ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL … · ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL COATING ON HIGHWAY STRUCTURES APRIL 1996 ... ENVIRONMENTAL GUIDELINES FOR STRUCTURAL

ENVIRONMENTAL GUIDELINES

FOR STRUCTURAL STEEL COATING

ON HIGHWAY STRUCTURES

APRIL 1996

PREPARED BY:

THE ONTARIO PAINTING CONTRACTORS ASSOCIATION,

THE ONTARIO MINISTRY OF ENVIRONMENT AND ENERGY & ,

THE ONTARIO MINISTRY OF TRANSPORTATION

ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL COATING ON mGHWAY STRUCTURES

prepared by

The Ontario Painting Contractors Association The Ontario Ministry of Environment and Energy and The Ontario Ministry of Transportation

under the direction of the

Development Committee - Environmental Guidelines For Structural Steel Coating On Highway Structures

February 1996

To all users of this publication:

The information contained herein has been carefully compiled and is believed to be accurate at the date ofpublication. Freedom from error, however, cannot be guaranteed.

Enquiries regarding the purchase and distribution of this manual should be directed to:

Publications Ontario

By telephone: 1-800-668-9938 By fax: (613) 566-2234 TTY: 1-800-268-7095 Online: www.publications.gov.on.ca

Enquiries regarding amendments, suggestions, or comments should be directed to the Ministry of Transportation at (905) 704-2065

ISBN 0-7778-4608-X © Queen's Printer for Ontario, 1996

www.publications.gov.on.ca

Comments

Comments on the content of this report should be directed to:

The Ontario Painting Contractors Association Suite 305 211 Consumers Road Willowdale, Ontario M214G8

To Order:

Ronen House 505 Consumers Road Suite 910 Toronto, Ontario M214V8

(416) 502-1441 (Toronto Local) or 1-800-856-2196

TABLE OF CONTENTS

UST OF TABLES

UST OF FIGURES

DEVELOPMENT COMMITTEE - ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL COATING ON HIGHWAY STRUCTURES

BACKGROUND

1 THE STRUCTURAL STEEL COATING REHABILITATION PROCESS AND POTENTIAL EMISSIONS/WASTE STREAMS

1.1 Introduction 1.2 The Structural Steel Coating Rehabilitation Process 1.3 Potential Waste Streams/Emissions 1.3.1 Air Emissions 1.3.2 Liquid Wastes 1.3.3 Solid Wastes 1.4 Waste Management

2 INTERPRETATION OF ENVIRONMENTAL LEGISLATION, STANDARDS AND POUCY GOALS

2.1 Introduction 2.2 The Environmental Protection Act (EPA) 2.2.1 EPA - Section 1 2.2.2 EPA - Section 6 2.2.3 EPA - Section 13 2.2.4 EPA - Section 14 2.2.5 EPA - Section 20 2.2.6 EPA Section 92 - Part X, Spills 2.2.7 EPA - Section 93

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2.3 Regulation 346, EPA - General Air Pollution 2.3.1 Regulation 346 - Section 3 2.3.2 Regulation 346- Subsection 5(3) 2.3.3 Regulation 346- Subsection 8(1) 2.3.4 Regulation 346 - Section 9 2.3.5 Regulation 346 - Section 11 2.3.6 Regulation 346 - Section 13 2.3.7 Regulation 347, EPA- General Waste Management 2.4 Ontario Water Resources Act (OWRA) 2.4.1 OWRA - Section 1 2.4.2 OWRA - Section 2 2.4.3 OWRA - Section 30 2.4.4 OWRA - Section 34 2.5 Fisheries Act 2.5.1 Fisheries Act- Section 35 (1) 2.5.2 Fisheries Act- Section 36 (3) 2.6 Guidelines For The Cleanup Of Contaminated Sites In Ontario 2.7 Reduce, Reuse And Recycle - Goals 2.8 Volatile Organic Compounds - Goals 2.9 Transportation Of Dangerous Goods Act 2.10 Environmental Situations And Responses 2.11 Due Diligence

3 PREPARATION METHODS AND COATING SYSTEMS

3.1 Introduction 3.2 Surface Preparation 3.2.1 Solvent Cleaning 3.2.2 Hand Tool Cleaning 3.2.3 Power Tool Cleaning 3.2.4 Vacuum Power Tool Cleaning 3.2.5 Abrasive Air Blasting 3.2.6 Vacuum Abrasive Blasting 3.2.7 Water Blast Cleaning 3.2.8 Air Abrasive Wet Blasting 3.2.9 Water Blasting and Abrasive Injection 3.3 Abrasives Used In Air Blast Cleaning 3.3.1 Metallic Abrasives 3.3.2 Non-Metallic Abrasives

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3.4 Coating Systems Used By The Ontario Ministry Of Transportation 3.4.1 Three Coat Alkyd System 3.4.2 High Build Alkyd System 3.4.3 Aluminium-Filled Epoxymastic System 3.4.4 Hot Dip Galvanizing 3.4.5 Metallizing 3.4.6 Coal Tar Epoxy 3.4.7 Inorganic Zinc/Epoxy/Urethane System 3.4.8 Coal Tar For Piles 3.4.9 Inorganic Zinc/Vinyl System 3.4.10 Epoxy Zinc/Vinyl System 3.5 Low Volatile Organic Compound (VOC) Coatings 3.6 Overcoating/Encapsulation Coating Systems

4 CONTAINMENT DURING SURFACE PREPARATION AND COATING

4.1 Introduction 4.2 Containment During Surface Preparation 4.3 Containment During Coating Application 4.4 Site Sensitivities

5 MONITORING OF PROCESS EMISSIONS AND ENVIRONMENTAL IMPACTS

5.1 Introduction 5.2 Monitoring Technologies 5.3 Visual Emissions 5.4 Ambient Air Suspended Particulate Matter (SPM), Lead And Dust Fall 5.5 Soil Sampling 5.6 Surface Water Sampling

6 WASTE MANAGEMENT

6.1 Introduction 6.2 Waste Classification 6.3 Solid Waste

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6.3.1 Spent Abrasive Blasting Medium And Removed Coating Material Sample Collection

6.3.2 Other Solid Wastes- Sample Collection 6.4 Liquid Waste 6.4.1 Liquid Waste - Sampling 6.5 Preparation Of Composite Samples 6.6 Storage Of On-Site Wastes 6.7 Transportation And Disposal 6.8 MOEE Caution Statement

7 SITE MANAGEMENT

7.1 Introduction 7.2 Field/Observation Monitoring 7.3 Site Management Plan 7.3.1 Site Sketch 7.3.2 Equipment Containment Specifications And Operating Procedures 7.3.3 Waste Collection And Recycling Procedures 7.3.4 Waste Disposal Procedures 7.3.5 Employee Health and Safety Procedures 7.4 Record Keeping 7.5 Containment Structure Design 7.6 Ventilation Of Work Areas

8 EMERGENCY RESPONSE PLANNING

8.1 Introduction 8.2 Spills Reporting 8.3 Emergency Response Plan - General Requirements 8.4 Emergency Response Plan - Implementation 8.5 Environmental Protection And Liability Risks

9 TRAINING

9.1 Introduction 9.2 Training Requirements

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REFERENCES

APPENDIX A DISTRICT MOEE OFFICES

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LIST OF TABLES

Table

1 CLEANUP GUIDELINES FOR LEAD IN SOIT..S AND GROUNDWATER

2 ENVIRONMENTAL SITUATIONS AND RESPONSES

3 PENALTIES UNDER THE ENVIRONMENTAL PROTECTION ACT

4 SURFACE PREPARATION METHODS, EMISSIONS, AND MINIMUM CONTAINMENT REQUIREMENTS

5 SITE SENSITIVITIES

6 SUMMARY OF SAMPLING METHODOLOGIES AND MOEE CRITERIA

7 MINIMUM NUMBER OF SAMPLE SITES FOR IN-SITU SOIL

8 SITE MANAGEMENT PRACTICES CHECKLIST

LIST OF FIGURES

FIGURE

Figure 1 POTENTIAL EMISSIONS/WASTE STREAMS FROM STRUCTURAL STEEL COATING REHABILITATION OPERATIONS

Figure 2 SPILL OCCURRENCE REPORT

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DEVELOPMENT COMMIT'fEE - ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL COATING ON IDGHWAY STRUCTURES

Maureen Marquardt Ontario Painting Contractors Association

Jeff Butcher Dayson Sandblasting and Coatings Ltd.

Frank Hruska National Painting And Decorating (Hamilton) Inc.

Jack Mills Harrison Muir Ltd.

William DeBoer C. H. Heist Ltd.

James Dorey Environmental Office Ontario Ministry of Transportation

Malcolm Maclean Contract Management Office Ontario Ministry of Transportation

Pat Kerins Structural Office Ontario Ministry of Transportation

Tom Pepper Northern Region Ontario Ministry of Transportation

Don Beckett Operations Division Ontario Ministry of the Environment

Eric Loi Environmental Science and Technology Branch Ontario Ministry of the Environment

James McRorie Southwestern Region Ontario Ministry of the Environment

Dennis Tolson Environmental Monitoring and Reporting Branch Ontario Ministry of the Environment

vii

BACKGROUND

The Ontario Ministry of Transportation (MTO) is responsible for the maintenance of over 800 bridges. Additional structures throughout the province are also maintained by municipal governments.

Corrosion is the destruction of metal by chemical or electrochemical reaction with the environment. Rust is the visible result of this process. If corrosion is not controlled properly it can significantly affect the durability and safety of steel structures such as bridges.

Bridges are continually subject to the affects of corrosion. Painting is the main method of corrosion control for bridges and failure of the coating system . invariably leads to material and performance defects of a structure's steel components. The related safety problems and rehabilitation costs are a major concern to public agencies such as MTO.

To achieve the best quality coating on a bridge, the old coatings, rust and scale must be removed. Several removal methods are available, all of which have the potential to result in emissions to the environment (e.g. dust and paint chips. containing lead) if proper environmental management practices are not followed.

These "Guidelines" are intended as a reference source for contractors, employees of custodial agencies (e.g. MTO and municipal governments), and inspectors of regulatory agencies (e.g. Ministry of Environment and Energy) involved in ensuring that our environment is not compromised in the process of carrying out bridge coating work. It includes interpretation of environmental legislation, monitoring of potential emissions, and waste management considerations. The guidelines also make reference to site management practices, training and emergency response planning, appropriate to contractors involved in bridge coating work.

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CHAPTER 1

THE STRUCTURAL STEEL COATING REHABn.ITATION PROCESS AND POTENTIAL EMISSIONS/WASTE STREAMS

1 THE STRUCTURAL STEEL COATING REHABILITATION PROCESS AND POTENTIAL EMISSIONS/WASTE STREAMS

1.1 Introduction

The Structural Steel Coating Rehabilitation (SSCR) process involves removal of the existing paint, and the application of a new coating system.

The process used to remove coating from steel surfaces is known as surface preparation. Surface preparation equipment can be grouped into three main categories:

1) hand tools;

2) power tools; and

3) abrasive blasting equipment.

In addition to the above, water blast cleaning may become a suitable alternate method of surface preparation in the future (contaminants, such as salt and metals, require that excess water be contained and collected for treatment).

The type of surface preparation equipment used can be dependant on site and structure characteristics. Different types of surface preparation equipment may be used on the same project. As an example, abrasive blast cleaning may be supplemented with hand and/or power tools to clean small surfaces that are difficult to access.

1.2 1be Stmctural Steel Coatiq RebabUitation Process

The first step of SSCR involves the removal of dirt, oil, grease and other residues from the steel surface using rags and solvent, hand scrappers, wire brushes and/or low pressure water.

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During coating removal, containment systems are constructed around the work area to minimize the escape of dust, paint chips, and abrasive. The extent and type of enclosure may vary throughout the project and from site to site, depending on the surface preparation method(s) used.

Spent abrasive, paint chips and dust collected by the enclosure may be removed manually (e.g. shovelling and sweeping) or by vacuum. Prior to recoating, residual dust and debris is cleaned from the steel surface so the new coating system properly adheres to the prepared surface.

Spray equipment is the most common method used to apply coatings. Hand brushes may be used to coat small and difficult to reach areas such as beam ends.

The final step is the dismantling of the enclosure. Prior to dismantling, the enclosure is cleaned of any remaining spent abrasive/debris. Residual dust and debris are vacuumed from the enclosure to prevent the escape of material that may have collected in joints and seams, or may remain on the surface of floors, walls etc... Larger bridges may be completed in sections, requiring the enclosure to be vacuumed and relocated several times.

1.3 Potential Waste Streams/Fmiuions

Wastes and emissions, that may be generated during the SSCR process, are presented in Figure 1.

Prior to the 1970's, lead was a common additive in the manufacture of coatings. As a result, wastes and emissions generated during the SSCR process may contain elevated lead concentrations, as well as trace amounts of other metals such as chromium and cadmium. Silica may also be found in wastes and emissions, where silica sand abrasive is used.

Off-specification coatings, and spent solvents from cleaning operations (e.g. bridge surfaces and coating equipment) are also hazardous materials of concern.

