UFC 1-900-01
1 DECEMBER 2002
or recycled.
Whole Building Demolition waste, as one commingled pile of rubble, is seldom regarded
as hazardous waste under the RCRA. Often, LBP in demolition debris is not found in
high enough concentrations to be hazardous waste and may be disposed of in a C&D
landfill among other options. Burning of wood LBP debris, however, may result in lead
releases since lead is a metal that is not destroyed through burning. The burning of
LBP debris should be discouraged due to potential liabilities associated with disposal of
the ash resulting from the burn. Before accepting LBP debris for burning activities, a
facility should ensure that there would be no violations of the Clean Air Act permit
conditions for burning buildings and that the facility will handle all ash in accordance
with Federal/State hazardous waste regulations.
During demolition, mitigation measures to reduce the dust clouds associated with
common demolition should be employed to decrease the exposure to lead. Exposure
occurs through the inhalation of lead dust or ingestion of deteriorated LBP. Fugitive
dust blown to neighboring property can contaminate soil and pass through open
windows to settle on exposed surfaces. Typical mitigation involves spraying with water
during demolition, watering down rubble pile, and spraying with water during loading
and handling. A HEPA vacuum may be used on-site for cleaning up small debris and
for vacuuming clothes and tools before exiting the site.
RECYCLE (Lead-Based Paint)
LBP debris may be recycled and reused in situations where there will be no human
contact. The recycling and reuse of LBP debris as mulch, ground cover, or topsoil may
cause health risks through ingestion of LBP, dust, or contaminated soil and should be
avoided. If the wood waste is going to be recycled and reprocessed for mulch,
composting or biomass fuel, painted or treated wood in general is highly undesirable.
RECOVER (LBP)
There are essentially three options available for the recovery and reuse of lumber that is
coated with LBP. Each of these options must be looked at very carefully. If the
building, intact, would be hazardous waste, then the performance of any of these three
treatments would require a RCRA permit prior to execution of the work. One option is to
remove the lead paint from the wood. All LBP removed from a substrate by virtually any
method will, almost without exception, be hazardous waste and will be subject to RCRA
disposal requirements. The second option is to encapsulate the LBP by painting over it,
thus eliminating the exposure pathway of the lead. However, in future demolition, the
LBP will be exposed again. The third option is to enclose and permanently seal lead
painted materials in place. This process has many applications such as covering lead-
painted drywall with new drywall, or reversing the painted surface of lumber to expose
the unpainted portion of the lumber. Again, this eliminates the pathway for human
contact, but would lead to re-exposure under future demolition of the structure. If LBP is
transferred to another party for any reason you must notify the recipient in writing of the
presence of LBP debris.
If the proposed USEPA regulation takes effect, items such as doors and windows that
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