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This document provides details for a federal contract solicitation. Solicitation number 36C24121R0163 from the Department of Veterans Affairs Veterans Health Administration Veterans Integrated Service Network 1 seeks proposals for the Z1DA--Mental Health Outpatient Renovation B5 Project 52A5-19-305. The opportunity type is listed as a solicitation. The solicitation is for renovations to support outpatient mental health services at the Brockton and Jamaica Plain VA medical centers in Massachusetts. Responses are due on an unspecified date. The award date is also unspecified. No other terms or conditions are included in this brief document.

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CRAWLSPACE SOILS ASBESTOS SAMPLING

SUMMARY REPORT

VA Contract No. VA 241-16-P-0357

VA BOSTON HEALTHCARE SYSTEM (HCS)

BROCKTON AND JAMAICA PLAIN

MASSACHUSETTS

Mabbett Project No. 2014001.002

February 17, 2016

Mabbett & Associates, Inc. www.mabbett.com

5 Alfred Circle Bedford, MA 01730-2318 T. 800-877-6050 Massachusetts | Virginia | Rhode Island | New Jersey

Prepared for:

U.S. Department of Veteran Affairs Boston HCS 940 Belmont Street Brockton, Massachusetts 02301

© 2016, Mabbett & Associates, Inc.

http://upload.wikimedia.org/wikipedia/en/0/0e/US-DeptOfVeteransAffairs-Seal-Large.png

VAMC BOSTON CRAWLSPACE SAMPLING REPORT

Boston HCS | Brockton and Jamaica Plain, MA

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS S:\ADMINA\2014001 VA Boston HC\VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716.doc

ACKNOWLEDGEMENT

This Crawlspace Soils Asbestos Sampling Summary Report has been prepared for the sole and exclusive use of the United States Department of Veterans Affairs, VA Boston Healthcare System (Client). This report is subject to and issued in connection with Solicitation Number VA241-16-Q-0104, and Contract Number VA241-16-P-0357 awarded to Mabbett by the Client on December 14, 2015, with one modification to the original contract dated January 5, 2016.

Any use or reliance upon information provided in this plan, without the specific written authorization of the Client and Mabbett & Associates, Inc. (Mabbett®), shall be at the User’s sole risk.

The report presented herein is based solely upon the laws and regulations existing as of the date of this report as well as information gathered to date. Should further environmental or other relevant information be developed at a later date, the Client should bring such information to the attention of Mabbett as soon as possible. If any of the information provided to Mabbett for the preparation of this report is incorrect, incomplete, or subject to change based upon an evaluation, Mabbett would wish to modify this report and its conclusions.

This report was prepared by the following Mabbett & Associates, Inc. personnel:

Kevin Donovan MA Asbestos Inspector (#AI002014)

This report has been reviewed and approved by:

Christopher L. Mabbett, CPG, PG, PMP Director of Operations

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS S:\ADMINA\2014001 VA Boston HC\VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716.doc

TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION & EXECUTIVE SUMMARY

1.1 APPLICABLE MASSDEP REGULATIONS……………………………………………………………………………………………….3

1.2 SITE DESCRIPTION

2.0 SAMPLING METHODOLOGY

3.0 ANALYTICAL METHODOLOGIES

4.0 SUMMARY OF ASBESTOS CONTAINING MATERIALS

5.0 SURVEY LIMITATIONS

6.0 FINDINGS AND RECOMMENDATIONS

Tables

1 Summary of Detected Asbestos Crawlspace Building Locations, Brockton VAMC 2 Summary of Detected Asbestos Crawlspace Building Locations, Jamaica Plain VAMC 3 Summary of Non-Detect Asbestos Crawlspace Building Locations, Jamaica Plain VAMC 4 Brockton VAMC - Dust and Soil Analytical Summary of Results 5 Jamaica Plain VAMC – Dust and Soil Sample Analytical Summary of Results

Drawings - Brockton

1 Building #1 2 Building #2 3 Building #3 4 Building #4 5 Building #5 6 Building #8 7 Building #22 8 Building #23 9 Building #24 10 Building #25 11 Corridors & Tunnels

Drawings – Jamaica Plain

12 Building #1 13 Building #1B 14 Building #2

Appendices Appendix A Laboratory Reports, Chains of Custody, and DLS Laboratory Certificate Appendix B Asbestos Inspector Certificates

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS

1.0 INTRODUCTION & EXECUTIVE SUMMARY

Mabbett® performed a limited asbestos soil and dust sampling program in the accessible crawlspaces beneath ten

(10) buildings and connecting corridor tunnels at the Brockton VAMC Campus and beneath three (3) buildings at the Jamaica Plain Campus from December 22, 2015, through January 12, 2016. The Brockton VAMC is located at 940 Belmont Street in Brockton, Massachusetts, and at the Jamaica Plain VAMC is located at 150 South Huntington Avenue, Jamaica Plain, Massachusetts. The soil and dust sampling program was performed in accordance with the established scope of work described in Contract No. VA241-16-P-0357 dated December 14, 2015, and modified on January 5, 2016. The site survey work was performed during December 2015 and January 2016 by appropriately credentialed Mabbett personnel as required. During the course of the survey, 246 soil and dust samples were collected. Samples were submitted to ProScience Analytical Services, Inc. located in Woburn, Massachusetts, a Massachusetts Department of Labor Standards asbestos analytical services certified laboratory (AA000156), American Industrial Hygiene Association (AIHA) and National Voluntary Laboratory Accreditation Program (NVLAP code 200090-0) accredited laboratory for bulk asbestos analysis by Polarized Light Microscopy (PLM) in accordance with U.S. EPA Method 600/R-93/116 and transmission electron microscopy (TEM). Of the 246 samples submitted for analysis 115 samples detected asbestos at a concentration of greater than 0%.