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• • • • • • • • •

• • • • • • • • • •

• • • • • • • • • • • • • • •

• • • • • •

• • • • •

• • • • • •

• • • • • •

;o • • • • • • • • • • • • •

• • • • • • • • • •

• • • • • • • • • •

•

•

Figure 1: Potential Emissions/Waste Streams from Strudural Steel Coating Rehabilitation

D e I

v e r y

s u r f a c e

p r e p a r a t

0

n

c 0

a t i n g

c I e a n

u p

ABRASIVES, SOLVENTS AND COATINGS POTENTIAL EMISSIONS/WASTE STREAMS

....__""T""_ __. • DRIPS, SPILLS to ground e OFF-SPEC MATERIAL to recycling/disposal facility

sne Storage • DRIPS, SPILLS to ground e OFF-SPEC MATERIAL to recycling/disposal facility

• CLOTHING to disposal • RESPIRATOR CARTRIDGES to disposal • WASHWA TER to treatment/disposal

RerncMIIof Grease Using

Solvent • SOLVENT CONTAINERS, RAGS to disposal • SPILLS to ground, surface water e SOLVENT EVAPORATION into air

Abrasive Blasting, Hanc:IIPower Tool Cleaning, Water Blasting

• PAINT CHIPS, ABRASIVE, WASTEWATER & FILTERS to disposaVrecycling facility

• SPILLS to ground, surface water • DUSTtoair

• PAINT CHIPS, ABRASIVE & FILTERS to disposaVrecycling

• SPILLS to ground, surface water • DUSTtoair

Coating end Overcoldlng • PAINT CONTAINERS, RAGS to disposal e SOLVENTS/PAINT to recycling/disposal • OVERSPRA Y/SPILLS to ground, surface water e SOLVENT EVAPORATION

vacuuming & Reloclltion of Containment

• PAINT CHIPS, ABRASIVE to disposaVrecycling • SPILLS to ground, surface water • DUSTtoair

Project Completion

e DAMAGED CONTAINMENT MATERIAL to disposal • CONTAMINATED SOIL to disposal

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1.3.1 Air Fmi~lons

Potential air emissions include dust from surface preparation, waste cleanup/handling and containment relocation, as well as overspray from coating operations.

Abrasive blasting operations typically generate significantly greater amounts of dust than power tool or hand tool cleaning. The type of abrasive may also impact on the level of dust generated. For example, silica sand abrasive tends to result in more dust than recyclable steel grit.

1.3.2 liquid wastes

Liquid wastes are limited to water from water blasting operations and washwater from on-site showers and laundry facilities. Other potential liquid wastes include off-specification coatings, spent solvent, and leaks or accidental spills of coatings and solvents.

1.3.3 Solid Wastes

The main types of solid wastes are paint chips and spent abrasive from surface preparation operations.

Other potential solid wastes include:

1) filters from dust collection systems and recycling equipment;

2) cartridges from breathing equipment;

3) disposable clothing and visors;

4) waste containment materials;

5) empty paint and solvent containers;

6) rags with solvent and paint; and

7) soil contaminated by accidental spills during the course of operation.

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1.4 Waste Management

Under Ontario Regulation 347, it is the responsibility of the generator to properly classify waste materials prior to disposal and manage them accordingly. Procedures for emissions monitoring, waste sampling and classification are presented in Chapters 5 and 6.

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CHAPTER.l

INTERPRETATION OF ENVIRONMENTAL LEGISLATION, STANDARDS AND POLICY GOALS

2 INTERPRETATION OF ENVIRONMENTAL LEGISLATION, STANDARDS AND POUCY GOALS

2.1 Introduction

This chapter is intended to provide an overview of the environmental legislation, policies and guidelines affecting Structural Steel Coating Rehabilitation (SSCR) . projects. Although legislation is quoted in part throughout the chapter, the reader is encouraged to reference official documents for further detail and clarification.

The agency primarily responsible for enforcing environmental legislation in Ontario is the Ontario Ministry of Environment and Energy (MOEE). The principal pieces of environmental legislation affecting Structural Steel Coating Rehabilitation (SSCR) projects, and enforced by the MOEB, are;

(1) The Environmental Protection Act (EPA);

(2) Ontario Regulation 346 (under EPA) governing air emissions;

(3) Ontario Regulation 347 (under EPA) governing waste management; and

(4) The Ontario Water Resources Act (OWRA).

Other environmental legislation that may impact on SSCR operations include the Fisheries Act and Transportation of Dangerous Goods Act. Both pieces of legislation have been introduced by the federal government, but are enforced by provincial Ministries.

The Fisheries Act is intended to protect fisheries resources, as well as fish habitat, and is enforced by The Ontario Ministry of Natural Resources (MNR).

The Transportation of Dangerous Goods Act (TDGA) regulates the handling, offering for transport and transportation of dangerous goods by air, rail, road and marine transport. The portion of the Act governing highway transportation is enforced in Ontario by the Ministry of Transportation through the Dangerous Goods Transportation Act (DGTA). Enforcement with respect to air, rail, and marine transport is the jurisdiction of the Federal government.

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In addition to the above, the MOEE has a number of guidelines and policies that have the potential to impact SSCR projects. These include;

(1) The Ontario Decommissioning Guidelines;

(2) provincial waste reduction, reuse and recycling goals; and

(3) provincial goals to reduce emissions of volatile organic compounds (VOCs).

l.l The Environmental Protection Act (EPA)

The Environmental Protection Act is the primary piece of environmental legislation in Ontario. The Act is administered by the MOEE, and contains a number of general provisions governing discharges/emissions to the environment. In addition, Regulations 346 (governing air emissions) and 347 (governing waste management), also under the EPA, have a direct impact on SSCR work.

2.2.1 EPA- Section 1

Section 1 contains definitions to help interpret the Act. The following definitions have been taken from the section;

"contaminant" means any solid, liquid, gas, odour, heat, sound, vibration, radiation or combination of any of them resulting directly or indirectly from human activities that may cause an adverse effect;

"adverse effect" means one or more of:

a) impairment of the natural environment for any use that can be made of it;

b) injury or damage to property or to plant or animal life;

c) harm or material discomfort to any person;

d) an adverse effect on the health of any person;

e) impairment of the safety of any person;

t) rendering any property or plant or animal unfit for human use;

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g) loss of enjoyment of normal use of property; and

h) interference with the normal conduct of business.

"discharge", when used as a verb, includes add, deposit, leak or emit and, when used as a noun, includes addition, deposit, emission or leak;

"natural environment" means the air, land and water, or any combination or part thereof, of the Province of Ontario;


EPA, Section 6 is a general provision that prohibits the discharge of contaminants in excess of established standards. The provision reads as follows;

"No person shall discharge into the natural environment any contaminant, and no person responsible for a source of contaminant shall permit the discharge into the natural environment of any contaminant from the source of the contaminant, in an amount, concentration or level in excess of that prescribed by the regulations."

Air emission standards are presented in Schedule 1 of Regulation 346 and include maximum concentrations at the point of impingement for suspended particulate matter (i.e. dust) and lead.


EPA, Section 13 (1) requires the Ministry to be notified when contamination exceeds a permitted level. The provision reads as follows;

"Every person,

a) who discharges into the natural environment; or

b) who is the person responsible for a source of contaminant that discharges into the natural environment, any contaminant in an amount, concentration or level in excess of that prescribed by the regulations shall forth with notify the Ministry of the discharge."

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EPA, Section 14 (1) is the general provision that prohibits the discharge of a contaminant that causes an adverse effect. This includes dust, odour and noise that may result from SSCR operations. The provision reads as follows;

"Despite any other provision of this Act or the regulations, no person shall discharge a contaminant or cause or permit the discharge of a contaminant into the natural environment that causes or is likely to cause an adverse effect."


EPA, Section 20 requires compliance by all Crown Corporations and Government Ministries.

2.2.6 EPA- Section 92, Part X, Spills

EPA, Section 92 (1) requires that spills be reported to the Ministry. The provision reads as follows;

"Every person having control of a pollutant that is spilled and every person who spills or causes or permits a spill of a pollutant that causes or is likely to cause an adverse effect shall forthwith notify the following persons of the spill, of the circumstances thereof, and of the action that the person has taken or intends to take with respect thereto,

a) the Ministry;

b) the municipality or, if the spill occurred within the boundaries of a regional municipality, the regional municipality within the boundaries of which the spill occurred;

c) where the person is not the owner of the pollutant and knows or is able to ascertain readily the identity of the owner of the pollutant, the owner of the pollutant; and

d) where the person is not the person having control of the pollutant and knows or is able to ascertain readily the identity of the person having control of the pollutant, the person having control of the pollutant.

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2.2.7 EPA -Section 93

EPA, Section 93 (1) requires that the adverse effects resulting from a spill are cleaned up. The provision reads as follows;

"The owner of a pollutant and the person having control of a pollutant that is spilled and that causes or is likely to cause an adverse effect shall forthwith do everything practicable to prevent, eliminate and ameliorate the adverse effect and to restore the natural environment."

2.3 Regulation 346, EPA- General Air Pollution

Regulation 346 is intended to control air emissions from commercial and/or industrial operations. Under the regulation, most facilities that produce emissions are required to obtain a Certificate of Approval (C of A). In addition, Schedule 1 of the regulation sets maximum contaminant concentrations that shall not be exceeded at the point of impingement. These standards apply to facilities operating under a C of A, as well as "approval exempt" facilities.

2.3.1 Regulation 346- Section 3

Section 3, Item 4 of the regulation exempts equipment used for highway construction and maintenance from the normal approval process. This includes equipment used during SSCR. However, as mentioned above, "approval exempt" operations must still comply with emission standards and other general provisions in the regulation and EPA. The provision that provides the exemption reads as follows;

"The following sources of contaminant are classes for which the approval of the Director as to the plans and specifications is not required under section 9 of the Act:

4. "Equipment for construction or maintenance of a highway while the equipment is being used on the highway."

2.3.2 Regulation 346- SubsectionS (3)

Subsection 5 (3) prohibits the discharge of a contaminant that exceeds a standard prescribed in Schedule 1 of the Regulation as measured at a point of

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impingement such as a neighbouring property or building. Schedule 1 contains standards for dustfall, lead, suspended particulate matter, and some of the common solvents. All of these contaminants may be emitted from a SSCR project. The standards for dustfall, lead, and suspended particulate are given in Section 6. Please refer to Schedule 1 in Regulation 346 for other contaminants.

2.3.3 Regulation 346 - Subsection 8 (1)

Subsection 8 (1) (b) prohibits the discharge of a visible emission (e.g. sand, dust or coating overspray) that has an opacity greater than 20 %. The provision reads as follows;

"Subject to subsection (2}, no person shall cause or permit to be caused a visible emission;

b) that obstructs the passage of light to a degree greater than twenty per cent at the point of emission."

2.3.4 Regulation 346 - Section 9

Section 9 of the regulation requires that any emissions resulting from a failure of equipment or change in operating practices (e.g emissions from enclosures, baghouses etc ...) shall be reported to the MOEE. The provision reads as follows;

"Where at any stationary source of air pollution a failure to operate in the normal manner or a change in operating conditions occurs, or a shut-down of the source or part thereof is made for some purpose, resulting in the emission of air contaminants that may result in quantities or concentrations in excess of those allowed in Sections 5, 6 and 8,

a) the owner or operator of the source of air pollution shall,

i) immediately notify a provincial officer and furnish him or her with particulars of such failure, change or shutdown; and

ii) furnish the provincial officer with the particulars in writing, as soon as is practicable, of such failure, change or shut-down; and

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b) if the provincial officer considers it advisable, the officer may authorize, in writing, the continuance of such operation for such period of time as he or she considers reasonable in the circumstances and may impose upon the owner or operator such terms and conditions for such continued operation as the officer considers necessary in the circumstances."


Section 11 of the regulation refers specifically to sandblasting and prohibits the discharge of a contaminant to an extent greater than that which would result ifall steps necessary had been taken.

"Except for heat, sound, vibration or radiation, no person shall,

a) construct, alter, demolish, drill, blast, crush or screen anything or cause or permit the construction, alteration, demolition, drilling, blasting, crushing or screening of anything so that a contaminant is carried beyond the limits of the property on which the construction, alteration, demolition, drilling, blasting, crushing or screening is being carried out; or

b) sandblast or permit the sandblasting of anything so that a contaminant is emitted into the air, to an extent or degree greater than that which would result if every step necessary to control the emission of the contaminant were implemented."


Section 13 of the regulation prohibits fugitive dust emissions such as might occur when waste sand is dumped into a garbage container or transported to a disposal site. The provision reads as follows;

"No person shall store, handle or transport any solid, liquid or gaseous material or substance in such manner that an air contaminant is released to the atmosphere."

2.3.7 Regulation 347, EPA- General Waste Management

This regulation governs the collection, storage, transport and disposal of all waste materials in the Province of Ontario. Generally speaking, the more hazardous the

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waste, the greater the degree of care and control that must be exercised by the persons responsible for the waste.

Regulation 347 requires that generators of Subject Waste (refer to Chapter 6 for definition of Subject Waste) file a Generator Registration Report (GRR) with the MOEE. In the GRR, the generator, which at a SSCR project would be the owner of the bridge, must classify the type of wastes that will be produced. The regulation also requires that all wastes be transported by MOEE approved waste carriers to waste disposal sites approved to receive the class of waste involved in the transaction. The movement of Subject Waste must be recorded on shipping manifests which are submitted to the MOEE.

2.4 Ontario Water Resources Act (OWRA)

The purpose of OWRA is to manage the quality and quantity of surface water and ground water resources. The Act protects against discharges that may negatively impact water quality and requires permits to take water. It is binding on the crown and also has a penalties system independent of the EPA.

2.4.1 OWRA - Section 1

OWRA, Section 1 contains definitions to help interpret the Act. Selected definitions, taken from the Section, are presented below;

"discharge", when used as a verb, includes add, deposit, leak or emit and, when used as a noun, includes addition, deposit, emission or leak;

"waters" mean a well, lake, river, pond, spring, stream, reservoir, artificial watercourse, intermittent watercourse, ground water or other water or watercourse;"


Section 2 binds the Crown. All Crown Corporations and Ministries must comply with the Act.

