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Safe Lead Abatement
at a Major Food Processing Plant
A Right-Angled
ROTO-PEEN Scaler, with a specially-configured motor drive, was
utilized for increased productivity on the interior webbing of
the beams.
F DA-regulated
process facilities are accustomed to complying with strict guidelines
to prevent product contamination from bacterial sources, acids, and
other substances... Now add lead-based paint to the list of worrisome
hazards! Although FDA regulations do not currently target the presence
of lead in food processing facilities, it would be unwise to assume
that lead paint does not exist. In general, any building older
than 1978 has a potential lead-based paint problem, with the likelihood
progressively increasing with the structure's age.
The
dangers of lead in food handling or processing plants is of special
concern, considering that the most common form of lead poisoning
is through ingestion. The negative health affects of lead exposure
are cumulative and can, at high exposure levels, lead to coma, convulsions,
and death. Lead affects children the most severely, impairing development
of the brain and nervous systems. The Centers for Disease Control
and Prevention (CDC) estimates that nearly 9 percent of American
children under the age of six are at risk with blood lead levels
above the threshold of 10 micrograms/dL, making lead exposure the
most pressing national environmental health concern for children.
As a result, implementation of proactive measures of protection
against lead is being undertaken by some of the larger food processors.
The
Problem
Aging,
flaking lead-based paint on overhead steel I-beams posed a contamination
risk within the processing and packaging areas of a 75 year-old
confectionery plant in the Northeast--especially rooms containing
vats and process piping for food ingredients. The owners recognized
the importance of proper lead-based paint removal as a matter of
public and employee health, maintaining confidence in consumer relations,
and adherence to the plant's established sanitary conditions. Project
specifications called for continuous air quality monitoring during
removal to detect trace quantities of airborne lead, periodic wipe
sampling of plant floors and quality checks to verify that cleanliness
levels were maintained, and achievement of surface profiles suitable
for the application of a modern protective coating system.
The
project scope included the cleaning of approximately 1,100 square
feet of surface area on steel I-beams located in the confection
ingredient processing rooms of the plant. Each room housed four
large processing vats which occupied most of the available space.
The goal was to remove the coatings while maintaining environmental
cleanliness and achieving a surface profile suitable for application
of the new epoxy-based protective coating. The specifications called
for a finish comparable to a Steel Structures Painting Council SP
6, Commercial Blast Cleaning, described as a surface "free of all
visible oil, grease, dirt, dust, mill scale, rust, paint, oxides,
corrosion products, and other foreign matter..."
Some sensitive areas containing lead-based paint presented challenges
that are particular to food processing plants: tight and hard-to-access
spaces, conduits and steam pipe congestion, and heat-induced hardening
of aged paint. Early attempts to remove the lead-based primer on
some of the I-beams proved too difficult using chemical stripping
methods. The chemical removal process also resulted in unpredictable
schedules that could not support narrow shutdown windows, and the
imprecise nature of chemical application cross-contaminated nearby
production equipment.
The
Solution
Pentek,
Inc., of Coraopolis, Pa., provided a dustless lead
abatement system, designed to capture hazardous airborne dust
and debris at the cutting edge of vacuum assisted power tools. Since
the Pentek process is completely dry, an absolute minimum of hazardous
waste is generated for disposal--only the removed coating itself.
Also, the dustless nature of the Pentek system eliminates the need
for expensive containment structures and burdensome worker respiratory
protection. Other removal methods can result in increased dispersion
of lead-based dust, aggravating the contamination problem and increasing
lead exposures. The essential feature of the Pentek process (which
was originally designed for the grueling demands of radiological
decontamination) is the strict vacuum control over the airborne
particulates, ideal in facilities such as food processing plants
where a pristine working environment is a must.
Pittsburgh-based
CRX Environmental Services provided turnkey lead abatement services,
labor, and materials to remove the hazardous coatings. CRX Environmental's
crew mobilized during a hectic Christmas holiday shutdown: 19 other
contractors were involved in various maintenance and construction
activities during the outage to prepare the plant for the new year.
