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This document provides a working checklist for compliance with an environmental site assessment (otherwise, environmental due diligence) for both commercial and industrial property. Also serves for All-Appropriate Inquiries (40CFR312 and ASTM Method E1527-05) as required by the Brownfields Revitalization Act.
PHASE I ENVIRONMENTAL ASSESSMENT STANDARD CHECKLIST TO DEVELOP THE SCOPE OF WORK Consulting Firm: Address: Phone: Date: Person(s) conducting the assessment: (a) Business Information 1. Provide basic information for this facility including: a) b) c) d) e) f) g) h) i) Business Name Location, Address (include County) Contacts (names and titles) Phone Numbers Facility SIC Code Facility Operator Facility Owner Owner and Operator Addresses Owner and Operator Phone Numbers 2. Does Business own or lease this property? If leased, provide owner name and address. 3) List all other locations where this business has: a) Employees, land or facilities b) 4) 5) 6) 7) Materials stored, supplies or vehicles List all prior locations of this operation (include dates). Number of years at current location. Obtain a site layout and plot plan of the facilities and property. Mark locations of key features and recommendations. Use a camera to take photos of potential problem areas and include photos in report with explanation. Describe current use of property and facility. Describe site geology. Include local subsurface information, information from soil boring data, information used to design the plant, excavations, etc. (b) Site Information 1) 2) 3) Describe site hydrogeology. Include ground water depth, known uses of ground water, ground water flow: volume and direction, ground water wells, which facility does or can monitor, has contamination been detected, if so, describe, identify any drinking water wells within a two-mile radius of property. 4) Describe site meteorological trends. SITE ASSESSMENT CHECKLIST 5) Describe site drainage patterns and impact on potential contamination. 6) Describe site easements. 7) Is location urban or rural? 8) Is area industrial, commercial, residential, or undeveloped? 9) Describe surface water within 500 feet (include flow and discharge). Locate on map. 10) Provide size of property (acres) and provide map of the area. 11) Describe developed area: buildings, paved areas, acres or square feet, building ages and construction materials arid locate on map. 12) Provide area and description of undeveloped property (acres or sq. ft.) and locate on map. 13) Describe any major demolition that occurred on-site. Include dates and locate areas on map. 14) Provide Site Utilities and Suppliers. a) b) c) d) Electric Gas Water Sewer (sanitary, industrial and storm) Locate on map. e) Other 15) Is local water supply provided by private wells or a central water system? 16) Does the site use well water? For each well include: a. Well depth b. Well delivery rate c. d. e. Well water use Were any wells capped within the last five years? If yes, explain why. Locate on map. 17) Does the site have any active or inactive monitoring wells? a) Describe sampling protocol and results. b) Describe why the monitoring wells were installed. c) Locate on map. 18) Does runoff from the site flow onto or into: a) Other property — provide direction and property owner b) Surface water c) Storm drainage systems SITE ASSESSMENT CHECKLIST 1. 2. Storm sewer discharge point What else is discharged to storm water? 19) Is the facility in the 25-year or 100-year flood plain? 20) Has this facility even been flooded? Describe and provide dates. 21) Is the facility in wetlands area? Describe the hydric soils. Describe whether the site has been mapped as a wetland by the Department of Interior or state or local planning areas. Include the date of the report and the areas designated as wetlands on the site map. 22) Describe vegetation on property. a) b) c) d) e) Typical vegetation Any areas of exposed soil or dead vegetation. Locate on map. Any newly surfaced areas or disturbed soil. Locate on map. Any evidence of spill. Locate on map. Do ditches have signs of sludge, discoloration or oil sheen? Locate on map. f) Any evidence of spills, releases or contamination on the property? Locate on map. 23) Describe any previous, current, or planned remediation on this property. Locate on map. 24) Do neighbors or authorities complain about odors, discharges or noise from this facility? 25) Describe general appearance of facility and grounds. Comment on the general housekeeping. 26) Other observations. (c) Site History 1) List the names of previous owners or operators of the facility for the previous sixty (60) years. If a title search is used, attach it as an exhibit to your report. For each owner or operator, provide the following information: a) The period of ownership or operation. b) The type of 'activity or manufacturing process conducted at the facility. c) The kinds of wastes or throw offs and any potential on-site contamination. d) How the wastes were disposed. e) Describe wastes stored, treated or disposed of on property. 