Acbm operations and Maintenance Program




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NOTICE

This “GENERIC” Operations and Maintenance Program (O&M Program) is provided as a guide to use in developing an O&M Program for a specific building. It is essential that this “GENERIC” O&M Program be custom fitted to the building in which it will reside. Reviewing this document, and the accompanying “Work Practices” document, you will observe that sections requiring specific building information and practices are omitted. As often as practical, sample information is included for use as a reference in customizing this O&M Program to a specific building. In order to adapt this O&M Program to a specific building, a complete asbestos building inventory must be conducted which will provide specific information that will aid in tailoring this program to a specific building. Information on key building personnel and occupants must be added to this O&M Program and a review of the section on “Work Practices” must be completed along with additional customization. This O&M Program will assist users in creating an Operations and Maintenance Program specific to their building, but this document should not be implemented in its current state.
Please be on notice that this O&M Program is generic in scope and requires inclusion of additional, essential information prior to implementation.
DRAFT

ACBM Operations and Maintenance Program


GENERIC

August 1, 2005



Control Copy #__
EMERGENCY CONTACT LIST


  1. Asbestos Coordinator:



  1. Asbestos NESHAPs Contact, Air Management Division:

USEPA, Region 1,

One Congress Street, Suite 1100

Boston, MA 02114

(617) 918-1852




  1. Massachusetts Departments of Labor and Workforce Development:

Division of Occupational Safety

1001 Watertown Street

West Newton, MA 02465

(617) 969-7177




  1. Massachusetts Department of Environmental Protection:

Air Quality Section Chief, Division of Air Quality Control

Met Boston/North Region

One Winter Street

Boston, MA 02108

(617) 654-6500, (617) 654-6595




6. Tenant Agency Coordinators:

Tenant 1:

Primary: TBD

Secondary: TBD
Tenant 2:

Primary: TBD

Secondary: TBD

Preface
This Operations and Maintenance Program (O&M) has been developed to address the management of asbestos containing building materials. The primary purpose of the O&M Program is to mitigate the exposure of building occupants, maintenance workers, and outside contractors to asbestos fibers. The procedures contained in this program have been developed to address common operations and maintenance activities as well as less frequent activities that are likely to disturb asbestos containing materials within the building.


This O&M Program must be tailored to each specific building in which it will be utilized. Without essential sections, such as “Appendix F”, including a complete asbestos inventory of the subject building, this O&M Program shall remain incomplete.
An O&M program is not required by Federal or State regulations for commercial office buildings. The establishment of this O&M plan, when complete and specifically tailored to a subject building, should exceed regulatory requirements and establish precautions, practices, and procedures for handling asbestos containing materials that are more stringent than regulations require.
In an effort to provide an O&M program that is maximally protective of building occupants, an additional conservative approach is established within this program. In order to minimize the potential for exposure to asbestos fibers in the building, the following policy shall be established: that all maintenance, operations, and non-routine work will be conducted under the assumption that asbestos containing materials are present. This shall include all operations and maintenance work, cleaning and housekeeping work, and all building system work, such as telecommunications and computer networks, electrical, HVAC, and plumbing.
This conservative approach to asbestos management recommends that all building occupants complete two hours of asbestos awareness training, which shall include training in this policy and the existence and content of this O&M Program. Operations and maintenance personnel and all outside building system contractors shall complete, at a minimum, an approved sixteen ­hour training program for Asbestos Associated Project Workers. In addition, operations and maintenance personnel and outside contractors shall receive training in the building’s specific procedures related to their tasks.
This program is designed to mitigate potential exposures to asbestos fibers from planned procedures and to minimize the opportunity for unplanned release of asbestos fibers. The program addresses operations and tasks from experience as well as anticipated procedures. However, every situation that may involve asbestos containing materials cannot be anticipated. If there is a question about the possibility of encountering asbestos containing materials during any task or operation in the building, assume that asbestos is present. The building management and/or asbestos coordinator can provide guidance and proper procedures for completing the task safely.


