Analysis of Brownfield Cleanup Alternatives .pdf

Consulting Engineers and

Scientists

Analysis of Brownfield Cleanup Alternatives (ABCA) for Asbestos Containing Materials and Lead-Based Paint

US EPA Brownfields Assessment Grant Cooperative Agreement BF-02D29722

Battey Business Complex 705 North Division Street Rome, Floyd County, Georgia

Prepared for:

Ms. Missy Kendrick Rome Floyd County Development Authority 800 Broad Street, Suite 102 Rome, Georgia 30161

Prepared by:

GEI Consultants, Inc.

3065 Akers Mill Road, Suite 235 Atlanta, GA 30339 404-592-0050

November 2023 Project 2300520

Prepared by: R. Jessica Turner, P.G.

Senior Project Manager

Reviewed by: James E. Laubenthal Vice President

ABCA – ACM and LBP Abatement Battey Business Complex, Rome, Georgia US EPA Brownfields Assessment Grant: BF-02D29722 November 2023

GEI Consultants, Inc. i

Table of Contents

1. Introduction 1

2. Background 2

2.1 Subject Property Description 2

2.2 Subject Property History 2

2.3 Previous ACM and LBP Surveys and Abatements 2

2.4 Current Environmental Concerns 6

3. Proposed Cleanup Objectives 8

3.1 Applicable Regulations and Abatement Standards 8

3.2 Cleanup Alternatives 8

3.2.1 Option No. 1 – No Action 9

3.2.2 Option No. 2 – ACM Abatement Prior to Building Demolition 9

4. Recommended Cleanup Alternatives 12

Table

1. Opinion of Estimated Cost for Alternative 2

Figures

1. Subject Property Location Map

2. Subject Property Layout Map

Appendices Appendix A - Portions of ACM and LBP Survey Report dated September 2023

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1. Introduction

GEI Consultants, Inc. (GEI), on behalf of Rome Floyd County Development Authority (RFCDA), has prepared this Analysis of Brownfield Cleanup Alternatives (ABCA) for the property known as the Battey Business Complex in Rome, Georgia. The RFCDA was awarded a United States Environmental Protection Agency (EPA) FY22 Community-Wide Brownfield Assessment Grant, Grant number BF-02D29722-2. The ABCA is a required element of the Brownfield Assessment Grant for properties funded by the grant where impacts were identified that require cleanup prior to redevelopment.

The Battey Business Complex (subject property) is located at 705 North Division Street, Rome, Georgia. The subject property consists of approximately 132.5 acres and is identified as Floyd County tax parcel I13X016, as shown on Figure 1.

In preparing this ABCA, GEI and the RFCDA considered environmental factors, site characteristics, land use restrictions, planned future uses of the subject property and surrounding area, and applicable cleanup standards.

This ABCA provides a comparative analysis of the cleanup alternatives being considered using the criteria of effectiveness, ability to implement, and cost of each alternative. This ABCA recommends the most appropriate cleanup alternative to enable the redevelopment of the subject property for commercial/industrial use which will directly benefit the community.

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2. Background

2.1 Subject Property Description

The subject property is located at 705 North Division Street, Rome, Georgia, consists of approximately 132.5 acres, and is identified as Floyd County tax parcel I13X016. The subject property is zoned for heavy industrial (H-I) use. The subject property is a vacant former military and state hospital campus located approximately 2 miles northwest of downtown Rome. A total of 66 vacant structures are located on the subject property including a security kiosk, main hospital building, laboratory/pharmacy, ancillary medical and administrative offices, patient and staff housing, events pavilions, laundry building, maintenance shops and materials storage buildings, grounds keeping storage areas, warehouse storage, steam and chiller plants, and a former incinerator/bio-hazard storage building.

2.2 Subject Property History

The subject property was initially developed by the US Army in the early-1940s as a temporary US Army hospital known as Battey General Hospital primarily serving tuberculosis patients. The US Army transferred the property to the state of Georgia in 1946, and it was renamed Battey State Hospital with a continued initial focus on tuberculosis treatment, and subsequent expansion of general health treatment. Areas of the subject property were redeveloped in the early-1970s to facilitate treatment of both tuberculosis and mental health patients. The subject property was renamed as the Northwest Georgia Regional Hospital (NWGRH) in July 1973. Historical records reported that by 1977 the hospital was averaging 281 patients a day with a staff of 605 professionals, with 260 beds reserved for mental health patients and approximately 50 beds for tuberculosis patients. The inpatient tuberculosis unit was phased out in the 1990s and the facility began solely treating patients with mental health and disability conditions. The NWGRH closed operations in June 2011.

2.3 Previous ACM and LBP Surveys and Abatements

Based on the initial development of the subject property in the early-1940s, and with redevelopment of portions of the subject property in the 1970s, asbestos containing materials (ACMs) and lead-based paint (LBP) were used in many of the structures. Numerous asbestos surveys and abatement reports completed in years 1981 through 2009 for the subject property were reviewed, and are summarized as follows:

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Survey Report, NWGRH, Rome, GA, completed by Law Associates, Inc., February 20, 1990.

o ACM survey of Buildings 103, 104, 315, 317, 401, 403, and five steam distribution valve pits. ACM was confirmed in Buildings 103, 104, 315, and 403. Additionally, this report included a page from an October 9, 1981, Asbestos Survey that stated 2ft x 4ft asbestos board around the perimeter overhang and asbestos insulation with fabric wrapping is present on all steam lines and duct work in Buildings 103, 104, 300, 315, 317, 400, 401, 402, 403, 404, 406, 408, 410, and 412.

Demolition of Buildings 101 and 204 Request Memo, NWGRH, Rome, GA, written by Carl E Roland, Jr., Director of Division of Mental Health, Mental Retardation, and Substance Abuse, November 19, 1996.

o Request for approval to demolish Buildings 101 and 204. Noted that asbestos is present in these buildings on pipe insulation in Building 101 and above the ceiling in Building 204.

Report of Asbestos Survey, NWGRH, Rome, GA, prepared by Law Engineering and Environmental Services, Inc., July 10, 1997.

o Pre-renovation ACM survey of Buildings 103 and 403. ACMs were identified including ceiling tile, spray-applied ceiling finish, floor tiles and mastic, sheet flooring systems, carpet mastic, pipe insulation, drywall, and joint compound. The report assumed the materials identified as ACM in the previous 1990 asbestos report as well.

