Spot Painting to Extend Highway Bridge Coating Life: Volume 1: Guidance (2018)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

NCHRP Project 14-30 59 5.0 WORKER SAFETY AND COMPLIANCE WITH ENVIRONMENTAL REGULATIONS 5.1 Worker Safety OSHA Regulations Workers involved in spot painting must take special precautions to protect themselves from hazards associated with painting operations. That is addressed under the Occupational Safety and Health (OSH) Act (1970), and it is regulated by the Occupational Safety and Health Administration (OSHA). Contractor employees are covered by OSHA regulations. State workers and local government agencies are not covered by federal OSHA, but have OSH protections if they work in states that have OSHA-approved state programs. Those programs may employ OSHA or their own (more stringent) regulations. Under OSHA, employers must provide safe workplaces. Under OSHA the major employer (highway agency) requirements are: • Informing workers of chemical hazards through training and, for coating supplies, PDSs • Keeping accurate records of employee injuries and illnesses • Performing tests in the workplace including air sampling (e.g., when disturbing lead- based coatings) • Providing Personal protection equipment (PPE) to workers • Providing medical surveillance and tests (e.g., hearing, blood sampling) when required by OSHA regulations • Posting OSHA citations and annually post injury and illness summary data where workers can see them • Promptly notifying OSHA of fatalities and major work-related injuries and illnesses OSHA (and its state partners) are responsible for enforcing compliance with OSHA standards. It uses enforcement by inspectors/officers to carry out site inspections and assess fines for regulatory violations. Site inspections can be the result of fatalities, injuries, and referrals, or focused on particularly hazardous work. OSHA can conduct inspections at jobsites without notice. They can also meet at an agency office for a preliminary conference and request access to the agency’s worker safety plan. Bridge painting is considered a dangerous activity that receives attention of OSHA inspectors. Accidents and worker complaints prompt OSHA inspections and, if significant problems (imminent danger) are observed, a job can be halted until the situation is corrected. The agency should have all relevant paperwork current and readily available, including a Hazard Communication Plan. OSHA (or its state partners) may perform courtesy inspections of jobsites at the request of the agency to inspect work being performed and identify any hazards that need to be address without penalty to the requesting agency. Under OSHA workers have rights to safe working conditions, to file complaints with OSHA (or a state program), hazard recognition, OSHA standards and safety training, histories of work- related injuries and illnesses, copies of their medical records, the ability to participate in an OSHA inspection and speak with an OSHA representative, and freedom from retaliation for requesting an OSHA inspection or exercising their rights under OSHA. Employers and highway agencies of states with OSHA programs are covered by the General Duty Clause of the OSH act that requires employers to keep workplaces free of serious recognized hazards and is a “coverall” regulation invoked when no specific OSHA standard

NCHRP Project 14-30 60 applies to a hazard. Worker safety and health requirements are addressed from an owner/contractor/ subcontractor perspective in SSPC PA 10, “Guide to Safety and Health Requirements for Industrial Painting Projects.” That document refers to OSHA Compliance Directive CPL 02-00- 124, which addresses citation policies for multi-employer worksites. A more applicable document is SSPC Technology Guide 17, “Guide to Developing a Corporate Safety Program for Industrial Painting and Coating Contractors.” While geared toward painting contractors, that guide addresses core elements and requirements for developing a safety program that incorporates good safety practice as well as regulatory requirements for meeting OSHA guidelines for a company (agency) safety program. Highway agencies involved with contractor painting already have the necessary organization to monitor spot painting projects safely. The same would apply for agencies that already have in-house maintenance painting projects. Highway agencies seeking to create an in-house painting capability either with dedicated crews or on an ad hoc basis using existing field maintenance crews would need to