Lead-Based Paint Removal

Water Pollution Control

The primary route of lead into surface waters during paint removal is through falling paint particles, fine dust, and contaminated blasting material.  Indirect routes include erosion of soils containing lead from paint and discharge of effluents into surface waters that have had lead paint particles enter through tributary waste streams via cooling water or municipal or industrial wastewater.  Wastewater sludges that are land applied may also contribute lead to surface waters.  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 sewer or water drainage system.

Water Pollution Standards

Illinois Water Quality Standards are adopted by the Illinois Pollution Control Board and are codified as “Title 35, Subtitle C, Part 302 of the Illinois Administrative Code”. Section 302.203 and similar passages in 302.403 and 302.515 requires that all waters be free from “sludge or bottom deposits, floating debris....of other than natural origin”. The presence in lakes and streams of paint solids, blasting media and paint dust, whether or not lead is present, is prohibited.

Sections 302.208, 302.304, 302.407 and 302.504 set numeric lead water quality standards for various Illinois waters.  For most Illinois waters (General Use waters) lead water quality standards cover lead in the dissolved form through acute standards for short duration exposures and chronic standards for longer term exposures.  These numeric standards exist in formulas which require the local water hardness value to calculate the lead standard in terms of a mg/L concentration.  These standards contain a conversion factor to convert the standards to total lead (dissolved plus suspended) if only total measurements are available or if a limit is required in an NPDES permit, which may limit only the total form of metals.

NPDES permits may limit lead content of effluents if a reasonable potential (a statistical probability) exists for lead in the effluent to exceed a water quality standard.  If lead in an effluent had a probability to exceed the lead water quality standards, a water quality-based effluent limit based on the acute and chronic water quality standard, would be imposed.  There are no numeric standards prescribed for land application of wastewater sludge, i.e., biosolids, from wastewater treatment plants; however, the heavy metals content of sludge will directly affect the site utilization life of the agricultural field 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 (i.e., laboratory methods) 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 found in the Division of Water Pollution Control, Surface Water Section’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. 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 contact the Division of Water Pollution Control Standards Section at (217) 558-2012.  Questions on surface water and sediment sampling should be directed to the Surface Water Section at (217) 782-3362.  For information on permit requirements for wastewater disposal, contact the Permit Section at (217) 782-0610.