VALERO – KROTZ SPRINGS
SHG #51
Page 1 of 8
APPROVED 11/10/03
LEAD PAINT GUIDELINE
1.0
PURPOSE
To provide guidance for the safe handling of materials containing lead compounds.
Inorganic lead is most commonly found in the Refinery in the form of lead-based paints.
2.0
SCOPE
This procedure applies to all Valero employees and Contractors who could potentially
disturb paints or primers that are not lead free. Contractors will provide the Safety
Department with a written Lead Compliance Plan.
3.0
DEFINITIONS

LEAD - metallic lead and all inorganic lead compounds, e.g. those used in paints
and primers.

PERMISSIBLE EXPOSURE LIMIT (PEL) - established by OSHA, is the
maximum concentration of lead to which an employee may be exposed in an 8hour work shift. The PEL for an 8 hour work shift is 0.05 mg/m3.

ACTION LEVEL - established by OSHA, is the concentration of lead above
which an employee is offered medical surveillance. The Action Level for an 8
hour shift is 0.03 mg/m3.

COMPETENT PERSON - a trained individual, who has knowledge to identify
where lead may be present in the work environment and to take action to
minimize exposures. A contractor’s competent person will oversee their
company’s lead program compliance efforts during work performed.

LEAD CONTAINING PAINT - Any paint or coating containing 0.06% (600 PPM)
or more of lead by dry weight.
VALERO – KROTZ SPRINGS
4.0
RESPONSIBILITY
INDIVIDUAL/GROUP
Owning Area
ASSIGNED RESPONSIBILITIES

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Environmental &
Safety Affairs
Department
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Training Department
Maintenance
Department
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
Contractors
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5.0
SHG #51
Page 2 of 8
APPROVED 11/10/03
Identify, via the work permit, those jobs that are likely to
disturb paints or primers, and stipulate the appropriate
respiratory protection and PPE for the task.
Inform the Environmental Department of any lead waste
accumulated from work activities.
A Safety Department Representative will conduct personal
exposure monitoring as needed to assess employee
exposures to airborne lead, particularly during tasks where
paint or primer is disturbed.
The Safety Department will assist in determining if
engineering or administrative controls are practical to avoid
use of respirators.
The Plant Nurse will maintain the Medical Surveillance
Program and ensure all rules and regulations of this program
have been addressed.
The Environmental Department will dispose of any lead waste
accumulated from work activities.
Develop annual training module with input from the Safety and
Maintenance Departments.
Deliver and document annually required training.
Ensure that respiratory protective equipment and PPE is worn
when performing jobs that create a potential for generating
airborne lead.
Inform the owning department of any lead waste accumulated
from work activities.
Provide the Safety Department with a written compliance
program as necessary.
Comply with Valero’s Safety and Health Guideline.
Inform the owning department of any lead waste accumulated
from work activities.
IDENTIFICATION OF LEAD-CONTAINING MATERIALS


Historically, lead has been used in paints and primers in certain areas of the
refinery, which will be listed in Attachment 1 of this guideline. These areas
(unless documented as lead free paint) will be the basis for the utilization of this
program.
The use of new applications of lead based paint within the refinery shall be
avoided, unless suitable alternatives are not available.
VALERO – KROTZ SPRINGS
6.0
SHG #51
Page 3 of 8
APPROVED 11/10/03
GENERAL WORK PRACTICES
The following general work practices are required for job tasks that will disturb lead
containing paint or materials. Refer to Attachment 1 for a list of these areas.
6.1
AIR MONITORING
Must be conducted for representative types of lead work activities. Previous
monitoring data may be used to meet this requirement if work conditions are
similar to earlier work. Employees must be allowed access to witness the
monitoring. All OSHA requirements relative to air monitoring must be met as
necessary.
6.2
RESTRICTED ACCESS
A restricted area must be established to prevent unprotected employees from
entering the work area using barrier tape or other means to prevent entrance. In
establishing the restricted area, considerations will be given to air monitoring
data and wind and weather conditions.
6.3
HYGIENE/INGESTION CONCERNS

The consumption of food or beverages, use of tobacco products and application
of cosmetics are not allowed in lead paint work areas. Personnel must wash
their hands and face prior to eating, drinking, smoking, or applying cosmetics.

