies. extensions on a case-by-case basis.
Up to one full drum of hazardous waste is allowed to
remain in the work area for no more than 3 days before it must 5.5.1.3 Generators exceeding the allowed accumulation
be moved to the temporary waste storage area. period are considered to be the operators of hazardous waste
storage facilities, and must comply with the regulations in 40
5.4 STORE WASTE AT TEMPORARY SITE: Site CFR Parts 264 and 265.
storage involves grouping of materials by particular work site,
even though the physical location of the storage site may be 5.5.2 Emergency Plan: A contingency plan and
separated from the work site itself. Regardless of the location procedures for use in an emergency must be developed.
of the storage site, certain requirements remain constant. Large-quantity generators must have a written contingency
The site must be secure. Security begins with the choice plan. Small-quantity generators are not required to have the
of a suitable location. Storage sites must be on well- drained plan in writing.

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5.5.3 Personnel Training: Workers involved in handling 5.6.3 NUMBER OF SAMPLES: The number of samples
and storage of hazardous waste must successfully complete needed is determined by the variability of the laboratory test
a program of classroom instruction or on-the-job training that results. SW 846, Chapter 9 - Sampling Plan, presents the
teaches them to perform their duties in a manner consistent requirements for determining the number of samples. Appendix
with the regulations and how to respond in emergencies A presents a detailed discussion of sampling requirements and
(40 CFR 265.16). The employer must maintain records of interpreting results.
training received by each employee. An annual review by
employees is required. 5.6.3.1 Minimum Number of Samples: The minimum
number of samples to be collected is four, unless the owner
5.6 SAMPLING: Sampling of debris for testing and has determined that the waste is to be classified as hazardous.
analysis (see Section 5.7) is the responsibility of the generator
(40 CFR 262.11). Information on sampling methods is given in 5.6.4 TESTING OF INITIAL SAMPLE: The samples
40 CFR 261, Appendix 1. should be sent to the laboratory with instructions to analyze just
one. TSDs and testing laboratories require a Chain of Custody
5.6.1 Sampling Plan: A sampling plan must be developed Form to accompany the samples sent to the laboratory.
prior to beginning work. The sampling plan should include who If the result of the initial test is 8 mg/L or greater for
will be responsible for the sampling, how often samples will be leachable lead, the waste should be declared hazardous, and
taken, how the samples will be obtained, where the samples no further laboratory testing is needed. If 8 mg/L leachable
will be taken, and how the samples will be handled. lead is found in one sample, then there is a possibility that the
Note: If the waste stream is known to exhibit one of the waste will be classified as non-hazardous (see Sections 5.7
other hazardous waste characteristics such as ignitability, and 5.8). As an example, if one sample had a leachable lead
corrosivity, or reactivity, the plan should include provisions for level of 8 mg/L and three samples had a leachable lead level
such testing. of 0 mg/L, then the leachable lead content for the waste these
samples represent would be 5.0 mg/L. The probability of this
5.6.2 Representative Samples occurring is extremely low if these are representative samples.
If the result of the initial test is between 5 and 8 mg/L,
5.6.2.1 It is necessary to obtain representative samples in the generator must decide whether or not to measure the
order to obtain legitimate results. The proper method for spent leachable lead content of the other three samples to determine
abrasive is to use a random sampling technique. The best time if the waste is non-hazardous, or to forego further testing and
to obtain a representative sample is before the material has declare the waste to be hazardous.
ever been moved. Appropriate sampling techniques are the If the result of the initial test is less than 5 mg/L, the
grid method or quartering method. The grid method consists other three samples should be tested to determine the waste
of drawing an imaginary grid on the containment floor and classification.
selecting row/column combinations using a random method
such as a random number table. The quartering method is 5.6.5 Determine Need for Additional Samples: If the
described in ASTM C702. result obtained from the initial sample shows the waste to be
hazardous, no further samples need to be tested.
5.6.2.2 If one piles the debris or places it in containers, If the average of the four samples plus the confidence
the task becomes difficult. There are thieving devices available interval (Appendix A) is 5 mg/L or less, the waste is classified
for such sampling, but a somewhat non-uniform material like as non-hazardous and no further samples are required.
spent abrasives would still be very difficult to sample. If the average of the four samples is less than 5 mg/L,
but the confidence interval increases it to above 5 mg/L,
5.6.2.3 For recyclable abrasives, the waste stream is the additional samples are needed to establish that the waste is
material discharged from the recycling machine. The periodic non-hazardous. The appropriate number of samples can be
method is used, where subsamples are obtained at regular calculated from Appendix A. Otherwise the waste is classified
time intervals and composited with each other. as hazardous.

