B.01 7N24R0001 TRGR Draft 100 Percent Specifications A24.pdf

Asbestos Survey Report The John Day Dam Powerhouse

Rufus, Oregon

Prepared for:

304 W 2nd, Rufus, OR 97050

Contract No. GS-10F-105BA Delivery Order No. W9127N22F0022

Prepared by:

13588 Florida Boulevard Baton Rouge, LA 70819

August 2022

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John Day Dam Powerhouse Rufus, Oregon

Concurrence and Approvals

Signature Sheet

Report Preparer:

Report Approver:

Deb Sartain________________08/22/2022_________________, QRI, LLC Deb Miller-Sartain, COSS Date Surveyor/SSHO

321.914.9394 (cell)

____________________________August 22, 2022___, QRI, LLC Laura Odenthal Date:

Project Manager

916.254.8608 (cell)

Report Concurrence:____________________________________________, ASHE, LLC David Jones Date:

CIH Consultant

757.262.7280 (cell)

QRI has been contracted to prepare the following Asbestos Survey Report to fulfill the requirements defined in the U.S. Army Corps of Engineers (USACE) Portland District, Contract Number: GS-10F-105BA, Delivery Order Number: W9127N-22-F-0022, entitled “John Day Hydropower Unit Asbestos Survey, Sherman County, Oregon.”

August 22, 2022

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Rufus, Oregon August 2022

Contract No. GS-10F-105BA Delivery Order No. W9127N22F0022

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TABLE OF CONTENTS

Signature Sheet

ABBREVIATIONS AND ACRONYMS

1.0 BACKGROUND INFORMATION AND SCOPE OF WORK

1.1 Date of Report Submittal

1.2 Survey Location

1.3 Survey Area Description

1.4 Report Writers and Reviewers

2.0 SURVEY LOCATION DESCRIPTION

2.1 Location Name

2.2 Type of Location

2.3 Special Features of Location

3.0 INSPECTOR FIRM/AFFILIATION/LAB INFORMATION

3.1 Inspector Name/Certification

3.2 Certified Industrial Hygienist Consultant Qualifications

3.3 Inspector Firm Information

3.4 Laboratory Name/Information

3.5 Transmission Electron Microscopy Method for Asbestos in Air

3.6 Polarized Light Microscopy Method for Bulk Asbestos Samples

4.0 SURVEY METHODOLOGY

4.1 Procedure Description

4.2 Inventory of Air Sampling Locations

4.3 Surfacing Materials

4.4 Thermal System Insulation

4.5 Miscellaneous Asbestos-Containing Material Areas

5.0 SAMPLE LOCATION DRAWING AND IDENTIFICATION

5.1 Digital Drawing

5.2 Sample Materials Tested

5.2.1 Thermal System Insulation

5.2.2 Surfacing Material ACM

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Contract No. GS-10F-105BA Delivery Order No. W9127N22F0022

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5.2.3 Miscellaneous ACM

5.2.4 Air Sampling

5.2.5 Materials found to be Non-ACM

5.3 Bulk Sample Results

5.4 Air Sample Results

6.0 ACM MANAGEMENT RECOMMENDATION

6.1 Abatement

6.2 Decision Tree Diagram/Response Action Key

6.3 Response Action Key

6.4 Response Action Level

6.5 Thermal System Insulation

6.6 Future Sampling

List of Appendices

Appendix A: Photos Appendix B: Daily Quality Control Reports Appendix C: Figures Appendix D: Laboratory Reports and Chain of Custody Documentation Appendix E: Certifications

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Contract No. GS-10F-105BA Delivery Order No. W9127N22F0022

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ABBREVIATIONS AND ACRONYMS

Abbreviation/Acronym Definition ACM Asbestos-Containing Material AED Automated External Defibrillator AHA Activity Hazard Analysis AHERA Asbestos Hazard Emergency Response Act CESCO Certified Environmental Safety and Compliance Officer CFR Code of Federal Regulations CIH Certified Industrial Hygienist cm Centimeter COSS Certified Occupational Safety Specialist CPR Cardiopulmonary Resuscitation CQM Construction Quality Management EMS Emergency Medical Services EMSL EMS Analytical, Inc.

EMT Emergency Medical Technician EPA U.S. Environmental Protection Agency HEPA High Efficiency Particulate Air LBP Lead-Based Paint LF Linear Feet OSHA Occupational Safety and Health Administration MCE Mixed-Cellulose Ester mm Millimeter NESHAP National Emission Standards for Hazardous Air Pollutants NVLAP National Voluntary Laboratory Accreditation Program PCM Phase Contrast Microscopy PLM Polarized Light Microscopy QRI Quaternary Resource Investigations, LLC TEM Transmission Electron Microscopy TSI Thermal System Insulation USACE U.S. Army Corps of Engineers

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1.0 BACKGROUND INFORMATION AND SCOPE OF WORK

Quaternary Resource Investigations, LLC (QRI) was contracted by the U.S. Army Corps of Engineers (USACE), Portland District, to perform a Hazardous Material Testing and Assessment at the John Day Dam Powerhouse at 304 W. 2nd, Rufus, Oregon 97050. QRI was awarded Delivery Order W9127N22F0022 under USACE Contract GS-10F-105BA. This report documents the absence and/or presence of asbestos-containing material (ACM) for four shut down hydropower units within the John Day Dam Powerhouse and within the breathable air within four operational hydropower units. The results of this survey provide a representative baseline regarding the hazardous nature and condition of the ACM that will require proper management by personnel conducting renovations on all 16 hydropower units within the Powerhouse. Non-destructive bulk samples were collected where possible from four hydropower units on maintenance shut down (units #7, #6, #10, and #11) and air samples were collected from hydropower units #8, #9, #1, and #3, respectively, while operational and two ambient background samples were collected from within the Powerhouse and outside the Powerhouse.