develop such a safety program. Regulations are constantly changing, and the agency worker safety division is responsible for providing necessary support to ensure supervisors and crews are performing the work in a manner that conforms to the latest regulations. As defined in SSPC Technology Guide 17, the primary elements of an agency safety program include: • Management leadership and employee participation • Hazard identification and assessment • Information and training • Evaluation of program effectiveness (enforcement) Some factors for agencies in performing in-house maintenance painting work (including spot painting) include: • An employee assigned to receiving and responding to reports about safety and health concerns • Reporting procedures to document all job fatalities, injuries, illnesses and near misses to identify hazards • Maintaining and retaining various safety records • Medical records of employees (period of employment + 30 years) • Employee training in compliance with OSHA requirements (plus re-training at specified intervals) • Development of appropriate ways to control hazards identified in accident reports A helpful checklist of questions for keeping records includes: • Are all occupational injuries and illnesses being recorded in the OSHA 300 log? • Are employee medical records and records of exposure to hazardous substances up- to-date? • Are the OSHA training records current and available for review? • Are medical records of employees being kept for period of employment plus 30 years? • Are inspection tags, operating permits and records up-to-date for firefighting equipment, air pressure tanks, and other equipment? SSPC Technology Guide 17, “Developing a Contractor Safety Program,” lists several

NCHRP Project 14-30 61 industrial painting operations that require OSHA-defined competent persons applicable to construction. Some of those are related to general activities performed by highway agency crews and may not require additional competent personnel outside of those specific to bridge painting. The guide suggests that employees be involved with safety issues by requiring them to assist with safety training, audits, and incident investigations. Employers (agencies) must regularly communicate with the all employees about any safety concerns. One good way to accomplish this is for the supervisor to conduct “tool box” meetings with the crew every day before work at a job site discussing tasks to be performed that day and safety issues/concerns. The supervisor should also keep a log recording when/where the meeting was held, topics discussed, and crew members present. The supervisor should note and promptly correct any unsafe conditions or unsafe actions. Training should permit workers to identify common workplace hazards and a means of communicating any concerns to the supervisor or agency safety personnel. SSPC Technology Guide 17 provides a list and description of OSHA employee training requirements for workers involved with painting, including those pertaining to disturbing existing lead-based coatings. Some applicable requirements related to the OSHA General Industry 29 CFR 1910 and Safety and Health Regulations for Construction 29 CFR 1926. The guide also provides the following sample documents: 1) program statement and signature page, 2) safety policy and rules, 3) safety goals (short-, intermediate and long-term), 4) safety responsibilities of key personnel, 5) schedule of training and activities, 6) examples of safe operating procedures, 7) copies of pertinent OSHA forms, and 8) cross-references of OSHA 1910 and 1926 standards. The top OSHA citation categories from 2011 to 2013 were fall protection, hazard communication, scaffolding, and respiratory hazards — all components of maintenance painting operations (D+D News September 2014). Maintenance painting is recognized by OSHA as a hazardous activity and all those categories can be encountered in bridge maintenance painting operations. OSHA has a hierarchy of approaches to minimize or eliminate exposure hazards. Those are (from most desirable to least): 1. Elimination — physically removing a hazard. Removing lead-based coatings on bridges may be an example for future maintenance painting work, but the elimination process poses risks in the near-term. 2. Substitution — replacing something that produces a hazard with something that does not. Use of water-based coatings instead of solvent-based coatings that use hazardous air pollutants (HAPs). 3. Engineering controls — adding ventilation to a work area to reduce worker exposure to respiratory hazards. 