Table of Contents




  1. INTRODUCTION 1


2.0 SCOPE AND OBJECTIVES 3
3.0 CRITICAL ROLES 4
4.0 COMMUNICATION…..….. 6
4.1 Communication with Tenants 6
4.2 Outside Contractor Communication 7
4.3 Employee Communication 7
4.4 Notification to Agencies 7

4.4.1 Notification Requirements 8

4.4.1.1 Planned Operations Involving ACBM: 8

4.4.1.2 Emergencies Involving ACBM: 8

4.4.2 Steps to Take for Notifying Regulatory Agencies 9

4.4.3 Timetable for Regulatory Notifications for Planned Work Involving Abatement 9

4.4.4 Timetable for Regulatory Notifications for Emergencies Involving ACBM 9

4.5 Warning Signs and Labels ………………………………………………………………… 10
5.0 LOCATIONS OF ACBM 12
6.0 TRAINING 13
6.1 Asbestos Coordinator 13
6.2 Building Maintenance Staff (16 Hour Trained) 14
6.3 Other Building Workers and Building Occupants ………………………………………14
6.4 Outside Contractors 15

6.4.1 Large Scale Asbestos Related Work 15

6.4.2 Small Scale Asbestos Related Work 15

6.4.3 Other Outside Contractors……………………………………………………………... 16



Table of Contents




7.0 WORKER PROTECTION PROGRAM 17
7.1 Program Administrator …………………………………………………………………... 17
7.2 Recordkeeping……………………………………………………………………………...17
7.3 Medical Surveillance………………………………………………………………………. 18

7.3.1 Who Should Receive Medical Surveillance…………………………………………… 19

7.3.2 Frequency of the Medical Examination………………………………………………... 19

7.3.3 Information Building Management will Provide to Physician ……………………….. 19

7.3.4 Content of Examination ……………………………………………………………….. 19
7.4 Respiratory Protection Program………………………………………………………… 20

7.4.1 Criteria for Selection of Respirators 21

7.4.2 Selection of Respirators 22

7.4.3 Fit Testing 22

7.4.3.1 Fit Check Procedures 23

7.4.3.2 Fit Test Procedures 23

7.4.4 Employee Training 24

7.4.5 Medical Surveillance 24

7.4.6 Respirator Maintenance and Storage 24

7.4.7 Program Evaluation 25


7.5 Protective Clothing 25

7.6 Personal Air Monitoring 25
8.0 EMERGENCY RESPONSE 27
8.1 Minor Fiber Release Episodes 27

8.1.1 Procedures for Control: 27


8.2 Major Fiber Release Episode 28

8.2.1 Procedures for Control: 29


9.0 PROCEDURES FOR PLANNED ACTIVITIES 31
9.1 Work Practices for Routine Maintenance and Custodial Operations in Which Disturbance to ACM is Unlikely 31


Table of Contents



9.2 Work Practices for Routine Maintenance and Custodial Operations in Which Disturbance to ACM is Likely…………………………………………………………… 32
9.3 Quality Assurance 34
9.4 Routine Cleaning 34
9.5 Ceiling Tiles 36

9.5.1 Notice Of Restricted Activities 36

9.5.2 Reporting Damaged or Missing Ceiling Tiles 36

9.5.3 Addressing Fallen Ceiling Tiles 37

9.5.4 Periodic Inspection 37

9.6 Occupation of Areas with Exposed Spray-on Asbestos 37
10.0 EQUIPMENT AND MATERIALS 38
10.1 Equipment ... 38
10.2 Materials 38
11.0 ACM DISPOSAL PROCEDURES 40
11.1 General Disposal Procedures 40

Point of Generation …..…..…………………………….……………………………………...40

11.1.2 Transportation…………………...……………………………………………………...41

11.1.3 Final Destination of Waste 41



11.2 Disposal Using On-site Abatement Contractor 41
11.3 Disposal Procedures Using an Outside Contractor 42
12.0 PERIODIC SURVEILLANCE. 43
12.1 Physical Inspection 43
12.2 Area Air Monitoring .. 43
13.0 PERIODIC EVALUATION OF THE O&M PROGRAM 44
13.1 Evaluation Schedule .. 44


Table of Contents




13.2 Steps to Evaluate the Program 44
14.0 RECORD KEEPING 46
14.1 General Provisions ……………………………………………………………………….. 46
14.2 Building Management’s Employee Files ……………….……………………………….. 47
14.2.1 Employee Communications 47

