United States
                     Environmental Protection
                     Agency
 Risk Reduction
 Engineering Laboratory
 Cincinnati, OH 45268
                     Research and Development
 EPA/600/SR-94/114    September 1994
xx EPA       Project  Summary
                     Removal  and  Containment of
                     Lead-Based  Paint Via Needle
                     Sealers
                     Paul B. Kranz, James E. Stadelmaier, and Paul M. Randall
                      This report describes a comparative
                    technical and  economic evaluation of
                    using a dustless needlegun system ver-
                    sus a conventional abrasive grit blast-
                    ing system to remove lead-based paint
                    from steel structures. The study objec-
                    tives were 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 eco-
                    nomic factors.
                      The dustless needlegun system dem-
                    onstrated its ability to produce a sub-
                    stantial  reduction  (97.5%)  in  the
                    generation of  hazardous waste when
                    compared with that  of conventional
                    abrasive blasting. The needlegun also
                    substantially reduced (up to 99%) the
                    airborne concentrations of respirable
                    dusts and lead-containing particulates
                    generated during paint removal opera-
                    tions.
                      Labor costs were decidedly higher
                    (approximately 300%) for the dustless
                    needlegun system primarily because of
                    slower production rates that necessi-
                    tate more operating personnel. These
                    costs are substantially mitigated by re-
                    duction of costs associated with ex-
                    pendable abrasive blast material and
                    hazardous waste disposal.
                      Conventional  abrasive  blasting
                    proved decidedly superior in the qual-
                    ity of surface preparation based on pre-
                    scribed contract specifications.
  The dustless needlegun system is
shown to be economically competitive
with conventional abrasive blasting
when considering the reduced require-
ments  for  containment, hazardous
waste disposal, and worker protection.
  This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
key findings of the research project
that is fully documented  in a separate
report of the same title (see Project
Report ordering information at back).

Introduction
  The use of abrasive blasting with ex-
pendable grit media for removing  lead-
based paints from steel  structures  has
been the standard for many years, mainly
because of its efficiency both in removing
the lead-based paint and in achieving the
surface cleanliness and profiles required
for subsequent coating operations. In re-
cent years, however,  the disadvantages
of using abrasive blasting  have become
increasingly apparent. The process's gen-
eration of difficult-to-contain,  airborne, lead-
contaminated particulates presents a high
potential of lead exposure to workers and
the local environment. Although sophisti-
cated systems to control or contain air-
borne particulates would  minimize the
potential for environmental contamination,
they may result in more hazardous local-
ized environments for workers and result
in substantially higher overall costs for
lead-based paint removal operations. Ad-
                                                                     Printed on Recycled Paper

-------
ditionally,  using expendable abrasive grit
to remove lead paint generates excessive
amounts of waste material that  requires
disposal as hazardous waste.
  This is a study of the effectiveness and
applicability of using a dustless needlegun
system to remove lead-based paint from
steel  bridges. The costs,  generation of
hazardous waste, and environmental and
worker safety are compared with those
arising from conventional abrasive blast-
ing.

Procedure
  The industrial  participants for this  pro-
gram  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
highway system. Pentek has been manu-
facturing  dustless surface preparation
equipment for use by nuclear facilities and
hazardous waste remediation/cleanup con-
tractors since 1985.
  The Pentek system is a form of power-
tool cleaning that  combines material re-
moval and containment. The Pentek COR-
NER-CUTTER®* (Figure  1),  a hand-held
needlegun for surface preparation in tight
spots and/or vertical and inverted horizon-
tal steel  or concrete surfaces,  is one of
three models of surface preparation tools
that Pentek manufactures.
  Material is removed through the actions
of pneumatically  operated reciprocating
cutting bits or steel  needles  that scarify
and  pulverize the  paint or coating. This
cutting action does  not adversely affect
the structural integrity of steel substrates.
The  surfaces of concrete substrates,  on
the other hand, can  be removed in con-
trolled layers of between 1/16- and 1/4-in.
thick. The removed material is contained
first  by  using an  adjustable shroud  lo-
cated at the tool's point of  operation to
localize containment, and second, by trans-
 Mention of trade names or commercial products does
 not constitute endorsement or recommendation for
porting the contained materials via vacuum
to an  attached  VAC-PAC® containment
vessel (DOT  1.7-H drum). The vacuum
head of the containment drum (VAC-PAC®
system) is equipped with high-efficiency
particulate air (HEPA)  filters that prevent
the escape of airborne dusts at the con-
tainment vessel.  Based  on field  experi-
ences,  Pentek  claims  to  immediately
capture 100% of airborne dusts and 99.5%
of solid debris at the surface.
   Conventional abrasive  blasting  (Figure
2) employs compressed air to propel ex-
pendable  abrasive particles against the
surface to be cleaned, to produce a sur-
face profile required  by  Standards and
Specifications of the Steel  Structures Paint-
ing Council No. 6 (SSPC-SP 6). The spent
abrasive and paint debris are manually
collected for  disposal,  usually  as hazard-
ous waste.
   Both paint removal  technologies  were
evaluated on NYSTA bridges  located  on
Interstate  90 in  western  New York. The
abrasive blasting evaluation was done on
NYSTA Bridge #10 on October 7 and 8,
                                                Corner-Cutter®
                                                  pneumatic
                                               operation housing
                              Removed paint
                              chips/dust/rust
                                                                                         2mm reciprocating
                                                                                             needles
                           Piston
                                                                                   Adjustable containment
                                                                                         shroud
                                                                                     Painted surface
                                                                                                              Substrate
Figure 1. Pentek CORNER-CUTTER® schematic.