4. Administrative controls — limiting workers’ exposure to hazards. Temporarily reassigning workers with elevated blood-lead levels from maintenance painting work. 5. PPE — the use of protective clothing, respirators, eyewear, and 3-point harnesses, among others, to protect the worker from immediate hazards. (Most spot painting work will be short-term and involve various locations around various bridges. Consequently, workers will commonly rely on PPE for safety.) Fall Protection A majority of the maintenance painting work on a bridge will involve working at heights. The leading cause of worker deaths in the construction industry is falls. Falls from scaffolding, ladders and structural steel account for nearly half of those fatalities. In the construction industry, fall protection is required for workers 6 ft. (1.83 m) or more over a lower level. Workers must be protected by guardrail systems, safety net systems, or personal fall arrest systems. The latter are

NCHRP Project 14-30 62 3-point (full body) harnesses, securely anchored using a shock-absorbing lanyard. Safe access must be provided to workers, inspectors, and regulatory agencies. Common issues include using scaffolds without guardrails or safe access. Workers using aerial lifts must not stand above the floor of the work platform (i.e., on the guardrails), and if leaning outside must have fall restraint. Horizontal lifelines allow workers to move horizontally and be tied off. They are made of load rated components, which comprise a complete anchorage. Catenary scaffolds (pick boards) supported by wire ropes are commonly used to access girders between anchorages and piers. Those should be limited to two persons per scaffold with the scaffold ends secured by wire ropes. Fall arrest is required and must be independent from the scaffold catenary line. Highway agencies are required to provide workers with fall protection training including: • The nature of fall hazards in the work area • Correct procedures for erecting, maintaining, disassembling, and inspecting fall protection systems • Use and operation of guardrail, personal fall arrest systems, safety nets, and other systems • Correct procedures for equipment and materials handling and for storage and erection of overhead protection • Knowledge of individual responsibility in fall protection • Knowledge of industry regulation basics and updates. Chemical Hazards Coatings, solvents, and other materials associated with painting contain harmful chemicals that pose several hazards to workers (e.g., health hazards, flame, skin corrosion, acute toxicity). OSHA has now adopted a Hazard Communication Standard (HCS) aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The result is a common, coherent approach to classify chemicals and communicating hazards information on labels and safety data sheets. All employers with hazardous chemicals in their workplaces must have labels and SDSs for exposed workers and train them to handle the chemicals appropriately. Coatings contain various harmful chemicals including solvents and other constituents, such as isocyanates used in curing. Those can be ingested by breathing, eating/drinking, or through skin contact. Personnel involved with solvent cleaning or the mixing, handling, or application of coatings or cleaning painting equipment should wear protective clothing and use respirators with organic vapor cartridges to preclude coatings-related exposure problems. Solvents and coatings can be absorbed through the skin, causing irritation or sensitization. They can make the skin susceptible to attack by fungi or bacteria as well, and damage the body if allowed to enter the blood stream. Proper protective clothing and good personal hygiene are necessary to minimize the potential for skin contact. Medical surveillance may be warranted when using coatings, particularly epoxies and polyurethanes that can cause sensitization. When polyurethane coatings are used for repair coatings, isocyanate exposure is a potential problem. In open areas, spraying is usually not a problem, but workers in the area need to use respirators with organic vapor cartridges. Exposed skin areas should be covered with clothing and permeation-resistant gloves. Areas with limited airflow may be more problematic and ventilation or air-supplied respirators may be required. SSPC has provided guidance for working with polyurethanes and polyureas in SSPC Technical Update (TU) 8, “The Use of Isocyanate- Containing Paints as Industrial Maintenance Coatings.”

