Attachment 1A - 21_0521 523A4-20-205 RBM Report.pdf
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This document is a Regulated Building Materials Survey Report for the West Roxbury Veterans Affairs Medical Center (VAMC) Emergency Department Expansion Project. Prepared by Mabbett & Associates on May 21, 2021, the report details the results of an asbestos and lead-containing paint survey conducted on April 27, 2021, for Building 3's emergency department renovation.
The survey collected 59 bulk samples for potential asbestos-containing materials (ACM) and 10 paint chip samples for lead content. Laboratory analysis revealed no materials containing asbestos greater than 1% and no paint samples exceeding the 0.5% lead concentration threshold set by the U.S. Department of Housing and Urban Development. The survey was limited to areas potentially impacted by the emergency department expansion, with some areas like within walls, fire doors, and electrical equipment remaining inaccessible. The report includes detailed appendices with sample locations, laboratory analysis results, and chain of custody documentation.
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REGULATED BUILDING MATERIALS
SURVEY REPORT
WEST ROXBURY VAMC
A/E Design for Expanding the Building 3 Emergency Department VA Project No. 523A4-20-205 255 Spring Street, West Roxbury, MA 02132
May 21, 2021
Mabbett Project No.: R2017024.010
Prepared for:
William Pevear Architects, Inc.
872 Mass Ave., #2-9 Cambridge, MA 02139
Mabbett & Associates, Inc.
105 Central Street, Suite 4100 Stoneham, MA 02180-1260 T. 781-275-6050 Massachusetts | Virginia | Rhode Island | New York
© 2021, Mabbett & Associates, Inc.
www.mabbett.com
REGULATED BUILDING MATERIALS SURVEY REPORT
A/E Design for West Roxbury VAMC, Emergency Department Expansion
© 2021, Mabbett & Associates, Inc. Page i May 21, 2021 Mabbett Project No. R2017024.010 S:\ADMINA\2017024 William Pevear Northampton VAMC\010\RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final.doc
ACKNOWLEDGEMENT
This Regulated Building Materials Survey Report has been prepared by Mabbett & Associates, Inc. (Mabbett®) for the A/E Design for Building 3, Emergency Department Expansion Project at the West Roxbury Veterans Affairs (VA) Medical Center located in West Roxbury, Massachusetts. The information presented herein is based on the facts and information conveyed to or received by Mabbett during the preparation of this report. If any of the information provided to Mabbett that was used in preparing this report is incorrect, incomplete, or subject to change, Mabbett would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to Mabbett as of the date of this report and considered applicable to this report.
The attached Regulated Building Materials Survey Report was prepared by Kevin Donovan, Senior Environmental Health & Safety Specialist of Mabbett & Associates, Inc.
This report has been reviewed and approved by:
Michael F. Delaney Director, Building Sciences Group
© 2021, Mabbett & Associates, Inc. Page ii May 21, 2021 Mabbett Project No. R2017024.010 S:\ADMINA\2017024 William Pevear Northampton VAMC\010\RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final.doc
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION
1.1 Summary of Survey Results
1.2 Purpose and Objectives
2.0 ASBESTOS SURVEY
2.1 Sampling Methodology
2.2 Analytical Methodology
2.3 Asbestos Containing Material Survey Findings
3.0 LEAD CONTAINING PAINT SAMPLING
4.0 CONCLUSIONS AND RECOMMENDATIONS
4.1 Asbestos
4.2 Lead Containing Paint
5.0 LIMITATIONS
TABLES
Table 1 – Summary of Lead Paint Chip Analytical Results (in text)
FIGURE
RBM-1
APPENDICES
Appendix A Appendix B Appendix C
Hazardous Material Sample Locations Plan
Summary of ACM Sampling Results Asbestos Laboratory Report and Chain of Custody Lead Paint Chip Laboratory Report and Chain of Custody
© 2021, Mabbett & Associates, Inc. 1 May 21, 2021 Mabbett Project No. R2017024.010 S:\ADMINA\2017024 William Pevear Northampton VAMC\010\RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final.doc
1.0 INTRODUCTION
Mabbett and Associates, Inc. (Mabbett®) performed a survey for regulated building materials (RBM) as part of the A/E Design Services for Building 3, Emergency Department Expansion Project at the West Roxbury VA Medical Center (VAMC) located in West Roxbury, Massachusetts. The site survey was performed by Mr. Kevin M. Donovan of Mabbett, on April 27, 2021 and consisted of the following activities:
A review of previous regulated building material reports and sampling;
An Asbestos Containing Material (ACM) survey of suspect materials (Analysis by Polarized Light Microscopy
[PLM]); and Lead Containing Paint (LCP) sampling (Analysis by atomic absorption [AA]).
