W912P5-16-R-0004_TSpecsAppA.pdf

RFP No. W912P5-16-R-0004

US Army Corps Of Engineers Nashville District

EXCITER EQUIPMENT REPLACEMENT

Barkley Power Plant Lyon County, Kentucky

Technical Specifications

Appendix A - Asbestos Survey of the Barkley Power Plant

July 2016

THIS PAGE INTENTIONALLY LEFT BLANK

FOR DUPLEX PRINTING

ASBESTOS SURVEY

OF THE

BARKLEY POWER PLANT

for

U.S. Anny Corps of Engineers

Nashville District

November 1993

Dames & Moore, Inc.

Job No. 24637-003-009

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...................................... ES-1

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1. 1 PROJECT BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.2 SCOPE OF WORK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

1.3 PERSONNEL QUALIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . 1-3

1.4 REPORT ORGANIZATION ........................... 1-3

2.0 DESCRIPTION OF BARKLEY POWER PLANT . . . . . . . . . . . . . . . . . . . . 2-1

3.0 BULK MATERIAL SURVEY AND SAMPLING .................... 3-1

3.1 SURVEY PROCEDURES ............................. 3-1

3. 1 . 1 Information Review . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.1.2 Initial Walk-Through Inspection ................ 3-2

3.1.3 Bulk Sample Collection Procedures ............. 3-2

3.1.4 Bulk Sample Identification ................... 3-3

3. 1 . 5 Quality Control Sampling . . . . . . . . . . . . . . . . . . . . 3:...3

3. 1 . 6 Laboratory Analytical Methods . . . . . . . . . . . . . . . . 3-.f

3.2 PHYSICAL ASSESSMENT OF ASBESTOS MATERIALS ....... 3-4

3.3 RESULTS OF THE BULK ASBESTOS SURVEY . . . . . . . . . . . . . 3:...5

3.3.1 Vinyl Flooring Products ..................... 3-6

3.3.2 HVAC Air Duct Insulation and Flexible Connections . 3-7

3.3.3 Ceiling Tile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

3.3.4 Pipe Insulation . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9

3.3.5 Electrical Wiring and Arc Shields .............. 3-11

3.3.6 Brake Pads ............................. 3-14

3.3. 7 Miscellaneous Materials .................... 3-15

3.3.8 Quality Control Sample Results ............... 3-17

4.0 AIR SAMPLING ........................................ 4-1

4.1 AIR SAMPLING COLLECTION PROCEDURES .............. 4-1

4. 1 . 1 Air Sampling Strategy . . . . . . . . . . . . . . . . . . . . . . 4-1

4. 1 . 2 Air Sampling Procedures . . . . . . . . . . . . . . . . . . . . 4-1

4.1.3 Air Sample Identification .................... 4-2

4.1.4 Air Sample Quality Control ................... 4-2

4.1.5 Laboratory Analytical Methods ................ 4-2

4.2 AIR SAMPLE RESULTS ...•.•....••.•............... 4-3

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DAMES & MOORE

TABLE OF CONTENTS

(Continued)

4.2.1 Primary Air Samples ....................... 4-3

4.2.2 OC Air Samples .......................... 4-4

4.3 INTERPRETATION OF THE RESULTS OF THE AIR SAMPLING .. 4-4

5.0 HAZARD ASSESSMENT .................................. 5-1

5.1 HAZARD ASSESSMENT METHODS . . . . . . . . . . . . . . . . . . . . 5-1

5.2 HAZARD ASSESSMENT RESULTS ..................... 5-3

5.2.1 HVAC Air Duct Insulation and Flexible Connections . 5-3

5.2.2 Pipe Insulation ........................... 5-3

5.2.2.1 5.2.2.2

Hot Water System Insulation . . . . . . . 5-3 Service, Cooling, and Raw Water Line Insulating Cement . . . . . . . . . . . . . . . 5-4

5.2.3 Wiring Insulation and Arc Shields .............. 5-4

5.2.4 Brake Pads .............................. 5-5

5.2.5 Mechanical Packings ....................... 5-5

5.2.6 Drying Oven Insulation ...................... 5-6

5.2.7 Light Fixture Gaskets ....................... 5-6

5.2.8 Emergency Generator Insulation ............... 5-6

5.2.9 Crane Flooring ........................... 5-7

6.0 COST ESTIMATES ...................................... 6-1

6.1 ABATEMENT PROJECT COST ESTIMATES ............... 6-1

6.2 OPERATIONS AND MAINTENANCE PROGRAM COST

ESTIMATE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

7.0 CONCLUSIONS, RECOMMENDATIONS, AND LIMITATIONS ......... 7-1

7.1 CONCLUSIONS .................................. 7-1

7. 2 RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2

7.3 SUMMARY OF COST ESTIMATE ...................... 7-3

7.4 LIMITATIONS .................................... 7-3

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TABLE

3-1

3-2

3-3

4-1

4-2

6-1

LIST OF TABLES

TITLE

Bulk Asbestos Sample Results

Summary of Asbestos Wiring in Electrical Equipment

Comparison of Primary and QC Bulk Sample Results

Air Sample Results

Comparison of Primary and QC Air Sample Results

Cost Estimates for Initial Asbestos Abatement

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FIGURE

2-1

3-1

3-2

3-3

3-4

3-5

5-1

LIST OF FIGURES

TITLE

Site location Map

Penthouse Floor Plan, Elevations 381 and 366

Powerhouse Elevation 3 4 7

Powerhouse Elevation 331 and 333.5

Powerhouse Elevation 315

Powerhouse Elevations 299

Hazard Ranking Decision Tree

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LIST OF APPENDICES

APPENDIX

A Curricula Vitae for Key Project Personnel

B Physical Assessment Forms c Laboratory Data Sheets for Bulk Samples

• Primary Standards

• Quality Control Samples

D Laboratory Data Sheets for Air Samples

• Primary Samples

• Quality Control Samples

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EXECUTIVE SUMMARY

The Nashville District of the U.S. Army Corps of Engineers (COE) operates the Barkley

Power Plant on the Cumberland River in Kuttawa, Livingston County, Kentucky.

