Attachment 3 09-16368 Waco Bldg. 17 Report.pdf

ASBESTOS ASSESSMENT

ASBESTOS REINSPECTION REPORT

Waco V.A. Medical Center

4800 Memorial Drive

Waco, Texas

Building 17

Prepared for:

Central Texas Veterans Health Care System

Waco V.A. Medical Center

4800 Memorial Drive

Waco, Texas

Prepared by:

P. O. Box 17867

Shreveport, Louisiana 71138-0867

(318) 687-3771

INTRODUCTION

2009 ASBESTOS REINSPECTION REPORT

CENTRAL TEXAS VETERANS HEALTH CARE SYSTEM

WACO VA MEDICAL CENTER

SCOPE OF WORK

1. The owner requested that no previous information be utilized during this reinspection.

Therefore, ALTEC treated this project as an initial asbestos assessment and sampled accordingly.

2. This asbestos reinspection complies with the requirements of Asbestos Hazard

Emergency Response Act (AHERA).

3. Each facility inspection was performed by an accredited inspector.

4. For each facility, the inspector performed the following tasks:

a. Visually inspected all accessible areas for suspect asbestos-containing material

(ACM).

b. Asbestos bulk samples were collected of all suspected materials and the samples were analyzed by EMSL Laboratories which is an NVLAP-accredited laboratory authorized to analyze asbestos bulk samples.

c. If any of the asbestos bulk samples contained asbestos from 1% to 5% in asbestos content, then the laboratory was requested to perform a Polarized Light

Microscopy (PLM) point count of that material for a more accurate analysis.

d. After reviewing the results from the asbestos bulk samples and subsequent point counting, homogeneous areas were determined for the various asbestos-containing materials.

e. Homogeneous area tables were prepared and condition summaries were completed.

f. A report was then completed that is outlined in the report section that follows this scope of work.

g. A management planner reviewed all work provided above and verified that the plan met all AHERA requirements. The appropriate response actions were recommended and the reinspection signed and dated. This report included the accreditation number of inspectors and planners. A copy of the 2009 Asbestos

Reinspection Report was submitted to the owner.

MANAGEMENT PLAN RECOMMENDATIONS

The following general notes are for all facilities inspected during the Asbestos Reinspection:

1. Removal Priorities were developed for each homogeneous area. The Removal Priorities are an indicator of priorities for future repair work or abatement work to be scheduled as financial budgets allow. Please see the 2009 Reinspection Condition and Removal

Priority Table for further details.

2. The current condition of material was listed for each homogeneous area. The condition, location, and potential for disturbance factors are used for the hazard ranking. Please see the 2009 Reinspection Condition and Removal Priority Table for the condition summaries.

3. Records for custodial, janitorial, and maintenance staff who have received two-hour awareness training should be filed in the Management Plan.

4. Any new custodial, janitorial, or maintenance staff that have the potential to come in contact with asbestos-containing materials (ACM) are required to attend a two-hour awareness training class. Records of training for new employees should be filed in the

Management Plan.

5. The Designated Person is required to inform workers and building occupants at least once a year about the Management Plan. This includes information about inspections, response actions, and post-response action activities that are planned or in progress.

6. Maintenance areas (boiler rooms, janitor closets, etc.) are required to have warning labels where ACM is located. Install warning labels in these areas as needed. Some older labels may have come loose and are no longer visible. Post the labels in a prominent location.

7. Review the enclosed 2009 Reinspection Condition and Removal Priority Table for maintenance actions that may be required and to establish priorities and budgets for future repair and abatement work.

8. Periodic “Surveillance Inspections” are required every six (6) months. This inspection should indicate the condition of the material and provide recommendations for repair or potential removal. Consistency of inspections is desired and, therefore, should be performed by the same individual(s) for all facilities. An accredited inspector is not required, but is recommended. Records of Surveillance Inspections should be filed in both the administrative and facility Management Plans.

9. “Reinspections” are required every three (3) years. Updated information should be added to the Management Plan.

10. An accredited “Supervisor” should be on staff or available on a contract basis per

AHERA guidelines. Certification paperwork should be filed in the training section of the

Management Plan.