The survey was limited to areas that may be impacted by the planned expansion of the Emergency Department.
Survey and sampling locations were determined based upon inspection of locations identified in the Schematic Design for VA Project Number 523A4-20-205. Areas and materials outside of this scope of work were not surveyed by Mabbett. Sampling of the roof system was not completed as part of this survey.
1.1 Summary of Survey Results
Bulk samples of suspected ACM were collected and submitted to a certified analytical laboratory for asbestos analysis by PLM using stop positive methodology. Paint chip samples were collected and submitted to a certified analytical laboratory for lead content analysis using atomic absorption spectroscopy. The survey efforts yielded the following results and conclusions:
Fifty-nine (59) bulk samples for suspect ACM were collected from various locations in the Emergency Department.
Based on laboratory analysis of suspect ACM, none of the identified materials contained asbestos greater than 1%. The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) defines ACM as any material that contains greater than one percent (>1%) asbestos.
Ten (10) paint chip samples from building surfaces were collected for laboratory analysis and reporting.
Based on laboratory analysis of paint chips, none of the collected samples revealed concentrations of lead in paint that exceeded the U.S. Department of Housing and Urban Development (HUD) threshold of 0.5 percent by weight.
No suspect PCB containing buildings materials were identified or sampled as part of this survey.
1.2 Purpose and Objectives
The regulated building material survey was comprised of three primary project tasks including:
Evaluation of existing site conditions and formulation of a sampling plan.
Site survey to collect building material samples for laboratory analysis.
Development of this Regulated Building Materials Survey Report.
This survey was designed to accomplish two primary objectives: to conduct a review of previous sampling in the building and collect a representative number of additional building materials for laboratory analysis and reporting;
and to use data from the laboratory analysis efforts to estimate the volume of regulated building materials present within the building’s interior for subsequent use in development of an abatement scope and design. These two objectives were met through a combination of a site visit and inspection to collect building material samples for laboratory analysis; and interpretation of qualitative data collected in the field; and the quantitative laboratory data generated from analysis of the building materials as summarized in this survey report.
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2.0 ASBESTOS SURVEY
A visual screening inspection was conducted by Mr. Kevin M. Donovan, a trained and licensed inspector (MA DLS #AI002014) to identify locations of suspect ACM and conceptualize the sampling program. Only areas that were accessible during the field work phase were inspected, with reasonable efforts made during the initial field survey work to access areas as necessary to complete the asbestos survey and sampling program.
2.1 Sampling Methodology
Bulk asbestos samples were collected using EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 763, and Asbestos Hazard Emergency Response Act (AHERA) protocols. Bulk suspect ACM sampling was generally conducted according to the following sampling protocol:
Friable surfacing material:
At least three bulk samples shall be collected from each homogeneous area that is 1,000 ft2 or less.
At least five bulk samples shall be collected from each homogeneous area that is greater than
1,000 ft2 but less than or equal to 5,000 ft2.
At least seven bulk samples shall be collected from each homogeneous area that is greater than
5,000 ft2.
Thermal system insulation:
At least three bulk samples shall be collected from each homogeneous area of thermal system insulation.
At least one bulk sample shall be collected from each homogeneous area of patched area of thermal system insulation.
Sufficient samples shall be collected from elbows and fittings to determine if they contain ACM.
Bulk samples shall not be collected from any homogeneous area where the state licensed asbestos inspector determined that the thermal system insulation is fiberglass, foam glass, rubber, or other non-ACM.