-------
                                                                                    Removed
                                                                                    paint and
                                                                                      spent
                                                                                    abrasive
                                                                                       grit
                                                                           Abrasive
                                                                            stream'
            Compressed
            air supply in
                                           Removed
                                           paint and
                                            spent
                                           abrasive
                                             grit
                                                               Painted
                                                               surface
                                                   Blasting
                                                   grit and
                                                 compressed
                                                      air
Figure 2. Abrasive blasting process schematic.
1992, and the Pentek evaluation was done
at NYSTA Bridge #1 on October 13, 1992.
The evaluations consisted of observations
of work practices, equipment and labor re-
quirements, and time required to complete
various tasks as well as to physically mea-
sure background and work-in-progress air-
borne dust and lead concentrations during
the paint removal operations.  Waste  ma-
terials from both processes were collected
and analyzed for lead concentrations. In-
terviews  were conducted  with NYSTA,
Pentek, Inc., and paint removal contractor
personnel to obtain background informa-
tion and historical data relative to the evalu-
ations.
  NYSTA Bridge #10 is of rolled beam
design and composed of approximately
151 tons  of steel and 14,946 ft2 of surface
area,  and the paint thicknesses  ranged
from 10 mils (0.254 mm  or 0.01 in.) to 13
mils  (0.330 mm or 0.013  in.).  Previous
testing by NYSTA had determined  the
presence of  lead-based  paints   as  the
primer and finish coatings.
  Historically, surface preparation of simi-
lar  NYSTA bridges, using conventional
abrasive  blasting methods to SSPC-SP  6
specifications, has generated an average
of 0.15 to 0.20 tons of waste (spent abra-
sive, paint and miscellaneous dirt, rust,
and mill scale) per ton of steel. Theoreti-
cally, this would equate to 22.7 to 30.2
tons of hazardous  waste generated  by
conventional abrasive blasting operations
at this structure.  This waste  has been
characteristically hazardous because of its
teachable lead content.
  Bridge #1, also of rolled beam design,
is comprised of approximately 315 tons of
steel and approximately 25,000 ft2 of sur-
face area. The paint thickness on this
bridge was again estimated by the NYSTA
to range from 10 to 13 mils. As with Bridge
#10, previous testing by NYSTA had de-
termined  the  presence  of lead-based
paints.
  Historically, paint  removal from similar
structures using the  Pentek system would
generate hazardous paint waste at a rate
of 1 oz/ft2 of area cleaned because of its
leachable lead content.
  The  abrasive blast  media consisted of
Ebony  Grit 20,  a nonsilica,  lead-free abra-
sive.

Conventional Abrasive Blasting
  To minimize the potential for cross-con-
tamination and  to satisfy bridge painting
schedules and  other  logistical concerns,
these comparative evaluations were con-
ducted on two separate bridges. Because
of the similarity of structures and the paint
coatings used on each, we believed this
would not compromise the quality  of the
data.
  On Day 1 of the conventional abrasive
blasting evaluation on Bridge #10, back-
ground information regarding the process
was obtained and both cleanup activities
from the prior day's work and setup activi-
ties for work to  be performed were ob-
served  and  recorded.  Background
lead-in-air concentrations, used  as  a
baseline for both  technology evaluations,
were also monitored.  On Day 2, we ob-
served work procedures, conducted per-
sonal  and  area  air  monitoring, and
recorded appropriate measurements to as-
sess productivity and waste generation.
  We interviewed employees and  super-
visors to develop information  relative to
time and labor  requirements  for daily
cleanup and job site mobilization and de-
mobilization activities. This information was
integrated with job site observations to
estimate the man  hours required and their
associated costs.
  Job  setup and mobilization required
seven workers for 1.5 hr each, mainly to