Asbestos has been used in a variety of applications and products to include thermal insulation for heating/cooling systems, as surfacing treatments and fireproofing, and miscellaneous applications such as gaskets, flooring, electrical insulation, roofing components, etc. On July 12, 1989, EPA issued a final rule banning most asbestos-containing products. In 1991, this regulation was overturned by the Fifth Circuit Court of Appeals in New Orleans. As a result of the Court's decision, the 1989 asbestos regulation only bans new uses of asbestos in products that would be initiated for the first time after 1989 and bans the following specific asbestos-containing products: flooring felt, rollboard, and corrugated, commercial, or specialty paper. In hydropower plants, asbestos was used as insulation for generators and turbines and sprayed on piping and conduits. By the mid-20th century, asbestos was used in fire-retardant coatings, concrete, bricks, pipes, gaskets, pipe insulation, ceiling insulation, fireproof drywall, flooring, and roofing. Asbestos may also be present in generator brakes and control cables.

Asbestos is a naturally occurring mineral which can form long, thin fibers. Inhalation of asbestos fibers can cause adverse health effects resulting in asbestosis, a scarring of the lung; and diseases including mesothelioma, a cancer of the lining of the chest or lining of the abdominal wall. Asbestos-containing materials can be categorized as nonfriable or friable.

Friable ACM can be crushed to powder by hand pressure while nonfriable material cannot be crushed by hand pressure. Fibers from friable ACM can be readily released to the air;

however, nonfriable ACM may also release fibers if damaged or disturbed.

All asbestos-related sampling activities conducted for this project followed the standards of the EPA (40 Code of Federal Regulations [CFR] Part 763, Subpart E), the National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart M, the National Emission Standard for Asbestos, and the Asbestos Hazard Emergency Response Act (AHERA) of 1986, Oregon state regulations; and applicable U.S. Army regulations and guidance.

Regulation of asbestos exposure in the occupational setting is the responsibility of the Occupational Safety and Health Administration (OSHA).

This asbestos survey was conducted on July 26-28, 2022, in a manner consistent with the level of care and skill ordinarily exercised by members of the profession. The results, findings, A24-6 t 1

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1.1 Date of Report Submittal

This report has been prepared in August 2022 on behalf of and exclusively for use by USACE for specific application of the assigned Delivery Order. For this project, QRI also provided USACE with the following reports: Asbestos Survey Plan (June 2022), Abbreviated Accident Prevention Plan, Revision 1 (June 2022), Environmental Protection Plan (June 2022), Quality Control Plan (May 2022), and Quality Control reports after completion of each onsite workday.

1.2 Survey Location

The project site is located at John Day Dam in Sherman County, Oregon. It is 216 miles upstream from the mouth of the Columbia River near the city of Rufus, Oregon. Access to the work site is from I-84 Exit 109.

1.3 Survey Area Description

The survey was conducted at four of the 16 hydropower units within the John Day Dam Powerhouse that were shut down for maintenance and four operating hydropower units for the air sample collection. The table below lists the units surveyed and used for the collection of the bulk and air samples.

Unit # Sample Type # Of Samples Collected 7 Bulk 10

6 Bulk 9

10 Bulk 7

11 Bulk 7

8 Air 3

9 Air 3

1 Air 3

3 Air 3 Note: Ambient interior and exterior background air samples were also collected and are not represented in this table.

Table 1, Units surveyed and nature of samples obtained

1.4 Report Writers and Reviewers

This survey report was written by the QRI surveyor Ms. Deb Miller-Sartain and reviewed by the QRI Project Manager, Ms. Laura Odenthal, PG, PMP, and concurred by Mr. David Jones, Certified Industrial Hygienist (CIH).

2.0 SURVEY LOCATION DESCRIPTION

The John Day Dam is 219 feet (67 meters) high and 5,640 feet (1,719 meters) long, located on the Columbia River between Oregon and Washington, and is a concrete gravity run-of-the-river dam spanning the Columbia River in the northwestern United States.

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2.1 Location Name

John Jay Dam Powerhouse, Sherman County, OR.

2.2 Type of Location

Hydroelectric power plant with 16 hydropower units.

2.3 Special Features of Location

The John Jay Dam Powerhouse complex consists of a navigation lock, spillway, Powerhouse, and features fish ladders on both sides. The lock has the highest lift (110 feet) of any U.S.

lock. The reservoir impounded by the dam is Lake Umatilla, which runs 76.4 miles up the river channel to the foot of the McNary Dam. John Day Dam is part of the Columbia River Basin system of dams. It is an extremely large generator of hydroelectric power. The dam’s reservoir regulates navigation upstream; locks provide ship passage from the Dalles Dam reservoir to McNary Dam.

3.0 INSPECTOR FIRM/AFFILIATION/LAB INFORMATION

3.1 Inspector Name/Certification

Ms. Miller-Sartain has served as an Asbestos Inspector/Project Manager, Asbestos/Lead/Mold Inspection/Supervisor, Site Safety and Health Officer, since 2007, and also holds a Construction Quality Management (CQM) certification. She has 25 years of relevant experience and has managed numerous USACE projects where she conducted inspections, sampling, and remediation in accordance with EPA and OSHA regulations.

Ms. Miller-Sartain has 15 years of experience in asbestos/lead-based paint (LBP)/mold assessment and remediation; Phase I and Phase II environmental site assessments;

environmental field services including debris removal; drilling and geophysical tools; hazard assessments and remediation; emergency response; quality control documentation and safety and health management.

Active licenses and certifications include:

• Certified Occupational Safety Specialist (COSS), #32507046

• Certified Environmental Safety and Compliance Officer (CESCO), Cert.