5.6.2.4 The waste streams from dust collectors and 5.7 TESTING AND ANALYSIS
recycling units should be sampled in accordance with 5.6.2.2
or 5.6.2.3. 5.7.1 Testing of the waste (paint and abrasive debris)
for leachable lead is performed by a laboratory. The Federal
5.6.2.5 Debris sampling should be performed early in government does not approve waste testing laboratories. Some
the project as it takes time for laboratory analysis, making states or organizations have requirements regarding who can
arrangements with the transporter and treatment, storage and perform the laboratory analysis. Jurisdictions over laboratories
disposal facility, and to obtain permits (if necessary). Delay approved to perform testing vary from state to state, or among
in testing may result in exceeding the 90-day on-site storage different authorities within the state. The generator should use
restriction for a large quantity generator. a laboratory that performs the analysis in accordance with test

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procedures and quality assurance requirements of the state 5.8.6 Waste that is not hazardous according to the
or jurisdiction where the waste had been generated and in above should be disposed of in accordance with Section 7.
accordance with 40 CFR Part 268, Appendix 1. This is EPA The generator should also check state or local regulations to
Method 1311, Toxicity Characteristic Leaching Procedure determine if the state has established any additional criteria for
(TCLP). hazardous waste (see Section 8.4).

5.7.2 Method 1311 consists of placing the solid waste in 6. PROCEDURES FOR DISPOSING OF
an acetic acid solution and tumbling the slurry for 18 hours. HAZARDOUS WASTE
The slurry is filtered and a sample of the liquid is then tested for
the heavy metals or materials of interest. (Note: There is a 20:1 6.1 If the analysis of the lead-containing waste stream
dilution as part of the TCLP test; therefore the waste can be shows that it contains more than 5 mg/L of leachable lead,
declared to be nonhazardous if the total metal concentration is and no present or future alternative use as a raw material
less than 20 times its regulatory limit [100 ppm for lead].) is anticipated (see Section 8.1.2), it is then declared to be
a hazardous waste. Preparations must be made to dispose
5.7.3 Once the concentrations of the elements of interest of it as such. An EPA number is obtained, a disposal site is
have been obtained, the average (x), standard deviation (S), chosen, all containers are properly labeled, and the required
standard error (Sx), and confidence interval (C.I.) are calculated manifests are prepared. An alternative is onsite treatment prior
as shown in Appendix A. to disposal as presented in Section 6.4.

5.8 DETERMINING IF WASTE IS HAZARDOUS 6.1.1 EPA Identification Number: A hazardous waste
generator must obtain an EPA identification number. This is
5.8.1 If the waste tested as described in Section 5.7 has a obtained from the state or local EPA office. The owner should
leachable lead concentration of 5 mg/L or greater, the waste is obtain the EPA identification number, rather than the contractor
considered hazardous. The threshold level of toxicity for other who performs the work. Waste cannot be transported or
heavy metals is shown in Table 1. disposed of without this number. The waste remains the
property of the generator in perpetuity. For surface preparation
5.8.2 In determining whether the waste is hazardous, one debris, the owner of the structure from which the debris
uses the average value of the leachable lead concentration was created and the contractor who created the waste are
of the four samples selected as in Section 5.6. Because of considered co-generators.
statistical fluctuations, the EPA requires that the average value
plus the confidence interval, when computed as described in 6.1.2 Different types of EPA identification numbers are
Appendix A, be less than 5 mg/L for lead. If the average is less available. The owner should determine the appropriate type
than 5 mg/L but the confidence interval brings the total above needed. The different types are:
5 mg/L, the waste is considered hazardous. It is possible to
reduce the confidence interval by taking a larger number of 6.1.2.1 Regular: Permanent ID numbers are intended
samples (see Section 5.6.5). for facilities that will generate a hazardous waste on a long-
term, consistent basis. Owners may desire to cover all of their
5.8.3 If the waste is hazardous, it becomes subject to the facilities where lead-containing debris will be generated under
provisions of the Resource Conservation and Recovery Act one ID number.
(RCRA). It must be treated to become non-hazardous before
it can be placed in a landfill (see Appendix B for additional 6.1.2.2 Site-Specific: Site-specific ID numbers are
sources of information). intended for facilities that will only generate a hazardous waste
one time. Owners may desire to identify each site, such as
5.8.4 Waste determined to be hazardous shall be disposed individual water towers, bridges, tank farms, etc., and have a
of as described in Section 6. unique ID number for each one.

