REMOVAL AND CONTAINMENT OF LEAD-BASED PAINT
                VIA NEEDLE SCALERS
                          by

                     Paul B. Kranz
     Erie County Department of Environment and Planning
           Division of Environmental Compliance
                   Buffalo, NY 14202

                  James E. Stadelmaier
                Recra Environmental,  Inc.
                Amherst, NY  14228-2298
          Cooperative Agreement No. CR-816762
                     Project Officer

                    Paul M. Randall
Waste Minimization, Destruction and Disposal Research Division
          Risk Reduction Engineering Laboratory
                 Cincinnati, OH 45268
    RISK REDUCTION ENGINEERING LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
  U.S. ENVIRONMENTAL PROTECTION LABORATORY
                CINCINNATI, OH  45268

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                                               NOTICE
        The information in this document has been funded wholly or in part by the United States Environmental
Protection  Agency  under Cooperative Agreement Number CR-816762-02-0  to  Erie  County Department of
Environment and Planning. It has been subjected to the Agency's peer and administrative review, and it has been
approved for publication as an EPA document. Mention of trade names of commercial products does not constitute
endorsement or recommendation for use.  This document is identified as an advisory guideline only to assist in
developing approaches to waste reduction.  Compliance with environmental and occupational safety and health laws
is the responsibility of each individual business and is not the focus of this document.

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                                              FOREWORD

        Today's rapidly developing and changing technologies and industrial products and practices frequently carry
with them the increased generation of materials that, if improperly dealt with, can threaten both public health and
the environment. The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's land, air, and water resources.  Under a mandate of national environmental laws, the agency strives to
formulate and implement actions leading to a compatible balance between human activities and the ability of natural
systems to support and nurture life.  These laws direct the EPA to perform research to define our environmental
problems, measure the impacts, and search for solutions.
        The Risk Reduction Engineering Laboratory is responsible for planning, implementing, and managing
research, development, and demonstration programs  to provide an authoritative, defensible engineering basis in
support of the policies, programs, and regulations of the EPA with respect to drinking water, wastewater, pesticides,
toxic substances, solid and hazardous wastes, Superfund-related activities, and pollution prevention. This publication
is one of the products of that research and provides a vital communication link between the researcher and the user
community.
        This report describes  the results of a technical and economic evaluation  of the comparison  between
conventional abrasive blasting and a dustless needlegun system for removing lead-based paint from steel structures.
The objective of the study was to substantiate the reduction of hazardous waste generation and airborne lead-
containing dusts from the  paint removal  operations  through the use of the dustless needlegun system and  to
comparatively analyze the economics associated with its substitution for conventional abrasive blasting.
                                                                E. Timothy Oppelt, Director
                                                                Risk Reduction Engineering Laboratory
                                                   111

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                                               ABSTRACT




         This report describes a comparative technical and economic evaluation of using a dustless needlegun system.




versus a conventional abrasive grit blasting system in the removal of lead-based paint from steel structures.  The




objective of the study was to comparatively  analyze  the operational and logistical aspects of using dustless




needleguns for lead-based paint removal as they relate to hazardous waste generation, worker health and safety and




associated economic factors.




         The dustless needlegun system demonstrated its ability to produce a substantial reduction (97.5%) in the




generation of hazardous waste when compared to conventional abrasive blasting. Also demonstrated was the ability




to substantially reduce (up to 99 %) the airborne concentrations of respirable dusts and lead-containing particulates




generated during paint removal operations.




         Labor costs were decidedly higher (approximately 300%) for the dustless needlegun system primarily due




to slower production rates which would necessitate more operating personnel.  These  costs are substantially




mitigated by the reduction of costs associated with expendable abrasive blast material and hazardous waste disposal.




         Conventional abrasive blasting proved to be decidedly superior in the quality of surface preparation, based




upon prescribed contract specifications.




         The dustless needlegun system is shown to be economically competitive with conventional abrasive blasting




when considering the reduced  requirements for containment, hazardous waste disposal and worker protection.




         This  report was submitted  in partial  fulfillment of contract  number  CR-816762 by the Erie  County




Department of Environment and Planning, under the sponsorship of the U.S. Environmental Protection Agency.




This report covers the period from July 1992 through August 1993. Field and analytical work was completed as of




March 1993.

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                                             CONTENTS

                                                                                                Page

Notice	  ii
Foreword	iii
Abstract	iv
List of Figures	vi
List of Tables  	vii
Acknowledgement	viii

        1.      Introduction	  1
                        Program Overview	1
                        Project Purpose	1
                        Industrial Participants  	1
                        Background	2
                        Objectives  	3
        2.      Technology Description	4
                        Paint Removal Systems  	4
        3.      Methodology	 %	8
                        Background and Historical Data	8
                        Procedures-Conventional Abrasive Blasting	9
                        Procedures-Pentek Dustless Needlegun System	11
                        Sampling and Analysis Plan	12
        4.      Results and Discussion	16
                        Performance and Discussion   	16
                        Environmental, Health and Safety	16
                        Economics	18
                        Analytical Data Quality Assurance	22
        5.      Conclusions	24

Appendices

        A.      Surface Preparation Specifications	26
                SSPC-SP 6
                SSPC-SP 11
        B.      Condensed Operating Procedures	35
                Pentek CORNER-CUTTER®
                Pentek VAC-PAC®
        C.      Demonstration Log Sheet	44
        D.      NYSTA Air Sampling Forms	49
                Air Sample Chain-of-Custody Forms
        E.      Analytical Results	 65
               NOTE:      Appendix D has been deleted from  this report.  Copies are
                            available from Paul Randall or James E. Stadelmaier.

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                                           FIGURES




Number                                                                                  Page




   1   Pentek CORNER-CUTTER® Schematic Diagram	 7




   2   Abrasive Blasting Process Schematic Diagram	7




   3   CORNER-CUTTER® Productivity Ranges  	.,19
                                              VI

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                                               TABLES

                                                                                                 Pa
Table 1         Specifications for Air-Powered and Electric-Powered Systems	6

Table 2         Paint Specifications	,	9

Table 3         Typical Chemical Analysis of Blast Media	 9

Table 4         Air Analysis Methods	13

Table 5         Waste Analysis Methods	13

Table 6         Type and Location of Samples	  14

Table 7         Air Sampling Analytical Results  	17

Table 8         Labor Costs-Paint Removal Operations	  18

Table 9         Labor Costs-Paint Removal Operations Support Labor (Entire Structure)	   19

Table 10        Labor Costs-Mobilization	20

Table 11        Labor Costs-Demobilization	.20

Table 12        Cleanup Costs  	:	20

Table 13        Total Estimated Labor Costs	21

Table 14        Materials Costs	21

Table 15        Hazardous Waste Generation and Disposal Costs	21

Table 16        Total Costs  	.22

Table 17        Waste Analytical Results	22
                                                 vu

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                                       ACKNOWLEDGEMENT

        The USEPA, Erie County and Recra Environmental, Inc. acknowledges the New York State Thruway
Authority (NYSTA) and Pentek, Inc. for its assistance and cooperation during this evaluation.
        The NYSTA Buffalo Division Department of Maintenance Engineering, Civil Engineer I Environmental
Specialist, Gary Hart,  provided the evaluation sites and  historical information.  The NYSTA Department of
Administrative Services Bureau of Occupational Safety and Health Services Senior Industrial Hygienist, Carol Butt,
performed the worksite air sampling.  Mr. Brad Fuller of Pentek, Inc. provided the operators and equipment for
testing.  Commercial Painting Co., Inc., Niagara Falls, New York, performed the abrasive blasting. The final report
was reviewed by Dr. Ralph Rumer of the New York Center for Hazardous Waste Management, Mr. George Moore
of the USEPA Toxics Control Branch,  and Mr. Bernard Appleman of the Steel  Structures Painting Council.
                                                 viu

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                                              SECTION 1
                                           INTRODUCTION

PROGRAM OVERVIEW
        This is a final report for the third of five innovative waste minimization technology evaluations which are
being conducted under the cooperative agreement program between the United States Environmental Protection
Agency (EPA) and Erie County, New York entitled "Waste Reduction Innovative Technology Evaluation" (WRITE)
Program, Contract No.  CR-816762-02-0. The project entailed the technical and economic assessment of a dustless,
mechanical lead-based paint removal system as compared to conventional abrasive blasting on a steel bridge. The
program was completed in conformance with work plans and quality assurance project plans previously submitted
and approved by the EPA.
        The project was completed under the terms of the Erie County/WRITE Program as a joint effort by the
New  York State Thruway  Authority; Pentek,  Inc., Coraopolis, PA; Erie County Environmental Compliance
Services,  Buffalo,  NY; Recra  Environmental, Inc.,  Amherst, NY; and the  EPA Office of Research and
Development, Cincinnati, OH.

PROJECT PURPOSE
        The purpose of this project was to evaluate an alternative to the current practices of abrasive blasting using
expendable media for removing lead-based paint from bridges and other structures with respect to any reduction in
the generation of waste or in worker exposure to hazardous materials. Furthermore, it was to evaluate the economic
and logistical aspects of replacing current practices with such an alternative.

INDUSTRIAL PARTICIPANTS
        The industrial  participants for this program were the New York State Thruway Authority (NYSTA) and
Pentek, Inc.
        The NYSTA is responsible  for the operation and maintenance of the New York State Thruway system.
The Buffalo District of the NYSTA, with offices located at 3901 Genesee Street in Cheektowaga, New York, 14225
(716-631-9017) is responsible for the westernmost part of New York. A significant portion of the maintenance
requirements for the Thruway deals with the upkeep of elevated portions of the roadway including bridge painting'.
The Buffalo District had scheduled for 1992, the commercial abrasive blast cleaning and repainting of 33 bridges
in Western New York. This work encompasses approximately 8,644 lineal feet of bridge span requiring the cleaning
and repainting of 5,832 tons of structural steel.
        Pentek, Inc., with offices located at 1026 Fourth Avenue, Coraopolis, Pennsylvania, 15108 (412-262-0725),
has been manufacturing dustless surface preparation equipment for use by nuclear facilities and hazardous waste
cleanup/remediation contractors since 1985. The equipment was developed  in the early 1980's for the removal of
                                                   1

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radioactive surface contamination during the Three Mile Island Unit 2 remediation efforts. The benefit derived from
the containment of the contamination enhanced the applicability of the technology for other surface contamination
removal projects including PCBs and lead-based paint.

BACKGROUND.
        In order to achieve sufficient metal surface preparation to insure proper coating and adherence of newly
applied paint, the NYSTA has  relied upon a commercial blasting procedure as  defined in the Steel Structures
Painting Council Specification SSPC-SP 6.  This procedure is a common standard for paint removal for bridges and
other similar structures.  The procedure is proficient at achieving the necessary surface cleanliness and profile for
the subsequent coating operation.
        Although the use of standard blast cleaning technologies are proficient in the removal of paint and rust and
surface preparation prior to repainting, there are disadvantages to its use:

        1.      Blast technologies present a problem with respect to containment of the blast media and removed
                paint.  Blasting technologies tend to pulverize the paint and the blast media resulting in the
                generation of a significant amount of airborne lead-contaminated particulates which are difficult
                to contain.   Contract  specifications usually dictate the requirements  for  varying levels  of
                containment  of the blast residues,  which  can range from simple curtains  or barriers  to
                sophisticated containment structures which include additional controls such as negative pressure
                or water  curtains.  Increasing regulatory attention toward reducing the  amount of lead in. the
                environment, fueled by increasing public concern and an aging infrastructure, will tend to force
                contractors to utilize the more sophisticated forms of particulate containment.  This containment,
                while minimizing environmental contamination, will tend to result in more hazardous localized
                environments for workers, and substantially higher costs for lead-based paint removal operations.
        2.      A high potential for worker  exposure to lead requires the use of extensive personal protective
                equipment to meet the new OSHA standards which were  published as an Interim Final Rule in the
                Federal Register on May 4, 1993. The new standard requires lead paint  removal contractors to
                institute worker protection practices  when airborne lead concentrations reach an action level of
                30ug/m3 of air when expressed as an 8 hour time-weighted average (8  hour TWA).  Worker
                protection practices include medical monitoring and surveillance, employee training, respiratory
                protection with higher protection factors, disposable protective clothing, upgraded personal hygiene
                facilities,  and more efficient engineering controls. These worker protection practice requirements
                become more pronounced when complete environmental containment structures are specified. The
                enhanced  worker protection requirements all serve to increase the cost for lead paint removal
                operations.

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         3.       Blast technologies using expendable media generate an excessive amount of waste material in the
                 form of lead-based paint chips mixed with substantial volumes of spent abrasive blast grit which
                 require disposal as a hazardous waste.  Additionally, depending upon the concentration of lead in
                 the waste abrasive blast mixture, additional treatment or stabilization of the waste may be required
                 to meet land ban disposal restrictions (LDR).

         Since 1986, the NYSTA has been aware of the potential adverse environmental and health effects of lead-
based chips contained in sandblasting debris generated during routine bridge maintenance. A policy of specifications
was developed by the  NYSTA for the containment of blast cleaning debris generated by paint removal operations.
The 1986 directives were focused on the handling and disposal of the waste material.  In addition, it was during
1986 that the NYSTA stopped using lead-based coatings on steel structures.
         The 1986 directives stipulate the use of blast cleaning methods which, as best as possible, contain the lead
contaminated debris for disposal as hazardous waste.  Provisions contained in standard NYSTA specifications call
for comprehensive coverage of potentially impacted surface areas, daily cleaning or vacuuming* of contaminated
surfaces and placement of residues in clean,  resealable, watertight 55 gallon steel drums.  Containment, however,
becomes even more difficult where the bridge spans  a continuously used right-of-way such as railroad or water
crossing.
         A potential solution to the difficulties encountered with the utilization of blast cleaning technologies for lead
paint removal would include a blastless paint removal system which had the capability to contain paint residues as
they are removed from the structure surface.  One such  technology  available for evaluation under  the WRITE
Program is the Pentek dustless needlegun system.

OBJECTIVES
        It is the intent of this WRITE Program evaluation  to comparatively analyze the technical and economic
advantages of employing Pentek's dustless  surface preparation  system for the containment and reduction of
hazardous waste relative to conventional abrasive blasting paint removal technologies.
        The objectives of the dustless paint removal and surface preparation system evaluation are as follows:

                 To determine the economics associated with removing lead-based paint from steel structures using
                 Pentek's dustless needlegun system relative to conventional abrasive blasting paint removal.
                 To quantify the potential reduction in the generation of hazardous waste through the utilization of
                 a blastless  paint removal technology.
                 To compare the ability of the Pentek System to contain  dust and particulates for the protection of
                 the environment and minimization of worker exposure.

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                                                SECTION 2
                                      TECHNOLOGY DESCRIPTION

 PAINT REMOVAL SYSTEMS
         There exists a variety of paint removal systems, most of which represent a variation of the traditional sand
 blast methods. Most recently, blast paint removal utilizing recycled blast media, such as steel shot or plastic beads,
 have been used. Other blast media used for specialized applications include baking soda and pelletized dry ice. High
 pressure water has been used both independently and in conjunction with an abrasive blast media.  Manual and
 powered hand tools,  along with chemical paint removal, are still utilized in areas inaccessible by other means.
         The disadvantage to some of these methods is that the residue generated as a result of the paint removal
 is increased by the introduction of a blast media or water, magnifying the waste disposal problem.  In addition, these
 methods do not address the concerns with respect to environmental and worker exposure.

 Mechanical Power Tool Paint Removal
         Power tools, such as rotary grinders and wire brushes and orbital, belt, and vibrating sanders, have been
 utilized for years to remove paints and coatings from both interior and exterior structures. The mechanism behind
 this process is primarily that of abrasive cutting action followed  by mechanical displacement of the paint by a
 rotating or reciprocating tool member at the point of operation.  The efficiencies of paint and coating removal are
 a function of the relative hardness of the coatings to be removed as compared to the abrasive impact of the power
 tool and the forces exerted by the operator and/or by the power tool itself, in addition to the tool's accessibility to
 different structure configurations.