Letter regarding Bulk Samples taken during walk-through on November 14, 2000, written by Lamario U. Joiner of Quality Analyst Consultants, Inc. for NWGRH.

o The letter presented the results of two samples collected from Building

205. Asbestos was detected in a sample of wall board.

Letter regarding Old Laboratory, Building 204, written by S. Pat Chesowsky of Winter Environmental for NWGRH.

o The letter presented the results of asbestos samples collected from Building 204 and an estimate for abatement. Asbestos was detected in mastic, floor tile and HVAC duct wrap.

Asbestos Bulk Sample Collection and Testing Activities on the NWGRH, Old Boiler Building, 1305 Redmond Circle, Rome, Georgia 30165, prepared by United Consulting for Northwest Georgia Regional Hospital, January 16, 2001.

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GEI Consultants, Inc. 4 o Asbestos survey report for the “old boiler building”. ACMs identified included thermal system insulation, roofing materials including mastic, roof layers and flashing, exterior window caulking.

Collection of Reports of Bulk Sample Collection and Testing, Houses 1231, 1118, 1121, 1223, 1225, 1227, 1229A, 1229B, 1233, 1235, 1237, 1100, 1120, 1102, 1112, 1104, 1108, 1114, 1116, 1205, 1209, 1213, 1215, 1217, 1219, 1245, Buildings 912, 100, 204, 206, 319, 510-512, 614, 803, 805, 906, 908, 807, 909, prepared by GLE Associates, Inc. for the Georgia Department of Human Resources Office of Facilities and Support Services, April 25, 2003.

o A collection of letters documenting the results of asbestos sampling at the above-referenced houses and buildings. Various ACMs were identified.

Asbestos Abatement Plan, Buildings 100, 204, 206, 319, 510-512, 614, 803, 805, 807, 906, 908 and 912, 909, 919, Houses 1100, 1102, 1104, 1106, 1108, 1110, 1112, 1114, 1116, 1118, 1120, 1205, 1209, 1213, 1215, 1217, 1219, 1221, 1223, 1225, 1227, 1229A & B, 1231, 1233, 1235, 1237 and 1245, prepared by GLE Associates, Inc. for the Georgia Department of Human Resources Office of Facilities and Support Services, 2004.

o A set of figures detailing sample locations positive for asbestos and asbestos abatement plans.

Asbestos Abatement – Preliminary Scope of Work and Drawings, NWGRH, Rome, Georgia, prepared by GLE Associates, Inc., February 11, 2004.

o A scope of work for abatement at 30 buildings and houses (building numbers 100, 204, 206, 319, 510-512, 614, 805, 807, 906, 908, 909, 912, 919, 1100, 1102, 1104, 1106, 1114, 1116, 1118, 1120, 1205, 1209, 1213, 1219, 1223, 1225, 1227, 1231, 1245). Includes a description of ACMs to be removed within each building.

Technical Specifications for Asbestos Abatement, prepared by GLE Associates, Inc. for the Georgia Department of Human Resources Office of Facilities and Support Services, May 2004.

o A plan describing the methods of abatement and a summary of numerous buildings and houses (building numbers 100, 204, 206, 319, 510-512, 614, 803, 805, 807, 906, 908, 909, 912, 919, 1100, 1102, 1104, 1106, 1108, 1110, 1112, 1114, 1116, 1118, 1120, 1205, 1209, 1213, 1215, 1217, 1219, 1221, 1223, 1225, 1227, 1229A+B, 1231, 1233, 1235, 1237, 1245) with descriptions of materials to be abated. Also included floor plans with sample locations and ACMs. Also detailed “put-backs” – the materials to be installed to replace abated ACMs.

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Addendum Number One, NWGRH, Removal of Asbestos Containing Materials, Rome, Georgia, prepared by GLE Associates, August 20, 2004.

o Detailed changes to the Technical Specifications for Asbestos Abatement.

Asbestos Abatement of Numerous Buildings at NWGRH, 2002-2004.

o A collection of records documenting the sampling and abatement of numerous buildings and houses at the site. The documents included lists of ACMs slated for abatement, certifications of asbestos abatement for buildings to be demolished, descriptions of put-backs, and lists of buildings and materials that had been abated.

Letter RE: Suspect Asbestos, House 1227, from Billy J Nicholson, Jr, Maintenance Director of NWGRH, to Rick Faircloth, GLE Associates, Inc.

February 16, 2005.

o Letter indicated that additional suspect ACMs were identified in pipe insulation and floor tile in the kitchen of House 1227, with a request for testing and abatement estimate. An asbestos disposal invoice and waste manifest was also included for buildings and materials that were abated.

Final Report for Asbestos Abatement at the NWGRH, Rome, Georgia, prepared by GLE Associates, Inc. for Northwest Georgia Regional Hospital, May 6, 2005.

o Report detailing the asbestos sampling and abatement work completed from 2002 until 2005 at 31 buildings and houses at the site.

Sampling and abatement of pipe insulation behind building 919, in 2009.

o Collection of documents regarding the discovery, testing and abatement and disposal of pipe insulation stored on the exterior of building 919.

Based on the likely presence of ACM and LBP remaining in subject property structures, GEI conducted a limited ACM and LBP Survey of the Battey Business Complex, formerly known as (fka) the NWGRH. The objective of ACM and LBP survey was to identify locations of ACM and LBP that require abatement prior to demolition in preparation for future redevelopment at the subject property. GEI performed the assessment in general accordance with the EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP) protocol. This assessment generally satisfies the federal NESHAP that requires identification and removal of all regulated asbestos-containing materials prior to renovation and demolition activities, except where noted below. Portions of the ACM and LBP Survey Report dated September 2023, including data tables, figures, and photo log, area, are provided for reference in Appendix A.

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2.4 Current Environmental Concerns

Numerous ACMs were identified throughout the property’s structures including:

Vinyl floor tile and mastic.

Thermal system insulation.

Joint compound, plaster and textured walls and ceilings.

Transite panels (cementitious panels) as exterior soffits and siding, and as wall panels in restrooms.

Window glazing and caulking.