5.8.5 Waste from abrasive blasting with ferrous abrasives 6.1.2.3 Provisional: Provisional ID numbers are intended
will most likely test as being non-hazardous due to a plating for unforeseen circumstances where a large amount (greater
reaction which removes lead ions from solution during the than 1,000 kg [2,200 lb]) of hazardous waste is generated. An
TCLP test and deposits it on the elemental iron particles as example would be clean-up of soil from an accidental spill of
lead metal. This plating reaction will occur as long as elemental diesel fuel.
iron is present. But eventually the iron will rust and the plating The owner may delegate obtaining Site-Specific and
reaction will not occur. At that point the waste will test as being Provisional EPA ID numbers to the contractor.
hazardous. It is good practice to stabilize and dispose of waste
streams generated from blasting with ferrous abrasives as if it 6.2 DETERMINE TREATMENT AND DISPOSAL
was a hazardous waste irrespective of the results of the TCLP OPTIONS: The generator must select a procedure or facility
test. for treating and disposing of the waste. The choices are as
follows.

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• Ship the waste to a permitted treatment and disposal the generator, each transporter, the disposal facility, and the
facility (see Section 6.3). copy from the disposal facility to be returned to the generator
• Treat the waste on-site in accumulation containers to within 45 days of the date of shipment (40 CFR Part 262.42).
render it non-hazardous and then dispose of it as a
non-hazardous waste (see Section 6.4). 6.3.4.2 A large quantity generator who has not received a
• Reuse the waste as a raw material for another signed copy of the manifest from the disposal facility within 35
process (see Section 8.1.2), with proper approval. days of acceptance of the waste by the initial transporter must
• Reclaim the lead from the waste contact the transporter or owner of the designated facility and
In the vast majority of cases, the generator does not have the initial transporter to determine the status of the hazardous
the resources, knowledge, or inclination to treat waste on-site waste.
and will use an outside service. Procedures for off-site disposal
are given in Section 6.3. Procedures for on-site treatment are 6.3.4.3 A large quantity generator must submit an
given in Section 6.4. Exception Report to the EPA Regional Administrator if the
signed copy of the manifest has not been received in 45 days.
6.3 OFF-SITE TREATMENT AND DISPOSAL: The The Exception Report must include:
waste can be shipped to a disposal facility or waste broker • A legible copy of the manifest for which the generator
for treatment and disposal. The generator must identify the does not have confirmation of delivery.
hazardous material present in the waste so the facility can • A cover letter signed by the generator or authorized
treat it prior to disposal. Once treated to meet the regulatory representative explaining the efforts taken to locate
requirements, the material can be disposed of in a Subtitle C the hazardous waste and results of these efforts.
or D landfill. Specific procedures are as follows.
6.3.4.4 Small quantity generators have 60 days from the
6.3.1 Select Treatment and Disposal Facility: There are time the waste was accepted by the transporter to receive
numerous hazardous waste treatment facilities available in the the copy of the manifest signed by the disposal facility’s
United States. The state or regional EPA office can provide representative. If no confirmation of delivery has been received
assistance in identifying these. The generator must inform in 75 days, the generator must then submit to state or regional
the treatment facility of the quantity and hazardous nature of US EPA authorities a legible copy of the manifest with some
the waste, so the facility can treat it prior to disposal. It is the indication that the generator has not received confirmation of
generator’s responsibility to assure that the disposal facility is delivery.
permitted and reputable.
6.3.5 Biennial Report: A generator who ships any
6.3.2 Select Hazardous Waste Hauler: Hauling of hazardous waste off-site to a treatment, storage, or disposal
the waste from the temporary storage site to the treatment, facility must submit a Biennial Report to the U.S. EPA Regional
storage, or disposal (TSD) facility must be performed by a Administrator by March 1 of each even numbered year (40
licensed transporter having an EPA identification number. A list CFR 262.41 Biennial Report). Many states require this report
of licensed hazardous waste haulers can be obtained from the be submitted yearly rather than every two years. It must be
appropriate state agency (Appendix B). submitted on EPA Form 8700-13A, and must include:
• The EPA identification number, name, and address of
6.3.3 Prepare Manifest: The generator of the waste must the generator.
prepare a manifest (40 CFR Part 262.20). Effective September • The calendar year covered by the report.
1, 2006, EPA no longer supplies copies of these forms. They • The EPA identification number, name, and address
must be obtained from EPA-registered printers. Information for each off-site treatment, storage, or disposal facility
on obtaining these forms can be found at http://www.epa.gov/ to which waste was shipped.
epaoswer/hazwaste/gener/manifest/registry/printers.htm • The name and EPA identification number of each
transporter used for shipping to a treatment, storage,
6.3.4 Ship Waste and Retain Manifest or disposal facility.
• A description, EPA hazardous waste number, DOT
6.3.4.1 After the form has been completed, the generator hazard class, and quantity of each hazardous waste
must sign the manifest certification and obtain the signature of shipped off-site.
the initial transporter and date of acceptance. The generator • A description of the efforts undertaken during the year
keeps one copy, which must be retained for three years. If to reduce the volume and toxicity of waste generated.
a signed copy is received from the designated facility that • A description of the changes in volume and toxicity of
received the waste, this copy must be retained as a record for waste actually achieved during the year in comparison
at least three years from the date the waste was accepted by to previous years, to the extent such information is
the initial transporter. (Records should be retained indefinitely.) available.
The remaining copies of the manifest are given to the • The signature of the generator or authorized
transporter. There must be enough copies of the manifest for representative.

