Information Statement On The Removal Of Lead-Based Paint
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Analysis And Disposal
Of Lead-Based Paint Waste
The requirements for the management of solid waste in Illinois are identified
by statutes in the Environmental Protection Act and regulations adopted thereunder
by the Illinois Pollution Control Board. The purpose of the statutory and regulatory
requirements identified above is to protect human health and the environment
by ensuring that wastes are handled in a safe and responsible manner in order
to prevent the contamination of air, water, soil and groundwater in Illinois.
For a copy of the statutes or regulations, please write to:
Illinois Environmental Protection Agency
Bureau of Land (#33)
P.O. Box 19276
Springfield, Illinois 62794-9276
or call (217) 524-3300
What is Residential LBP Waste?
Residential LBP waste is waste generated by a homeowner or contractor through
LBP removal activities from a household. Solid waste that is generated from
a household is exempt from being a hazardous waste under Section 721.104(b)(1).
Household is defined in Illinois' Resource Conservation and Recovery Act (RCRA)
regulations at 35 Ill. Adm. Code Section 721.104(b)(1) as: ". . .single and
multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters,
campgrounds, picnic grounds and day-use recreation areas. . ." Residential soil
contaminated with LBP also meets the definition of household LBP waste.
Handling and Disposal of Residential LBP Waste
LBP waste removed from a household by the homeowner or a contractor meets
the household waste exemption and may be disposed of as municipal waste. LBP
waste derived from a household must be sent to a landfill, incinerator or other
waste facility that is permitted by the Illinois EPA to accept municipal waste.
If LBP is removed from the original substrate to which it was adhered, precautions
must be taken to properly containerize the waste in order to prevent releases
to the air, land and water. If the contractor/generator collects the LBP waste
at ground level, an impermeable base or liner must be placed on the ground to
prevent soil contamination. During precipitation events, or if liquid wastes
are generated during removal activities, measures must be taken to ensure that
water contaminated with waste is contained and does not contaminate surrounding
soil and surface water. In addition, precautions must be taken to prevent releases
to the air which may result in soil and/or surface water contamination and exposure
of LBP removal worker(s) and the general public.
Non-Residential LBP Waste
If demolition/construction debris containing LBP still adhered to the substrate
is generated from a non-residential structure, the waste may be handled as general
refuse. However, if the LBP is removed from the original substrate to which
it was adhered, then the waste is a special waste. The waste must also be tested
to determine if it is a hazardous waste. The entire waste stream (e.g., paint
chips, blasting grit with paint chips, stripping agent with paint chips) must
be analyzed. LBP waste that meets the definition of special waste is hazardous
if it has a concentration of lead equal to or greater than 5.0 mg/l as determined
by the Toxicity Characteristic Leaching Procedure (TCLP). In addition, other
parameters must be below the regulatory limits for toxicity and other characteristics
and listings. The handling and disposal of hazardous waste in Illinois must
be conducted in accordance with the Resource Conservation and Recovery Act (RCRA)
regulations applicable to the activity being conducted.
If the generator/contractor determines that the LBP waste is hazardous, then
the waste must be treated prior to disposal in a facility that is permitted
by IEPA to accept that waste. The treatment technology that is used is stabilization.
The treatment of hazardous LBP waste must render the waste non-hazardous prior
to disposal at a properly permitted facility.
Hazardous LBP waste may not be stored on-site for greater than 90 days (or
180 days for a small-quantity generator; 270 days for a small-quantity generator
that transports his/her waste greater than 200 miles) without a RCRA permit.
If the special waste is determined to not be a hazardous waste, the waste may
be certified by the generator to be just solid waste provided it does not exhibit
certain characteristics. The generator of the special waste may certify the
waste if the waste passes the paint filter test (is not a liquid), does not
contain PCBs, is not a hazardous waste, is not regulated asbestos-containing
material, does not result from shredding recyclable metals, and is not former
hazardous waste rendered non-hazardous. Documentation of the certification must
be maintained by the generator and made available to the Agency or disposal
company upon request. If the special waste is certified, it may be handled as
general refuse and no manifest or additional recordkeeping requirements are
applicable. Questions concerning the certification of special waste should be
directed to the Bureau of Land's permit section at (217) 524-3300.
Transportation of LBP Waste
Anyone who hauls or transports any special waste within Illinois must have
a current, valid waste hauling permit issued by the IEPA. Note: Any person who
transports special waste only from generators who generate less than 100 kilograms
(220 pounds) of special waste in a calendar month is exempt from this requirement.
Manifest and Recordkeeping Requirements
Any person who delivers any special waste to a permitted special waste hauler
shall complete a manifest to accompany the special waste from delivery to destination.
In order to manifest special waste off site, the generator must obtain an IEPA
identification number (and a USEPA identification number if the waste is hazardous).
In addition, if the waste is a non-hazardous special waste and is sent out of
state, the generator must submit an Illinois Generator Non-Hazardous Solid Waste
Annual Report for Waste Shipped Out-of State to the IEPA. If the waste is a
hazardous waste and the generator exceeds 1000 kilograms in any month, the generator
must submit a hazardous waste annual report to the IEPA. Note: A person who
generates less than 100 kilograms (220 pounds) of special waste in every calendar
month in a calendar year is exempt from manifesting and reporting requirements.
Recycling of LBP-Contaminated Material
If a material contaminated with LBP is sent to a recycling, smelting or scrap
facility, the IEPA recommends that the generator:
- remove the LBP from the substrate and dispose of the LBP accordingly (special
and/or hazardous waste); or
- inform the reclamation facility of the presence of LBP on the material.
If you have questions regarding the disposal of LBP waste, please contact
Todd Marvel at (217) 524-5024 or the IEPA/Bureau of Land (BOL)/Field Operations
Section (FOS) regional office that serves your county.
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