#857680052

• CQM for Contractors (Course No. 784, Rev. 2004; update 05-2018)

• Utah Asbestos Inspector #ASB-7437, expires 04/22/23

• OSHA 30-hour Course in Occupational Health and Safety for the Construction

Industry (29 CFR 1926)

3.2 Certified Industrial Hygienist Consultant Qualifications

David Jones is a CIH and has been a practicing CIH with over 30 years of successful management of diverse environmental compliance, industrial hygiene, and occupational safety and environmental health programs both in the government and civilian sectors. He has comprehensive experience in biosafety, hazardous waste management, and industrial hygiene, including conducting industrial hygiene surveys, authoring site-specific health and safety plans, responding to OSHA citations, previous management oversight of two Resource Conservation and Recovery Act 90-day hazardous waste storage facilities and one small quantity generator site, occupational health surveys, and exposure monitoring in both

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Mr. Jones has an MBA, MS in Food Technology, and BA in Zoology. He possesses CIH Certificate #7761 (expires on 06/01/2024), American Board of Industrial Hygiene and Certified Hazardous Materials Manager (Master’s Level), Certificate #13018 (exp 02/28/26), Institute of Hazardous Materials Management.

Mr. Jones is not an employee of QRI LLC and will fulfill the role of certified 3rd party industrial hygienist as specified in paragraph 7.6.6 of the Performance Work Statement.

3.3 Inspector Firm Information

Established in 1986, QRI is a Woman-Owned Small Business headquartered in Baton Rouge, Louisiana. Over the past 35 years, QRI has grown through acquisition and the expansion of services to government and commercial clients, as well as the petrochemical and oil and gas industry. QRI provides environmental consulting, geophysical assessments, environmental remediation, emergency response, and construction services. Through various commercial and federal contracts, QRI has established its reputation as a premier provider of asbestos, LBP, and mold investigations and remediation. QRI headquarters is located at 113588 Florida Boulevard, Baton Rouge, 70819, telephone: 225.292.1400.

3.4 Laboratory Name/Information

EMSL Analytical, Inc. (EMSL), located in San Leandro, California, was the laboratory used for asbestos sample analysis. EMSL is accredited through the National Voluntary Laboratory Accreditation Program (NVLAP) for asbestos analysis. The figure below shows the qualifications and accreditations of the laboratory.

Figure 1, EMSL Laboratory Accreditation Information

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3.5 Transmission Electron Microscopy Method for Asbestos in Air Transmission electron microscopy (TEM) technology was used for the analysis of the samples in this project due to the need for accuracy and because the area where the samples were collected are within an operational air housing where ACM is known to exist. The phase contrast microscopy (PCM) method of analysis can count fibers but cannot positively identify the fibers as asbestos. Using PCM analysis, fibers of a certain width to length ratio are assumed to be asbestos fibers and counted accordingly. In comparison, TEM sampling methods use a higher magnification, thereby allowing smaller fibers to be detected and this allows the technician to positively differentiate between an asbestos fiber or a non-asbestos fiber with less chance of false positive results.

TEM analysis requires the collection of airborne fibers using calibrated sampling pumps with mixed-cellulose ester (MCE) filters and analysis by TEM. A known volume of air is drawn through a 25-millimeter (mm) diameter cassette containing an MCE filter. The cassette is equipped with an electrically conductive 50-mm extension cowl. The sampling time and rate are chosen to give a fiber density of between 100 fibers/mm2 to 1,300 fibers/mm2 on the filter.

A portion of the sample fiber is cleared and prepared for asbestos fiber counting by PCM at a magnification of 400X for accuracy.

3.6 Polarized Light Microscopy Method for Bulk Asbestos Samples

Polarized light microscopy (PLM) is the technique most often employed for the analysis of bulk building materials. This light microscopy technique utilizes the unique features of polarized light to observe mineral-specific optical properties. In this manner, PLM can differentiate asbestos from non-asbestos fibers and further classify the various species that compose the asbestos mineral family. Moreover, the technique records the identity of the non-asbestos fibrous component of each bulk building material sample.

Point counting will be employed to more accurately determine the percent of asbestos that is in the material being sampled if fibers are present and the results are inconclusive.

Additionally, samples analyzed via PLM frequently are determined to contain “trace” amounts of asbestos usually written as <1% asbestos. Any sample determined to contain <1% asbestos must be point counted to prove it contains less than 1% asbestos otherwise, it assumed to be positive regardless of the PLM results.

Typical materials that are candidates for point count analysis include drywall-joint compound, ceiling or wall texture, hard plaster, etc. The main purpose to point count material is to determine if a material contains less than 1% asbestos since materials containing ≤1% are by definition “non-asbestos containing.” If point counting is not used, many materials could be mistakenly considered to contain >1% asbestos thus meeting the definition of an asbestos-containing material. This mistaken assumption could lead to an expensive asbestos management or remediation projects that could otherwise be avoided.

With the point count procedure, for each layer of material to be point counted, eight mounts are made by dispersing eight pinches of a sample in a suitable fluid. A reticule is placed on the eyepiece of the microscope that superimposes a grid of points over the field of view. Fifty non-empty points are examined for each mount yielding 400 points, some of which would be identified as asbestos and the rest as non-asbestos material. A simple calculation gives the percentage of asbestos; four points in 400 would be 1%.

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4.0 SURVEY METHODOLOGY

QRI conducted a representative asbestos survey on four of the 16 Powerhouse hydropower units within the John Day Dam complex which were shut down for maintenance. Utilizing non-destructive methods, representative samples of suspect material were collected homogeneous areas, documented for location, quantity, and condition; and submitted to an accredited laboratory for analysis.

4.1 Procedure Description

The sampling protocol employed for this project was consistent with the sampling protocol contained in 40 CFR 763. The following describes the bulk and air sampling activities conducted at the John Day Dam Powerhouse from July 26-28, 2022:

• Conducted an initial pre-work safety briefing with the John Day Dam personnel and USACE team prior to the first day of work and conducted daily tailgate safety briefings.;

• Obtained from John Day personnel the list of four generators identified for asbestos inspection and sampling and the four generators identified for air sampling;

• Conducted a visual inspection of the generators slated for surveying and testing to identify homogenous areas of friable and nonfriable suspect ACM;

• Assumed and documented inaccessible areas of suspect ACM;

• Assessed location, quantity, and condition of friable and nonfriable suspect ACM;

• Determined area airflow, dust-laden areas, calibrated and set up air sampling pumps to conduct air monitoring;

• Decontaminated sampling instruments between samples;

• Utilized nitrile gloves during sampling. Gloves were changed between samples to avoid cross-contamination and were disposed of as contaminated waste;

• Double bagged and sealed samples in accordance with AHERA/OSHA requirements.

