Minnesota Department of Transportation

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Building, Bridge Demolition and Relocation

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Disposal and recycling

Process

Disposing or reusing regulated materials by other methods may expose the department to additional legal liabilities. Contact the Office of Environmental Stewardship if other disposal/reuse methods are being considered. All waste materials must be disposed of or recycled by vendors selected from MnDOT Approved List of Waste Contractors (DOCX).

Asbestos containing materials

Examples and sampling requirements

Examples of materials that must be sampled during the assessment process because they commonly contain asbestos:

Acoustical Plaster Floor Backing
Adhesives Gaskets
Asphalt Floor Tile Heating & Electrical Ducts
Caulking & Putties Insulations (all types)
Ceiling Tiles & Panels Mastics
Cement Pipes Paints & Coatings
Cement Siding Pipes & Solder
Cement Wallboard Roofing Shingles & Felt
Chalkboards Sheetrock
Cooling Towers Sheetrock Joint Compounds
Curtains & Draperies Thermal Paper
Electrical Cloth Transite
Fire Doors Vermiculite
Fire Proof Materials Vinyl Floor Tile
Flashing & Roof Vents Vinyl Sheet Tile

Sampling frequency of suspected asbestos containing materials

Use the following guidelines when sampling homogeneous suspect asbestos containing material:

Surfacing Material (example: sprayed or troweled ceiling finishes) and Vermiculite
  • Less than 1000 Sq. Ft. - Minimum 3 samples
  • 1000 Sq. Ft. to 5000 Sq. Ft. - Minimum 5 samples
  • Over 5000 Sq. Ft. - Minimum 7 samples 
For Thermal System Insulation (TSI)
  • Minimum 3 samples
  • Patched Areas less than 6 Sq. Ft. or 6 Lineal Feet - Minimum 1 sample 
Miscellaneous Material
  • Minimum 1 sample

Types of asbestos containing materials

Four common types of asbestos containing materials (ACMs): 

  • Friable Asbestos - Materials with greater than 1% asbestos that when dry can be crumbled, pulverized or reduced to a powder under hand pressure.
  • Category I Non-Friable Asbestos - Typically packing material, gaskets, resilient floor covering and roofing products that contain greater than 1% asbestos and are in good condition.
  • Category II Non-Friable Asbestos - Any material with greater than 1% asbestos, excluding category I non-friable ACM, that when dry cannot be crumbled, pulverized, or reduced to powder by hand pressure.  Examples include: cementitious asbestos board, Transite ® siding, asbestos putties, asbestos sealants and adhesives.
  • Vermiculite Containing Asbestos - When vermiculite has been identified during assessment of the structure, the following guidelines will be observed during abatement/oversight:
    • If any of the analyses of the vermiculite containing material detect the presence of any amount of asbestos, all vermiculite containing material must be treated as RACM.
    • If all of the vermiculite analyses conducted during the assessment do not detect any asbestos, then all of the vermiculite containing material within the structure can be managed with the rest of the building as demolition debris.

Disposal Requirements

All asbestos waste shall be disposed of in a MnDOT approved landfill, scroll down to Landfills/Regulated Waste. Demolition debris landfills must not be used to dispose of any asbestos containing materials. 

Documentation Requirements

Copies of all shipping papers (also known as Asbestos Shipping Manifest) shall be furnished to the MnDOT Project Engineer within 10 days of the waste being shipped off the project site. If the contractor does not provide the shipping papers to the Project Engineer, the Project Engineer shall contact the contractor in an attempt to acquire them. If after 10 days the shipping papers signed by the owner/operator of the disposal site are not provided, the Project Engineer or oversight contractor shall notify the Office of Environmental Stewardship regarding the missing documentation, as they can assist in determining who to contact at the regulatory agencies.

Transportation Requirements

All friable asbestos over 1 pound in quantity must be handled as a hazardous material and transported with an Asbestos Shipping Manifest (furnished by the landfill). 

All ACM with asbestos content over 1% must be transported with:

  • An Asbestos Shipping Manifest if the material is friable or
  • U. S. DOT does not regulate non-friable asbestos as a hazardous material, so a hazardous material shipping paper is not required for asbestos contained in natural or artificial binding material. However, it is advisable to use a tracking document such as a bill of lading or invoice, in case it becomes necessary to produce disposal documentation. 