11. ACM should only be removed by contractors licensed and accredited in the State of

Texas. Response actions related to abatement activity should be filed in the Management

Plan. Removal of limited amounts of asbestos by the accredited Supervisor and trained individuals is within the scope of the Management Plan.

12. Notification should be provided to “outside contractors” about ACM within the facility.

This should include such trades or services as telephone, electrical, plumbing, air conditioning, and other construction work. A form should be created for this purpose and placed in the Management Plan.

13. New building construction and portable buildings added to a facility are required to be inspected and sampled for ACM. In lieu of this, a letter from the architect, engineer, or manufacturer can be obtained that states “no ACM were specified or used in the facility.”

A copy of this letter is to be filed with the Management Plan at the facility. This letter will cancel the requirement for sampling.

14. Abatement Costs were developed for each homogeneous area and per facility. The estimated abatement cost is for budget purposes only. The cost is based on the area of material and estimated abatement costs for this material. The cost is for abatement only and does not include abatement design, air monitoring, or project observation costs.

POINT COUNT PROCEDURES

If any of the initial asbestos bulk samples that were analyzed by the laboratory resulted in asbestos content of 1% to 5%, then the samples were analyzed by PLM point counting method.

This method allows for a more precise analysis of the percentage of asbestos fibers in an asbestos bulk sample.

The following were the guidelines that were followed in analyzing this data:

1. If the original asbestos bulk sample analysis resulted in:

a. A non-detect level, then the material was immediately classified as not containing asbestos.

b. An asbestos content greater than 5%, then the material was considered to contain asbestos and would be a regulated material.

c. An asbestos content from 1% to 5%, then the material was PLM point counted to determine a more accurate percentage.

2. If the original asbestos bulk sample was point counted and analysis resulted in:

a. An asbestos content greater than 1% asbestos, then the material was considered to contain asbestos and would be a regulated material.

b. An asbestos content 1% or less, then the material would be considered to be at or below the Environmental Protection Agency (EPA) regulated limit of 1% asbestos content and would not be regulated under AHERA.

After analyzing these results, all documentation, tables, and drawings were changed to reflect these analytical results.

REPORT SECTION

2009 ASBESTOS REINSPECTION REPORT

This report will include a combination of the following sections:

ACM Homogeneous Areas Summary Table and Drawings

This section provides a quick table reference to all asbestos-containing homogeneous areas found during the reinspection, and to drawings with the asbestos-containing homogeneous areas found during the 2009 asbestos reinspection.

This section will not be included in the building reports that did not require any sampling due to no suspected ACM being present. The section will also not be included if asbestos bulk samples were collected and the results indicated no asbestos-containing materials were found in that building.

Condition and Removal Priority Table

This section provides a table with the current condition, potential for disturbance, and removal priority for each homogeneous area.

Master Summary Table – Asbestos Bulk Samples

This table provides a listing of all asbestos bulk samples taken to date.

no suspected ACM being present.

Asbestos-Containing Bulk Samples

This table provides a listing of all asbestos-containing bulk samples.

2009 Reinspection – Inspection Logs

This section provides the field inspection logs for samples taken during the 2009 asbestos reinspection.

Bulk Sample Location Drawings

This section provides drawings with sample locations for all asbestos bulk samples.

Site and sample location drawings will be included in the building reports that did not require any sampling due to no suspected ACM being present.

2009 Reinspection – Photographs

This section provides photographs of all asbestos bulk samples taken during the 2009 asbestos reinspection.

2009 Reinspection – Laboratory Reports

This section provides all laboratory analytical results.

Certifications

This section provides certifications for all Inspectors, the Management Planner who reviewed this Management Plan, and the laboratory that performed the bulk sample analysis.

Periodic Surveillance Forms

This section includes the forms to be completed during the periodic surveillance inspections required every six (6) months.

This section will not be required for building reports that did not require any sampling due to no suspected ACM being present. This section will also not be required if asbestos bulk samples

Management Plan Updates

This section includes the records of any asbestos abatement activities that are completed at the subject site. Notifications, daily notes, drawings, etc., should be placed in this section. This would also include air-monitoring data from asbestos abatement projects.

Response Actions

This section includes the records of any internal asbestos abatement or operation and maintenance activities that may be completed by VA employees. This would include any drawings, field notes, and air monitoring that was completed.