2) Review and provide copies of available topographic maps, geologic surveys, historical maps and aerial photographs of the facility. Discuss the results of the review; include any indicators of potential on-site contamination. 3) Contact the planning or building commission and ask about the prior use of the facility and the adjoining property. Ask about zoning and zoning changes in the area of the facility (e.g. from residential to industrial). Review neighborhood zoning and land use maps. Determine whether the property was ever the site of an industrial or manufacturing concern or whether property was ever a disposal site for on-site or off-site wastes. 4) Obtain and evaluate copies of any filings and/or inspection reports concerning t he facility by any federal, state, or local environmental authorities. SITE ASSESSMENT CHECKLIST 5) 6) 7) Make appropriate inquiry to determine whether any past owner or operator of the facility received notice that it is or may be potentially responsible person in connection with response costs, including costs of removal or remedial action under CERCLA. Contact appropriate agencies to determine whether there is any known ongoing environmental investigation by federal, state, or local government agencies of any site within a two-mile radius of the facility. Make appropriate inquiry to determine whether any past owners have received notification from any private citizen, group, or governmental entity of an intent to file a lawsuit alleging a violation of federal or state environmental laws or damage to natural resources. Obtain and evaluate copies of any such notices. Make appropriate inquiry to determine whether any suits have been instituted by private citizens or governmental entities which seek civil or criminal damages or injunctive relief arising out of alleged violations of federal or state environmental laws or damage to natural resources, or alleging trespass, nuisance. 8) (d) Adjacent Property Information 1) Provide names and location of current adjacent property owner or operators. 2) For each adjacent property: a. Describe the current use. b. Describe previous uses. c. Does the adjacent property have any environmental impact on this facility? d. Is any of the adjacent property used for petroleum storage or delivery? e. Is any of the adjacent property used for chemical manufacturing? f. Describe surrounding vegetation and any indication of adverse environmental impact. g. Determine whether any complaints, citations, or notices of violation were filed or issued to the current or previous owner or operator of adjacent property. h. Is there any indication of on-site disposal or soil contamination? 3) Identify: a) National Priorities List sites in the area. h) CERCLIS sites and comparable state list sites in the area. c) Active landfill or land disposal sites in the area. d) Inactive or closed landfill or land disposal sites in the area. e) Any other potential concerns in the area. f) Any past or current treatment or disposal sites that may cause liabilities. 4) Obtain and evaluate copies of any filings and/or inspection reports concerning adjoining properties by any federal, state, or local environmental authorities. 5) Do the sites have any active or inactive monitoring wells? a) Describe sampling protocol and results. SITE ASSESSMENT CHECKLIST b) Describe why the monitoring wells were installed. c) Locate on map. 6) Does runoff from adjacent sites flow onto or into? a) Site property - provide direction and property owner b) Surface water c) Storm drainage systems 1. Storm sewer discharge point 2. What else is discharged to storm water (e) General information 1) 2) 3) 4) 5) 6) 7) 8) Describe in detail current operations, processes. Locate on map. Attach flow chart for processes, if available. Describe previous operations and processes. Include discussion of potential environmental impact. Locate on map. Describe off-site and on-site remediation action that owner or operator is involved in or has been asked to participate in. If on-site, locate on map. Describe potentially responsible party (PRP) notifications that the owner or operator has received or expects to receive. List all notices, violations and fines against the facility for alleged violations. Review and describe all documentation including remaining issues. Describe any known or suspected environmental problems associated with the property (both current and past). If on-site, locate on map. Describe any previous, current or planned remediation on this property. Locate on map. Contact appropriate agencies to determine whether there is any known ongoing environmental investigation or any noncompliance issues by federal, state, or local government agencies. 9) Make appropriate inquiry to determine whether current owners have received notification from any private citizen, group, or governmental entity of an intent to file a lawsuit alleging a violation of federal or state environmental laws or damage to natural resources. Obtain and evaluate copies of any such notices. 