Contractor Paint Removal Operations Process

Lead content determination

Use of Recyclable Abrasives for Paint Removal

Only recyclable abrasives (steel grit) will be used by contractors removing both lead and non-leaded paint from MnDOT steel structures. The Bridge Office must approve the use of Blastox for paint removal projects and will only grant approval under special circumstances.

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 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 with the Environmental Modeling and Testing Unit for more information. When possible, please request sampling at least six months in advance.

Containment

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:

Paint removal containment (PDF)
Notification (PDF) required for lead paint removal; prepare for residences or institutions near the project location.

Waste management

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/or PCB paint removal (PDF)

Only in emergency situations Blastox™ can be used with written approval from the Project Engineer, if used:

Lead paint and non-PCB removal using Blastox™ media (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.