1.1 APPLICABLE MASSDEP REGULATIONS

The Massachusetts Department of Environmental Protection (MassDEP) 310 CMR 7.00 defines the following:

ASBESTOS-CONTAINING MATERIAL (ACM) as any material containing 1% or more asbestos as determined by a laboratory using protocols set forth in the Method for the Determination of Asbestos in Bulk Building Materials found in EPA report EPA/600/R-93/116, or another method as directed by the Department.

ASBESTOS-CONTAINING WASTE MATERIAL (ACWM) means any ACM removed during a demolition or renovation project and anything contaminated with asbestos in the course of a demolition or renovation project including, but not limited to, asbestos waste from control devices, bags or containers that previously contained asbestos, contaminated clothing, materials used to enclose the work area during the demolition or renovation operation, and demolition or renovation debris. ACWM shall also include ACM on and/or in facility components that are inoperable or have been taken out of service and any ACM that is damaged or deteriorated to the point where it is no longer attached as originally applied or is no longer serving the intended purpose for which it was originally installed.

Although never finalized, MassDEP also issued Asbestos-in-Soil Draft Final Regulations and Policies in October 2007.

The changes were intended to revise the Massachusetts Contingency Plan regulations and clarify the notification and cleanup requirements for asbestos fibers and asbestos- containing material in soil. The proposed changes included new notification requirements and amendments of 310 40.0030, Management of Remediation Waste, to ensure that off-site management of soil containing asbestos meets all applicable state and federal requirements which were intended as proposed changes to the Massachusetts Contingency Plan regulations.

1.2 SITE DESCRIPTION

The Brockton VAMC Campus was built in 1950s and consists of various buildings with connecting sub-basement crawlspaces. The Jamaica Plain VAMC Campus was built in the 1950s and consists of various buildings with sub-basement crawlspaces. All of the crawl spaces are constructed of concrete walls and ceilings with varying dirt or concrete floors. The soils and concrete floors in the crawls spaces at both sites, Brockton and Jamaica Plain, were sampled for asbestos content to determine if there was a potential for asbestos exposure to employees and

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS S:\ADMINA\2014001 VA Boston HC\VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716.doc contractors performing work in the crawlspaces. Per the direction of the Client the soils in the crawlspaces beneath Building 60 and 61 at the Brockton VAMC were not sampled, and the soils in the crawlspace beneath Building 23 was sampled. A summary of the building location and crawlspaces sampled an approximate square footages as provided by the VA are presented below:

Brockton VAMC Campus Jamaica Plain VAMC Campus Building 1 sub-basement – 11,975 ft2 Building 1 sub- basement - 19,000 ft2

Building 2 sub-basement - 7,300 ft2 Building 2 sub-basement - 2,000 ft2

Building 3 sub-basement – 7,990 ft2 Building 1B sub-basement - 2,000 ft2

Building 4 sub-basement - 11,200 ft2

Building 5 sub-basement– 4,397 ft2

Building 8 sub-basement – 7,800 ft2

Building 22 sub-basement – 3,260 ft2

Building 23 sub-basement – 7,900 ft2

Building 24 sub-basement – 281 ft2

Building 25 sub-basement – 13,545 ft2

Connecting Corridors Tunnel – 14,430 ft2

2.0 SAMPLING METHODOLOGY

The soil and dust sampling program was performed from December 22, 2015, through January 12, 2016, by Katherine Hanrahan, Kevin Donovan and Darren Andrews, of Mabbett. Mr. Donovan is a licensed Massachusetts DLS asbestos inspector (Certification #AI002014 see Appendix B). Suspect ACM dust and soil samples were collected using United States Environmental Protection Agency (U.S. EPA) National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 763 and Asbestos Hazard Emergency Response Act (AHERA) protocols. Every effort was made during the field work to access areas as necessary however due to the configuration of some of the crawlspaces full access was not available in all of the building surveyed. The purpose of this sampling program was to collect representative samples in the crawlspaces and not to perform a full-scale characterization of the soils present. As such, suspect ACM sampling was generally conducted according to the following sampling plan as outlined in the contract’s SOW:

(a) Dust and soil material:

(1) At least one sample for every 500 ft2; and/or

(2) At least three samples collected from each accessible entry area of the crawlspace.