 Pentek's Dustless Needlegun Sealer System
         The Pentek System is a form of power tool cleaning which combines material removal and containment.
 Pentek  Inc. manufactures three models of surface preparation tools as follows:

         1.       "MOOSE®"  - for scabbling and scarifying of large horizontal concrete surfaces.
        2.       "SQUIRREL III®" - for scabbling and scarifying smaller horizontal concrete surfaces  including
                corners and wall/floor joints.
        3.       " CORNER-CUTTER®" - hand-held needlegun for surface preparation in tight spots and/or vertical
                and  inverted horizontal steel or concrete surfaces.

        Material  removal is accomplished through the actions of pneumatically operated reciprocating cutting bits
or steel  needles which scarify and pulverize the paint or coating. This cutting action does not adversely impact the
structural integrity of steel substrates. The surfaces of concrete substrates,  on the other hand, can be removed in

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controlled layers of between 1/16 and 1/4-inch thick. Containment of the removed material is accomplished first
by utilizing an adjustable shroud located at the tool's point of operation to localize containment, and second,  to
transport the contained materials via vacuum to an attached VAC-PAC® containment vessel (DOT 17-H drum).
The vacuum head of the containment drum (VAC-PAC® system) is equipped with High-Efficiency Particulate Air
(HEPA) filters which serve to prevent the escape of airborne dusts at the containment vessel.  Based on field
experiences, Pentek claims to provide immediate capture of 100% of airborne dusts and 99.5% of solid debris at
the surface.
        The Pentek System utilized in this evaluation is comprised of the following components:

        1.       CORNER-CUTTER® needlegun - This hand-held,  pneumatic, piston-driven power tool  uses
                multiple 2mm diameter hardened steel needles which strike the surface 3500 times per minute,
                independently conforming and adjusting to surface irregularities, to scarify and pulverize the paint
                or coating and produce a surface profile required by SSPC-SP  11.  These specifications are
                depicted in Appendix A.  As many as three CORNER-CUTTER® units can be supported by a
                single vacuum system (see VAC-PAC®, Item 3 below). Each CORNER-CUTTER® consumes 5
                scfm of 90 psig compressed air and is capable of a production rate of 20-30 sq. ft. per hour on
                flat surfaces and 30-60 linear feet per hour on edges  and corners.

        2.       ADJUSTABLE  CONTAINMENT SHROUD  -  This component,  which is attached  to the
                CORNER-CUTTER®, provides containment of the dislodged material at the point of operation.
                Interchangeable end shrouds on the tool conform to the work surface, flat inside/outside corners,
                and custom contours to direct the vacuum flow and provide effective localized containment.

        3.       VAC-PAC® HEPA VACUUM/DRUMMING SYSTEM - This vacuum system provides negative
                pressure  at the CORNER-CUTTER® containment shroud,  which serves to complement the
                localized containment shroud's effectiveness by minimising fugitive dust emissions  from the paint
                removal point of operation.  The VAC-PAC® system may be operated remotely at distances of up
                to  100 feet  from  three  (3)  simultaneously operating  CORNER-CUTTER®  tools without
                compromising air flow or process containment. The  VAC-PAC® is equipped with self-cleaning
                first stage filters in order to maintain continuity of rated flow.  Self-cleaning is accomplished by
                blowing back high pressure pulses of air which restores the filter to near-original efficiency while
                depositing  the dislodged particulates  into the waste collection  drum.   First stage filtration
                efficiency is 95% at  1  micron.   A second stage high efficiency particulate air filter has an
               efficiency of 99.9% at 0.3 micron. Recommended filter service intervals are once per year for
               average usage.

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                 The design of the VAC-PAC® incorporates a controlled-seal drum fill system that allows an
                 operator to fill, seal, remove and replace the waste drum under controlled vacuum conditions.
                 This feature serves to positively control waste and dust and minimize the production of fugitive
                 dust emissions during waste drum changes.  The system is equipped with a bin level indicator
                 which informs the operator both visually and audibly that the waste drum requires changing.

         Vacuum units can be either pneumatically or electrically driven.  Specifications for the various systems are
 presented in Table 1:

                  Table 1.  Specifications for Air-Powered and Electric Powered Systems

Rated Vacuum Flow (scfm) [Note 1]
Rated Static Lift (in W.G.)1
Air Consumption @ 85 psig (scfm)
Rated Motor HP
Primary Roughing Filter Cartridges
Secondary HEPA Filters
Overall Dimensions: LxWxH
(inches)
Standard Waste Drum Size (gallons)
Approximate Weight
(pounds)
AIR-POWERED
Model 6
150
100
70
N/A
2
2@ 8"
dia.
48x28x72
21/52/55
650
Model 9D
225
100
105
N/A
3
3@8"
dia.
48x28x72
21/52/55
750
ELECTRIC-POWERED
Model 10
250
93
N/A
5
2
1@
12"x24"
48x28x72
21
950
Model 11
325
102 *
N/A
7.5
2
1@
12"x24"
48x28x84
21
1100
Model 12
550
102
N/A
15
3
1®
12"x24"
48x28x84
21
1250
1  Inches of vacuum measured by water gauge.

        Condensed operating procedures for the CORNER-CUTTER® and VAC-PAC® systems are included in
Appendix B. The CORNER-CUTTER® is schematically shown in Figure 1.
Conventional Abrasive Blasting
        In this method, compressed air is used to propel expendable abrasive particles against the surface to be
cleaned, to produce a surface profile required by SSPC-SP  6.  These specifications are provided in Appendix A.
The spent abrasive and paint debris are manually collected for disposal, usually as hazardous waste.  A conventional
abrasive blasting operation is schematically shown in Figure 2.

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                                   Corner-Cutter®
                                     Pneumatic
                                  Operation Housing
Removed Paint
Chips/Dust/Rust
                                Needle
               Piston     Anvi|    Holder
                                                                    Adjustable Containment
                                                                           Shroud
                                                                                              . Substrate
                     Figure 1.  Pentek CORNER-CUTTER® Schematic Diagram
Compressed
Air Supply In
                                        Blasting
                                        Grit and
                                      Compressed
                                           Air
                                                                         Removed
                                                                         Paint and
                                                                           Spent
                                                                         Abrasive
                                                                            Grit
                                                                Abrasive
                                                                 Stream
               Removed
               Paint and
                 Spent
               Abrasive
                  Grit
                                                                                      jm1490
                                    Painted
                                   ' Surface
                      Figure 2.  Abrasive Blasting Process Schematic Diagram

                                                  7

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                                               SECTION 3
                                            METHODOLOGY

         Both paint removal technologies were evaluated on New York State Thruway Authority (NYSTA) bridges
 located on Interstate 90 in Western New York, and as such receive essentially identical exposure to weathering and
 traffic flow. The abrasive blasting evaluation was performed on  NYSTA Bridge #10 on October 7 and 8, 1992.
 The Pentek evaluation was performed at NYSTA Bridge #1 on October  13, 1992.  The evaluations consisted of
 observations of work practices, equipment and labor requirements,  time required for various task completion as well
 as physical measurements of background, and work-in-progress airborne dust and lead concentrations during the
 paint removal operations.  Waste materials from both processes were collected and analyzed for lead concentrations.
 Interviews were conducted with NYSTA, Pentek, Inc., and paint  removal contractor personnel in order to obtain
 background information and historical data relative to the evaluations.

 BACKGROUND AND HISTORICAL DATA
 Conventional Abrasive Blasting
         NYSTA Bridge #10 is  of rolled beam design and is comprised of approximately 151 tons of steel  and
 14,946 sq. ft. of surface area by NYSTA calculations. The paint thicknesses on this bridge were estimated to range
 from  10 mils (.254 mm or 0.01 inches) to 13  mils (.330 mm or 0.013 inches), based upon NYSTA upon field
 measurements. Previous  testing  by NYSTA had determined the presence of lead-based paints as the primer  and
 finish coatings.
         Historically, surface preparation of similar NYSTA bridges using conventional abrasive blasting methods
 with expendable media to SSPC-SP 6 specifications has generated an average of 0.15-0.20 tons of waste per ton
 of steel consisting of spent abrasive, paint and miscellaneous dirt, rust and mill scale.  Theoretically, this would
 equate to 22.7-30.2 tons of waste generated by conventional abrasive blasting operations at this structure. This
 waste has been characteristically hazardous due to its leachable lead content.

 Pentek Dustless Needlegun System
         NYSTA Bridge #1 also of rolled beam design, is comprised of  approximately 315  tons of steel and
 approximately 25,000 sq ft of surface area. The paint thickness on this bridge was again estimated by the NYSTA
 to range from 10-13 mils. As with Bridge #10,  previous  testing by NYSTA had determined the presence of lead-
 based paints.
        Historically, paint removal from similar substructures would generate paint waste at a rate of 1 ounce per
 sq.  ft. of area cleaned. This waste has been characteristically hazardous due to its leachable lead content.

 Paint
         Based upon information provided by the NYSTA, the following represents specifications for the lead-based
paint on the structures evaluated.  These  are estimated averages based upon paint specification sheets and are used
in subsequent calculations and comparisons:

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                                       Table 2.  Paint Specifications
                  Ibs/gallou (liquid)                                    14.3 Ib/gallon
                  % solids (non-volatile)                                   62.2%
                  Ibs/gallon (solids)                                    8.9 Ib/gallon
                  density                                              66.3 Ib/cu. ft.
                  % Pb in solids (average)                                  20%
Abrasive Blast Media
         The abrasive blast media utilized in this evaluation consisted of Ebony Grit 20, non-silica abrasive provided
to the contractor by Barmin, Inc., of Waterdown, Ontario, Canada. The abrasive was certified to be lead-free based
upon technical data sheets provided by the supplier. The bulk density is 128 Ibs/cu. ft. as per technical data sheets,
provided by the NYSTA.
         Table 3 lists the typical chemical analysis of the blast media.

                          Table 3.  Typical Chemical Analysis of the Blast Media
                             Silica (as Iron Silica)                  32.6%
                             Silica (Crystalline)                    0.1%
                             Iron Oxide (Fep^+FeO)             54.0%          :
                             Alumina (A12O3)                      4.7%
                             Lime(CaO)                          2.3%
                             Magnesia  (MgO)                       1.3%
                             Alkalies (NazO+KjO)                  1.5%
                             Copper (Cu)                          0.8%
                             Zinc (Zn)                             2.8%
                                                                 100.1%
PROCEDURES - CONVENTIONAL ABRASIVE BLASTING
         In order to minimize the potential for cross-contamination and to satisfy bridge painting schedules and other
logistical concerns, these comparative evaluations were conducted on two separate bridges.  It was felt that this
would not compromise the quality of the data obtained due to the similarity of structures  and the paint coatings used
on each.
         The conventional abrasive blasting evaluation was performed  on October 7 and 8,  1992.   Day 1 was
dedicated to obtaining background information regarding the process and to observe and record both clean-up
activities from the prior day's work and set-up activities for work to be performed. Day  1 was also used to perform
background air monitoring of lead-in-air concentration to be used as  a baseline for both technology evaluations.
Day 2 activities consisted of observing work procedures, conducting personal and area air monitoring and recording
appropriate measurements to assess productivity and waste generation.
         Employee and supervisor interviews were conducted to develop information  relative to time and labor
requirements for daily cleanup  and job  site mobilization and demobilization  activities.  This  information was
integrated with job site observations to calculate estimates of man hours required and their associated costs.

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 Set-up/Mobilization
         Job set-up and mobilization required seven workers for 1.5 hours each and consisted mainly of establishing
 traffic control, positioning equipment and installing hanging enclosure tarps and ground cover tarps.  Equipment
 used consisted of two 7-ton capacity abrasive blast reservoir pots with compressors, two truck-mounted mobile
 platforms and several straight body and pick-up trucks for hauling equipment and transporting personnel. The work
 enclosures, which are contractually required by the NYSTA consisted of canvas tarpaulins which were suspended
 from cables attached to the bridge structure so as to form a three-sided enclosure,  the closed sides facing traffic
 during abrasive blasting operations.  The tarpaulins extended from the underside  of the bridge structure to the
 ground cover tarps placed below.  The suspended tarps were fastened at the grommeted edges with clips to minimize
 sailing due to winds or passing traffic.

 Abrasive Blasting Operations
         Abrasive blasting operations conducted on October 8, 1992 were performed simultaneously on the interior
 eastbound  and westbound lanes.  Two operators with abrasive blasting nozzles were utilized per section, which
 consisted of six 32 inch x 12 inch flange I-beams placed 20 feet on center with connecting 13 inch steel channel
 bracing and mechanical fastening with nuts and bolts.  The beam undersides  are elevated approximately  15 feet
 above the center median and road surfaces, which necessitated the use of a mobile elevated work platform for access
 by the abrasive blast nozzle operators.  Only the operations on the westbound section of the Thruway bridge were
 considered for the purposes of this evaluation. The operations conducted concentrated on the 30 foot length of I-
 beam extending from the center of the westbound lane to the support column located in the median, in addition to
 all connecting braces and supports. A total of approximately 1180 sq. ft. of surface was completed during the 4-hour
 evaluation.  The blasting grit vessels and compressors •were located approximately 150 feet from the work zone.
 Grit usage, based on past experiences, was estimated to be 4-7 tons per day of average production per vessel, based
 upon 1/2 ton/hour of grit usage per nozzle operator.  This usage was expected to  produce specification surface
 preparation at a rate of 120 sq. ft. per hour per operator.
         Prior to  commencement of the evaluation  phase, the two nozzle operators performing work  on  the
 westbound section were each fitted with two air sampling pumps (SKC low  volume) which were calibrated to
 provide a flow rate of 1.5-1.7 liters of air per minute using an SKC digital calibrator. The media for collection of
 total and respirable dusts emitted  during the blasting process consisted of Millipore 37mm, 0.8/i MCEF Matched-
 Weight Cassettes with cyclone separators for respirable dust collection. The nozzle operators were  dressed  in
 standard work clothes with cloth coveralls and were equipped with air supplied, type  CE abrasive blasting helmets.
 Work progressed continuously from 9:45 am to 1:45 pm with three short (5 minute) breaks taken for the purpose
of changing air monitoring  cassettes.   The operation was  very noisy, however, sound  pressure levels were not
evaluated.  Hearing protection was available, but was not utilized by all workers.
                                                   10

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         During the abrasive blasting operation, it was very apparent that the tarpaulins installed to enclose the
 operation were less than 100% efficient in containing the abrasive blast grit and paint removal residues. Visible
 plumes of dust were noted escaping from the enclosure and depositing along the Thruway and elevated sections of
 roadway and median areas. Light winds were noted to be from the East Northeast at 1-5 mph and  were not
 considered to be a factor in this evaluation. The weather was clear and 65°.

 Clean-up
         The clean-up activities observed were performed at  the termination of abrasive blasting activities  on
 October 7, 1992, one day prior to the abrasive blasting operation evaluation.  The clean-up activities were described
 by NYSTA and  the contractors to be typical and  consisted of manually dry sweeping spent abrasive and paint
 residues, progressively elevating ground tarps  to consolidate wastes and then manually shoveling the  collected
 materials into openhead 55 gallon  steel drums.  The section cleaned  was approximately 40 feet x 100 feet with a
 3:1 sloped earthen embankment from the road  surface to the bridge and bearing supports.  The slope served to
 facilitate the consolidation of spent  abrasive and paint, as much of the material was swept yja gravity to the
 collection points.  Manpower consisted of six laborers and clean-up of this  section took 1.5 hours.  The clean-up
 operation was noted to be very dusty.  Laborers wore only standard work clothes.  Paper dust masks (non-toxic
 variety) were available, but noted to  be used by only one worker.
         Additional clean-up was also required of the roadway above which had received overspray or deposits of
 fugitive dusts.  The material was dry swept and shoveled to drums.