14.2.2 Medical Surveillance Files . ... 47

14.2.3 Respiratory Protection Program File 48 14.2.4 Personal Air Monitoring File 48 14.2.5 Employee Training Program File 48 14.2.6 Individual Employee Files 49
14.3 Operations and Maintenance Activities Files 50

14.3.1 The Operations and Maintenance Plan File... 50

14.3.2 The Communication and Notification File 50

14.3.3 Periodic Surveillance File 51

14.3.4 Equipment and Materials File 52

14.3.5 Maintenance Activities File 52

14.3.6 Fiber Release Episode File…………………………………………………………… 53

14.3.7 Disposal Files ………………………………………………………………………….. 53

14.3.8 Outside Contractors Files………………………………………………………………. 54

14.3.9 Major Asbestos Abatement Activities Files……………………………………………. 54



15.0 BACKGROUND INFORMATION ON ASBESTOS 56
15.1 Occurrence, History and Use 56
15.2 Health Effects Associated With Exposure to Asbestos 57

15.2.1 Introduction 57

15.2.2 Routes of Entry 58

15.2.3 Asbestos Related Diseases 58


16.0 GLOSSARY OF TERMS 60

APPENDIX A

LETTERS



Tenant Agency Notification Letter………………………………………………………….. A-1


Outside Contractor Notification Letter………………………………………………….…. A-2



Building Management’s Employee and Contractor Employee Notification Letter……… A-3


Employer Asbestos Clearance Letter ………………………………………………………. A-4

Employee Asbestos Notification Letter …………………………………………………….. A-5


Minor Fiber Release Cover Letter…………………………………………………………... A-6



Major Fiber Release Cover Letter………………………………………………………….. A-7



Maintenance of Ceiling Tiles Notice to Occupants………………………………………… A-8



Use of Space ………………………………………………………………………………….. A-9

APPENDIX B

REGULATORY POLICY DOCUMENTS




DLI Policy #8905……………………………………………………………………………... B-1


DEP Policy # BWP-96-012…………………………………………………………………… B-2



APPENDIX C


FORMS

DEP Notification Form………………………………………………………………………. C-1



Job Request Form……………………………………………………………………………. C-2


Asbestos Repair/Removal (Under 3 Linear Feet)………………………………………….. C-3




SAMPLE Contractor Work Permit…………………………………..………………..…… C-4

(Using agency to substitute their form)

Monthly Inspection Report……………….………………………………………………… C-5

(Using agency to substitute their form)

ACM Storage Room Access Log……………………………………………………………. C-6
Building ACM Log…………………………………………………………………………… C-7

Labels for ACM Bags…………………………………..……………………………………. C-8


Log of Bag Numbers Containing ACM ………………………………….………………… C-9

APPENDIX C


FORMS (continued)
Request for Medical Evaluation Sample…………………………………………………….C-10


Respirator Form Sample…………………………………………………………………….. C-11


Disposal Form-Manifest Sample……………………………………………………………. C-12



Chain of Custody Form……………………………………………………………………… C-13
Daily Inspection Report……………………………………………………………………… C-14

APPENDIX D




Medical Questionnaires contained in Appendix D of 29 CFR 1910.1001………………... D-1

APPENDIX E

STANDARD WORK PRACTICES

Standard Work Practices…………..……………………………………………………….. E-1

General Procedures……………………………………….…….. Section 1
Surface Materials Work Practices……………………….…….. Section 2

Thermal System Insulation Work Practices……………..……. Section 3

Miscellaneous Materials Work Practices………………...……. Section 4
APPENDIX F

BUILDING ACM INVENTORY

BULK SAMPLING
(This section must be generated specifically for each building)
Bulk Sample Analysis Results………………...……………..…………………………….. F-1

Asbestos Containing Material Location Drawings………………………………….……. F-2



Sample Location Drawings……..………………….……………………………………….. F-3



1.0 INTRODUCTION
This O&M Program addresses the management of asbestos containing building materials (ACBM). Many of the recommendations and procedures contained herein are based upon existing regulatory guidelines, including United States Environmental Protection Agency's (USEPA) document "Managing Asbestos in Place - A Building Owner's Guide to Operations and Maintenance Programs for Asbestos-Containing Materials". When asbestos-containing materials are present in a building, proper management of the materials is necessary to prevent the occurrence of hazardous conditions to building occupants.
The elements of this O&M Program are designed to provide an understandable description of the practices required to properly manage ACBM in the building. Sections included the following:
Section 1: Introduction.
Section 2: Purpose.
Section 3: Critical Roles: The roles of persons and agencies involved in the implementation

and managing of this asbestos O&M Program are defined.