Packaging asbestos:

  • All asbestos packages greater than one pound must be dust and sift proof. Non-bulk bags or other non-rigid packaging must be placed in rigid, leak tight outer packaging (drums, boxes, closed truck bodies or freight containers) for transport. Non-bulk packages of asbestos must be marked “RQ, Asbestos, NA 2212”, and labeled with a Class 9 hazard label. Bulk packages (net mass exceeding 882 pounds) must be rigid, leak tight closed bulk bins or boxes.  Bulk containers must display the ID # 2212 on a Class 9 placard, or a white square on point device or an orange panel. 

Vehicle marking:

  • The transport vehicle must be marked on all four sides with the same ID number used on the packaging and displayed on a placard, white-square on point device, or orange panel. Bulk packages must be transported by a contractor registered with the Mn/DOT Office of Freight and Commercial Vehicle Operations as a hazardous material transporter. If a U.S. DOT placard is used to label the vehicle, the driver must have a commercial driver’s license with a hazardous material endorsement. 

All asbestos waste materials shall be transported directly from the project site to the MPCA permitted landfill. Temporary storage of asbestos waste materials shall not be allowed.

Chloroflorocarbons (CFC's)

Regulations associated with CFC equipment can vary depending on whether the equipment is attached to the structure being demolished or not. Therefore, management of CFC equipment also varies. 

Examples of Equipment Containing CFC’s

Equipment containing CFC’s includes but is not limited to the following: heat pumps, fire extinguishers, air conditioners, dehumidifiers, walk-in coolers, refrigerators, freezers and vending machines.

Disposal, Recycling and Documentation Requirements 

CFC Equipment Attached to the Structure
  • Examples of CFC equipment attached to the structure include heat pumps and central air conditioning units.
  • All CFC equipment must be removed from the structure prior to demolition or relocation of the structure. CFC’s must be removed from the equipment by a certified CFC contractor before removing the equipment from the structure, regardless of whether the equipment will be disposed of or reused. 
  • Copies of the completed Verification of Refrigerant Removal Form shall be furnished to the MnDOT Office of Environmental Stewardship within 10 days of completion of CFC removal.
  • The Minnesota Pollution Control Agency (MPCA) does not have to be notified of CFC removals.
  • Functional CFC equipment can be reused after the CFC’s have been removed. Ownership transfer of the CFC equipment must be documented with theCFC transfer of ownership form (PDF). Copies of the transfer form must be kept in the project file. 
CFC Equipment Unattached to the Structure
  • CFC’s do not need to be removed before removing the equipment from the structure.
  • Unattached CFC equipment can be disposed of at a MPCA permitted mixed municipal solid waste landfill as white goods. The landfill must be notified of the intent to dispose of CFC equipment so that they can properly remove the CFC’s.
  • Tipping receipts issued by the landfill for CFC equipment disposal must be provided to the project engineer.
  • Functional, unattached CFC equipment can be reused without removal of the CFC’s. Ownership transfer of the CFC equipment must be documented with the CFC transfer of ownership form (PDF). Copies of the transfer form must be kept in the project file. 
Transportation Requirements

There are no transportation requirements for attached or unattached CFC equipment.

Polychloronatedbiphenols (PCB's)

Examples of Equipment Containing PCB’s

  • Equipment containing PCB’s includes but is not limited to the following: transformers, transistors, capacitors and lighting ballasts.
  • In caulk in structures built prior to 1978. 

Disposal and Recycling Requirements

  • All electrical equipment and caulk identified in the structure as containing PCB’s or on the property must be removed prior to demolition.
  • All PCB-containing items shall be recycled or disposed of by MnDOT Approved List of Waste Contractors (DOCX). 

Documentation Requirements

  • Removal contractor must document the PCB-containing items removed on a shipping paper or hazardous waste manifest.
  • Copies of the completed shipping paper/manifest and the recyclers waste acceptance form shall be furnished to the project engineer within 10 days of completion of the removal and kept in the project file. 

Transportation Requirements

  • The PCB-containing waste must by accompanied by a hazardous waste manifest or shipping paper with proper shipping description; POLYCHLORINATED BIPHENYLS, liquid, 9, UN2315, PG III.
  • Packages for PCB-containing items that weigh one pound or greater must be packaged in compliance with U.S. DOT regulations. The containers can be a U.S. DOT authorized 5 gallon bucket with a lid or a UN 1A2 metal drum or 1H2 plastic drum. Label container using a Class 9 label according to the following example: Waste PCB Ballast for Recycling, POLYCHLORINATED BIPHENYLS, liquid, 9, UN2315, PG III.
  • No other waste materials may be placed in the same container with PCB containing materials. For example, HID bulbs (mercury containing) cannot be placed in the same container with ballasts or capacitors (PCB containing).