The dust samples were collected using a battery powered Gillian personal air pump set at a flow rate between 2.0 liters per minute (LPM) and 2.5 LPM with a 25 millimeter (mm) PCM air cassette. The cassette was tracked over a one square foot area, side to side slowly and then back over the same area diagonally. The cassette was then removed from the pump, the caps were put back on the cassette, the cassette was labeled and logged on to the chain-of-custody, and submitted to the laboratory for analysis.

The soil samples were collected to a maximum depth of approximately three (3) inches using a small stainless steel garden spade. The soil sample was then placed into a three (3) inch by five (5) inch plastic zip lock bag, labeled and logged on to the chain-of-custody, and submitted to the laboratory for analysis. The stainless steel spade was appropriately decontaminated between soil sampling locations. Mabbett placed a temporary labeled orange flag at the approximate soil sample locations (where possible) for future field identification purposes.

No pictures of the sampling locations were taken, per the direction of the Client and confirmed in an e-mail

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS S:\ADMINA\2014001 VA Boston HC\VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716.doc communication from the GEMS Coordinator, Bryan Soltysik, on December 22, 2015.

The analytical laboratory reports identified dust and soil samples as positive for asbestos that met criteria of greater than or equal to one percent (>1%) asbestos and identified “trace” as samples with greater than zero percent (> 0%) but less than one percent (<1%) asbestos. Dust and soil samples that tested negative for the presence of asbestos are identified as containing zero percent (0%) asbestos e.g. No Asbestos Detected (NAD) on the laboratory reports.

Laboratory reports and chain of custody documentation are provided in Appendix A of this report.

3.0 ANALYTICAL METHODOLOGIES

A total of 213 soil and 33 dust samples were analyzed by polarized light microscopy (PLM) analysis in accordance with U.S. EPA Method 600/R-93/116. PLM sample results that were observed to contain trace asbestos (>0% but <1%) were re-analyzed (78 samples) using transmission electron microscopy (TEM) to confirm asbestos content. These samples were processed to remove non-asbestos interference. The remaining residue was examined using a Philips CM-12 or 420 transmission electron microscope equipped with selected area electron diffraction (SAED) and an EVEX energy dispersive x-ray analyzer.

The soil and dust samples were submitted to ProScience Analytical Services, Inc. of Woburn, Massachusetts for PLM and TEM analysis following chain-of-custody protocols. ProScience is a Massachusetts Department of Labor Standards (DLS) asbestos analytical services certified laboratory (AA000156), American Industrial Hygiene Association (AIHA) and National Voluntary Laboratory Accreditation Program (NVLAP code 200090-0) accredited laboratory.

4.0 SUMMARY OF ASBESTOS CONTAINING MATERIALS

Tables 1 and 2 below present a summary of the buildings where at least one of the samples collected had asbestos detected. The connecting corridor tunnel dust samples collected from the concrete floors tested non-detect for asbestos. Table 3 below presents a summary of buildings surveyed where all of the samples collected tested non-detect for asbestos.

Table 1 - Summary of Detected Asbestos Building Crawlspace Locations

Brockton VAMC

Location Material

Building 1 crawlspace Soil Building 2 crawlspace Soil Building 3 crawlspace Soil Building 4 crawlspace Soil Building 5 crawlspace Soil Building 8 crawlspace Soil Building 22 crawlspace Soil Building 23 crawlspace Soil Building 24 crawlspace Soil Building 25 crawlspace Soil Connecting corridor tunnel Soil

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS

Table 2 - Summary of Detected Asbestos Building

Jamaica Plain VAMC

Building 1 sub-basement crawl space Soil

Table 3 - Summary of Non-Detect Asbestos Building

Building 1B sub-basement crawl space Soil

Building 2 sub-basement crawl space Soil

NOTES: Text in BOLD above indicates asbestos detected.

Approximate soil and dust sample locations are presented on Drawings 1 through 14 attached. Sample locations marked by a blue dot signifies that no asbestos was detected at that location, an orange dot signifies that trace asbestos was detected at a concentration greater than zero percent (>0%) but less than one percent (<1%), and a red dot signifies that asbestos was detected at a concentration greater than or equal to one percent (≥1%).

5.0 SURVEY LIMITATIONS

This survey was a screening survey and not a comprehensive asbestos in soil characterization survey. Only accessible and representative areas (approximately one sample every 500 sq. feet) were included in the sampling. Mabbett does not claim to have identified all of the asbestos containing/contaminated materials that may be present in the crawlspaces surveyed. In addition the soils in the crawlspaces may be disturbed so that areas that appeared to not have asbestos contaminated soils could later be contaminated. Mabbett has conducted this assessment with reasonable care and has performed this project within generally accepted industry standards. There can be no assurances, and Mabbett makes no assurances, that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results reported herein.

6.0 FINDINGS AND RECOMMENDATIONS

Nearly all of the crawlspaces surveyed had some asbestos detected as summarized in the tables above. Prior to initiating plans for maintenance activities, the Boston Healthcare System should review the dust and soil sampling results to determine whether any of the soils and/or concrete floors identified as ACM will be disturbed by proposed future work activities. This report may not be used as a renovation/demolition asbestos abatement work plan or an Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) type inspection.