Section 4: Communication: The steps to properly notify building occupants, contractors,

and employees of the presence of asbestos in the building; the existence of the

O&M Program, and abatement activities are described. The Communication

section also addresses warning labels and caution signs where appropriate.


Section 5: Locations of ACM in Building: The general locations of asbestos-containing materials are described.
Section 6: Training: Requirements for training of the Asbestos Coordinator, maintenance workers, custodial workers, and outside contractors are described.
Section 7: Worker Protection Requirements: Requirements for protective clothing, respiratory protection, medical surveillance, and personal air monitoring for personnel involved in any form of asbestos related work are described.
Section 8: Emergency Response: Procedures to be followed in the event of an emergency involving the disturbance or release of asbestos are described.


Section 9: Procedures for Planned Activities: Procedures are outlined for conducting maintenance and other work that may disturb ACM.
Section 10: Notification: The steps necessary to properly notify regulatory agencies, building occupants, workers, and sub-contractor are described.
Section 11: Equipment and Materials: A list of the materials and equipment that should be available for use by trained maintenance staff for ACM related activities.
Section 12: Disposal Procedures: Requirements for proper containerization, storage and disposal of ACM are described.
Section 13: Periodic Surveillance: Mechanisms and requirements for annual visual surveillance and air sampling to document and assess conditions are described.
Section 14: Program Evaluation: O&M Program evaluation mechanisms are described to ensure that the program is periodically reviewed and revised to maintain program conformance with changing regulations, state-of-the-art procedures, and buildings conditions.
Section 15: Record Keeping Requirements: Requirements for maintenance of records for each element of the O&M Program are described.
Section 16: Background on Asbestos and Related Health Effects.
Section 17: Glossary of Terms.
Appendix A: Sample Letters
Appendix B: Regulatory Policies
Appendix C: Sample Forms
Appendix D: Medical Questionnaire, 29 CFR 1910.1001
Appendix E: Standard Operating Procedures
Appendix F: Building Inventory (This section must be generated specifically for each building.)



2.0 SCOPE AND OBJECTIVES
The principle objective of this Operations and Maintenance (O&M) Program is to manage asbestos-­containing building materials (ACBM) in order to mitigate the exposure of building occupants to airborne asbestos fibers. The O&M Program will minimize the release of asbestos fibers by:


  • Maintaining asbestos-containing building materials (ACBM) in good condition;

  • Defining specific work procedures for planned building activities to control the disturbance of ACBM;

  • Responding to emergencies involving the disturbance of asbestos; and

  • Monitoring the condition of the ACBM.

The O&M Program will remain in effect until such time as all asbestos containing materials are removed from the building. This O&M Program is intended to be "State of the Art" and therefore may be more stringent than current applicable federal, state, and local regulations. However, if adherence to the O&M Program fails to meet future regulatory requirements, the applicable regulations will be followed and the O&M Program will be updated and revised.



3.0 CRITICAL ROLES
The purpose of this section is to define the roles of persons and agencies involved in the implementation and management of the Asbestos O&M Program for the building.

Asbestos Coordinator. The Asbestos Coordinator is the central coordinator for the O&M Program. He/she is the primary person to assess a situation concerning asbestos and determine whether outside assistance is needed. The Asbestos Coordinator will have many resources to use, including certified asbestos professionals, asbestos contractors, and regulatory agencies. Whether the work is done in-house or by outside companies, the Asbestos Coordinator will oversee the entire O&M Program. All work done in the building requires a Job Request Form (See Sample Form C-2). The Asbestos Coordinator will authorize all work, including: reviewing all Job Request Forms; inspecting work areas before work begins for potential asbestos presence and disturbance; reviewing completed work for signs of disturbance of asbestos.

Division of Capital Asset Management. The Division of Capital Asset Management (DCAM) is the agency that will be involved in major asbestos abatement projects (i.e. greater than $100,000).1

Asbestos O&M Response Team. The O&M response team conducts limited work with ACM and provides initial response to emergency releases of ACM within the building. The O&M Response Team is comprised of designated maintenance staff who have completed the required 16-hours of training in accordance with applicable regulations, and have demonstrated proficiency in required skills.

