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LA Investigating Uncontained Coating Project

Monday, February 21, 2011

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The Louisiana Department of Environmental Quality is investigating practices used to strip and recoat the Bonnet Carré Spillway, saying the project should have employed some method to capture the spillway’s old lead-containing vinyl paint.

Bonnet Carré Spillway

DEQ has opened a complaint regarding the project, and “we’re going to check it out,” department spokesman Tim Beckstrom told PaintSquare News in an interview. Although no permit was required specifically for abrasive blast cleaning, he said, “They have to have some capturing method, like a shroud.”

Robbie Hunter, project manager for contractor Lamplighter Construction, told PaintSquare News that he had used no shroud or dust-suppression measures while stripping the vinyl coating from 152 bays along the spillway, because the dust and debris “was really not that bad.”

“We had lead samples pulled,” Hunter said. “It’s such a small trace that it’s not harmful. It’s like when you water down your orange juice. It just gets so dilute that it’s not even like orange juice anymore.”

The recycled-glass medium used for blasting was not harmful to wildlife because “it’s dust,” said Hunter. “It’s not like there’s chunks of glass floating around in the water.”

Bonnet Carré Spillway

Hunter has said that the project required no containment or cleanup. The U.S. Army Corps of Engineers, which has jurisdiction on the project, agrees and has praised the progress of the work.

Air, Soil Sampling

Both the contractor and USACE said they had taken multiple soil and air samples before and during the project. They did not test nearby bodies of water, they said, because the spillway bays were emptied of water for the project.

“The only time there’s water in the spillway is when the river comes up,” Hunter said.

The 74-year-old spillway is a flood-control structure containing 359 20-foot-long bays. About once a year, authorities say, the bays are used to divert rising flood waters from the Mississippi River into Lake Pontchartrain and then into the Gulf of Mexico.  The 1.5-mile-long spillway is the southernmost floodway in the Mississippi River and Tributaries (MR&T) system to bypass New Orleans.

The site is also a popular recreation area, drawing about 400,000 visitors each year for fishing, crawfishing, hunting, dog training, camping and wildlife watching. The site also includes ATV and motorcycle riding areas, boat launching sites, and a campground.

A detention pond near the spillway provides habitats for fish and wildlife. Water seeps through the spillway bays, even when they are closed, and ends up in and around the pond, said USACE project engineer Darren Siddons.

Coating Project

The spillway was last painted in the 1970s using a vinyl coating system that contained lead, authorities said. In the current phase of the project, Lamplighter Construction, of Baton Rouge, has been working since last August to strip the old coatings from about half of the bays and repaint with a vinyl system. The contract is valued at $634,128.

The project involves recoating the steel beams that carry cranes across the bays. Each bay has more than a dozen rail beams and cross members.

Because the project is using recycled-glass media, which contains no silica, the Corps of Engineers had determined that no containment was required.  More than 600 tons of blast medium have been used on the project, which is nearly complete, authorities said.

Siddons said the Corps had not worked with the blast medium before and so had it reviewed by a staff Certified Industrial Hygienist. The CIH determined that containment was not needed for either the blast medium or the old coating.

Bidders Alerted

“It’s just dust,” Siddons said. Testing showed only “traces” of lead in the old paint, he said, leaving the Corps “absolutely” confident that open-air blasting would pose no environmental or health threat.

“There was a minimal amount [but] safe enough for wildlife and humans,” Siddons said. “We did a whole bunch of airborne samples and soil samples. We determined it would be safe for kids playing in the area and wildlife.”

He said the spillway’s last coating project, in the 1970s, should have left the surface “100% clean” of lead paint, “but there’s no such thing as 100%.”

Indeed, Siddons said, the presence of lead traces prompted the Corps to inform potential bidders on the project that lead was part of the job, and lead is noted in the bid specs.

“It was very low, but it was enough that we had to tell all the bidders when they bid on the job that, ‘Hey, this is out there. It’s up to you whether you want to protect your employees.’”

The Corps’ bid specs for the project, issued Sept. 8, 2009, note that the work “includes removal of paint containing lead (PCL) during surface preparation.”

“NOTE: The existing paint to remove contains small concentrations of lead (~4500 ppm),” the specs say.

Under a section called “Unforeseen Hazardous Material,” the specs note that a previous painting project at the site in 2008-09 “identified small amounts of lead in the existing paint coating, in the amount of 4260 parts per million in the samples taken.”

The document adds: “Lead concentrations may not be uniform over the entire area to be painted, since the lead is a residue from incompletely-removed previous painting activities. The Contractor shall perform monitoring as per the requirements of Section 09 97 02 and ensure that the removal of paint containing lead (PCL) does not constitute a hazard to workers and/or the public.”

‘The Wind Kind of Took It Away’

Dust from the blast medium and the old paint was left in the bays, “because there were no big paint chips or anything,” said Siddons. “It became such fine particles that the wind kind of took it away.”