Mercury

Examples of Equipment Containing Mercury

Equipment containing mercury includes but is not limited to the following: electrical switches (including silent switches), thermostats, gauges, batteries (may be within smoke detectors and emergency lighting), exit signs security systems, alarm systems, thermometers, barometers manometers, relays, thermocouples and the following types of lighting: fluorescent, mercury vapor, metal halide, high-pressure sodium, neon and HID (high-intensity discharge). 

Disposal and Recycling Requirements

Mercury-containing products are regulated. All of these items identified in the structure or on the property must be handled and disposed of properly. Because many of the items containing mercury are fragile, the following storage and transport procedures must be followed to ensure proper handling:

  • Store used fluorescent tubes and high-intensity discharge lamps in the original box or a box of similar size. To prevent breakage, box spacers may be needed.
  • Store other mercury-containing items in a sturdy cardboard box or plastic pail.
  • Keep box/container in a designated storage location.
  • Do not tape tubes together.
  • Do not break or crush tubes.
  • Place a hazardous waste label on the container. In addition, write “Used Fluorescent Tubes”, “Used High-Intensity Discharge Lamps”, “Thermometers for Recycling”, or “Switches for Recycling” etc. on the container.
  • If mercury-containing products break, store the broken pieces in a sealed container (5 gallon plastic pail). Place a hazardous waste label on the sealed container. Label the container with a clear description of the waste such as, “Broken Thermometers” or Broken Fluorescent Tubes. 

All mercury-containing items shall be recycled.  All removal and recycling shall be performed by MnDOT Approved List of Waste Contractors (DOCX). 

Documentation Requirements

  • Removal contractor must document the mercury-containing items removed on a shipping paper (PDF).
  • Copies of the completed Shipping paper and the recyclers waste acceptance form will be furnished to the project engineer within 10 days of completion of the removal and kept in the project file. 

Transportation Requirements

  • The waste must by accompanied by a shipping paper (PDF) or the transporter must be issued a receipt by the facility accepting the waste material. There are more regulations when transporting over one pound of mercury, contact the Office of Environmental Stewardship if this amount is exceeded.

Lead

Examples of Lead Sources

Sources of lead include but are not limited to the following: 

  • batteries
  • roof flashing and molding
  • piping
  • bridge bearing plates
  • bridge 1 beam paint 

Disposal and Recycling Requirements 

Lead paint chips must be disposed of as a hazardous waste through the MnDOT Approved List of Waste Contractors (DOCX). Lead bearing plates, lead pipes, and any lead bearing materials other than paint chips shall be recycled by a lead scrap recycler. 

Beneficial reuse

Any materials with intact lead based paint (no peeling paint), such as steel beams, may be sold or released for reuse. Ownership transfer of materials with lead-based paint must be documented with a transfer of ownership form (PDF). Copies of the transfer form must be kept in the project file. 

Other materials made out of lead, for example bridge bearing plates, may be sold for reuse. Ownership transfer of the materials must be document with thetransfer of ownership (PDF) form. Copies of the transfer form must be kept in the project file. 

Documentation Requirements

Encapsulated Peeling Lead Paint
  • For materials with peeling lead paint that has been encapsulated, the oversight contractor must provide certification to the project engineer.  
Lead Paint Chips
  • Lead paint chips are hazardous waste and must have an EPA ID number and be transported off site by MnDOT's approved hazardous waste vendor using a hazardous waste manifest. For assistance, contact Mark Vogel or Jackie Klein with MnDOT Office of Environmental Stewardship. 
Other Lead Bearing Materials
  • Receipt from lead scrap recycler that indicates:
    • where the material was generated
    • who received the material for recycling
    • date the material was received for recycling
    • a description of the material
    • quantity of material

Transportation Requirements

Leaded Paint Chips
  • Paint chips are hazardous waste and so must be transported by the MnDOT Approved List of Waste Contractors (DOCX). The hazardous waste contractor will furnish the required hazardous waste manifest. The transport containers must be a UN 1A2 metal drum or a 1H2 plastic drum. 
Other Lead Bearing Materials
  • There are no transportation requirements for piping, bearing plates or other lead bearing materials.

Treated Wood

Examples of Treated Wood

Sources of treated wood include but are not limited to the following: creosote, pentachlorophenol. CCA (chromated copper arsenate or green treat), ACQ (alkaline copper quat), CA (copper azole), copper naphthanate, disodium octaborate tetrahydrate. 