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Section 30 of the Act prohibits the discharge ofpolluting material into any waters or any place from where it may flow into any waters and requires that such a discharge be reported to the Ministry. Polluting materials commonly found at SSCR projects include spent abrasives, paint chips, paint, solvents and fuels. The provision reads as follows;

(1) "Every person that discharges or causes or permits the discharge of any material of any kind into or in any waters or on any shore or bank thereof or into or in any place that may impair the quality of the water of any waters is guilty of an offence.

(2) Every person that discharges or causes or permits the discharge of any material of any kind, and such discharge is not in the normal course of events, or from whose control material of any kind escapes into or in any waters or on any shore or bank thereof or into or in any place that may impair the quality of the water of any waters, shall forthwith notify the Minister of the discharge or escape, as the case may be."


OWRA, Section 34 requires that a permit to take water be obtained for water takings in excess of 50,000 litres in a day. This requirement may be a factor for projects involving waterblasting.

2.5 Fisheries Act

The Fisheries Act is federal legislation, administered by the provincial Ministry of Natural Resources. The Act is intended to protect fish and fish habitat. Under the Act, permits are required for work that may significantly alter fish habitat.

2.5.1 Fisheries Act- Section 35 (1)

Section 35 (1) of the Act protects fish habitat and reads as follows;

"No person shall carry on any work or undertaking that results in the harmful alteration, disruption or destruction of fish habitat."

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2.5.2 Fisheries Act - Section 36 (3)

Section 36 (3) of the Act protects fish and reads as follows;

"No person shall deposit or pennit the deposit of any deleterious substance into any water frequented by fish. n

It should be noted that a deposit of silt or other fine material (e.g abrasive) has the potential to be deleterious to fish and to alter fish habitat in a harmful manner as it fills in and destroys spawning areas and food resources typical of well aerated, riffle habitat.

2.6 Guidelines For The Cleanup Of Industrial Sites In Ontario

These guidelines are commonly referred to as the Ontario Decommissioning Guidelines, and establish water and soil clean-up criteria for a number ofpotential contaminants of concern including lead. The criteria for any one contaminant may vary depending on the use of the property (e.g agricultural, residential, commercial, or industrial).

The guidelines generally come into affect when a property is to be decommissioned and redeveloped. However, property owners and purchasers often use the guideline criteria as a means of measuring the environmental quality/liabilities of a site. The guidelines may be followed at SSCR projects to determine if soil had been contaminated during the project, and the degree of clean-up required. In this situation, the main contaminant of concern at the SSCR project would be lead, although other contaminants may also be of concern.

The most recent guideline criteria for lead in soil and in groundwater are given in Table 1. Where actual lead concentrations exceed the guidelines, the soil and/or groundwater would be considered to be contaminated. If a clean-up was carried out, any lead contaminated soil would have to be managed as a waste under Regulation 347.

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TABLE 1: CLEANUP GUIDELINES FOR LEAD IN SOll.S AND GROUNDWATER

SOIL CLEAN-UP CRITERIA GROUNDWATER CRITERIA

AGRICULTURAL RESIDENTIAL & PARKLAND

INDUSTRIAL & COMMERCIAL

ALL LAND USE CATEGORIES

200 ppm 200 ppm 1000 ppm 10 ppb

2.7 Reduce, Reuse and Recycle- Goals

The 3Rs hierarchy (i.e. reduce, reuse and recycle) is the primary component in Ontario's Waste Reduction Action Plan. Ontario has achieved its 1992 goal of a 25% reduction from 1987 levels in the amount of waste going into municipal disposal systems. The goal for the year 2000 is a minimum of a 50% reduction. Regulations have been passed for certain sectors of the economy to ensure that the goal is obtained. However, SCCR projects, are not presently covered by these regulations. Voluntary actions to reduce waste at SSCR projects should be encouraged and the potential for reductions in disposal costs should not be overlooked.

For many job sites, local municipalities or private operators will have systems in place for the recycling of segregated wood, cardboard, paper, and other waste materials.

The reuse of abrasives materials is encouraged by the MOEE. Adequate controls must be in place to ensure that any processing of waste abrasives to recover the reusable fraction does not result in any significant environmental effects.

2.8 Volatile Organic Compounds - Goals

The Canadian Council of Ministers of the Environment (CCME) agreed in principle to a "Management Plan For Oxides Of Nitrogen (NOx) And Volatile Organic Compounds (VOCs) - Phase 1 ". The plan recommends a 25% reduction in NOx and VOCs emissions from 19851evels, within the Quebec City-Windsor corridor, by the year 2005. Vapour recovery at fuel distribution systems, control

17

of dry cleaner emissions, control of stationary combustion turbine emissions, reduction in gasoline volatility and vehicle inspection and maintenance are some of the measures being considered by the Ontario government in support of the Plan.

At SSCR projects, VOCs will be emitted from paint thinners and solvents and from motor vehicles and gasoline powered engines. Voluntary maintenance programs for motor vehicles and engines and the voluntary use of low VOC coatings will further assist in meeting Ontario's reduction targets.

2.9 Transportation of Dangerous Goods

There is both federal and provincial legislation regulating the transportation of dangerous goods. The Transportation of Dangerous Goods Act (TOGA) and its regulations comprise the federal legislation. In Ontario, the Dangerous Goods Transportation Act (DGTA) mirrors the federal Act and the Ontario regulation adopts the federal regulations as they apply to on highway transportation only. MTO is responsible for enforcing the provincial legislation only.

At SSCR projects, the contractor could possibly be a receiver of dangerous goods such as paints or solvents. Under TOGA, the legal requirements for receivers include TOGA training of staff; reporting dangerous occurrences and missing consignments; signing shipping manifests; and retaining shipping manifests on file for a minimum of two years.

The contractor at SSCR projects may also be a shipper of dangerous goods when waste solvents or other hazardous wastes are shipped for disposal. In this situation, the shipper is required under the TOGA to train staff, prepare packaging, complete shipping documentation and provide all required safety marks and placards.

2.10 Environmental Situations And Responses

Table 2 and 3 summarize the actions required for a number of situations that may develop at a SSCR project and potential fines or penalties. The tables are not all inclusive and are intended as a quick reference aid only. It is recommended that the reader refer to the actual legislation for detailed information and interpretation.

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TABLE 2: ENVIRONMENTAL SITUATIONS AND RESPONSES

SITUATION LEGISLATION SECTION ACTION REQUIRED

spill - paint, fuel, dust, waste

EPA Part X

92 (1) a 92 (1) b 93 (1)

-report to MOEBt,3

-report to Municipality -stop spill and clean-up

generate subject waste4 Reg. 347 18 (1) -submit Generator Registration Report to MO~

store subject waste more than 3 months

Reg. 347 18 (10) -report to Regional MOEE Director3

ship subject waste Reg. 347 41 19 (1) 23 (2)

-use certified hauler -complete manifest -mail manifest to MOEE:z -keep manifest copy

ship non-subject waste EPA 41 -use certified hauler

abnormal discharge to water

OWRA 30 -report to MOEE1,3

-control discharge -clean up

emit dust from sandblasting EPA

Reg. 346

14 & 15

11 & 13

-report to MOEE1,3

-control discharge -clean up

air management equipment failure

Reg. 346 .

9 -report to MOEE1,3

-follow MOEE directions -repair equipment

Notes:

1) For Spills Reporting call the MOEE Spills Action Centre at 1-800-268-6060. 2) Environmental Monitoring and Reporting Branch, Area "M", 135 St. Clair Ave. W.,

Toronto, M4V 1PS (416-313-7995). 3) For a list of MOEE Regional and District Offices see Appendix A. 4) For definition of subject waste see Chapter 7.

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TABLE 3: PENALTIES UNDER THE ENVIRONMENTAL PROTECTION ACT

VIOLATION FIRST OFFENCE SUBSEQUENT OFFENCE

general penalty individual $ 10,000 max. $ 25,000 max.

corporation $ 50,000 max. $ 100,000 max.

actual pollution (Section 14)

individual $ 10,000 + 1 year max.

$ 25,000 + 1 Year max.

corporation $ 2, 000 to $ 200 '000

$ 4, 000 to $400,000

hazardous waste individual $ 2 '000 to $ 10,000 + 1 Year

$ 4 '000 to $ 25,000 + 1 Year

corporation $ 2 '000 to $ 100' 000

$ 4,000 to $200,000

hazardous waste & adverse effect

individual $ 2 '000 to $ 50,000 +!Year

$4,000 to $ 100,000 + 1 Year

corporation $ 2 '000 to $ 1 '000 '000

$4,000 to $2,000,000

Notes:

1) Penalties under the Ontario Water Resources Act are identical to those under EPA, except the maximum fines for corporations for "actual pollution" are $100,000 for first offenses and $200,000 for subsequent offenses.

2) A fine equal to any monetary benefit (savings) acquired by the accused may be added for any offence.

3) Licences may be suspended or refused if fines not paid. 4) Probation orders may be issued for any offence. 5) Court orders may be issued to protect and restore the environment.

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2.11 Due DiJi&ence

Most environmental offences fall within the category known as strict liability offences. In a strict liability offence, the onus is on the defendant to prove to the Court, on a balance of probabilities, that they took all reasonable care and thus exercised due diligence. The efforts required to establish due diligence will vary with each project depending upon several factors.

In one Ontario court case, Judge Hackett stated "reasonable care and due diligence do not mean superhuman efforts. They mean a high standard of awareness and decisive, prompt and continuing action." (R. vs Commander Business Furniture and Raymond T. Hanson (1993), 9 C.E.L.R.(N.S.) 185 (Ontario Court (Prov. Div.))

Judge Hackett went on to list a number of factors that should be weighed and assessed in determining if there was due diligence. These factors include, but may not be limited to, the following:

1) the nature and gravity of the adverse effect;

2) the foreseeability of the effect including abnormal sensitivities;

3) the alternative solutions available;

4) legislative or regulatory compliance;

5) industry standards;

6) the character of the neighbourhood;

7) what efforts were made to address the problem;

8) over what period of time and the promptness of the response;

9) matters beyond the control of the accused including technological · limitations;

10) skill level expected of the accused;

11) the complexities involved;

12) preventative systems;

13) economic conditions; and

14) actions of officials.

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CHAPI'ER. 3

PREPARATION METHODS AND COATING SYSTEMS

3 PREPARATION METHODS AND COATING SYSTEMS

3.1 Introduction

The process used to remove existing coating from steel structures is referred to as surface preparation.

Surface preparation is the most important single factor in obtaining good performance from reapplied coating systems. The surface preparation effort required to remove an existing coating system is dependant on the condition of the coating, the condition of the substrate, and the kind of coating to be reapplied.

The Ontario Ministry of Transportation (MTO) uses specifications developed by the Steel Structures Painting Council (SSPC), when defining the degree of surface preparation required. These specifications are:

(1) SSPC specification for "Solvent Cleaning" (SPl);

(2) SSPC specification for "Hand Tool Cleaning" (SP2);

(3) SSPC specification for "Power Tool Cleaning" (SP3);

(4) SSPC specification for "White Metal Blast Cleaning" (SP5);

(5) SSPC specification for "Commercial Blast Cleaning" (SP6);

(6) SSPC specification for "Brush-Off Blast Cleaning" (SP7) by MTO staff for touch-up work;

(7) SSPC specification for "Near White Blast Cleaning" (SPlO); and

(8) SSPC specification for "Power Tool Cleaning To Bare Metal" (SPll).

3.2 Surface Preparation Methods

The equipment most commonly used for surface preparation can be grouped into the following main categories;

(1) hand tool cleaning;

(2) power tool cleaning, with and without a vacuum capability;

(3) abrasive blasting, with and without a vacuum capability; and

(4) methods that employ water or a combination of water and abrasive.

In addition to the above, solvent cleaning is used as a first step to remove oil and grease. Also, surface preparation technologies may be used in combination depending on site specific characteristics. For example, abrasive blasting may be supplemented with hand and/or power tools to clean small surfaces and surfaces that are difficult to access.

The various methods and equipment that may be used to prepare or clean steel surfaces to SSPC specifications are presented below.

3.2.1 Solvent Cleaning

Solvent cleaning is used to remove heavy oil or grease from the steel surface. Although used infrequently, solvent cleaning is typically carried out prior to removal of the existing coating system using other methods of surface preparation. If left on the surface, blast cleaning may force oil and grease into the steel profile causing adhesion problems when the new coating system is applied.

3.2.2 Hand Tool Cleaning

Hand tool cleaning equipment consists ofwire brushes, chipping hammers, chisels and scrapers. Hand cleaning is carried out in the following circumstances:

(1) when the coating is in reasonably good condition with only a few deteriorated spots; and

(2) to prepare rivets, welds, comers, joints, and other "blind" spots that blast cleaning cannot reach.

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3.2.3 Power Tool Cleaning

Examples of power tool cleaning equipment include scalers, rotary scarifiers, disc sanders, and rotary wheel flap tools.

Power tool cleaning is most commonly used to:

(1) replace slower methods of hand tool cleaning;

(2) clean areas not accessible to blast cleaning;

(3) clean areas where traffic prohibits the use of blast cleaning equipment;

(4) roughen the surface for better coating adhesion; and

(5) clean large areas with very thick, heavy corrosion.