Hunter said that his firm “didn’t have to build any kind of scaffold, or contain anything, or dispose of anything. We had no cleanup whatsoever.”

Siddons said the medium has about a 10-foot blast range. “It’s not terrible,” he said, “but on windy days, it can be.”

State Enforcement

Siddons said that he was not sure what state regulations applied to the job, but that he was “sure that someone in our district office checked with DEQ.” He added: “I’m sure they had to go through all the environmental checks. It wouldn’t make sense to go through a whole job without checks.”

He was unable to provide specifics, however, and DEQ said it had no record of the job.

“The department does have regulations that apply to abrasive blasting,” said Celena Cage, administrator of the enforcement division for DEQ’s Office of Environmental Compliance. “The regs are specific about what needs to be done.”

Louisiana Code Requirements

Louisiana Administrative Code (LAC), Air Regulations Chapter 13 Subchapter F, addresses emissions from abrasive blasting.

“The purpose of this Subchapter is to reduce particulate matter emissions from facilities that engage in abrasive blasting,” the code says. The regulations apply to “any material used in abrasive blasting,” although exemptions may be granted “as approved by the department on a case-by-case basis.”

The code requires facilities to either “fully enclose the item, or surround the structure, to be blasted” or to “prepare and implement a best management practices (BMP) plan as described in LAC 33:III.1331.”

The code details the BMP Plan at length. Among many requirements, the plan must include:

• A description of any nearby waters of the state that may be affected, their distances and directions from the facility, and how emissions to those waters will be prevented or minimized;

• A statement of the facility's procedures for preventing nuisances and/or adverse off-site impacts, including a description of any emission control equipment;

• Provisions for personnel training; and

• Detailed records of how spent material is handled, recycled, reused, or disposed of.

The Corps did not respond to a question about whether there was a BMP for the spillway project.

In addition, “Chapter 13, Emission Standards for Particulate Matter” spells out how emission of particulate matter is to be controlled in “any operation, process, or activity from which particulate matter is emitted…”

“All reasonable precautions shall be taken to prevent particulate matter from becoming airborne,” the code states. “These precautions shall include, but shall not be limited to” use of water or chemicals for dust suppression and dust collectors to contain emissions. “Adequate containment methods shall be employed during sandblasting or other similar operations,” the code says.

Blast Medium

The blast medium used in the project is made by Novetas Solutions LLC, of Philadelphia. The company says its New Age Blast Medium is made from non-toxic, chemically inert, recycled bottle glass and is thus safe for use near and around water. Contaminants and waste by-products are stripped from the glass during manufacturing, according to Novetas.

Paul Mellon, of Novetas, said the product was allowed to hit the water after blasting in this and other projects. Novetas says the product has previously been used in a variety of bridge and ship blasting and cleaning projects.

The product appears on the Navy’s Qualified Products list. The Naval Environmental Health Center has also reviewed the product. NEHC says the most common hazards in working with the medium are skin irritation and high-velocity body injuries.

   

Tagged categories: Abrasive blasting; Containment; Lead; Protective coatings; Surface preparation

Comment from Scott Starchuk, (2/22/2011, 4:07 AM)

Did all the attention that the previous article on Paintsquare garnered prompt the authorities to investigate?


Comment from Gerald Burbank, (2/22/2011, 7:27 AM)

Am I missing something here? Isn't it against federal regulations to dump hazardous materials into waterways? Can I use the "Gee whiz... The lead paint chips just blew away" defense on my next project as well?


Comment from Billy Russell, (2/22/2011, 8:35 AM)

Wow, you are kidding me (Tim, Rick and David). I guess you smart guys are going to defend this guy that said it's not enough lead to harm the kids and wildlife in the area, and they have no waste to clean up. You have got to be kidding me. This job should have been contained. The Corps and their chemist are wrong on this one. Not smart, guys, not smart at all. This level of unprofessionalism makes everybody look bad, very bad.


Comment from Trevor Neale, (2/22/2011, 9:14 AM)

Surely a strong case for QP 1 and QP2 qualified application contractors.


Comment from M. Halliwelll, (2/22/2011, 10:50 AM)

Wow...just wow. With this being along fish-bearing water, the Canadian DFO (I'm from "up north") would have crucified the contractor for this sort of thing. I cannot fathom how the USACE can alert bidders that lead paint is present (and say the concentration may be variable) but so casually say worker protection is optional and no containment is required. Totally unprofessional. From my point of view, the minimum standard for any work has to be the minimum requirements of *any* regulator involved or potentially involved...local, state, federal or other. Just because one claims jurisdiction and gives you the go ahead doesn't mean you're absolved from meeting the requirements of the others. To believe it does just opens you up for litigation and very, very bad press.


Comment from john murray, (2/22/2011, 11:12 AM)

I'm either missing something or misunderstanding the regulations. Aren't there acceptable levels for air and ground? If they took readings and were below the exposure levels, why would you have to contain? There's naturally occurring levels of lead everywhere.