CRX ran a sample area with Pentek's shrouded power tools as a reference
standard for the surface finish and, upon approval, work on the
beams commenced.
Preparations
were straightforward. A plastic drop cloth was stretched across
the vat beds, drains, pumps, and motors as a precaution against
the chance that heavier, non-respirable particulates could accidentally
escape the strong pull of the vacuum system. Ladders were used along
with planks to access the 12 ft. high beams. These accessories comprised
the sum of CRX's work area preparation; no elaborate containment
structures were required, nor were expensive ventilation schemes.
A Pentek VAC-PAC
self-drumming HEPA vacuum unit, capable of running 10 shrouded power
tools over 200 ft. away was stationed outside the rooms. Pentek's
shrouded power tools include ROTO-PEEN Scalers to remove coatings
in broad swaths and CORNER-CUTTER
needle guns to access corners, edges, and around rivets. CRX personnel
attacked the beams with these tools from various positions around
and over the vats, each connected by a length of hose that conveyed
all removed coatings directly into the VAC-PAC's onboard, DOT approved,
55-gallon waste disposal drum.
The
ROTO-PEEN Scaler
and CORNER-CUTTER needle gun work in complementary fashion: the
former for flat areas and the latter, with the help of a battery
of specially conformed shrouds, for hard-to-reach corners and edges
. Each individual operator could quickly change his tool by transferring
the vacuum hose and air line to the new tool. The hose lengths were
taped off at strategic positions so that workers lifted only the
tool itself, not the weight of the hose. This ability to rapidly
change out the light-weight tools or adjust the geometry of the
CORNER-CUTTERs' shrouds meant that workers could efficiently abate
all the surfaces within their reach--flanges, tight interior webbing,
rivets and bolts--providing flexibility unavailable with other methods.
Using
this integrated approach, CRX workers were able to delead extremely
tight surfaces like the inside top flanges, inside webbing, and
inside bottom flanges of I-beams that were close to the walls. A
Right-Angled ROTO-PEEN Scaler, with a specially-configured motor
drive, was utilized for increased productivity on the interior webbing
of the beams. The VAC-PAC, conveniently parked outside the work
area, served as a powerful, central conveyor and safe depository
for all the accumulated waste material.
The
Results
The
shrouds and evacuated nature of the tools effectively protected
the sensitive food production equipment from any ingestible hazards.
After deleading, each beam was wiped down with a general solvent
to remove any residue, and the area was vacuumed clean. As the workers
moved through the rooms, the completed beams had shiny, bare metal
finishes comparable to an abrasively blasted profile.
With
respect to worker safety and hygiene, CRX personnel wore respirators
only until such time airborne monitoring and personal sampling verified
the cleanliness of the Pentek system; readings were often below
detection limits, and none were above 7 micrograms per cubed meter.
These were well below regulatory standards which limit lead concentrations
for each worker at a Personal Exposure Limit of 50 micrograms per
cubed meter and allowed continued operations without the use of
respiratory protection. Post-job worker blood tests revealed negligible
changes in lead blood concentration. Due to the cleanliness of the
Pentek abatement process, and buttressed by ample historical performance
data, CRX Environmental does not normally require their crew to
wear respirators when using the Pentek system. "The residual risk
has been reduced through Pentek's engineering to near zero airborne
discharges," said John Sotiriou, CRX's project manager.
"The
[Pentek] process is wonderful, and the beams look great," said the
facility's project engineer, pleased that there would be time to
repaint and refill the vats before the outage was over. "With so
many different operations going on at the same time, the contractor's
lead removal activities were the least of my worries."
Additional
rooms with more lead-coated structures were scheduled to be deleaded
by CRX Environmental during the next shutdown. The initial abatement
project provided the confectionery plant with the data necessary
to forego the expense of air and hygiene monitoring on future projects
(usually mandatory parts of a decontamination service contract),
as well as contractual requirements for pollution liability insurance,
resulting in an overall decrease in direct project overhead estimated
by the owner at 20 percent of total project costs.
Pentek technology has become an important component of the company's
corporate lead abatement strategy. Future projects will target conveyor
systems, water tanks, and other infrastructure maintenance activities.
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