Training Documents

This section includes the records of training for the Designated Person and accredited

Supervisor, as well as the two-hour awareness training for the custodial, janitorial, and maintenance staff.

CONTRACTOR

2009 ASBESTOS REINSPECTION REPORT

This 2009 Asbestos Reinspection was provided by:

Contractor:

ALTEC Environmental Consultants, Inc.

10100 Woolworth Road

Keithville, LA 71047

(318) 687-3771 (Office)

(318) 687-9923 (Fax)

INSPECTORS:

Brandon Odom Donald R. Joiner

LA Certificate No. 0I01392 LA Certificate No. 0I01348

Gray Chase Jerry Heidecker

LA Certificate No. 0I01035 LA Certificate No. 0I01698

Justin L. Holcomb Brandon Sanders

LA Certificate No. 0I00306 LA Certificate No. 0I01097

MANAGEMENT PLANNER:

Roy W. Dowling

LA Certificate No. 0I00213 – Inspector

LA Certificate No. 0P00072 – Management Planner

Accreditation Agency: Louisiana Department of Environmental Quality which is a recognized EPA accreditation agency

ACM HOMOGENEOUS AREAS

SUMMARY TABLE AND DRAWINGS

WACO V. A. MEDICAL CENTER

2009 THREE-YEAR ASBESTOS REINSPECTION

ACM HOMOGENEOUS AREAS SUMMARY TABLE

Floor Flooring Materials Ceiling Materials TSI Materials Miscellaneous Materials

Basement No ACM No ACM No ACM No ACM

Floor Flooring Materials Ceiling Materials TSI Materials Miscellaneous Materials

1 HMA-01 - Flooring Mastic No ACM No ACM No ACM

Floor Flooring Materials Ceiling Materials TSI Materials Miscellaneous Materials

Roof No ACM No ACM No ACM No ACM

Building 17 - Basement

Building 17- First Floor

Building - Roof

CONDITION AND REMOVAL PRIORITY TABLE

Qualitative Ranking Numerical Rating

Good 8, 9, 10

Fair 4, 5, 6, 7

Poor 1, 2, 3

Physical Disturbance Environmental Disturbance

Low 1, 2, 3

Medium 4, 5, 6, 7

High 8, 9, 10

Qualitative Ranking Numerical Rating

High 1, 2, 3

Medium 4, 5, 6, 7

Low 8, 9, 10

Address with on-going maintenance procedures

Maintain in good condition

Surfacing material has moderate but not extensive amounts of visible damage; covering on thermal system insulation is cut or torn, exposing moderate but not extensive amounts of insulation; moderate but not extensive damage to miscellaneous materials such as floor tile; moderate but not extensive amounts of visible dust and debris..

Qualitative Rankings and Quantitative (Numerical) Ratings for Removal Priority

Description of Current Condition

Address short-term

Extensive damage to surfacing material; covering on thermal system insulation is cut or torn extensively and insulation itself is damage; miscellaneous materials such as floor tile extensively damaged and underlying mastic exposed; extensive amounts of dust and debris.

Accessibility: accessibility during normal operations

Activities: activities that people do and how often they do them

Vibration: vibration from operating machinery, HVAC equipment, and so forth

Air/Dust: air currents strong enough to dislodge loose

ACM; airborne dust that can erode material

Corrosive: corrosive atmosphere or liquids that can erode the covering or matrix

Water Damage: water damage from leaking roof, pipe or other source

Qualitative Rankings and Quantitative (Numerical) Ratings for Current Condition

Qualitative Rankings and Quantitative (Numerical) Ratings for Potential for Disturbance

Assessment Factors Qualitative Ranking Numerical Rating

Description of Current Condition

Surfacing material has no visible damage or small amounts of damage; covering on thermal system insulation is intact or has small amounts of damage; miscellaneous materials intact; no visible debris or small amounts of debris.

CONDITION AND REMOVAL PRIORITY TABLE

Rating Based On Rating Based On

HMA-1 17 1 Floor Mastic No No 10 Intact 1 Access 9

Floor Material Description

Building - Roof

Removal

Priority

Building 17 - First Floor

Current Condition

Building 17 - Basement

Friable

Yes/No

No ACM

No ACM

Accessibility

Yes/No

Restricted

Potential for

Disturbance 2Homogeneous

Area No.