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6.3.6 State Regulations: Some states waste regulations is a non-hazardous waste, it can be disposed of as in Section 7.
are more stringent so they may differ from those outlined here. If it is still hazardous, it may be retreated as above or disposed
Generators and co-generators are cautioned to check with of off-site as described in Section 6.3.
local agencies before proceeding to make sure that additional
requirements can be met if any exist. 6.5 BENEFICIAL REUSE AND RECYCLING

6.4 ON-SITE TREATMENT AND DISPOSAL 6.5.1 Beneficial Reuse: The waste may have use
as a raw material for other products. This is usually based on
6.4.1 General Requirements: Generators can treat the chemical composition of the abrasive, i.e., iron, silicon, or
the waste on-site in 90-day holding containers or tanks, if aluminum content. The people who take the waste should be
approved by the state or regional EPA office. A waste analysis informed that there is lead (and other toxic metals, if present)
plan (Section 6.4.3) must be submitted prior to treatment. The in the waste.
waste must be treated within the 90-day holding period (or
longer) allowed for waste accumulation. Waste must be treated 6.5.2 Recycling: Recycling consists of sending the waste
to leach no more than 0.75 mg/L of lead. Once the waste has to a secondary smelter to reclaim the lead as lead metal.
been treated and is determined to meet treatment standards, it The lead metal then becomes a raw material making other
can be disposed of at a Subtitle C or Subtitle D landfill. products, the most common one being lead acid batteries.
The secondary smelter will determine whether or not they
6.4.2 Treatments for Lead: A number of treatment will accept the debris based on its chemical composition, as
methods have been used on lead-containing debris that have there are some metals that destroy their kiln process. Abrasive
resulted in the treated waste meeting treatment standards. blasting debris using sand or slag abrasives is not acceptable
These processes are typically based on mixing the waste with for the secondary lead smelting process.
portland cement, lime, lime-fly ash, or silicates. Proprietary
commercial treatments are available. Lead in sufficiently high 6.5.3 Advantages of Reuse and Recycling: The
concentration can be recovered in a lead blast furnace and advantage of beneficial reuse and recycling is in meeting one
reused in lead batteries or other reprocessing. Lead may also of the goals of the RCRA regulation to minimize the amount
be incinerated. Appendix C presents information on treatment of hazardous waste generated. It also eliminates long-term
methods. liability to the generator once the material has been reused or
recycled, as there no longer is any hazardous waste.
6.4.3 Waste Analysis Plan: On-site treatment requires
filing a waste analysis plan with the regional EPA office or the 7. Procedures for Disposing of Non-
state within 30 days prior to treatment by some mechanism
Hazardous Waste
that can verify delivery, i.e., return receipt requested, or by
Federal Express or other messenger.
7.1 NON-HAZARDOUS WASTE: Waste that has a
The waste analysis plan (40 CFR Part 264.13, General
leachable lead content of less than 5 mg/L as tested in Section
Waste Analysis) must include:
5.7 can be disposed of at a Subtitle D (non-hazardous) landfill.
• The parameters for which each hazardous waste will
The waste may not be subject to the requirements of RCRA,
be analyzed and the rationale for these parameters.
but may be regulated by state and local waste regulations (see
• The test methods that will be used to test for these
Section 7.3).
parameters.
• The sampling method that will be used to obtain a
7.2 TREATED WASTE: Waste that has been treated on
representative sample to be analyzed.
site and determined to be non-hazardous after treatment may
• The frequency with which the initial analysis of the
be disposed of at a Subtitle D (non-hazardous) landfill. The
waste will be reviewed or repeated to ensure that the
generator must submit a tracking document to the regional
analysis is accurate and up to date.
EPA office or authorized state office. The tracking document
The generator is not required to obtain approval of the must include:
waste analysis plan prior to starting the on-site treatment, but • Complete and accurate description of the waste,
the EPA can reject the plan at any time. including its former hazardous waste classification.
6.4.4 Treat and Test Waste • The identity and location of the Subtitle D facility
where the waste has been sent.
6.4.4.1 The hazardous waste is then treated in accordance • Available waste analysis data.
with the procedures selected in Section 6.4.2 and sampled in The tracking document is not sent to the disposal facility.
accordance with the plan in Section 6.4.3. Some states regulate non-hazardous, lead-containing wastes
as a special, industrial, or residual waste. Only certain landfills
6.4.4.2 The treated waste must be retested as described may accept the waste. State hazardous waste offices should
in Section 5.7 and reclassified as described in Section 5.8. If it be contacted to determine if and how the waste is regulated
(see Appendix B).