Sink mastic undercoating.

Vinyl sheet flooring.

Tar and felt roofing layers.

The roof systems of only a select group of buildings have been thoroughly sampled and/or assessed. This limited roof sampling was performed due to the possibility of causing water damage and/or voiding existing warranties of the roof system and the uncertainty of the timeframe when the building will be renovated or demolished. Based on the roofing samples that were collected, no asbestos was detected in the standard 3-tab asphalt shingles. Most of the flashing samples collected were ACM, and asbestos was found in some of the roof field samples collected. The roofing materials should be assumed to contain asbestos until they can be further assessed. Moreover, additional sampling of the suspect asbestos containing material (SACM) roofing membrane should be performed prior to its renovation or demolition to determine if it contains ACM.

Although reasonable effort was made to survey all accessible SACM, GEI did not conduct complete destructive sampling techniques and, therefore, there is a possibility for ACM to be located within sealed walls, pipe chases, and other wall cavities that were not accessible to the asbestos inspectors. Vermiculite insulation was present in walls throughout Buildings 104, 300, and 402 based on exposed areas of these buildings where the vermiculite could be seen in the cavities of the interior cinderblock walls. It is possible that vermiculite may be present throughout many of the buildings constructed in the early 1970s. It may be necessary to further assess this material. During renovations and/or demolition, it will be important to have an accredited asbestos inspector on site to visually assess these types of areas as they are exposed.

LBP was also identified throughout the property’s structures. Any contractor who performs removal or disturbance of these surfaces/materials will need to establish their means and methods for protecting their employees. Although this is not an EPA and United States

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Department of Housing and Urban Development (HUD) targeted housing or child occupied facility, it is recommended that the contractor’s workforce be trained in the provisions of the Occupational Safety and Health Administration (OSHA) Lead in Construction Standard and comply with the requirements of the OSHA standard. Preferably, a registered Georgia Lead abatement contractor or Renovation, Repair, and Painting (RRP) trained contractor or its competent person should perform the lead disturbance activities such as abrasive scraping, grinding, or torching.

Additionally, the abatement contractor shall be responsible for the proper handling, transportation, and disposal of lead-containing waste generated on this project. The contractor shall sample and characterize the waste in accordance with the selected disposal facility requirements, and in accordance with Resource Conservation Recovery Act requirements. This shall include waste characterization utilizing Toxicity Characteristic Leachate Procedure (TCLP) sample analysis for lead. Metal components that have LBP can be recycled without abatement. The receiving facilities must be informed of the presence of lead. Additionally, appropriate work practices and adequate engineering control of lead dust must be used to avoid lead contamination of the soil during renovation.

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3. Proposed Cleanup Objectives

3.1 Applicable Regulations and Abatement Standards

The purpose of this ABCA is to compare cleanup alternatives based on site specific conditions, technical feasibility, and preliminary cost evaluations. The ACM Survey completed by GEI in 2023 consisted of a limited NESHAP assessment that included an inspection of the property in which the location and number of samples collected, using limited destructive testing, provided sufficient detail to more accurately identity the location of the ACM on each building on the property. During the assessment, GEI followed, in part, the federal NESHAP sampling protocol. The federal NESHAP (40 CFR 61.145) requires the following:

“…the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos…”

The intent of these federal regulations requires that SACM that will be disturbed during the demolition or renovation (including repair), be assessed for content, then removed and disposed of properly. GEI utilized both statistically random and discrete sampling procedures during the assessments to find safely accessible sampling locations as well as ensuring that as many suspect building materials were sampled as possible. It is possible that SACM is located behind walls or in pipe chase areas that were not observed or sampled.

The LBP Survey identified structures containing LBP or lead-containing paint that are planned for demolition, and in part, to provide a recommendation for proper disposal and worker protection according to the Georgia Environmental Protection Division (EPD), EPA, HUD, and OSHA guidelines.

3.2 Cleanup Alternatives

The two cleanup alternatives identified are:

1. No action.

2. ACM abatement/removal and proper disposal off-site.

The two cleanup alternatives are further discussed below. Each alternative will be considered with respect to protection of public health and the environment, ability to remove or minimize contaminants, prevention of exposure to potential receptors (construction

US EPA Brownfields Assessment Grant: BF-02D29722 November 2023

GEI Consultants, Inc. 9 workers, future occupants, residents and/or workers on adjoining properties), and long-term effectiveness. The ability to implement each alternative will also be considered, including the administrative and technical feasibility. Lastly, the estimated cost for each alternative will be considered.

3.2.1 Option No. 1 – No Action

No remedial activities would be performed at the subject property as part of the No Action alternative. This alternative assumes no action is taken and would leave the ACM and LBP in place, and hence is not a valid option for the subject property.

While the No Action alternative would be the lowest cost, this alternative does not reduce the threat of potential exposure to the identified ACM and LBP in the buildings at the subject property. Additionally, the No Action alternative provides no worker protection or proper handling of the ACM and LBP waste. The No Action alternative ultimately prevents demolition and redevelopment of the subject property.

Effectiveness

The No Action alternative is not considered effective or reliable in addressing the risk of exposure to receptors to the identified ACM and LBP at the subject property. The ACM and LBP would not be abated prior to demolition, which would prevent future renovation and/or demolition of the subject property buildings. Additionally, this alternative does not protect the human health of receptors or the environment.

Ability to Implement

This option would be the simplest to implement; however, it is not technically feasible as it leaves the property in its current condition, which prevents the planned redevelopment.

Cost

There is no cost associated with this alternative. However, the ACM and LBP present at the subject property would remain in place and prevent redevelopment activities.

3.2.2 Option No. 2 – ACM Abatement Prior to Building Demolition

The most common and widely accepted approach for cleanup is to properly abate the ACM prior to demolition or renovation activities. Notifications to EPD will be required if renovation or demolition activities are planned that may disturb identified ACM. The NESHAP notification form must be filled out and submitted at least 10 working days prior to disturbing the identified ACM.

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During the abatement process, the ACM must be removed wet, all materials placed in 6-mil plastic bags labeled as “Asbestos,” and disposed of according to EPD regulations. Copies of solid waste manifests must be provided to RFCDA by the abatement contractor for both ACM transportation and disposal, and to document that the ACM was properly disposed.

