Environmental process | Environmental review | Regulated Materials/Waste
Regulated Materials/Waste process
Purpose
The purpose of considering regulated materials/wastes is to ensure proper management in accordance to applicable federal and state regulations and to reduce liability to the department. Identification of regulated material/wastes associated with building demolitions or relocations and bridge demolitions or rehabilitation projects enables Regulated Materials Unit (RMU) in the Office of Environmental Stewardship (OES) to prepare contracts to manage the materials/wastes properly and to apply special provisions, as necessary.
Contacting the Regulated Materials Unit (RMU) in the Office of Environmental Stewardship
RMU can assist you in determining if your project will encounter regulated materials/wastes.
In order for RMU to have sufficient time to review a project and provide meaningful comments, it is essential that you contact them approximately 12 to 18 months prior to project letting.
Threshold criteria
MnDOT projects may generate and require management of regulated materials/wastes (above ground) such as lead-based paint, asbestos-containing material, polychlorinated biphenyl (PCB)-containing materials, mercury-containing materials, treated wood, hazardous waste, and other regulated wastes. RMU can provide you with guidance if you are likely to encounter regulated materials/wastes during a project.
RMU can assist in determining if you are likely to encounter regulated materials/wastes during a project. Any project that includes building demolition or relocation or bridge demolition or rehabilitation requires an assessment of the structure and surrounding area to determine the presence of any regulated materials/wastes.
Who? Describe any such material that you identify during the assessment in the project documentation. Include the need for appropriate special provisions detailing proper handling and/or disposal in the project contract. The following project activities require evaluation for potential issues related to regulated materials/waste identification, documentation, and disposal:
- Bridge demolition or relocation
- Bridge demolition or rehabilitation
- Bridge painting
- Other steel structure painting
- Paint removal by abrasive blasting
- Asbestos dumps and pipes
- Acquisition of right of way containing any above-ground discarded or abandoned regulated material or waste (MnDOT generally assumes responsibility and liability for properly disposing of material/wastes it encounters on the right of way)
Regulated materials/wastes include, but are not limited to the following items:
- Asbestos materials: in dumps, buildings, and bridges
- Chlorofluorocarbons (CFCs): from heat pumps, central air conditioners, etc.
- Polychlorinated biphenyls (PCBs): from caulk, bituminous felt, light ballasts, electronic relays, etc.
- Mercury: from fluorescent lighting, electrical switches, thermostats, etc.
- Lead: paint, gaskets, circuit boards, light-emitting diode (LED) bulbs, piping, batteries, etc.
- Treated wood: from guardrail systems, buildings, decks, etc., including subsurface pilings (creosote, pentachlorophenol, chromated copper arsenate (CCA), etc.
- Other household hazardous wastes on the premises: e.g., waste paints, pesticides, solvents, etc.
- Abandoned subsurface structures such as wells and sewage treatment systems (SSTS)
- Contents of flammable waste traps, sedimentation traps, holding tanks, and cisterns
- Other solid wastes, such as appliances (white goods) and electronics
Regulated materials/wastes on projects
In order for RMU to have sufficient time to review a project and provide meaningful comments, please contact them approximately 12 to 18 months prior to project letting.
District personnel inform RMU of any project involving demolition or relocation of buildings and/or demolition or rehabilitation of bridges:
- Contact RMU at least six months prior to possession of parcels with building demolitions/relocations
- Contact RMU at least one year prior to letting projects with bridge demolition/rehabilitation
RMU prepares contracts to:
- Complete assessments to identify the presence of asbestos and other regulated materials in buildings or bridges
- Complete the removal of asbestos and regulated materials for building demolitions/relocations prior to commencement of the construction project
- Provide oversight of the contractor performing the removal process of buildings or bridges
NOTE: Only contractors on the MnDOT certified list can be selected to perform the actions above on MnDOT projects.
Responsibilities of the district include:
- Completing the initial contact with RMU to identify projects with building demolition or renovation or bridge demolition or rehabilitation
- Identifying a district coordinator for the project. The district coordinator is responsible for:
- Providing RMU with as-built drawings for bridges or building books for buildings
- Furnishing keys and arranging the schedules for building assessments
- Scheduling bridge assessments
- Directing all technical questions from contractors or MnDOT personnel to OES
See the Building Demolition site for more information.
OES reviews assessment reports and other documents to ensure proper completion and then sends final reports to the district.
For paint removal projects that use abrasive blasting, the district notifies RMU of paint removal activities a minimum of one year prior to letting. RMU can provide just-in-time training upon request. See the Paint Removal site.
Processes
Building demolition or relocation
Contact RMU to manage regulated materials prior to demolition. OES will prepare contracts for structure assessment, abatement/removal of materials, and oversight of the removal procedure. Initiate the process by contacting OES 12 to 18 months prior to letting (or as soon as practical).
When it becomes the owner of any building, MnDOT assumes responsibility for identifying and properly disposing of all regulated materials/wastes that are part of the building structure (such as asbestos and treated wood), items that are left inside the building (such as fluorescent bulbs, mercury thermostats, and household chemicals) or items left outside the building (such as drums or other containers or waste). MnDOT is liable for the proper handling and disposal of all regulated materials associated with demolition or relocation of a structure.
Bridge demolition or rehabilitation
Contact OES who will prepare contracts for structure assessment, abatement/removal of materials, and oversight of the removal procedure. Prior to bridge demolition or rehabilitation, RMU must assess the bridge for asbestos-containing material (ACM), lead-based paint (on steel components), lead gaskets, PCB-containing materials, LED bulbs, fluorescent bulbs, high-intensity discharge (HID) bulbs, treated wood, and other electronic components. If the bridge has ACM, lead-based paint, or other regulated materials, those materials must be properly handled and disposed of prior to demolition or rehabilitation. RMU hires an oversight contractor if ACM or PCBs are present.
Bridge painting
Contact the Office of Bridges and Structures (OBS) who will prepare contract language to ensure that work will conform to environmental regulations and MnDOT policy. MnDOT must document any waste materials (such as spent abrasives, paint chips, waste paint solvents, and unusable paint) from a bridge painting project.
Other steel structure painting
An example of a steel structure apart from a bridge is an electrical box.
Contact RMU who will prepare contract language so that the work will conform to environmental regulations and MnDOT policy. MnDOT must document any waste materials (such as spent abrasives, paint chips, waste paint solvents, and unusable paint) from a steel structure painting project.
For more information about regulated materials/wastes on bridge projects, see:
- Managing Regulated Materials on Building and Bridge Projects
- MnDOT Steel Structure Paint Removal Program
External agencies involved
The Minnesota Pollution Control Agency (MPCA) regulates structure demolition and disposal activities and asbestos, solid, and hazardous waste management and disposal activities.
The Minnesota Department of Health (MDH) regulates asbestos management, contractor licensing, and asbestos abatement permitting.
US Department of Transportation (DOT) regulates the transport of hazardous materials.