Information Statement On The Removal Of Lead-Based Paint

Information Statement On The Removal Of Lead-Based Paint

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Water Pollution Control

The primary route of entry into surface waters during paint removal is through falling paint particles, fine dust, and contaminated blasting media. Other routes of entry include surface erosion of lead contaminated soils, airborne drift of fine dust, and contamination of other sources of discharge into surface waters such as cooling water streams or wastewater treatment plant effluents. Contamination of wastewater sludges must also be considered. Although sludge is not discharged into surface waters, soil contamination by lead can result when wastewater treatment plant sludge is applied to the land as a soil amendment. Suitable work site containment must be provided to prevent paint chips, dust, and blasting media from entering any waters of the State or falling/flushing into any type of drainage structure such as a sewer or drainage channel.

Water Pollution Standards

Illinois' Water Quality Standards were adopted by the Illinois Pollution Control Board and are codified as "Title 35, Subtitle C", Part 302 - Water Quality Standards, Subpart B - General Use Water Quality Standards. Section 302.203 requires that all surface waters be free from "unnatural sludge or bottom deposits, floating debris . . ." The presence in surface water of paint solids, blasting media, and dust containing lead may violate this rule.

Section 302.208 limits total lead in the water column to a numeric value based upon the hardness of the water body with the value never to exceed 0.1 mg/l for general use waters. Section 302.304 limits lead to 0.05 mg/l in surface waters designated for public water supplies. Point sources such as treated wastewater and cooling water which discharge to surface waters must have a National Pollutant Discharge Elimination System permit (NPDES). These permits contain specific limits for the various pollutants discharged. Effluent limits for lead are prescribed under Part 304 of the Illinois regulations - Effluent Standards. Section 304.124 limits lead to 0.20 mg/l.

There are no numerical standards prescribed for treated wastewater sludges; however, the heavy metals content of sludge will directly affect the site utilization life where sludge is applied as a soil amendment. Wastewater facility operators are cautioned to prevent lead paint residues from falling into wastewater treatment units.

Compliance

The analytical procedures that must be used to monitor for lead in effluents and in surface waters are listed in Title 40 of the Code of Federal Regulations, Part 136, Table 1 B. If a paint removal project has the potential to affect a body of water or a wastewater treatment plant, sampling may need to be conducted prior to, during, and after the removal work. Surface water and sediment sampling procedures should be in accordance with those utilized by the Agency. These procedures are outlined in the Illinois Environmental Protection Agency's Bureau of Water, Division of Water Pollution Control's Quality Assurance and Field Methods manual. In the case of a wastewater plant, the raw sludge quality may need to be determined and monitored during the course of the project. The Division of Water Pollution Control Planning Section can furnish specific instructions for taking representative water column and sediment samples. If impacts to either the water column or sediment are noted from sample results during the progress of the removal project, immediate steps should be taken to improve containment measures.

Disposal of Wastewater From Lead-Based Paint Removal Operations

A lead-based paint removal project may generate wastewater from cleaning painted surfaces, wet abrasive blasting, or decontamination of personnel or equipment. Regardless of the source, wastewater containing lead or paint solids must be collected, properly treated, and discharged to a permitted location in order to prevent water pollution.

Wastewater may either be collected into drums or other containers and transported to a permitted disposal facility, or discharged in an appropriate location at or near the project site. In either case, it will be beneficial to minimize the amount of wastewater generated. If the wastewater is collected and hauled to a treatment or disposal facility, the rules which apply to solid waste management (characterization, manifesting, etc.) must be followed. If it is possible to discharge the wastewater to an on-site sanitary sewer, the requirements of the city or sanitary district which owns the sewer must be followed. These rules may include numerical limits for lead or other parameters, and prohibitions or limits on the amount of solid material which can be discharged. As the requirements vary from city to city, the sewer owner must be contacted for each project. New connections to a sanitary sewer, or any treatment facilities which may be needed to meet the sewer owner's requirements (filtration, settling, etc.) may require a permit from the IEPA.

For Further Information

For further information on water quality standards and surface water and sediment sampling, contact the Bureau of Water, Division of Water Pollution Control Planning Section at (217) 782-3362. For further information on permit requirements for wastewater disposal, contact the Bureau of Water, Division of Water Pollution Control Permit Section at (217) 782-0610.

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