Dames & Moore, Inc. (Dames & Moore) performed an asbestos survey of the Barkley

Power Plant to identify friable and non-friable asbestos-containing materials (ACM) present in the plant and to assess the potential health hazards which the identified

ACM presents to COE personnel.

The asbestos survey of the Barkley Power Plant included: review of the results of previous asbestos sampling; review of available building plans and specifications; a walk-through survey of the plant to identify suspect ACM; collection of bulk material samples; collection of air samples; performance of a hazard assessment of the ACM based upon the requirements of the Asbestos Hazard Emergency Response Act

(AHERA); and, preparation of a report of the asbestos survey.

A total of 59 samples were collected by Dames & Moore during the bulk survey.

Asbestos was detected in 38 of these samples. The samples were analyzed using polarized light microscopy (PLM). The materials which were determined to contain asbestos included: heating, ventilation, and air-conditioning (HVAC) duct insulation and flexible connections; pipe insulation and insulating cement; brake pads on the generators, cranes, and spillway gates; electrical wiring insulation and arc shields;

drying oven insulation; mechanical packings; light fixture gaskets; flooring material in the cranes; and, thermal insulation and a rope-like gasket used on the emergency generator exhaust.

The damaged areas of HV AC duct insulation, damaged pipe insulation and debris, insulation in the drying oven, and the rope-like gasket on the emergency generator exhaust were friable. The other types of ACM detected in the power plant were non friable.

Dames & Moore collected 13 air samples in the areas of the plant containing friable

ACM and/or non-friable ACM which was subject to potential damage. The air samples were analyzed using transmission electron microscopy (TEM). The results of analyses

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for these samples revealed that the asbestos fiber concentrations on the samples were below the primary and Quality Control (QC) laboratory's limits of quantification. Thus, airborne asbestos fiber concentrations in the plant were below the Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL) for asbestos fibers at the time that the samples were collected.

Dames & Moore assessed the potential health hazards presented by the identified

ACM. The hazard assessment was based on the bulk and air sample results and on physical assessment forms completed during the survey. Significantly damaged insulation was observed in the drying oven in the oil treatment room on elevation 299.

This material represented an immediate potential health hazard to COE employees. The presence of this significantly damaged material was brought to the attention of Mr.

Frank Kee, the power plant superintendent. Mr. Kee then directed two COE employees to place the damaged pieces of insulation into an asbestos disposal bag which was provided by Dames & Moore. Dames & Moore then used a vacuum cleaner equipped with a high efficiency particulate air (HEPA) filter to remove the visible insulation debris from inside the drying oven and from the floor beneath the drying oven. Damaged pipe insulation or insulating cement in the pipe chase on elevation 366; in the warehouse;

and, on the generator cooling water lines on elevation 331 were also identified as potential health hazard. The woven flexible connections on the HV AC units and a rope-like gasket on the emergency generator exhaust were also identified as potential health hazards. Dames & Moore recommends that these materials be removed from the plant and be replaced with non-asbestos-containing materials.

The non-friable ACM detected in the Barkley Power Plant appeared to represent minor health hazards. These materials should be included in a site specific Operations and

Maintenance (O&M) Program.

The cost for a preliminary asbestos abatement project is estimated to range from approximately $73,200 to $89,800. Dames & Moore estimates that the costs for development and the implementation of an O&M Program would range from $15,000 to $20,000.

ES-2

ASBESTOS SURVEY

OF THE

BARKLEY POWER PLANT

FOR

U.S. ARMY CORPS OF ENGINEERS

NASHVILLE, DISTRICT

NOVEMBER 1993

1.0 INTRODUCTION

This report presents the findings of the asbestos survey of the Barkley Power Plant located in Kuttawa, Livingston County, Kentucky. The asbestos survey was performed by Dames & Moore, Inc. (Dames & Moore) for the Nashville District of the U.S. Army

Corps of Engineers (COE).

1.1 PROJECT BACKGROUND

The COE/Nashville District (CEORN) operates nine hydropower plants within the drainage area of the Cumberland River in the states of Tennessee and Kentucky. In

1987, COE personnel collected a limited number of bulk samples from suspected asbestos-containing materials (ACM) in the plants. Based on the results of this limited asbestos sampling, CEORN decided to conduct thorough asbestos surveys in each of the nine hydropower plants. The purpose of these surveys is to identify friable and non-friable ACM present in the plants and to assess the potential health hazards which these materials present to COE personnel at each of the facilities. The CEORN issued

Dames & Moore Delivery Order 003 under Indefinite Delivery Contract DACA

62-92-D-0015 to perform these asbestos surveys.

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1.2 SCOPE OF WORK

In accordance with the provisions of the CEORN July 1, 1992 Scope of Work for the asbestos surveys, Dames & Moore's survey of the Barkley Power Plant included performance of the following tasks:

• Task 1. lnfonnation Review- Prior to initiating the survey, Dames & Moore reviewed drawings of the Barkley Power Plant which had been provided by the COE. At the beginning of the bulk survey, Dames & Moore reviewed the construction specifications for the power plant. The drawings and specifications were reviewed for references to the use of asbestos materials during construction.

• Task 2. Initial Walk-Through- An initial walk-through survey of the facility was performed in order to identify suspect ACMs used in the power plant, dam, and associated facilities. Following the walk-through, a sampling plan was devised for the collection of bulk samples of suspect ACM.

