0231621a-3146-46cf-bc0b-b38500889c6f.pdf

P.O. Box 13216

Lansing, MI 48901

Phone: 888.449.4566

Fax: 888.448.8739 www.redcedarconsulting.net

October 16, 2025

Mr. Brian Taylor

City of Jackson

Community Development Department

Jackson, MI 49202

RE: Asbestos Containing Material and Hazardous Materials Inspection

410 S Webster St. Jackson, MI 49203

Parcel ID: 3-077100000

Dear Mr. Taylor:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at 410 S Webster St. Jackson, Michigan (Subject Property). This inspection was completed at the request of the City of Jackson to comply with the United States Environmental Protection Agency

(USEPA) requirements for demolition and renovation set forth under the National Emissions Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 61). This inspection was also completed to comply with the Occupational Safety and Health Administration (OSHA) Asbestos Standards for Construction

(29 CFR 1926.1101) which limits employee exposure to asbestos.

SUBJECT PROPERTY

The Subject Property is comprised of a .10-acre residential parcel which contains an approximate 869 square foot residential building (the Building) constructed in 1920. The Building was constructed on a concrete basement with two aboveground floors. The exterior walls of the Building were finished with vinyl and wood lap while the roof was sealed with asphalt shingles. The Building can be further divided into a front porch, living room, dining room, kitchen, bath, and front porch on the first floor while the second floor contains two bedrooms.

VISUAL INSPECTION AND SAMPLING

Asbestos Containing Materials Inspection

Jeff Cain of Red Cedar Consulting (Red Cedar), accredited State Of Michigan/EPA Asbestos Building

Inspector (Accreditation Number A14057) who completed training per the Michigan Asbestos Workers

Accreditation Act 440, completed an inspection of the Subject Property on September 15, 2025, for suspected asbestos containing building materials.

Project No.: 12-1027

This inspection, and subsequent sample collection was completed in accordance with the USEPA

Asbestos Hazard Emergency Response Act (AHERA) (40 CFR Part 763) assessment and sampling protocol.

During the completion of the inspection, each area of the Subject Property was visually inspected for asbestos containing building materials (ACBM). Following the completion of the visual inspection, Red

Cedar staff identified each suspect area of friable and non-friable ACBM and sorted them into one of three homogenous categories for sampling purposes. AHERA defines friable as a material that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. A homogenous area is defined by

OSHA as an area of surfacing, thermal system insulation (TSI) or miscellaneous material that is uniform in color and texture. Surfacing materials are most commonly found in sprayed-on, troweled-on or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members. TSI refers to materials applied to pipes, fittings, boilers, ductwork, or other components to prevent heat loss or gain, or condensation. Any material that does not fall under the surfacing or TSI category, such as floor tile, drywall, and acoustical ceiling tile are placed into the miscellaneous materials category.

Following the completion of the visual inspection, Red Cedar staff identified the following materials as suspect ACBM:

• Roofing Materials

• Fiberboard

• Tar Paper

• Window Caulk

• 12”x12” Ceiling Tile with Glue Pods

• Linoleum

• Drywall with Compound

• Plaster

Red Cedar staff collected thirty-three samples of suspect ACBM separated into fourteen distinct homogenous groups for laboratory analysis. Samples were collected and submitted to APEX Research

Inc. Laboratories (APEX) (Accreditation Number 102118-0) for laboratory analysis. Analysis was completed utilizing polarized light microscopy (PLM) which is the Environmental Protection Agency

(EPA) approved method for analysis of bulk materials for asbestos. PLM analysis completed pursuant to method (EPA 600/M4-82-020) identifies asbestos fiber bundles by the visual properties displayed when the sample is treated with various dispersion staining liquids. The laboratory report completed following the sample analysis indicates if asbestos is present, and at what percentage along with a description and percentage of other fibrous and non-fibrous materials and sample color. Chain-of-custody documentation was followed from sample collection through shipping and receiving of the samples at the designated laboratory. The documentation assures that samples will meet the quality assurance/quality control measures defined by AHERA. The laboratory analytical report prepared by APEX for the thirty-three samples is included as Attachment A.

Hazardous Materials Inspection

On September 15, 2025, the Subject Property was also inspected for the presence of hazardous materials which include but are not limited to polychlorinated biphenyls (PCBs) and potential mercury containing equipment and any items or containers that may contain or be classified as a hazardous or regulated material. Each material, if identified, was documented along with the approximate location. Any materials identified as hazardous are included in Table 1.

INSPECTION RESULTS AND RECOMMENDATIONS

During the completion of the asbestos inspection, thirty-three samples of suspect ACM were collected and are documented in Table 2 along with the Red Cedar sample number, description, friability, material type, ACM classification, sample location, material quantity and laboratory analytical results. A Site

Diagram was prepared which provides the general building layout and sample locations and is included as

Attachment B.