Certified Asbestos Manager (Asbestos Consultant). The Certified Asbestos Manager is the professional who advises the Asbestos Coordinator with respect to various elements of the Program. The Certified Asbestos Manager may also conduct Work Practice Quality Assurance, Air Monitoring, Training of O&M Workers or assisting the Asbestos Coordinator in assessing asbestos related issues.

Tenant Agency Coordinator. Each Tenant Agency, within the building, will designate a representative (Tenant Agency Coordinator) who is responsible for disseminating information and schedules, regarding routine operation and maintenance activities, to appropriate building occupants. The designation of the primary and secondary Tenant Agency Coordinators will occur on the return of the Tenant Agency Notification Letter (Appendix A, Letter A-1). The names and contact information for the Tenant Agency Coordinator’s will be added to the
Emergency Contact List, found at the beginning of this Program. Each Tenant Agency’s Coordinator is responsible for notifying the Asbestos Coordinator of all work requested to be performed within each Tenant’s space. Notification to the Asbestos Coordinator shall be performed with the submission of a complete Job Request Form (Appendix C, Form C-2) and submission of any additional documentation requested by the Asbestos Coordinator. The Tenant Agency Coordinator will work with the Asbestos Coordinator to arrange to have all work performed so as to cause minimal interruption of normal building operations.
4.0 COMMUNICATION
The Communication section describes the steps to properly notify building occupants, contractors, and employees of the presence of asbestos in the building, the existence of the O&M Program and abatement activities. The Communication section also addresses warning labels and caution signs where appropriate.
Good communication between the building management, all tenants, contractors, and employees ensures:


  • That all regulatory requirements are met;

  • That all work will be performed in accordance with the O&M Program;

  • That persons lacking appropriate training are prevented from disturbing asbestos; and

  • That misunderstandings will be prevented.

Sample notification letters and forms for various situations are provided in Appendix A.


4.1 Communication with Tenants
Communication between the building management and the tenant agencies should be documented to file. Upon implementation of this O&M plan, the Asbestos Coordinator will inform tenant agencies that the O&M Program is available for their review (Appendix A, Letter A-1, Tenant Agency Notification Letter). Particular attention will be paid to:


  • The locations of ACM within the tenant's space (when documented);

  • The communication/notification system as described in this section; and

  • Prohibited practices.

The building occupants are specifically prohibited from certain activities that have the potential to disturb ACBM. In particular, the following activities are prohibited:




  • Performing work above dropped ceilings on unabated floors;

  • Entering or penetrating utility shafts;

  • Entering or penetrating interior and perimeter column enclosures;

  • Disturbing floor tiles or floor tile mastics;

  • Disturbing any building materials suspected of containing Asbestos.

The Asbestos Coordinator will respond to building occupants questions concerning their role in the O&M Program. In accordance with Letter A-1, each Tenant Agency will provide the name of a primary and secondary Tenant Agency Coordinator, facilitating implementation of the O&M Program.


When an O&M operation will be performed in a tenant's space, the Asbestos Coordinator will notify the Tenant Agency Coordinator, and will arrange to perform the work so as to cause
minimal interruption of normal building operations.
4.2 Outside Contractor Communication
All contractors (non-abatement) working in the building should be notified of the presence and locations of ACBM. They will also be notified that any work which will disturb ACBM, including work above dropped ceilings on unabated floors, must be performed in accordance with the specific requirements of the O&M Program (Appendix A, Letter A-2, Contractor Notification Letter).
Before a Contractor may begin work, receipt of the letter of notification should be signed by a responsible person of the contractor firm. The Contractor should certify that all employees have received the proper training for the work which they will perform, as outlined in Section 6, Training.
If the Contractor encounters any suspect ACBM, or if any planned work would disturb ACBM (such as work above dropped ceilings on unabated floors or work in shafts), the Contractor must contact the Asbestos Coordinator prior to the start of the work. The Asbestos will arrange for the work to be performed by a licensed abatement contractor.
4.3 Employee Communication
The Asbestos Coordinator will initially notify all building management employees of the presence of asbestos in the building through a written notification letter (Appendix A, Letter A-3 Employee Notification Letter).
The tenant agency is responsible for any communications with their employees regarding asbestos, as may be required by law.
4.4 Notification to Agencies
When asbestos-containing materials are disturbed, intentionally or unintentionally, one or more government agencies must be notified, depending on the amount of material. During asbestos abatement in the building, any planned abatement as part of the O&M Program will be performed by a licensed abatement contractor who will also make the notifications. A licensed abatement contractor will also make the necessary notifications for any minor or major disturbances to which they respond at the building. It is important for the Asbestos Coordinator and others to know, however, under what conditions notifications are required, and the amount of time required for notifications, so that appropriate planning can occur. In addition, there may be occasions, during some emergencies, when the Asbestos Coordinator will make notifications directly.
When the proper procedures for making notification are understood and followed, regulatory compliance for notifications will be ensured. When responding to an emergency, addressing and
resolving the relevant issues should be the primary concern, with appropriate notification being the second concern.