 PROCEDURES - PENTEK DUSTLESS NEEDLEGUN SYSTEM
         The Pentek System evaluation was performed on October 13, 1992 at NYSTA Bridge #1, which was not
 scheduled for paint removal and repainting until the spring of 1993.  Evaluation  activities consisted of observing
 and documenting mobilization, paint removal, and  clean-up and demobilization activities, as well as performing
 personal and area air monitoring and making necessary measurements to assess productivity and waste generation.

 Set-up/Mobilization
        Job set-up and mobilization required four workers for 0.5 hours each and consisted primarily of positioning
equipment.  Equipment used consisted of one pick-up truck which carried the VAC-PAC® system and CORNER-
CUTTER® units and hauled a trailer with an air compressor.  There were no containment enclosures or ground
cover tarpaulins used.

Pentek Dustless Needlegun Paint Removal Operations
        The Pentek System was evaluated above the upper section of the sloped embankment on Bridge #1 so as
to eliminate the necessity of using elevated working platforms and thus simplify later cost comparisons.  Three
                                                   11

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 operators each with a CORNER-CUTTER® unit were employed for paint removal at the evaluation area which
 consisted of four 34 inch x 12 inch flange I-beams with connecting 13 inch steel channel bracing and connecting
 hardware. A total of approximately 119 sq. ft. of surface was completed during the 3 hour,  15 minute evaluation
 period, however, Pentek, Inc. reported that this is most likely a depressed number due to several factors including,
 but not limited to, the inexperience of operators and their unfamiliarity with SSPC-SP 11 requirements. Pentek, Inc.
 management stated that this production number should be closer to 260 sq.  ft. based upon previous experience.
         Prior to commencement of the evaluation, two of the three CORNER-CUTTER® operators were fitted with
 two air sampling pumps each, with appropriate media for collection of total and respirable dusts emitted during the
 paint removal operations. The CORNER-CUTTER® operators were dressed in Tyvek suits and were equipped with
 full-face, negative pressure air-purifying respirators with high-efficiency particulate cartridges. Work progressed
 continuously from 8:30 am to 12:30 pm with three work breaks totalling 45 minutes.
         During the Pentek  System paint removal operations, there were no visible emissions of dust or paint
 residues.  The operation was very noisy, however, sound pressure levels were not evaluated and operators were
 utilizing hearing protection.  The CORNER-CUTTER® units removed the finish paint coat layers with little
 difficulty, however, the orange primer required considerably more effort and time, which served to further depress
 the square foot production area expected by Pentek, Inc. personnel.

 Clean-up
         Upon  completion of paint removal operations, it was apparent that nearly all paint residues had been
 effectively contained and collected by the Pentek System. Some minor residues consisting of large paint chips and
 rust were easily collected using the vacuum hose attached to the CORNER-CUTTER®. Clean-up operations then
 consisted of wiping down, disassembly and storage of equipment which required four workers for 0.5 hour.  This
 operation would normally only be conducted after job completion and not on a daily or shift-by-shift basis.

 SAMPLING AND ANALYSIS PLAN
         Sampling and analysis for this evaluation was conducted in accordance with the approved Quality Assurance
 Project Plan (QAPjP).
         Air sampling consisted of pre-work samples taken at Bridge #1 on October 7, 1992, to establish a baseline
of background airborne dust and lead in air, and work-in-progress samples of operator breathing zones and work
areas for both the abrasive blasting and Pentek System operations. All air sampling was conducted over a 4-hour
period coinciding with  the technology evaluations. Air samples were collected on 37mm, 0.8/t matched-weight,
mixed  cellulose ester fiber (MCEF) filter cassettes. This type of filter media was chosen so as to allow both dust
and lead analyses to be performed on the same cassette, thus minimizing the amount of sampling equipment and
the number of samples required for this evaluation. Digestion procedures were evaluated using an  SRM (NIST
 1579).  The first procedure, from NIOSH 7082, resulted in a 65.2% recovery. The second procedure, a modified
                                                  12

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version of NIOSH 7082 as described in the NTIS publication "Standard Operating Procedures for Lead in Paint by
Hotplate - Microwave - Based Acid Digestions and Atomic Absorption or Inductively Coupled Plasma Emission

Spectrometry", resulted in a recovery of 121 %. The second procedure was utilized for this evaluation. Samples were

analyzed for the following:

                                   Table 4.  Air Analysis Methods

                                Parameter                Method
                           Total Dust                    NIOSH 0500
                           Lead in Total Dust             NIOSH 7082
                           Respirable Dust                NIOSH 0600
                           Lead in Respirable Dust        NIOSH 7082
        Waste samples were collected from both operations by compositing grab samples and were analyzed as

follows:


                                  Table 5.  Waste Analysis Methods

                 	Parameter	Digestion Method	Method	

                        Total Lead        Modified NIOSH 7082     SW-846 7420
                        TCLP Lead                3010             SW-846 7420
                                                 13

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The following Table 6 summarizes the type and location of samples:
                                            Table 6. Type and Location of Samples


Total Nuisance Dust
Non-QC (primary)
Field blank2
Total Lead in Total
Nuisance Dust
Non-QC (primary)
Field blank2
Matrix spike
Total Respirable Dust
Non-QC (primary)
Field blank2
Total Lead in Resoirable
Dust
Non-QC (primary)
Field blank2
Matrix spike
TCLP Lead in Waste
Non-QC (primary)
Matrix spike
Matrix spike duplicate
Total Lead in Waste
Non-QC (primary)
Matrix spike
Miscellaneous
Independent check3
(Lead in paint SRM)
Number of Analyses Performed
Sample Points*
a
2
2
2
2
1
2
2
2
2
1
0
0
0
0
0
0
b
1
1
1
1
1
1
1
1
1
1
0
0
0
0
0
0
c
1
1
1
1
0
1
1
1
1
0
0
0
0
0
0
0
d
2
2
2
2
1
2
2
2
2
1
0
0
0
0
0
0
e
1
1
1
1
1
1
1
1
1
1
0
0
0
0
0
0
f
1
1
1
1
0
1
1
1
1
0
0
0
0
0
0
0
g
2
2
2
2
1
2
2
2
2
1
0
0
0
0
0
0
h
0
0
0
0
0
0
0
0
0
0
1
1
1
1
1
0
i
0
0
Total
0
0
0
Total
0
0
.Total
0
0
0
Total
1
1
1
Total
1
1
Total
0
Total
Total
101
JO.
20
10'
10
_5_
25
10
10
20
10
10
5 ,
25
2
2
2
6
2
2
4
1
1
' Sample Points:
          a. Background                                  d. Abrasive blasting area                 g. Pentek area
          b. Abrasive blasting operator #1                   e. Pentek operator #1                    h. Abrasive blasting waste drams
          c. Abrasive blasting operator #2                   f. Pentek operator #2                    i. Pentek waste drums
          Each sample consists of 3, 37mm matched weight 0.8 micron MCEF filter cassettes. Samples to be taken in consecutive 80-minute
          sequences with a maximum air volume throughput of 133 liters/cassette. The analysis results are additive for both total dust and lead
          in total dust.
          Field blanks for air monitoring are included at the rate of one blank per sample set for a total of 10 field blanks. Each blank is to
          be analyzed for dusts and total lead.
          The independent check standard will consist of a Standard Reference Material (SRM) for lead based paint.  The SRM was used to
          determine the adequacy of digestion procedures used in lead analysis and also for performing necessary matrix spikes.
                                                             14

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         Work area samples for the abrasive blasting operations were obtained within the tarpaulin work enclosure
approximately 25 feet distant from the points of operations.  No evaluations were performed outside the work
enclosure. Work area samples for the Pentek operations were conducted approximately 25 feet distant from the point
of operations, but were more vulnerable to changing air currents due to Thruway traffic.
         Waste quantities generated by the abrasive blasting operations were determined by examining Line 11 of
the New York State Hazardous Waste Manifests from Bridge #10 and extrapolating data based upon total surface
areas of the bridge versus total surface area of paint removal
         Waste  quantity generated by the Pentek operations was determined by performing net and tare drum
weights of the VAC-PAC® system collection drum. This figure could then be extrapolated to total quantity for an
entire structure based upon surface area of paint removal during the  evaluation.
         Surface areas cleaned were calculated based on direct measurement with a standard 25 foot carpenter's tape
measure.
                                                    15

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                                               SECTION 4
                                      RESULTS AND DISCUSSION

PERFORMANCE AND PRODUCT QUALITY
         The contract specifications for the bridges evaluated called for SSPC-SP6 (commercial blast) to remove
all visible paint from two-thirds of the bridge surface area prior to repainting. This specification was augmented by
NYSTA's requirement for all paint to be removed. This additional requirement was included in order to minimize
the potential for lead releases and exposures during future maintenance operations. The abrasive blasting operation
was able to meet or surpass this level of surface preparation for all areas of the structure.
         The Pentek system, by definition, cannot meet SSPC-SP6 specifications as it is not an abrasive blasting
technology. As  evaluated  according  to  the  contract surface  preparation  specifications, the Pentek System
demonstrated a less efficient removal of paint, especially the orange primer coat, and was also less effective while
performing around irregular surfaces such as nut and bolt heads and in inaccessible corners. The NYSTA bridge
inspectors indicated that a post-blast would be required for  the Pentek-cleaned sections in order to meet contract
specifications.
         Historical information provided by Pentek indicates the post-blast operation necessary to ashieve the desired
surface quality would typically require consumption of about 1 Ib. of abrasive/sq ft of surface area. Pentek reported
that spent abrasives would typically be classified as non-hazardous, however, this would need to be determined on
a case-by-case basis.
         The Pentek System demonstrated superiority in its potential to minimize the generation of hazardous waste
(see Table 14).

ENVIRONMENTAL, HEALTH AND SAFETY
         The results of the air sampling performed before and during the evaluations is presented in Table 7.  Air
sampling was performed for four hour periods on two abrasive blast operators and two Pentek CORNER-CUTTER®
operators in addition to  work areas proximate to the paint removal activities.  There was no sampling performed
on support labor or during mobilization, demobilization or cleanup operations, and no area  samples were obtained
from outside the abrasive blasting containment area.
         As can be seen from the abrasive blasting sampling data, OSHA Permissible Exposure Limits (PELs) were
exceeded for total dust, respirable dust and total airborne lead on three samples and respirable lead on two of four
samples based upon eight hour  time-weighted  averages (TWA).   This is assuming that  no other dust or lead
exposures are encountered for the remainder of the work day. If exposures were to stay constant for the entire work
period, PELs would have been exceeded by all samples based upon levels encountered in the four hour sampling
period.  Nonetheless, even extrapolating eight hour TWA values from the four hour sampling period, all sampling
results obtained for the abrasive  blasting operation are above the OSHA action level for lead of 30 /i/m3 or 0.03
mg/m3 of air.  This value is irrespective of personal protective or respiratory protective equipment used.
        The Pentek air sampling results exhibited no detectable airborne lead or respirable dust, and only negligible
amounts of total dust.
                                                   16

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                                        Table 7.  Air Sampling Analytical Results

Sampling
Point
Background
Background (D)
Abrasive Blast
Area
Abrasive Blast
Area (D)
Abrasive Blast
Operator #1
Abrasive Blast
Operator #2
Pentek Area
Pentek Area (D)
Pentek
Operator #1
Pentek
Operator #2
Sampling Period
Total
Dust
mg/ms
0.6
ND
41.2
34.1

8.0

89.2

0.2
ND
2.9

2.7

Respirable
Dust
mg/m5
0.2
ND
12.5
11.9

0.7

12.3

ND
ND
ND

ND

Total Pb
mg/m'
0.01
ND
0.32
1.4

0.1

0.89

ND
ND
ND

ND

Respirable
Pb
mg/m'
ND
ND
0.26
0.1

ND

0.24

ND
ND
ND

ND

8 Hour TWA"
Total'
Dust
mg/m'
0.3
ND
20.6*
17.1*

4.0

44.6*

0.1
ND
1.5

1.4

Respirable2
Dust
mg/m'
0.1
ND
6.3*
5.9*

0.4

6.2*

ND
ND
ND

ND

Total3
Pb
mg/m'
.005
ND
0.2*
0.7*

0.05

0.45*

ND
ND
ND

ND

Respirable
Pb
mg/m3
ND
ND
0.1*
0.05

ND

0.12*

ND
ND
ND

ND

LEGEND:       D = Duplicate sample
                1 OSHA PEL = 15 mg/m3
                3 OSHA PEL = .05 mg/m3
                *  Exceeds OSHA PEL
ND - Not detectable
2 OSHA PEL = 5 mg/m3
4 Assuming no exposures during remainder of work day totalling 8 hours.
                N.D. (not detectable) is used in all cases where all contributing values are below the detection limit.  In
        cases where all contributing values are above the detection limit, the arithmetic mean is used. If one or more values
        are below the detection limit, and the remainder above, then the arithmetic mean of the values is used, preceded
        by the "less than" sign (<) where applicable.

                It is customary for the laboratory to report all non-detectable or zero values at the DL followed by a "U"
        or undetectable designation.  The values appearing in Table 7 are actual values derived from raw data.  Therefore,
        even if the lab report shows 1.7 (U), the actual value may be zero.  In these cases, the zero value is used to
        complete the applicable Table 7 calculation. For example, for the background total dust sample, the actual amounts
        of dust detected are 0.2, 0.0 and O.Omg, respectively, with an air volume of 360 liters. This calculates to 0.55 or
        0.6 mg/m3.
                                                          17

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         Total and respirable lead values, as they appear in Appendix E, are in units of ing/I/cassette and required
conversion to mg/m3 via the formula.
         Conc.(mg/m3) = Cs.Vs, + CsWs-, + Cs,Vs,
                                 V,
         Where  Cs = concentration of Pb in mg/ml in sample
                 Vs = volume of sample solution
                 Vt = total volume of air sampled

         The respiratory protection worn by the abrasive blasting nozzle operators appeared to have been adequate
for this particular job; (i.e, A type CE, continuous flow respirator carries a protection factor of 25 as assigned by
NIOSH which provides protection for up  to 1.25 mg/m3 of lead in air).  This level was exceeded by one area sample
(1.4 mg/m3). This is probably not true for ground support labor  or cleanup laborers who performed their duties
without benefit of any respiratory protection.
         Because the tarpaulin containment systems were less than 100% efficient, visible plumes of potentially lead-
contaminated material exited the immediate work area.  This potentially provides a source of lead exposure to the
general public and the environment.

ECONOMICS
         The economic evaluations depicted here are not intended to be all-inclusive or representative of all potential
project costs. Specifically excluded from  this  evaluation  are costs  related to capital  equipment,  equipment
maintenance, vehicles, utilities and fuel,  containment structures , and personal protective equipment.
         Observations and interviews were utilized in lieu of in-depth time studies for determining and calculating
labor costs. For the purposes of simplicity and uniformity, a standard  labor rate of $15.00 per hour was assumed
for all labor classifications.

Labor Costs
         Labor activities were divided into five categories: Paint Removal Operations, Support Labor, Mobilization,
Demobilization and Cleanup.