Bldg

MASTER SUMMARY TABLE

ASBESTOS BULK SAMPLES

SUMMARY OF BULK SAMPLES TAKEN TO DATE

(determined by Point Count analysis)

Building Floor Room Sample ID Material Description

17 1 2A WA-09-292-0521 White 12x12 floor tile, yellow mastic

17 1 2A WA-09-292-0522 Red 12x12 floor tile, yellow mastic

17 1 2 WA-09-292-0523 Layer 1 - tan 12x12 floor tile

17 1 2 WA-09-292-0523 Layer 2 - black mastic

17 1 2B WA-09-292-0524 Layer 1 - tan 12x12 floor tile

17 1 2B WA-09-292-0524 Layer 2 - black mastic

17 1 2A WA-09-292-0525 Layer 1 - tan 12x12 floor tile

17 1 2A WA-09-292-0525 Layer 2 - black mastic

17 1 2 WA-09-292-0526 White 12x12 floor tile, yellow mastic

17 1 3A WA-09-292-0527 Gray and white 12x12 floor tile, yellow mastic

17 1 3 WA-09-292-0528 Gray and white 12x12 floor tile, yellow mastic

17 1 2 WA-09-292-0529 White 12x12 floor tile, yellow mastic

17 1 2 WA-09-292-0530 Red 12x12 floor tile, yellow mastic

17 1 2C WA-09-292-0531 Gray 12x12 floor tile, yellow mastic

17 1 71 WA-09-292-0532 12-inch vertical pipe - yellow insulation, white wrap

17 Roof Roof WA-09-292-0533 Black flashing, silver wrap

17 Roof Roof WA-09-292-0534 9-inch horizontal pipe - yellow insulation, white wrap

17 Roof Roof WA-09-292-0535 9-inch elbow pipe - yellow insulation, white wrap

17 Base-ment Tank Room WA-09-292-0536 8-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Tank Room WA-09-292-0537 3-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Tank Room WA-09-292-0538 10-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Tank Room WA-09-292-0539 8-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Tank Room WA-09-292-0540 Red gasket material

17 Base-ment Tank Room WA-09-292-0541 10-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Tank Room WA-09-292-0542 7-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Crawl 104 WA-09-292-0543 8-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Crawl 104 WA-09-292-0544 3-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment Crawl 104 WA-09-292-0545 7-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment 104 WA-09-292-0546 3-inch horizontal pipe - yellow insulation, white wrap

17 Base-ment 104 WA-09-292-0547 5-inch vertical pipe - yellow insulation, white wrap

17 1 4 WA-09-292-1001 2x4 ceiling tile

17 1 2A WA-09-292-1002 2x4 ceiling tile

17 1 Entry Way WA-09-292-1003 2x4 ceiling tile

Red = Asbestos-Containing Material (ACM) Blue = Non ACM Green = Non Asbestos-Containing Material

ASBESTOS-CONTAINING BULK SAMPLES

LIST OF ASBESTOS-CONTAINING SAMPLES

Building Floor Room Sample ID Material Description

17 1 2 WA-09-292-0523 Layer 2 - black mastic

17 1 2B WA-09-292-0524 Layer 2 - black mastic

17 1 2A WA-09-292-0525 Layer 2 - black mastic

Red = Asbestos-Containing Material (ACM)

2009 REINSPECTION INSPECTION LOG

Client: Date: October 19, 2009

Location: Gray Chase and Brandon Sanders

4800 Memorial Drive, Waco, Texas

(determined by Point Count analysis)

ASBESTOS INSPECTION LOG

Inspector(s):

NOTE: Red = Asbestos-containing Material Blue = Non Asbestos-containing Material Green = Non Asbestos-containing Material

Central Texas Veterans Health Care System

Waco V. A. Medical Center

Sample ID Material Description

M at er ia l

C at eg or y

Fria bi lit y

C on di tio n

Bui ld in g

Flo or

R oo m Location Asbestos

% Type

WA-09-292-0521 White 12x12 floor tile, yellow mastic M NF 9 17 1 2A Northwest quadrant ND