Miscellaneous material:
At least two bulk samples shall be collected from each homogeneous area that is less than 100 ft2.
At least three bulk samples shall be collected from each homogeneous area that is greater than 100 ft2.
Examples of areas that were inaccessible, or where the survey was limited to visual observation only, are provided below:
Within walls;
Within fire doors;
Enclosed pipe/duct chases;
Inside mechanical equipment/ductwork;
Above fixed drywall or plaster ceilings; and Electrical equipment.
2.2 Analytical Methodology
The collected bulk samples were submitted under standard chain of custody (COC) procedures to ProScience Analytical Services, Inc. (ProScience) of Woburn, Massachusetts. Sample analysis was conducted by PLM, in accordance with EPA Method 600/R-93/116, using stop positive methodology. ProScience is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP).
© 2021, Mabbett & Associates, Inc. 3 May 21, 2021 Mabbett Project No. R2017024.010 S:\ADMINA\2017024 William Pevear Northampton VAMC\010\RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final.doc
Bulk sample results from this inspection are summarized in Appendix A, Summary of ACM Building Inspection Results. The EPA and Occupational Safety and Health Administration (OSHA) define ACM as any material that contains greater than one percent (>1%) asbestos. As such, the analytical laboratory would identify bulk samples of suspected ACM as positive for asbestos when they met or exceeded the regulatory criteria of greater than one percent (>1%) asbestos. Asbestos analytical laboratory report and the chain of custody is provided in Appendix B of this report.
2.3 Asbestos Containing Material Survey Findings
Mabbett identified twenty-six (26) areas of homogenous materials and collected fifty-nine (59) representative bulk ACM samples. Asbestos sampling locations and results are identified on Figure RBM-1. Results for all the bulk samples collected during this survey are presented in Appendix A. The laboratory analytical results indicated that none of the homogenous materials sampled during the Mabbett survey contained asbestos.
3.0 LEAD CONTAINING PAINT SAMPLING
Limited sampling of painted surfaces was conducted on April 27, 2021. The limited LCP survey included the collection of ten (10) paint chips from materials and surfaces that may be impacted by the proposed work. Paint chip samples were submitted under standard chain of custody procedures to ProScience. Analysis was conducted using AA EPA method SW846-7000B/3051. The laboratory analytical report is included in Appendix C of this report.
The results of the limited LCP sampling are summarized in Table 1 below:
TABLE 1
Summary of Lead Paint Chip Analytical Results
Building 3, Emergency Department Expansion Project West Roxbury VA Medical Center
Sample # Sample Location Substrate and Component Color Result (% by weight)
Pb-01 GA-194C Metal door frame White <RL Pb-02 GA-194 Men’s Locker Gypsum wall White <RL Pb-03 GA-192 Metal door frame Tan <RL Pb-04 Corridor GA-153 Metal door Tan <RL Pb-05 Waiting Area Gypsum wall White <RL Pb-06 Exam Room #13 Metal door frame Tan <RL Pb-07 Exam Room #5 Window frame White <RL Pb-08 Exam Room #6 Metal door frame White <RL Pb-09 Exam Room #6 Gypsum wall White <RL Pb-10 Exam Room #17 Metal door frame Tan <RL
Notes <RL = Less Than Reporting Limit
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4.0 CONCLUSIONS AND RECOMMENDATIONS
4.1 Asbestos
ACM was not identified in the areas and materials surveyed. Any suspect materials encountered during renovation/demolition activities that are not identified in this report as being non-ACM should be assumed to be ACM unless sample results prove otherwise. If ACM is identified, all abatement must be performed in accordance with federal, state, and local requirements.
The scope of this survey was limited to materials and areas that may be impacted by the Emergency Department Expansion project, and as described in this report. Suspect materials that may be present in areas outside the scope of this work were not included in this survey and therefore were not sampled.
4.2 Lead Containing Paint
The purpose of the limited LCP survey was to identify similar areas of LCP. During the on-site survey, representative samples of similar areas of interior building coatings were collected and analyzed for lead content. The regulations addressing LCP in non-residential buildings are focused on occupational exposures involved with paint-disturbing activities and related waste-disposal activities.
