Safe Lead Abatement at a Major Food Processing Plant

    by Patrick Nace, Pentek


 

    Roto-Peen being used on an I beam 

    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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