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Turning a Liability into an Asset!

The Story of an Old Power Plant
by Richard Dupuy, Robert Ashworth, and Lydia Frenzel

Editor's Note: This article has been adapted from a paper published in the Proceedings of the 2001 WJTA American Waterjet Conference and presented in August at the WJTA convention, in Minneapolis. Additional background material has been added from the Austin Chronicle and the Journal of Protective Coatings & Linings (JPCL) has been added.


Sitting vacant, since 1976, on the banks of the Comal River in New Braunfels, Texas, is the Comal Power Plant. Built in 1926, the plant is located at the entrance to Landa Park, the largest park in Texas. The June 6, 2000 edition of the Austin Chronicle records that "in its 47 years of service, the Comal Power Plant contributed substantially to the development of Central Texas. When it was built, less than 2% of Texas farms had electricity. At one time, it was the main electric generating plant for San Antonio and helped that city attract its military bases. By the time it closed, all of its 60,000 kWh of production were used by New Braunfels."

Granted, the structure could have been mothballed or demolished, but instead the plant's owner decided to refurbish the building, creating a luxury hotel, restaurant, and conference center. Preliminary plans call for 120 rooms, in addition to more than 40 cottages, all designed to grace the 28 acres along the river. The area is home to 3 endangered species and more than 63 different species of flora and fauna.

This conversion process has not been an easy task. According to the Chronicle article, "Because the building was constructed around coal handling equipment, boilers, and furnaces that stretch nearly

Comal Power Plant

the full 100-foot height from floor to ceiling, there are few floors for rooms. Also complicating the new construction is that the building went up in three sections, each with a different base line.

"The removal of the lead based paint and repainting that was completed from September 1999-July 2000 was just one step in a multi-year, multi-stage project. For this refurbishment project, the owner had spent more than a decade on environmental cleanup and other site work, including the asbestos, PCBs, landfills, and repairs on the Comal Dam, which helps control the level of nearby Landa Lake. The investment could total as much as $11 million.

Condition of the Site

Piles of rust had accumulated on the floor of the plant since the metal had been exposed during the asbestos remediation. Small animals had made their homes in the plant; pigeons roosted in the rafters. Tests showed that the levels of lead content in the paint ranged from 0.3 to 13.5% by weight. Because this was to be used for the general public and might be turned into apartments, U.S. Department of Housing and Urban Development's (HUD) Lead Based Paint-Interim Guidelines for Hazard Identification and Abatement in Public and Indian Housing were followed. This is an unusual requirement for an industrial lead-based project (lbp) project. Pre-job wipes provided results from 220 to 11,790 mg/sq.ft.

The cleaning and sealing task appeared daunting. The amount of structural steel (walls and flat surfaces) covered approximately 55,000 sq.ft. (about the area equivalent to a football field). As for the 363,700-sq. ft. mass of complex shaped steel beams that needed to be cleaned and coated, imagine cleaning 7.6 football fields of area all in the shape of the goalposts. No robotic equipment was used during the project.

Comal Power Plant

Going into the project, the known hazards included

  • physical safety concerns including hazards from falling object, i.e. fire bricks, holes in the floors, and water or bird/animal feces; and
  • health hazards from lead paint, asbestos, and the presence of large amounts of bird feces. There is the potential for one to contract hypersensitivity pneumonitis, or bird fancier's lung, through exposure to organic debris.

Key Personnel

The owner, contractor, and coatings manufacturer formed the nucleus of the team that would meet the challenges of such a project. The owner or operator of the facility initiated and controlled the project often with the assistance of an engineering or planning firm who may have acted for the owner. Yet, the bid specification language allowed all three viewpoints to come together which permitted a "new or emerging" process to become an accepted process. Environmental regulations, health and safety, and performance, along with the cost drivers of location (mobilization), containment, and waste disposal, propelled and continue to propel the decision-making processes.

The bid document was opened to all types of technologies including dry blasting, wet abrasive blasting, waterjetting (WJ), and power tool cleaning as appropriate. The bid document included consideration of the amount of material released to the air and the total amount of hazardous waster to be disposed.

