Lead Paint Neutralized
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 [hci chemtec, inc.] 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."