• Task 3. Bulk Material Survey - Dames & Moore collected samples from materials which were suspected to contain asbestos. The estimated amount, condition, accessibility, and the potential for damage of the suspect ACM were recorded on physical assessment forms during the bulk survey.

• Task 4. Air Sample Collection - Following the collection of the bulk samples and review of the physical assessment forms, Dames & Moore returned to the plant to collect air samples in areas where damaged and/or friable ACM was detected. The air samples were collected in order to measure the concentration of airborne asbestos fibers present in the atmosphere in the facility.

• Task 5. Hazard Assessment- Hazard assessments were performed for the asbestos materials detected in the plant. These hazard assessments were based on the laboratory results of the bulk and air samplings and on the documentation included in the physical assessment forms which were completed during the bulk survey.

• Task 6. Survey Report- At the conclusion of the survey, Dames & Moore prepared a report which documented the results of the survey.

Prior to implementing the field portion of the asbestos survey at the Barkley Power

Plant, a Work Plan and Site Safety Plan for the project were developed and approved by CEORN.

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1.3 PERSONNEL QUALIFICATIONS

The tasks described in Section 1. 2 above were performed by qualified Dames & Moore personnel. All field work was performed by a two-person field team. The field team leader for the Barkley Power Plant bulk survey and sampling was Mr. Dennis P.

Popham who is certified under the U.S. Environmental Protection Agency (EPA)

Asbestos Hazard Emergency Response Act (AHERA) and who is also qualified to perform the duties of the Site Safety Coordinator. For the Barkley Power Plant bulk survey and sampling Mr. Popham was accompanied by Mr. Kendall J. Deatherage.

Mr. Deatherage is also AHERA certified and is qualified to perform asbestos inspections. Curriculum Vitae for Mr. Popham and Mr. Deatherage are included in

Appendix A.

1.4 REPORT ORGANIZATION

This report is organized into seven sections, as described below:

Section 1 describes the project background, the Scope of Work performed, the qualifications of the personnel performing the survey, and the report organization.

Section 2 provides a brief description of the Barkley Power Plant.

Section 3 discusses the bulk survey and sampling portion of the project. It provides descriptions of the procedures used to perform the bulk survey and sampling and presents the results and findings of the bulk survey.

Section 4 discusses the air sampling portion of the project. It provides descriptions of the procedures used to perform the air sampling and presents the results and findings of the air sampling.

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Section 5 describes the Hazard Assessment performed by Dames & Moore as part of this asbestos survey. Recommendations for controlling asbestos exposures for COE personnel are made in this section.

Section 6 provides the cost estimate for implementing the recommendations set forth in Section 5.

Section 7 presents a summary of the project conclusions, recommendations, and limitations.

The tables, figures, and photographs are included at the end of the section in which they are first mentioned. The appendices are included after Section 7.

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2.0 DESCRIPTION OF BARKLEY POWER PLANT

The Barkley Dam and Power Plant are located on the Cumberland River in Kuttawa, Livingston County, Kentucky. The general location of the Barkley Dam and Power

Plant is shown on Figure 2-1. The dam was constructed for the purposes of navigation, flood control, power generation, and recreation.

Construction of the dam and power plant began in the early 1960's and the power plant became operational in 1966. The power plant contains four hydroelectric generators which are each rated at 25 megawatts. Electrical power produced at the plant is marketed through the Southeastern Power Administration (SEPA).

The Barkley Dam is a reinforced concrete-gravity and earthen fill structure. The dam is a "low head" dam with an associated lock to accommodate river traffic. The Barkley power plant is a five-story reinforced concrete structure which contains approximately

75,000 square feet of floor space. A metal warehouse building which contains approximately 7,200 square feet of floor space is located near the powerhouse and is used for storage of surplus equipment.

The Barkley Power Plant is normally operated by a staff of 16. The powerhouse staff includes: management personnel, powerhouse operators, clerical staff, electricians, mechanics, and custodial workers. At least one powerhouse operator is required to be at the plant at all times.

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10000 5.000 0 2 3

Feet

Miles

Figure 2-1

VICINITY MAP

Barkley p U.S. Arm ower Plant

Y Corps of E .

Nashville Distric~QI nears

DAMES AM' OORE

3.0 BULK MATERIAL SURVEY AND SAMPLING

The bulk material survey of the Barkley Power Plant was performed by

Messrs. Popham and Deatherage during the period from January 4 to 7, 1993. During the bulk survey and sampling, Messrs. Popham and Deatherage were accompanied by

Mr. Bob Jarret of the COE.

This section of the report provides a discussion of the methods and procedures used by Dames & Moore during the bulk material survey and provides the results of analysis for all of the bulk samples collected during the survey.

3.1 SURVEY PROCEDURES

3. 1 . 1 lnfonnation Review

Prior to visiting the Barkley Power Plant, Dames & Moore reviewed floor plans of the plant provided by the COE. At the beginning of the survey, Dames & Moore reviewed the construction specifications for the power plant. These plans and specifications were reviewed for references to the use of ACM during construction of the plant.

References to asbestos were not observed on the floor plans for the powerhouse. The construction specifications referenced the use of thermal asbestos insulation on the hot water lines. Asbestos canvas was specified for use as a flexible connection material between the fans and metal ductwork in the plant. Heating ventilating and air conditioning (HVAC) ducts were specified to be coated by a hydraulic (asbestos) cement. The construction specifications also made reference the use of asbestos electrical conduit.

Dames & Moore reviewed laboratory data for samples collected during the COE's limited asbestos survey in 1987. The limited asbestos sampling at the Barkley Power

Plant confirmed the presence of ACM in insulation used on the plant's HVAC ductwork, in insulating cement used on water pipes, and in the insulation on the emergency generator exhaust.