Disposal and Recycling Requirements

Landfill
  • Treated wood can be disposed of in MPCA permitted mixed municipal solid waste landfills and some industrial landfills. However, some of these landfills have a more stringent acceptance policy and may not accept at least some types of treated wood. 
Incineration
  • Only creosote treated wood may be chipped and incinerated for disposal. In general, chipping is only cost effective for large volumes of wood, such as an amount produced by dismantling a railroad yard or a building. Only a MnDOT Approved List of Waste Contractors (DOCX) may be used to dispose of creosote treated wood. 
Beneficial reuse
  • Any treated wood that is in a condition where it is reusable in its original form or in a secondary application such as fence posts or landscaping material. However, treated wood cannot be chipped and used as mulch or as wood chips on landscaping projects.
  • Ownership transfer of treated wood must be documented with a treated wood transfer of ownership form (PDF). Copies of the transfer form must be kept in the project file. 
Documentation Requirements

Project files must include manifests, scale tickets or transfer of ownership forms to document disposal or reuse of treated wood. 

Transportation Requirements

There are no transportation requirements for treated wood materials.

Hazardous or Household Hazardous Wastes (HHW)

Examples of HHW

Examples of HHW include but are not limited to the following: oil, paint, solvent, fertilizer and pesticide that are present on residential properties. Waste materials on commercial properties cannot be managed as HHW. 

Disposal, Recycling and Documentation Requirements

HHW can be disposed of by private property owners for no charge through their county HHW waste program. To accomplish this task, MnDOT should provide the home owner with the following information:

It is highly encouraged that MnDOT does everything possible to have private property owners remove and dispose of all household hazardous wastes prior to taking possession. All HHW identified in the assessment/inspection report must be removed from the house prior to demolition. Any remaining household hazardous waste after the state takes possession must be disposed of using one of the following two methods:

  • MnDOT can request the county to accept the waste if it is delivered to their HHW collection site. The county has the option to accept or refuse the waste. If they accept the waste materials, MnDOT must obtain a receipt from the county detailing the amounts and types of waste brought to the county facility. This option is only available for private household hazardous waste. The program is not intended to handle other hazardous wastes, such as those present in equipment attached to the structure. See county contact information related to HHW collection.
  • For HHW not accepted by the county HHW facility or hazardous wastes generated from commercial operations, MnDOT can dispose of these materials through the state hazardous waste contract. A hazardous waste manifest and land disposal restriction form will be furnished by the hazardous waste contractor. If this option becomes necessary contact Mark Vogel for assistance. 

Transportation Requirements

  • The MnDOT Approved List of Waste Contractors (DOCX) can transport HHW wastes to a County HHW facility, provided the county will accept the waste. If the county does not accept the waste, the MnDOT approved hazardous waste contractor must remove the waste off site and make other arrangements for proper disposal. 

Packaging Requirements

Note: For the following section, the term “container” refers to the vessel holding the hazardous waste, which may be the original product package or other vessel. It does not refer to the U.S. DOT approved shipping container.

  • Lab Packing Small Volume Containers 

Any plastic or metal container with a volume less than 5.3 gallons or any size glass container must be lab packed and meet the following criteria:

  • The containers must be placed in a UN 1A2 metal drum or 1H2 plastic drum;
  • Only like materials in the same U.S. DOT classification can be placed in the same drum - no mixing of materials with different classification;
  • The inner containers must be surrounded by a chemically compatible sorbent material;
  • The gross weight of the lab pack cannot exceed 452 lbs.
  • Larger Volume Containers 

All containers with a volume equal to or greater than 5.3 gallons must be transported in a UN 1A2 metal drum or 1H2 plastic drum. If the container holding the hazardous waste is already contained in either a UN 1A2 metal drum or 1H2 plastic drum, the existing container may be used for transport as long as it is structurally sound. If the container is not structurally sound, it must be overpacked in a UN 1A2 metal drum or 1H2 plastic drum.

Solid Wastes

Examples of Solid Waste

Examples of solid waste include but are not limited to the following: “white goods” such as stoves, refrigerators and window air conditioners, furniture and garbage. 

Disposal, Recycling and Documentation Requirements

Solid waste must be taken to a MPCA permitted solid waste landfill for recycling or disposal. Documentation of proper disposal must be kept in project file. Acceptable documentation includes manifests and/or scale tickets. 

Transportation Requirements

There are no special transportation requirements for solid waste. Waste, container lids and tarps must all be properly secured prior to transport.