Field Methods for Determining Lead Content in Bridge Paint Removal Waste
NYSDOT is seeking a reliable method for quickly determining whether or not paint
removal waste from a particular bridge will be classified as a hazardous waste. Paintedsteel
bridges constructed before 1988 were originally coated with lead-based paint (LBP).
When a bridge is repainted, the existing coating must be removed (part of surface
preparation) and disposed of. When LBP is removed, the removal waste is classified as a
hazardous waste, because the concentration of leachable lead by Toxicity Characteristic
Leaching Procedure (TCLP) analysis is 5 milligrams/liter (mg/l) or greater. Because
surface preparation does not always involve 100% removal of the previous coating, there
can be enough residual lead on the bridge to cause a non-LBP coating to be a hazardous
waste upon removal for subsequent painting. Based on these circumstances, and because
NYSDOT does not currently have a reliable, efficient, and cost effective method to
determine whether or not a bridge rehabilitation project will generate hazardous paint
removal waste prior to construction, NYSDOT considers all bridge-paint waste from
painted steel bridges constructed before 1988 to be a hazardous waste, even though much
of it may be non-hazardous. Because we consider the waste to be hazardous, it is more
expensive to dispose of (roughly twice the cost of non-hazardous waste). Additionally,
the regulatory burden (taxes, fees, surcharges, training, recordkeeping, etc.) and liabilities
associated with the generation of hazardous waste are quite onerous. If NYSDOT were
able to quickly and efficiently analyze bridge paint and use a reliable model to determine
whether or not the paint removal waste will be a hazardous waste prior to construction,
these regulatory burdens and liabilities would be greatly diminished.