NCHRP Project 14-30 63 Respiratory Protection Respiratory protection is an important factor for workers involved in maintenance-painting activities. Workers cleaning bridges can be exposed to lead disturbed by the cleaning processes and histoplasmosis from bird droppings. Typically, those exposures require respiratory protection such as masks with dust cartridges or other types of protection such as wetting the dropping prior to removal. Workers around coatings with VOCs classified as HAPs should wear respirators with organic vapor cartridges. Most half-face respirators can accommodate both particulate and fume cartridges. Those need to be replaced frequently. Disturbing Lead-Based Coatings Respiratory protection is typically desirable for any cleaning operations that generate airborne particulates. Of particular concern is respiratory protection for workers disturbing existing lead- based coatings regardless of the length of exposure or the tools employed. Any activity that disturbs lead-based coatings requires personal monitoring to establish respirable lead levels and protection levels. OSHA maintains a list of hazardous materials (e.g., lead and some VOCs) along with permitted airborne exposure limits, usually taken over an 8-hour workday. Those are given as Permissible Exposure Limits (PELs). Highway agencies must exercise care in exposing workers to those materials. Generally, there are threshold limits that entail limiting exposures. For lead, the lowest limit is called the action level, set at 30 µg/m3, which requires air monitoring at lead-related work areas at the job site. The higher level, set at 50 µg/m3, triggers the requirement for using respiratory protection and protective clothing. There are various levels of control to limit worker exposure to lead particulates: 1) avoidance, 2) administrative controls (limiting time of exposure), 3) engineering controls (ventilation) and 4) PPE. Usually, an industrial hygienist is needed to monitor air quality inside respirators used on a project. Since the time that workers spend on a spot painting project is brief — too short for an OSHA initial exposure determination — suitable respiratory protection issues will need to be resolved with the regulatory agency based on historic data. OSHA recognizes the practicality of controlling exposures for specific tasks. Employers are required to use ‘interim controls’ based on work tasks until exposure assessments are completed. Airborne concentrations of lead need to be determined by mask sampling or using applicable historical data. OSHA presumes that certain tasks result in specific estimated exposures, and thus requires specific worker protection. For example, if workers are using scalers without vacuum attachments to remove lead paint, OSHA assumes that they are exposed up to 2500 µg/m3; respirators that protect up to 50 times the PEL must be used.” Under normal OSHA criteria, hand and power tool cleaning with shrouds are Category 1 exposures with lead particulate ratings above the PEL (without respiratory protection) to < 500 µg/m3. Half-face or full respirators equipped with particulate filter cartridges are usually sufficient for SSPC-SP 3 cleaning if vacuum shrouded tools are used. Those have Assigned Protection Factors of 10 and 50, respectively. They can safely be used with Maximum Use Concentrations of 500 µg/m3 and 2,500 µg/m3 of airborne lead, respectively, and keep the user within the PEL. When working with leaded paint, SP 2 or SP 3 surface preparation typically poses low risks of generating airborne lead. For SP 2 hand tool cleaning, the concern is workers not using respiratory protection. Under those conditions, workers have experienced high lead levels due to inhalation. For SP 3 tools without shrouds, airborne lead particulates may require greater respiratory protection than for tools equipped with shrouds.

NCHRP Project 14-30 64 The use of vacuum-shrouded power tools reduces the worker exposure to respirable lead but some level of personal monitoring is required to establish exposure levels. Experience has shown that hand/power tool surface preparation have had minimal environmental impacts beyond the need to dispose of lead paint debris as a hazardous waste and that worker safety and health requirements have been typically limited to half-face respirators. Vacuum shrouds do not collect larger particles; therefore, protective equipment and good hygiene are required. Vacuum- shrouded power tools do not have sufficient suction to pull in all paint chips, so ground covers are needed to capture those that are not collected by vacuum. Improper use of the tools or attempting to clean complex shapes results in some dust escaping, and side shields will be needed in sensitive areas. Workers involved with leaded paint must have lead awareness training, annual blood lead testing, and be fitted annually with respirators appropriate to their level of exposure. They should be provided personal respirators and observe proper hygiene practices when they are not using them. Workers also need to be provided with clothing