Samples were sent for ACM analysis to the 3rd party testing facility (EMSL) approved by the NVLAP;

• Requested five-day turnaround for analytic results; and

• Prepared final report showing sample locations, type, (thermal, miscellaneous, surfacing; friable, and nonfriable), locations, and quantity of ACM, date of collection, photos, and map of positive ACM locations.

Bulk sampling was conducted as follows:

• Determined homogeneous areas of suspect material for sampling;

• Used a clean and dry, small sealable sample bag to contain the sample;

• Before taking the bulk sample, the material to be sampled was wetted with a fine mist of water containing a few drops of detergent to minimize the potential release of asbestos fibers. Additionally, a plastic sheet was placed under the sample site to catch any material which may fall;

• A clean knife or T-Core sampling device was used to remove a small piece of material about two square inches and placed in a labeled zip-lock bag;

• Ensured any paint or other protective coating was penetrated and ensured all layers of the material down to the base substrate were sampled;

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• The sample bag was sealed, and exterior wiped with a damp paper towel to remove any material which may have adhered to the bag during sampling. Paper towels used for this purpose were disposed of as contaminated waste;

• For pipe/boiler/duct insulation samples, the location from which the sample was taken was patched by carefully applying a generous amount of caulk to seal the knife or T- Core sample tool hole;

• The plastic sheet was misted with water and carefully folded and the work area cleaned using a damp paper towel or disposable cloth. Note: the area was not HEPA vacuumed. Asbestos bulk sampling waste, including gloves, and wipe clothes, were sealed in a plastic bag and disposed of as contaminated waste in accordance with John Day Dam procedures; and

• The sample bags were labeled, identifying the feature (i.e., generator, the date the sample was taken, the specific location of the sample in the room or structure, and who collected the sample).

Air sampling was conducted as follows:

• An appropriate sample air flow rate for the situation being monitored was selected. The air sampling flow rate was set to 20 liters per minute since the area being sampled was reasonably clean with no visible dust and workplace signage indicated known ACM was well contained and maintained where air samples were collected. The flow rate was chosen to avoid overloaded filters;

• Each sampling pump was calibrated to a secondary standard which was previously calibrated against a primary standard before and after sampling with a calibration cassette in-line (Note: This calibration cassette is from the same lot of cassettes used for sampling using a rotameter to calibrate each pump). Sampling pumps were calibrated at the sampling site prior to and after air sample collection each day to ensure validity of reported sample volume;

• Sampling pumps were connected to the cassette via flexible tubing. At the beginning of sampling, the end cap of the cassette was removed to collect air samples at the open face of the cassette. The surveyor ensured that each sample cassette was secured on a stand at breathing zone level prior to beginning sampling;

• A suggested minimum air flow rate when sampling to determine time-weighted average compliance is 20-25 liters per minute with a minimum collection volume of 1,200-1,800 liters;

• Sample volumes used during air monitoring at this project are as follows:

Environment Volume (Liters) Units #8, #9, #1, and #3 inside air housing on south, west, and northeast sides of round room 1,200

Indoor background sample outside west side of Unit #7 1,200

Outdoor background sample by main entrance bay door east side 1,200

Table 2, Air sample volumes by location

• Two field blanks were used to determine if any contamination occurred during sample

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• Immediately after sampling, each cassette was closed and sealed with the base and plastic plugs while not touching nor puncturing the filter membrane; and

• Cassettes were then sealed in sample bags containing the appropriate sample identification information.

4.2 Inventory of Air Sampling Locations

Generator Number Type of Sample Number of Samples

8 Air 3

9 Air 3

1 Air 3

3 Air 3

Baseline indoors Air 1

Baseline outdoors Air 1 Table 3, Air sample location and quantity

4.3 Surfacing Materials

Surfacing ACM means surfacing material which contains > 1% asbestos. Surfacing material is typically sprayed on, troweled-on, or otherwise applied to surfaces (such as acoustical plaster on ceilings, fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes). Surfacing material was not found in the John Day Dam Hydropower Units surveyed for this project; therefore, no bulk samples were collected in this category.

4.4 Thermal System Insulation

Thermal system insulation (TSI) is commonly applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain. Thermal system insulation ACM means thermal system insulation which contains more than 1% asbestos.

The QRI asbestos inspector collected samples from areas of suspect TSI ACM and mudded fittings according to AHERA/OSHA protocols as follows:

• A minimum of three samples from each homogeneous area of TSI were collected from the cooling water lines in each unit surveyed for this project.

• Samples were collected in a manner sufficient to determine if a homogeneous area of mudded joints contained asbestos or not. Four to five samples were collected from each mechanical system cooling line. Three samples were collected from the main and flexible leads of Unit #7 by removing material that had delaminated from the copper leads.

The QRI asbestos surveyor collected samples of areas of suspected TSI and mudded fittings according to AHERA/OSHA protocols as follows. The table below provides an inventory of bulk samples collected.

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Sample Area Hydropower Unit #7

Hydropower Unit #6

Hydropower Unit #10

Hydropower Unit #11

Main and flexible leads 3 bulk samples 0 samples 0 samples 0 samples

Cooling line insulation and mudded joints

4 bulk samples 4 bulk samples 5 bulk samples 4 bulk samples

Note: Asbestos-containing insulation around electrical wiring is known to exist within the conduit in the air housing. All sampling was conducted on a non-destructive basis.