Comment from Tim Race, (2/22/2011, 1:25 PM)

OK, folks, I never said that I thought that open abrasive blast cleaning without containment at Bonnet Carre Spillway was acceptable. However, I do continue to stand behind and support the Corps' practices and policies with regards to environmental protection as well as health and safety. I last updated the Corps of Engineers' guide document for painting hydraulic structures a couple years ago. I have done this under contract twice since I left the Corps in 1998. The painting guide specification is supposed to be used by Corps Districts to develop bid specs. The guide document does, in fact, recommend containment for the type of work being performed at the Bonnet Carre Spillway. My previous posts were intended to address some of the questions and misconceptions regarding the work--namely, that the work is not being performed over or near water and that there are, in fact, no sensitive receptors in the vicinity of the work. The structure is fairly low, and the airborne drift of blast debris should be minimal. The original article did not mention the presence of lead. It's not clear to me whether the lead is residual from an old coating system or if it is the lead content typical of a zinc-rich paint from the 1970s. It's also not clear to me what logic the New Orleans District used in its decision not to require containment of the work. The painting guide specification contains provisions for monitoring visible emissions, PM-10, TSP, and TSP-Pb, as well as water and soil quality, and lead-specific medical surveillance and worker air monitoring. The guide spec also says to check on what, if any, state and municipal regulations apply to the proposed work.


Comment from Billy Russell, (2/22/2011, 2:24 PM)

OK folks,the original article did not mention lead. I smell "crawfish." Anybody involved in this industry knows the potential ramifications of being around an open-air blasting operation (run as far and fast away as you can). Waste handling and disposal regulations are very detailed and quite clear. "The wind took it away" is the kind of answer they make jail cells for. That clearly tells me that contractor is clueless, along with the Corps and the people involved in signing off on no containment. "The structure is low and the airborne drift of blast debris should be minimal" is ludicrous. The Corps, in their original spec, stated to the contractor there was lead present. Based on that statement alone, containment was and is necessary. DEQ had not been asked to give an opinion, or containment would have been used. Vinyl & glass would have had no relevance, which is what they used to sell less informed people as to proper procedure in any blasting operation. You will be hard pressed to find any state that allows open-air blasting regardless of proximity to water, if federal money is involved. The rules are clear; the industrial hygienist involved needs to go back to school. He/she skipped the BASICS.....


Comment from Tim Race, (2/22/2011, 3:21 PM)

Thanks for your kind words, David. My comments were meant to be informative and constructive.


Comment from Paul Archambo, (2/22/2011, 3:52 PM)

I am quite sure he was the lowest bidder!!


Comment from James Johnson, (2/23/2011, 10:20 AM)

What am I missing here? If the lead was below the action level in all their testing, is there a problem? According to the Corps, there is not. The last I knew, containment was not required for every project and, in some cases, open-air blasting is okay, is it not? Tim's explanation sounds the most reasonable to me.


Comment from Joseph Brandon, (2/23/2011, 4:31 PM)

One of the most important characteristics of a fair competitive bidding process is having a bid package that is interpreted identically by all potential bidders. It appears that this project may not have been such a project. I would be interested in hearing from contractors that bid on this project, and those that considered bidding, as follows: 1. Did you bid? 2. Were the bid criteria clear and actionable? 3. If bid criteria was not clear, did you submit questions prior to the date of bids?


Comment from Kathy Lauckner, (2/24/2011, 4:40 PM)

Did anyone check the workers for exposure to lead? There are always OSHA regulations to consider, and the workers must be protected. 4500ppm lead could easily expose workers to air levels that surpass the 50ug/m3 (8 hour TWA) for worker PEL. Not to mention the lead dust they may have carried home with them every day. It seems to me that the Corps of Engineers staff need to take a lead refresher class. There have been several cases where by workers have been put at risk due to the Corps' disregard for lead hazards or assumption that they are contracting with competent companies.


Comment from Michael Beitzel, (2/25/2011, 9:57 AM)

Louisiana Code Requirements Louisiana Administrative Code (LAC), Air Regulations Chapter 13 Subchapter F, addresses emissions from abrasive blasting. “The purpose of this Subchapter is to reduce particulate matter emissions from facilities that engage in abrasive blasting,” the code says. The regulations apply to “any material used in abrasive blasting,” although exemptions may be granted “as approved by the department on a case-by-case basis.” The code requires facilities to either “fully enclose the item, or surround the structure, to be blasted” or to “prepare and implement a best management practices (BMP) plan as described in LAC 33:III.1331.” The code details the BMP Plan at length. Among many requirements, the plan must include: • A description of any nearby waters of the state that may be affected, their distances and directions from the facility, and how emissions to those waters will be prevented or minimized; • A statement of the facility's procedures for preventing nuisances and/or adverse off-site impacts, including a description of any emission control equipment; • Provisions for personnel training; and • Detailed records of how spent material is handled, recycled, reused, or disposed of.


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