Occupational exposure to lead in construction is regulated by OSHA regulation 29 CFR 1926.62 “Lead in Construction”, as well as other applicable state and local regulations. These regulations involve the air monitoring of workers to determine exposure levels when disturbing paint containing measurable concentrations of lead. A LCP survey cannot determine the safe level of lead for the purpose of paint-disturbing activities but is intended to provide guidance as to the locations of LCP. Employers and contractors may use this information to better determine where worker exposures to airborne lead may occur and, through the interpretation of LCP concentration data, assess the potential magnitude of exposure to their employees and identify the controls necessary to limit health risks.
A concentration of lead greater than or equal to 0.5 mg/Kg percent by weight or 1.0 mg/cm2 exceeds EPA and HUD residential standards is considered an indicator of risk. Representative samples of LCP waste to be generated during building renovation, or following demolition but prior to disposal, should be collected and analyzed using toxicity characteristic leaching procedure (TCLP) in accordance with 40 CFR Part 261. Management and disposal of lead containing waste must be done in accordance with all applicable local, state, and federal regulations.
OSHA regulations may require certain procedures for any paint that contains lead, even if it is below these levels. All LCP identified, regardless of the lead content, should either be sampled and analyzed by TCLP and then handled/disposed of accordingly, or segregated from other large-scale debris and then managed as hazardous waste in accordance with federal, state, and local hazardous waste disposal regulations.
© 2021, Mabbett & Associates, Inc. 5 May 21, 2021 Mabbett Project No. R2017024.010 S:\ADMINA\2017024 William Pevear Northampton VAMC\010\RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final.doc
5.0 LIMITATIONS
This survey report is the result of a diligent and thorough inspection for regulated building materials of the areas and materials that may be impacted by the proposed Building 3, Emergency Department Expansion Project. Inaccessible areas were not included in this survey. Although a comprehensive inspection was performed, Mabbett does not claim to have identified all hazardous materials that could be present in the facility (for example, materials potentially located within the inaccessible areas). Mabbett has conducted this assessment with reasonable care and has performed this project in accordance with 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.
© 2021, Mabbett & Associates, Inc. FIGURE Mabbett Project No. R2017024.010
May 21, 2021 RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final
FIGURE
16 17 18 19 20
/1 AS401
/1 AS402
A S
A S
EXAM 11
GA-164
EXAM 15
GA-169
EXAM 2
GA-152
OFFICE
GA-173
OFFICE
GA-174
OFFICE
GA-175
PUBLIC
TOILET
GA-146
STAFF
TOILET
GA-172
DECONT.
ROOM
GA-168
AMBULANCE
ENTRY
CG-21A
EXAM 13
ISOLATION
GA-166
EXAM 12
ISOLATION
GA-165
EXAM 10
GA-163
EXAM 9
BARIATRIC
GA-161
EXAM 8
MENTAL
HEALTH
GA-160
EXAM 6
MH FLEX
GA-158
EXAM 7
MH FLEX
GA-159
EXAM 3
GA-154
EXAM 5
GA-156
EXAM 4
GA-155
WAITING
GA-145
TRIAGE 1
GA-148
PATIENT
TOILET
GA-153
EXAM 14
WOMEN'S
HEALTH
GA-167
TEAM
WORK
AREA
GA-157
EXAM 16
GA-170 LOCKER
GA-194B
EXAM 1
GA-151
MED /
NOURISH
GA-150
STAFF
LOUNGE
GA-194
LOCKER
GA-194A
HAC
GA-179
EQUIPMENT
STORAGE
GA-178
SOILED
UTIL.