      1. Notification Requirements

Projects which are performed near ACBM, but which will not actually disturb ACBM, do not require notifications to any agencies. Disturbance of ACBM is caused when any process, which through direct contact, vibration, air movement, or other means, physically moves ACBM in such a way that fibers could become airborne. If there is any doubt as to whether ACBM could be disturbed during an operation, the Asbestos Consultant should be consulted.


4.4.1.1 Planned Operations Involving ACBM:
Two government agencies must be notified of planned asbestos operations. The Massachusetts Department of Environmental Protection (DEP) must be notified of all planned projects involving ACBM. The Massachusetts Department of Labor and Workforce Development (DLWD) must be notified of all projects involving more than 3 square feet or 3 linear feet of ACBM. The U.S. Environmental Protection Agency (USEPA) must be notified of all operations involving more than 160 square feet or 260 linear feet of ACBM. DEP has been designated by USEPA as their representative and as such, notification to DEP fulfills the requirement of notification to USEPA. The notification forms presented in Appendix C serve as common notification to both DEP and DLWD.
The DEP and DLWD must be notified 10 working days prior to any projects for which notification is required.
4.4.1.2 Emergencies Involving ACBM:
An emergency is any situation which may damage or harm property or human health. Agencies generally do not grant emergency waivers for the purposes of convenience or ease of scheduling. For emergencies involving any amount of ACM, an emergency waiver number may be obtained from the DEP, and the DEP must then be notified in writing within 24 hours after the project begins.
For emergencies involving greater than 3 square feet or 3 linear feet of ACBM, the DLWD should be notified within one day of the beginning of work.
DLI has issued a separate policy statement for work above ceiling tiles under spray-applied asbestos surfaces, Policy #8905 (see Appendix B). This allows certain exemptions from the asbestos regulations, including exemption from notifications, provided work practices outlined in the policy are met. The DEP has verbally confirmed that it also does not require notifications if the work involves only moving a ceiling tile, but if any other ACBM is disturbed, a notification must be made. When there is any question as to whether a notification is required, the Asbestos Consultant can assist in making the determination.

The DLWD and DEP have policy statements concerning certain non-friable materials, such as floor tile, which allow certain exemptions from the asbestos regulations, including exemptions from notifications, provided the material remains non-friable. It should be assumed that notifications should be made for projects involving floor tile, unless the Asbestos Consultant determines otherwise.


4.4.2 Steps to Take for Notifying Regulatory Agencies
For planned operations involving ACBM, notifications will be made by the designated abatement contractor.
When an emergency situation arises then the designated abatement contractor will handle the situation, and will prepare all necessary notifications, to then be signed by the building management. If the abatement contractor is not present in the building at the time of the emergency, then the Asbestos Coordinator should, after ensuring initiation of emergency response actions by the O&M Response Team, notify the appropriate agencies. The following tables summarize the agencies to contact. Generally, the designated abatement contractor will then prepare follow-up written notifications to be signed by the building managemnt. All written notifications made will use the specified forms (Asbestos Notification Form [Form C-1]).
4.4.3 Timetable for Regulatory Notifications for Planned Work Involving Abatement


Type of Work

Amount of ACM

Agency

Notice Required

Abatement

Any Amount

DEP

10 Working Days
















Abatement, Except VAT

>

3 linear feet or 3 square feet

DLWD

10 Working Days










DEP

10 Working Days















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