Selecting the Process

Over the past few years, the owner had shifted to more WJ as a surface preparation process in maintenance projects based on economics. The use of WJ was possible because the older surfaces already had had a primary surface preparation. The owner also wanted to use a process that was environmentally friendly, so the decision was made to use WJ in removing the lead paint. Richard Dupuy, UHP Projects, Inc., writes in his article "Ultra-High-Pressure Waterjetting for Maintenance Coatings Applications," JPCL, July 2001, that "a 1995 report from the National Institute for Occupational Safety and Health (NIOSH) on lead abatement hazards states the following about WJ: 'The water suppresses the dust by agglomerating the dust into water droplets.'" Eliminating the dust reduces the amount of exposure to the airborne lead. Also, the owner was familiar with both dry abrasive blasting and WJ and had seen the cost to remove paint increase as more EPA and OSHA regulations were established.

In working with the coatings manufacturer, the owner had definite ideas about the coatings to be used since he believes that the high solids, low volatile organic compounds (VOC) approach that met California air emissions is part of the commitment to pollution prevention and waste minimization.

A technical representative from the coatings manufacturer assisted the owner in reviewing the general request for bid and selecting a coating system suitable for industrial and commercial usage since there would be an indeterminate time before the building was occupied. Once the project began, another technical representative from the coatings manufacturer moved to New Braunfels to oversee the project.

Health and Safety

In part because of the many individuals hired from the community to do painting, general work, and WJ, a comprehensive health and safety plan was implemented early. Between 60-65 people were used on the project between the WJ, scaffolding, electricians, and environmental personnel. The contractor had complete control of the building and workforce. Some of the new personnel found permanent positions. With safety of paramount importance, a full time safety person led a safety meeting every day. Employees notified the contractor of each and every problem as they saw it, not later.

During the first ten days of work, ambient air monitoring was measured. Fifteen samples were taken with only one above the "no detection" level. After the air monitoring results were reviewed, project management made the decision to remove the respirator requirements initially enforced during the testing procedures and to implement a random sampling as necessary to ensure personnel safety. These types of readings are typical on UHP lead abatement projects. The safety precautions focused on personal hygiene, i.e. washing hands and face, and changing clothes in the change room. The emphasis was "Do not take lead home."

The Project

Environmental concerns were the first things to be addressed. Lined, sand-filled, bermed containments for all of the equipment and pumps were set up to contain any diesel spills with easy clean up. The contractor set up plumbing to ensure water volume to the farthest areas. Gutter work for the windows was also completed.

Windows, windows everywhere. With over 300 panes and frames (mostly broken and unable to be shut tightly), the windows proved fairly easy to clean. With a change in pressure and nozzles to fit the conditions, the lbp removal went just as planned . The gutters caught both interior and exterior water from the cleaning operations and directed the water into the building for the collection sump. Ground tarps and geotextile materials were placed to collect any chips. Use of man-lifts and swing-stages were necessary to complete the work on the building's exterior. The use of small, fine hand brushes to paint the muttons and crosspieces proved time consuming. It was tedious since the opening mechanism is chain driven and couldn't be seen until the painters got into the project.

The brick surfaces varied from old steel with multi-layered paint, to hard brick, to horse hair filled mortar and very soft, old brick. The paint over the soft interior stucco and concrete was softened with biodegradable chemical strippers and washed down gently. Much of the mortar consisted of sandstone and horsehair.

Man lifts, scaffolding, and dance floors were also necessary to complete much of the interior cleaning. It did not take long to discover that the WJ and painting could proceed faster than the staging could be erected and moved.

Surface Preparation

The owner worked with coatings manufacturers to supply coatings that could go over tightly adherent existing coating or tight primer. They found that field abatement, not total removal, would be cost and performance effective. For the most part, the existing paint system was easily removed to the NACE No.5-SSPC SP-12 surface preparation of WJ-3 with retention of tightly adherent primer.

The contractor hit one section that had a tightly adherent black layer that was difficult to remove. It was initially identified as paint but proved to be mill scale.

The areas were pressure washed after UHP work was completed in an area and the surface preparation was complete. The pressure washing was used to remove general dust as well as loose flash rust. After an area was completed, an intermediate coat and topcoat were applied."