Workers leaving a lead work area must either HEPA vacuum their protective
clothing or remove it and place it in a sealed bag. Compressed air may not be
used for decontamination of clothing or tools.
6.4
WASTE DISPOSAL

All lead containing debris must be collected in labeled hazardous waste
containers. Refer to the Environmental Department if there are any questions on
labeling lead waste containers.

Waste, such as scrap metal or equipment, covered by leaded paint must be
noted on the “Bill of Lading” or manifest that the surface coating contains lead. If
contamination of surface area is suspected, refer to the Safety Department for
help in testing the surface.
6.5
LEAD TRAINING

Annual lead training is required for all employees involved in lead work activities.
VALERO – KROTZ SPRINGS
SHG #51
Page 4 of 8
APPROVED 11/10/03
6.6
MEDICAL SURVEILLANCE/PERSONAL MONITORING

Any employee who has been exposed to lead above the OSHA Action Level for
more than 30 days per year must be included in a lead medical surveillance
program.

Employees and their designated representatives must be provided access to
their medical and exposure records upon request.
6.7
CONTAINMENT OF WORK AREAS

The need to provide full containment (i.e. plastic enclosures) will vary depending
on the job and its proximity to other workers.

Full containment is not required when using chemical paint remover.
6.8
REGULATED AREAS

Areas must be established with warning signs and/or barricade tape posted at a
minimum of 10-foot diameter around the work. The warning will read:
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING
7.0

Lead debris should not be allowed to accumulate on surfaces. Wet sweeping is
a preferred method of clean up. Dry sweeping and shoveling of lead-containing
debris may be performed ONLY if wet sweeping cannot be performed. A halfmask respirator with HEPA cartridges MUST be worn when dry sweeping or
shoveling lead-containing debris.

Paint or primer debris should not be allowed to contact the ground, particularly
unpaved surfaces. Plastic tarps should be laid out under the work to collect the
debris.
JOB SPECIFIC GUIDELINES
The following guidelines are required for job tasks that will disturb lead containing paint
or materials. Refer to Attachment 1 for a list of these areas.
7.1
GRINDING, SANDING, OR BUFFING WITH POWER TOOLS
7.1.1 Respiratory Protection
All personnel entering the restricted area must wear, as a minimum, a half mask dust
respirator until paint or primer has been removed.
VALERO – KROTZ SPRINGS
SHG #51
Page 5 of 8
APPROVED 11/10/03
7.1.2 Protective Clothing
Full body protective clothing (e.g. Tyvek coveralls) must be worn over Nomex in the
restricted area. When decontaminating, disposable coveralls must be disposed of as
hazardous waste. The Safety Department may revise protective clothing requirements
after an evaluation of the size and scope of work.
7.1.3 Confined Space Work
Refer to section 8.4.
7.1.4 Containment of Job Site
Use containment sufficient to capture lead debris (i.e., tarps, full or partial enclosures,
etc.).
7.2
PAINT REMOVAL WITH CHEMICAL PAINT STRIPPER
7.2.1 Respiratory Protection
Refer to the chemical paint stripper MSDS
7.2.2 Protective Clothing
Standard PPE and chemical gloves with 12” cuff
7.2.3 Containment of Job Site
Use containment sufficient to capture lead debris (i.e., tarps, full or partial enclosures,
etc.).
7.3
BURNING, FLAME –TORCH CUTTING AND WELDING

Burning, cutting or welding on lead-containing surface coatings is not permitted.
Before these work activities are performed, the paint must be removed to bare
metal 6” in all directions by grinding, sanding or buffing the surface or use a with
power tools or using a chemical paint stripper in accordance to the previous
sections.