         Table 8 shows the paint removal operators' (abrasive blasting nozzle and Pentek CORNER-CUTTER®
operators) labor time and surface area of paint removal performed during the evaluation period.  This data is used
to calculate a production rate in sq. ft. per hour per operator, a unit cost of $/sq. ft.  and a "total" cost assuming
work on an identical 15,000 sq. ft. bridge.  As can be seen, at the  production rates demonstrated, it would require
approximately eight Pentek systems utilizing three CORNER-CUTTERS® each to equal the production rate of the
two operator abrasive blasting process. This translates into approximately an eightfold increase in production labor
requirements and a greater than tenfold increase in associated production costs for the Pentek System.
                                                    18

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                            Table 8.  Labor Costs - Paint Removal Operations



Abrasive
Blasting

ff
Operators
2


Time

-------
                                          Table 9.  Labor Costs
                       Paint Removal Operations - Support Labor (Entire Structure)

Abrasive
Blasting
Pentek
Total Time
(far.)
75
406
Rate
($/hr.)
$15.00
$15.00
Total
Cost
$1125
$6090
         Table 10 shows labor costs for daily mobilization. Again, here it is assumed that eight Pentek Systems
 requiring thirty-two employees would be required.  As before,  labor costs are higher due to sheer number of
 employees, however, the daily time required for this activity is reduced.


                                  Table 10.  Labor Costs - Mobilization

Abrasive
Blasting
Pentek
#
Personnel
7
32
Rate
$/hour
$15.00
$15.00
# Hours
Daily
1.5
0.5
#Days
6
6
Total
Cost
$945
$1440
         Table 11 depicts a one-time demobilization. Again, Pentek costs are higher due to the number of workers
required.  As with mobilization, however, the times required for this activity are reduced.

                                 Table 11. Labor Costs - Demobilization

Abrasive
Blasting
Pentek
# Personnel
7
32
Rate
$/hour
$15.00
$15.00
# Hours
2
1.5
Total Cost
$210.
$720.
        Table 12 shows costs associated with cleanup activities for a ground surface area of 26,000 sq. ft. wMch
would be typical for a 15,000 sq. ft. bridge. Here costs are substantially higher for the abrasive blasting process
due to the requirements for raising and sweeping ground tarpaulins and manual handling of the abrasive blast debris.
                                                   20

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                           Table 12.  Cleanup - 260' x 100' - Ground Area Only

Abrasive
Blasting
Pentek
#
Personnel
7
32
# Hours'
Section
8
0.5
#
Sections
6.5
N/A2
Total
Man
Hours
364
20
Rate
$/hour
$15.00
$15.00
Total Cost
$5460.
$240.
1         One section = 4000 sq. ft of flat ground area.
2        Cleanup of ground sections not applicable due to minimal residues noted.

         Table 13 compiles the total labor costs developed in Tables 8-12, and shows the Pentek System labor costs
to be approximately three times that of abrasive blasting.

                                  Table 13. Total Estimated Labor Costs
                                             Abrasive Blasting	Pentek
Paint Removal
Support
Mobilization
Demobilization
Cleanup
Labor Totals
$1500
$1125
$945
$210
$5460
$9240
$18450
$6090
$ 1440
$ 720
$ 240
$26940*
* Not including additional labor which would be necessary if a post-blast were required to meet surface preparation specifications.
Material Costs
         It was assumed that all  Pentek equipment was  reusable and that the only expendable material to be
evaluated would be the abrasive blasting media used. Table 14 shows this usage and the approximate cost based
upon operator usage of 0.5 ton per hour per operator.
                                        Table 14.  Materials Costs

Abrasive
Blasting
'Tons of
Abrasive Grit
50.8
Cost
$/ton
$38.50
Total
$1957
                             Pentek            0           —         0
                 1        Based upon 0.5 ton of grit usage/hour/operator.
Hazardous Waste Generation and Disposal Costs
         Table 15 shows the amount of wastes generated during the  evaluation periods and extrapolates  these
numbers to a complete bridge. As can be seen, abrasive blasting generates approximately 40 times more waste than
the Pentek System due to the use of expendable blasting media. The total waste generated by the abrasive blasting
process was obtained from New York State Hazardous Waste Manifests and weights determined at the hazardous
waste disposal facility.  It should be noted that only 31 tons of waste was disposed from this job, and that, based
upon usage estimates, approximately 50.8 tons of abrasive grit was used (see Table 14).

                                                   21

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                         Table 15.  Hazardous Waste Generation and Disposal Costs
Removal
Area
(sq.ft.)
Abrasive
Blasting
Pentek
Pentek
1180

119
—
Waste
Generated (Ibs)
Theo. Actual
4170

7.4J
—
1 4807

11.5
—
Lbs. Waste
sq.ft.
4.1

0.1
l.O4
Est. Total
Waste flbs.)
61,500

1500
15,000
Total Waste
(tons)
30.8

0.75
7.5
'Disposal
$/Ton
$300

$300
$300
Total
Disposal $
$9240

$225
$2250
  (post-blast
  if required)
         Theoretical waste generated based upon .175 tons waste/tons of steel cleaned.
         Theoretical waste generated based upon 11.5 mil. paint thickness and paint solids density of 66.3 lbs./ft?.
         Industry average for bulk waste including transportation.
         Theoretical post-blast abrasive usage as per Pentek historical data.

         Table 16 shows a summary of total  costs for labor, materials and hazardous waste disposal.

                                            Table 16.  Total Costs

                                               Abrasive Blasting      Pentek
Labor
Materials
Haz. Waste
Disposal
$ 9240.00
$ 1957.00
$ 9240.00

$26,940
$ 0
$ 225

                               Total                $20,437          $27,165*
*  Not including additional labor, materials and waste disposal costs if a post-blast was required.


         Table  17 shows analytical results for abrasive blasting and Pentek waste samples obtained during the
evaluation periods.  As can  be seen,  both wastes are considered characteristically hazardous for lead by TCLP
analysis.  Total lead analysis shows the Pentek waste to be approximately 39% lead by weight. This waste may now
or in the future, be acceptable by some secondary smelting operations for lead recovery which would present a less
expensive disposal option.   For both wastes,  land ban disposal restrictions  (LDRs) require that treatment or
stabilization be  performed and that a teachable lead in waste concentration of less than 5 mg/£ be attained prior to
land disposal.
                                     Table 17.  Waste Analytical Results
Waste Type
Abrasive Blast
Abrasive Blast
(MD)3
TCLP Pb
rng/61
78.0
77.7
Total Pb
/*g/g
14,600
75602
                                Pentek
                                Pentek (MD)3
440
391,000
381,000
                                  Above EPA maximum of 5.0 mg/£ categorizes waste as hazardous.
                                  Difference due to reported non-homogeneity of waste sample.
                                  MD = Matrix Duplicate
                                  TCLP MD not performed
                                                      22

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          The estimate of 1 oz. of paint per ft2 of area cleaned was provided by Pentek based upon historical data.
 The actual paint removal,  based upon this evaluation, is 11.5 lbs/119 ft2 or 1.55 oz./fi2 of area cleaned.  This
 calculates to 114 Ibs. of paint waste generated by the abrasive blasting operation.  Assuming that 8000 Ibs of grit
 were used and an average of 38.6% Pb in the paint, the average concentration of Pb now should not exceed 5500
 ppm (0.386 x 114 x 10*78000 = 5500 ppm Pb).  This value is reasonable as compared to the analytical results
 obtained on the abrasive blasting waste when considering that not all of the paint  was removed by the Pentek
 process.  Had all the paint been removed, it is reasonable to assume that paint removal could approximate the 2.1-
 4.1 oz/ft2 required to reconcile the 7560-14,600 ppm analytical results.

 ANALYTICAL DATA QUALITY ASSURANCE
          Although not all quality assurance objectives relative to precision and accuracy of analytical results were
 met, all data is deemed useable based upon the following results.

 Solid Matrix Data Quality Objectives fDOQ')
         Pentek Bridge #1 analytical results displayed excellent reproduceability (381,000 vs. 391,000 pg/g) for a
 relative percent difference (RPD) of 0.13 % which is significantly lower than the DQO of < 20 %.  NYSTA Bridge
 #1 analytical results displayed a significantly higher RPD of 31.8% (7,560 vs. 14,600 /xg/g). Although the RPD
 for the NYSTA Bridge  #10 duplicate analysis exceeds the stated DQO, these  results are usable  based upon the
 Pentek results  and the reproduceability of results obtained from the analyses of the standard reference material
 (SRM). The reported apparent heterogeneity of the NYSTA Bridge #10 samples is believed to be the reason for this
 higher RPD as opposed to any analytical control variances.
         Accuracy, measured as  % recovery, was 102% for NYSTA Bridge #10 and 83.5% for Pentek Bridge #1.
 These results, coupled with a 99.7 % SRM recovery support the useability of the data.  Precision results are all well
 within Quality Assurance Project Plan stated DQO's of 50-140%.

 TCLP  Extracts
         NYSTA Bridge #1 analytical results displayed excellent reproduceability (78.0 vs. 77.7 mg/1) for a RPD
 of 0.2%, with an accuracy  as % recovery of 101.9% and a SRM recover  of 99%. These results all support the
 useability of the data.
         The failure to meet  the DQO for the Pentek Bridge #1 matrix  spike is the  result of  serial dilutions
necessary to accurately quantitate the sample and is not reflective of uncontrolled analytical recoveries.
                                                   23

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                                                SECTION 5
                                              CONCLUSIONS

         Although, the economic and product quality aspects tend to favor conventional abrasive blasting over the
Pentek system for lead paint removal, the volume of hazardous waste generated and its associated increased costs
need to be factored in when considering the surface preparation specifications of similar projects.
         The decision to specify a lead paint removal system should also be strongly influenced by the potential
impacts to worker health and safety and to die environment. Conventional abrasive blasting, as suggested by this
evaluation, exposes workers  to airborne lead levels which exceed current Permissible Exposure Limits (PELs) as
established by OSHA, and potentially exposes  the local environment to unacceptable levels of lead-contaminated
dusts. On this job alone, based upon the estimated abrasive blast grit usage and the total lead analysis results in the
waste samples, it can be estimated that between 465 and 900 Ibs. of lead were released to the local environment.
The safe use of the abrasive blasting process  for the removal of lead-based paints  requires the utilization of
additional controls which specifically address the issues of worker health and safety and lead-contaminated residuals
containment. These controls, depending on the sensitivity of the worksite locations, may require highly engineered
containment systems that, while providing  for the necessary levels of worker  and environmental safety,  also
significantly increase total paint removal costs.
         The option of using alternative processes such as  the Pentek dustless needlegun system becomes more
economically advantageous when sophisticated containment structures, personal protective equipment, training and
medical surveillance programs and their associated costs become unnecessary due to the Pentek system's ability to
control potential contaminants at the source.
         Additional evaluations of post-blasting requirements necessitated by the Pentek system's apparent inability
to remove paint from inaccessible areas, should be performed.  Also, future research and development activities for
Pentek and other similar blastless technologies should focus on maximizing paint removal efficiencies, especially
in inaccessible areas,  to eliminate the necessity for post-blasting activities, which would increase overall paint
removal costs.
         The potential benefits of using the Pentek dustless needlegun system in helping to address the global lead-
based paint removal problem are clear. These include:
                 Substantial  reductions (up to 97.5%) in the generation of hazardous wastes.
                 Enhanced worker health and safety through  substantial reduction (up to 99 %) of airborne dusts
                 and lead-containing residues, thus eliminating the necessity for additional administrative controls
                 necessary to comply with OSHA  standards.
                 Enhanced protection of the local environment through substantial reduction (up to 99 %) of fugitive
                 emissions of lead-containing dusts and spent abrasive debris.  This may preclude the necessity for
                 additional measures in order to comply with federal, state and local regulations dictating control
                 over multi-media toxic chemical releases.
                                                    24

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Optimization of the concentration of lead in solids, thus enhancing the potential to reclaim the
metal for reuse rather than disposal in secure landfills.
Economically competitive when factoring in costs of sophisticated containment structures and
engineered systems to assure worker health and safety and environmental protection.
                                    25

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                          APPENDIX A

           SURFACE PREPARATION SPECIFICATIONS

                           SSPC-SP 6
                           SSPC-SP 11

Reprinted from Volume 2, "Standards and Specifications" of the Steel
Structures Painting Manual, Sixth Edition, 1991, Steel Structures Painting
Council, 4516 Henry Street, Pittsburgh, PA  15213.
                               26

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                                                                                               SSPC-SP 6
                                                                                             March 1. 1985
                                                               September 1, 1989 and June 1, 1991 (Editorial Changes)
                               Steel Structures Painting Council
           SURFACE  PREPARATION  SPECIFICATION  NO. 6
                              Commercial Blast  Cleaning
1. Scope
    1.1 This specification  covers the requirements  for
Commercial Blast Cleaning of steel surfaces by the use of
abrasives.
2. Definition
    2.1 A Commercial  Blast Cleaned surface, when
viewed without magnification, shall be free of all visible
oil, grease, dirt, dust, mill scale, rust, paint, oxides, corro-
sion products, and other  foreign matter, except for stain-
ing, as noted in Section 2.2.
    2.2 Staining shall  be limited to no more than 33 per-
cent of each square inch  of surface area and may consist
of light shadows, slight  streaks, or minor discolorations
caused by stains of rust, stains of mill scale, or stains of
previously applied paint.  Slight residues of rust and paint
may also be left in the bottoms of pits if the original sur-
face is pitted.
    2.3 ACCEPTABLE VARIATIONS IN  APPEARANCE
THAT  DO  NOT  AFFECT SURFACE CLEANLINESS as
defined in Sections 2.1 and 2.2 include variations caused
by type of steel, original surface condition, thickness of
the steel, weld metal, mill or fabrication  marks,  heat
treating,  heat affected zones, blasting abrasive,  and dif-
ferences  in the blast pattern.
    2.4 When painting is specified, the surface  shall be
roughened  to a degree  suitable for  the specified paint
system.
    2.5 Immediately prior to paint application, the surface
shall  comply with  the degree  of cleaning as specified
herein.
    2.6 SSPC-Vis 1-89 or other visual standards of surface
preparation may be specified to supplement the written defi-
nition.
"NOTE:  Additional information  on visual standards is
available in Section A.4 of the Appendix.

3.  Blast Cleaning  Abrasives
    3.1  The selection of abrasive size and type shall be
based on the type, grade, and surface  condition of the
steel   to  be cleaned, type of blast  cleaning  system
employed,  the finished  surface to be produced (cleanli-
ness  and roughness), and  whether the  abrasive will be
recycled.
'Notes are not requirements of this specification.
    3.2 The cleanliness and size of recycled abrasives
shall  be  maintained  to insure  compliance  with  this
specification.
    3.3 The blast cleaning abrasive shall be dry and free
of oil, grease, and other harmful materials at the time of
use.
    3.4 Any  limitations or restrictions on the use  of
specific abrasives, quantity of contaminants, or degree of
embedment shall be included in the procurement docu-
ments (project specification) covering the work, since
abrasive embedment and abrasives containing contam-
inants may  not  be acceptable for some  service  re-
quirements.
'NOTE: Additional information on  abrasive selection is
available in Section A.2 of the Appendix.

4. Reference Standards
    4.1 If there is a conflict between the cited reference
standards and this specification, this specification shall
prevail unless otherwise indicated  in the  procurement
documents (project specification).
    4.2 The  standards  referenced  in this specification
are:
    SSPC-SP 1    Solvent Cleaning
    SSPC-Vis 1-89 Visual  Standard for Abrasive  Blast
                  Cleaned Steel

5. Procedure Before Blast Cleaning
    5.1 Before blast cleaning, visible deposits of oil or
grease shall be removed by any of the methods specified
in SSPC-SP 1  or other agreed upon methods.
    5.2 Before blast cleaning, surface imperfections such
as sharp fins, sharp edges, weld spatter, or burning slag
should be removed from the surface to the extent required
by the procurement documents (project specification).
'NOTE: Additional information on surface imperfections is
available in Section A.5 of the Appendix.