In accordance with state regulations, the condition of the LBP surfaces should be inspected.

A component removal, such as doors, door casings, etc., will be performed on the identified lead-based paint building components. Upon removal, these components should be wrapped, segregated, and stockpiled to a lead-based paint specified dumpster. Prior to disposal, the waste stream will be tested for TCLP to evaluate the potential for leaching in a landfill. If the waste stream fails the TCLP test, then the abatement contractor should dispose the lead containing waste at an approved landfill that accepts lead containing waste.

Effectiveness

The effectiveness of ACM abatement prior to building demolition is high, as it protects human health during building demolition activities by having removed the ACM and flaking LBP prior to site activities. It is also effective in protecting the environment by reducing the amount of building material disposed in landfill space permitted for ACM disposal and by removing the potential for ACM and LBP to be released to the soil during building demolition. Furthermore, complete abatement allows for the demolition and redevelopment of the property.

Ability to Implement

This alternative is easily implemented by licensed ACM abatement contractors. The abatement work will be conducted in accordance with applicable federal, state, and local regulations including but not limited to the Department of Transportation, OSHA, EPA, and

EPD.

Cost

On September 25, 2023, three independent abatement contractors toured the Battey Business Complex for the purposes of developing rough order of magnitude (ROM) estimates of ACM abatement costs. ROM cost estimates to abate the identified ACM at the subject property were obtained from two of the abatement contractors. The estimated ROM costs provided by the abatement contractors include the estimated labor, materials, equipment, and the permits and associated fees to complete the asbestos abatement based on the ACM identified in the past and by GEI.

In addition to the abatement contractor ROM costs, the fees associated with contractor oversight, air monitoring, additional sampling of SACM and LBP, and 10% contingency budgets for both scope and bid were included for the duration of the abatement project. The

US EPA Brownfields Assessment Grant: BF-02D29722 November 2023

GEI Consultants, Inc. 11 abatement contractors stated that the duration of the ACM/LBP abatement is anticipated to take between 185 to 205 working days, and the contractor oversight cost estimates were based on that project duration. Costs for oversight includes the air monitoring analytical fees, plus additional laboratory fees for SACM sample analysis on materials not previously sampled (i.e., roofing on some buildings, vermiculite not previously accessible, etc.).

Table 1 outlines the estimated ROM costs associated with each of the tasks associated with the ACM and LBP abatement cleanup alternative. In total, the range of estimated ROM cost of cleanup for Alternative 2 is $5,188,550 to $5,227,455.

Each contractor presented a list of assumptions and clarifications that may alter these ROM cost estimates once the work begins. The contractor ROM cost estimates assume that electricity service will be provided to support abatement activities, and that ACM waste will be removed and disposed of by the abatement contractor. Municipal water service is not connected to the subject property. Water for use during the abatement will have to be supplied by an off-site source (i.e., connection to off-site fire hydrant, water truck, totes, etc.). There is an on-site well that currently provides non-potable water to the maintenance building in limited capacity. Once the project begins, the abatement contractor will evaluate if the well can produce sufficient water volume to avoid the cost of off-site water sources.

Additional sampling of the SACM roofing, or additional SACM found in wall cavities that were not identified during the previous assessments, may also alter these cost estimates.

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4. Recommended Cleanup Alternatives

Based on the conditions at the site, type of impact requiring remediation, and experience with EPD, ACM abatement and off-site disposal as special waste is the only feasible and practical approach. This is the corrective action approach already approved by EPD and is the recommended cleanup alternative.

Implementation of ACM abatement is often achieved through targeted removal of identified ACMs, which are then placed directly into lined roll-off boxes and transported to the appropriately licensed landfill. Based on previous conversations with EPD personnel, this is the most widely used remediation method on Brownfield sites.

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Table

Table 1 - Opinion of Estmaded Rough Order of Magnitude Cost for Alternative 2

ABCA for Battey Business Complex ACM and LBP Abatement

Rome Floyd County Development Authority

Rome, Georgia

Asbestos Abatement and Disposal Tasks

Asbestos / LBP Abatement Contractor Contractor 1 Contractor 2

Asbestos / LBP Abatement Cost including Transportation and Disposal

- Residential Houses $212,010 $251,250

- Remaining Site Buildings $3,830,869 $3,729,125

Total Contractor Cost* $4,042,879 $3,980,375

Subtotal Contractor and Vendor Services

Scope Contingency (10%) $404,288 $398,038

Bid Contingency (10%) $404,288 $398,038

Abatement Oversight and Reporting

Abatement Project and Safety Management $63,300 $67,400

Field Oversight of Abatement Contractor $300,800 $332,800

Analytical Testing and Field Equipment and Supplies $11,900 $11,900 Total Abatement Oversight Cost $376,000 $412,100

Total Estimated Abatement Cost $5,227,455 $5,188,550

* Cost provided by abatement contractor. This assumes the contractor will be contracted directly with the RFCDA.

Estimated ROM Costs

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Project 2300520 October 2023

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Figures

FIGURE TITLE LINE 1

FIGURE TITLE LINE 3

SUBJECT PROPERTY

LOCATION MAP

September 2023 Fig. 1Project 2300520Rome Floyd County Development Authority

Battey Business Complex 705 North Division Street

Rome, Georgia 30165

SOURCE:

7.5-MINUTE USGS 2014 ROME NORTH, GA MAP, NOT TO SCALE

SITE

FIGURE TITLE LINE 1

FIGURE TITLE LINE 3

SUBJECT PROPERTY

LAYOUT MAP

September 2023 Fig. 2Project 2300520Rome Floyd County Development Authority

Battey Business Complex 705 North Division Street

Rome, Georgia 30165

Aerial Imagery Provided by Google Maps.