if the airborne lead particulate level exceeds 200 µg/m3. They must have suitable on-site hygiene facilities (which normally do not need to be extensive for typical spot painting exposures). Workers exposed to lead must not be allowed to wear work clothing and PPE away from the job site. Where lead is present and showers are not provided, workers should have suitable facilities to wash their hands and face at the end of the workday (Figure 42). Workers need to be trained to take special precautions prior to smoking, drinking, or eating. Protective clothing, including shoe covers, can be disposed of daily. Recordkeeping is required for all personnel requiring medical surveillance for lead levels in blood over the bridge painting season. Those records must be retained for several decades. Even if a project does not involve leaded coatings, workers performing surface preparation, or any aspect of paint preparation/application should use respiratory protection in the form of respirators equipped with particulate and possibly vapor cartridges. The use of power tools requires that workers wear protective eyewear and hearing protection. Prior to use an electrician should check cords on electric powered equipment. Air hoses should be free from cracks and frays. The tool must be disconnected from its power source when changing media. Other Personal Protection Equipment In addition to protective clothing and respirators, workers engaged in spot painting need to be provided with suitable head, eye, and hearing protection. A variety of eyewear is available to meet the requirements of the specific work tasks, from goggles to face shields. Code-conforming hard hats must be worn where impacts or falling objects are possible. Hearing protection is necessary when operating power tools and working around generators and compressors. Figure 42. Portable wash station for bridge painting crew

NCHRP Project 14-30 65 5.2 Environmental Compliance Wastes generated during spot painting can include: • Wastewater from washing operations • Airborne particulates from surface preparation operations • Miscellaneous solid wastes from cleaning operations • Spent solvents and coatings/ containers • Paint chips • Related debris from surface preparation and painting (e.g. rags, tarps, brushes and rollers) • Used respirator filters and disposable clothing. If washing operations are employed, state environmental regulators may require the collection and treatment of wastewater prior to disposal. If more lenient, they may allow the agency to filter it to remove large solids before depositing it on the ground or into receiving waters. These requirements are more likely if the existing paint contains lead or other heavy metals. Of particular concern are airborne emissions of fine lead particulates generated by surface preparation operations (especially abrasive blasting) that can contaminate areas proximate to bridge painting operations. The current National Ambient Air Quality Standard (NAAQS) for lead is 0.15 µg/m3 of total suspended particulates (TSP) as a 3-month average. Spot painting operations are usually too short in duration to cause impacts under most circumstances. SSPC Technology Guide 6, “Guide for Containing Surface Preparation Debris Generated during Paint Removal Operations,” provides guides for paint removal, containment systems, and procedures for minimizing or preventing emissions from escaping the work area as well as related assessment methods. During surface preparation, airborne particulates and debris can be generated that contaminate air, soil, and water adjacent to bridges. Those can pose hazards to the public and the environment. There are two approaches to mitigating those events: 1) using surface methods that limit the generation of particulates/debris/wastewater, and 2) containment systems that retain the particulates/debris/wastewater and facilitate their collection. The containment systems are categorized into up to four classes per type of paint removal method, based upon the extent to which emissions are controlled. Containment systems may involve enclosures erected to surround a work area (typically throughout the surface preparation and coating application steps), arrangements of wind screens/curtains and ground cloths, bibs, and vacuum shrouds for power tools or vacuum blasting. Potential surface preparation/coating removal methods for use on bridges include: • Abrasive blasting (using expendable or reusable abrasives) and vacuum blasting using reusable abrasives • Hand and power-tool cleaning (with and without vacuum shrouds) Class 1 containment provides the highest level of emission control. For abrasive blasting and hand and power-tool cleaning (Classes 1A and IP respectively) it incorporates air- impermeable walls, ceilings and floors with rigid or flexible framing, fully sealed joints, airlock or resealable entryways and negative air pressure through forced or natural air flow, and exhaust air filtration. For wet processes walls, ceilings, and floors should be water impermeable. Class 2 provides a high level of containment for abrasive and hand and power-tool cleaning (Classes 2A and 2P respectively) and varies from Class 1 by allowing partially sealed entryways