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Boston HCS

Under current MassDEP regulations 310 CMR 7.15, following any asbestos abatement activity, an inch of soil shall be removed from dirt floors and disposed of as ACWM. Clean-up shall be to the level of no visible debris.

Mabbett recommends that if crawlspaces must be routinely entered and asbestos containing/contaminated soil must be disturbed in these crawlspaces, that the Boston HCS consider removing or encapsulating the contaminated soil utilizing a licensed asbestos abatement contractor in accordance with applicable regulations. If the asbestos containing/contaminated soils are to be removed Mabbett would recommend removing the surficially impacted three inches of soils that were sampled and tested positive, followed by removing one additional inch of “clean” material for a totol of four inches. As stated in 310 CMR 7.15 “Clean-up shall be to the level of no visible debris.”

If staff or contractors are going to enter the crawlspaces where asbestos was detected they need to be adequately trained and protected including the wearing of appropriate respirators if exposure to asbestos is expected to exceed Permissible Exposure Limits. Specific written procedures should be established by the Safety Office for entry into these spaces based on the results of this survey.

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4

VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 01 Building #23 service floor crawl space – SW (pool) Soil NAD -

BS - 02 Building #23 service floor crawl space – West (pool) Soil NAD -

BS - 03 Building #23 service floor crawl space – NW (pool) Soil 2% Chrysotile Asbestos -

BS -04 Building #23 service floor crawl space – South (pool) Soil NAD -

BS - 05 Building #23 service floor crawl space – SE (pool) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 06 Building #23 service floor crawl space – East (pool) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 07 Building #23 service floor crawl space – North (pool) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 08 Building #23 service floor crawl space – North (pool) Soil 2% Chrysotile and Trace

Amosite Asbestos -

BS - 09 Building #23 service floor crawl space – North (pool) Soil NAD -

BS - 10 Building #23 service floor crawl space – NE (pool) Soil Trace Chrysotile

Asbestos 2.91% Chrysotile

Asbestos

BS - 11 Building #23 service floor crawl space – North (gym) Soil NAD -

BS - 12 Building #23 service floor crawl space – Center (gym) Soil NAD -

BS - 13 Building #23 service floor crawl space – South (gym) Soil NAD -

BS - 14 Building #23 service floor crawl space – SE (gym) Soil NAD -

BS - 15 Building #3 stairwell 2 - 3 crawl space East Soil NAD -

BS - 16 Building #3 stairwell 2 - 3 crawl space East Center Soil NAD -

BS - 17 Building #3 stairwell 2 - 3 crawl space West Center Soil 2% Chrysotile Asbestos -

BS - 18 Building #3 stairwell 2 - 3 crawl space West Soil NAD -

BS - 19 Building #3 stairwell 2 - 3 crawl space Landing Soil 2% Chrysotile and Trace

Amosite Asbestos -

BS - 20 Building #3 stairwell 1 - 3 crawl space NE Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 21 Building #3 stairwell 1 - 3 crawl space North Center Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 22 Building #3 stairwell 1 - 3 crawl space South Soil Trace Chrysotile and

Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 23 Building #3 stairwell 1 - 3 crawl space SE Soil 2% Chrysotile Asbestos -

BS - 24 Building #3 stairwell 3 - 3 crawl space East Soil Trace Chrysotile

Asbestos 1.56% Chrysotile

Asbestos

BS - 25 Building #3 stairwell 3 - 3 crawl space Landing South Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 26 Building #3 stairwell 3 - 3 crawl space West Soil 2% Chrysotile Asbestos -

BD - 27 Underground corridor tunnels near 21 crawl space Dust NAD -

BD- 28 Underground corridor tunnels near 21 crawl space Dust NAD -

BD - 29 Underground corridor tunnels near 21 crawl space Dust NAD -

BD - 30 Underground corridor tunnels near 21 crawl space Dust NAD -

BD - 31 Underground corridor tunnels near 4 crawl space Dust NAD -

BD - 32 Underground corridor tunnels near 4 crawl space Dust NAD -

BD - 33 Underground corridor tunnels near 4 crawl space Dust NAD -

BD - 34 Underground corridor tunnels near 4 crawl space Dust NAD -

BD - 35 Underground corridor tunnels near 4 crawl space Dust NAD -

BD - 36 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 37 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 38 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 39 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 40 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 41 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 42 Underground corridor tunnels near 20 crawl space Dust NAD -

BD - 43 Underground corridor tunnels near 20 crawl space Dust NAD -

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BD - 44 Underground corridor tunnels near 5 crawl space Dust NAD -