Table 4, Inventory of quantity and location of TSI bulk samples taken

4.5 Miscellaneous Asbestos-Containing Material Areas

QRI followed AHERA/OSHA requirements for miscellaneous areas where ACM was suspected to be present. This category generally encompasses floor and ceiling tiles, integral building members, and structural components or fixtures. Areas of miscellaneous ACM (primarily gaskets) were sampled in a manner sufficient to determine the homogeneous area of the material or to collect a minimum of three samples per type of material.

Sample Area Hydropower Unit #7

Hydropower Unit #6

Hydropower Unit #10

Hydropower Unit #11

Generator 1 bulk sample of felt and dust

1 bulk sample of felt and dust

1 bulk sample of felt and dust

1 bulk sample of felt and dust

Gaskets 2 bulk samples 4 bulk samples 1 bulk sample 2 bulk samples Table 5, Inventory of quantity and location of Miscellaneous bulk samples taken

5.0 SAMPLE LOCATION DRAWING AND IDENTIFICATION

5.1 Digital Drawing

Drawings detailing sample locations are provided in Appendix C.

5.2 Sample Materials Tested

5.2.1 Thermal System Insulation

This category encompasses insulation applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain. Visual inspection and physical sampling indicated that the cooling line white insulation contains between 10-20% chrysotile. The sample results are shown in Appendix D.

5.2.2 Surfacing Material ACM

This category includes materials sprayed or troweled onto walls, ceilings, and structural building members such as decorative and acoustic textures and sprayed-on fireproofing.

Visual inspection determined that surfacing material no longer exists within the hydropower units. No samples were collected in this category.

5.2.3 Miscellaneous ACM

This category encompasses floor and ceiling tiles, integral building members and structural components or fixtures. The John Day Dam Hydropower Units contain generators and gaskets which were sampled as suspect ACM. Visual inspection and confirmatory testing determined that the gaskets, generator brake dust, and felt have been remediated on the four units surveyed. Asbestos-containing gaskets, generator dust, and felt should still be assumed

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5.2.4 Air Sampling

Fourteen air samples were collected to determine if airborne asbestos fibers exist in the air housing. Survey results available at the facility indicate that the air housing area contains known ACM in the form of nose gaskets, stator coils, 13.86-kilovolt bus black insulation below the air housing, black wrap over fibrous insulated electrical lines within the conduit inside the air housing, and white insulation within the cooling line wrap above the air housing. Twelve asbestos-containing heaters remain under units #7, 10, and 11. New heaters were installed in unit #6. Air samples collected at specified locations were found to be below the limit of detection for airborne asbestos fibers.

5.2.5 Materials found to be Non-ACM

Miscellaneous materials suspected to contain asbestos were sampled at the designated locations. Of the sampled material, the following materials tested negative for asbestos: all accessible gaskets, generator dust, and felt.

5.3 Bulk Sample Results

Generator #7 Bulk Sample Results (PLM)

Sample Date Material Type Tested Location Quantity Functional Space Sample

ID # Analytical Results

07/26/2022 Generator brake dust/felt

Generator brake dust and felt NA Generator Room B1 7 Non-detect

07/26/2022 Cooling water lines pipe lag, mud

Cooling water lines leading into

Generator Room 10 LF* Generator Room B2 7 Non-detect

07/26/2022 Cooling water lines pipe lag, mud

Cooling water lines leading into

Generator Room 10 LF Generator Room B3 7 Non-detect

07/26/2022 Cooling water lines pipe lag, mud

Cooling water lines leading into

Generator Room 10 LF Generator Room B4 7

White insulation- 15% chrysotile

Mastic and wrap Non-detect

07/26/2022 Cooling water lines pipe lag, mud Cooling water lines 10 LF Generator Room B5 7 Non-detect

07/26/2022 Gasket Gasket under conduit lines in air housing 2 Air Housing B6 7 Non-detect

07/26/2022 Gasket Turbine gasket 1 Turbine Pit B7 7A Non-detect

07/26/2022 Main leads Under the deck plates of Unit #7

Area inaccessible

Main leads under the deck plates of

Unit #7 B8 7B Non-detect

07/26/2022 Main leads Under the deck plates of Unit #7 1 Main leads under the deck plates of

Unit #7 B9 7C Non-detect

07/26/2022 Main flexible lead

Under the deck plates of Unit #7 4 LF

Flexible main lead connectors under the deck plate B10 7 Non-detect

* “LF” refers to linear feet

Table 6, Generator 7 bulk sample results by PLM

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Generator #6 Bulk Sample Results (PLM) Sample

Date Material Type

Tested Location Quantity Functional Space

Sample

ID #

Analytical Results

07/26/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B1 6

Insulation 15% chrysotile

Mastic and wrap

Non-detect

07/26/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B2 6

White Insulation 15% chrysotile

Mastic and wrap

Non-detect

07/26/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B3 6

White Insulation 20% chrysotile

Tan insulation mastic and wrap

Non-detect

07/26/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B4 6

White insulation 15% chrysotile

Mastic and wrap

Non-detect

07/26/2022 Generator brake dust and felt

Generator Room NA Generator Room B5 6 Non-detect

07/26/2022 Gasket Small Turbine pit gasket 1 Turbine Pit B6 6 Non-detect

07/26/2022 Gasket Large Turbine gasket 1 Turbine Pit B7 6 Non-detect

07/26/2022 Gasket Gasket on west side of Air Housing

1 Air Housing B8 6 Non-detect

07/26/2022 Gaskets Gaskets under conduit in air housing 2 Air Housing B9 6 Non-detect

* These four samples were collected from different portions of the same 10 LF run of insulation Table 7, Generator 6 bulk sample results by PLM

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Generator #10 Bulk Sample Results (PLM)

Sample Date

Material Type Tested Location Quantity Functional

Space Sample

ID #

Analytical Results

07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B1 10

White insulation 15% chrysotile

Mastic and wrap Non-detect

07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B2 10

White insulation 15% chrysotile

Mastic and wrap Non-detect

07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B3 10

Insulation 15% chrysotile

Mastic and wrap Non-detect

07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator Room 10 LF* Generator