6. Blast Cleaning Methods and Operation
    6.1 Clean, dry, compressed  air shall  be used  for
nozzle blasting. Moisture separators, oil separators, traps
or other equipment may be  necessary to achieve this re-
quirement.
                                                    27

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 SSP-C-SP 6
 March 1,1985
 September 1, 1989 and June 1, 1991 (Editorial Changes)

     6.2 Any of the following methods of surface prepara-
 tion may be used to achieve a Commercial Blast Cleaned
 surface:
     6.2.1  Dry  abrasive  blasting using compressed air,
 blast nozzles, and abrasive.
     6.2.2 Dry abrasive blasting using a closed cycle, recir-
 culating abrasive system with compressed air, blast noz-
 zle, and abrasive, with or without vacuum for dust and
 abrasive recovery.
     6.2.3 Dry  abrasive  blasting,  using  a closed cycle,
 recirculating abrasive system with centrifugal wheels and
 abrasive.
     6.3 Other methods  of surface preparation (such as
 wet abrasive blasting) may be used to achieve a Commer-
 cial  Blast Cleaned surface  by mutual  agreement be-
 tween the party responsible for performing the work and
 the party responsible for establishing the requirements or
 his representative.
 * NOTE: If wet abrasive blasting is used, information on the
 use of inhibitors to prevent  the formation of  rust im-
 mediately after wet blast cleaning is contained in Section
 A.9 of the Appendix.

 7.  Procedures Following Blast Cleaning and
 Immediately Prior to Painting
     7.1 Visible deposits of oil,  grease, or other con-
 taminants  shall  be removed  by any  of the  methods
 specified in SSPC-SP 1 or other methods agreed upon by
 the party  responsible for establishing the requirements
 and the party responsible for performing the work.
     7.2 Dust  and loose  residues shall be removed from
 prepared surfaces by brushing, blowing off with clean, dry
 air, vacuum cleaning or other methods agreed upon by the
 party responsible for establishing the requirements  and
 the party responsible for performing the work. Moisture
 separators, oil  separators, traps, or other equipment may
 be necessary to achieve clean, dry air.
    7.3 After blast cleaning, surface imperfections which
 remain (i.e., sharp fins, sharp edges, weld spatter, burning
 slag, scabs, slivers, etc.) shall be removed to the extent re-
 quired in the procurement documents (project specifica-
 tion). Any damage to the surface profile resulting from the
 removal of surface  imperfections shall be  corrected to
 meet the requirements of Section 2.4.
 "NOTE: Additional information on surface imperfections is
 contained in Section A.5  of the Appendix.
    7.4 Any visible rust that forms on the surface of the
 steel after blast cleaning shall be removed by reblasting
the  rusted  areas to  meet  the  requirements  of this
specification before painting.
 'NOTE: Information  on rust-back (rerusting) and surface
condensation is contained in Sections A.7 and A.8 of the
Appendix.

8.  Inspection
     8.1 Work and materials supplied under this specifica-
tion are subject to inspection by the party responsible for
establishing  the  requirements or  his   representative.
Materials and work areas shall be  accessible to the in-
spector. The procedures and times of inspection  shall be
as agreed upon by the party responsible for establishing
the requirements and the party responsible for performing
the work.
     8.2 Conditions not complying with this specification
shall be  corrected. In case of dispute  the arbitration or
settlement procedure  established  in  the procurement
documents (project specification) shall  be  followed. If no
arbitration or settlement procedure is  established, then
the procedure  established by the American  Arbitration
Association shall be used.
     8.3 The procurement  documents  (project specifica-
tion) should establish the responsibility for inspection and
for  any required affidavit certifying  compliance with the
specification.

9. Safety and Environmental Requirements
    9.1 Blast   cleaning  is   a hazardous  operation.
Therefore, all work shall be conducted in such a manner to
comply with all applicable insurance  underwriter, local,
state, and federal safety  and  environmental rules  and
requirements.
*NOTE: SSPC-PA Guide 3, "A Guide to Safety in Paint
Application," addresses safety concerns for coating work.

10.  Comments
     10.1 While every precaution is taken to insure that all
information furnished in SSPC specifications is as ac-
curate, complete, and useful as possible, the Steel Struc-
tures Painting Council cannot assume  responsibility nor
incur any obligation resulting from  the use of any mate-
rials, paints, or methods  specified therein,  or of  the
specification itself.
     10.2 Additional information and data  relative to this
specification are contained in the following brief Appen-
dix. More detailed information and data  are presented in a
separate document, SSPC-SP COM,  "Surface Preparation
Commentary."  The recommendations  contained in the
Notes, Appendix, and SSPC-SP COM are believed to repre-
sent good  practice, but are not to  be  considered as re-
quirements of the specification. The table below lists the
subjects discussed relevant to Commercial  Blast Cleaning
and appropriate section of SSPC-SP COM.
                                                     28

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Subject
Abrasive Selection	
Degree of Cleaning	
Film Thickness	
Wet Abrasive Blast Cleaning.
Maintenance Painting	
Rust Back (Rerusting)	
Surface Profile	
Visual Standards	
Weld Spatter	
Commentary Section
         5
        11.6
        10
         9
         3.2
         8
         6
         7
         4.1
A.  Appendix
     A.1  FUNCTION—Commercial Blast Cleaning (SSPC-
SP 6) provides a greater degree of cleaning than Brush-Off
Blast Cleaning (SSPC-SP 7) but less than Near-White Blast
Cleaning (SSPC-SP 10). It should be used where a high but
not  perfect degree  of  blast  cleaning  is required. The
primary functions of  blast cleaning before painting are: (a)
to remove material from the surface that can cause early
failure of the coating system, and (b) to obtain a suitable
surface roughness.
     A.2  ABRASIVE  SELECTION—Types of metallic and
non-metallic abrasives are discussed in the Surface
Preparation Commentary (SSPC-SP COM). It is important
to recognize that blasting abrasives may become embed-
ded in  or leave  residues on the surface of the steel during
preparation. While normally such embedment  or residues
are not detrimental, care should be taken (particularly if the
prepared steel is to be used in an immersion environment)
to assure that the abrasive is .free from detrimental amounts
of water soluble, solvent soluble, acid soluble, or other such
soluble materials.  Requirements for selecting and evaluat-
ing mineral and slag abrasives are given in SSPC-AB 1,
"Mineral and Slag Abrasives."
     A.3 SURFACE PROFILE —Surface profile is the
roughness of the surface which results from abrasive blast
cleaning. The profile depth (or height) is dependent upon
the size, type, and hardness of the abrasive, particle veloci-
ty and  angle of impact, hardness of the surface, amount of
recycling, and the proper maintenance of working mixtures
of grit  and/or shot.
    The allowable minimum/maximum height of profile is
usually dependent upon the thickness of the paint to be
applied. Large particle sized abrasives (particularly metal-
lic) can produce a profile which may be too deep to be ade-
quately covered by a single thin film coat. Accordingly, it is
recommended that the use of larger abrasives be avoided
in these cases.  However, larger abrasives may be needed
for thick film coatings or to facilitate removal of heavy mill
scale or rust. If control of profile (minimum/maximum) is
deemed  to  be  significant  to coatings performance, it
should  be addressed  in  the  procurement  documents
(project specification).
    Typical maximum profile heights achieved with com-
                                           SSPC-SP 6
                                          March 1, 1985
          September 1,1989 and June 1, 1991 (Editorial Changes)

mercial abrasive media are shown in Table 8 of the Surface
Preparation  Commentary (SSPC-SP COM). Methods (i.e.,
comparators,  replica  tape,  depth  micrometers)  are
available to  aid in estimating the profile of surfaces blast
cleaned with sand, steel grit, and steel shot.
    A.4  VISUAL STANDARDS—Note that the use of
visual standards in conjunction with this  specification is
required only when they  are specified in the procurement
documents (project specification) covering the work. It is
recommended, however,  that the use of visual standards
be made mandatory in the procurement documents (proj-
ect specification).
    SSPC-Vis 1-89, "Visual Standard  for Abrasive Blast
Cleaned Steel," provides color photographs for the various
grades of surface preparation as a function of the initial con-
dition of the  steel. The following table lists the photographs
for this specification that are applicable to the rust grades
listed below.
                       Rust Grade
                       Pictorial
                       Standards
                Mill Scale
                and Rust

                 BSP 6
 100%
 Rust

CSP  6
100% Rust
 With Pits

  D SP 6
                            Many other visual standards are available and are
                       described in Section 7  of the Commentary  {SSPC-SP
                       COM).
                            A.5 SURFACE IMPERFECTIONS—Surface imperfec-
                       tions can cause premature failure when the  service is
                       severe. Coatings tend to pull away from sharp edges and
                       projections,  leaving  little or  no coating  to protect the
                       underlying steel. Other features which are difficult to prop-
                       erly  cover and protect include crevices, weld porosity,
                       laminations, etc. The high cost of the methods to remedy
                       the surface imperfections requires weighing the benefits
                       of edge rounding, weld spatter removal, etc., versus a
                       potential coating failure.
                            Poorly adhering contaminants, such  as weld slag
                       residues, loose  weld spatter, and some minor surface
                       laminations, may be removed during the blast cleaning
                       operation. Other surface defects (steel laminations, weld
                       porosities, or deep corrosion pits) may not be evident until
                       the surface  preparation  has been completed. Therefore,
                       proper planning for such surface repair work is essential
                       since the timing of the repairs may occur before, during, or
                       after the blast  cleaning operation. Section 4 of the  Com-
                       mentary (SSPC-SP  COM) contains additional information
                       on surface imperfections.
                            A.6 CHEMICAL CONTAMINATION—Steel contam-
                       inated with  soluble  salts (i.e., chlorides and sulfates)
                       develops rust-back  rapidly at intermediate  and  high
                       humidities. These soluble salts can be present on the steel
                       surface prior to blast cleaning as a result of atmospheric
                                                      29

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SSPQ-SP 6
March 1, 1985
September 1,1989 and June 1,1991 (Editorial Changes)
 contamination.  In  addition,  contaminants  can  be de-
 posited  on  the steel  surface  during  blast  cleaning
 whenever the abrasive is contaminated.  Therefore, rust-
 back can be minimized by removing these salts from the
 steel  surface,  preferably before  blast  cleaning,  and
 eliminating sources of recontamination during and after
 blast cleaning. Identification of the  contaminants along
 with their concentrations may be obtained from laboratory
 and field tests. A number of tests for soluble salts are now
 under study by the SSPC, ASTM, Maritime Administration,
 and ISO.

     A.7 RUST-BACK—Rust-back (rerusting) occurs when
freshly cleaned steel is exposed to conditions of high
humidrty,  moisture, contamination,  or a corrosive at-
mosphere. The time interval between blast cleaning and
rust-back  will  vary greatly from one environment  to
another. Under mild ambient conditions it is best to blast
clean and coat a surface the same day.  Severe conditions
may require coating more quickly while for exposure under
controlled conditions the coating time  may be extended.
Under no circumstances should the steel  be permitted to
rust-back  before painting regardless of the time elapsed
(see Appendix A.6).

     A.8 DEW POINT—Moisture condenses on any sur-
face that is colder than the dew point of  the surrounding
air. It is, therefore, recommended that the temperature of
steel surface be at  least 5 degrees F (3 degrees C) above
the dew point during dry blast cleaning operations. It is ad-
visable to visually inspect for moisture and periodically
check the surface temperature  and dew point during blast
cleaning operations. It is important that the application of
paint over a damp surface be avoided.
     A,9 WET ABRASIVE BLAST CLEANING—Steel that
is wet abrasive blast cleaned may rust rapidly. Clean water
should be used for rinsing (studies have shown that water
of at least 15,000 ohm-cm resistivity is preferred). It may be
necessary that inhibitors be added to the water or applied
to the surface  immediately after blast cleaning  to tem-
porarily prevent rust formation. The coating should then be
applied before any rusting is visible. One inhibitive treat-
ment for blast cleaned surfaces is water containing 0.32%
sodium nitrite and 1.28% by weight  secondary ammonium
phosphate (dibasic).
CAUTION: Some inhibitive treatments may interfere with
the performance of certain coating  systems.
     A.10  FILM THICKNESS—It is essential that ample
coating be applied after blast cleaning to adequately cover
the  peaks of the surface profile. The dry paint film
thickness above the peaks of the profile should  equal the
thickness known to be needed for the desired protection. If
the dry film thickness over the peaks is inadequate, prema-
ture rust-through or failure will occur. To assure that coating
thicknesses are properly measured, refer to SSPC-PA  2,
"Measurement  of  Dry  Paint  Thickness with  Magnetic
Gages."
     A.11 MAINTENANCE AND REPAIR  PAINTING —
When this specification is used in maintenance painting,
specific instructions should be given on the extent of sur-
face to  be blast cleaned or spot  blast cleaned  to this
degree of cleanliness. SSPC-PA Guide 4, "Guide to Main-
tenance Repainting  with  Oil  Base  or Alkyd  Painting
Systems," provides a description of accepted practices for
retaining old  sound  paint,  removing  unsound  paint,
feathering, and spot cleaning.
                                                      30

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                                                                                                SSPC-SP11
                                                                                            November 1, 1987
                                                                 September 1,1989 and June 1, 1991 (Editorial Changes)
                               Steel Structures  Painting Council
           SURFACE  PREPARATION SPECIFICATION  NO. 11
                              Power Tool Cleaning  to Bare Metal
1.  Scope
    1.1 This specification covers the requirements for pow-
er tool cleaning to produce a bare metal surface and to re-
tain or produce a surface profile.
    1.2 This specification is suitable where a roughened,
clean, bare metal  surface is required, but where abrasive
blasting is not  feasible or permissible.
    1.3 This specification differs from SSPC-SP 3, Power
Tool Cleaning,  in that SSPC-SP 3 requires only the removal
of loosely adherent materials and does not require produc-
ing  or retaining a surface profile.

2. Definition
    2.1 Metallic surfaces which are prepared according to
this specification, when viewed without magnification, shall
be free of all visible oil, grease, dirt, dust, mill scale, rust,
paint, oxide, corrosion products, and other foreign matter.
Slight residues of rust and paint may be left in the lower por-
tion of pits if the original surface is pitted.
    2.2 When  painting is specified, the surface shall be
roughened to a degree suitable for the specified paint sys-
tem. The surface  profile shall not be less than  1 mil  (25
microns). 'NOTE: Additional information on profile is con-
tained in Sections A.5 and A.6 of the Appendix.
  2.3 Photographs or other visual standards may be used
to supplement the written definition. *NOTE: Additional in-
formation on visual standards is available in Section A.7 of
the  Appendix.

3. Power Surface Preparation Tools and Media
    3.1 Surface Cleaning Power Tools (that may or may not
destroy the surface profile): any tool capable of appropriate-
ly driving the media of Section 3.3 is acceptable.
    3.2 Impact and Other Profile Producing Power Tools:
any tool on which the media of Section 3.4 can be properly
mounted and used to produce the required uniform profile
is acceptable. *NOTE: Information on suitable tools is found
in Sections A.S.a and A.S.b of the Appendix.
    3.3 Surface Cleaning Media:
    3.3.1 Non-woven abrasive wheels and discs — con-
structed of a non-woven synthetic fiber web material of con-
tinuous undulated filaments impregnated with an abrasive
grit. *NOTE: Information on suitable discs and wheels is
found in Section A.S.c of the Appendix.
    3.3.2 Coated abrasive discs (sanding pads), coated
abrasive flap wheels, coated abrasive bands or other coat-
ed abrasive  devices capable  of running on power tools.
'NOTE: Information on suitable wheels is found in Section
A.S.d  of the Appendix.
    3.3.3 Other materials that produce the requirements of
Section 2.1.
    3.4 Surface Profile Producing Media:
    3.4.1. Rotary impact flap assembly consisting of a flexi-
ble loop construction with carbide spheres bonded to  the
peening surfaces of each of the metal supports fastened to
the loop.* NOTE: Information on suitable flap assemblies is
found in Section A.S.e of the Appendix.
    3.4.2 Needle guns consisting of a bundle of wire "nee-
dles"  which can impact a surface, producing a peened ef-
fect.  'NOTE: Information on suitable needles is found in
Section A.S.f of the Appendix.