NOT TO SCALE

510/512

304 104

1223 1217

A + B

813903

LEGEND

– 400 = BUILDING NUMBER

= APPROXIMATE SUBJECT PROPERTY BOUNDARY

= FORMER BUILDING

RAILROAD

R E

D M

O N

D C

IR

C

LE

N

O R

T H

D

IV

IS

IO

N S

T R

E E

T N

W

MARABLE WAY

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Appendix A

Portions of the ACM and LBP Survey Report dated September 2023

Asbestos and Lead-Based Paint Assessment Report Battery Business Complex Rome, Georgia September 2023

Tables

Tables

Battey Business Complex

Rome, Georgia

General Notes:

AM amosite

BB cove base mastic

CH chrysotile

COC chain-of-custody

CT ceiling tiles

CR crocidolite

DM Duct Mastic

E east

EJ floor expansion joint compound

FDI field detect

FDI fire door insulation

FSP fire stop putty

FT floor tile

GLD glue dabs

JC joint compound

LCI lab countertop

MF muffler insulation

N north

ND non-detect

NE northeast

NW northwest

PFI pipe fitting insulation

PFW pipe fitting wrap

PLCTF plaster ceiling with textured finish

PLW plaster wall

RF roof flashing

RM roof membrane

S south

SE southeast

SM sink mastic

SW southwest

TC textured ceiling

TG tank gasket

TKI tank insulation

TP transite panel

TSI thermal systems insulation

TSIM thermal system insulation mastic

VD vibration damper

VO or VM vermiculite

VSF vinyl sheet flooring

W west

WBJC wallboard joint compound

WC window caulking

WG window glazing

Table 1. Summary of Positive ACM Samples

Battey Business Complex Rome, Georgia

CH AM CR

Room 112; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 111; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 102; Joint compound; Joint compound 2 ND ND Room 101; Joint compound; Joint compound 2 ND ND Room 214; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 208; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 204; Joint compound; Joint compound 2 ND ND Ladies bathroom - first floor; Transite panel bathroom walls; Panel. Paint included as binder 15 ND ND

Ladies bathroom - Second floor; Transite panel bathroom walls; Panel. Paint included as binder 15 ND ND

General Notes:

1. ACM joint compound was identified throughout the finished walls and ceilings of the building.

2. ACM transite wall panels were identified in the bathrooms.

3. Presumed ACM thermal system insulation was observed on the floor of the crawl space.

Building 100

Sample DescriptionSample ID Asbestos Content (%)

100-JC-04

100-JC-05

100-JC-06

100-JC-07

100-TP-01

100-TP-02

100-JC-01

100-JC-02

100-JC-03

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Project 2300520 September 2023

Battey Business Complex Rome, Georgia

CH AM CR

Sample DescriptionSample ID Asbestos Content (%)

--; --; Floor tile 2 ND ND --; --; Black mastic 5 ND ND Room 117; 12x12 floor tile - green with olive green streaks; Black mastic 5 ND ND East hallway; 12x12 floor tile - green with olive green streaks; Black mastic 5 ND ND West hallway; 12x12 floor tile - green with olive green streaks; Black mastic 5 ND ND Across from room 96; 12x12 floor tile - grey; Floor tile 2 ND ND Across from room 96; 12x12 floor tile - grey; Black mastic 5 ND ND Room 93; 12x12 floor tile - grey; Floor tile 2 ND ND Room 93; 12x12 floor tile - grey; Black mastic 5 ND ND Across from janitor room 104; 12x12 floor tile - grey; Floor tile 2 ND ND Across from janitor room 104; 12x12 floor tile - grey; Black mastic 5 ND ND Room 107; 12x12 floor tile, light brown; Floor tile 2 ND ND Room 107; 12x12 floor tile, light brown; Black mastic 5 ND ND Room 61; 12x12 floor tile, light brown; Floor tile 2 ND ND Room 61; 12x12 floor tile, light brown; Black mastic 5 ND ND Room 60 vault area; 12x12 floor tile, light brown; Floor tile 2 ND ND Room 60 vault area; 12x12 floor tile, light brown; Black mastic 5 ND ND Room 99; 12x12 floor tile, solid brown; Floor tile 2 ND ND Room 99; 12x12 floor tile, solid brown; Black mastic 5 ND ND Room 101; 12x12 floor tile, solid brown; Floor tile 2 ND ND Room 101; 12x12 floor tile, solid brown; Black mastic 5 ND ND Room 96; Joint compound; Joint compound 2 ND ND Room 92; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 119; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 09; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 35; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 57; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 84; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 86; Pipe fitting insulation; Insulation 15 5 ND Room 84; Pipe fitting insulation; Insulation 15 5 ND Room 27; Sink mastic; Undercoat 5 ND ND Room 31 bathroom; Sink mastic; Undercoat 5 ND ND Room 32 skylight area; Textured ceiling; Joint compound. Paint included as binder 2 ND ND Room 32 skylight area; Textured ceiling; Joint compound. Paint included as binder 2 ND ND Outside of main lobby; Transite panel - soffit, peghole; Panel. Paint included as binder 15 ND ND Outside of main lobby; Transite panel - soffit, smooth; Panel. Paint included as binder 15 ND ND Room 134; Vinyl sheet flooring; Backing with glue 45 ND ND Room 118; Vinyl sheet flooring; Backing with black mastic 45 ND ND Room 35; Vinyl sheet flooring; Backing with glue 45 ND ND Lobby room 1-01; Window caulking; Beige caulk 2 ND ND Room 32; Window caulking; Beige caulk 2 ND ND Lobby room 1-01; Window glazing; Glazing 5 ND ND Room 32; Window glazing; Glazing 5 ND ND Exterior - outside Room 1-01 lobby; Window glazing; Glazing 5 ND ND

General Notes:

2. ACM joint compound was identified throughout the finished walls and ceilings of the building.

3. ACM transite panels were identified throughout the exterior soffit of the building.

4. ACM window glazing and caulking were identified throughout the building windows.

5. ACM vinyl sheet flooring was identified in several rooms.

6. ACM pipe fitting insulation was identified in rooms 84 and 86, but may be found elsewhere

7. ACM textured ceiling finish was identified in the skylights.

Building 103-1A

1031A-WG-02

1031A-WG-03

1. ACM floor tile and/or mastic were identified throughout the building. Some may have 2 or 3 layers of flooring and the bottom layer was often identified as ACM.