Room B4 10

Insulation 15% chrysotile

Mastic and wrap Non-detect

07/27/2022 Green cooling water straight lines

Leading into Generator Room 10 LF Generator

Room B5 10 Non-detect

07/27/2022 Generator brake dust and felt

Generator Room NA Generator Room B6 10 Non-detect

07/27/2022 Gasket Gaskets under conduit in air housing 2 Air Housing B7 10 Non-detect

* These four samples were collected from different portions of the same 10 LF run of insulation Table 8, Generator 10 bulk sample results by PLM

Generator #11 Bulk Sample Results (PLM) Sample

Date Material Type

Tested Location Quantity Functional Space

Sample

ID #

Analytical Results

07/27/2022 Cooling water green straight lines

Leading into Generator

Room 10 LF* Generator Room B1 11

Wrap and insulation

Non-detect

07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator

Room 10 LF* Generator Room B2 11

Brown insulation 10% chrysotile

Yellow insulation, mastic and wrap

Non-detect

07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator

Room 10 LF* Generator Room B3 11

White insulation 15% chrysotile

Mastic and wrap Non-detect

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07/27/2022 Cooling water lines pipe lag, mud

Leading into Generator

Room 10 LF* Generator Room B4 11

Insulation- 15% Chrysotile

Mastic and Wrap- Non-detect

07/27/2022 Generator brake dust and felt

Generator Room NA Generator Room B5 11 Non-detect

07/27/2022 Gasket Gasket top of generator area 1 Generator Room B6 11 Non-detect

07/27/2022 Gasket Gaskets under conduit in air housing 2 Air Housing B7 11 Non-detect

* These four samples were collected from different portions of the same 10 LF run of insulation Table 9, Generator 11 bulk sample results by PLM

5.4 Air Sample Results

Sample Date

Sample ID Sample Location Volume (liters)

Fiber Concentration

(S/cc)

07/26/2022 A1 B7 Baseline indoors east side of hydropower facility by Unit #7

1,200 <0.0045

07/ 26/2022 A2 BO Baseline outdoors west side of bay door outside main entry

1,200 <0.0045

07/27/2022 A39 NE Generator #9 NE side 1,200 <0.0045

07/27/2022 A49 W Generator #9 west side 1,200 <0.0045

07/27/2022 A59 S Generator #9 south side 1,200 <0.0045

07/27/2022 A68 S Generator #8 south side 1,200 <0.0045

07/27/2022 A78 W Generator #8 west side 1,200 <0.0045

07/27/2022 A88 NE Generator #8 NE side 1,200 <0.0045

07/28/2022 A91 NE Generator #1 NE side 1,200 <0.0045

07/28/2022 A101 W Generator #1 west side 1,200 <0.0045

07/28/2022 A111 S Generator #1 south side 1,200 <0.0045

07/28/2022 A123 NE Generator #3 NE side 1,200 <0.0045

07/28/2022 A133 W Generator #3 west side 1,200 <0.0045

07/28/2022 A143 S Generator #3 south side 1,200 <0.0045 Note: S/cc = structures per cubic centimeter

Table 10, Air sample location and results

6.0 ACM MANAGEMENT RECOMMENDATION

6.1 Abatement

As a result of the survey, the presence of asbestos was documented for several types of materials. The physical assessments and the appropriate EPA/AHERA Decision Tree/Response Action Key for these materials are summarized below.

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6.2 Decision Tree Diagram/Response Action Key

Figure 2, Decision Tree Diagram/Response Action Key

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6.3 Response Action Key

Response Actions

Response Action 1 Isolate area and restrict access. Remove as soon as possible.

Response Action 2 Continue operation and maintenance.

Remove as soon as possible or reduce potential for disturbance.

Response Action 3 Continue operation and maintenance.

Schedule removal when practical or cost effective or reduce disturbance.

Response Actions 4, 5 Continue operation and maintenance.

Schedule removal when practical or cost effective. Number indicates priority for removal (4 before 5).

Response Actions 6, 7 Continue operation and maintenance. Take preventive measures to reduce disturbance.

Number indicates priority for removal (6 before 7).

Response Action 8 Continue operation and maintenance until major renovation or demolition requires removal under NESHAP or until hazard assessment factors change.

6.4 Response Action Level

Recommended asbestos management response action based upon this survey:

Response Action # Action Plan Priority

7 Low

As a result of the survey, the presence of asbestos was documented in cooling water line white insulation near the generator and brown insulation on the cooling water line of Unit 11.

Site personnel confirmed that several types of materials had been previously identified as asbestos-containing including electrical wiring insulation within conduit, heaters below some of the units, and insulating compound around the 13.86-kilovolt bus. These items were already posted with asbestos warning signs.

Further recommend that areas confirmed by this report to contain asbestos be posted with warning labels worded as specified in 40 CFR 763:

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“CAUTION: ASBESTOS

HAZARDOUS

DO NOT DISTURB WITHOUT PROPER TRAINING AND EQUIPMENT”

6.5 Thermal System Insulation

This ACM is friable, has no visible damage, and low potential for disturbance.

Material Type Location Quantity Functional Space

Cooling water line white insulation (10-20% chrysotile)

Units #7, #6, #10, and #11 40 LF total Generator room

6.6 Future Sampling

Known ACM exists above, within, and under the air housing of the John Day Dam Hydropower Units in the form of electrical wiring insulation within conduit, heaters below some of the units, cooling line white insulation near the generator, and insulating compound around the 13.86-kilovolt bus.

ACM observed in accessible areas appeared to be in good condition, well contained, and maintained. During maintenance shutdowns of each unit, areas may be opened up exposing suspect ACM. Any suspect ACM should be tested prior to being disturbed or maintained.