    3.4.3 Other materials which, when mounted on power
hand tools, can produce the profile required in Section  2.2.

4. Reference Standards
    4.1 The standards referenced in this specification are
listed  in Section 4.4. and form a part of this specification.
    4.2 The latest issue, revision, or amendment of the refer-
enced standards in effect on the date of invitation to bid shall
govern unless otherwise specified.
    4.3 If there is a conflict between the requirements of any
of the cited  reference standards and this specification, the
requirements of this specification shall prevail.
    4.4  STEEL STRUCTURES PAINTING  COUNCIL
(SSPC) SPECIFICATIONS:
    SSPC-SP 1 Solvent,Cleaning
    SSPC-SP 3 Power Tool Cleaning
                                                    31

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 : SSPC-SP -U
 , November 1, 1987
 September 1, 1989 and June 1, 1991 (Editorial Changes)

 !5.  Procedures  Prior to  Power Tool Surface
 Preparation
 :    5.1 Prior to power tool surface preparation, remove visi-
 • ble deposits of oil or grease by any of the methods specified
 in SSPC-SP 1, "Solvent Cleaning," or other agreed-upon
 ;methods.
     5.2 Prior to power tool surface preparation, remove sur-
 face imperfections such as sharp fins, sharp edges, weld
 spatter, or burning slag to the extent required by the procure-
 ment documents (project specification). *NOTE: Additional
 information on surface imperfections is available in Appen-
 dix A.9.

 ;6.  Power Tool Surface Preparation Methods
 and Operations
 ,    6.1 Depending on profile conditions, use either or both
 of the following methods to remove tightly adhering materi-
 als and to retain or produce the required surface profile with
 power tools:
     6.1.1 Profile Condition A,  Acceptable Profile Exists:
 Achieve the cleanliness required in Section 2.1 by using pow-
 er tools described in Section 3.1.
 |    6.1.2 Profile Condition B. Unacceptable Profile Exists:
 Achieve the cleanliness required in Section 2.1 and the pro-
 file required in Section 2.2 by using  power tools described
 in Section 3. *NOTE: Information on the selection of tools
 and cleaning media is found in Section A.2 of the Appendix.

 7.  Procedures Following Power Tool Surface
 Preparation
     7.1 After power tool surface preparation and prior to the
 application of coatings, reclean the surface if it does not con-
 form to  this  specification.
 ,    7.2 Remove visible deposits of oil, grease, or other con-
 taminants by any of the methods specified in SSPC-SP 1 or
 other methods agreed upon by the party responsible for es-
 talishing the  requirements and the party responsible for per-
 forming the work. 'NOTE: Information on oil contamination
 is  found in Section A.4.d of the Appendix.
     7.3 Remove dirt, dust, or similar contaminants from the
 surface. Acceptable methods include brushing, blow off with
oil free, clean, dry air; vacuum cleaning; or wiping with a
clean, dry cloth.
    7.4 Power tool prepared surfaces must be coated prior
to  the reformation of rust or visible contamination.
 8. Inspection
     8.1 Surfaces prepared under this specification shall be
 subject to timely inspection by the purchaser or his author-
 ized representative. The contractor shall correct such work
 as is found defective under this specification. In case of dis-
 pute, the  arbitration or settlement procedure as established
 in the procurement documents (project specification), shall
 be followed. If no arbitration procedure is established, the
 procedure specified by the American Arbitration Association
 shall be used.

     8.2 The procurement documents (project specification)
 covering work or purchase shall establish the responsibility
 for testing and for any required affidavit certifying full com-
 pliance with the specification.

 9. Safety
    9.1 All safety requirements stated in the procurement
 document as well as this specification and its component
 parts apply in addition to any applicable federal, state, and
 local rules and requirements. They also shall be in  accord
 with instructions and requirements of insurance underwriters.

 10. Comments
    10.1 While every precaution is taken to insure that all
 information Burnished in SSPC specifications is as accurate,
 complete,  and useful as possible, the Steel Structures Paint-
 ing Council cannot assume responsibility nor incur any obli-
 gation resulting from the use of any  materials, paints, or
 methods specified therein, or of the specification itself.
    10.2 Additional information  and  data relative  to this
 specification are containec in the following Appendix. Addi-
 tional detaiied information  and data  are  presented  in a
 separate document, SSPC-SP COM, "Surface Preparation
 Commentary." The recommendations contained  in  the
 Notes, Appendix, and SSPC-SP COM  are believed to
 represent good practice, but are not to  be considered as re-
 quirements of the specification.
    The tabie below lists the appropriate section of SSPC-
 SP COM.
Subject
Degree of Cleaning . .
Film Thickness	
Maintenance Painting
Rust-Back (Rerusting)
Surface Profile	
Visual Standards ....
Weld Spatter	
 Commentary Section
         11
         10
          3
          8
          6
          7
:          4.1
                                                           32

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A.  Appendix
    A.1 FUNCTION —Power tool surface preparation to re-
move tightly adherent material produces a surface which is
visibly free from all rust, mill scale, and old coatings and
which has a surface profile. It produces a greater degree of
cleaning than SSPC-SP 3, "Power Tool Cleaning," (which
does not remove tightly adherent material) and may be con-
sidered  for coatings requiring a bare metal substrate.
    The surfaces prepared according to this specification are
not to be compared to surfaces cleaned by abrasive blast-
ing. Although this method produces surfaces that "look" like
"near-white" or "commercial blast," they are not necessar-
ily equivalent to those surfaces produced by abrasive blast
cleaning as called for in SSPC-SP 10 or SP 6.
     A.2  SELECTION OF TOOLS AND CLEANING
MEDIA—Selection of power tools and cleaning media shall
be based on (1) the condition of the surface prior to surface
preparation, (2) the extent of cleaning that is required to re-
move rust, scale and other matter from the surface and (3)
the type of surface profile required.
     A.2.1 Selection  of Media—If an  acceptable surface
profile  existed  prior  to preparing the surface, cleaning
media,  such as found in Section 3.3, shall be selected that
will remove surface contaminants without severely reducing
or removing the profile, if possible. If the surface profile is re-
moved  or severely reduced when preparing the surface, or
if there was no profile prior to surface preparation, surface
profiling media, such as found in Section 3.4, shall be select-
ed that  will produce an acceptable surface profile as required
 by this  specification. When power tool cleaning rusted sur-
 faces it is important to avoid embedding or peening rust into
 the substrate. This may require removal of rust prior to use
 of surface profiling media. These factors may require em-
 ploying more than one type of medium in order to obtain the
 desired end result. 'NOTE: Power wire brushes when used
 alone will not produce the required surface profile and may
 remove or degrade an existing profile to an unacceptable
 level.
     A.2.2 Selection of Tools—Power tools shall be se-
 lected  on the basis of the size and speed  rating of the
 media. These  requirements may differ from one type of
 media  to another and  shall be taken into consideration in
 more than one type of medium will be used in  the surface
 preparation process. Power tools shall be selected that will
 produce enough  power to perform the cleaning operation
 efficiently. Operator fatigue shall be considered in the selec-
 tion of power tools.
     Further information on the selection of power tools and
  media is contained in Chapter 2.6, "Hand  and  Power Tool
  Cleaning," of Steel Structures Painting Manual, Volume 1,
  "Good Painting Practice," 2nd Edition, 1982.
      A.3 SUITABLE TOOLS AND MEDIA—The text of this
  specification makes reference to the following footnotes. In-
  clusion of these items in this appendix is intended solely to
  guide  the user to typical types of equipment and media which
  are available to meet the specification. The items mentioned
                                           SSPOSP I!
                                       November 1, 1987
           September 1, 1989 and June 1,1991 (Editorial Changes)

 are not exhaustive of the tools or products available, nor does
 their mention constitute an endorsement by SSPC.
     a. The "Mini-Flushplate"® from Desco Manufacturing
       Company, Inc., Long Beach, California, has been
       found suitable as a tool system which meets the re-
       quirements of this  section.
     b. The Aro Corporation, Bryan, Ohio, and VON ARX Air
       Tools Company, Englewood, New Jersey, are sup-
       pliers of needle gun equipment.
     c. 3M Scotch-Brite Clean 'n Strip discs and wheels are
       able to satisfy the  requirements.
     d. Grind-O-Flex  wheels  from  Merit Corporation,
       Compton, California and Nu-Matic air inflated wheels,
       from  Nu-Matic Grinders,  Euclid,  Ohio, have been
       found suitable.
     e. 3M Heavy-Duty Roto-Peen flap assembly has been
       found suitable.
     f. Needles  having a diameter of 2 mm have been
       found to produce a surface profile suitable for many
       painting systems.
     A.4 OPERATION OF TOOLS—The tools  shall be
 operated in accordance with the manufacturers' instruc-
 tions. In particular, note the following:
         a. Observe the  recommended operating speed
 (ROS). The  maximum operating speed (MOS) does  not
 necessarily give  the most efficient cleaning.
         b. The "rpm" (rotational speed) rating of some pow-
 er tools and the cleaning media may not  be compatible and
 could result in physical injury to the operator.
         c. Exercise caution when power tools are used at
 critical structures (e.g., pressure vessel boundaries) so that
 excessive base metal is not removed.
         d. When air driven tools are used, the exhaust could
 contain oil and/or moisture that could easily contaminate the
 recently prepared surface.
         e. The media used on power tools have a finite life.
 When they do not produce the specified profile they shall be
 replaced.
         Additional information on the operation of tools can
 be found in Chapter 2.6 of Volume 1, "Good Painting Prac-
 tice" of Steel Structures Painting Manual, 2nd Edition, 1982.
      A.5 PROFILE—The type of power tools to be  used
 depends upon whether or not an acceptable profile exists
 on the surface to be cleaned.
          Some limitations of the various types of media to
  produce a specific profile or to preserve an existing profile
  are as follows:
          Media of Section 3.3 produce a profile of approxi-
  mately one-half mil (10-15 microns), whereas the media of
  Section 3.4 may produce a profile of 1  mil (25 microns) or
  more. The profile depends on the abrasive embedded in the
  rotary flaps or the diameter of the needles.
          Impact tools may produce sharp edges or cut into
  the base metal  if not used properly.
33         it is important to determine whether the profile re-

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  SSPC-SP 11
  November 1,1987
  September t, 198S ar\d June -(., 199V (Editorial Changes)

  quirements for the specified coating system can be met by
  this power tool cleaning method of surface preparation.
      A.6 MEASUREMENT OF SURFACE PROFILE —
  Surface profile comparators and other visual or tactile
  gages used for abrasive blast cleaning are not suitable for
  measuring profile  produced by power tools because of the
  differences in appearance. One acceptable procedure is
  use of coarse or extra coarse replica tape,  as described in
'  Method  C of ASTM D-4417, "Field  Measurement of Surface
  Profile of Blast Gleaned Steel." Replica tapes are valid for
  profiles  in the ranges of 0.8 to 1.5 mils (coarse) to 1.5-4.5
 mils  (extra-coarse). (Note: Because of the  limitations  in
 compressibility of the mylar film, however, even very
 smooth  surfaces will give  readings of 0.5  mils or greater
 using the replica tape.)
      A.7 VISUAL  STANDARDS —SSPC-Vis 1-89, "Visual
 Standard for  Abrasive  Blast  Cleaned  Steel,"  ISO
  8501-1:1988,  and the National Association of Corrosion En-
  gineers  "Blast Cleaning Visual Standards," TM-01-70 and
 TM-01-75, are not suitable for assessing surfaces power
 tool cleaned to bare metal.
     The SSPC is currently preparing photographs which il-
 lustrate typical end conditions achieved using the power tools
 described in  this specification over the initial rust grades
 depicted in SSPC-Vis 1-89.
     A.8 INACCESSIBLE AREAS —Because of the shape
 and configuration of the power tools  themselves, some areas
 of a structure may be inaccessible for cleaning. These areas
 include  surfaces close to bolt heads, inside corners, and
 areas with limited clearance. Areas which are inaccessible
 by this method of surface preparation shall be cleaned us-
 ing an alternate  method of surface preparation which may
 result in  a different degree of surface cleanliness and sur-
 face profile. The alternate method shall  be mutually agreed
 upon before commencing work.
     A.9 SURFACE IMPERFECTIONS—Surface imperfec-
 tions  can cause premature  failure when the  environment is
 severe. Coatings tend to pull away from sharp edges and
 projections, leaving little or no coating to protect the under-
 lying steel. Other features which are difficult to properly cover
 and protect include crevices, weld porosity, laminations, etc.
The high cost  of methods to remedy the surface imperfec-
tions requires  weighing the benefits of edge rounding, weld
spatter removal, etc., versus a potential coating failure.
    Poorly adherent contaminants,  such  as weld slag
residues, loose weld spatter, and some minor surface lami-
nations,  must  be removed during the power tool cleaning
operation. Other surface defects (steel laminations, weld
porosities, or deep corrosion pits) may not be evident until
the surface preparation has been  completed. Therefore,
proper planning for such repair work is essential, since the
timing of the repairs may occur before, during, or after the
cleaning  operation. Section 4 of the "Surface Preparation
Commentary"  (SSPC-SP COM) contains additional informa-
tion on surface imperfections.
      A.10 CHEMICAL CONTAMINATION—Steel contami-
 nated with soluble salts (i.e., chlorides and sulfates) devel-
 ops  rust-back rapidly at intermediate and high humidities.
 These soluble salts can be present on the steel surface
 prior to cleaning as a result of atmospheric contamination.
 In addition, contaminants can be deposited on the steel sur-
 face during cleaning whenever the media is contaminated.
 Therefore, rust-back can be minimized by removing these
 salts from the steel surface, preferably before power tool
 cleaning, and eliminating sources of recontamination during
 and after power tool cleaning. Identification of the contami-
 nants along with their concentrations may be obtained from
 laboratory or field tests.
      A.11 RUST BACK—Rust-back (rerusting)  occurs
 when freshly cleaned steel is exposed to conditions of high
 humidity, moisture,  contamination, or a corrosive atmo-
 sphere. The time interval between power tool cleaning and
 rust-back will vary greatly from one environment to another.
 Under mild ambient conditions, it is best to clean and coat a
 surface the same day. Severe conditions may require coat-
 ing more quickly, while for exposure under controlled condi-
 tions the coating time may be extended.  Under no
 circumstances shall the steel be permitted to rust-back
 before painting regardless of time elapsed (see Appendix
 A.10).
     A.12 DEW POINT—Moisture condenses on any sur-
 face that is colder than the dew point of the surrounding air.
 It is,  therefore, recommended that the temperature of the
 steel surface be at least 5 degrees F (3 degrees C) above
 the dew point during power tool cleaning operations. It is ad-
 visable to visually inspect for moisture and periodically check
 the surface temperature and dew point during cleaning oper-
 ations.  It is important that the application of a coating over
 a damp surface  be avoided.
     A.13 FILM  THICKNESS—It is essential that ample
 coating be applied after power tool cleaning to adequately
 cover the peaks of the surface profile. The dry film thickness
 above the peaks of the profile shall equal the thickness
 known to be needed for the desired protection. If the dry film
 thickness over the peaks is inadequate, premature rust-
 through or failure will occur. To assure that coating thickness-
 es are properly measured, refer to SSPC-PA 2, "Measure-
 ment  of Dry Paint Thickness with  Magnetic Gages."
    A.14 MAINTENANCE  AND REPAIR PAINTING— »
 When this specification is used in maintenance painting,
 specific instructions shall be given on the extent of surface
 to be power tool cleaned or spot cleaned. SSPC-PA  Guide
4,  "Guide to Maintenance Repainting with Oil Base or Alkyd
Painting Systems," provides a description of accepted prac-
tices for retaining old sound paint, removing unsound paint,
feathering, and spot cleaning.
                                                       34

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          APPENDIX B

CONDENSED OPERATING PROCEDURES

     PENTEK CORNER-CUTTER®
        PENTEK VAC-PAC®
              35

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             CONDENSED OPERATING PROCEDURES FOR
                        PENTEK CORNER-CUTTER®
Introduction
The  CORNER-CUTTER® is designed to remove lead-based paints, radioactivity and other
hazardous contaminants from both steel and  concrete surfaces in an environmentally-safe
manner.  Pentek developed the CORNER-CUTTER® to scarify walls, joints, ceilings, girders,
equipment supports and other hard to get places in a single step process. Surfaces are left clean
and ready to receive new protective coatings, toppings and overlays.