1031A-VSF-03

1031A-WC-01

1031A-WC-02

1031A-WG-01

1031A-SM-01

1031A-SM-02

1031A-TC-01

1031A-TC-02

1031A-TP-01

1031A-TP-02

1031A-PFI-02

1031A-FT-4-01

1031A-FT-4-02

1031A-FT-4-02

1031A-JC-01

1031A-JC-02

1031A-JC-03

1031A-VSF-01

1031A-VSF-02

1031A-FD-02

1031A-FD-02

1031A-FT-2-02

1031A-FT-2-03

1031A-FT-2-03

1031A-FT-3-01

1031A-FT-3-01

1031A-FT-3-02

1031A-FT-3-02

1031A-FT-3-03

1031A-FT-3-03

1031A-FT-4-01

1031A-FT-1-01

1031A-FT-1-02

1031A-FT-1-03

1031A-FT-2-01

1031A-FT-2-01

1031A-FT-2-02

1031A-JC-04

1031A-JC-05

1031A-JC-06

1031A-JC-07

1031A-PFI-01

GEI Consultants, Inc.

Battey Business Complex Rome, Georgia

CH AM CR

Sample DescriptionSample ID Asbestos Content (%)

--; --; Joint compound 2 ND ND Hallway by 1-171; 12x12 floor tile - tan with red streaks; Brown floor tile 2 ND ND Hallway by 1-171; 12x12 floor tile - tan with red streaks; Black mastic 5 ND ND Hallway by 1-171; 12x12 floor tile - tan with red streaks; Beige floor tile 2 ND ND Hallway by 1-171; 12x12 floor tile - tan with red streaks; Black mastic 3 ND ND Hallway by 1-177; 12x12 floor tile - tan with red streaks; Brown floor tile 2 ND ND Hallway by 1-177; 12x12 floor tile - tan with red streaks; Black mastic 5 ND ND Hallway by 1-177; 12x12 floor tile - tan with red streaks; Beige floor tile 2 ND ND Hallway by 1-177; 12x12 floor tile - tan with red streaks; Black mastic 3 ND ND Hallway by 1-157; 12x12 floor tile - tan with red streaks; Brown floor tile 2 ND ND Hallway by 1-157; 12x12 floor tile - tan with red streaks; Black mastic 5 ND ND Hallway by 1-157; 12x12 floor tile - tan with red streaks; Beige floor tile 2 ND ND Hallway by 1-157; 12x12 floor tile - tan with red streaks; Black mastic 3 ND ND Doubledoor by cafeteria; 12x12 floor tile - white with grey streaks, 2 layers (bottom is brown); Dark brown floor tile 2 ND ND

Doubledoor by cafeteria; 12x12 floor tile - white with grey streaks, 2 layers (bottom is brown); Black mastic 5 ND ND

Patient dining room; 12x12 floor tile - white with grey streaks, 2 layers (bottom is brown); Dark brown floor tile 2 ND ND

Patient dining room; 12x12 floor tile - white with grey streaks, 2 layers (bottom is brown); Black mastic 5 ND ND

Room 154; 12x12 floor tile - white with grey streaks, 2 layers (bottom is brown); Dark brown floor tile 2 ND ND

Room 154; 12x12 floor tile - white with grey streaks, 2 layers (bottom is brown); Black mastic 5 ND ND

Room 163; Joint compound; Joint compound 2 ND ND Room 154; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 156; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 150; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 44; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 46; Joint compound; Joint compound. Paint included as binder 2 ND ND Linen closet; Pipe fitting insulation - magnesia type; Pipe mastic 2 ND ND Linen closet; Pipe fitting insulation - magnesia type; Insulation 5 3 ND Can wash room; Pipe fitting insulation - magnesia type; Pipe mastic. Paint included as binder 2 ND ND

Can wash room; Pipe fitting insulation - magnesia type; Insulation 10 ND ND Patient dining room; Textured ceiling finish; Joint compound. Paint included as binder 2 ND ND Outside side entry; Transite panel soffit - smooth; Panel. Paint included as binder 20 ND ND Room 1-169; Window caulking; Glazing. Paint included as binder 3 ND ND Entry; Window caulking; Glazing 3 ND ND Room 1-169; Window glazing; Glazing 3 ND ND Entry; Window glazing; Glazing. Paint included as binder 3 ND ND Exterior outside room 1-169; Window glazing; Glazing 3 ND ND Exterior outside entry; Window glazing; Glazing 3 ND ND

General Notes:

2. ACM joint compound was identified throughout the finished walls and ceilings of the building.

3. ACM transite panels were identified throughout the exterior soffit of the building.

4. ACM window glazing and caulking were identified throughout the building windows.

5. ACM pipe fitting insulation was identified in a linen closet and can wash room.

6. ACM textured ceiling finish was identified in the skylights.

Building 103-1B

1031B-WG-02

1031B-WG-03

1031B-WG-04

1. ACM floor tile and/or mastic were identified throughout the building. Some may have 2 or 3 layers of flooring and the bottom layer was normally identified as ACM.

1031B-PFI-02

1031B-TC-01

1031B-TP-01

1031B-WC-01

1031B-WC-02

1031B-WG-01

1031B-JC-04

1031B-JC-05

1031B-JC-06

1031B-PFI-01

1031B-PFI-01

1031B-PFI-02

1031B-FT-2-02

1031B-FT-2-03

1031B-FT-2-03

1031B-JC--01

1031B-JC-02

1031B-JC-03

1031B-FT-1-03

1031B-FT-1-03

1031B-FT-1-03

1031B-FT-2-01

1031B-FT-2-01

1031B-FT-2-02

1031B-FT-1-01

1031B-FT-1-02

1031B-FT-1-02

1031B-FT-1-02

1031B-FT-1-02

1031B-FT-1-03

1031B-FD-01

1031B-FT-1-01

1031B-FT-1-01

1031B-FT-1-01

GEI Consultants, Inc.

