MnDOT Districts 1, 2, 3, 4 & Metro North and East
MnDOT Districts 6, 7, 8 & Metro South and West
Paint removal operations process - contractors
Lead content determination
Legal definitions of lead, non-lead and PCB paint
- Lead paint is defined as paint that has a lead concentration equal to or greater than 0.5% (5,000 ppm) by weight as determined by laboratory analysis or XRF measurement.
- Non-lead paint is defined as paint that contains less than 0.5% (5,000 ppm) total lead by weight as determined by laboratory analysis or by XRF measurement.
- PCB paint regulated as hazardous waste is defined as paint over 50 ppm by laboratory analysis.
Lead determination methods
Any of the three methods listed below may be used to determine lead content of paint:
- Review paint records of structure to determine the presence of lead. Because the structure may have several layers of paint, relying on paint records for determining lead content must include review of all paints present on a structure including the primer.
- Laboratory Analysis - Sample paint coating(s) on the steel structure for lead concentration and submit for laboratory analysis (see sampling procedure, PDF).
- Field Analysis - The Office of Environmental Stewardship can make a determination of the lead content using an XRF field instrument. Contact Harold Bottolfson or Luke Bistodeau with the Environmental Modeling and Testing Unit for more information. When possible, please request sampling at least six months in advance.
PCB content determination
- Field Analysis - The Office of Environmental Stewardship can make a determination of the PCB content by sampling and laboratory analysis. Contact Harold Bottolfson or Luke Bistodeau with the Environmental Modeling and Testing Unit for more information. When possible, please request sampling at least six months in advance.
Lead, PCB and non-lead paint removal containment
Determine proper containment of structure to prevent release of lead and other particulate matter to the environment:
- Lead paint or PCB paint removal containment (PDF)
- Notification (PDF) required for lead paint removal; prepare for residences or institutions near the project location.
- Non-lead and non-PCB paint removal containment (PDF)
Blasting waste sampling, storage, transportation and disposal requirements
To determine appropriate waste management requirements for a specific project, select from the following options:
- Non-lead and non-PCB paint removal (PDF)
- Lead paint and non-PCB removal using Blastox™ media (PDF)
- Lead paint removal using media other than Blastox™ and/or PCB paint removal (PDF)
Contractors are required to supply their own solvents and paints. The Contractor is also the owner of waste solvent and paint generated on the project and so is responsible for properly managing and disposing of the waste. Contract language on MnDOT projects requires the Contractor to follow Minnesota Pollution Control Agency regulations for waste handling and disposal. Solvents can be reused, but unusable solvent and paint sludge must be disposed of through a licensed hazardous waste disposal facility. Drying and disposing waste solvent and oil-based paint in the garbage is not permitted.
It is recommended that MnDOT Bridge Inspectors receive training on environmental regulations and best management practices associated with abrasive paint removal operations prior to the start of work. This training is provided upon request by contacting Mark Vogel or Jackie Klein.