MnDOT paint removal operations process
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 if 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 determination method
- 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 and non-lead paint removal containment
Determine proper containment of structure to prevent release of lead and other particulate matter to the environment:
- Paint removal containment (PDF)
- Notification (PDF) required for lead paint removal; not required for paint removal from surface areas less than 500 square feet. Contact us if paint removal surface area will exceed 500 square feet.
Abrasive blasting waste management
Removing paint by dry blasting with the product Blastox™ should produce a blasting waste that is non-hazardous. Using the product Blastox™ will not affect PCB paint; this waste must be treated as hazardous waste. This greatly reduces cost and requirements in handling, transport and disposal of the waste. Proper management of abrasive blasting waste must meet the following requirements:
- Daily Collection/Cleanup (PDF) – during and at completion of the project
- Storage and Labeling (PDF)
- Sampling Waste (PDF) – to verify that the waste is non-hazardous
- Transport, Disposal and Documentation (PDF)
Alternative paint removal by hand scraping or power tools
There are fewer regulations when hand scraping or power tools are used to remove paint as compared to abrasive blasting. Sufficient tarps must be used as ground cover and as curtains to contain paint particles within the work area. This containment minimizes impacts to air and soil. Ground cover is not needed over intact paved areas that can be swept to recover paint particles. Paint particles must be cleaned up daily.
- Power tools with vacuum systems - Ground cover and curtains are not required if the power tool is equipped with a vacuum to prevent visual air emissions.
- Transportation and disposal - Consult your District Safety Administrator for proper waste management procedures.
Non-lead paint particles can be brought back to MnDOT District Headquarters in a container with a secured lid (5 gallon bucket with lid) and managed as an industrial waste. This waste can be disposed of at a mixed municipal solid waste landfill or industrial landfill permitted by the Minnesota Pollution Control Agency. The container must be labeled “Non-Lead Paint Chips”.
Lead paint particles can be brought back to MnDOT District Headquarters in a container with a secured lid (5 gallon bucket with lid) and managed as a hazardous waste. This waste can be disposed of with MnDOT hazardous waste contractor. The container must be labeled “Hazardous Waste” and “Lead Paint Chips”.
Submit a written record of the following information to the District Safety Administrator:
- work site (location of bridge or other structure)
- date of paint removal work
- lead or non-lead paint determination
- quantity of paint chips generated
- statement that the paint chip waste was sent to the MnDOT District Headquarters
- disposal location
Following the paint removal operation, the structure is ready for painting. Painting operations typically produce used solvent and oil-based paint sludge that must be managed properly.
- Used solvent can either be reused or disposed of as hazardous waste. It is illegal to evaporate used solvent. Any used solvent not reused must be disposed of through MnDOT’s current hazardous waste disposal contractor.
- It is illegal to dispose of oil-based paint sludge in the garbage or to allow oil-based paint to dry by evaporation. Oil-based paint must be disposed of through MnDOT’s current hazardous waste disposal contractor.
For more help on reuse and disposal procedures, contact your MnDOT District Safety Administrator or see MnDOT's regulated material management site.