The CORNER-CUTTER® operates by pneumatically driving specially hardened needles into the
surface being cleaned.  The process takes place within an evacuated enclosure preventing the
escape of dust, debris and airborne contamination. Standard shrouds are provided with each unit
to allow the cutter to conform to inside corners, outside corners, door jambs and flat surfaces.
Special shrouds can be custom engineered to conform to particularly odd geometric shapes.

The  CORNER-CUTTER®  is one  of several types  of pneumatically  operated  scarifiers
manufactured by Pentek that operates in conjunction with an ultra-high performance HEPA-
filtered vacuum system.  The CORNER-CUTTER® incorporates unique vacuum flow design
features which provide high efficiency performance in contaminated or clean room environments
which require stringent control of loose material. Users will find that the CORNER-CUTTER®
minimizes  the  need  for the respiratory protections of operating  personnel  from airborne
radiological and toxic particulate hazards;  the need to erect tents or temporary enclosures to
protect nearby operating equipment from flying dust and debris is also reduced.

The  CORNER-CUTTER®'s light weight, low reaction forces and infinitely adjustable vacuum
enclosure minimizes operator fatigue and provide for comfortable operation in*any position. The
ergonomic design of the operator's handle provides complete operator control, and is equipped
with a quick-release-to-off safety feature.


General Safety Precautions

1.     Keep hands and feet away from the needles when connected to a compressed air supply.

2.     The CORNER-CUTTER® should be operated utilizing an air supply capable of delivering
       90 psig measured at the tool, with consumption of approximately 5 scfm.

3.     The CORNER-CUTTER® operator and other personnel near the work area must wear
       safety goggles.
                                         36

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4.    Ear protection  should  be required for all personnel in the  vicinity of  CORNER-
      CUTTER® operation.

5.    The proper shroud should be  installed at the tool end  to ensure proper control of
      contamination. The shroud should be inspected prior to using the equipment; its integrity
      is important in maintaining the proper contamination control.


Support Requirements

The following are to support the operation of the CORNER-CUTTER®.

1.    Clean, dry air supply rated at 90 psig at approximately 5 scfm, supplied through a
      pressure-rated air hose.  The air hose should be at least 1/2 inch in diameter or larger.

2.    A HEPA-filtered vacuum system.

3.    Standard 1-1/2 inch RX polyethylene-EVA vacuum hose or equivalent.

4.    Correct shrouds to provide contamination control to the surfaces encountered in the work
      area.


Preparing the CORNER-CUTTER® for Operation

1. ,   Check the condition of the CORNER-CUTTER® prior to operation on a new job. The
      CORNER-CUTTER® maintenance should be current.  Bolts and fittings should be tight.

2.    Before operation and after each three hours of continuous operation, it is recommended
      the CORNER-CUTTER® be lubricated with Marvel Mystery Oil or equivalent. Five to
      ten drops of Marvel Mystery OH should be placed directly into the CORNER-CUTTER®
      in the pneumatic supply port at the base of the handle.

3.    Another approach is to install an in-line oiler to the air supply line to ensure continuous
      lubrication during tool operation.

4.    Connect a 1-1/2" vacuum hose from the  CORNER-CUTTER® to a filtered vacuum
      system; HEPA filters are required for contamination control; turn the vacuum system on.

5.    Connect the pneumatic supply hose.  The CORNER-CUTTER® requires a pneumatic
      supply of 90 psi and a flow of about 5 scfm; in no event should the air supply pressure
      exceed  120 psig.
                                         37

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Operation of the CORNER-CUTTER®

1.      Adjust the orientation of vacuum hose by rotating the vacuum front piece barrel such that
       it does not interfere with the work or the comfortable operation of the unit.

2.      Place the shroud firmly against surface and squeeze the throttle valve to begin operation.

3.      Move the CORNER-CUTTER® along the surface or edge to be cleaned at a sufficiently
       slow and steady rate to allow for complete scarification.  Be certain to maintain the
       shroud in contact with the surface to avoid loss of control of contaminated material.

4.      When scarifying concrete,  it is possible to control cutting depth.  To make a rough-
       adjustment, loosen Locking Collar and ran unit on area to be cleaned.  When the desired
       depth of cut has been attained, hold vacuum slide firmly in place and tighten Locking
       Collar; finer adjustments may be required after first use.

5.      Monitor the hoses and tend them as required; stop the CORNER-CUTTER®, if necessary
       to permit adjustment of the hoses.

6.      When operating the CORNER-CUTTER® on a ceiling, it is recommended to set the
       locking collar as instructed in Step 4.  This will minimize operator fatigue and promote
       contamination control by maintaining constant clearance between the shrouds and the
       ceiling surface.
                                          38

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             CONDENSED OPERATING PROCEDURES FOR
                      PENTEK VAC-PAC® MODEL 9D
Introduction
Pentek developed the VAC-PAC® ultra-high performance vacuum system to support our line of
concrete decontamination equipment: MOOSE®, SQUIRREL IE®, AND CORNER-CUTTER®.
This manual describes the VAC-PAC®  as an independent system for  use to support  other
decontamination operations, or any operation where a  high-performance vacuum  system is
required.

The VAC-PAC® offers two stage positive filtration sufficient to support safe and efficient
vacuuming of radioactive and toxic materials.  First stage roughing filter efficiency is 95% at
1 micron, with second stage HEPA efficiency of 99.97% at 0.3 microns.  The VAC-PAC®
features automatic  self-cleaning  of the first stage filters using reverse-flow pulses of high-
pressure  air.   This exclusive  feature virtually eliminates filter clogging, and allows  for
continuous vacuuming without interruptions to change filters.

The portable  VAC-PAC® system  utilizes high  recovery pneumatic  eductors which  use
compressed air to produce vacuum performance rivaling that produced by much larger truck-
mounted  "super vacuums".

Also featured in the VAC-PAC® design is Pentek's exclusive controlled seal drum fill system,
which allows the operator to fill, seal, remove, and replace the waste drum under  controlled
vacuum conditions.  This  assures positive control of  waste and dust, and  minimizes  the
possibility of releasing airborne contamination during drum changing operations.

The entire vacuum system is mounted on the VAC-PAC®'s powered lift mechanism.   The
wheeled lift permits easy transport and positioning of the VAC-PAC®, and for the waste drum
as well.  The VAC-PAC® can accommodate either 21-, 52-, or 55-gaUon waste drums.
General Safety Precautions

1.     When charging the battery, use a 110 VAC, 60 Hertz electrical supply which is properly
       grounded and protected with a Ground Fault Circuit Interrupt.

2.     Clean, dry compressed  air should be used to drive the VAC-PAC®.  Air supplies
       contaminated with excessive amounts of water and oil should be processed an using an
       in-line separator located  upstream of the VAC-PAC®.

3.     Use only lockable air supply fittings when connected an air hose to the VAC-PAC®; e.g.,
       Chicago fittings, Hansen couplings, National couplings.

                                         39

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4.     Disconnect the electrical power and the air supply before opening any electrical
       enclosures, or performing maintenance or any other service on the VAC-PAC®.

5.     Disconnect the electrical power and air supply before cutting or disconnecting any tubing
       on the unit.

6.     Ear protection should be required for  all personnel in  the vicinity of VAC-PAC®
       operations.

7.     Keep hands clear of the vacuum head and lift mechanisms when raising or lowering the
       vacuum head.

8.     Drum changeout procedures must be carefully followed to prevent  the  release of
       hazardous materials.
Support Requirements

The following are required to support operation of the VAC-PAC®:

1.     Standard 110 VAC electrical outlet (for battery charging).

2.     Air supply rated at a nominal 120 psi.  Air consumption for the VAC-PAC® 6 is 70
       scfm, and for the VAC-PAC® 9 it is 105 scfm; both are 85 psi measured at the VAC-
       PAC® pressure gauge.

3.     Replaceable vacuum nozzles and strap wrench for installation/removal.

4.     Standard 1-1/2 inch RX polyethylene vacuum hose or equivalent.  Note that while the
       VAC-PAC® is supplied with standard 1-1/2 inch nozzle/hose connection, 2 inch, 2-1/2
       inch, and 3 inch hose connections are available.

5.     21-, 52-, or 55-gallon drums (with lids) to be used as waste containers.

6.     Disposable cardboard disks used to provide temporary containment of the vacuum head
       during drum changeout.

7.     Aluminum positioning disc  (reusable) used to position the disposable cardboard disc
       during drum changeout.

8.     "Shower Cap" covers to cover the open  mouth of the vacuum head during storage and
       transport of the  VAC-PAC®.

9.     Selection of plastic caps to cover vacuum nozzles, ports, and hose ends when not is use.

                                          40

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10.    Pentek recommends the use of Pentek's line of hand tools whenever aggressive, dust-
       controlled surface preparation, material removal, and decontamination are desired.  'The
       SQUIRREL III®  scabblers remove concrete  from  horizontal  surface areas.   The
       CORNER-CUTTER® removes paint and other coatings from corners,  floors, walls,
       beams and from spaces inaccessible to larger equipment.
Preoperational Checks

Physical setup:

1.     Ensure that the items described in "Support Requirements" are available.

2.     Move the VAC-PAC® to a central location in the work area.

3.     Apply the brakes by pulling up on the brake lever until it is locked in the horizontal
       position.

4.     If a  drum  is not in place, follow the instructions  in  the "New Drum Installation
       Procedure."

5.     Confirm that a drum is in place and resting against pin locators on the legs of the VAC-
       PAC®, or on a pallet.

6.     Confirm that the vacuum head is fully lowered and resting squarely on the lip of the
       drum by slowly moving the lift control level to the "Down" position.  If there is no
       motion, the vacuum head is resting  on the drum.

7.     Insert vacuum nozzles into the vacuum ports which are to  be used during the vacuuming
       operation using the strap wrench supplied with the unit (Figure 2). Plug unused nozzles
       or ports with appropriate plastic plugs, and tape the plugs securely  in place.

       NOTE:  It may be  necessary to  remove  the  vacuum  nozzles to provide  sufficient
       clearance for the VAC-PAC® to pass through some doorways.  Insertion and removal of
       the vacuum nozzles requires the use of the strap wrench provided.

8.     Install vacuum hose(s) in the nozzles to be used by threading them into place using a
       counter-clockwise twisting motion.  Tape the hoses securely in place.
                                          41

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Power and Controls

1.     When the charging battery, plug the VAC-PAC® power cord into a 110 VAC, 60 Hertz
       source which is properly grounded.  It is also recommended that the VAC-PAC® power
       supply be protected by a Ground Fault Circuit Interrupt (GFCI).

2.     Confirm that the "Vacuum-Exchange" mode selector switch on the main control panel
       is positioned to "Exchange".

       NOTE:  The mode selector switch should be positioned to "Vacuum" ONLY during
       normal VAC-PAC® vacuuming  operation and ONLY when a drum is in position and
       sealed against the foam drum seal.  When the switch is in this position, the green "OK
       to Vacuum" indicator will light and the lift will be disabled for added safety.

3.     Test the drum level detector by placing a  solid object (such as a drum lid)  directly in
       front of the blue sensor.  Hold the object in place for approximately 30 seconds, or until
       the "Full Drum" alarm sounds.

4.     Confirm that the drum level detector retracts properly. Connect the VAC-PAC® to  an
       air supply, and open the air supply valve. Move the "Vacuum-Exchange" switch to the
       "Vacuum" mode, then back to the "Exchange" mode.  Look to confirm that the dram
       level detector has withdrawn into the filter housing.

       NOTE:  When conducting this test, DO NOT allow the VAC-PAC® to remain in the
       "Vacuum" mode for more than 15 seconds. As discussed above, the VAC-PAC® should
       not be in the "Vacuum" mode without a drum in place.  This test is the only exception
       to that rale.

5.     The green and red indicator lamps contain push-to-test lamps.  The green indicator may
       only  be tested  when the mode  selector switch is in the "Vacuum" position; the red
       indicator may be tested with the mode selector switch in any position.

Air Supply

1.     Confirm that the air supply  valve on the VAC-PAC® is turned to the "OFF" position
       (i.e., handle in horizontal).

2.     Connect an air supply hose  to the air supply fitting on the VAC-PAC®.

3.     Connect the opposite end of the air hose to the fitting at the main air supply.

4.     Open the valve at the main air supply valve. This will start the VAC-PAC® at low flow,
       even though the air supply valve at the VAC-PAC® inlet manifold is closed.

5.     The VAC-PAC® is now ready for operation.
                                         42

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Operation

1.     Open the air supply valve at the VAC-PAC®; this initiates full vacuum flow.  Check the
       air supply pressure gauge on the VAC-PAC®; it should be 85 psig.  Adjust the optional
       pressure regulator accordingly; set 9/16 inch locking nut. The VAC-PAC® is now ready
       to supply vacuum to the hose nozzle.

2.     Move the mode selector switch to the "Vacuum" position.

3.     When the drum is empty, the green "OK to Vacuum" indicator will light.  This indicates
       that it is all right to proceed with vacuuming operations.

4.     When the drum is full, the green "OK to  Vacuum" indicator will go out, and the red
       "Full Drum" indicator will light.  This will be accompanies by a loud beeping signal.
       When this occurs, discontinue vacuuming immediately.

5.     Turn the mode selector switch to the "Exchange" position.   This will silence the full
       drum signal, and prepare the VAC-PAC® for drum changeout.  The drum* level detector
       will automatically withdraw into the vacuum head, causing the red "Full Drum" indicator
       to go out as it loses contact with the material in the drum.

6.     Begin drum changing  operations  in accordance with the  "Full Drum"  changeout
       procedure.
                                          43

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        APPENDIX C




DEMONSTRATION LOG SHEETS
           44

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                                             FORMA
                      CONVENTIONAL ABRASIVE BLASTING LOG SHEET
Location:	

I.       Mobilization
                                                                            Date:
n.
        Equipment Arrival Time:
        Equipment Set-Up Completed:
               Total Time:

        Equipment Used:
No. Personnel Required:

Operations
        Material Use:
         Total Abrasive at Start: 	
         Total Abrasive at Finish:
               Total Abrasive (spent):
        Start Time:
                       Finish Time:
                                                     Hours/Total:
        No. Personnel Required:
                                             Duties
                   at.
                  .at.
                   at.
                   at
                     hours
                     hours
                     hours
                     hours
        Production:

        Paint Removal Area:

        % Vertical Face	
        No. Inside Corners
        No. Outside Corners
        No. Bolt Heads
        No. Nutted Ends

        Air Monitoring
                           ft. X
                       % Horizontal Face (top).
                              Total Length	
                _ft. = 	sq. ft.

                          _    % Horizontal Face (bottom)
                        ft.
                              Total Length	ft
          No.
         1.

         2.

         3.

         4.

         5.
           Type
Location
Time
On

Time
Off

Flow
Rate
Total Air
Volume

                                                45

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                                           FORMA
                      CONVENTIONAL ABRASIVE BLASTING LOG SHEET
                                          (Continued)
m.
Clean-Up

Method:
       No. Personnel Required:,
       Equipment Used:
       Start Time:
       Waste Collected:
                      Finish Time:
Hours/Total:
Type



Amount



Lbs.
n
n
D
Ft.3
n
n
n
Gals.