-------
establish traffic control, position equipment,
and  install hanging enclosure tarps  and
ground cover tarps. The work enclosures,
which are contractually required  by the
NYSTA,  consisted  of  canvas tarpaulins
suspended from cables attached to the
bridge structure so as  to form a three-
sided enclosure:  the  closed sides  face
traffic during abrasive blasting operations.
The  tarpaulins extended from the under-
side  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 on Day  2
were done simultaneously on the interior
eastbound and westbound lanes. Two op-
erators  with abrasive  blasting  nozzles
were used per section, which consisted of
six 32-in.  x 12-in.  flange I-beams placed
20 ft on center with connecting 13-in. steel
channel  bracing  mechanically  fastened
with  nuts  and bolts. Approximately  1180
ft2 of surface was completed during the 4-
hr evaluation. Grit use, based on  past
experiences, was estimated to be 4 to  7
tons/day of average production per ves-
sel, based upon 1/2 ton/hr of grit use per
nozzle operator. This  use was  expected
to produce specification surface prepara-
tion at a rate of 120 ft2/hr per operator.
  Before beginning the evaluation phase,
the  two nozzle  operators working on the
westbound section were each fitted with
two air sampling pumps  (low volume) cali-
brated to provide a flow rate of 1.5 to  1.7 L
of air/min  using a  digital calibrator.  Total
and  respirable  dusts  emitted during the
blasting  process were  collected with the
use of Millipore 37mm, 0.8^. mixed cellu-
lose  ester filter  (MCEF) matched-weight
cassettes, with cyclone separators for re-
spirable dust collection.
  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 resi-
dues. Visible plumes of dust were noted
escaping from the enclosure.
  Before the abrasive  blasting operation
evaluation, cleanup activities  from  previ-
ous blasting were observed. The cleanup
activities,  described by NYSTA and the
contractors as typical, consisted of manu-
ally dry sweeping spent abrasive and paint
residues,  progressively  elevating ground
tarps to  consolidate  wastes,  and  then
manually shoveling the collected materi-
als into openhead 55-gal steel drums. Six
laborers cleaned  this  section  in 1.5 hr.
The  cleanup operation was  noted  to be
very dusty. The roadway above  required
additional cleanup; the overspray or de-
posits  of  fugitive dusts were  dry  swept
and shoveled to drums.

Pentek Dustless Needlegun
System
  The  Pentek system was evaluated on
October 13, 1992, at NYSTA  Bridge #1.
Evaluation consisted of observing  and
documenting mobilization, paint removal,
and cleanup and demobilization activities,
as well as performing personal and area
air monitoring and making necessary mea-
surements to  assess productivity  and
waste generation.
  Job  setup and  mobilization, requiring
four  workers for 0.5 hr each, consisted
primarily of positioning equipment. No con-
tainment enclosures or ground cover tar-
paulins were used.
  Three operators, each with a CORNER-
CUTTER® unit, removed paint at the evalu-
ation area, which consisted of four 34-in.
x 12-in. flange  I-beams with connecting
13-in. steel channel bracing and connect-
ing  hardware.  Paint from approximately
119 ft2 of surface was removed during the
3.25-hr evaluation period.
  Before the evaluation began, two of the
three CORNER-CUTTER® operators were
each fitted with two  air sampling pumps
having appropriate media for collecting to-
tal and respirable dusts emitted during the
paint removal operations.
  During the Pentek system paint removal
operations, there were  no visible emis-
sions of dust or paint residues. The COR-
NER-CUTTER® units removed the finish
paint coat layers with little difficulty; how-
ever, the orange primer required consid-
erably  more effort and time.
  When  this  paint  removal  operation
ended, it was apparent that nearly all paint
residues  had been effectively contained
and collected by the Pentek system. Some
minor residues (large paint chips and rust)
were easily collected using  the  vacuum
hose attached to the CORNER-CUTTER®.
Cleanup operations, i.e., wiping down, dis-
assembling, and storing of equipment, re-
quired four workers for 0.5  hr.  This
operation  would normally only be done
after job completion,  not  on a  daily or
shift-by-shift basis.
  Air sampling consisted of pre-work
samples, done  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 the 4-hr period coinciding with the
technology  evaluations.  Work area
samples for the abrasive blasting opera-
tions were taken within the tarpaulin work
enclosure approximately 25 ft  from  the
points of operations. For the Pentek op-
erations, work  area  samples,  taken  ap-
proximately  25  ft  from the  point of
operations,  were more  vulnerable to
changing air currents  from  the  thruway
traffic. Quantities of  waste generated by
the abrasive blasting operations were de-
termined by  examining New York State
Hazardous Waste Manifests  and extrapo-
lating these data based on  total surface
areas of the bridge  versus  total surface
area of paint removed.
  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 amount
for  an entire structure  based on surface
area of  paint removal during the evalua-
tion.