10) Make appropriate inquiry to determine whether any suits have been instituted by private citizens or governmental entities which seek civil or criminal damages or injunctive relief arising out of alleged violations of federal or state environmental laws or damage to natural resources, or alleging trespass, nuisance. 11) Describe any environmental testing that has been carried out at the property (e.g. well sampling of ground water, surface soil sampling, soil boring sampling, ambient air monitor ing). Locate on map. 12) Outline environmental organization at site. 13) Review and comment on the recordkeeping and reporting systems implemented. 14) Determine whether any of the following has been conducted at the facility: SITE ASSESSMENT CHECKLIST a) Environmental assessments or audits; b) Regulatory inspections; c) Soil, air or water sampling; d) e) Underground storage tank inspections; Environmental impact, statement; or f) Reports to planning, zoning or community boards. 15) Ask for a copy of any reports. List reports available and describe the report results. 16) 17) 18) 19) Is the facility in compliance with all permits and applicable federal, state and local regula tions, ordinances, etc. List any areas of noncompliance associated with the facility within the last two (2) years. Highlight the major environmental concerns at the facility. Include any areas of regulatory uncertainty and any areas of environmental risks. Provide a summary list of all parameters addressed in the assessment and the status of each parameter. Reference recommendation number on status report. Provide a list of all persons contacted during the assessment including agency contacts and off-site contacts. (f) Raw Materials 1) List substances (for example, solvents, acids, caustics, lubricants, oils, fuel oil, gasoline, pesti cides, boiler treatment chemicals, cleaners, inks, adhesives, glues, batteries, process chemicals, paint, maintenance chemicals and cleaners etc.) used and stored at the facility. Include for each: a) Material, chemical name b) Hazard c) Quantity (maximum and average) d) How stored: 1) Above ground storage tank 2) Underground storage tank 3) Containers, drums 4) Sumps or pits 5) Locate on map. e) MSDS available (g) Raw Material Container Storage Areas 1) List all raw material container storage areas. Include for each: a) Material stored a) Container description (drum, tote, etc.) Include volume of containers. b) Properly labeled SITE ASSESSMENT CHECKLIST (h) Aboveground Storage Tanks 1) List all aboveground storage tanks. Include for each: a) b) c) d) e) f) g) Material/waste stored (indicate if material is a raw material or waste) Tank identification Volume Construction material Properly labeled Age of tank Containment, capacity, age, condition, clean out procedures h) Location (indoors or outdoors). Locate on map. i) Compliance status j) Risk management issues 2) Describe any signs of environmental contamination at aboveground storage tank areas. Locate on map. 3) Specify aboveground storage tanks requiring containment or improved containment. Recom mend containment requirements. Locate on map. 4) Describe any aboveground tanks that have been removed. For each, include: a) Tank identification, location. Locate on map. b) Dates in operation and date removed c) Materials stored d) Why were tanks removed 5) Describe any spill or releases, include: a) Tank identification, location. Locate on map. b) Date c) Material release d) e) f) Amount Notifications required Notifications made g) Remediation action h) Disposal sites used 6) Specify any recommended sampling or remediation for existing or removed tanks. Locate on map. SITE ASSESSMENT CHECKLIST a) Average and maximum number of containers stored b) Number stored on-site during site visit c) Containment, age of storage area, age of containment, condition, capacity d) Location (indoors, outdoors). Locate on map. e) f) Compliance status Risk management issues 2) Describe previous container storage areas. Locate on m ap. 3) Describe any signs of environmental contamination at existing or previous storage areas. Locate on map. 4) Specify container storage areas requiring containment or improved containment. Recommend storage areas and containment requirements. Locate on map. 5) Describe any spills or releases: a) b) c) d) e) f) g) Location. Locate on map. Material released Amount Notification required Notification made Remediation activity Disposal site 6) Describe loading, unloading areas. Are areas paved? Is there evidence of spills in the area? Locate areas on map. 7) Specify any recommended sampling or remediation for existing or previous storage areas and for loading, unloading areas. Locate on map. 8) Does the facility have a SPCC plan? Does the SPCC Plan meet regulation requirements? Is a new or improved SPCC Plan and/or Emergency Response Plan recommended. 