GA-176
CLEAN
UTILITY
GA-177
CLEAN
LINEN
GA-180
WALK-IN
ENTRY
CG-20B
TOILET/
SHWR
GA-171A
STRG
GA-168A
ON-CALL
BEDROOM
GA-171
PATIENT
TOILET
MH
GA-162
CORRIDOR
CG-24
CORRIDOR
CG-20
CORRIDOR
CG-21
CT
GA-101
CT
CONTROL
GA-101A
RECEPTION
GA-147
TRIAGE 2
GA-149 STAFF
TOILET
GA-194C
WHEELCHAIR
STRG
GA-145A
CORRIDOR
CG-22
CORRIDOR
CG-23
CORRIDOR
CG-21A
DA#3
DA#2
TYP. ALL EXAM ROOMS
STORAGE
GA-181
01C
16A, 17A
Pb-05
04B
18B, 19B
11B, 12B
02B, 07B, 08B
20B
Pb-04
21A, 22A
05C, 06C, 13B, 14B
18A, 19A
21B, 22B
03B, 25B, 26B
23B, 24B 05B, 06B 13A, 14A Pb-03 20A
11A, 12A
Pb-02
15A, 15B
04A, 07A, 08A, 09A, 10A
01A, 02A, 03A
Pb-01
25A, 26A
05A, 06A
09B, 10B
23A, 24A
Pb-06
Pb-07
16B, 17B 01B Pb-08
Pb10 Pb-09
BUILDING-3, GROUND LEVEL PLAN
Scientists I Engineers I Program Managers
Mabbett & Associates, Inc.
105 Central Street, Stoneham, MA 02180
T. 781-275-6050 www.mabbett.com
Mabbett
R
523A4-20-205
VAMC WEST ROXBURY
EXPAND EMERGENCY
DEPARTMENT
255 SPRING ST, WEST ROXBURY, MA 02132
05/06/2021
1/8" = 1'-0"
E1
HAZARDOUS MATERIALS LEGEND:
NO ASBESTOS DETECTED (NAD)
APPROXIMATE SAMPLE LOCATION
01A
LEAD SAMPLING LOCATION(Pb-01)
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© 2021, Mabbett & Associates, Inc. APPENDIX A Mabbett Project No. R2017024.010
May 21, 2021 RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final
APPENDIX A
Summary of ACM Sampling Results
© 2021, Mabbett & Associates, Inc. Appendix A Page 1 of 2 May 21, 2021 Mabbett Project No. R2017024.010 RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final
Appendix A Summary of ACM Sampling Results
Building 3, Emergency Department Expansion Project West Roxbury VA Medical Center
Sample No. Sample Location Description of Material Percent and Type of Asbestos 01A GA-194C Spray-On Fireproofing NAD 01B Nurse's Station Spray-On Fireproofing NAD 01C Waiting Area Spray-On Fireproofing NAD 02A GA-194A Red Fire Stop NAD 02B Corridor @ GA-157 Red Fire Stop NAD 03A GA-194C 2’ x 4’ White Ceiling Tile (Dots) NAD 03B GA-183 2’ x 4’ White Ceiling Tile (Dots) NAD 04A GA-194 2’ x 4’ White Ceiling Tile (Fissured) NAD 04B Reception Area 2’ x 4’ White Ceiling Tile (Fissured) NAD 05A GA-194 Men's Locker Gypsum Wallboard NAD 05B Exam Room #7 Gypsum Wallboard NAD 05C Reception Area Gypsum Wallboard NAD 06A GA-194 Men's Locker Joint Compound NAD 06B Exam Room #7 Joint Compound NAD 06C Reception Area Joint Compound NAD 07A GA-194 6" Gray Cove Base NAD 07B Corridor @ CG-20A 6" Gray Cove Base NAD 08A GA-194 6" Gray Cove Base Adhesive NAD 08B Corridor @ CG-20A 6" Gray Cove Base Adhesive NAD 09A GA-194 12” x 12” Gray Floor Tile NAD 09B GA-192 12” x 12” Gray Floor Tile NAD 10A GA-194 12” x 12” Gray Floor Tile Mastic NAD 10B GA-192 12” x 12” Gray Floor Tile Mastic NAD 11A Corridor @ GA-192 4" Gray Cove Base NAD 11B Corridor @ Recycle Bin 4" Gray Cove Base NAD 12A Corridor @ GA-192 4" Gray Cove Base Adhesive NAD 12B Corridor @ Recycle Bin 4" Gray Cove Base Adhesive NAD 13A Corridor @ GA-176 12” x 12” Dark Gray Floor Tile NAD 13B Corridor @ CG-20A 12” x 12” Dark Gray Floor Tile NAD