BD - 45 Underground corridor tunnels near 5 crawl space Dust NAD -

BD - 46 Underground corridor tunnels near 5 crawl space Dust NAD -

BD - 47 Underground corridor tunnels near 5 crawl space Dust NAD -

BD - 49 Underground corridor tunnels near 23 crawl space Dust NAD -

BD - 50 Underground corridor tunnels near 23 crawl space Dust NAD -

BD - 51 Underground corridor tunnels near 23 crawl space Dust NAD -

BD - 52 Underground corridor tunnels near 23 crawl space Dust NAD -

BD - 53 Underground corridor tunnels crawl space SE corner Dust NAD -

BS - 54 Underground corridor tunnels near 7 Soil Trace Chrysotile and 2%

Amosite Asbestos -

BS - 55 Underground corridor tunnels near 7 Soil Trace Chrysotile and 3%

Amosite Asbestos -

BS - 56 Underground corridor tunnels near 7 Soil Trace Chrysotile and 2%

Amosite Asbestos -

BS - 57 Underground corridor tunnels near 7 Soil Trace Chrysotile and

Trace Amosite Asbestos 1.05% Chrysotile

Asbestos

BS - 58 Underground corridor tunnels near 7 Soil Trace Chrysotile and

Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 59 Underground corridor tunnels near 22 Soil Trace Chrysotile and

Trace Amosite Asbestos 1.08% Chrysotile

Asbestos

BS - 60 Underground corridor tunnels near 22 Soil Trace Chrysotile and 2%

Amosite Asbestos -

BS - 61 Underground corridor tunnels near 22 Soil NAD -

BS - 62 Underground corridor tunnels near 22 Soil 2% Chrysotile and Trace

Amosite Asbestos -

BS - 63 Underground corridor tunnels near 25 Soil Trace Chrysotile and

Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 64 Underground corridor tunnels near 25 Soil Trace Chrysotile and

Trace Amosite Asbestos NAD

BS - 65 Underground corridor tunnels near 25 Soil 3% Chrysotile and 2%

Amosite Asbestos -

BS - 66 Underground corridor tunnels near 25 Soil Trace Chrysotile

Asbestos

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 67 Underground corridor tunnels near 8 Soil Trace Chrysotile and

Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 68 Underground corridor tunnels near 8 Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 69 Underground corridor tunnels near 24 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 70 Underground corridor tunnels near 21 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 71 Building #1, basement North crawl space (NW) Soil NAD -

BS – 72 Building #1, basement North crawl space (NW) Soil NAD -

BS - 73 Building #1, basement North crawl space (North center) Soil NAD -

BS - 74

Building #1, basement North crawl space (North center)

Soil

NAD

BS - 75 Building #1, basement North crawl space (NE) Soil NAD -

BS - 76 Building #1, basement North crawl space (NE) Soil NAD -

BS - 77 Building #1, basement North crawl space (NW) Soil NAD -

BS - 78 Building #1, basement East crawl space (SW) Soil NAD -

BD - 79 Building #1, basement East crawl space (SW) Dust NAD -

BS - 80 Building #1, basement East crawl space NW) Soil NAD -

BD - 81 Building #1, basement East crawl space (NW) Dust NAD -

BS - 82 Building #1, basement East crawl space (NE) Soil NAD -

BD - 83 Building #1, basement East crawl space (NE) Dust NAD -

BS - 84 Building #1, basement East crawl space (SE) Soil Trace Chrysotile

Asbestos NAD

BD - 85 Building #1, basement East crawl space (SE) Dust NAD -

BS - 86 Building #1, basement crawl space 008A (SW) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 87 Building #1, basement crawl space 008A (NE) Soil 2% Chrysotile and Trace

Actinolite Asbestos -

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 88 Building #1, basement crawl space 008A (South) Soil Trace Chrysotile

Asbestos NAD

BS - 89 Building #1, basement crawl space 008B (SE) Soil NAD -

BS - 90 Building #1, basement crawl space 008B (NE) Soil NAD -

BS - 91 Building #1, basement crawl space 008B (NW) Soil Trace Amosite Asbestos NAD

BS - 92 Building #1, basement crawl space 008B (SW) Soil NAD -

BS - 93 Building #1, sub-basement crawl space (Entry) Soil 5% Chrysotile and 2%

Amosite Asbestos -

BS - 94 Building #1, sub-basement crawl space (South) Soil 3% Chrysotile and 2%

Actinolite Asbestos -

BS - 95 Building #1, sub-basement crawl space (North) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 96 Building #2 basement crawl space

– stairwell 2 - 2 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 97 Building #2 basement crawl space – stairwell 2 - 2 Soil NAD -

BS - 98 Building #2 basement crawl space

– stairwell 2 - 2 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 99 Building #2 basement crawl space

– mechanical room A5A Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 100 Building #2 basement crawl space

– mechanical room A5A Soil 5% Chrysotile and 5%

Amosite Asbestos -

BS - 101 Building #2 basement crawl space

– mechanical room A5A Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 102 Building #2 basement crawl space

– stairwell 3 - 2 Soil Trace Chrysotile and

Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 103 Building #2 basement crawl space

– stairwell 3 - 2 Soil 5% Chrysotile and 2%

Amosite Asbestos -

BS - 104 Building #2 basement crawl space

– stairwell 3 - 2 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 105 Building #4 basement crawl space

– stairwell B003 (South) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 106 Building #4 basement crawl space

– stairwell B003 (Center) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS – 107 Building #4 basement crawl space