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3.1.2 Initial Walk-Through Inspection

The next task conducted by Dames & Moore at the Barkley Power Plant was the completion of an initial walk-through inspection. During the walk-through, accessible areas of the powerhouse, dam, warehouse, switchyard, and radio building were viewed. The locations of suspected ACM were noted on a floor plan of the facility at this time. At the conclusion of the walk-through, Dames & Moore devised a plan for the collection of bulk samples. The sampling plan was based on the EPA Publication

No. 56015-85-024, Guidance for Controlling Asbestos-Containing Materials in

Buildings (the •Purple Book") dated June 1985.

The materials which were identified for sampling included: ceiling tile; HV AC duct insulation; vinyl flooring products; pipe insulation, electrical wiring insulation and arc shields; brake pads; wall plaster; mechanical packings; insulation on the emergency generator exhaust; and, other miscellaneous materials which were not extensively used in the plant.

3.1.3 Bulk Sample Collection Procedures

During the collection of bulk samples Dames & Moore made every effort to minimize the release of asbestos fibers to the environment. When sampling friable materials a polyethylene drop cloth was placed beneath the sample location.

Prior to collecting a sample from friable suspect ACM, the material was sprayed with amended water. By wetting the material in this fashion, the likelihood of the release of asbestos fibers was diminished. A knife or other sampling tool was used to collect the sample. A hammer and chisel were used to sample non-friable ACM such as floor tile and brake pads. After a sample was collected the sampling tool was decontaminated by spraying with amended water and then wiping the tool with a pre moistened cloth. The collected sample was then placed into an air-tight container.

The area from which the sample was collected was repaired using silicon caulk, spray adhesive, or duct tape.

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A vacuum cleaner equipped with a high efficiency particulate air (HEPA) filter was used to clean the areas where the samples were collected. The wastes generated during the asbestos survey were placed inside of a labeled asbestos disposal bag. These wastes included: respirator filters, paper towels, protective coveralls, and tape. The bag of waste was left at the plant for disposal by the COE at a later date.

All sampling locations were recorded in the field on diagrams of the plant provided by

CEORN.

At the conclusion of the sampling effort, the samples were shipped via courier to the subcontracted laboratories. Chain-of-custody forms were completed and shipped with the samples to the laboratories.

3.1.4 Bulk Sample Identification

A unique sample identification (10) was assigned to each discrete sample. The location where the sample was collected was marked with plastic tape which contained the unique 10. In some locations, an indelible marker was used to write the 10 directly upon-the material or equipment which was sampled.

An alpha-numeric system was utilized for sample 10. For this site, each sample was given the prefix "BAR", which indicated that the sample was collected at the Barkley

Power Plant. The letter "B" was used in the sample 10 to indicate that the sample was a bulk sample. Each successive sample was then numbered 001, 002, 003 .... etc.

3. 1 . 5 Quality Control Sampling

One quality control (QC) duplicate sample was collected for every 20 bulk samples.

Each QC sample was collected adjacent to the primary sample. The same alpha numeric sample 10 was used for both the primary and the QC sample except that the letter "Q" was added to the end of the sample 10 for the QC sample.

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A total of four QC samples were collected during the survey. These QC samples were submitted to a separate laboratory independent from the primary laboratory subcontractor. A chain-of-custody form was completed and shipped with the samples to the laboratory.

3.1 . 6 Laboratory Analytical Methods

The primary bulk samples collected during this survey were submitted to Environmental

Technology Services, Inc., (ETS) of Atlanta, Georgia. The QC samples were submitted to AMA Analytical Services, Inc. (AMA), of Lanham, Maryland. Both ETS and AMA are American Industrial Hygiene Association accredited laboratories. Each participates in the National Voluntary Laboratory Accreditation Program (NVLAP) for analysis of bulk asbestos samples.

The primary and QC samples were analyzed using polarized light microscopy (PLM) in accordance with the EPA •Interim Method for the Determination of Asbestos in Bulk

Insulation Samples, EPA/600/M4-82-020, December 1982. •

3.2 PHYSICAL ASSESSMENT OF ASBESTOS MATERIALS

During the collection of bulk samples the Dames & Moore inspectors completed physical assessment forms for the suspect ACM. The information entered onto these forms included: the type and amount of suspect ACM; whether or not the material was friable; the current condition of the material; the accessibility of material to building occupants; and, the potential of the material to become damaged in the future.

The suspect ACM was also assessed in accordance with the methods outlined by

AHERA. In the AHERA method, friable suspect ACM is categorized according to the type of material and the amount of damage which the material has sustained or is likely to sustain in the future. The AHERA method contains seven possible assessment categories for friable ACM. The seven AHERA Assessment Categories are as follows:

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1 . Damaged or Significantly Damaged Thermal System Insulation (TSI)

2. Damaged Friable Surfacing Material

3. Significantly Damaged Friable Surfacing Material

4. Damaged or Significantly Damaged Friable Miscellaneous Material

5. ACM with Potential for Significant Damage

6. ACM with Potential for Damage

7. Any Remaining Friable ACM or Friable Suspect ACM

The AHERA physical assessment method defines "significant damage• as evenly distributed damage to greater than 10 percent of a material's surface or localized damage to greater than 25 percent of the material's surface. An ACM is classified as

•damaged" if the material's surface is crumbling, blistered, water stained, or gouged over less than 10 percent of the surface (if the damage is evenly distributed); or less than 25 percent if the damage is localized. Material which is classified as being in good condition shows only •very limited" ( < 1 percent) damage or deterioration.

Non-friable ACM is not required to be assessed under the AHERA method. However, for the purpose of this project, all non-friable materials were placed into Assessment

Categories 5 or 6. The Physical Assessment Categories were assigned to suspect materials at the time samples were collected. Subsequent laboratory analysis indicated some of the materials did not contain asbestos. Therefore, Physical Assessment

Categories assigned to these non-asbestos-containing materials are, in retrospect, not applicable.