NCHRP Project 14-30 66 • Water blasting/water jetting (with or without abrasives) • Chemical stripping The first two methods are more likely to be used on bridges except for vacuum blasting, which has rarely been used. Pressure washing is commonly used to clean coating surfaces and remove soluble salts, but not to remove existing paint (unless weakly adherent) for abrasive blasting and dispensing with the negative air pressure requirement for the containment for hand and power-tool cleaning. For wet processes walls, ceilings, and floors should be water impermeable. Class 3 provides a moderate level of containment for emission control. For abrasive blasting and hand and power-tool cleaning (Classes 3A and 3P, respectively) it incorporates air- penetrable walls, ceilings and floors (as applicable) with rigid or flexible framing, partially sealed joints and entryways and exhaust filtration for abrasive blasting with a minimal framing requirement, partially sealed joints, open seal entryways, and natural air flow for hand and power- tool cleaning. For wet processes walls, ceilings, and floors should be water impermeable. Class 4 containment provides a minimum level of emission control. For abrasive blasting (Class 4A), it incorporates air-penetrable walls, ceiling, and floors (as applicable) with flexible framing, open seams and entryways, and natural airflow. Hand and power-tool cleaning are not covered by this class of containment. For wet processes, walls, ceilings, and floors should be water penetrable but capable of collecting solid debris (e.g., filter fabrics). For locations where clearance restrictions exist, erecting containment may not be practical. In those cases, rapid deployment lift trucks may be used, especially for overpass bridges for off-peak-hour establishment of localized containment (several beam lines for one lane-width of work), permitting surface preparation and, possibly spot painting in that area. Those are available for rental from at least one equipment manufacturer. The method of surface preparation, the presence of hazardous (lead-based) existing coatings, and the sensitivity of the environment are all factored into selection of containment or the determination of whether it is even needed. The type of coatings to be applied and the method of application will also play into that decision. Urban and industrial areas typically warrant higher levels of containment than rural areas. In rural areas, waterways typically pose potential environmental issues (e.g., drinking water intakes, endangered species). Traffic can also pose a problem in terms of overspray issues. Air Monitoring For environmentally sensitive areas, air monitoring may be necessary to ensure the spot painting work poses no hazards to the public. This is usually achieved by ambient air monitoring for toxic metals, usually by monitoring for TSP Lead or other hazardous heavy metal — Method D SSPC-TU 7 “Conducting Ambient Air, Soil, and Water Sampling of Surface Preparation and Paint Disturbance Activities”). Air monitors are usually placed between the worksite and potential receptors such as houses, offices, and sidewalks (Figure 43). This work would typically be arranged by the central office Figure 43. TSP air monitor to detect airborne lead on paint project

NCHRP Project 14-30 67 environmental division personnel if in-house forces were involved. Unlike abrasive blasting, hand tools and power tools with vacuums shrouds typically do not pose significant air emission problems and can be used safely in most environments with a minimum level of containment (ground cloths and wind screens or bibs) when spot painting in areas with a low potential for environmental impacts even when performing spot painting on existing lead-based coatings (Figure 44). During surface preparation, abrasive blasting and hand and power-tool cleaning result in deposits of paint, rust, and other debris either in the containment enclosure or on ground cloths. Abrasive blasting will generate more wastes due to the use recyclable or non-recyclable abrasives. Waste Collection and Disposal When power tool cleaning is used, the total amount of waste generated per square foot will be only about one ounce for a 10 mil (250 micron) thick coating. Power tool cleaning generates a minimal amount of waste because the waste typically consists of only paint, rust, and mill scale. The leaded waste from power tool cleaning will typically be classified as a hazardous waste if the existing paint is an old lead-based alkyd. Hand tool cleaning will generate both fine and large particulates and may require the use of ground tarps and diapers. Waste collection is facilitated when using vacuum-shrouded power tools by usually only needing to empty the vacuum waste containers and clean up ground tarps and diapers. Those can be collected by brooming, shoveling, or vacuuming. When brooming is used, the debris can be wetted to suppress airborne dust if lead paint is involved. For collection from ground cloths, it is desirable to perform collections daily to prevent potential dispersion from wind or rain and promote good housekeeping at the jobsite. All collected waste should be stored in appropriately labelled containers. All paint debris, especially if it contains lead, should be stored separately from other wastes, as should any wastes that are lead contaminated (e.g., disposable clothing, respirator filters). Non-hazardous wastes should be stored separately from potentially hazardous (e.g., lead-contaminated) wastes. Spent solvents should be placed in covered containers and properly disposed of or recycled. Waste Figure 44. Paint chips generated by surface preparation laying on a ground cloth