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7.3 STATE AND LOCAL RESTRICTIONS: A number of and testing of similar materials, the waste may be declared
states have special requirements for handling and disposing hazardous without any testing.
of waste containing less than 5 mg/L leachable lead or other
materials which are not defined as hazardous by the EPA. The 8.3 TIME LIMITS FOR STORAGE OF WASTE ON-
generator must consult the state or local environmental agency SITE: Once a material has been declared a hazardous waste,
to determine if such rules are applicable. In addition, certain it must be treated or moved to a hazardous waste disposal
disposal or treatment facilities may have special requirements facility within the allowed time limit as presented in 40 CFR
for handling or labeling these “special” wastes. Thus, the Part 262.34 Accumulation Time. This limit may be 90, 180,
generator should not assume that because the waste has 270, or an unlimited number of days depending on the weight
less than 5 mg/L leachable lead it can be disposed of at any of the material that has been declared a hazardous waste
municipal or other non-hazardous landfill. and whether it must be shipped over 200 miles (322 km) as
presented in Section 5.5.1. For most surface preparation
8. Commentary operations, 90 days is the maximum time material hazardous
waste can remain in the temporary storage site. After material
The following supplementary notes provide additional has been declared to be a hazardous waste, holding it in a
guidance on the procedures described in Sections 4 through 7. storage area longer than the allowed time is illegal and makes
the storage site an un-permitted hazardous waste storage
8.1 HAZARDOUS WASTE DEFINITION AND facility.
CLASSIFICATION
8.4 STATE REGULATION OF HAZARDOUS WASTE:
8.1.1 There are a number of chemical elements where The regulations discussed are based on RCRA directives
land disposal is regulated. Some of these may be present in from the U.S. EPA. The state regulations must be at least as
protective coatings or abrasives. Because of the land disposal stringent as the Federal regulations. The states can establish
restriction portion of the Hazardous Solid Waste Amendments more stringent requirements (lower threshold levels) for
(HSWA), land disposal (i.e., burial in a landfill) of hazardous defining a toxic metal. States can also include other metals not
wastes is no longer permitted in the United States. The included on the EPA list.
EPA has several criteria for determining whether a waste is
hazardous. Certain wastes, known as “listed wastes,” are 8.5 Additional Information: Additional sources of
automatically established to be hazardous. Waste is also information are provided in Appendix B.
designated as hazardous if it possesses any of the following
four characteristics: ignitability, corrosivity, reactivity, or toxicity. 9. Disclaimer
The major concern for lead and other heavy metals is toxicity.
9.1 This guide was developed by SSPC: The Society for
8.1.2 It is important to remember that a material is not Protective Coatings. While every precaution is taken to ensure
hazardous waste until it has been so declared. Even if the that all information furnished in SSPC guides, standards, and
samples that have been tested are reported to contain 5 mg/L specifications is as accurate, complete, and useful as possible,
leachable lead or higher, the material does not automatically SSPC cannot assume responsibility nor incur any obligation
become a hazardous waste. It may have utility as a raw resulting from the use of any materials or methods specified
material for another use, or it may be possible to have the lead therein, or of the guide itself.
reclaimed by a secondary smelter. However, it does become
a hazardous material. If the lead-containing debris is being 9.2 This guide does not attempt to address problems
held for use as a raw material for some other process, it must concerning safety associated with its use. The user of this
be shipped from the site within 90 days. Such accumulation guide, as well as the user of all products or practices described
must be approved by the regulating state prior to actual herein, is responsible for instituting appropriate health
accumulation. and safety practices and for ensuring compliance with all
governmental regulations.
8.2 GENERAL PROCEDURE FOR HAZARDOUS
WASTE DETERMINATION: The generator of a solid waste is Appendix A. Determining Confidence
responsible for determining if a waste is hazardous. It must
Interval for Hazardous Waste Analysis
be determined whether the waste is excluded from regulation
under RCRA. It must be determined whether the waste is
The confidence interval is the safety factor required by
listed as a hazardous waste. If the waste is not listed, it must
EPA for determining that a waste is non-hazardous. Thus, the
be determined whether the waste is hazardous by testing
average value of the lead concentration plus the confidence
for toxicity or other characteristics, or by knowledge of the
interval (C.I.) must be less than 5 mg/L. First, the number
hazardous characteristics. If the generator has sufficient
of samples needed must be determined as shown on the
knowledge of the waste characteristics based on prior sampling
following page:

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1. Analyze four or more samples and determine the 4. Calculate the leachable lead content as follows:
Standard Deviations.
Leachable lead = x + C.I.

5. The result is then compared to the Regulatory Threshold

limit to determine whether the samples tested represent a
non-hazardous waste. Examples of calculations are given the
Where xi = value of each test result Journal of Protective Coatings and Linings, Vol. 7, No. 4, pp.
x = average of the four samples 36-45 (1990).
n = number of samples collected
Note: The number of degrees of freedom (df) is equal to n-1
2. Calculate the appropriate number of samples (N) by the where “n” is the number of samples collected from a solid waste.
following equation: Tabulated “t” values are for a two-tailed confidence interval and
probability of 0.20. (The same values are applicable to a one-
tailed confidence interval and probability of 0.10.)

Appendix B. Additional Sources of

Information
Where t= Student’s “t” for 20 percent probability
(Table 2) 1. State Hazardous Waste Regulations:
RT = Regulatory Threshold (i.e., Toxicity Level, For information on state hazardous waste regulation,
Table 1) see: <http://www.epa.gov/epawaste/wyl/stateprograms.
N (a) = number of samples required htm>
2. Internet and Hotline Information:
3. Once the number of samples is known and the • RCRA/Superfund Hotline 1-800-424-9346 (in
proper number of samples has been analyzed, compute the Washington DC 703-412-9810)
confidence interval (C.I.). • EPA Small Business Ombudsman Hotline
<http://www.epa.gov/sbo> or 1-800-368-5888
C.I. = tSx • National Response Center at 1-800-424-8802.
(in Washington DC 202-267-2675) <http://www2.epa.
Where gov/emergency-response/national-response-center>
S
S=x
n
• Transportation of Hazardous Materials
<http://www.epa.gov/waste/hazard/transportation/
index.htm>
• Toxic Substance Control Act (TSCA) Assistance Service
TABLE 2 <http://www2.epa.gov/compliance/resources-and-
TABULATED VALUES OF STUDENT’S “t” guidance-documents-compliance-assistance>