9) List the materials used, stored or produced on-site which require notification under SARA Title III. 10) Describe compliance status of: a) OSHA Hazard Communication Program b) c) d) e) f) SARA Title III Reporting HMIS Labeling System Emergency Response Program Hazardous Material. Inventory NIOSH Reports SITE ASSESSMENT CHECKLIST (i) Waste Storage Areas 1) List all waste storage areas, include for each. a) Waste material a) Container description ( drum, tote, dumpster, sumps, pits etc.) Include volume of containers b) Properly labeled c) Average and maximum number of containers d) e) f) g) Number stored on-site during site visit Containment, age of storage area, age of containment, condition, capacity Location (indoors, outdoors). Locate on map. Compliance status h) Risk management issues 2) Locate previous container storage areas, locate on map. 3) Describe any signs of environmental contamination at existing or previous storage areas. Recommend containment requirements. Locate on map. 4) Specify storage areas requiring containment or improved containment. Locate on map. 5) Describe any spill or releases: a) Location. Locate on map. b) Material released c) d) Amount Notification required e) Notification made f) Remediation activity g) Disposal site 6) Describe existing and past collection, storage and disposal methods for empty drums; include "empty" procedures, labeling requirements and disposal contractors. Locate on-site collection, storage, treatment or disposal areas. Locate on map. 7) Specify any recommended sampling or remediation. Locate on map. (j) Solid/Hazardous Waste 1) List all wastes (solid wastes, special waste, hazardous wastes, general trash, empty drums, scrap by-products, spent solvents, sludges, used oils, fill materials, removed soils, scrap metal, coal ash, etc.) generated, include for each: a) Waste material b) How generated (process) SITE ASSESSMENT CHECKLIST c) How collected (for example, open top containers, dumpsters, drums, totes, pits, sumps, etc.) Locate on map. d) Volume generated per month e) Suspect hazardous waste f) Waste characterization on file g) Waste characterization recommended h) Disposal method (for example, landfill, incineration, off-site recycling, on-site reclamation, on-site burning, off-site treatment, on-site treatment, industrial sewer, sanitary sewer, storm water sewer, etc.) i) Transporters and off-site facilities. List name, location, owner/operator of facility, identification numbers, for all include previous and current sites with dates j) Manifests used k) Manifests on file 1) Compliance status m) Risk management issues 2) Describe all past and current on-site treatment and on-site disposal methods. Locate on map. 3) Have any wastes been disposed on-site or off-site in an approved or unapproved lagoon or impoundment or disposal area? Describe wastes, volumes, dates and sites. If on-site, locate on map. 4) Has any material ever been disposed or stored on or beneath the surface of the property? Describe. Locate on map. 5) Describe past and current sludge disposal practices (for example, waste water treatment plant sludges, petroleum still bottoms, tank bottoms, pit or sump solids, solvent still bottoms, etc.). If on-site, locate on map. 6) Describe past and current used oil reclamation, recycling or disposal practices. If on-site, locate on map. Has the facility been involved with or is the facility involved with any off-site waste treatment or disposal facility that is currently being cleaned up, or being considered for clean-up, under provisions of the superfund program or state program. List facilities. 8) List any federal or state superfund sites for which the facility has been identified as a potentially responsible party or could be identified. 9) List past (at a minimum 15 years) and present transporters and off-site facilities used for all wastes, include for each: a) Waste description b) Volume of waste sent c) Dates used d) Facility name 7) SITE ASSESSMENT CHECKLIST g) Sewer h) Incinerators, furnaces i) Landfills j) Land treatment k) Drum burial 1) If on-site, locate on map. m) Describe compliance status and risk management issues 16) Does the facility use hazardous waste as a fuel or raw material? 17) Has the facility ever disposed of hazardous waste on-site? Locate on map. 18) Ask whether the facility has disposed of hazardous waste off-site. 19) Describe any past or current disposal practices that could be a liability. 20) Is facility in compliance with all applicable regulations? 21) Specify any recommendation to ensure compliance and risk management. (k) Air Emissions 1) List each permitted source, include for each: a) c) d) e) f) Source name/description. Locate on map. Issuing agency Expiration date Maj or pollutants Emission rate and capacity limitations b) Permit number/designation g) Control devices h) Monitoring required i) Records (maintenance, testing, calibration) j) Compliance status 2) Describe any additional air emission sources including: a) c) d) e) f) g) Process stacks, boiler stocks Fans Open processes, evaporative processes Process equipment (driers, mixers, spray booths) Fugitive emission sources Bulk loading, unloading areas b) Vents, exhaust ports SITE ASSESSMENT CHECKLIST e) Location, address f) Owner/operator g) Facility identification number h) Compliance status j) Risk management issues 10) Describe any inactive land disposal sites owned or operated by the facility. If on-site, locate on map. 11) Describe facility waste minimization program. 