Note that the physical assessments are similar to, but not interchangeable with, the

Hazard Assessments which are described in Section 5.1 and listed on the figures.

3.3 RESULTS OF THE BULK ASBESTOS SURVEY

A total of 59 samples were collected by Dames & Moore during the bulk survey.

Asbestos was detected in 38 of these samples. This section describes the types and the locations of the materials which were sampled.

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The sample locations are shown on Figures 3-1 through 3-5. Figures 3-1 through 3-5 also indicate the locations of ACM such as HVAC air duct insulation, brake pads, floor tile, wiring insulation, pipe insulation, etc., detected in the plant. Notes on the figures describe hazard rankings and recommendations for the various types of ACM.

A discussion of the physical assessments of the materials as recorded in the field by the Dames & Moore inspectors is also provided in this section. Copies of the physical assessment forms completed during the survey are contained in Appendix B.

Table 3-1 provides the results of laboratory analyses, lists the sampling location and material type for each sample, provides an estimated quantity of the material (if appropriate), identifies the A HERA Physical Assessment Category and the Hazard Rank

Category for each sample, and lists the figure and photo numbers which illustrate the sample location. Table 3-1 also summarizes the recommendations described in the text with regard to the ACM detected at the plant.

Laboratory data sheets for the primary bulk samples are contained in Appendix C.

Photographs of the sample locations are included at the end of this section of the report.

3. 3. 1 Vinyl Flooring Products

Four samples were collected from the two types of vinyl floor tile observed in the power plant. The types of floor tile identified included: a 12x1 2-inch gray tile used in the control room, telephone room, chart room and corridor of elevation 34 7; and a tan and brown floor tile used in the lobby and office corridor on elevation 366.

Sample BAR-B-O 14 (Photo 14) was taken from the 12x1 2-inch gray floor tile used in the telephone room on elevation 34 7. Another sample of this 12x1 2-inch gray floor tile (sample BAR-B-O 18 shown in Photo 18) was taken from the instrument room on elevation 34 7. No asbestos was detected in these samples of 12x12-inch gray floor tile.

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Sample BAR-B-029 (Photo 28) was taken from the 12x12-inch tan and brown floor tile used in the office corridor on elevation 366. Another sample of this 12x12-inch tan and brown floor tile (sample BAR-B-030 shown in Photo 29) was taken near the visitor's entrance on elevation 366. No asbestos was detected in these floor tile samples.

Both types of vinyl floor tile observed in the plant were placed into AHERA Physical

Assessment Category 6 (ACM With a Potential For Damage) at the time of the survey.

Because no asbestos was detected in these floor tile samples, this classification is no longer applicable.

3.3.2 HVAC Air Duct Insulation and Flexible Connections

A trowelled-on plaster insulation was used on the HVAC supply ducts in the power plant. On elevation 366, this material was observed on the HVAC air ducts in fan room #1 0. On elevation 34 7, the trowelled-on plaster insulation was observed on ductwork in fan room #3, in the machine shop, electric shop, maintenance shop office and in a closet by the control room.

Sample BAR-B-O 1 0 (Photo 1 0) was taken from HVAC duct insulation on an air duct in the maintenance office on elevation 3 4 7. This sample contained 4 0 percent chrysotile asbestos.

Sample BAR-B-04 7 (Photo 46) was taken from HVAC duct insulation in fan room #1 0 on elevation 366. This sample contained 10 percent chrysotile asbestos.

The majority of the trowelled-on plaster HV AC duct insulation in the plant w~s in good condition and was not friable. Dames & Moore placed the majority of the duct insulation into AHERA Physical Assessment Category 6 (ACM With a Potential For

Damage). Throughout most of the plant this material was present at the ceiling level and was not readily accessible. However, it was readily accessible in the in maintenance shop office and in the closet by the control room. In these areas the ducts passed through the floor of elevation 3 4 7 to elevation 331 below. A section of

3-7 duct in the maintenance shop showed evidence of having been damaged from physical contact in the past. This damage appeared to have been repaired by painting over the damaged areas. In fan rooms #3 and #1 0, sections of the duct insulation showed evidence of past damage during the installation of new air-conditioning units. In both areas, this damage was repaired with duct tape. Because of this damage, the sections of duct insulation in fan rooms #3 and # 1 0 were placed into a AHERA Physical

Assessment Category 1 (Damaged or Significantly Damaged TSI).

Dames & Moore estimated that 750 square feet of plaster HVAC duct insulation were present on the ducts on elevation 34 7. Approximately 21 0 square feet of the HVAC duct insulation were noted in fan room #1 0 on elevation 366.

A grayish white woven canvas material was used as a flexible connection between each of the HVAC fans and associated metal duct work in the power plant. Sample

BAR-B-005 (PheW 5) was taken from a flexible connection in fan room #7 on elevation 331 . Analysis of this sample indicated that the flexible connection contained

85 percent chrysotile asbestos. Sample BAR-B-019 (Photo 19) was taken from a flexible connection in fan room #4 on elevation 34 7. This sample contained 40 percent chrysotile asbestos. Fourteen of these canvas flexible connections were noted during the survey. These flexible connectors were in good condition and were not considered to be friable. They were placed into AHERA Physical Assessment Category

6 (ACM With a Potential for Damage).

3.3.3 Ceiling Tile

Three types of ceiling tile were observed in the Barkley Power Plant. These included:

a 2x4-foot ceiling tile used in the employee break room on elevation 34 7; a

12x12-inch spline ceiling tile used in the office corridor and visitor's center on elevation 366 and in the telephone room on elevation 347; and, a second type of

12x12-inch spline ceiling tile used only in the Superintendent's office.