– stairwell B003 (North) Soil 2% Chrysotile Asbestos -

BS - 108 Building #4 basement crawl space

– stairwell B003 (Upper Level) Soil Trace Chrysotile and

Trace Amosite Asbestos NAD

BS - 109 Building #4 basement crawl space

– stairwell B003 (Upper Level) Soil Trace Chrysotile

Asbestos

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 110 Building #4 basement crawl space

– stairwell B003 (Upper Level) Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 111 Building #4 basement crawl space

– stairwell B003 (Upper Level) Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 112 Building #4 basement crawl space – stairwell CS1 Soil NAD -

BS - 113 Building #4 basement crawl space – stairwell CS1 Soil NAD -

BS - 114 Building #4 basement crawl space – stairwell CS1 Soil NAD -

BS - 115 Building #4 basement crawl space – adjacent to C036B Soil NAD -

BS - 116 Building #4 basement crawl space

– adjacent to C036B Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 117 Building #4 basement crawl space

– adjacent to C036B Soil Trace Chrysotile

Asbestos NAD

BS - 118 Building 8 basement crawl space mechanical room C-020 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 119 Building 8 basement crawl space mechanical room C-020 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 120 Building 8 basement crawl space mechanical room C-020 Soil NAD -

BS - 121 Building 24 basement crawl space – stairwell ST-001 Soil 2% Chrysotile Asbestos -

BS - 122 Building 24 basement crawl space – stairwell ST-001 Soil 2% Chrysotile and Trace

Amosite Asbestos

BS - 123 Building 8 basement crawl space – mechanical room A-008 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS -124 Building 8 basement crawl space – mechanical room A-008 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 125 Building 8 basement crawl space – mechanical room A-008 Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 126 Building 8 basement crawl space – mechanical room A-003 Soil NAD -

BS - 127 Building 8 basement crawl space – mechanical room A-003 Soil NAD -

BS - 128 Building 8 basement crawl space – mechanical room A-003 Soil NAD -

BD - 129 Building 8 basement crawl space – mechanical room A-008 Dust NAD -

BD - 130 Building 8 basement crawl space – mechanical room A-008 Dust NAD -

BS - 131 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil Trace Chrysotile

Asbestos

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 132 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil NAD -

BS - 133 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil NAD -

BS - 134 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil NAD -

BS - 135 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 136 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil NAD -

BS - 137 Building 25 – basement crawl space Room – 001 - 25 (South Wing) Soil NAD -

BS - 138 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil NAD -

BS - 139 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil NAD

BS - 140 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil 2% Chrysotile Asbestos -

BS - 141 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 142 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 143 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil Trace Chrysotile and 2%

Amosite Asbestos -

BS - 144 Building 25 – basement crawl space Room – 001 - 25 (East Wing) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 145 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

BS - 146 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 147 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil NAD -

BS - 148 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil NAD -

BS - 149 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil NAD -

BS -150 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil Trace Chrysotile

Asbestos NAD

BS - 151 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil NAD -

BS - 152 Building 25 – basement crawl space Room – 001 - 25 (North Wing) Soil Trace Amosite Asbestos NAD

BS - 153 Building 5 – sub-basement west side Soil NAD -

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 154 Building 5 – sub-basement west side Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos BS -155 Building 5 – sub-basement west side Soil NAD - BS - 156 Building 5 – sub-basement west side Soil NAD - BS - 157 Building 5 – sub-basement west side Soil NAD - BS - 158 Building 5 – sub-basement west side Soil NAD - BS - 159 Building 5 – sub-basement west side Soil NAD - BS - 160 Building 5 – sub-basement west side Soil NAD - BS - 161 Building 5 – sub-basement west side Soil NAD - BS - 162 Building 5 – sub-basement west side Soil NAD - BS - 163 Building 5 – sub-basement west side Soil NAD -

BS - 164 Building 5 – sub-basement west side Soil Trace Chrysotile

Asbestos NAD

BS - 165 Building 5 – sub-basement near stairwell Soil NAD -

BS - 166 Building 5 – sub-basement east side Soil Trace Chrysotile Asbestos

Trace Chrysotile Asbestos

BS - 167 Building 5 – sub-basement east side Soil NAD - BS - 168 Building 5 – sub-basement east side Soil NAD - BS - 169 Building 5 – sub-basement east side Soil NAD - BS - 170 Building 5 – sub-basement east side Soil NAD - BS - 171 Building 5 – sub-basement east side Soil NAD - BS - 172 Building 5 – sub-basement east side Soil NAD - BS - 173 Building 5 – sub-basement east side Soil NAD -

BS - 174 Building 22 – sub-basement right side Soil NAD -

BS - 175 Building 22 – sub-basement right side Soil NAD -

BS - 176 Building 22 – sub-basement right side Soil NAD -

BS - 177 Building 22 – sub-basement right side Soil NAD -

BS - 178 Building 22 – sub-basement right side Soil NAD -

BS - 179 Building 22 – sub-basement right side Soil NAD -

BS - 180 Building 22 – sub-basement right side Soil NAD -

BS - 181 Building 22 – sub-basement right side Soil NAD -

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 4 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 4 – Summary of Dust and Soil Sample Results Brockton VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

