The Environmental Protection Agency (EPA)
Disposing of LBP debris can be very
costly. The EPA estimates that LBP
debris tested and managed as hazardous waste can cost up to $316 per ton.
The EPA believes that the costs of LBP debris disposed as solid waste
will be significantly less—approximately one-tenth the cost of disposal as
hazardous waste. By allowing LBP
debris to be disposed of in a less-costly manner, the EPA hopes the new TSCA
standards will hasten the pace with which LBP and LBP hazards are removed from
residences and public and commercial buildings.
Under the proposed TSCA rule, generators
would no longer need to test LBP debris for lead. Instead, a generator may
dispose of the LBP debris in a C&D landfill or in one of the landfill
options listed in this article.
What Is LBP Debris?
LBP debris is any component, fixture, or
Materials that are not considered LBP
debris include paint chips and dust, leftover paint or paint thinners, sludge,
solvents, vacuum filter materials, wash water, sandblasting material, and
lead-contaminated soil. They remain subject to RCRA requirements.
However, you may be able to manage these materials as a solid waste, if:
The quantities of hazardous waste
(including non-LBP debris waste from LBP activities) you generate are less
than 100 KG (approximately one 55-gallon drum/container) per month.
You qualify as a conditionally exempt
small quantity generator of hazardous waste (including non-LBP debris waste
from LBP activities).
Who Is Affected By This Rule?
This rule covers persons and firms that
What Are Your Options For Disposal Of
Under the proposed TSCA standards, LBP
A C&D landfill;
A landfill receiving waste from
conditionally exempt small quantity generators (CESQG);
An approved hazardous waste disposal
A hazardous waste treatment, storage,
and disposal facility that has
qualified for interim
A Resource Conservation and Recovery
The proposal will not allow LBP debris to
be disposed of in a municipal solid waste landfill
What Management Requirements
The following describes the proposed
management requirements to reduce LBP exposures when disposing of LBP debris:
Generators disposing of concentrated LBP
wastes—such as sludge and paint chips—must comply with existing Federal RCRA
hazardous waste regulations as they are not eligible for disposal under the
proposed TSCA standards.
LBP debris may not be used as mulch, roadbed, or fill material.
LBP debris may not be reused if it contains deteriorated LBP. Once the
LBP is removed from the component, the component is no
Access Limitations And Storage
LBP debris may not be stored for more than
180 days after generation. Once you have generated LBP debris, you have 180 days
to dispose of it in a C&D landfill. After
3 days, LBP debris must be stored in a place with restricted access such as
6-foot dumpsters; covered drums or dumpsters; fenced areas that are locked; or
locked, unoccupied structures.
When LBP debris is transferred from one
person to another, the person transferring the LBP debris must notify the
recipient of the presence of LBP debris, the date it was generated, and the
address of the generator and refer the recipient to the manage-ment and disposal
standards for LBP debris. Both the recipient and the transferor must sign and
date this notification and keep a copy for 3 years.
Vehicles transporting LBP debris off-site
must be contained in a covered receptacle or a covered vehicle.