The Safety Department may approve exceptions to this requirement where
rigorous control measures are taken.
7.4
CONFINED SPACE POWERED TOOL PAINT REMOVAL
(PNEUMATIC CHIPPING, BUFFING, GRINDING, OR SANDING)
7.4.1 Respiratory Protection
Respiratory protection for confined space powered tool paint removal will vary
considerably (i.e. from half-face air purifying to SCBA respirators). Each job’s respirator
requirements must be reviewed with the Safety Department.
7.4.2 Protective Clothing
Full body protective clothing (e.g. Tyvek coveralls) must be worn over Nomex in the
restricted area. When decontaminating, disposable coveralls must be disposed of as
hazardous waste. The Safety Department may revise protective clothing requirements
after an evaluation of the size and scope of work.
VALERO – KROTZ SPRINGS
SHG #51
Page 6 of 8
APPROVED 11/10/03
7.4.3 Containment of Job Site
Use containment sufficient to capture lead debris (i.e., tarps, full or partial enclosures,
etc.).
7.5
HYDRO, VACUUM, AND WET ABRASIVE BLASTING, and CHEMICAL PAINT
STRIPPING
7.5.1 Respiratory Protection
May be required for protection from paint stripping chemicals. Consult the Safety
Department.
7.5.2 Protective Clothing
Hydroblasting will require protection from water spray. Rain gear or water impermeable
clothing will prevent lead contamination of clothing and will allow employees to remain
dry. Either rinse/decontaminate clothing or dispose of as hazardous waste. Appropriate
gloves should be worn while using chemical paint strippers.
7.5.3 Containment of Job Site
Wet abrasive and hydroblasting will require partial containment to capture the water and
debris. The lead debris must be disposed of in accordance with Environmental
Department requirements.
7.6
DRY ABRASIVE BLASTING
7.6.1 Respiratory Protection
The blasting operator must wear, as a minimum, a NIOSH approved Type CE abrasive
blasting hood covering the head, neck and shoulders. The hood must be connected to
an approved breathing air source meeting OSHA grade D air requirements.
7.6.2 Persons working in the vicinity of blasting operations must wear face and
eye protection in addition to an air-purifying respirator with HEPA filter.
7.6.3 Confined Space Blasting Work
If ventilation is not adequate, work within an enclosed area will require a supplied air
blasting hood that is “tight fitting” for increased protection. Other personnel must wear
the same respirator and PPE as the blast operator. Ventilation may be required to help
reduce airborne lead and dust within enclosures.
7.6.4 Protective Clothing
Full body protective clothing (e.g. Tyvek coveralls) must be worn over Nomex in the
restricted area. When decontaminating, disposable coveralls must be disposed of as
hazardous waste. The Safety Department may revise protective clothing requirements
after an evaluation of the size and scope of work.
7.6.5 Containment of Job Site
Containment must be sufficient to capture lead debris. Containment methods must be
reviewed and approved by the Safety Department.
VALERO – KROTZ SPRINGS
7.7
SHG #51
Page 7 of 8
APPROVED 11/10/03
MEDICAL SURVEILLANCE
7.7.1 This Medical Surveillance Program will incorporate employees that have
been or may be exposed above the action level for more than 30 days per year.
7.7.2 All medical examinations and procedures will be performed by or under
the supervision of a licensed physician.
7.8
Biological Monitoring
7.8.1 Blood lead and zinc protoporphyrin levels and analysis will be performed
at least every 6 months on any employee covered under the Medical Surveillance
Program.
7.8.2 Employees with prior blood sampling and analysis indicating a blood lead
level at 40 g/100g of whole blood will be tested at least every two months and continue
until two consecutive blood samples and analyses indicate a blood lead level below 40
g/100 g of whole blood.
7.8.3 Blood lead and ZPP levels will be tested on all employees removed from
exposure to lead due to an elevated blood lead level on a monthly basis during the
removal period.
7.9
Medical Examinations and Consultations
Medical examinations and consultations will be provided annually to each employee with
a blood lead level at or above 40 g/100 g of whole blood within the past 12 months.
7.10
Medical Removal
An employee with elevated blood lead levels will be removed from projects with potential
lead exposure in accordance with OSHA guidelines and physician consultation.
VALERO – KROTZ SPRINGS
SHG #51
Page 8 of 8
APPROVED 11/10/03
ATTACHMENT 1
AREAS CONTAINING PAINT AT OR ABOVE 0.06% LEAD BY DRY WEIGHT
Rail Rack
Dock 3
Dock 4
Complex I (All areas)
MTBE Fuel Gas Line (Yellow Paint)
Fire Water Line and Hydrants (Red Paint)