3.2.4 Vacuum Power Tool Cleaning

Vacuum power tool cleaning involves fitting vacuum shrouds to traditional surface preparation equipment to contain, collect, and separate spent abrasive blast media (separated abrasive is recycled on site) and removed coating material. The vacuum power tools typically used include needle guns, rotary scarifiers, rotary wheel flap tools and disc sanders. Productivity rates are dependant on the thickness and type of coating being removed and the specified degree of cleaning.

3.2.5 Abrasive Air Bast Cleaning

Abrasive air blast cleaning is the most widely used surface preparation method. It is the fastest, most productive method and provides a well roughened surface to which the new coating system adheres more easily.

This method achieves coating/rust removal by impacting the steel surface with a continuous stream of abrasive propelled by compressed air through a nozzle. The abrasive normally bombards the substrate at about 689 KPa (100 psi).

Both metallic and non-metallic abrasives can be used in air blast cleaning operations. Metallic abrasives are normally separated from removed coating material on-site and recycled until the material is no longer effective (i.e. due to breakdown). Most non-metallic abrasives (except aluminum oxide and specular hematite) cannot be recycled and are collected for off-site disposal, or reuse in

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secondary products/processes.

Air blast cleaning productivity rates range from 17 to 27 m2/hr, depending on the abrasive. These rates may be achieved using a 9.5 mm orifice nozzle at 689 KPa to clean to a near white finish.

3.2.6 Vacuum Abrasive Blasting

This method is similar to abrasive air blast cleaning except that the vacuum contains and collects the abrasive blast media and removed coating material at the nozzle.

Aluminum oxide or steel grit are normally used as abrasives, and they are typically recycled on-site. Productivity rates range from 6 to 12 m2/hr and are dependant on the thickness and type of coating being removed and the specified degree of cleaning.

3.2.7 Water Blast Cleaning

Water blast cleaning typically involves a jet of water between 13780 KPa (2000 psi) to 137800 KPa (20000 psi). The primary use of this technology is to remove oil, grease and dirt. It may also remove coating, but not scale.

Coating removal productivity rates range from 2 to 56 m2/hr and are dependant on the thickness and type of coating being removed. It is about three times slower than abrasive air blast cleaning due to it's smaller "footprint" ( 5 em wide versus 15 em). In addition, ultra-high jetting (i.e water blasting at pressures > 137800 KPa) is viewed as the only way to remove soluble salts from steel substrate.

Water blasting reduces airborne dust levels, but at the same time, generates a liquid waste stream that must be contained and collected for disposal. Once collected, dust and debris can be removed using filtration and the water reused, thereby lowering the volume of liquid waste that is generated.

There are two other methods that employ water: air abrasive wet blasting ("water ring") and water jetting with injection of abrasives. These methods are discussed below in Sections 3.2.8 and 3.2.9.

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3.2.8 Air Abrasive Wet Blasting

Air abrasive wet blasting employs a water spray, or mist, in combination with air blast cleaning. The dry air-abrasive mixture leaves the nozzle at 620 to 689 KPa and is surrounded by a water ring (413 to 689 KPa).

The technology is used for two reasons:

(1) to reduce airborne dust; and

(2) lower ionic contamination of the steel surface.

Productivity rates vary from 6 to 18 m2/hr and are dependant on the coating that is being removed. The removal rate for thick coal tar epoxy coating is at the lower end of the range (i.e. 6 m2/hr), whereas the removal rate for a thin or brittle film, such as aged epoxies or alkyds, is > 9m2/hr.

3.2.9 Water BJastiD& With Abrasive IIUection

In this method the abrasive is co-injected into the water system at water pressures between 13780 and 137800 KPa (2000 to 20000 psi). Abrasive consumption is variable, but less than that of air blast cleaning (ie: < 15 to 39 kg./m.~. Water is consumed at between 0.8 and 0.9 litre/second. Unlike water blast cleaning, it can impart a profile to the substrate and remove scale from a steel surface. Productivity rates range from 2 to 9 m2/hr depending on the coating being removed, but are lower than productivity rates for air blast cleaning.

3.3 Abrasives Used In Air Blast Cleaning

A rough steel surface is necessary to enable effective adhesion of the new coating system. This surface roughness, known as the surface profile, must be between 25 and 75 microns. Written standards in conjunction with reference photographs are used to judge the acceptability of the cleaned surface.

Abrasives can be grouped into two categories - metallic and non-metallic. Both metallic and non-metallic abrasives can achieve surface profile requirements.

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3.3.1 Metallic Abrasives

Metallic abrasives (eg: steel shot and grit) are normally used in shop blasting operations with recovery facilities. Steel grit is being used with more frequency on-site, due to recent advances in portable recovery machinery.

3.3.2 Non-Metallic Abrasives

Non-metallic abrasives are classified into three sub-groups:

(1) naturally occurring abrasives;

(2) abrasives from by-products; and

(3) manufactured abrasives.

Naturally occurring abrasives include silica sand, syenite and olivine. These abrasives are relatively inexpensive and come in a wide range of product sizes, but lack the effectiveness and recycling capability of other types. High dust and silica levels are also a drawback because of environmental protection requirements and worker exposure.

Silica sand is the most often used abrasive because it is relatively cheap, has a good cutting action, and can be sized to achieve the specified profile.

By-product abrasives include:

(1) Black Beauty, a residue from coal-burning boilers; and

(2) Ebony Black, a residue from iron smelting.

Black Beauty is a common abrasive and produces a slightly higher surface profile compared to silica sand.

Examples of manufactured abrasives include aluminum oxide, glass beads, and silicon carbide. Manufactured abrasives can be tailor-made for specific purposes but are typically more expensive than natural or by-product abrasives. They are generally not used for highway bridges.

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3.4 Coating Systems Used By The Ontario Ministry of Transportation

A number of different coating systems are used by MTO. Prior to use, the systems are subject to an approval process involving laboratory tests. Successful or approved coatings are listed in the Ministry's Designated Sources Manual (DSM).

A brief summary of the coating systems that have been used by MTO are presented below in sections 4.4.1 through 4.4.10.

3.4.1 Three Coat Alkyd System

Discontinued in 1974, the three coat alkyd system is the first used by MTO. The individual coats that make up this system are:

(1) a red, lead primer coat;

(2) a light grey mid-coat; and

(3) a green, or grey top coat.

3.4.2 Jli&h Bulld Alkyd System

This system was used on MTO structures from 1974 to approximately 1985. The individual coats that make up this system are:

(1) a yellow zinc chromate primer (1 or 2 coats), followed by;

(2) a green, alkyd top-coat for handrails or a grey, alkyd top-coat for beams.

3.4.3 Aluminum-Filled Epoxymastic System

This system has been in use since 1982, primarily on carbon steel bridges. It has also been used on atmospheric corrosion resistant (weathering) steel, under expansion joints. The system, discontinued in 1988, consists of two coats of aluminum coloured epoxymastic.

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3.4.4 Hot Dip Galvanizing

Hot dip galvanizing has been used to coat Bailey bridges and handrails, since 1970. MTO has coated three bridges using hot dip galvanizing since 1991. The process involves the off-site application of zinc to steel. The end product is recognizable by it's smooth, large grain, shiny to semi-dull appearance.

3.4.5 ~~

Metallizing has been used to coat Bailey bridges and handrail posts since 1970. The process involves the spray coating of zinc or zinc/aluminum. The end product is recognizable by a coarse or gritty surface appearance resembling sandpaper.

Since 1991, the meta11ized surfaces of handrail posts have been protected with a grey vinyl top coat.

3.4.6 Coal Tar Epoxy

This system is black, or dark brown in colour and in the past has been used on the inside of box girders. It is now specified for steel piles.

3.4.7 Inorpnic-Zinc/Epoxy/Urethane System

This system was applied to an end span of Hoggs Hollow bridges in 1990. The individual coats that make up the system are:

(1) a reddish grey to greenish grey, inorganic-zinc primer;

(2) a green, or white, epoxy coat; and

(3) a grey, urethane top-coat.

3.4.8 Coal Tar For Piles

This system is black in colour and has been used on inaccessible steel, behind abutment diaphragms, and on steel piles. The system has been discontinued by MTO.

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3.4.9 Inorganic Zinc/Vinyl System

This system has been in use since 1982. It is the primary system used to coat girder type bridges. The individual coats that make up the system are:

(1) a reddish grey to greenish grey, inorganic-zinc primer;

(2) a reduced vinyl wash-coat, or proprietary tie-coat that is white, green or grey;

(3) a green high-build, vinyl coat; and

(4) a high-build, vinyl top-coat that is grey or green.

3.4.10 Epoxy-Zinc/Vinyl System

This system was first used in 1987 and is the main system for truss type bridges. The individual coats that make up the system are:

(1) a green, or reddish grey, organic zinc primer;

(2) a high-build, vinyl coat, that is green, or light grey; and

(3) a grey, high-build, vinyl top-coat.

3.5 Low Volatlle Organic Compound (VOC) Coatings

Due to restrictions on VOC emissions, the coating industry may in future be required to use low VOC coatings more often. The result will be a shift toward either water based or higher solids coatings. MTO has recently approved five low VOC coating systems. The systems will be applied to selected bridges over the next few years, and monitored to gam field experience and performance data before employing them to a greater degree.

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3.6 Overcoating/Encapsulation Coating Systems

Overcoat or encapsulation systems are applied on top of the coating system already on the structure. Except for localizm hand and/or power tool cleaning, minimal surface preparation work is required. As aresult, surface preparation and environmental protection costs are lower, with minimal air emissions.

The service life of this class of coating is unknown but would be less than the service life of a zinc-rich system applied over a thoroughly cleaned substrate.

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CHAPI'ER4

CONTAINMENT DURING SURFACE PREPARATION AND COATING

4 CONTAINMENT DURING SURFACE PREPARATION AND COATING

4.1 lntroduetlon

All surface preparation technologies have the potential to result some type of waste or emission that must be managed for environmental protection purposes. However, waste volumes and emission levels may vary significantly between surface preparation technologies.

The primary wastes generated by surface preparation operations are spent abrasive and paint chips, while dust emissions are the most difficult to contain, and can travel significant distances impacting receptors both on and off the job site.

4.2 Containment During Surface Preparation

Abrasive blasting operations typically produce the greatest amount ofdust because of the high pressures and volumes of abrasive involved. As a result, abrasive blasting operations require the most comprehensive containment measures. Hand tools, generate little, or no dust, and require minimal containment.

Containment is the most effective mitigation method available to minimize the impact of emissions during surface preparation. Table 41ists the most commonly used surface preparation methods, and recommended minimum containment.

Minimum containment recommendations are only as effective as the quality of workmanship during construction. Past experience has shown that, regardless of the degree of containment, if poorly constructed performance will be inadequate. This is particularly evident with respect to entrance ways, as well as seams and joints between construction materials.

Effective performance is also dependant on proper maintenance practices. Prompt repair of holes, and leaks from seams, joints, etc... is essential so that containment systems perform as intended. In addition, daily clean-up of spent abrasive and debris from within the enclosure will minimize escapes in the event of damage caused by poor weather conditions (e.g. high winds). Termination of work during periods of high winds is also recommended.

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TABLE 4: SURFACE PREPARATION METHODS, EMISSIONS AND MINIMUM CONTAINMENT REQUIREMENTS

SURFACE PREPARAnON METHOD

POTENTIAL EMISSIONS AND WASTES CONTAINMENT COMMENTS

hand tool cleaning

potential emissions - minimal dust. solid waste - paint chips. liquid waste - not applicable.

- partial enclosure with ground cover.

-no abrasive. - paint chips are not collected by equipment.

vacuum power potential emi11ions - minimal dust. - partial enclosure -no abrasive. tool cleaning solid waste - paint chips.

liquid waste - not applicable. with ground cover. - potential for Increased emiBBiona

of dust &. paint chips If the vacuum seal is broken.

po-rtool potential emissions - minimal dust but - partial enclosure - no abrasive. cleaning greater than vacuum power tool cleaning.

solid waste - paint chips. liquid waste- not applicable.

with ground cover. - there may be varying degrees of dust generated depending on the power tool involved. For example, disk sanders may result In more dust then air scalers.

vacuum abrasive potential emissions - minimal duat with - partial enclosure -abrasive is present. air blast cleaning potential for high levels.

solid waste - paint chips &. spent abrasive. liquid waste- not applicable.

with ground cover or full enclosure.

- potential for lncreaud emissions of dust, paint chips and abrasive If the vacuum seal Is broken.

abrasive air blast cleaning

potential emissions - high dust levels. solid waste - paint chips &. spent abrasive. liquid waste- not applicable.

- full enclosure with negative pressure.

- abrasive is present. - the amount of dust generated will vary with the type of abrasive (e.g dust levels from silica sand abrasive are greater than from st-1 grit).

water blast potential emissions - washwater and - partial enclosure - not a commonly used mathod. cleaning overspray

solid waste- paint chips and dirt settled from washwater. Uquid waste - washwater to treatment facility/disposal.

with water collection system.

- eliminates dust problem but requires a comprehensive collection system to contain and collect washwater, dirt and debris.

abrasive water potential emissions- washwater, overspray - partial enclosure - not a commonly used mathod. blast cleaning and wet abrasive

solid waste - paint chips/dirt settled from washwater. liquid waste - washwater and abrasive slurry.

with water collection system.

-eliminates dust problem but requires a comprehensive collection system to contain and collect washwater and liquid slurry.

Definitions

Pertlel Enolaures shall prevent the escape of all materials during surface preparation, with the exception of dust. A partial enclosure is not an appropriate containment system If significant dust is being generated. Partial enclosures may consist of vertical tarps and floor tarps so long as the tarps are overlapped and securely fixed together at the seams.

