Health & Safety Project

Generating Plant Asbestos and Lead Paint Survey

Confidential Electrical Utility Provider Florida

Solution Overview


Confidential Electric Utility Company

Business Challenge:

  • Quantify and document asbestos‑containing materials (ACM) and lead-containing paint (LCP) at a large, active power generation plant


  • Develop a sampling approach in alignment with the Asbestos Hazard Emergency Response Act (AHERA) and other local and state requirements as well as a method for labeling and documenting any positive materials identified


  • A comprehensive survey and operations and maintenance (O&M) plan that allowed the client to proceed with its maintenance and renovation activities while safeguarding worker health and safety


Apex Companies was contracted by a large national electric utility provider to provide a comprehensive plant-wide ACM and LCP survey at a plant it recently acquired. The plant currently runs on natural gas and provides 340 MW net capacity of electricity but was built in the 1960s and historically operated coal generation units. The client also requested O&M plans based on the results of the survey activities so that they could proceed with plant upgrades and renovations with full knowledge of any hazardous materials present onsite.


In September 2019, Apex mobilized a team of two AHERA-accredited asbestos inspectors to the facility. During the seven-day assessment, Apex identified 260 different homogeneous areas of materials that might potentially contain asbestos. Seven‑hundred nineteen individual samples of the suspect materials were collected and submitted for analysis. Laboratory analysis of 719 individual sample layers revealed no asbestos detected above one percent in any of the samples. Apex also collected photographic images of the suspect materials and noted the locations, approximate quantities, and physical condition. Sample locations were provided on facility figures.

Additionally, where surface coatings were present, Apex collected paint chip samples of suspect LCPs. Coatings that were similar in color and appearance in the same area were assumed to be homogeneous in age and composition. Fifty-eight paint chip samples were collected for analysis of lead content by percent. Of these samples, laboratory analysis indicated that six of the coatings were found to contain lead levels at or above the reporting limit for the analytical method. Color, location, and photographs of the coatings were provided in the report, along with the laboratory analytical report. Based on the paint analytical results, a lead paint O&M plan was developed and provided to the client.

Numerous unlabeled pipes and the associated suspect insulation were identified at the facility. Apex personnel developed a homogeneous area/sample identification system based on such factors as pipe diameter, plant location, and apparatus (valves, tanks, etc.) connected to the pipe. In this way, each asbestos sample could be assigned a unique identifier, allowing an interested party to immediately determine the asbestos content status of any given pipe within a given plant location.


Apex completed the project both on time and under the allocated budget. After the laboratory results were finalized for the considerable number of samples collected, Apex prepared a draft report for review by client representatives. After receiving comments from client stakeholders, the final survey report was delivered in February 2020. The client was pleased with the timeliness, communication, and professionalism of the staff, whose approach paved the way for its planned facility modifications and renovations.

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