-'- How Stored



IV.    Demobilization
       Start Time:
                      Finish Time:
       No. Personnel Required:_
Hours/Total:
V.
Quality of Surface Preparation
VI.
Observations - Other
                                              46

-------
                                            FORMB
                        DUSTLESS NEEDLEGUN SYSTEM EVALUATION
                                 DEMONSTRATION LOG SHEET
Location:
                                                                           Date:
I.
n.
Mobilization

Equipment Arrival Time:
Equipment Set-Up Completed:
        Total Time:

Equipment Used:
No. Personnel Required: 	

Operations

Material Use:
 Total Abrasive at Start: 	
 Total Abrasive at Finish:
        Total Abrasive (spent):
        Start Time:
                       Finish Time:
                                                    Hours/Total:
        No. Personnel Required:
                                             Duties
at
at
at
at
hours
hours
hours
hours
        Production:
        Paint Removal Area:
          Vertical Face
                           ft. X
                       % Horizontal Face (top) .
                              Total Length	
                                     .ft- =	sq. ft.

                                                _   % Horizontal Face (bottom).
                                                     ft.
No. Inside Corners   	•
No. Outside Corners	        Total Length	ft.
No. Bolt Heads      	
No. Nutted Ends
        Air Monitoring
          No.
         1.

         2.

         3.

         4.

         5.
           Type
                      Location
Time
On

Time
Off

Flow
Rate
Total Air
Volume

                                                47

-------
                                          FORMS
                       DUSTLESS NEEDLEGUN SYSTEM EVALUATION
                               DEMONSTRATION LOG SHEET
                                         (Continued)
ffl.
Clean-Up

Method:
       No. Personnel Required:_
       Equipment Used:
       Start Time:
       Waste Collected:
                     Finish Time:
Hours/Total:
Type



Amount



Lbs.
D
D
D
Ft.3
D
n
a
Gals.



How Stored



IV.    Demobilization
       Start Time:
                     Finish Time:
       No. Personnel Required:,
Hours/Total:
V.
Quality of Surface Preparation
VI.
Observations - Other
                                             48

-------
                               APPENDIX D

                     NYSTA AIR SAMPLING FORMS
               AIR SAMPLE CHAIN-OF-CUSTODY FORMS
This Appendix has been deleted because of poor reproducible quality.  Copies of
p. 49-64 are available from:

      Paul Randall
      Waste Minimization, Destruction and Disposal Research Division
      Risk Reduction Engineering Laboratory
      Cincinnati, OH 45268
                                 or
      James E. Stadelmaier
      Recra Environmental, Inc.
      Amherst, NY  14228-2298
                                    49

-------
    APPENDIX E




ANALYTICAL RESULTS
        65

-------
           RECRA
           ENVIRONMENTAL
           INC.
                                 MEMORANDUM
   TO:
FROM:
 DATE:
   RE:
          Stadelmaier
      Deborah J. Kinecki
      March 12, 1993
      Analytical Results
                                          Deborah J. Kinecki
                                          Date
KPK/DJK/dras
                                                      LD. #93-0334
                                                          #NYOC2448
                                       66

-------
                              ANALYTICAL RESULTS


                                    Prepared For

                                   Jim Stadelmaier


                                    Prepared By

                              Recra Environmental, Inc.
                            10 Hazelwood Drive, Suite 106
                           Amherst, New York 14228-2298
METHODOLOGIES

       The specific methodologies employed in obtaining the enclosed analytical results are
indicated on the specific data table.

    *  U.S. Environmental Protection Agency "Test Methods for Evaluating Solid Waste-
       Physical/Chemical Methods."  Office of Solid Waste and Emergency Response.
       November 1986, SW-846, Third Edition.

    *  The Toxicity Characteristic Leaching Procedure was performed in accordance with
       modified method 1311, 40CFR, Appendix H to Part 261, June 1990.

    *  Methods approved by the National Institute of Occupational Safety and Health.
COMMENTS

       Comments pertain to data on one or all pages of this report.

       In accordance with the recent update to the TCLP protocol, sample results are not
corrected for analytical bias.

       TCLP extractions were performed on February 15,  1993.

       The qualifier "U" indicates a result below the method detection limit.

       The difference between Total Lead results  for sample NYSTA BRIDGE 10 and
NYSTA BRIDGE 10 MATRIX DUP is attributable to sample non-homogeneity.
 RECRA
 ENVIRONMENTAL
 INC.

-------
       The spike percent recovery for sample PENTEK BRIDGE 1 MATRIX SPIKE was
0.0%. This is due to the elevated concentration of Lead in the associated sample.

       The results for undetected Total and Respirable Dust analyses are presented in two
forms:

       1.)     Undetected results for samples which had air passed through them are reported
              as the method detection limit, corrected for the volume of air sampled. The
              value is qualified with a "U".

       2.)     Undetected results for samples which have not had air passed through them
              (ie. FIELD BLANK), are reported as "ND".

       The "B" qualifier indicates that associated field blank exhibited detectable levels and
are included in one calculation.
  RECRA
  ENVIRONMENTAL
  INC.

-------
                 TOTAL NUISANCE DUST  - NIOSH 0500
                            AIR MATRIX
Laboratory:  Recra Environmental,  Inc
Lab Job No:  93-0334
Units: mg/m3
                               69

-------
                 TOTAL NUISANCE DUST - NIOSH 0500
                            AIR MATRIX
Laboratory: Recra Environmental,  Inc.
Lab Job No: 93-0334
Units: Mg/M3
CI*ZENT SAMPLE' ZD"
T-10892-A.3D
FB-10892-AD
T-10892-OP.1.1
T-10892-OP1.2
T-10892-OP1.3
FB-10892-OP1
T-10892-OP2.1
T-10892-OP2.2
T-10892-OP2.3
FB 10892-OP2
T-10892-A.1
T-10892-A.2
T-10892A.3
FB 101392 AD










ItKB &SMP3HE ID
AS026270
AS026272
AS026273
AS026274
AS026275
AS026277
AS026278
AS026279
AS026280
AS026282
AS026283
AS026284
AS026285
AS026286










ANMtYSlS
I3&TE
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93










- RESTJI*T
43.0
ND
19.0
5.0
1.6
ND
•"5.9
6.7
250
ND
27.0
32.0
62.0
ND










$

U


U
U



U



U










                                 70

-------
              RESPIRABLE NUISANCE DUST
                            AIR MATRIX
- NIOSH 0600
Laboratory: Recra  Environmental,  Inc.
Lab Job No: 93-0334
                                                      Units:  mg/m3
caaaaSF"skw&t^ , to: J
R-10792
R-10792-D
FIELD BLANK
10792
FIELD BLANK
10792D
R101392-OP-1
R101392-OP-2
FB 101392-OP1
FB 101392-OP2
R 101392
R 101392-D
R 10892-OP1
FB 10892-A
R10892-D
FB-10892-AD
R-10892
FB-10892-OP1
R-10892-OP2
FB 10892 -OP2






.. •• *• * % *. - ^"*i**i>^*V^'> "*•' :
%±a*3B 3BttE£g3BEH
*. : >>*rija ~\$0** j
AS026242
AS026246
AS026247
AS026248
AS026254
AS026255
AS026262
AS026263
AS026264
AS 02 62 65
AS026266
AS026267
AS026271
AS026272
AS026276
AS026277
AS026281
AS026282






^Stafcysis' |
* VJSRSKS " j
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93
02/25/93






^'SESUl*^, ;
:: •.* :
0.50
0.50
ND
ND
0.50
0,50
ND
ND
0.50
0.50
0.71
ND
12.0
ND
13.0
ND
12.0
ND






* ^
%- '•
U
U


U
U


U
U














                                 71

-------
                     TOTAL LEAD  - NIOSH  7082
                            AIR MATRIX
Laboratory: Recra Environmental,  Inc.
Lab Job No: 93-0334  '*
    Units: mg/1/cassette
Digestion Date: 02/17/93
C&H38HP SAM3?I*E X» -
FB 101392 -OP2 -
R 101392
R 101392-D
R 10892-OP1
FB 10892-A
T-10892-A.1D
T-10892A.2D
T-10892-A.3D
R10892-D
FB-10892-AD
T-10892-OP.1.1
T-10892-OP1.2
T-10892-OP1.3
R-10892
FB-10892-OP1
T-10892-OP2.1
T-10892-OP2.2
T-10892-OP2.3
R-10892-OP2
FB 10892-OP2
T-10892-A.1
T-10892-A.2
T-10892A.3
FB 101392AD
££B SHaJQM^'XD
AS026263
AS026264
AS026265
AS026266
AS026267
AS026268
AS026269
AS026270
AS026271
AS026272
AS026273
AS026274
AS026275
AS026276
AS026277
AS026278
AS026279
AS026280
AS026281
AS026282
AS026283
AS026284
AS026285
AS026286
&KaXtfS2£ -
* XWS&
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
mSSEfM*'..,
0.05
0.05
0.05
0.36
0.05
0.08
Q;.09
1.6
0.40
0.05
0.23
0.05
0.06
1.3
0.05
0.14
0.06
0.89
0.05
0.05
0.05
0.05
1.1
0.05
,«K' !
^•x ;
U
U
U

U




U

U


U



U
U
U
U

U
                               72

-------
                     TOTAL LEAD - NIOSH 7082
                            AIR MATRIX
Laboratory: Recra Environmental, Inc.
Lab Job No: 93-0334
    Units:  mg/1/cassette
Digestion Date: 02/17/93
c&zmz '$m&i& txf
* ^'- •• i
T-10792-1
T-10792-2
T-10792-3
R-10792
T-10792-1D
T-10792-2D
T-10792-3D
R-10792-D
FIELD BLANK
10792
FIELD BLANK
10792D
T-101392-OP1.1
T-101392-OP2.1
T-101392-OP1.3
T-101392-OP2.2
T-101392-OP2.3
R101392-OP-1
R101392-OP-2
T-101392-A.1
T-101392-A.1.D
T-101392-A.3
T-101392-A.2.D
T-101392-A.3.D
FB 101392-A
FB 101392-OP1
LAB SAMPLE ID \
AS026239
AS026240
AS026241
AS026242
AS026243
AS026244
AS026245
AS026246
AS026247
AS026248
AS026249
AS 0-2 62 50
AS026251
AS026252
AS026253
AS026254
AS026255
AS026256
AS026257
AS026258
AS026259
AS026260
AS026261
AS026262
' *Jttfti&SXS
USES - * i
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
02/19/93
. f K&sttK? \
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
- "~ar |
u

u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
                                 73

-------
                      TOTAL LEAD -  NIOSH  7082
                            AIR MATRIX
Laboratory:  Recra Environmental,  Inc.
Lab Job No:  93-0334
    Units: mg/1/cassette
Digestion Date: 02/17/93
| CLXEHT SAMPLE ID ,
FB 101392-OP2
R 101392
R 101392-D
R 10892-OP1
FB 10892-A
T-10892-A.1D
T-10892A.2D
T-10892-A.3D
R10892-D
FB-10892-AD
T-10892-OP.1.1
T-10892-OP1.2
T-10892-OP1.3
R-10892
FB-10892-OP1
T-10892-OP2.1
T-10892-OP2.2
T-10892-OP2.3
R-10892-OP2
FB 10892-OP2
T-10892-A.1
T-10892-A.2
T-10892A.3
FB 101392AD
LAB SAMPLE TD
AS026263
AS026264
AS026265
AS026266
AS026267
AS026268
AS026269
AS026270
AS026271
AS026272
AS026273
AS026274
AS026275
AS026276
AS026277
AS026278
AS026279
AS026280
AS026281
AS026282
AS026283
AS026284
AS026285
AS026286
^ ANALYSIS
I O&TE
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
2/19/93
1RESULT
0.05
0.05
0.05
0.05
0 .05
0.08
0.09
1.6
0 .40
0.05
0.23
0.05
0.06
1.3
0 .05
0.14
0.06
0.89
0 .36
0.05
0.05
0.05
1.1
0.05
Q
u
u
u
u
u




u

u


u




u
u
u

u
                                  74

-------
                      TOTAL LEAD -  NIOSH 7082

                             AIR MATRIX
Laboratory: Recra Environmental,  Inc.

Lab Job No: 93-0334
                       Units: mg/1/cassette

                   Digestion Date: 02/17/93
       , .  , -  %:-.xf  '^WVA
 CLIENT SAMPLE  XD; ,
 PATE


02/19/93
      • -

02/19/93
-- • - •

02/19/93
  -

02/19/93


02/19/93
 . - -

02/19/93
- . - -


02/19/93


02/19/93
  .

02/19/93
                         AS026239
  T-10792-1
                         AS026240
   T-10792-2
                         AS026241
   T-10792-3


   R-10792
AS026242
                         AS026243
   T-10792-1D
                         AS026244
   T-10792-2D
                         AS026245
   T-10792-3D
                         AS026246
   R- 10792-D
                         AS026247
   FIELD BLANK

   10792
   FIELD BLANK

   10792D
   T-101392-OP1.1
   T-101392-OP2.1
  	_	•	

   T-101392-OP1.3
  	

   T-101392-OP2.2
   T-101392-OP2.3
               ™  "

   R101392-OP-1


   R101392-OP-2


   T-101392-A.1


   T-101392-A.1.D
  _	

   T-101392-A.3
   T-101392-A.2.D
   T-101392-A.3.D
   FB 101392-A
   FB 101392-OP1
                         AS026248
                         AS026249
AS026250
        • —


AS026251


AS026252
     •


AS026253
  -


AS026254
__


AS026255
	


AS026256
        -


AS026257
	—	•


AS026258
.	•	—


AS026259
         1


AS026260



AS026261
	

AS026262
               02/19/93
               02/19/93
 02/19/93
__	

 02/19/93
_.

 02/19/93


 02/19/93


 02/19/93
—       "-

 02/19/93


 02/19/93


 02/19/93
        •-

 02/19/93


 02/19/93


 02/19/93


 02/19/93
                                                      0.05
0.05
0.05


0.05


0.05


0.05


0.05
0.05


0.05


0.05


0.05
                                        U
                         U
          U
 U

JJ_

_u_

 U
                                                                U
                                                                 U
                                    75

-------
                            TOTAL LEAD
                    SOLID MATRIX - PAINT CHIPS
Laboratory: Recra Environmental,  Inc.
Lab Job No: 93-0334
Method: 7420
                              Units: ug/g
                 Digestion Date:  02/17/93
                    Sample Volume:
                     100 ml
  NYSTA BRIDGE 10
  ___———————^^—

  NYSTA BRIDGE 10
  matrix dup
        ••

  PENTEK BRIDGE 1
   matrix dup
   matrix spike

   PENTEK BRIDG
   matrix spike
E aas |
E 10
E 10
GE 1
GE 1




& ED
JE 10
:e
)GE 1
ce








3*6B S
ASO
ASO
ASO
ASC




IAB i
AS(
AS








                         S£K&&£  33D |
                                      02/19/93
                           14600
              02/19/93
              7560
J7MD




r.ts TTI
02/19




^•KTAI.^
/93
/93




39100
38100




                        AS026236MS
AS026237MS
              02/19/93
02/19/93
                                                    102.0
                              83.5
                                   76

-------
                   TOTAL LEAD - TCLP EXTRACTION
                    SOLID MATRIX - PAINT CHIPS
Laboratory: Recra Environmental,  Inc.
Lab Job No: 93-0334
Method: 7420
             Units:  mg/1
Digestion Date: 02/17/93
   Sample Volume: 100 ml
C&EESP? &&K&I& i'fc
•• 't ""%*' f
NYSTA BRIDGE 10
PENTEK BRIDGE 1
LEAD STANDARD




CLIENT S^MPItE TD '\
NYSTA BRIDGE 10
matrix spike
PENTEK BRIDGE 1
matrix spike







•




£&Bij£&lS|I3ti& 3C&
' ^
AS026236
AS026237
AS026238




liaB S2a»I,B 3J*
.. ' ' % 
-------