Q. Is it required to have a separate contained wastewater wash station when working with lead paint removal? Does the waste have to be disposed of properly?

A. EPA regulations for lead-based paint activities under 40 CFR 745.85 require various work practices be followed when performing lead paint removal during certain residential property renovations. One of these required work practices is to thoroughly mop uncarpeted floors after a renovation has been completed. A mopping method must be used that keeps the wash water separate from the rinse water, such as the 2-bucket mopping method, or using a wet mopping system.

40 CFR 745.85 also requires certain work practices be followed when dealing with the lead-contaminated waste generated from lead paint removal activities:

• Waste from renovation activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. If a chute is used to remove waste from the work area, it must be covered.
• At the end of each workday and each renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents the release of dust and debris from the work area and prevents access to dust and debris.
• When waste is transported away from the area in which renovation activities occurred, the waste must be contained to prevent the release of dust and debris.

In addition, any waste generated from lead paint removal activities needs to be separated so that it can be properly characterized, labeled, stored, and disposed of in accordance with applicable waste regulations. First, the wash water needs to be characterized to determine if it is a hazardous waste. If so, then it needs to be managed in accordance with your state’s hazardous waste management regulations.. Lead is considered a substance that has the hazardous characteristic of toxicity. A waste that contains lead in a quantity at or above the applicable threshold, which is 5.0 milligrams per liter (mg/L), is considered a toxic hazardous waste. A representative sample of the contaminated wash water can be tested using the Toxicity Characteristic Leaching Procedure, more commonly known as the TCLP test, as described under 40 CFR 261.24.