WA-09-292-0522 Red 12x12 floor tile, yellow mastic M NF 9 17 1 2A Northwest quadrant ND

WA-09-292-0523 Layer 1 - tan 12x12 floor tile M NF 9 17 1 2 Southwest quadrant ND

WA-09-292-0523 Layer 2 - black mastic M NF 9 17 1 2 Southwest quadrant 3.6% chry

WA-09-292-0524 Layer 1 - tan 12x12 floor tile M NF 9 17 1 2B Southwest quadrant ND

WA-09-292-0524 Layer 2 - black mastic M NF 9 17 1 2B Southwest quadrant 3.0% chry

WA-09-292-0525 Layer 1 - tan 12x12 floor tile M NF 9 17 1 2A Southeast quadrant ND

WA-09-292-0525 Layer 2 - black mastic M NF 9 17 1 2A Southeast quadrant 3.8% chry

WA-09-292-0526 White 12x12 floor tile, yellow mastic M NF 8 17 1 2 Southwest quadrant ND

WA-09-292-0527 Gray and white 12x12 floor tile, yellow mastic M NF 9 17 1 3A Southeast quadrant ND

WA-09-292-0528 Gray and white 12x12 floor tile, yellow mastic M NF 9 17 1 3 Northwest quadrant ND

WA-09-292-0529 White 12x12 floor tile, yellow mastic M NF 9 17 1 2 Southeast quadrant ND

4800 Memorial Drive, Waco, Texas

(determined by Point Count analysis)

ASBESTOS INSPECTION LOG

Inspector(s):

NOTE: Red = Asbestos-containing Material Blue = Non Asbestos-containing Material Green = Non Asbestos-containing Material

Central Texas Veterans Health Care System

Waco V. A. Medical Center

Sample ID Material Description

M at er ia l

C at eg or y

Fria bi lit y

C on di tio n

Bui ld in g

Flo or

R oo m Location Asbestos

% Type

WA-09-292-0530 Red 12x12 floor tile, yellow mastic M NF 9 17 1 2 Southeast quadrant ND

WA-09-292-0531 Gray 12x12 floor tile, yellow mastic M NF 9 17 1 2C Southeast corner ND

WA-09-292-0532 12-inch vertical pipe - yellow insulation, white wrap T F 8 17 1 71 Northeast quadrant ND

WA-09-292-0533 Black flashing, silver wrap M NF 9 17 Roof Roof South base of AHU-7 air unit ND

WA-09-292-0534

9-inch horizontal pipe - yellow insulation, white wrap T F 9 17 Roof Roof Northwest quadrant ND

WA-09-292-0535 9-inch elbow pipe - yellow insulation, white wrap T F 9 17 Roof Roof Northwest quadrant ND

WA-09-292-0536

8-inch horizontal pipe - yellow insulation, white wrap T F 8 17

Base-ment

Tank

Room Southeast end ND

WA-09-292-0537

3-inch horizontal pipe - yellow insulation, white wrap T F 8 17

Base-ment

Tank

Room Southeast end ND

WA-09-292-0538

10-inch horizontal pipe - yellow insulation, white wrap T F 8 17

Base-ment

Tank

Room Southeast end ND

WA-09-292-0539

8-inch horizontal pipe - yellow insulation, white wrap T F 8 17

Base-ment

Tank

Room Center ND

WA-09-292-0540 Red gasket material M F 5 17 Base-ment

Tank

Room West side, Tank 2 at 3-inch flange ND

WA-09-292-0541

10-inch horizontal pipe - yellow insulation, white wrap T F 8 17

Base-ment

Tank

Room Southwest corner ND

4800 Memorial Drive, Waco, Texas

(determined by Point Count analysis)

ASBESTOS INSPECTION LOG

Inspector(s):

NOTE: Red = Asbestos-containing Material Blue = Non Asbestos-containing Material Green = Non Asbestos-containing Material