BS - 182 Building 22 – sub-basement right side

Soil Trace Chrysotile and Trace Amosite Asbestos

Trace Chrysotile Asbestos

BS - 183 Building 22 – sub-basement right side Soil Trace Chrysotile

Asbestos Trace Chrysotile

Asbestos

BS - 184 Building 22 – sub-basement right side Soil NAD -

BS - 185 Building 22 – sub-basement right side Soil NAD -

BS - 186 Building 22 – sub-basement left side Soil NAD - BS - 187 Building 22 – sub-basement left side Soil NAD - BS - 188 Building 22 – sub-basement left side Soil NAD - BS - 189 Building 22 – sub-basement left side Soil NAD - BS - 190 Building 22 – sub-basement left side Soil NAD - BS - 191 Building 22 – sub-basement left side Soil NAD - BS - 192 Building 22 – sub-basement left side Soil NAD - BS - 193 Building 22 – sub-basement left side Soil NAD - BS - 194 Building 22 – sub-basement left side Soil NAD - BS - 195 Building 22 – sub-basement left side Soil NAD -

NOTES: Text in BOLD font indicates asbestos was detected NAD – No Asbestos Detected

- = Not Analyzed

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 5

Table 5 – Summary of Soil Sample Results

Sample No. Sample Location Description of Material PLM Result TEM Result

JS - 01 Building 1 – C Wing sub-basement crawl space Soil Trace Chrysotile Asbestos and 10% Actinolite -

JS - 02 Building 1 – C Wing sub-basement crawl space Soil 2% Chrysotile and Trace

Amosite Asbestos -

JS - 03 Building 1 – C Wing sub-basement crawl space Soil 2% Chrysotile and Trace

Amosite Asbestos -

JS - 04 Building 1 – C Wing sub-basement crawl space Soil Trace Chrysotile Asbestos Trace Chrysotile

Asbestos

JS - 05 Building 1 – C Wing sub-basement crawl space Soil 2% Chrysotile and Trace

Actinolite Asbestos -

JS - 06 Building 1 – C Wing sub-basement crawl space Soil 3% Chrysotile and 2%

Amosite Asbestos -

JS - 07 Building 1 – C Wing sub-basement crawl space Soil 2% Chrysotile and Trace

Amosite Asbestos -

JS - 08 Building 1 – C Wing sub-basement crawl space Soil 10% Actinolite Asbestos -

JS - 09 Building 1 – C Wing sub-basement crawl space Soil 2% Actinolite and Trace

Amosite Asbestos -

JS - 10 Building 1 – D Wing sub-basement crawl space Soil Trace Chrysotile Asbestos 4.35% Chrysotile

Asbestos

JS - 11 Building 1 – C Wing sub-basement fire alarm room Soil Trace Chrysotile Asbestos Trace Chrysotile

Asbestos

JS - 12 Building 1 – D Wing sub-basement crawl space Soil Trace Amosite Asbestos NAD

JS - 13 Building 1 – D Wing sub-basement crawl space Soil NAD -

JS - 14 Building 1 – D Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos Trace Chrysotile

Asbestos

JS - 15 Building 1 – D Wing sub-basement crawl space Soil NAD -

JS - 16 Building 1 – D Wing sub-basement crawl space Soil NAD -

JS - 17 Building 1 – D Wing sub-basement crawl space Soil Trace Chrysotile Asbestos Trace Chrysotile

Asbestos

JS - 18 Building 1 – D Wing sub-basement crawl space Soil 2% Chrysotile and Trace

Amosite Asbestos -

JS - 19 Building 1 – D Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos Trace Chrysotile

Asbestos

JS - 20 Building 1 – D Wing sub-basement crawl space Soil Trace Chrysotile Asbestos Trace Chrysotile

Asbestos

JS - 21 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile Asbestos 1.55% Chrysotile

JS - 22 Building 1 – E Wing sub- Soil 2% Chrysotile Asbestos -

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 5 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 5 – Summary of Soil Sample Results Jamaica Plain VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result basement crawl space

JS - 23 Building 1 – E Wing sub-basement crawl space Soil 2% Chrysotile and Trace

Amosite Asbestos -

JS - 24 Building 1 – E Wing sub-basement crawl space Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

JS - 25 Building 1 – E Wing sub-basement crawl space Soil NAD -

JS - 26 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos 1.64% Chrysotile

Asbestos

JS - 27 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile Asbestos 4.02% Chrysotile

Asbestos

JS - 28 Building 1 – E Wing sub-basement crawl space Soil Trace Amosite Asbestos Trace Chrysotile

Asbestos

JS - 29 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos 3.88% Chrysotile

Asbestos

JS - 30 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile Asbestos Trace Chrysotile