Results and Discussion
  The economic evaluations depicted here
are not intended to be all-inclusive or  rep-
resentative of  all relative project  costs.
Specifically excluded are costs related to
capital  equipment,  equipment  mainte-
nance, vehicles, utilities and fuel, contain-
ment structures, and personal protective
equipment. For simplicity and uniformity,
a standard labor rate of $15/hr was as-
sumed for all labor classifications. Labor
activities were divided into five categories:
paint removal operations, support labor,
mobilization, demobilization, and cleanup.
Production  rates in square foot per hour
per operator were  used  to calculate  a
total labor cost assuming work on  identi-
cal  15,000-ft2 bridges.  Based on demon-
strated  production  rates, approximately
eight Pentek systems, each using three
CORNER-CUTTERS®,  would be needed
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 as-
sociated production costs for the  Pentek
system.
  Labor requirements for support, mobili-
zation, and demobilization were also higher
for  the Pentek system, primarily because
of  the  number  of  workers  required.
Cleanup labor  costs were  substantially
higher for the abrasive blasting process.
These comparative labor costs are shown
in Table 1.

-------
Table 1. Total Estimated Labor Costs

               Abrasive Blasting   Pentek
Labor Category        ($)            ($)
Paint removal
Support
Mobilization
Demobilization
Cleanup
Labor Totals
1,500
1,125
945
210
5.460
9,240
18,450
6,090
1,440
720
240
26,940
  Table 2  shows  the  amount  of  waste
generated during the evaluation periods
and extrapolates these numbers to a com-
plete  bridge. As can be seen, abrasive
blasting generates approximately 40 times
more  waste than the Pentek system be-
cause abrasive blasting uses expendable
blasting media. Note that only 31 tons of
waste were disposed from this job,  and
that, based upon use estimates, approxi-
mately 50.8 tons of abrasive grit would be
used.
  Table 3 summarizes total  costs  for la-
bor, materials, and hazardous waste dis-
posal. Material  costs were based  on the
assumption that the abrasive blast  media
was the only expendable material used.
This cost  was  based on each operator
using 0.5 ton of grit/hr.
  The results of the air sampling done
before and during the evaluations are pre-
sented in Table 4. Air sampling was done
for 4-hr periods on two abrasive blast op-
erators  and two Pentek  CORNER-CUT-
TER® operators in addition to sampling
work areas proximate to the paint removal
activities.
  For  the  8-hr  time-weighted  averages
(TWA), the abrasive blasting sampling data
indicate OSHA Permissible Exposure Lim-
its (PELs) were exceeded  for total dust,
respirable dust, and total airborne lead on
three samples and for  respirable lead on
two of four  samples.
  The  Pentek air sampling results exhib-
ited no detectable  airborne lead or respi-
rable dust, and only negligible amounts of
total dust.
  The  contract specifications  for  the
bridges evaluated  called  for SSPC-SP 6
(commercial blast) to  remove all visible
paint and residues from two-thirds of the
bridge surface area before repainting. The
abrasive blasting operation  was able to
surpass this level  of surface preparation
for all areas of the  structure.
  The Pentek system demonstrated a less
efficient removal of paint, especially the
orange primer coat; it also was less effec-
tive while performing around irregular sur-
faces such  as nuts and bolt heads and in
inaccessible corners. The NYSTA bridge
inspectors indicated that a post-blast would
be  needed for the Pentek-cleaned  sec-
tions to meet  SSPC-SP 6 specifications.
Conclusions
  The economic and product quality as-
pects tend to favor conventional abrasive
blasting over the Pentek  system for  re-
moving lead paint; however, the decision
to specify a  lead  paint removal  system
should be strongly influenced  by the  in-
creased volumes of hazardous waste gen-
erated and the potential for negative effects
to worker health  and safety and to the
environment.
  The Pentek dustless needlegun system
labor costs  were approximately  300%
higher than those of the conventional abra-
sive blasting  process; however, the over-
all  costs  were mitigated  by the 97.5%
reduction in  generation  of hazardous
waste. Additionally, fugitive  emissions of
airborne dusts were  reduced up  to 99%,
which serves  to enhance the level of envi-
ronmental protection  and  worker  health
and safety.
  The dustless needlegun  system is eco-
nomically  competitive when factoring in
costs of sophisticated containment struc-
tures and engineered systems necessary
to ensure worker health and safety and
protection of the environment.
  The full report was submitted  in fulfill-
ment of CR-816762  by  Erie County  De-
partment  of  Environment  and  Planning
under the sponsorship of  the U.S. Envi-
ronmental Protection Agency.
Table 2. Hazardous Waste Generation and Disposal Costs

