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SPRINGFIELD, OR: "During our September mill maintenance shutdown
we endeavored to clean and paint the structural steel supports inside
one of our large chip silos. We have four such vessels and have undertaken
this work on two of them previously.
"The project began early swing shift on Sunday and proceeded
on or ahead of schedule until about 5:30am on Wednesday. During the
pressure-washing phase of the job the painting foreman observed what
appeared to be lead primer under the topcoat of steel. The paint
was then tested and found to contain high levels of lead. The two
silos we worked on previously are of the same vintage and construction
but had no lead-based paint in them. Nor could we have tested for
lead before the shutdown because the steel is inaccessible under
operating conditions.
- "The sandblasting phase of the work could not proceed because
the personal protective gear and engineering controls were not
in place for an OSHA-compliant lead abatement project. But the
lead posed another problem. EPA classifies our mill as a "small
generator" of hazardous waste. We plan our abatement projects
quite carefully to avoid exceeding the monthly limits of hazardous
materials necessary to maintain that classification. By the time
this project got underway, we had already reached out monthly limit
for waste generation... with 8 days to go before the start of a
new month. Furthermore, this project would generate 4 times our
monthly limit!
"We had two choices at this point:
- "Abandon the painting job and wait for a later 7 day mill
outage opportunity, or
- "Acquire and use a lead "neutralizer" product,
such as ENVIRO-PREP® that would permit us to proceed with blasting
and painting, albeit with some schedule delay. (ENVIRO-PREP® is
a non-hazardous product we have screened and tested on another
project.) Our tests have demonstrated that it is effective at rendering
lead paint to non-detectable in TCLP (toxicity characteristic leaching
procedure) tests and therefore not regulated by the EPA. This product
converts the soluble lead compounds to harmless metal salts...
in this case, lead phosphate.
"We called Hoffer's Coatings in Wausau WI at 6:15AM PST and
asked them to assemble 60 gallons of ENVIRO-PREP® and prepare it
for immediate shipment by air. At about 8AM our purchasing manager
contacted corporate aviation to arrange a charter that could get
the product to our mill immediately. By 4PM that same day the painting
contractor was applying the ENVIRO-PREP® in the silo. During the
day they had set up their clean rooms, changing stations, air compressors
and implemented engineering controls for a full lead abatement project.
They had also drafted a project lead compliance program and a fall
protection program for our review and approval. Arrangements were
made to collect the spent blasting media and store it in a secure
area on site pending the results of TCLP tests to confirm its disposability.
"The sandblasting actually went a little faster than planned
and we did some creative scheduling to recover the balance of the
lost time. The project finished within 2 hours of the original plan
and production was not impacted. TCLP tests performed on the 8,000
lb. of spent blasting media indicated that ENVIRO-PREP had, indeed,
rendered the lead to be non-detectable. It was then hauled to a landfill
with no special documentation required or extraordinary disposal
costs incurred.
"In the process of researching ENVIRO-PREP® our environmental
team learned of several other products that claim to be as effective
as this one. However it appears that some of these contain lime and
portland cement which really do nothing to remove the hazardous lead
compounds but simply act to defeat some of the testing processes
used to detect them."
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