Ful Enclosures shall be Impervious to dust and wind and prevent the escape of all materials Including dust from •1ow dust• generating surface preparation equipment. A full enclosure is not an appropriate containment system for •high dust• generating surface preparation equipment such as abrasive air blast cleaning. Full enclosures shall be free of any openings with joints, seams, and overlaps fully sealed.

Ful Enoloeures With Negative Preaure shaU be Impervious to dust and wind and equipped with a negative pressure system to prevent the escape of all material• including dust from abrasive air blast cleaning. The system shall be free of any openings with joints, seams, and overlaps fully sealed.

Water Colectlon Systems shaD collect and prevent the escape of water end debris generated from water blast cleaning/abrasive water blast cleaning operation•.

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4.3 Containment During Coating Application

The principle concern during coating is the escape of overspray particles. Containment of overspray is a relatively easy task compared to dust, as the particles tend to drift shorter distances.

Vertical tarps and floor tarps are satisfactory so long as the seams between tarps are overlapped and securely fixed together. Openings in containment for ventilation do not result in overspray releases provided the openings are not near the work area being coated. Practically speaking, the same containment system used during surface preparation is adequate for overspray containment although negative pressure would not be required.

4.4 Site Sensitivities

Emissions containment and environmental protection goals for projects remain constant regardless of the environmental sensitivities of sites. However, site specific environmental sensitivities can result in both a greater degree of public concern and closer monitoring by regulatory authorities. In such instances, a communication program to inform concerned parties of the environmental protection measures implemented at the site is recommended. This may help to identify site specific solutions and demonstrate that the project is being undertaken in an environmentally sound manner. A list of site sensitivities that may result in an elevated public profile are presented in Table 5.

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TABLE 5: SITE SENSITIVITIES

ENVIRONMENTAL ISSUES FACTORS INCREASING SENSITIVITY

dust - proximity of residences schools, hospitals, commercial operations, fanning and livestock.

discharges to water - drinking water supply, fisheries, boating and other water sports.

noise - proximity of residences, schools, hospitals, animal rearing barns.

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CHAPrERS

MONITORING OF PROCESS EMISSIONS AND ENVIRONMENTAL IMPACTS

5 MONITORING OF PROCESS EMISSIONS AND ENVIRONMENTAL IMPACTS

5.1 Introduction

Emissions from Structural Steel Coating Rehabilitation (SSCR) projects can lead to the release of contaminants to the air, soil and water. These emissions can be minimized through good operating practices and control measures. However, there may be circumstances where emissions cannot be eliminated and their impacts may need to be monitored.

An environmental monitoring program will only be needed at selected sites. The need for such a program will be site specific, and may depend on the sensitivity of the site and complexity of the work. The requirement for a monitoring program is generally at the discretion of the proponent (e.g. MTO) and/or MOEE. In certain cases, a monitoring program may be a requirement in the proponent's contract. If the proponent/MOEE have not requested a monitoring program, the contractor can still undertake a voluntary monitoring program to ensure the impacts are acceptable.

The various monitoring strategies, analytical procedures and sampling methodologies are described in this chapter. Where monitoring programs are undertaken, these reference methods can be used to determine the levels of contaminants in the soil, water and air. These levels can then be compared to regulatory soil, water and air standards, guidelines or criteria to assess their impacts and to confirm compliance with MOEE regulations.

5.2 Monitoring Technologies

Where a monitoring program is undertaken, the following sampling and analytical methods can be used for the air, soil and water media:

1) Visual Dust Emissions - USEP A Method 9 for visual determination of visual emissions from operations, and compliance with Section 8 (opacity limits) of Regulation 346;

2) Ambient Air Suspended Particulate Matter (SPM) and Lead Concentrations - High Volume (HiVol) sampling and analysis for determining impacts and compliance with Ministry SPM and Lead ambient air quality criteria;

36

3) Dust Fall- dust jar sampling and analytical methodologies for determining compliance with the Ministry dust fall limits;

4) Soil Sampling- soil sampling and analytical methodology for determining the concentration of Lead, for comparison with the Guidelines for Decommissioning and Cleanup of Sites in Ontario; and

5) Water Sampling - water sampling and analytical methodology for determining compliance with the Provincial Water Quality Objectives (PWQO).

Table 6 summarizes the various types of samples, sampling and analytical methods and applicable regulatory criteria.

37

I

TABLE fi: SUMMARY OF SAMPLING METHODOWGIES AND MOEE CRITERIA

MEDIA TYPE OF SAMPLE APPLICABLE MOEE STANDARDS, GUIDELINES, CRITERIA

SAMPLING! ANAL meAL METHODS TYPICAL MINIMUM DETECTION LIMITS

MISC. INFORMATION • REFERENCES

.... vl11111l H emf..lona Reg. 348, Sec. I: - 20" opacity 8t aourue

- USEPA method I for vlauel detennlnlllfon of opacity

0 to 100" opiCity - USEPA method I mey not be eppffcllble to SSCR operation•

emblent air • auapended particulate matter ISPMI

Reg. 337: - 120 ug/m' 124 hi

- HIVol aamplar -gravimetric anelyala (MOE-AMP "011

2 uatm• - USEPA 1190 - MOEE 1171

ambient air • lead MOEE and ACES A-mmendlllfona: - 2 uatm' 124ht • 0.7 ug/m1 (30 deyal

·HIVolaamplar • dlgelllfon by nltrlclhydraftuorlc acid anlllyala by AAS or ICP

0.01 ug/m' ·ACES 1114 • MOEE 11148

Reg. 337: • 2 ug/m1 (annual aeom8trlc meant

dut~tt• Reg. 348: • 1000 ua/m11%h

Reg. 337: - 7t/m1/30 daya - 4.8 a/m1/yaar

• du8t fan Jar IMOEE·AMP "421 0.03 tlm1/30 daya (I Inch jar openlntl

• MOEE 1913

lOll Lead In Surf- Sol ACES A-ndlllfona: - 200 ppm (w/wl for relklentlal/partdand and 81rlculturlll • 1000 ppm for lndUibllll/commercllll

- core Sampler • hot dlgeatlon with aqua regia - anlllyala by AAS or ICP

10ppmfwlwl ·ACES 1994 • MOEE 1990 • MOEE 1194a • MOEE 1994c - MOEE 1994d • MOEE 1994e

IUrfeceWater lead In aurface w8ter Plovlncllll W8ter Quality Objectlwa: - 1 ug/L 10-30 maiL hanlne••l - 3 ug/L f3CJ.IO maiL hanlneaal - & uaiL I>eo maiL hantne ..t

• polyethylene terephthalate bottle - preaerwd with nitric acid - reconcentnlted by avapol'lltlon In the preaence of nitric acid analyala by ICP-MS

0.2 uaiL - MOEE 1914 - MOEE 11Mb - MOEE 1994d

ACES • Advlaary Committee on Envlranmentel Stendanla ICP • lnductfwly coupled pla1ma MS • m811 apectraacopy ppm (w/wl • part• per mmlon, weight b81fl

AAS • 8tomfa abaorptlon lpactr0ICOPY L ·ltre MOEE • Mlnlt~try of Envlranmant and Eneray ua • mlcraar•m

h·how ma • mlflfgram m' • cubic metra

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5.3 Visual Emissions

Section 8(1) of Regulation 346 specifies that no person shall cause or permit -to be caused a visible emission that obstructs the passage of light to a degree greater than twenty (20%) percent at the point of emission (opacity of 20%). The opacity is determined visually by a trained observer in accordance with USEP A Method 9. Under this method, the trained observer takes 24 consecutive observations of fifteen seconds each, with the sun oriented in the 1400 to the observer's back and such that the line of vision is perpendicular to the plume direction. The average of the 24 consecutive readings should be less than 20%. It may not be possible to use this method in some situations, especially when there are obstructions or problems with access to certain locations.

In addition to Section 8(1) on visible emission at the source, Section ll(a) of Regulation 346 also states no contaminant (including dust) shall be carried beyond the limits of the property on which the construction, alteration, demolition, drilling, blasting, crushing or screening is being carried out, and sandblast or permit the sandblasting of anything so that a contaminant (including dust) is emitted into the air, to an extent or degree greater than that which would result if every step necessary to control the emission of the contaminant were implemented. The operators should comply with requirements for both visible emission at the source and at the property line.

5.4 Ambient Air Suspended Particulate Matter (SPM), Lead And Dust Fall

An ambient air monitoring program normally consists of three phases:

1) The Pre-operational Phase - to determine background levels, sampling frequency can be every 6th day for four weeks.

2) Operational - during actual SSCR activities, which should begin with frequent sampling initially. If off-site levels of contaminants meet standards, then the frequency can be reduced to once every 3 to 6 days depending on the length of the project. Samplers should be sited close to the fence line or property boundary (if any), upwind and downwind of the site. If there are no property boundaries, then it should be placed near the residents or the nearest areas of concern.

3) Post-operational- there may be a need to monitor ambient air for a short period after the completion of the SSCR projects, to ensure there is no residual threat to the neighbouring community.

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The current MOEE 24 hour ambient air quality criteria (AAQC) for SPM is 100 ug/m3 and for Lead is 5 ug/m3• However, the Minister of Environment and Energy has recently accepted the recommendations of the Advisory Committee on Environmental Standards (ACES) to revise the lead AAQC to a 30 day AAQC of 0.7 ug/m3• The corresponding new 1h hour standard and 24 hour AAQC are likely to be 6 ug/m3 and 2 ug/m3 respectively. When ambient air monitoring is used for these compounds, the HiVol method is generally applied. A HiVol sampler consists of a vacuum motor drawing air through a pre-weighed and preconditioned glass fibre filter. The mass of particulate collected on the filter is determined gravimetrically, by difference in the before and after weights of the filter. The collected mass of particulate is divided by the sample air volume to yield the concentration in ug/m3•

The SPM sample can also be analyzed for lead followed gravimetric analysis for SPM. For lead analysis, the filters can be ashed in a muffie furnace, following by nitric/hydrofluoric acid digestion and then analyzed by atomic absorption spectroscopy analysis (AAS). The sample preparation and analytical procedure may differ from those described here. The acceptability of alternative analytical methods can be confirmed with the MOEE staff prior to the initiation of the sampling program.

The MOEE dust fall limits are 0.008 g/m2/ 1h hour, 7 g/m2/30 days and 4.6 g/m2/year. Dustfall is monitored by exposing an open top plastic jar {with a polyethylene liner) for 30 days. The containers are 2.4- 3.1 em (6-8 inches) in diameter, 6.3-7.1 em (16-18 inches) in height, and placed vertically 3 to 4.6 metres (10-15 feet) above the ground. After the 30 day sampling period, the soluble and insoluble material deposited onto the liner is processed and analyzed gravimetrically. The dry weight of the deposited material and the area of the jar opening is then used to determine the dust fall rate in units of g/ml/30 days. The annual value is the arithmetic mean of the thirty day results.

There are several real time particulate monitoring systems which can also provide similar information on SPM concentration. The TEOM monitor is one such system. The TEOM system consists of a tubular filter with a taper support element. The taper element is vibrated at its natural frequency, which is dependent on the mass of the filter. As ambient air is drawn through the filter, particulates collect on it and increase the mass of the filter, thus resulting in a corresponding decrease in vibration frequency. The TEOM system measures this change in frequency and derives an ambient air SPM concentration. Another system is the Beta Gauge Monitor, which measures the absorption of beta rays on a filter tape to derive the SPM concentration. The beta rays are generated by a radioactive source integrated into the instrument.

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Not every SSCR project requires an ambient air monitoring program. In some cases, the Ministry of Labour monitoring for workers may be sufficient to also evaluate the ambient air impacts.

5.5 SoD Sampling

Soil sampling can be conducted to determine the existing levels and the contamination resulting from the SSCR projects. The sampling of the existing levels of contamination is highly recommended prior to the start of the SSCR work. The soil sampling results can then be compared to the MOEE's criteria for various types of land use, as listed in the MOEE's Guidelines for the Decommissioning and Cleanup of Sites in Ontario. The existing soil Clean-Up criteria are 500 ppm for residential/parkland and agricultural lands, and 1000 ppm for industrial/commercial lands.

The Minister of Environment and Energy has recently accepted the recommendations of the ACES to revise the cleanup guidelines for lead. The new guidelines are 200 ppm for agricultural/residential/parkland and 1000 ppm (unchanged) for industrial/commercial lands. The clean-up guidelines provide guidance to property owners/consultants on how to assess a site for possible contamination and clean up the property for re-use or development.

In most cases, the application of the clean-up guidelines will be at the discretion of the property owner. There is no MOEE legislative or regulatory requirement to follow the clean up guideline unless the site is causing or is likely to cause an adverse effect (as defined in the Environmental Protection Act).

The soil sampling program for surface contamination should consist of the collection of a number of core or grab samples. Normally a minimum of 10 sampling sites per hectare (10,000 ml) of land should be sampled. Table 7 outlines the number of sample sites required for various sizes of areas under 1 hectare. At each sampling site, a minimum of 10 core or grab samples should be collected from within a 2 metre radius circle (or equivalent area). The individual core or grab samples are then combined to form one composite sample for analysis. SSCR projects are likely to result only in surface contamination, therefore, core or grab samples should be obtained from the 0-5 em depth. Some additional confirmatory sampling should occur below this depth (eg. 5-15 em) to assure that contamination has not moved below the surface.

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Ifa single composite sample result exceeds a guideline, that sample is deemed to have failed the guideline, and soil up to the next sample site that passes the guideline is also deemed to be in exceedance of the guideline. This allows the proponent to choose between additional sampling to better define contaminated areas or remediate all potentially contaminated soils.