Battey Business Complex Rome, Georgia

CH AM CR

Sample DescriptionSample ID Asbestos Content (%)

Hallway next to nurse station; 12x12 floor tile, white and grey, 2-layers (brown bottom layer); Brown floor tile 3 ND ND

Hallway next to nurse station; 12x12 floor tile, white and grey, 2-layers (brown bottom layer); Black mastic 3 ND ND

Inside nurse station; 12x12 floor tile, white and grey, 2-layers (brown bottom layer);

Brown floor tile 3 ND ND

Inside nurse station; 12x12 floor tile, white and grey, 2-layers (brown bottom layer);

Black mastic 3 ND ND

Exit area NW side; 12x12 floor tile, white and grey, 2-layers (brown bottom layer);

Brown floor tile 3 ND ND

Exit area NW side; 12x12 floor tile, white and grey, 2-layers (brown bottom layer); Black mastic 3 ND ND

Room 202; 12x12 floor tile, tan; Floor tile 3 ND ND Room 202; 12x12 floor tile, tan; Black mastic 3 ND ND Kitchen dining area; 12x12 floor tile, tan; Floor tile 3 ND ND Kitchen dining area; 12x12 floor tile, tan; Black mastic 3 ND ND Room 254; 12x12 floor tile, tan; Floor tile 3 ND ND Room 254; 12x12 floor tile, tan; Black mastic 3 ND ND Outside room 268; 12x12 floor tile, dark brown; Floor tile 2 ND ND Outside room 268; 12x12 floor tile, dark brown; Black mastic 3 ND ND Outside room 253; 12x12 floor tile, dark brown; Floor tile 2 ND ND Outside room 253; 12x12 floor tile, dark brown; Black mastic 3 ND ND Room 248; 12x12 floor tile, dark brown; Floor tile 2 ND ND Room 248; 12x12 floor tile, dark brown; Black mastic 3 ND ND Room 198; Sink mastic; Undercoat 3 ND ND Room 265; Sink mastic; Undercoat 3 ND ND Patient waiting room; Textured finish on skylight ceiling area; Joint compound. Paint included as binder 2 ND ND

Patient waiting room; Textured finish on skylight ceiling area; Joint compound. Paint included as binder 2 ND ND

Medical records area; Textured finish on skylight ceiling area; Joint compound. Paint included as binder 2 ND ND

Room 244; Textured ceiling finish - swirl pattern; Texture. Paint included as binder 2 ND ND Room 245; Textured ceiling finish - swirl pattern; Texture. Paint included as binder 2 ND ND Room 245; Textured ceiling finish - swirl pattern; Joint compound. Paint included as binder 2 ND ND

South entrance; Transite panel - exterior soffit, smooth; Panel. Paint included as binder 15 ND ND South entrance; Transite panel - exterior soffit, peghole; Panel. Paint included as 15 ND ND Interior - work interview room; Window caulking; Caulk 3 ND ND Interior - room 1-259; Window caulking; Caulk. Paint included as binder 3 ND ND Interior - work interview room; Window glazing; Glazing 3 ND ND Interior - room 1-259; Window glazing; Glazing 3 ND ND Exterior outside work interview room; Window glazing; Glazing 3 ND ND Exterior outside room 1-259; Window glazing; Glazing 3 ND ND

General Notes:

2. ACM transite panels were identified throughout the exterior soffit of the building.

3. ACM sink mastic was identified on the underside of stainless steel sinks.

4. ACM window glazing and caulking were identified throughout the building windows.

5. ACM textured ceiling finish was identified in the skylights.

Building 103-1C

1031C-WG-04

1. ACM floor tile and/or mastic were identified throughout the building. Some may have 2 or 3 layers of flooring and the bottom layer were normally identified as ACM.

1031C-TP-02

1031C-WC-01

1031C-WC-02

1031C-WG-01

1031C-WG-02

1031C-WG-03

1031C-TC-1-02

1031C-TC-1-03

1031C-TC-2-01

1031C-TC-2-02

1031C-TC-2-02

1031C-TP-01

1031C-FT-3-02

1031C-FT-3-03

1031C-FT-3-03

1031C-SM-01

1031C-SM-02

1031C-TC-1-01

1031C-FT-2-02

1031C-FT-2-03

1031C-FT-2-03

1031C-FT-3-01

1031C-FT-3-01

1031C-FT-3-02

1031C-FT-1-02

1031C-FT-1-03

1031C-FT-1-03

1031C-FT-2-01

1031C-FT-2-01

1031C-FT-2-02

1031C-FT-1-01

1031C-FT-1-01

1031C-FT-1-02

GEI Consultants, Inc.

Battey Business Complex Rome, Georgia

CH AM CR

Sample DescriptionSample ID Asbestos Content (%)

--; --; Floor tile 5 ND ND --; --; Black mastic 3 ND ND Corridor across from room 73; 12x12 floor tile, dark brown; Floor tile 2 ND ND Corridor across from room 73; 12x12 floor tile, dark brown; Black mastic 3 ND ND Room 49; 12x12 floor tile, dark brown; Floor tile 2 ND ND Room 49; 12x12 floor tile, dark brown; Black mastic 3 ND ND West staircase landing; 12x12 floor tile, light brown; Floor tile 2 ND ND West staircase landing; 12x12 floor tile, light brown; Black mastic 3 ND ND Room 2-64; 12x12 floor tile, light brown; Floor tile 2 ND ND Room 2-64; 12x12 floor tile, light brown; Black mastic 3 ND ND Room 2-76; 12x12 floor tile, tan with brown streaks; Floor tile 2 ND ND Room 2-76; 12x12 floor tile, tan with brown streaks; Black mastic 3 ND ND Room 2-77; 12x12 floor tile, tan with brown streaks; Floor tile 2 ND ND Room 2-77; 12x12 floor tile, tan with brown streaks; Black mastic 3 ND ND Room 2-95; 12x12 floor tile, tan with red streaks; Floor tile 2 ND ND Lobby waiting room 2-01; 12x12 floor tile, tan with red streaks; Floor tile 2 ND ND Room 7; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 20; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 35; Joint compound; Joint compound 2 ND ND Room 49; Joint compound; Joint compound 2 ND ND Room 95; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 73 nurses station; Sink mastic, white; Under sink 3 ND ND Bathroom next to room 2-63; Sink mastic, black; Black mastic 3 ND ND Room 48; Vinyl sheet flooring; Backing 50 ND ND Room 48; Vinyl sheet flooring; Black mastic 3 ND ND Room 45; Vinyl sheet flooring; Backing 50 ND ND Room 45; Vinyl sheet flooring; Black mastic 3 ND ND Room 2-06; Window caulking; Black gray caulk 3 ND ND Room 2-06; Window glazing; Caulk 3 ND ND Room 2-93A; Window glazing; Caulk 3 ND ND

General Notes:

2. ACM joint compound was identified throughout the finished walls and ceilings of the building.

3. ACM window glazing and caulking were identified throughout the building windows.

4. ACM vinyl sheet flooring was identified in several rooms.

5. ACM sink mastic was identified on the underside of stainless steel sinks.

Building 103-2

1032-WG-02

1032-VSF-01

1032-VSF-01

1032-VSF-02

1032-VSF-02

1032-WC-01

1032-WG-01

1. ACM floor tile and/or mastic were identified throughout the building. Some may have 2 or 3 layers of flooring and the bottom layer was normally identified as ACM.