Central Texas Veterans Health Care System

Waco V. A. Medical Center

Sample ID Material Description

M at er ia l

C at eg or y

Fria bi lit y

C on di tio n

Bui ld in g

Flo or

R oo m Location Asbestos

% Type

WA-09-292-0542

7-inch horizontal pipe - yellow insulation, white wrap T F 8 17

Base-ment

Tank

Room Southwest corner ND

WA-09-292-0543

8-inch horizontal pipe - yellow insulation, white wrap T F 4 17

Base-ment

Crawl

Crawlspace 104, east side, 12 feet inside access hatch

ND

WA-09-292-0544

3-inch horizontal pipe - yellow insulation, white wrap T F 6 17

Base-ment

Crawl

Crawlspace 104, northwest quadrant ND

WA-09-292-0545

7-inch horizontal pipe - yellow insulation, white wrap T F 7 17

Base-ment

Crawl

Crawlspace 104, west side, middle ND

WA-09-292-0546

3-inch horizontal pipe - yellow insulation, white wrap T F 7 17

Base-ment 104 South end, center ND

WA-09-292-0547 5-inch vertical pipe - yellow insulation, white wrap T F 7 17 Base-ment 104 East wall, center ND

WA-09-292-1001 2x4 ceiling tile M NF 9 17 1 4 Northeast quadrant of room ND

WA-09-292-1002 2x4 ceiling tile M NF 9 17 1 2A Northeast quadrant of room ND

WA-09-292-1003 2x4 ceiling tile M NF 9 17 1 Entry

Way Southwest corner of room ND

ND=None DetectedPlease use the following guidelines when reading this report:

GOOD = Surfacing material has no visible damage or small amounts of damage; covering on thermal system insulation is intact or has small amounts of damage; miscellaneous materials intact; no visible debris or small amounts of debris. FAIR = Surfacing material has moderate but not extensive amounts of visible damage; covering on thermal system insulation is cut or torn, exposing moderate but not extensive amounts of insulation; moderate but not extensive damage to miscellaneous materials such as floor tile; moderate but not extensive amounts of visible dust and debris. POOR = Extensive damage to surfacing material; covering on thermal system insulation is cut or torn extensively and insulation itself is damaged; miscellaneous materials such as floor tile extensively damaged and underlying mastic exposed; extensive amounts of dust and debris.

Material Category: T=TSI S=Surfacing M=Miscellaneous Friability: F=Friable NF=Non-Friable Condition: Good = 8, 9, 10 Fair = 4, 5, 6, 7 Poor = 1, 2, 3

BULK SAMPLE LOCATION DRAWINGS

Basement

First Floor

Roof

2009 REINSPECTION PHOTOGRAPHS

WACO VETERANS ADMINISTRATION MEDICAL CENTER

BUILDING 17

WACO, TEXAS

sample contains asbestos sample does not contain asbestos sample does not contain asbestos determined by point count

WA-09-292-0521 WA-09-292-0522

WA-09-292-0523 WA-09-292-0524

WA-09-292-0525 WA-09-292-0526

WA-09-292-0527 WA-09-292-0528

WA-09-292-0529 WA-09-292-0530

WA-09-292-0531 WA-09-292-0532

WA-09-292-0533 WA-09-292-0534

WA-09-292-0535 WA-09-292-0536

WA-09-292-0537 WA-09-292-0538

WA-09-292-0539 WA-09-292-0540

WA-09-292-0541 WA-09-292-0542

WA-09-292-0543 WA-09-292-0544

WA-09-292-0545 WA-09-292-0546

WA-09-292-0547 WA-09-292-1001

WA-09-292-1002 WA-09-292-1003

2009 REINSPECTION LABORATORY REPORTS

CERTIFICATIONS

PERIODIC SURVEILLANCE FORMS

6-MONTH ASBESTOS SURVEILLANCE

BUILDING 17 – FIRST FLOOR

HMA Material Description Location Friable

Yes/No

Conditions at Last

Inspection1

Damage

Severity2

Conditions at Current

Inspection1

Comments

HMA-01 Flooring Mastic First Floor

Conditions: G=Good R=Repaired D=Damaged SD= Significantly Damaged

Damage Severity: M=Minor O=Occasional X-Extensive P=Punctures N=None

Printed Competent Person’s Name

Asbestos Inspector Certification Number and Expiration Date

Signature

Surveillance Inspection Date

MANAGEMENT PLAN UPDATE

RESPONSE ACTIONS

TRAINING DOCUMENTS

ANNUAL NOTIFICATION LETTERS