Coating System

The owner had a history of 5-6 years performance with certain urethane coatings in prior industrial and dam projects over a waterjet cleaned surface and had success with products containing micaceous iron oxide (MIO). While originally planning on using three coatings that all contained MIO, when a potential developer was identified during the course of the project, the owner went with a primer and semi-gloss topcoat to take advantage of the cost savings of having the scaffolding already in place, eliminating the need to have the building scaffold again for coatings applications. The coatings manufacturer felt that the two coats would be quite sufficient because this is a low stress exposure with no UV exposure. The coating, a single-component, moisture-cured urethane (MCU) is very reliable, easy to use, and very user friendly.

For all interior structural steel, interior plates, ladders, doors, exterior signs, windows and frames, and awnings, the coating system was primer and an attractive semi-gloss, luster topcoat with the desired finish color to match existing colors on doors, windows, signs, and ceilings. The exterior concrete coating system was a buff primer and a luster topcoat to hide the multiple tones of the underlying concrete.

Proper Waste Management

To meet the HUD guidelines for closure on the building, the entire structure was pressure washed before wipe tests were taken. All areas were prepared to provide closure wipe tests agreed upon by the owner and the contractor.

With the river right next to the plant, a double 4-ft. high silt fence was built that was bermed. From the building to silt fence, a double layer of enviro screen was laid. Water was collected that came from the building through gutters and was put back into the building where it was stored. There was no contamination of the soil.

On some of the windows, where paint was coming off in chunks, 100-mesh enviroscreens were used to collect the paint and chips along the way. The screens were place out 30 feet from the building.

Most of the wastewater used on the project was collected from the concrete floors in the interior of the building and pumped to a holding tank and a large sump pump. The solids were allowed to settle during the project. Retained water evaporated during this time. The water was separated from the solids through decanting and filtrations. After the water was tested for heavy metals by an independent lab using the TCLP method, the non-hazardous 400,000 gallons of effluent water was disposed through the municipal water treatment facility at a cost of $2.79 /1,000 gallons (0.003 dollars per gallon) or a total cost of $1,126.

The painting process generated approximately 44,000 lbs. of hazardous waste (paint cans and other solids) that were disposed of by the owner. This waste stream included an estimated 4,000 lbs. of waste paint thinner.

Another 10,000 gallons of hazardous waste sludge comprised of the solids that settled from the water was disposed of by the owner at an estimated cost of $20,000.

It is estimated that the project savings were over $500,000 by using UHP WJ technology over abrasive blasting. These savings resulted from minimal containment requirements, reduced waster disposal, and high production rates.

Benefits of WJ

For lead abatement projects, the use of UHP WJ technology provides reduced waste stream, minimal environmental impact, no dust, and greatly reduced liabilities. Worker and surrounding area exposure to contaminants are minimized. The advantage of knowing approximate disposal costs prior to the start of each project make budgeting easier.

Coatings manufacturers have accepted this surface preparation technology and are approving their products in conjunction with properly prepared surfaces using UHP WJ. Many have issued standards for their own products or have endorsed published standards. The industry has successfully cleaned and recoated millions of square millions of square feet of area in a variety of applications.

Summary

Transformation of the Comal Power Plant complex will generate tax revenues for the city with new jobs and support service. The economic impact for the city could be at least $12 million a year. The removal of the lead-based paint and repainting was nearly the last step before construction could begin. The use of UHP WJ in removing the lbp not only provided additional safety for the community, but is an additional project that continues to show this technology to be a cost effective, environmentally friendly technology for many maintenance coating applications.

Richard Dupuy is CEO of UHP Projects, Inc. Robert Ashworth is COO of the company.
Lydia M. Frenzel, Ph.D., serves as executive director of the Advisory Council.



LCRA WASTE DATA

Interior structural steel

363,700 Ft2

Exterior structural steel

21,250 Ft2

Interior Masonry

28,600Ft2

Comal Power Plant

WASTE GENERATED AMOUNT DISPOSAL

Waste Solids

44,000 lbs

$16,000

Non-Hazardous Waste Water

400,000 gallons

$146

Hazardous Waste Sludge

10,000 gal

$ 4,000


If abrasive blasting would have been used an estimated 1,640 tons (8 lbs/ft2) of potentially hazardous waste would have been generated.


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