n t n t 3. EPA Documents:
1 3.078 18 1.330 • EPA/530-SW-86-019, September 1986,
2 1.886 19 1.328 Understanding the Small Quantity Generator,
3 1.638 20 1.325 Hazardous Waste Generator
4 1.533 21 1.323 • EPA/530-SW-037, November 1986, Solving the
5 1.476 22 1.321 Hazardous Waste Problem - EPA’s RCRA Program
6 1.440 23 1.320
4. Journal of Protective Coatings and Linings available
7 1.415 24 1.318
from Technology Publishing Co., 2300 Wharton St., Suite 310,
8 1.397 25 1.316
Pittsburgh, PA 15203 (800-837-8303).
9 1.393 26 1.315
10 1.372 27 1.314 5. Other Publications
11 1.363 28 1.313
12 1.356 29 1.311 “Bridge Paint Removal, Containment, & Disposal,”
13 1.350 30 1.310 Synthesis Report 20-05/20-09, 1992. Transportation
14 1.345 40 1.303 Research Board, 2101 Constitution Ave., Washington,
15 1.341 60 1.296 DC 20418
16 1.337 120 1.282 “Removal of Lead-Based Bridge Paints,” NCHRP Report
17 1.333 265, December 1983, Transportation Research
Board.

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Industrial Lead Paint Removal Handbook, 2nd Edition is questionable, further stabilization must be performed as
SSPC 93-02, July 1993. described below in Section C.4 of this Appendix to minimize
Chapter 9.2 “Waste Handling and Disposal,” Good liability exposure under the Comprehensive Environmental
Painting Practice, Volume 1 of SSPC Painting Response, Compensation, and Liability Act (CERCLA).
Manual, 4th Edition, 2002.
“EPA Changes Treatment Standard for Lead Wastes; C.2.4 A proprietary cementitious additive has a
Bans Iron Filings as a Permanent Treatment recommended addition rate of 15-18 percent by weight.
Method,” Journal of Protective Coatings and Linings, Leachable lead concentrations of debris incorporating this
September 1998, pp. 97-98. additive at the recommended amount are about 0.1 mg/L.
The stabilization method as identified by the manufacturer is
APPENDIX C. STABILIZATION METHODS pH control and encapsulation. In one experiment, abrasive
blasting debris stabilized with this material when tested by EPA
C.1 The methods to stabilize lead in abrasive blasting Test Method 1320 has shown no increase in leachable lead
debris include pre-treatments, in-process treatments, and concentration for10 leaching cycles.6
post-treatments. Pre-treatment consists of the use of abrasive
additives or special paints. C.2.5 Proprietary paints containing metal-stabilizing
These materials are added to the blasting abrasive pigments are applied to the surface at a thickness
before the waste is generated or applied to the surface prior recommended by the manufacturer. The paint is allowed
to blast cleaning. The pretreatments, when added or applied to dry for several hours before blast cleaning the surface.
in the proper amount, result in a waste classified as non- Stabilization is achieved by incorporating materials such as
hazardous when tested by the TCLP procedure. They can Portland cement in the paint formulation. In several cases,
then be handled as a non-hazardous, lead-containing waste. abrasive blasting debris stabilized with these materials has
In-process treatments are methods of treating airborne dusts met the non-hazardous waste standard for lead (i.e., leachable
such as the fines collected by a dust collector attached to a level less than 5.0 mg/L).7
containment or an abrasive recycling system. Post-treatments
are methods of stabilizing lead-containing debris after the C.2.6 Further stabilization of pre-treated waste can be
waste has been generated. The requirements presented in performed with a post-treatment method as described in
Section 6.4 describe the procedures that must be followed if Section C.4 of this Appendix. The requirements in Section
on-site stabilization of a hazardous waste is performed. 6.4 do not apply as long as the waste is classified as non-
hazardous.
C.2 PRE-TREATMENTS
C.3 IN-PROCESS TREATMENTS
C.2.1 The pretreatments with the greatest field history are
steel grit, a proprietary cementitious material, and specially C.3.1 Although state regulations may vary, the US EPA
formulated paints. generally does not consider airborne dusts to be wastes until
they are collected, as long as these dusts remain in a closed
C.2.2 Addition of 3-6 percent by weight of G-80 steel structure (dust collector). Addition of treatment chemicals in an
grit to expendable abrasives has resulted in leachable acceptable manner before collection has been allowed as a
lead concentrations below 5 mg/L. The exact percentage is process change or as a totally enclosed treatment (TET) by US
dependent on the leachable lead concentration of the waste EPA and a number of states.
without the additive, and source of the steel grit. The exact
percentage can be determined by laboratory tests. The C.3.2 Proprietary admixtures and injection equipment
alternative is to add 10% percent steel grit by weight, as this have been developed and used to generate non-hazardous
amount has been shown to be sufficient, resulting in leachable waste for the fines collected in dust collectors. The process
lead concentrations usually less than 1 mg/L. (See C.2.3 consists of injection of a powdered admixture into the air
below.) stream containing the dust. The admixture chemistry and
amount to be added varies and the supplier must be contacted
C.2.3 Stabilization of lead with steel grit results from an to determine the proper material and addition rate.
oxidation-reduction reaction. Lead ions plate out on the steel C.3.3 Although these wastes may pass the TCLP test, it
particles during the TCLP. Abrasive blasting debris stabilized is sometimes desirable to further stabilize the waste with post-
with iron has been tested using EPA Test Method 1320, treatment methods described in Section C.4 of this Appendix.
Multiple Extraction Procedure. Leachable lead concentration The requirements of Section 6.4 of the Guide do not apply as
increases measurably after each extraction. In the final long as the waste is classified as non-hazardous.
extraction, the level has exceeded 5 mg/L. For this reason, the
EPA has declared that this is not a recommended procedure 6
Lead-Containing Paint Removal, Containment, and Disposal, (McLean, VA:
to stabilize lead containing waste.5 Because long-term stability U.S. Dept. of Transportation, Federal Highway Administration) Publication No.
FHWA-RD-94-100.
5
EPA Changes Treatment Standard for Lead Wastes; Bans Iron Filings as a 7
Christopher A. Rehmann, “New Process for Stabilizing Lead-Based Paint,” in
Permanent Treatment Method,” Journal of Protective Coatings and Linings, Expanding Coatings Knowledge Worldwide: Proceedings of the SSPC 1997
September 1998, pp. 97-98. Seminars, SSPC Publication 97-09, (Pittsburgh, PA: SSPC, 1997) November
16-20, 1997 San Diego CA, pp. 127-132.
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C.4 POST-TREATMENTS