Sample BAR-B-O 11 (Photo 11) was taken from the 2x4-foot ceiling tile used in the employee breakroom. Sample BAR-B-O 15 (Photo 15) was taken from 12x12-inch

3-8 spline ceiling tile in the telephone room, elevation 34 7. Sample BAR-B-031 (Photo 30) was taken from the 12x12-inch spline ceiling tile in the office corridor on elevation 366. Sample BAR-B-048 (Photo 4 7) was taken from the 12x12-inch spline ceiling tile used in the Superintendent's office on elevation 366. No asbestos was detected in any of these ceiling tile samples. Therefore, the AHERA Physical

Assessment Category to which the ceiling tiles were assigned in the field (Category 6) is not applicable.

3.3.4 Pipe Insulation

Two types of pipe insulation were observed in the plant. Cellular glass pipe insulation was used on the service water, raw water, and generator cooling water lines. The cellular glass was covered by a felt vapor barrier. An insulating cement was used on the elbows, joints, and valves of these systems. The second type of insulation consisted of preformed sections of a chalky-type pipe insulation. This chalky insulation was used on the two hot water circulation systems in the plant. An insulating cement was also used on the elbows, joints, and fittings of the hot water lines.

Sample BAR-B-006 (Photo 6) was taken from insulating cement on a pipe elbow on a service water line in the water treatment room on elevation 3 31 . No asbestos was detected in this sample. Most of the insulating cement in the water treatment room was in good condition and was not friable; however, one section of insulation and insulating cement was damaged and friable. Therefore, the insulating cement in the water treatment room was placed into AHERA Physical Assessment Category 1

(Damaged or Significantly Damaged TSI) at the time of the survey.

Sample BAR-B-007 (Photo 7) was taken from insulating cement on a pipe elbow on a cooling water line for Unit #2 on elevation 331. This sample contained 40 percent chrysotile asbestos and 3 percent amosite asbestos. The insulating cement on the cooling water lines for Unit #2 was in good condition and was not friable. This material was placed into AHERA Physical Assessment Category 6 (ACM With a

Potential for Damage).

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Sample BAR-B-008 (Photo 8) was taken from insulating cement used on a pipe elbow on a cooling water line for Unit #3 on elevation 331. The sample contained less than

1 percent chrysotile asbestos and 20 percent amosite asbestos. This material was categorized as being damaged. The material was friable where damaged, but was otherwise non-friable. Dames & Moore placed the insulating cement on the Unit #3 cooling water lines into AHERA Physical Assessment Category 1 (Damaged or

Significantly Damaged TSI).

Sample BAR-B-O 13 (Photo 13) was taken from pipe insulation on a hot water line in the pipe chase by the break room on elevation 34 7. This sample contained 40 percent chrysotile asbestos and 1 0 percent amosite asbestos. The pipe insulation in this area was in good condition and was not friable. It was placed into AHERA Physical

Assessment Category 6 (ACM With a Potential for Damage).

Sample BAR-B-O 16 (Photo 16) was taken from pipe insulation on a hot water line in the pipe chase by the elevator on elevation 34 7. This sample contained 40 percent chrysotile asbestos and 1 0 percent amosite asbestos. The pipe insulation in this area was in good condition and was not friable. It was placed into AHERA Physical

Assessment Category 6 (ACM With a Potential for Damage).

Sample BAR-B-042 (Photo 41) was taken from insulating cement in a small pile of cellular glass pipe insulation debris located in the storage warehouse. Analysis of this sample indicated that the insulating cement contained 35 percent amosite asbestos.

This material was significantly damaged and friable. It was placed into AHERA

Physical Assessment Category 1 (Damaged or Significantly Damaged TSI). Less than

1 cubic foot of this insulation debris was observed.

Sample BAR-B-059 (Photo 58) was taken from insulating cement on a pipe elbow on a service water line located in the pipe chase near the elevator on elevation 34 7. This sample contained 20 percent chrysotile asbestos. No damage was observed to the fittings and elbows on which this insulating cement was used. Dames & Moore placed the insulating cement on the service water lines into AHERA Physical Assessment

Category 6 (ACM With a Potential for Damage).

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Dames & Moore estimated that 90 elbows and joints were present on the service water lines in the water treatment room. Approximately 120 fittings with asbestos-containing insulating cement were observed on the generator cooling water lines outside of the four generators. Another 100 elbows and fitting with assumed asbestos insulating cement were observed in the wheel pits of the generators.

There are two separate hot water circulation systems in the Barkley Power Plant. One of the systems originates at a water heater in the pipe chase by the employee break room on elevation 34 7. This system provides hot water to the locker room.

Approximately 90 linear feet of pipe insulation were noted in the pipe chase by the break room and another 75 linear feet of insulation were observed in fan room #7, in the paint storage room, and in the battery room on elevation 331. As a whole, the insulation on this system was in good condition and was not friable. The entire system was included in AHERA Physical Assessment Category 6 (ACM With a Potential for

Damage).

The second hot water circulation system originated at a water heater in the pipe chase by the elevator on elevation 347. Approximately 75 linear feet of insulation and 40 elbows and fittings covered with insulating cement were observed in this pipe chase.

This system provides hot water to the visitor's area rest room on elevation 366. In the pipe chase between the visitor's area restrooms, Dames & Moore observed approximately 60 linear feet of pipe insulation. This insulation was damaged and friable. Dames & Moore placed the insulation on this hot water circulation system into

AHERA Physical Assessment Category 1 (Damaged or Significantly Damaged TSI).