12) Hazardous wastes a) Waste b) Volume generated/month c) Is hazardous waste mixed with solid waste or waste oil? d) If volume is greater than 100 kg 1) RCRA plans (contingency) 2) Manifests (3 years) 3) Notification of hazardous waste activity 4) Storage less than 90 days 5) Volume of hazardous waste now on-site e) Are hazardous wastes recycled or recovered on-site. Locate on map. 13) Describe on-site hazardous waste management practices. a) Accumulation (less than 90 day storage, with or without a permit) b) Storage facilities (containers, tanks). Locate on map. c) On-site treatment, disposal, reclamation or recycling facilities. Locate on map. d) Compliance status e) Risk management issues 14) Describe Resource Conservation and Recovery Act (RCRA) permit status of any treatment, storage or disposal (TSD) facilities. Part A or Part B filed. 15) Does the facility store or dispose of any waste material (hazardous or nonhazardous) in a) Surface impoundments b) Sludge lagoons c) Waste piles d) Deep wells e) Dry wells f) Septic systems SITE ASSESSMENT CHECKLIST h) Locate on map. 3) 4) 5) 6) 7) Are any of the sources identified above without required registrations or permits or have permits expired? Describe testing procedures for control devices. Are odors, fumes or dust observed from the facility? Is an emission inventory system report required for the facility? Has an emissions inventory been performed at the site? If so, please attach a copy. 8) Describe any problems or community complaints associated with odors, noise, visible emissions or dust produced by the facility. 9) Describe any visible gas, particulates or dust emissions in the air. 10) Specify any recommendations to ensure compliance and risk management. (l) Water Supply/Waste Water 1) Describe sources of water (i.e. well, municipal, etc.) and volume of water used. 2) Describe all water uses and approximate volume. Include detailed infor mation for process using water. 3) List all waste water permits for the facility, include for each: a) Name b) Discharge sources c) Type of permit and number d) Discharge point (sewer, surface water, etc). Locate on map. e) f) g) Issuing agency Expiration date Limitations h) Monitoring and reporting requirements (parameters and frequency) i) Compliance status 4) Obtain and evaluate copies of any discharge monthly reports submitted within the past two years. Describe any violation of any permit limitations. 5) List all waste water streams (for example industrial process discharges, boiler blow down, cooling water, lab sink wastes, steam condensate). For each include any available sampling results, potential contaminants, discharge point and whether discharge point is properly per mitted. List permits. 6) Describe treatment or pretreatment processes utilized. (Include National Pollutant Discharge Elimination System (NPDES) permits, discharges to Publicly Owned Treatment Works (POTWs), name of receiving stream, treatment plant authority, POTW treatment processes, POTW compliance status, disposal of sludge, etc). Locate on map. 7) List storm water discharges (approximate volume, area being drained, sampling results and number of discharge points) and permits. Locate on map. SITE ASSESSMENT CHECKLIST 8) Are there any wastes or drainage discharged to the storm water sewer that should be investiga- ted? Locate on map. 9) Is there any evidence of contamination at any discharge points? Locate on map. 10) List sanitary discharges (volume, sampling results and treatment). Are there any septic tanks on-site? If so, how many? Locate on map. 11) Are there any wastes or drainage discharged to the sanitary sewer that should be investigated? Locate on map. 12) Describe any floor drains, catch basins, pits or sumps inside or outside the facility that could discharge spill, leaks or process water from storage or process areas. a) Size, depth of lagoon b) Design of lagoon c) Sludge disposal method d) Any evidence of adverse environmental impact e) Describe any monitoring conducted and results 13) Is waste water stored in a pond, pit or lagoon? f) Locate on map 14) How is runoff from roofs discharged? 15) Is the facility located on a waterway? If so, describe the types of business or manufacturing operation located upstream and downstream. Describe any potential concerns. (m) Underground Storage Tanks 1) List underground storage tanks presently in service or out of service and not removed, include for each: a) Tank identification b) Tank age c) d) e) Size (volume) Construction materials Materials stored f) Overfill protection g) Location. Locate on map. h) Compliance status i) Risk management issues 2) Have proper notifications been submitted? 3) For each tank, describe tank and line tightness test dates and results (include any suspected leaks). 