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APPENDIX A

PHOTOGRAPHS

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A-1

Unit 7 Cooling Lines

Figure 3, Unit 7 Cooling Lines, Samples B5 7, B2 7, B3 7, and B4 7

Samples B5 7, Sample B2 7, and Sample B3 7 tested negative for asbestos.

Sample B4 7 contained 15% chrysotile asbestos in the white insulation material.

The green pipe insulation in the foreground has been remediated and tested negative for asbestos. The rear-most cooling line in this photograph (Sample B4 7) has not been remediated and contains the white insulation mentioned in this report. Wrap and mud tested negative for asbestos. The cooling lines on all units are near the bottom section of the generator on one side of the bushing area and if not tested should be suspect.

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A-2

UNIT 7 Main Leads

Figure 4, Unit 7 Main Leads, Samples B7 7 Figure 5, Unit 7 Main Leads, Sample B8 7

The main leads shown in Figures 4 and 5, above, tested negative for asbestos.

Figure 6, Unit 7, Sample B10 7 C, flexible main leads under deck plates

The flexible main leads under the deck plates shown in Figure 6, above, tested negative for asbestos.

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A-3

Generator Unit 6

Figure 7, Generator Unit 6, Sample B1 6, white pipe insulation

Figure 8, Generator Unit 6, Samples B2 6 and B3 6, white pipe insulation

Sample B1 6 (Figure 7, above) contained 15% chrysotile asbestos, samples B2 6 and B3 6 (shown in Figure 8, above) contained 15% and 20% chrysotile asbestos, respectively, in the white pipe insulation.

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Figure 9, Generator Unit 6, Sample B4 6, white pipe insulation

Sample B4 6 (Figure 9, above) contained 15% chrysotile asbestos in the white insulation.

Figure 10, Generator Unit 6, Sample B5 6, brake dust/felt

Sample B5 6 (Figure 10, above) brake dust/felt tested negative for asbestos in Unit #6.

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A-5

Figure 11, Generator Unit 6, Sample B6 6, Figure 12, Generator Unit 6, Sample B7 6, Large turbine gasket Turbine pit gasket

Sample B6 6 (Figure 11, above) tested negative for asbestos. Sample B7 6 (Figure 12, above) tested negative for asbestos.

Figure 13, Generator Unit 6, Sample B8 6, Figure 14, Generator Unit 6, Sample B9 6, Gaskets under conduit in air housing Gasket in north side of air housing

Gasket materials shown in Figures 13 and 14, above, tested negative for asbestos.

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A-6

Generator Unit 10 Cooling Water Lines

Figure 15, Generator Unit 10, Cooling Figure 16, Generator Unit 10, Cooling, Water Lines, Sample B1 10 Water Lines Sample, B3 10

Sample B1 10 (Figure 15, above) contained 10-15% chrysotile asbestos in the white insulation.

Sample B3 10 (Figure 16, above) contained 10-15% chrysotile asbestos in the white insulation.

Figure 17, Generator Unit 10, Cooling Water Lines, Sample B2 10, located in the horizontal straight above the vertical straight The brown insulation shown in Figure 17, above (Sample B2 10) contains 10% chrysotile

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A-7

Figure 18, Generator Unit 10, Cooling Water Lines, Sample B4 10, white insulation

White insulation shown in Figure 18, above, (Sample B4 10) contains 15% chrysotile asbestos in the white insulation.

Figure 19, Generator Unit 10, Cooling Water Lines, Sample B5 10, green cooling water line

The green straight cooling water line insulation shown in Figure 19, above, tested negative for

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A-8

Figure 20, Generator Unit 10, Sample B6 10, generator dust and felt

Generator dust and felt collected from the bushing area from below and on the top of the generator as Sample B6 10 (Figure 20, above) tested negative for asbestos.

Figure 21, Generator Unit 10, Sample B7 10, gaskets in air housing below the conduit area

Gasket material from Sample B7 10 (Figure 21, above) tested negative for asbestos.

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A-9

Generator Unit #11 Cooling Water Lines

Figure 22, Generator Unit 11, Cooling Figure 23, Generator Unit 11, Cooling Water Lines, Sample B1 11, green straights Water Lines, Sample B2 11, white insulation

Sample B1 11, green straights (Figure 22, above) tested negative for asbestos. Sample B2 11, white insulation (Figure 23, above), contains 10% chrysotile asbestos.

Figure 24, , Generator Unit 11, Cooling Water Lines, Samples B3 11 and B4 11, white insulation

Samples B3 11 and B4 11 (Figure 24, above) contain 15% chrysotile asbestos in the white insulation.

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A-10

Figure 25, Generator Unit 11, Cooling Water Figure 26,, Generator Unit 11, Cooling Water Lines, Lines, Sample B5 11, generator dust and felt Sample B6 11, gasket from outside the generator tower

Sample B5 11 (Figure 25, above), generator dust and felt tested negative for asbestos. Sample B6 11 (Figure 26, above) gasket material from the top of the generator tower tested negative for

Figure 27, Generator Unit 11, Cooling Water Lines, Sample B7 11, gaskets under the conduit in the air housing

Sample B7 11, (Figure 27, above), gasket material under the conduit in the air housing tested negative for asbestos.

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A-11

Air Monitoring

Figure 28, Sample A14 3S: Air Sample by the south door in Unit #3.

Figure 29, Inside the NE corner of the air housing where air samples were collected

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A-12

Asbestos-Containing Materials

Cooling water lines were found to contain chrysotile asbestos at concentrations between 15-20% in the white insulation as well as in the brown insulation in Unit #11 (Figure 17, above). Asbestos can be assumed to exist in the cooling water lines in all units and any brown insulation not previously tested. The green wrapped lines have been remediated and were not found to contain asbestos in any of the units surveyed.

Potential Asbestos-Containing Materials

The electrical wiring within the metal conduit lines in the air housing, as well as throughout the hydroelectric units, may contain asbestos black wrap over asbestos fibrous asbestos insulation within the conduit.