3. 3. 5 8ectrical Wiring and Arc Shields

During the survey, Dames & Moore inspected the interior of the electrical equipment which had been identified by the COE prior to the beginning of this project as possibly containing wiring insulated with asbestos. Dames & Moore also inspected the interior of the electrical equipment for the presence of potential asbestos-containing arc shields. Fourteen samples were collected from various types of electrical wiring

3-11 insulation used throughout the plant. One sample was collected from an arc shield during the survey.

Electrical wiring was considered to potentially contain asbestos if the insulation consisted of a woven fabric. Wiring which was insulated with rubber or vinyl was not considered to be suspect ACM; therefore, it was not sampled. Arc shields were suspected to contain asbestos if they were made from a material which resembled cementitious asbestos.

The suspect asbestos-containing wire insulation and arc shields were placed into

AHERA Physical Assessment Category 6 (ACM With a Potential for Damage). This classification no longer applies to the wire insulation which was later found to be non asbestos-containing. However, because of the similarity between the wire insulation which contained asbestos and the wire insulation which did not contain asbestos, Dames & Moore recommends that all wiring with woven insulation be treated as potential ACM.

The results of analyses for wiring insulation and arc shield samples collected during the survey are as follows:

• Sample BAR-B-002 (Photo 2) was taken from insulation on a 1' -inch gray wire in the C02 equipment control panel on elevation 299. This sample contained 5 percent chrysotile asbestos.

• Sample BAR-B-009 (Photo 9) was taken from insulation on a o/a-inch gray wire in the unit board #3 on elevation 331. This sample contained 5 percent chrysotile asbestos.

• Sample BAR-B-O 17 (Photo 17) was taken from insulation on a 1' -inch gray wire in the main control board in the control room on elevation 3 4 7. This sample contained 1 0 percent chrysotile asbestos.

• Sample BAR-B-020 (Photo 20) was taken from a box of Cerro brand 1'-inch gray switchboard wire stored in the electrical storage area on elevation 34 7.

This sample contained 5 percent chrysotile asbestos.

• Sample BAR-B-021 (Photo 21) was taken from a box of General Electric brand 1' -inch gray switchboard wire stored in the electrical storage area on elevation 34 7. This sample contained 1 0 percent chrysotile asbestos.

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• Sample 8AR-8-022 (Photo 22) was taken from an unused voltage regulator arc shield stored in the electrical storage area on elevation 34 7. This sample contained 40 percent chrysotile asbestos. Other types of cementitious arc shields were observed in the storage area, but were not sampled. Dames & Moore assumes that all of the gray cementitious arc shields used in the plant contain asbestos.

• Sample 8AR-8-024 (Photo 24) was taken from insulation on a ~-inch grayish brown wire in the main control panel of the powerhouse crane. This sample contained 30 percent chrysotile asbestos.

• Sample 8AR-8-025 (Photo 24) was taken from insulation on a *-inch black wire in the main control panel of powerhouse crane. No asbestos was detected in this sample.

• Sample 8AR-8-034 (Photo 33) was taken from insulation on a l' -inch white wire in the hoist control panel for the tail deck crane. This sample contained 60 percent chrysotile asbestos.

• Sample 8AR-8-037 (Photo 36) was taken from insulation on a l' -inch gray wire in the #12 spillway gate control panel. This sample contained 10 percent chrysotile asbestos.

• Sample 8AR-8-040 (Photo 39) was taken from insulation on a :Ya-inch gray wire in the main control panel of the intake crane. This sample contained 1 5 percent chrysotile asbestos.

• Sample 8AR-8-044 (Photo 43) was taken from insulation on a l'-inch gray wire in the control panel of the ITE oil circuit breaker in the switchyard. No asbestos was detected in this sample.

• Sample 8AR-8-046 (Photo 45) was taken from insulation on a l'-inch reddish brown wire in the control panel of motor operated disconnect #965 in the switchyard. No asbestos was detected in this sample.

• Sample 8AR-8-050 (Photo 49) was taken from insulation on a ~-inch black wire in the Unit #1 main exciter. No asbestos was detected in this sample.

• Sample 8AR-8-051 (Photo 50) was taken from insulation on a l'-inch black wire in the Unit #1 main exciter. This sample contained 55 percent chrysotile asbestos.

Table 3-2 indicates the various types of electrical equipment in which suspected (or confirmed) asbestos-containing wire insulation was observed.

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3.3.6 Brake Pads

In accordance with the Scope of Work for this project, Dames & Moore collected samples from brake pads on several types of equipment at the Barkley Power Plant.

A total of nine brake pad samples were collected during the survey. Samples were collected from the brakes used on: the service elevator (BAR-B-003 shown in

Photo 3); the powerhouse crane (BAR-B-026, BAR-B-027, and BAR-B-028, shown in

Photos 25, 26, and 27, respectively); the tail deck crane (BAR-B-035 and BAR-B-036, shown in Photos 34 and 35, respectively); the spillway gates (BAR-B-038, shown in

Photo 37); a motor operated disconnect (MOD) in the switchyard (BAR-B-045, shown in Photo 44); and, from a generator brake pad on Unit #1 (BAR-B-049, shown in

Photo 48).

Laboratory analyses indicated that all but one of the brake pad samples contained chrysotile asbestos. The amounts of asbestos detected in the brake pad samples ranged from 3 to 90 percent chrysotile asbestos. The sample of the elevator brake pad

(BAR-B-003) did not contain asbestos. None of these brake pads were considered to be friable. With the exception of the elevator brake pads, most of the brake pads on the equipment were the original pads. Each of the asbestos-containing brake pads were placed into AHERA Physical Assessment Category 6 (ACM With a Potential for

Damage).

Settled dust was observed on horizontal surfaces inside of the generator thrust housings where the generator brakes are located. The presence of dust in the thrust housings may be an indication that the generator brakes release asbestos-containing dust when they are used.