TABLE 7: MINIMVM NUMBER OF SAMPLE SITFS FOR IN-SITU SOIL

Area (Square Meters) Minimum Number of Sample Sites

< 200 2

200-500 3

500-750 4

750- 1000 5

1000-2000 6

2000-3500 7

3500-5000 8

5000-7500 9

7500- 10000 10

> 1 hectare 10 sites per hectare

5.6 Surface Water Sampling

Sampling of surface water (rivers, streams, lakes, artificial impoundments, runoff, etc.) may be necessary when there is a potential for contaminants such as lead to have adversely affected the quality of an on-site or nearby water body. The objectives of the sampling program should be to meet regulatory requirements and provide results that allow for the comparison of water quality immediately downstream from the SSCR site with.that of upstream waters. The proposed Provincial Water Quality Objective (PWQO) for lead is 1 ug/L with water hardness of 0-30 mg/L (as CaCO,), 3 ug/L with water hardness of 30-80 mg/L and 5 ug/L with water hardness of greater than 80 mg/L.

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In most cases, manual sampling using equipment such as buckets, funnels and suitable lengths of chain or dip poles should be sufficient. All samples for analysis should be obtained from a point in the stream that is representative of the whole stream composition. The volume of sample taken must be sufficient to allow for analysis of all required analysis and quality control samples (eg. field duplicate, laboratory replicate and spiked sample). Grab samples can be taken by dipping a clean sampling bucket, bottle or vial, into the water stream .using an appropriate retrieval device such as a chain, rope or pole. The water samples are then transferred to an appropriate laboratory container(s), and preserved as necessary. If possible, collect the sample directly in the sample bottle to avoid possible contamination of the water by the sampling device.

The preferred method is to slowly move the sample bottle through the depth profile of the water body as it is filling. When done properly, this method produces a sample that represents the full depth profile of the constituent of interest. For lead samples, the surface water can be collected in polyethylene terephthalate (PET) bottles and preserved to pH 2 with nitric acid. The samples are usually reconcentrated by evaporation in the presence of nitric acid and then analyzed by inductive coupled plasma mass spectroscopy (ICP-MS). In addition to ICP-MS, other analytical methodologies may also be acceptable to the MOEE.

For the monitoring and evaluation of sediments, the proponent should consult with MOEE on the appropriate monitoring procedures and criteria.

Discharge to sanitary, storm or combined sewers is also an area of concern. The operator should ensure any discharge to sewers meets the requirements of the municipal sewer user bylaws in the municipality where they are working.

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CHAPTER6

WASTE MANAGEMENT

6 WASTE MANAGEMENT

6.1 Introduction

This chapter reviews the regulatory and operational requirements for the management of waste generated during Structural Steel Coating Rehabilitation (SSCR). The assumption has been made that all waste material, will be managed within the province of Ontario and as close to the point of generation as possible.

Waste management and disposal requirements are dependant on the hazardous characteristics of the waste material. Regulation 347, under the Environmental Protection Act, is the primary piece of environmental legislation governing waste management/disposal in Ontario. The regulation provides a comprehensive registration and shipping manifest system that monitors waste material from the point of generation through to disposal.

A number of different liquid and solid waste materials may be generated during SSCR - the primary source of these wastes being surface preparation and coating operations. Solid wastes from these operations have the potential to become contaminated with lead and other metals (e.g. cadmium and chromium) associated with the coating system being removed.

Like solid wastes, liquid wastes have the potential to become contaminated with metals from existing coating systems. Liquid wastes may also posess additional hazardous characteristics that are unrelated to metal contaminantion (e.g. the flash point or ignitability of spent solvents).

6.2 Waste Classification

Regulation 347 requires generators to evaluate their waste material and, if found to be a Subject Waste (i.e. Hazardous Waste or Liquid Industrial Waste), to register with the MOEE. In addition, Regulation 347 requires the registration of solid wastes that, when subject to the Leachate Extraction Procedure, generate leachate contaminant levels between 10 and 100 times the levels specified in Schedule 4 of the Regulation. These wastes are often referred to as Registerable Solid Waste.

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Under Regulation 347 hazardous waste is defined as;

"... a waste that is a,

(a) hazardous industrial waste,

(b) acute hazardous waste chemical,

(c) hazardous waste chemical,

(d) severely toxic waste,

(e) ignitable waste,

(f) corrosive waste,

(g) reactive waste,

(h) radioactive waste, except radioisotope wastes disposed of in a and filling site in accordance with the written instructions of the Atomic Energy Control Board,

(i) pathological waste,

G) leachate toxic waste, or

(k) PCB waste as defined in Regulation 362 of Revised Regulations of Ontario, 1990,

and includes a mixture of acute hazardous waste chemical, hazardous waste chemical, hazardous industrial waste, pathological waste, radioactive waste or severely toxic waste and any other waste or material, but does not include,

(1) hauled sewage,

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(m) waste from the operation of a sewage works subject to the Ontario Water Resources Act where the works;

(i) is owned by the municipality,

(ii) is owned by the Crown subject to an agreement with the Municipality under the Ontario Water Resources Act, or

(iii) receives only waste similar in character to the domestic sewage from a household,

(n) domestic waste,

(o) incinerator ash resulting from the incineration of waste that is neither hazardous waste nor liquid industrial waste,

(p) waste that is a hazardous industrial waste, hazardous waste chemical, ignitable waste, corrosive waste, leachate toxic waste or reactive waste and that is produced in any month in an amount less than five kilograms or otherwise accumulated in an amount less than five kilograms,

(q) waste that is an acute hazardous waste chemical and that is produced in any month in an amount less than one kilogram or other wise accumulated in an amount less than one kilogram,

(r) an empty container or the liner from an empty container that contained hazardous industrial waste, hazardous waste chemical, ignitable waste, corrosive waste, leachate toxic waste or reactive waste,

(s) and empty container of less than twenty litres capacity or one or more liners weighing, in total, less than ten kilograms from empty containers, that contained acute hazardous waste chemical,

(t) the residues or contaminated materials from the clean-up of a spill of less than five kilograms of waste that is a hazardous industrial waste, hazardous waste chemical, ignitable waste, corrosive waste, leachate toxic waste or reactive waste, or

(u) the residues or contaminated materials from the clean-up of a spill of less than one kilogram of waste that is an acute hazardous waste chemical."

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Liquid Industrial Waste is defmed to include liquids from industrial processes that are obivious liquids, as well as those sludges that fail the Slump Test outlined in Regulation 34 7. The Slump test involves placing the material in a 30 em open inverted cone. The cone is removed and the immediate decrease (slump) in the height of the waste material is measured. If the material slumps such that the height of the origional height of the is reduced by 15 em or more, the waste is a liquid.

Explanations of the types of the Hazardous Wastes referred to above may be found in the MOEE document titled, "Registration Guidance Manual For Generators of Liquid Indusrial and Hazardous Wastes".

All waste material generated should be presumed to be a Subject Waste, until proven otherwise using appropriate testing and classification procedures (refer to Regulation 347 and the MOEE Guidance Manual).

6.3 Solid Waste

The primary types of solid waste generated by SSCR operations are spent abrasive and removed coating material (i.e. paint chips). Other solid wastes that may be generated include off-specification coating material that has solidified; contaminated soil; protective clothing; and damaged construction materials.

Removed coating material has the potential to contaminate wastes with metals such that leachate concentrations exceed 100 times Schedule 4levels (i.e. greater than 5 mg/1 of lead). Depending on sampling and testing effort, two management strategies may be considered for such materials;

(1) do not sample waste materials and declare all potentially contaminated wastes to be Leachate Toxic Waste; or

(2) obtain and test representative samples and manage waste materials as Leachate Toxic, Registerable Solid Waste, or Non-Registerable Solid Waste.

The most economical strategy can only be determined on a project specific basis, by undertaking a cost benefit analysis.

In strategy 1, there are no testing costs. However, the material would be disposed of at the more expensive rate for Leachate Toxic Waste. In addition, transport costs may be an issue, particularly for remote sites located far away from the licensed facilities able to accept the material.

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In strategy 2, sample collection and testing costs would be incurred, but these costs may be off set by lower disposal rates for Registerable Solid Waste and Non-Registerable Solid Waste.

6.3.1 Spent Abrasive Blasting Medium And Removed Coating Material Mixture Sample Collection

Uneven distribution ofpaint chips throughout the spent abrasive blasting medium, may result in variable lead concentartions. These variations have the potential to occur both vertically and horizontally. As a result of the potentially heterogeneous nature of the waste material, it is essential that effective sampling strategies be implemented to collect representative samples for analysis. Possible approaches to achieve this objective include the following:

(1) collect one or more full depth sub-samples using a hand held auger, from each container of similar waste material and combine the sub-samples into one or more composite samples for analysis. If similar wastes cannot be easily identified, it may be necessary to test a sample taken from each container of waste;

(2) using a trowel or shovel, collect sub-samples from each container of waste at different levels as the material is placed in the container, or at different time intervals (e.g. end of each work day). Sub-samples from individual containers, or multiple containers of similar waste, may then be combined into one or more composite samples for analysis; or

(3) where there are a large number of containers of similar waste material, it may be desirable to use a random sampling strategy and then evaluate the test results using statistical methods.

Whereas full depth sampling, and sampling at specified volume and/or time intervals address vertical variations, horizontal variations are addressed by collecting vertical profile samples at multiple locations throughout the waste container. For drums, a single vertical profile sample may be sufficient. However, in the case of a lugger bin, vertical profile samples from two or more locations may be necessary to address horizontal variations. Generally speaking the greater the number of samples taken the more representative they will be.

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6.3.2 Other Solid Wastes- Sample Collection

The sample collection procedure outlined above for spent blasting medium containing removed coating material may also be followed for other solid waste materials.

Spent abrasive blasting medium, and removed coating material separated through recycling operations, are typically more homogeneous in nature than a mixture of the two. Potential metal contaminants, such as lead, are concentrated in the removed coating material causing it to be a Leachate Toxic Waste in most instances. Likewise, the absence of the removed coating material leads to lower levels of contaminants such as lead. As a result, solid wastes such as separated spent abrasive blasting medium tend to be either Registerable Solid Waste, or Non-Registerable Solid Waste, in most instances.

6.4 liquid Waste

Liquid waste materials can be generated from several sources during a SSCR project. Possible types of liquid waste include off-specification coatings and solvent cleaners; residual thinners and reducers from cleaning operations; spent solvents; washwater from bridge cleaning; wastewater from decontamination facilities (e.g. showers/laundry); wastewater from hydroblasting operations; and contaminated site runoff.

Like solid wastes, liquid wastes genrated by SSCR operations have the potential to contain lead at concentrations greater than 100 times Schedule 4 limits. However, many liquid wastes may also posess other hazardous characteristics that also need to be identified/measured before they can be properly classified and disposed of. As an example, if the flash point of a waste (e.g spent solvent) is less than 61 degrees celcius, then it would be classified as an Ignitable Waste, even if leachate levels exceed 100 times Schedule 4limits.

For further guidance on classifying wastes, reference should be made to Regulation 347 and the MOEE publication titled, "Registration Guidance Manual for Generator of Liquid and Hazardous Waste."

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6.4.1 Liquid Waste - Sampling

The following sampling strategies may be used for liquid wastes:

(1) if the liquid waste may possess a hazardous characteristic other than Leachate Toxic, sample and test each container of liquid waste;

(2) for each type of liquid waste KNOWN to have the same waste classification under Regulation 347, collect one or more full depth subsamples from each container and combine the sub-samples into one or more composite samples for analysis. If similar wastes cannot be easily identified, it may be necessary to sample and test each container of liquid waste; or

(3) where there are large number of containers of liquid waste, all of which are KNOWN to have the same primary characteristic/waste classification, it may be desirable to use a random sampling strategy and evaluate the test results using statistical methods.

For liquid wastes, there is also a tendency for vertical seperation of materials due to the nature of dissimilar liquids. As a result sampling procedures should account for potential variations that may exist vertically, both within and betweeen containers.

The following equipment may be used to collect liquid waste samples from drums and containers:

(1) tube and ball valve sampler;

(2) composite liquid waste sampler;

(3) concentric tube sampler; and

(4) constricted or regular glass tube samplers.

Details on these samplers are provided in the MOEE document titled, "Industrial Waste Sampling Manual".

6.5 Preparation Of Composite Samples

Composite samples that contain unequal volumes of waste material from one or more sub-samples may produce a test result that is not representaive of the waste material overall.

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The following procedure may be followed when preparing composite samples:

(1) combine and thoroughly mix together individual sub-samples from containers of similar waste materials;

(2) pile the sample into a cone while placing it on a clean plastic sheet. As the material is emptied from the container, place it at the cone's apex and allow the material to run down the sides of the cone;

(3) flatten the cone into a rough circle of uniform thickness. Divide the circle into four quarters and reject two opposite quarters;

(4) repeat the procedure of coning and quartering until approximately 500 grams of composite sample remains; and

(5) place the composite sample into a laboratory cleaned, glass jar and label as follows:

SAMPLE NUMBER: DATE SAMPLED:

LOCATION (EG. BRIDGE SPAN): NAME OF SAMPLER:

TELEPHONE NUMBER: BIN NUMBER:

6.6 Storage Of On-Site Wastes

The Environmental Protection Act, Part ll, Section 6 states that "no person shall discharge into the natural environment any contaminant and no person responsible for a source of contaminant shall permit the discharge into the natural environment... •. In addition, Section 14 prohibits the discharge of a contaminant into the natural environment that "causes, or is likely to cause an adverse effect." These sections essentially require that hazardous materials be stored in a safe and secure manner.