C.4.1 Common post-treatment methods include use of

lime or Portland cement.

C.4.2 Lime stabilizes lead-containing debris by pH control.

Addition of lime has been shown effective in several instances
at a level of about 10-15 percent by weight.6 Lead compounds
are amphoteric, meaning they are soluble in acidic and
alkaline solutions. Adding too much lime will raise the pH, and
may result in a leachable lead concentration above 5 mg/L.
Laboratory testing is needed to determine the proper amount
of lime to add for a specific waste stream. No tests of long-term
stability (EPA Method 1320) are known.

C.4.3 Stabilizing lead with Portland cement can be

performed either as a dry addition, or with water to make
concrete. Adding Portland cement at a level of 10 percent by
weight or higher typically results in very low leachable lead
concentrations, usually 0.05-0.10 mg/L. Concretes can be
made using a water/cement ratio of 0.5. A representative
mixture design to form blocks is 300 pounds (140 kg) of debris,
94 pounds (43 kg) (one sack) of cement, and 7.5 gallons (28 L)
of water. Wastes stabilized in this manner have been evaluated
for long term stability by EPA Method 1320 and show no
increase in leachable lead concentration for 10 cycles.

C.4.4 Fine-grained wastes such as dust from dust collectors

or the fines from steel recycling units have been successfully
stabilized with Portland cement. However, more water must
be added to the mixture for these wastes. The mixture design
in Section C.4.3 is not appropriate for fines. Laboratory tests
must be performed to determine an adequate amount of water.
Fines from dust collectors may be classified as a hazardous
waste unless in-process treatment was performed.

COPYRIGHT ©
SSPC standards, guides, and technical reports are copyrighted
world-wide by SSPC: The Society for Protective Coatings. Any
photocopying, re-selling, or redistribution of these standards,
guides, and technical reports by printed, electronic, or any
other means is strictly prohibited without the express written
consent of SSPC: The Society of Protective Coatings and a
formal licensing agreement.

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