NCHRP Project 14-30 68 paint can be left in open containers until it has solidified and is disposed of as a non-hazardous waste. For small quantities of hazardous wastes, the agency can cooperate with the state DNR to develop a suitable guide for collecting, storing, transporting and disposing of hazardous waste. Wastewater generated from cleaning/soluble salt treatment operations must be disposed of to meet DNR requirements. Those requirements differ among states. Some agencies are permitted to filter the wastewater of solids and discharge it into receiving waters as long as it does not pose undue environmental impacts. Other agencies must collect all wastewater and dispose of it at a treatment, storage, or, disposal (TSD) facility, especially if used to wash existing lead- based coatings. That can prove very expensive. Most spot painting activities will be of short duration and the disadvantages posed by pressure washing may outweigh the potential benefits (e.g., waiting for the surface to dry and the time/effort to collect and treat the wastewater). Wastewater generated from pressure washing operations is typically collected in impermeable bibs, ground cloths or troughs and pumped into storage tanks prior to treatment and disposal SSPC Technology Guide 7, “Guide to the Disposal of Lead-Contaminated Surface Preparation Debris,” addresses the disposal of lead and other heavy metals designated as EP Toxic by the US EPA. The disposal limits are set as toxicity leachate levels for metals including arsenic, barium, cadmium chromium, lead, mercury, selenium, and silver. Beside lead, other heavy metals have been found in existing coatings. Typically, reviews of older agency paint specifications (which were commonly formula-based) will reveal when those other metals should be of concern. Preliminary field assessments, paint sampling, and elemental analysis of the samples should indicate if other heavy metals are a potential concern. Lead-based paint wastes are classified as hazardous when they exhibit lead concentrations greater than 5 mg/L using the US EPA Toxicity Characteristic Leaching Procedure (TCLP) test. If other heavy metals are present, they will need to be analyzed as well to determine if they are in sufficient concentrations to classify the waste as hazardous. Surface preparation debris is not classified as a hazardous waste until tested unless classified as hazardous by the agency as a standard practice. For years, the Kentucky Transportation Cabinet considered paint wastes from all bridges with existing lead-based alkyds to be hazardous wastes. Rags/burlap used in wiping surfaces, vacuum filters, respirator filter Figure 45. Storage tank used to collect wastewater from a pressure washing operation

NCHRP Project 14-30 69 cartridges, and disposal clothing can be stored in sealed impermeable bags or other sealed containers and labelled as a lead-containing waste (depending on the concentration of lead in the coating). Most spot painting projects will not involve large quantities of hazardous paint debris. Highway agency environmental officials can consult state environmental authorities and provide appropriate collection, testing, storage, and waste disposal procedures. EPA allows one drum of hazardous waste to be kept at the jobsite for three days prior to moving it to a temporary secure storage area. Regardless of waste characterization, it is good practice for workers to collect and remove all wastes from the job site daily and place them in a secure temporary storage area. All hazardous (or potentially hazardous) paint wastes need to be placed in US DOT standard containers or bins for transport off-site. The lid of the containers must be firmly secured and the containers marked with contents, origin, and date of collection. For TCLP testing, the containers need to be referenced to samples extracted. A temporary storage site can be established at the jobsite or, if permitted by the DNR, taken to the agency’s facility (e.g., garage) for storage. For hazardous wastes, the storage site needs to be a lockable fenced-in area with placards denoting the presence of hazardous material. The site must be well drained and not exposed to flooding. Hazardous waste containers inside the storage area need to be segregated from non-hazardous wastes and placed on pallets or dunnage