Recommendations for proper storage of hazardous materials include:

(1) store unused chemicals/raw materials in an area seperate from waste materials;

(2) locate storage areas away from storm sewers, conduits, and surface waters;

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(3) locate storage areas away from the main work area such that the security of the materials is not compromised (i.e. knocked over, punctured, etc ...) by the day to day operations at the site;

(4) provide secondary containment with a capacity of 130% to 140% that of the liquid materials in storage;

(5) use only undamaged, well maintained containers free of holes and rust, with secure fitting lids;

(6) do not leave unopened containers unattended and when not in use, keep container lids closed at all times;

(7) maintain a minimum spill response capabilility at the site to clean-up "small" spill situations and contain "larger" spills until off-site emergency response teams arrive at the site;

(8) do not mix or combine materials suspected of, or known to have, different hazardous characteristics/waste classes;

(9) clearly label all materials and containers to avoid cross contamination of materials and potentially dangerous mixing of reactive materials;

(10) maintain a daily record of the type and quantity of material, number of containers, potential hazardous characteristics (e.g. Leachate Toxic, Ignitable, etc •.. ) and material safety data sheets in a prominent location for reference by employees and emergency personnel;

(11) restrict access to authorized, trained personnel only and ensure that storage areas are secure from vandilism and unauthorized access;

(12) maintain an emergency response plan at the site that identifies the location of storage areas, surafce waters, sensitive environmental habitat, storm sewers/conduits, and local authorities (e.g. fire, police and medical officials, spill clean-up companies, local MOEE offices, etc ...);

(13) remove excess chemicals and waste materials from the site as expeditiously as possible to minimize safety and security concerns. Also, storage of subject waste on-site for more than three monthes requires submission of a "Storage Report" to the MOEE, (Regulation 347, Section 18 - (10)); and

(14) ttain staff in the proper handling, storage and disposal of hazardous materials used and/or generated at the site.

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6.7 Transportation And Disposal

Under Regulation 347 carriers and receivers of Subject Waste must be licensed by the MOEE. Carriers and receivers are not permitted to accept Subject Waste from a generator that has not obtained a Generator Registration Document.

In addition, the regulation requires that each shipment of Subject Waste be accompanied by a waste manifest, copies of which are to be forwarded to the MOEE at critical points in the waste transfer.

6.8 MOEE Caution Statement

Contractors and proponents of SSCR projects are cautioned to ensure that operations and sevices are performed in accordance with appropriate federal and provincial legislation and other laws (e.g. local by-laws) governing such practices.

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CHAPTER 7

SITE MANAGEMENT

7 SITE MANAGEMENT

7.1 Introduction

To properly manage waste streams, and protect the environment against spills and potentially harmful emissions, it is recommenced that a comprehensive site management plan be prepared prior to project start-up.

The plan should include:

a field or observation monitoring component;

a site plan;

equipment specifications;

documented procedures for equipment maintenance; and

documented procedures for critical site operations.

The primary stages of a project, for which a site management plan should be prepared, are:

1) project start-up;

2) surface preparation and coating;

3) end of day clean-up;

4) waste collection and disposal; and

5) relocation of enclosure/project completion.

7.2 Field/Observation Monitoring

Field, or observation monitoring, can be a very effective tool for tracking environmental performance. To be most effective, it should be made an inherent part of all site operations and performed daily, or whenever the operation of interest is undertaken.

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A field monitoring checklist, for each of the primary project stages referenced above, is presented in Table 8. The checklist is a series of questions, and can be used to document the environmental performance of equipment and procedures, and identify remedial action as required.

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TABLE 8: SITE MANAGEMENT PRACTICES CHECKLIST

PROJECT START-UP YES NO CORRECTIVE · ACTION

Is lead paint present?

Are other potentially hazardous materials present?

Is subject waste (as defined by Regulation 3471 to be generated at the site 7

If subject waste is generated, is there a waste generator registration number from the Ministry of Environment and Energy for this site 7

Are there separate designated storage areas for hazardous materials and wastes7

Are hazardous materials and waste storage areas properly signed and secure from unauthorized access?

Have potential types and sources of emissions been identified?

Have appropriate mitigation measures and procedures been developed to contain emissions?

Are work areas properly signed and secure from unauthorized access?

Is there a facility for workers to remove and store contaminated clothing?

Has a site management plan been prepared for the project, including an employee health and safety plan and spill contingency plan 7

SURFACE PREPARATION AND COATING REMOVAL YES NO CORRECTIVE ACTION

Are there any visible emissions escaping to the environment during materials transfer, surface preparation and coating operations?

Are there visible emissions escaping from site enclosures?

Is there fall-out to nearby soils or waters?

Is there visible discharge of liquid effluent to soils, surface water or sewers?

Is the wind creating operating problems with the enclosure?

Is the nearby traffic creating problems with the enclosure (e.g. traffic induced wind interferences)?

Has equipment been cleaned of dust and waste material prior to removal from the enclosure?

Are there visible dust emissions from emissions control equipment (e.g. baghouse, filters)?

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TABLE 8: CONTINUED

SURFACE PREPARATION PAINT REMOVAL (CONTINUED) YES NO CORRECTIVE ACTION

Are there visible tears or holes in the baghouse/dust collector filters?

Is the pressure drop across the baghouse lower or higher than normally expected?

Is there excessive material in the baghouse hopper?

Are the baghouse exhaust fans operating at a normal speed?

Are the baghouse air flow dampers properly set?

Is there audible air leakage through the discharge valve or tube sheet of the baghouse7

END OF DAY CLEAN-UP YES NO CORRECTIVE ACTION

Has the inside of the enclosure been cleaned of standing debris (e.g. spent abrasives)?

Has the enclosure been inspected for leaks, holes etc •••?

Is the work area outside the enclosure inspected and cleaned as required, including spills of abrasive and other debris?

Have hazardous material/waste storage areas and container lids been secured?

Has access to the site, work areas, and hazardous materials/waste storage areas been secured to prevent unauthorized entry?

Are contaminated work clothes removed and properly stored before the workers leave the work site?

WASTE COLLECTION AND DISPOSAL YES NO CORRECTIVE ACTION

Is waste material stored in secure containers and labelled correctly?

Are hazardous material and waste containers free of rust and holes?

Are hazardous material and waste container lids closed at all times when not in use?

Is hazardous waste material stored separately from nonhazardous waste material?

Are hazardous material and waste storage areas/containers inspected on a daily basis for leaks and spills?

Are there visible emissions of dust and debris from enclosures, waste lugger bins or conduits during waste transfers?

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TABLE 8: CONTINUED

WASTE COLLECTION AND DISPOSAL !CONTINUED! YES NO CORRECTIVE ACTION

Is waste material sampled and tested and classified, in accordance with Ontario Regulation 347, prior to shipment off-site?

Are sample chain of custody forms completed for each sample that is sent for analysis?

Has a sampling procedure been developed to ensure that the samples collected are representative of the waste 7

Is the manifest for the transportation of hazardous waste properly completed for the disposal of the hazardous waste generated on site 7

Do carriers and receiving facilities have MOEE certificates of approval to receive the wastes?

RELOCATION OF ENCLOSURE/PROJECT COMPLETION YES NO CORRECTIVE ACTION

Is the enclosure vacuumed prior to disassembly?

Has all hazardous material, waste, debris and equipment been removed from the site7

Has the site been restored to its original condition?

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7.3 Site Management Plan

The site management helps to identify, prepare for, and avoid potential problems in advance. The plan can also be used to train staff, monitor operations, identify areas for improvement after the project has started, and communicate environmental protection measures to regulatory authorities.

The site management plan should consist of the following individual plans and procedures:

1) site plan;

2) paint removal technology and containment specifications;

3) waste collection and recycling plan/procedures;

4) waste disposal procedures;

5) waste collection, storage and disposal procedures; and

6) employee health and safety procedures.

7 .3.1 Site Sketch

The site sketch identifies key features for reference by employees, regulatory authorities and emergency response personnel and should include:

the steel structure under repair;

site entrances/access routes;

storage areas for paints, thinners &. blasting material;

storage areas for off-specification paints, spent thinners, spent blasting medium, removed coating material and other wastes;

the location of office trailers, waste collection bins and other equipment (e.g. dust collectors and recycling equipment);

potential environmental receptors (e.g. surface waters, residential agricultural, commercial and industrial properties, parks etc...); and

utilities (e.g. storm sewers, natural gas and hydro/power lines).

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7 .3.2 Equipment/Containment Stmcture Specifications And Operating Procedures

Specifications and operating procedures help to ensure proper construction, operation and maintenance of equipment and containment structures. This is particularly true for surface preparation and coating operations, to ensure the effective performance of mitigation measures designed to prevent the escape of harmful emissions.

Equipment and containment structure specifications and operating procedures should include:

the type of coating removal and coating application equipment to be utilized (e.g. vacuum abrasive blasting over water and hand tools for areas that are difficult to access with vacuum abrasive blasting equipment, etc••);

a description of the wastes and potential emissions that may be generated by surface preparation and coating operations and the procedures and equipment to be used to prevent escapes;

a description of containment structure, negative pressure systems and dust collectors, including detailed design and procedures for construction;

equipment and containment structure maintenance and operating procedures;

procedures for relocating enclosures and equipment, including procedures for site clean-up.

7 .3.3 Waste Collection And Recycling Procedures

Waste collection and recycling procedures help to ensure the safe transfer of spent abrasive, removed coating material and other debris between equipment and storage containers.

Waste collection and recycling procedures should include:

a method of transfer of materials (e.g. spent abrasive, removed coating material, and paint) from enclosures, dust collectors and other sources of waste to storage containers and eventually on-site waste storage areas;

a designated frequency for clean-up of waste materials (e.g at the end of each work day);

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a description of the equipment involved in the collection and transfer of waste materials to and from containers and storage areas (e.g hoppers, waste transfer lines);

potential sources of emissions during materials collection and transfer and the mitigation procedures and engineering controls to be utilized to prevent emissions; and

a description of the recycling equipment to be utilized including specifications and procedures for mobilization, operation and maintenance.

7.3.4 Waste Disposal Procedures

Wastes disposal procedures are required to ensure compliance with waste disposal regulations.

Waste disposal procedures should include:

procedures for sample collection and preparation;

directions for completing sample chain of custody forms;

waste classification and registration procedures in compliance with Ontario Regulation 347;

directions for identifying certified carriers and disposal companies;

directions on completing waste shipping manifests in compliance with Ontario regulation 347 and the Transportation of Dangerous Goods Act;

record keeping requirements for sample chain of custody documents, waste shipping manifests and sample results; and

emergency spill response procedures.

7 .3.5 Employee Health And Safety Procedures

Employee health and safety procedures are required to protect workers against exposure to hazardous materials, and prevent the movement of hazardous materials off-site.

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Employee health and safety procedures should include:

a hazard communications plan identifying hazardous materials and potential for exposure;

employee training program;

on-site posting of health and safety procedures and sign requirements regarding hazards;

protective clothing requirements;

procedures for operating site equipment;

procedures and training for proper use of breathing equipment;

description of decontamination facility, including wash trailer with clean side and dirty side;

procedures for cleaning and personal hygiene at breaks and end of shifts;

procedures for cleaning and/or disposal of work clothes; and

procedures for monitoring effects of lead on workers (e.g air monitoring, medical surveillance).

NOTE: All workers can be exposed to incidental lead on-site whether they are blasting, rigging, cleaning or operating equipment and must be protected.

7.4 Record Keeping

Some legislation requires that records be retained for a minimum period of time after the job has been completed. In addition, even if not required by law, records may help to demonstrate due diligence with respect to environmental protection and employee health and safety.

The following site records should be maintained beyond completion of the project:

hazard determination records that document background contamination (e.g. soil, water and air samples);

pre-job meeting records identifying site project hazards;

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a site compliance plan containing material safety data sheets, warning signs, labels and employee training programs;

employee lead exposure assessment records;

employee training records;

medical surveillance records;

job communications records;

environmental equipment maintenance records;

engineering controls/documentation (e.g.air management);

waste shipment documentation/manifests;

waste generator registration information;

waste sample collection procedure; and

waste sample analytical test results.

7.5 Containment Structure Design

Containment of surface preparation operations (e.g. abrasive blasting) is the primary mitigation measure used to prevent the escape of harmful emissions such as paint chips, spent abrasive, dust and other debris to the environment.

Surface preparation methods that generate significant levels of dust require, as a minimum, a full enclosure containment system. A typical full enclosure may include the following:

sealed entnmces or air locks;

impermeable tarps or other material with sealed, overlapping seams;

securely fastened tarps at frequent intervals to minimize wind loads; and

sealed joints between construction materials such as plywood sheets used for floor construction and wall frames;

It is also necessary to implement a system to manage the removal of dust contained within the enclosure.

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Various standards have been employed to ensure adequate air is removed to minimize the accumulation of dust. All equipment utilized in this endeavour must contain adequate filtration to prevent dust from escaping the equipment. This is usually achieved by filtration added to the exhaust equipment.

(NOTE: Equipment may retain lead and should be cleaned thoroughly before leaving the site.)

7.5.1 VentUation Of Work Areas

Different methods can be used to adequately ventilate the work area. There should be regular inspection to ensure the integrity of the containment structure.

Ne:ative Air

Adequate air evacuation will create a negative pressure and pull any air in through minor leaks at joints. However, tightly sealed containments may achieve adequate negative air pressure but create a static situation within the enclosure. This requires the input of make-up air to overcome the static and may lower the instrument readings.