4) Is there evidence of spills near loading pipe? Locate on map. SITE ASSESSMENT CHECKLIST 5) Is there dead vegetation in the area? Locate on map. 6) 7) 8) 9) 10) 11) Specify any testing, sampling or remediation recommended. Locate on map. List underground tanks that have been removed (include tank age, size and construction, materials stored; overfill protection and why tanks were removed). Locate on map. Was proper notification submitted and were sound engineering practices used during removal? Is there any reason to suspect the tanks had leaked or that there were spills in the loading pipe area? Describe. Locate on map. Describe results on any sampling conducted during removal (include soil and ground water). Describe any remediation conducted. Locate on map. 12) Describe any ground water monitoring program and results. 13) Specify any recommended sampling and remediation. Locate on map. (n) Asbestos 1) Are there asbestos-containing materials on-site, either presently in use or as part of scrap or demolition materials which have not been disposed? 2) Describe any insulated pipes, tanks or equipment suspected of containing asbestos. 3) Describe any other suspected asbestos containing materials located on the property (e.g. sprayed-on ceiling coatings, transite wall panels, cement asbestos soffit or fas cia materials, asbestos roofing felts or roof flashings, vinyl asbestos floor tile, coated beams, plaster -like coating on boilers). Has an asbestos survey been conducted at the facility? Does the survey appear to be adequate? Has an asbestos management program been implemented? Were samples collected of suspected asbestos containing materials? Describe any areas containing suspected asbestos containing materials that are in need of sampling, removal or encapsulation (include all areas with friable conditions). Locate on map. (o) PCB Information 1) 2) Describe any PCB electrical equipment located on the premises (transformers, capacitors, fluorescent light ballast). List any PCB contaminated (50-500 ppm) or PCB equipment (above 500 ppm) at the facility (equipment number, type, capacity, volume of liquids, in-service, in-storage, PCB concentrations and where located in facility). Include all PCB containing transformers or capacitors presently in-use or awaiting disposal. Locate on map. Who owns the transformers and capacitors? Is any electrical equipment labeled as containing PCBs? Is any electrical equipment labeled as not containing PCBs? Did the PCB equipment ever leak? Is there any evidence of spills around and beneath transformers? Locate on map. Is any of the PCB equipment inside a building? (Identify the building and its use.) 4) 5) 6) 7) 3) 4) 5) 6) 7) 8) SITE ASSESSMENT CHECKLIST 9) Is the PCB equipment marked, well maintained and secure? 10) Have there been any spills or fires involving PCB equipment? Locate on map. 11) Does the facility own, store or has the facility disposed of PCBs? 12) 13) Is the facility in compliance with all reporting and record keeping requirements (notifications, annual documents, inspection records, disposal records, etc.)? For any power transformers or capacitors removed from the property: a) List equipment removed. b) Who owned the transformers or capacitors that have been removed? c) Why were they removed? d) Describe removal and disposal records, include disposal sites. e) Do you suspect any contained PCBs? f) Locate on map. (p) Radon 1) 2) 3) Ask whether there is any concern in the local area with elevated levels of radon. Has the facility performed any test for radon on site or in the building? Is the facility located on or near sites which were used for phosphate extraction or uranium, thorium or radium processing? What were the results? (q) Other Issues 1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) 12) Describe pesticide use, handling or storage at the facility. Include contractor activities. Describe pesticide manufacturing on-site. Include type and approximate volume produced. List any processes that use specially denatured alcohol or rum which require an Alcohol, Tobacco and Firearms permit. List approximate amount of each material used per year. Describe any processes or products that are subject to the requirements of the FDA. Describe any special or unique activities involving toxic or hazardous materials or substances at the site (i.e. radioactive wastes, pathogenic wastes, animal wastes, etc.). Describe the procedure for determining if materials used, stored, produced or imported by the facility are on the Toxic Substance Control Act Inventory. List the products for which Premanufacturing Notifications have been submitted to EPA within the past five years. Describe Local Fire and Health Department records regarding operations or possible com plaints which may have been filed relating to the site operation. Has the State Fire Marshal made annual inspections of the facility? Report results. Are insurance reports available from Factory Mutual or other insurance carriers who have coverage for the buildings? Report results. Do any buildings have urea formaldehyde foam insulation? Locate on map. Do any of the buildings have peeling lead paint? Locate on map.
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