to prevent corrosion of the containers and ground cloths placed under them to collect any spills. For ease of handling, 30-gallon (113.6 L) containers are preferable to 55-gallon (208.2 L) ones. If hazardous wastes are encountered, the agency must file a site-specific permit with the DNR to dispose of it. The permit will be based upon the amount of hazardous waste material generated. The permits are bridge-specific, but hazardous wastes from each jobsite can be stored at a common temporary storage site. Those wastes must be manifested and shipped to a TSD facility within the allotted timeframe established by the EPA for the specific generator category. Large quantity generators that produce 2,200 lb. (1,000 kg) or more of hazardous waste can store them for a maximum period of 90 days. That might be typical of agencies that spot paint large areas using abrasive blasting with consumable abrasives. Small quantity generators that produce more than 220 lb. (100 kg) per month, but less than 2,200 lbs. (1,000 kg) may accumulate waste on-site from one bridge for a maximum of 180 days provided that the total quantity of hazardous waste on site from a bridge does not exceed 13,200 lb. (5,987 kg). Most highway agency work involving spot painting with power tools will probably qualify as small quantity generation from a bridge. For spot painting of small- to medium-sized bridges, the agency may qualify as a very small quantity generator if producing less than 220 lb. (100 kg) of hazardous waste per month from a bridge. Under that classification, the highway agency cannot store more than 2,200 lb. (1,000 kg) of hazardous waste from a bridge at one time. Very small quantities of hazardous wastes can be incorporated with hazardous wastes from large quantity generation if both projects are under the management of the same person. Very small generators are not required to have an EPA ID number for the waste or go through the reporting requirements of the other categories of waste generators. They can store the waste for an extended period if they are under the maximum accumulation limit. Eventually the waste must be treated on-site, delivered to a large- quantity generator under control of the same person, or delivered to a TSD facility for ultimate disposal. Large quantity waste generators are required to have an emergency plan and procedures in writing as a contingency for any hazardous waste releases. Small quantity generators are not required to have a written plan, but a basic plan is required. Different categories of waste generators have significantly different US EPA requirements. State EPAs may have varying

NCHRP Project 14-30 70 categories of waste generators and different requirements from those of the US EPA. Hazardous waste needs to be permitted, manifested, and delivered to TSD facilities by licensed hazardous waste transporters. There are chain of custody records that must be retained by the owner for decades. Options for dealing with waste lead paint are to perform on-site treatment to render the waste non-hazardous or recycle leaded paint debris. Lead-based paint residue can only be recycled if it contains spent iron or steel abrasives used in abrasive blasting, eliminating the possibility of recycling lead wastes generated by power tool cleaning. Spent solvents, depending upon type, are typically stored in containers and subsequently recycled or disposed of as a hazardous waste. Non-hazardous dry wastes can be collected and taken to a Category D landfill for disposal. That includes any wastes treated on site or at a TSD facility to render them non-hazardous. Unused repair coatings can be left in open buckets and allowed to dry. Thereafter, they usually can be disposed of as non-hazardous waste. In some cases, testing of air, soil and water are necessary to ensure that paint activity that disturbs lead or other heavy metals in existing coatings on bridges does not pose a hazard to the public or the environment, or assess a hazard if it exists. Guidance on what tests to perform is contained in SSPC Technology Update TU-7, “Conducting Ambient Air, Soil, and Water Sampling of Surface Preparation and Paint Disturbance Activities.” That document provides air monitoring guidance for in-process surface preparation activities, usually involving lead-based paints, including the methods to be used and frequency of monitoring. The classes of monitoring are: • Method A: Visual Emissions • Method B: Ambient Air Monitoring for PM-10 • Method C: Occupational Monitoring of Area Emission of Hazardous and Toxic Substances • Method D: Ambient Air Monitoring for TSP Lead • Method E: Soil Analysis for Hazardous and Toxic Substances • Method F: Water and Sediment Analysis for Hazardous and Toxic Substances Generally, soil testing is performed before and after maintenance painting operations that disturb existing lead-based paints. Other criteria for testing include circumstances where releases of lead wastes have occurred, and it is necessary to determine whether the release has had a significant effect that requires some remedial action.