1032-JC-02

1032-JC-03

1032-JC-04

1032-JC-05

1032-SM-01

1032-SM-02

1032-FT-3-01

1032-FT-3-02

1032-FT-3-02

1032-FT-4-01

1032-FT-4-02

1032-JC-01

1032-FT-1-02

1032-FT-2-01

1032-FT-2-01

1032-FT-2-02

1032-FT-2-02

1032-FT-3-01

1032-FD-01

1032-FD-01

1032-FT-1-01

1032-FT-1-01

1032-FT-1-02

GEI Consultants, Inc.

Battey Business Complex Rome, Georgia

CH AM CR

Sample DescriptionSample ID Asbestos Content (%)

--; --; Joint compound. Paint included as binder 2 ND ND Room 3-03; 12x12 floor tile, light brown; Floor tile 2 ND ND Room 3-03; 12x12 floor tile, light brown; Black mastic 5 ND ND Corridor by room 3-39; 12x12 floor tile, tan with brown streaks; Floor tile 2 ND ND Corridor by room 3-39; 12x12 floor tile, tan with brown streaks; Black mastic 5 ND ND Room 3-16; 12x12 floor tile, green with grey specks; Floor tile 2 ND ND Room 3-16; 12x12 floor tile, green with grey specks; Black mastic 5 ND ND Room 3-47; 12x12 floor tile, green with grey specks; Floor tile 2 ND ND Room 3-47; 12x12 floor tile, green with grey specks; Black mastic 5 ND ND Room 3-03; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 3-11; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 3-18; Joint compound; Joint compound 2 ND ND Room 3-43; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 3-47; Joint compound; Joint compound. Paint included as binder 2 ND ND Room 3-03; Window glazing; Glazing 3 ND ND Corridor 3-19; Window glazing; Glazing 3 ND ND

General Notes:

2. ACM joint compound was identified throughout the finished walls and ceilings of the building.

3. ACM window glazing was identified throughout the building windows.

Building 103-3

1033-JC-03

1033-JC-04

1033-JC-05

1033-WG-01

1033-WG-02

1033-FT-4-01

1033-FT-4-01

1033-FT-4-02

1033-FT-4-02

1033-JC-01

1033-JC-02

1. ACM floor tile and/or mastic were identified throughout the building. Some may have 2 or 3 layers of flooring and the bottom layer was normally identified as ACM.

1033-FD-01

1033-FT-1-01

1033-FT-1-01

1033-FT-2-01

1033-FT-2-01

GEI Consultants, Inc.

Battey Business Complex Rome, Georgia

CH AM CR

Sample DescriptionSample ID Asbestos Content (%)

--; --; Glazing 5 ND ND Room 17; 12"x12" floor tile (white with grey flecks on second layer olive floor tile);

Brown floor tile 3 ND ND

Room 17; 12"x12" floor tile (white with grey flecks on second layer olive floor tile); Black mastic 3 ND ND

Corridor 1 across from room 4; 12"x12" floor tile (white with grey flecks on second layer olive floor tile); Gray floor tile 2 ND ND

Corridor 1 across from room 4; 12"x12" floor tile (white with grey flecks on second layer olive floor tile); Black mastic 3 ND ND

Hallway across from room 12; 12"x12" floor tile (pink on second layer olive floor tile);

Gray floor tile 2 ND ND

Hallway across from room 12; 12"x12" floor tile (pink on second layer olive floor tile);

Black mastic 3 ND ND

Room 7; 12"x12" floor tile (pink on second layer olive floor tile); Gray floor tile 2 ND ND Room 7; 12"x12" floor tile (pink on second layer olive floor tile); Black mastic 3 ND ND Room 14; 12"x12" floor tile (aqua on second layer olive floor tile); Gray floor tile 2 ND ND Room 14; 12"x12" floor tile (aqua on second layer olive floor tile); Black mastic 3 ND ND Room 26; 12"x12" floor tile (aqua on second layer olive floor tile); Gray floor tile 2 ND ND Room 26; 12"x12" floor tile (aqua on second layer olive floor tile); Black mastic 3 ND ND Room 13; Glue dabs; Mastic. Paint included as binder 3 ND ND Room 14; Glue dabs; Mastic. Paint included as binder 3 ND ND Room 32; Sink mastic; Coating 3 ND ND Outside room 8; Transite panel exterior soffit - peghole; Panel. Paint included as binder 15 ND ND Outside room 3; Transite panel exterior soffit - smooth; Panel. Paint included as binder 15 ND ND Room 31; Vinyl sheet flooring; Tan floor tile 2 ND ND Room 31; Vinyl sheet flooring; Black mastic 3 ND ND Room 33; Vinyl sheet flooring; Tan floor tile 2 ND ND Room 33; Vinyl sheet flooring; Black mastic 3 ND ND Room 29; Vinyl sheet flooring; Tan floor tile 2 ND ND Room 29; Vinyl sheet flooring; Black mastic 3 ND ND Interior - Room 17; Window caulking; Glazing. Paint included as binder 3 ND ND Interior - Room 24; Window caulking; Glazing. Paint included as binder 3 ND ND Interior - Room 17; Window glazing; Glazing 5 ND ND Interior - Room 24; Window glazing; Glazing 5 ND ND Exterior - Room 14; Window glazing; Glazing 5 ND ND

General Notes:

2. ACM vinyl sheet flooring was identified in several rooms.

3. ACM window glazing and caulking were identified throughout the building windows.

4. ACM glue dabs were identified on walls in rooms 13 and 14.

5. ACM sink mastic undercoat was identified in room 32.

Building 104

104-WC-02

104-WG-01

104-WG-02

104-WG-03

1. ACM floor tile and/or mastic were identified throughout the building.