Asbestos

JS - 31 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos 3.33% Chrysotile

Asbestos

JS - 32 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos 1.71% Chrysotile

Asbestos

JS - 33 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile Asbestos NAD

JS - 34

Building 1 – E Wing sub-basement crawl space Soil

5% Chrysotile, 5% Amosite and Trace Actinolite

Asbestos

JS - 35 Building 1 – E Wing sub-basement crawl space Soil NAD -

JS - 36 Building 1 – E Wing sub-basement crawl space Soil NAD -

JS - 37 Building 1 – E Wing sub-basement crawl space Soil NAD -

JS - 38 Building 1 – E Wing sub-basement crawl space Soil NAD -

JS - 39 Building 1 – E Wing sub-basement crawl space Soil Trace Chrysotile and Trace

Amosite Asbestos 1.57% Chrysotile

Asbestos

JS - 40 Building 1 – E Wing sub-basement crawl space Soil 2% Chrysotile Asbestos -

JS - 41

Building 1 – E Wing sub-basement crawl space steam alley

Soil Trace Amosite Asbestos 1.70% Chrysotile Asbestos

JS - 42 Building 1 – E Wing sub-basement storage room Soil Trace Chrysotile and Trace

Amosite Asbestos NAD

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Table 5 VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

Table 5 – Summary of Soil Sample Results Jamaica Plain VAMC

Sample No. Sample Location Description of Material PLM Result TEM Result

JS - 43 Building 1 – B Wing sub-basement mechanical room Soil 5% Chrysotile and Trace

Amosite Asbestos -

JS - 44 Building 1B – Dirt room sub-basement crawl space Soil NAD -

JS - 45 Building 1B – Dirt room sub-basement crawl space Soil NAD -

JS - 46 Building 1B – Dirt room sub-basement crawl space Soil NAD -

JS - 47 Building 1B – Dirt room sub-basement crawl space Soil NAD -

JS - 48 Building 2 – mechanical room sub-basement crawl space Soil NAD -

JS - 49 Building 2 – mechanical room sub-basement crawl space Soil NAD -

JS - 50 Building 2 – mechanical room sub-basement crawl space Soil NAD -

JS - 51 Building 2 – mechanical room sub-basement crawl space Soil NAD -

NOTES: Text in BOLD font indicates asbestos was detected

NAD – No Asbestos Detected

- = Not Analyzed

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Drawings

VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL_021716

DRAWINGS

Brockton and Jamaica Plain

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Appendix A

APPENDIX A

Laboratory Reports, Chains of Custody, and

DLS Certification

© 2016, Mabbett & Associates, Inc. February 17, 2016 Project No. 2014001.002 Appendix B VA Brockton & Jamaica Plain Dust & Soil Rpt

_FINAL_021716

APPENDIX B

Asbestos Inspector Certificates

VA Brockton & JP Drawings 1 - 14.pdf
B-1 Bldg-1 Basement
B-2a Bldg-2 Basement
B-3a Bldg-3 Sub-Basement
B-4 Bldg-4a Sub-Basement
B-5a Bldg-5 Sub-Basement
B-6a Bldg-8 Basement
B-7a Bldg-22 1st Floor
B-8a Bldg-23 Sub-Basement
B-9a Bldg-24 Basement
B-11a Brockton-Corridor-Underground
JP-12 Bldg-1 Sub Basement-Layout1
JP-13 Bldg-1B Basement-Layout2
JP-14 Bldg-2 Basement-Layout1
VA Brockton & JP Appendix A.pdf
A99342 Brockton VA PCM
A99343 Brockton VA PCM
B99337 Report Brockton VA Soil Samples
B99338 Report Brockton VA Soil Samples
Brockton VA Soils - S99338
NT15560 - BS-05 to BS-25
NT15568 Jamaica Plain VA - Soil Samples
NT15574 - BS-57 to BS-70
NT15576 - BS-84 to BS-117
NT15583 - BS-118 to BS-152
NT15584 - BS-154 to BS-183
S99175 Report Brockton VA
S99262 Report JP VA Soils
S99291 Report Brockton VA Soil Samples
S99301 Report Brockton VA Soil Samples
W99289 Report Brockton VA Dust Samples
W99302 Brockton VA Dust Samples
W99302 Report Brockton VA Dust Samples
W99339 Report Brockton VA Dust Samples
VA Brockton & JP Appendix B.pdf
KMD - Asbestos Designer Refresher - Exp. 7.17.16
KMD - Asbestos Inspector Refresher - Exp. 7.13.16
KMD - Asbestos Project Monitor Refresher - Exp. 7.20.16
KMD - MA Asbestos Designer - Project Monitor - Inspector - Exp. 7.21.16
VA Brockton & Jamaica Plain Dust & Soil Rpt _FINAL2_021716_.pdf
1.0 INTRODUCTION & EXECUTIVE SUMMARY
1.2 SITE DESCRIPTION
2.0 SAMPLING METHODOLOGY
3.0 ANALYTICAL METHODOLOGIES
4.0 SUMMARY OF ASBESTOS CONTAINING MATERIALS
5.0 SURVEY LIMITATIONS
6.0 FINDINGS AND RECOMMENDATIONS

File details come from the government source that posted it. Updated .