14A Corridor @ GA-176 12” x 12” Dark Gray/Pink Floor Tile Mastic NAD
14B Corridor @ CG-20A 12” x 12” Dark Gray/Pink Floor Tile Mastic NAD
15A GA-194 Gray Sink Coat NAD 15B GA-194 Gray Sink Coat NAD 16A Exam Room #13 Gray Sheet Flooring NAD 16B Exam Room #5 Gray Sheet Flooring NAD 17A Exam Room #13 Gray Sheet Flooring Adhesive NAD
© 2021, Mabbett & Associates, Inc. Appendix A Page 2 of 2 May 21, 2021 Mabbett Project No. R2017024.010 RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final
Appendix A Summary of ACM Sampling Results
Building 3, Emergency Department Expansion Project West Roxbury VA Medical Center
Sample No. Sample Location Description of Material Percent and Type of Asbestos 17B Exam Room #5 Gray Sheet Flooring Adhesive NAD 18A Reception Area Wood Sheet Flooring NAD 18B Waiting Area Wood Sheet Flooring NAD 19A Reception Area Wood Sheet Flooring Adhesive NAD 19B Waiting Area Wood Sheet Flooring Adhesive NAD 20A Corridor @ GA-192 2x2 White Ceiling Tile NAD 20B Corridor @ GA-157 2x2 White Ceiling Tile NAD 21A Waiting Room 6" Tan Cove Base NAD 21B Waiting Room 6" Tan Cove Base NAD 22A Waiting Room 6" Tan Cove Base Adhesive NAD 22B Waiting Room 6" Tan Cove Base Adhesive NAD 23A Outside Exam Room #1 12” x 12” Light Gray Floor Tile NAD 23B Outside Exam Room #7 12” x 12” Light Gray Floor Tile NAD
24A Outside Exam Room #1 12” x 12” Light Gray/Pink Floor Tile Mastic NAD
24B Outside Exam Room #7 12” x 12” Light Gray/Pink Floor Tile Mastic NAD
25A GA-194C Ceramic Tile Grout NAD 25B GA-183 Restroom Ceramic Tile Grout NAD 26A GA-194C Ceramic Tile Adhesive NAD 26B GA-183 Restroom Ceramic Tile Adhesive NAD
13A.1 Corridor @ GA-176 Pink Floor Tile NAD 13B.1 Corridor @ CG-20A Pink Floor Tile NAD 23A.1 Outside Exam Room #1 Pink Floor Tile NAD 23B.1 Outside Exam Room #7 Pink Floor Tile NAD
NAD = No Asbestos detected
© 2021, Mabbett & Associates, Inc. Appendix B May 21, 2021 Project No. R2017024.010 RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Finaldoc
APPENDIX B
Asbestos Laboratory Report and Chain of Custody
© 2021, Mabbett & Associates, Inc. APPENDIX C May 21, 2021 Mabbett Project No. R2017024.010 RBM Survey Report_West Roxbury Emergency Dept Expansion V1-Final
APPENDIX C
Lead Paint Chip Laboratory Report and Chain of Custody
| 1.0 INTRODUCTION |
| 1.1 Summary of Survey Results |
| 1.2 Purpose and Objectives |
| 2.0 ASBESTOS SURVEY |
| 2.1 Sampling Methodology |
| 2.2 Analytical Methodology |
| 2.3 Asbestos Containing Material Survey Findings |
| 3.0 LEAD CONTAINING PAINT SAMPLING |
| 4.0 CONCLUSIONS AND RECOMMENDATIONS |
| 4.1 Asbestos |
| 4.2 Lead Containing Paint |
| 5.0 LIMITATIONS |
| RBM-1 - Sampling Locations Plan-RBM-1.pdf |
| Sheets and Views |
| RBM-1 |
| 2021-05-24T10:45:06-0400 | |
| Michael F. Delaney |
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