ACM, as defined by the USEPA NESHAP is “any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763 Section 1, Polarized

Light Microscopy”.

Friable ACM is defined by NESHAP as any material containing more than 1 percent asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Friable ACM is a concern due to the ease of unintentionally disturbing the ACM which may result in “visible emissions” which is known as a Fiber Release Episode.

Non-friable asbestos-containing material is defined as “material containing more than 1 percent asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable

ACMs are separated into Category I and Category II ACM. Category I ACM is any asbestos containing packing’s, gaskets, resilient floor coverings (vinyl floor tile and linoleum are examples of these) and asphalt roofing products. Category II ACM is stated by NESHAP as any material excluding Category I non-friable ACM such as drywall, plaster or fiberboard insulation.

Presumed Asbestos Containing Material

Presumed Asbestos Containing Materials (PACM) are suspect surfacing, TSI and miscellaneous materials found in buildings constructed prior to 1980 which are classified as and due to the age of the structure, are assumed to be ACM and do not require sample collection and analysis. OSHA dictates that PACM may be “rebutted” following a complete inspection pursuant to AHERA protocol.

No PACM was identified during the completion of this inspection. All suspect materials identified were sampled and analyzed for ACM.

Table 3 lists the location, material description, friability, condition, material type (surfacing, thermal or miscellaneous) and approximate quantity of all PACM documented at the Subject Property.

Table 4 provides a summary of all ACM documented at the Subject Property which includes the material location, description, and approximate quantity.

Friable ACM’s

No friable ACM’s were identified during the completion of this inspection.

Category I ACM

No Category I ACM was identified during the completion of this inspection.

Category II ACM

No Category II non-friable ACM was identified during the completion of this inspection.

RECOMMENDATIONS

Asbestos Containing Materials

No ACM was identified within the Building that would require abatement prior to demolition/renovation of the structure.

Please note: The location of samples obtained during this inspection were in a random fashion and areas that were not identified during this inspection may be damaged or have become damaged since the inspection was completed. If Category I or Category II friable materials are discovered prior to or during the demolition/renovation process, these materials must be abated prior to commencement of any demolition/renovation activities at the Subject Property.

Hazardous Materials

Hazardous Materials identified at the Subject Property and documented in Table 1 which require proper removal and disposal consist of the following items:

• No Hazardous Materials Identified

REGULATORY REQUIREMENTS

A Notification of intent to Renovate/Demolish form must be filed with the Michigan Department of

Environmental Quality- Air Quality Division at least 10 working days prior to any renovation or demolition activities at a site.

The Notification of Intent to Renovate/Demolish form must also be completed and submitted to the

MIOSHA-Asbestos Program whenever demolition, encapsulation and/or renovation activities at a site involving greater than ten lineal feet and/or fifteen square feet of ACM will be completed.

Regulated asbestos containing materials per NESHAP (40 CFR Part 61) which falls into any of the following categories are ACM’s that must be removed prior to any renovation/demolition activities at the

Subject Property.

• Friable asbestos material.

• Category I non-friable ACM that has become friable.

• Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.

• Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of renovation or demolition operations.

Asbestos abatement should only be performed by a certified asbestos abatement contractor licensed to complete abatement work. The contractor must also follow the standards and requirements set forth per the OSHA Asbestos Standards for Construction (29 CFR 1926.1101) and the USEPA NESHAP (40 CFR

Part 61).

Additional information regarding the OSHA Asbestos Standards for Construction (29 CFR 1926.1101) and the USEPA NESHAP (40 CFR Part 61) can be obtained by contacting the associated agency below.

NESHAP Asbestos Program MIOSHA-CSHD-Asbestos Program

Department of Environmental Quality State of Michigan

Phone: 517-284-6777 Phone: 517-284-7680

Email: asbestos@michigan.gov

DISCLAIMER

Red Cedar Consulting performed destructive testing methods in an attempt to access and inspect all areas of the Building. Unfortunately, due to the age of construction along with multiple additions/renovations that may have been completed on the Building, additional inspections may be required if suspect ACM material not documented within this report is encountered during renovation/demolition activities.

This report was prepared at the request and for exclusive use by the City of Jackson and may not be reproduced or sold without written permission from Red Cedar Consulting.

We appreciate the opportunity to provide the requested services. Please contact us at (888) 449-4566 with any questions or concerns.

Sincerely, Red Cedar Consulting

Aaron Paquet

Michigan/EPA Certified Asbestos Building Inspector

(A30955)

©2025 Red Cedar Consulting, LLC.