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A-13

Heaters under the air housing connected to the electrical wiring within the conduit may contain asbestos in some of the units where they have not been changed out. This area was inaccessible and materials should be assumed to contain asbestos unless surveyed and found not to contain

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A-14

Numerous gaskets exist throughout the units. All accessible gaskets sampled during this survey were found negative for asbestos. Some asbestos-containing gaskets, such as the bull nose gaskets at the base of the cone area, not easily accessible still exist in some units.

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APPENDIX B

DAILY QUALITY CONTROL REPORTS

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B-1

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B-2

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B-3

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B-4

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B-5

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B-6

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APPENDIX C

FIGURES

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C-1

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C-2

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C-3

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C-4

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APPENDIX D

LABORATORY REPORTS AND

CHAIN OF CUSTODY DOCUMENTATION

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D-1

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D-2

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D-3

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D-4

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D-5

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D-6

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D-7

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D-8

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D-9

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D-10

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APPENDIX E

CERTIFICATIONS

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E-1

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E-2

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E-3

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E-4

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E-5

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TRANSMITTAL OF SHOP DRAWINGS, EQUIPMENT DATA, MATERIAL SAMPLES, OR

MANUFACTURER'S CERTIFICATES OF COMPLIANCE

For use of this form, see ER 415-1-0; the proponent agency is CECW-CE

SECTION I - REQUEST FOR APPROVAL OF THE FOLLOWING ITEMS (This section will be initiated by the contractor)

TO: FROM: CONTRACT NO. THIS IS A:

PROJECT TITLE AND LOCATIONSPECIFICATION SEC. NO. (Cover only one section with each transmittal) THIS TRANSMITTAL IS FOR: (Check one)

DATE TRANSMITTAL NO.

NEW TRANSMITTAL

3/18/2019 01 35 26.00 25-9

JD MU 6 Generator Repair, John Day Lock & Dam01 35 26.00 25-SD-01 Preconstruction Submittals & SD-06 Test Reports & SD-07 Certificates

W9127N18C0083

VANCOUVER RESIDENT OFFICE

4480 SE COLUMBIA WAY

VANCOUVER, WA 98661-5570

National Electric Coil Co., L.P.

3330 East 14th Street Brownsville TX78521-3232

FIO GA DA CR DA/CR DA/GA S

ITEM NO.

(See Note

3) a.

DESCRIPTION OF SUBMITTAL ITEM

(Type size, model number/etc) b.

SUBMITTAL TYPE CODE

(See Note 8) c.

NO. OF

COPIES

d.

CONTRACT REFERENCE

DOCUMENT

SPEC. PARA

NO.

e.

DRAWING

SHEET NO.

f.

FOR

CONTRACTOR

USE

g.

VARIATION

(See

Instruction No.

6) h.

FOR CE USE

CODE

(Note 9) i.

31 Asbestos and Lead Testing Results 06 - TEST REPORTS 0 A No Remarks from Contractor

ENCLOSURES RETURNED (List by item No.) DATE

SECTION II - APPROVAL ACTION

NAME, TITLE AND SIGNATURE OF APPROVING AUTHORITY

I certify that the above submitted items have been reviewed in detail and are correct and in the strict conformance with the contract drawings and specifications except as otherwise stated.

NAME AND SIGNATURE OF CONTRACTOR

ENG FORM 4025-R, JUL 2015 REPLACES EDITION OF MAR 2012, WHICH IS OBSOLETEPage 1 of 1 smcmahon@national-electric-coil.com

2019.03.18 17:01 Steve McMahon; Sr.

Project Manager, Nationla Electric Coil

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NATIONAL ELECTRIC COIL

Submittal Description

Asbestos and Lead Testing Results Section 01 35 26.00 25-31

Paragraph: None

CORPS OF ENGINEERS

JOHN DAY UNIT 6

Contract No. W9127N18C0083

Transmittal No. 01 35 26.00 25-9 March 18, 2019

NAMEPLATE:

OEM-GENERAL ELECTRIC

163,420 kVA; 13.8 kV: PF 0.95: 3 PH: 90 RPM, 60 HZ

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USACE/John Day Dam

RE: Analytical Results for

Project #

January 28, 2016

ASBESTOS BULK ANALYSIS REPORT

Analytical Results Summary

No Asbestos Detected:

<1% Asbestos:

1% or Greater Asbestos:

Number of Samples Submitted: 3

Client PO 60135942VV

0Asbestos Contamination:Interstate 84, Exit 109 Rufus,OR 97050

15384LOG #

3Total Suspect Asbestos Materials:

Source: Field Location:

SAMPLE SUMMARY

Result:Sample #Lab #

Precision Analytical & Environmental Services PO Box 28 Rickreall, Oregon 97371

(503) 835-7096 fax: 835-1117

BULLSEYE

John Day/Willow Creek Project

John Goldsberry

15384-1 Asbestos Containing1 Main Unit 318 AWG RTD 20 Wire Insulation

15384-2 No Asbestos Detected2 Main Unit 310 AWG Wire Insulation

15384-3 No Asbestos Detected3 Stator BarInsulation

All samples are analyzed by the method 40 CFR Part 763 Appendix E, Section 1 Polarized Light Microscopy (PLM), and where appropriate procedures outlined in the EPA 600/R-93 -116 Method for the Determination of Asbestos in Bulk Building Materials (July 1993). A lower detection limit for this method of less than 1% asbestos is achievable by skilled technicians participating in rigorous QA/QC programs. This analytical method does not cover settled dust samples. Fibers less than 1 micrometer in length are not detectable by PLM.

Point counting is required by NESHAPS (40 CFR Part 61) for quantitation of samples containing less than 10% asbestos by PLM analysis only when materials are not treated as asbestos containing material (ACM). Samples reported by BULLSEYE as containing 1% or less asbestos by standard PLM may require point count verification or additional quantification at an additional cost. Unless otherwise requested, samples will be retained for a period of 30 days, after which they will be discarded.