Removal
System
Abrasive
blasting
Pentek
Removal
Area
(ft2)

1,180
119
Waste Generated (Ib)

Theoretical

4,170*
7.4*

Actual

4,807
11.5

Lb Waste
(ft2)

4.1
0.1

Est. Total
Waste (Ib)

61,500
1,500

Total Waste
(tons)

30.8
.75
Disposal
Costs
($/ton)'

300
300
Total
Disposal
Costs ($)

9,240
225
* Industry average for bulk waste including transportation.
f Theoretical waste generated based upon . 175 ton waste/ton of steel cleaned.
t Theoretical waste generated based upon 11.5-mil. paint thickness and paint solids density of 66.3 Ib/ft.3
Table 3. Total Costs
Abrasive Blasting Pentek
Category ($) ($)
Labor
Materials
Hazardous waste
disposal
Total
9,240
1,957
9,240
20,437
26,940
0
225
27,165

-------
Table 4. Air Sampling Analytical Results
                                   Sampling Period
                                                                                               8-hr TWA'
Sampling
Point
Background
Background(D)n
Abrasive blast
area
Abrasive blast
area (D)
Abrasive blast
operator #1
Abrasive blast
operator #2
Pentek area
Pentek area (D)
Pentek
operator #7
Pentek
operator #2
Total
Dust
(mg/m3)
0.6
ND
41.2
34.1

8.0
89.2
0.2
ND

2.9

2.7
Respirable
Dust
(mg/m3)
0.2
ND
12.5
11.9

0.7
12.3
ND
ND

ND

ND
Total Pb
(mg/m3)
0.01
ND
0.32
1.4

0.1
0.89
ND
ND

ND

ND
Respirable
Pb
(mg/m3)
ND"
ND
0.26
0.1

ND
0.24
ND
ND

ND

ND
Total
Dust*
(mg/m3)
0.3
ND
20.6"
17.1*"

4.0
44.6***
0.1
ND

1.5

1.4
Respirable
Dust*
mg/m3
0.1
ND
6.3**
5.9***

0.4
6.2***
ND
ND

ND

ND
Total
Pb§
mg/m3
.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
ft
     Assuming no exposures during remainder of 8-hr work day.
     OSHA PEL = 15 mg/m3.
     OSHA PEL = 5 mg/m3.
     OSHA PEL = .05 mg/m3.
     Not detectable.
     Duplicate sample.
     Exceeds OSHA PEL.

-------

-------
Paul B. Kranz is with Erie County Department of Environment and Planning,
  Buffalo, NY 14202; James E. Stadelmaier is with Recra Environmental, Inc.,
  Amherst, NY 14228; and the EPA author Paul M. Randall (also the EPA
  Project Officer), is with the Risk Reduction Engineering Laboratory,
 Cincinnati, OH 45268 (see below).
The complete report, entitled "Removal and Containment of Lead-Based Paint
    Via Needle Sealers," (Order No. PB94-193216; Cost: $19.50, subject to
    change) will be available only from:
        National Technical Information Service
        5285 Port Royal Road
        Springfield, VA 22161
        Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
        Risk Reduction Engineering Laboratory
        U.S. Environmental Protection Agency
        Cincinnati, OH 45268
 United States
 Environmental Protection Agency
 Center for Environmental Research Information
 Cincinnati, OH 45268

 Official Business
 Penalty for Private Use
 $300
      BULK RATE
POSTAGE & FEES PAID
         EPA
   PERMIT No. G-35
 EPA/600/SR-94/114

-------