Dames & Moore estimated that 16 brake pads were used on the powerhouse crane.

The tail deck crane contained 4 brake pads and the intake crane contained an estimated 8 brake pads. Twenty four brake pads were estimated to be present on the spillway gates. Six brake pads were estimated to be in the MODs in the switchyard.

Two brake pads were noted on the elevator motor. The generators were estimated to contain 48 brake pads.

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3. 3. 7 Miscellaneous Materials

Dames & Moore collected sixteen samples during the survey from miscellaneous materials used in the plant. The miscellaneous materials sampled included: insulation on the interior of the drying oven in the oil treatment room; light fixture gaskets;

carpet adhesive; flooring material in the crane cabs; insulation and a rope-like gasket on the emergency generator exhaust; window caulking; a roofing shingle on the radio building; wall plaster; and, spare mechanical packings. This section describes the locations from which these miscellaneous samples were collected and provides the results of laboratory analyses for the samples.

• Sample BAR-B-OO 1 (Photo 1) was taken from insulation in the drying oven located in the oil treatment room on elevation 299. This sample contained 80 percent chrysotile asbestos. The insulation in the drying oven was significantly damaged and friable. Dames & Moore felt that this insulation represented an immediate health risk to plant personnel. Therefore, the damaged insulation was brought to the attention of Plant Supervisor, Mr. Frank Kee. Mr. Kee directed COE employees to place the most severely damaged piece of insulation into a labeled asbestos disposal bag, which was provided by Dames & Moore. The remaining insulation in the drying oven was placed into AHERA Physical Assessment Category 4 (Damaged or Significantly Damaged Friable Miscellaneous Material). Approximately 20 square feet of this insulation were observed.

• Sample BAR-B-004 (Photo 4) was taken from a gasket used on a spare light fixture located in fan room #9 on elevation 315. This sample contained 90 percent chrysotile asbestos. These light fixture gaskets were in good condition and were not friable. They were placed into AHERA Physical Assessment Category 6 (ACM With a Potential for Damage). Dames & Moore noted 14 of the spare light fixtures in fan room #9.

• Sample BAR-B-012 (Photo 12) was taken from carpet adhesive in the break room of elevation 34 7. No asbestos was detected in this sample.

Therefore, the AHERA Physical Assessment Category to which this material was assigned in the Field (Category 6, ACM With a Potential for Damage) is not applicable.

• Sample BAR-B-023 (Photo 23) was taken from the flooring material in the cab of the powerhouse crane. This sample contained 40% chrysotile asbestos. This flooring material was not damaged and was not friable. It was placed into AHERA Physical Assessment Category 6 (ACM With a Potential for Damage). Approximately 36 square feet of this material were observed.

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• Sample BAR-B-032 (Photo 31) was taken from thermal insulation on the emergency generator exhaust line in the emergency generator room on elevation 366. Analysis of this sample indicated that the insulation on the exhaust line contained 30 percent amosite asbestos and 2 percent chrysotile asbestos. This insulation was in good condition and was not friable. It was placed into AHERA Physical Assessment Category 6 (ACM With a Potential for Damage). Approximately 20 linear feet of insulation were noted on the emergency generator exhaust line.

• Sample BAR-B-033 (Photo 32) was taken from thermal insulation on the emergency generator muffler located in the emergency generator room on elevation 366. Analysis of this sample indicated that the insulation on the muffler contained 1 0 percent chrysotile asbestos. This insulation was also in good condition and was not friable. It was placed into AHERA Physical Assessment Category 6 (ACM With a Potential for Damage). Approximately 4 0 square feet of insulation were observed on the emergency generator muffler.

• Sample BAR-B-039 (Photo 38) was taken from the flooring material in the intake crane control cab. This sample contained 60 percent chrysotile asbestos. This flooring material was in good condition and was not friable.

It was placed into AHERA Physical Assessment Category 6 (ACM With a Potential for Damage). Approximately 20 square feet of the flooring were observed.

• Sample BAR-B-041 (Photo 40) was taken from the caulk used on the windows of the intake crane control cab. No asbestos was detected in this sample. Therefore, the AHERA Physical Assessment Category to which this material was assigned (Category 6, ACM With a Potential for Damage) is not applicable.

• Sample BAR-B-043 (Photo 42) was taken from a roofing shingle used on the radio building. No asbestos was detected in this roofing shingle sample.

Therefore, the AHERA Physical Assessment Category to which this sample was assigned (Category 6, ACM With a Potential for Damage) is not applicable.

• Sample BAR-B-O 52 (Photo 51) was taken from wall plaster in the control room on elevation 34 7. No asbestos was detected in this wall plaster sample. Therefore, the AHERA Physical Assessment Category to which this sample was assigned (Category 6, ACM With a Potential for Damage) is not applicable.

• Sample BAR-B-053 (Photo 52) was taken from wall plaster in the telephone room on elevation 34 7. No asbestos was detected in this wall plaster sample. Therefore, the AHERA Physical Assessment Category to which this sample was assigned (Category 6, ACM With a Potential for Damage) is not applicable.

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• Sample 8AR-8-054 (Photo 53) was taken from 1 x1-inch white turbine shaft mechanical packing stored in the heavy equipment storage room on elevation 331. No asbestos was detected in this sample. Therefore, the AHERA Physical Assessment Category to which this sample was assigned (Category 6, ACM With a Potential for Damage) is not applicable. One box of this type of mechanical packing was noted in the heavy equipment storage roorn.

• Sample 8AR-8-055 (Photo 54) was taken from *x*-inch white gate stem mechanical packing in the heavy equipment storage room on elevation 331.

This sample contained 60 percent chrysotile asbestos. This material was not friable and was in good condition. It was placed into AHERA Physical Assessment Category 6 (ACM With a Potential for Damage).