Cross-Sectional Air Flow

Specifying cross-sectional air flow at 100 ftlminute is also utilized and requires the addition of make-up air. The normal, accepted standard is 100 ftlminute x the cross-sectional area. Therefore a 40'x 20' containment requires 80,000 cfm air removal.

This system does not take into account the length of the containment. The above calculation for a 40' long containment would result in an air change every 24 seconds.

Air Cbanm

Air changes per hour is a method utilized to take into account the construction and size of the enclosure and specify the amount of air required to be removed to achieve a controlled situation.

No matter which standard is set, it is essential that the design of the structure and the management of the air prevent any dust from escaping the enclosure.

When blasting near seams and joints of the enclosure, it is possible that dust will be forced out from the high pressure zone of the blast nozzle. This should be minimized.

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CBAYI'ER 8

EMERGENCY RESPONSE PLANNING

8 EMERGENCY RESPONSE PLANNING

8.1 Introduction

An emergency response plan should be prepared for each project to ensure rapid and effective response to site spills. The plan should outline procedures for both spills reporting, containment and cleanup.

In preparing the plan, potential hazards/failures should be identified and some assumptions made about the local impacts in the event of a spill situation. The plan should be site-specific and take into consideration the unique aspects of the project, including physical characteristics of the site and surrounding area.

8.2 Spills Reporting

All spills and discharges should be immediately recorded and reported to the Ontario Ministry of Environment and Energy and other appropriate authorities. A sample spill occurrence report form is presented in Figure 2.

Spills or discharges that should be reported include escapes/emissions of dust, abrasive, paint chips, coatings/paint, fuel, oils, solvents or any other contaminants that may have a negative impact on the environment (e.g. soil, water, air and noise quality) or cause a nuisance to surrounding properties.

The occurrence report should identify the type, source and cause of the spill as well as authorities and individuals that have been notified (e.g. local police, fire department and emergency spill response/cleanup companies).

65

ACDONTIIII

.

FIGURE 2: SPILL OCCURRENCE REPORT

II PROJECT NAME AND LOCATION:

DATE: SWFT: TIME: AM/PM

CONTRACTOR & HEAD OFFICE ADDRESS: TIME NOTIFIED:

CONTRACTOR TELEPHONE NUMBER:

SITE SUPERVISOR: TIME NOTIFIED:

SITE TELEPHONE NUMBER:

LOC.AL MOEE ADDRESS AND TELEPHONE NUMBER:

CONTACT PERSON: TIME NOTIFIED:

OTIIER NOTIFICATIONS (SPECIFY): TIME NOTIFIED:

TYPE OF EMISSION SOURCE/CAUSE DURATION AND/OR VOLUME

RECEPTOR(S)

ABRASIVE ()

DUST ()

PAINT CHIPS ( )

COATING OVBRSPRAY ()

SOLVENT()

FUEL ()

OIL ()

OTHER ( ) - SPECIFY:

REPORT COMPLETED BY: SIGNATURE: DATE:

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8.3 Emergency Response Plan - General Requirements

The plan should:

state policy, explain purpose and illustrate organizational structure;

be geared to the most probable spill size;

address the following phases of spill response:

• discovery and notification • evaluation and initiation of action • containment and countermeasures • cleanup, mitigation and disposal • documentation and cost accounting;

clearly assign duties and roles to appropriate personnel/organizations;

outline containment and clean-up equipment requirements for spill control;

have procedures for updating the plan on a regular basis;

outline training requirements in prevention, personnel protection and response for site personnel; and

be submitted to appropriate government agencies for review.

8.4 Emergency Response Plan - Implementation

The plan should:

address human safety issues;

pre-arrange for use of best available cleanup/containment equipment;

describe location, capability and limitations of cleanup/ containment equipment;

identify detailed response options/strategies;

67

detail how communications will be maintained between all parties during response operations; and

assign and train personnel to respond to public inquiries or calls from the media.

8.5 Environmental Protection & Liability Risks

The plan should:

identify high-risk areas and operations;

identify critical environments for protection and place in order of priority;

detail specific actions for minimizing damage;

have provisions for responding to spills under all anticipated weather conditions; and

pre-arrange response capability for "worse case" situations.

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CHAPfER9

TRAINING

9 TRAINING

9.1 Introduction

Training of workers is essential to ensure they are aware of the environmental and occupational health and safety hazards associated with the removal of bridge coatings. There are several worker training courses that have been developed to meet this need. One example is the Ontario Painting Contractors Association/ffiPAT - Lead Based Paint Abatement Course and workers who have sucx-.essfully completed this course are issued a certificate ID card. All workers on the site including inspectors and supervisory staff should have this type of training.

9.2 Training Requirements

A typical course outline would include the following topics:

EnvironmentaVWaste Manar:ement

environmental regulations;

Environmental Guidelines For Structural Steel Coating Rehabilitation Operations On Highway Structures;

emissions monitoring;

emergency spill response;

waste storage and management/disposal;

effective housekeeping practices; and

record keeping.

69

Health and Safety

hazard communications (determining the hazard);

proper hygiene practices;

decontamination procedures and facilities;

personnel exposure monitoring;

instruction/training on proper use and maintenance of personnel protective equipment; and

labelling/ signage requirements.

En~ineerin~ Controls and Surface Preparation Equipment

lead-based paint removal/surface preparation methods;

emissions collection/containment systems;

ventilation systems and engineering controls;

set-up and use of negative air flow system; and

proper use of hepa vacuum.

In addition to formal courses, each worker should be given project specific training on environmental and occupational health and safety issues pertaining to the specific project prior to starting work. A record of this training should be documented by having the worker and trainer/supervisor sign a check list of the key points covered.

70

REFERENCES

References

1. Advisory Committee on Environmental Standards, Soil. Drinking Water. and Air Quality Criteria for Lead, Report 94-02, ACES, Toronto, Ontario, (1994).

2. Ontario Ministry of Environment and Energy, Method for High Volume Sampling and Determination of Total Suspended Particulate Matter in Ambient Air, Report AMP-101, MOEE, Toronto, Ontario (1979).

3. Ontario Ministry of Environment and Energy, Method for the Sampling and Determination of Atmomheric Pustfall, Report AMP 142, MOEE, Toronto, Ontario (1983).

4. Ontario Ministry of Environment and Energy, Water Management Goals. Policies. Objectives and Implementation Proce4ures of the Ministzy of Environment, MOEE, Toronto, Ontario (1978, Revised May, 1984).

5. Ontario Ministry of Environment and Energy, Guidelines For The Decommissioning And Cleanup Of Sites In Ontario, MOEE, Toronto, Ontario, (1989).

6. Ontario Ministry of Environment and Energy, Rationale for the DevelQPment of Soil. Drinking Water. and Air Oua.lity Criteria for Lead, MOEE, Toronto, Ontario, (1993).

7. Ontario Ministry of Environment and Energy, Summmy of Point of Impingement Standards. Ambient Air Quality Criteria CAAOCs). and Ap,prova}s Screening Levels CASLs), MOEE, Toronto, Ontario (1994).

8. Ontario Ministry of Environment and Energy, Pro.posed Guidelines For The Clean-up Of Contaminated Sites In Ontario, MOEE, Toronto, Ontario (1994).

9. Ontario Ministry of Environment and Energy, Note on Water Management. Program Develo.pment Branch, MOEE, Toronto, Ontario (1994).

10. Ontario Ministry ofEnvironment and Energy, Praft Sampling. Processing and Analytical Procedures for Soil. Rock and like Materials, MOEE, (1994).

71

11. Ontario Ministry of Environment and Energy, Proposed Draft Guidance on Samplin~ and Analytical Methods for Site Clean-yps in Ontario, MOEE, Toronto, Ontario (1994).

12. Ontario Ministry of Environment and Energy, Stricter Lead Limits Recommended for Ontario Environment, News Release, MOEE, Toronto, Ontario (1994).

13. United States Environmental Protection Agency, Reference Method for the Determination of Sus.pended Particulate Matter in the Atmomhere (Hi~hVolume Method), Codes of Federal Regulations (CFR), Protection of Environment, 40 Part 50, Appendix B, USEPA, Washington, D.C (1990).

14. United States Environmental Protection Agency, Visual Determination of the Qpacity of Emissions From Stationcu:y Sources, Codes of Federal Regulations (CFR), Protection of Environment, 40 Part 60, App. A, Method 9, USEPA, Washington, D.C. (1993).

15. Steel Structures Painting Council, Systems and Specifications, Sixth Edition, SSPC, Pittsburgh, PA, (1991).

16. Ontario Ministry of Transportation, Construction Specification For Coatin~ Structural Steel, Ontario Provincial Standard and Specification 911, MTO, Downsview, Ontario, (1990).

17. Steel Structures Painting Council, Visual Standard For Abrasive Blast Cleaned Steel, SSPC, Pittsburgh, PA, (1989).

18. Ontario Ministry of Transportation, Desi~nated Sources For Materials Manual, MTO, Downsview, Ontario (1995).

19. Ontario Ministry of Transportation, Environmental Protection Durin~ Structural Steel Coatin~ Rehabilitation. Special Provision 911S01, MTO, Downsview, Ontario (1994).

20. Ontario Ministry of Transportation, Mana&ement of Spent Blastin~ Medium and Dimosal of Removed Coatin~ Material and Spent Blastin~ Medium, Special Provision 911S05, MTO, Downsview, Ontario (1994).

21. Ontario Ministry of Transportation, Samplin~ Protocol for Removed Coating Material and Spent Blastin~ Medium, MTO, Downsview, Ontario (1994).

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APPENDIX A

MOEE DISTRICT OFFICES

Ontario Ministry of the Environment and Energy

REGION REGIONAL OFFICI DISTRICT OFFICI. DISTRICT OFFICI. DISTRICT OFFICI DISTRICT OFFICI.

SOUTIIWESTERN

London 985 Adelaide St S. London, Ontario N6E 1V3 (519) 661-2200

OwmSolUld 1180- 20th St Owen SolUld, Ontario N4K6H6 (519) 371-2901

Samia 1094 London Road Samia, Ontario N7S 1PI (519) 336-4030

Windsor 250 Windsor Ave. 6th Fl. Windsor, Ontario N9A6V9 (519) 254-2546

London 985 Adelaide St. S. London, Ontario N6E IV3 (519) 661-2200

WEST-CENTRAL

Hamilton 119 King St. W. 12th Fl., P.O. Box 2112 Hamilton, Ontario L8N3Z9 (905) 521-7640

CambridJe 320 Pinebush Road P.O. Box219 Cambridge, Ontario N1R5T8 (519) 622-8121

Hamilton 119 King St. W. 12th Fl., P.O. Box 2112 Hamilton, Ontario L8N3Z9 (905) 521-7650

Weiland 637-641 Niagara St. N. Weiland, Ontario L3C 1L9 (905) 732-0816

CENTRAL

1'mmtll 5175 Yonge Street North York, Ontario M2N411 (416) 326-6700

York Durham 230 Westney Road SthFI. Ajax, Ontario (905) 427-5600

Haltcm.-Peel 1235 Trafalgar Rd. Suite401 Oakville, Ontario L6H3P1 (905) 815-5920

.ImmJ.m. 5175 Yonge Street North York, Ontario M2N4Jl (416) 326-6700

EASTERN

Kincston 133 Dalton St. Kingston, Ontario K7L4X6 (613) 549-4000

OttiD 2435 Holly Lane Ottawa, Ontario K1V7P2 (613) 521-3450

Comwall 205 Amelia St. Cornwall, Ontario K6H3P3 (613) 933-7402

Kingston 133 Dalton St. Kingston, Ontario K7L4X6 (613) 549-4000

Peterborou&h 139 George St. N. Peterborough. Ontario K9J3G6 (705) 743-2972

MID-ONTARIO

Sudbu[y 199 Larch St. 11th Fl. Sudbury, Ontario P3ESP9 (705) 675-4501

North Bay Northgate Plaza ISOO Fisher St. North Bay, Ontario PlB2H3 (705) 476-1001

sudbm 199 Larch St. 11th Floor Sudbury, Ontario P3ESP9 (705) 675-4501

~ 54 Cedar Pointe Dr. Unit 1203 Barrie, Ontario IANSR7 (705) 726-1730

Mllskgki-Haliburtm 483 Bethwe Dr. Gravenhurst, Ontario POC 100 (705) 687-6647

NORTHERN

Thwcler BAY 435 James St. S 3rd Ft., P.O. Box 5000 Thunder Bay, Ontario P1CSG6 (807) 475-1205

Kmgm 808 Robertson St. P.O. Box SISO Kenora, Ontario P9N IX9 (807) 468-2718

ThunclerBay 435 James St S. 3rd Fl, P.O. Box 5000 Thunder Bay, Ontario P1CSG6 (807) 475-1315

Slul1 &G. Marie Timmins 83 Algonquin Blvd. W. Timmins, Ontario P4N2R4 (705) 268-3222

44S Albert St. E. Sault Ste. Marie, Ontario P6A2J9 (705) 949-4640

revisedAprill6, 1996

Environmental Office Ministry Mezzanine Level of 301 St. Paul Street Transportation St. Catharines, Ontario

L2R 7R4 Ontario

0 ISBN 0-7n8-4608-X 01996 Queen's Printer for Ontario

Documents

ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL … · ENVIRONMENTAL GUIDELINES FOR STRUCTURAL STEEL COATING ON HIGHWAY STRUCTURES APRIL 1996 ... ENVIRONMENTAL GUIDELINES FOR STRUCTURAL