943_Williams_St._Asbestos_Containing_Materials_and_Hazardous_Materials_Report_042525.pdf

P.O. Box 13216 Lansing, MI 48901 Phone: 888.449.4566 Fax: 888.448.8739 www.redcedarconsulting.net

April 25, 2025

Mr. Brian Taylor City of Jackson Community Development Department Jackson, MI 49202

RE: Asbestos Containing Material and Hazardous Materials Inspection 943 Williams St. Jackson, MI 49203 Parcel ID: 4087700000

Dear Mr. Taylor:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at 943 Williams 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 .05-acre residential parcel which contains an approximate 945 square foot residential building (the Building) constructed in 1871. The Building was constructed on a concrete basement with two aboveground floors. The exterior walls of the Building were finished with wood siding while the roof was sealed with asphalt shingles. The Building can be further divided into one open room on each floor as all interior building materials have been removed to the studs.

VISUAL INSPECTION AND SAMPLING

Asbestos Containing Materials Inspection

Darrell DeMasters of Red Cedar Consulting (Red Cedar), accredited State Of Michigan/EPA Asbestos Building Inspector (Accreditation Number A31159) who completed training per the Michigan Asbestos Workers Accreditation Act 440, completed an inspection of the Subject Property on April 10, 2025 for suspected asbestos containing building materials.

Project No.: 12-1027

Parcel ID: 943 Williams St.

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:

• Asphalt Shingle

• Window Caulk

Red Cedar staff collected four samples of suspect ACBM separated into two 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 four samples is included as Attachment A.

Hazardous Materials Inspection

On April 10, 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, four 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.

Attachment A

APEX Research Laboratory Analytical Results

Certificate of Laboratory Analysis Test Method, Polarized Light Microscopy (PLM)

Report To: ARI Report # 25-117036 Mr. Aaron Paquet Date Collected: 04/10/25 Red Cedar Consulting Date Received: 04/11/25 P.O. Box 13216 Date Analyzed: 04/16/25 Lansing, MI 48901 Date Reported: 04/16/25

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 117036 - 01 Asbestos Present: NO Fiberglass - 30%

Cust. #: WS-HM-01A No Asbestos Observed Other - 70% Material: Asphalt Shingle Location:

Appearance: black,fibrous,nonhomogenous Layer: 1 of 2

Lab ID #: 117036 - 01a Asbestos Present: NO Fiberglass - 40% Cust. #: WS-HM-01A No Asbestos Observed Other - 60% Material: Felt Location:

Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 117036 - 02 Asbestos Present: NO Fiberglass - 30% Cust. #: WS-HM-01B No Asbestos Observed Other - 70% Material: Asphalt Shingle Location:

Appearance: black,fibrous,nonhomogenous Layer: 1 of 2

For Layered Samples, each component will be analyzed and reported separately.

Robert T. Letarte Jr., Laboratory Director

Test Method EPA 40 CFR - Part 763 and/or EPA 600/R-93/116 was used to analyze the above samples. Matrix interference and/or resolution limits may yield false/negative results in certain circumstances. Suspect floor tiles containing <1% should be tested with SEM or TEM. This certificate of analysis relates only to the samples as submitted and to insure the integrity of the results, may only be reproduced in full. This certificate must not be used by the customer to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. Liability limited to cost of analysis.

Project: 943 Williams St.

NVLAP Lab Code 102118-0

APEX Research Inc., 7717 Kensington Ct., Brighton, MI 48116

(734) 449-9990, Fax (734) 449-9991 Page 1 of 2

Certificate of Laboratory Analysis Test Method, Polarized Light Microscopy (PLM)

Report To: ARI Report # 25-117036 Mr. Aaron Paquet Date Collected: 04/10/25 Red Cedar Consulting Date Received: 04/11/25 P.O. Box 13216 Date Analyzed: 04/16/25 Lansing, MI 48901 Date Reported: 04/16/25

Project: 943 Williams St.

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 117036 - 02a Asbestos Present: NO Fiberglass - 40%

Cust. #: WS-HM-01B No Asbestos Observed Other - 60% Material: Felt Location:

Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 117036 - 03 Asbestos Present: NO Other - 100% Cust. #: WS-HM-02A No Asbestos Observed Material: Window Caulk Location:

Appearance: white,nonfibrous,homogenous Layer: 1 of 1

Lab ID #: 117036 - 04 Asbestos Present: NO Other - 100% Cust. #: WS-HM-02B No Asbestos Observed Material: Window Caulk Location:

Appearance: white,nonfibrous,homogenous Layer: 1 of 1

For Layered Samples, each component will be analyzed and reported separately.

Robert T. Letarte Jr., Laboratory Director

Test Method EPA 40 CFR - Part 763 and/or EPA 600/R-93/116 was used to analyze the above samples. Matrix interference and/or resolution limits may yield false/negative results in certain circumstances. Suspect floor tiles containing <1% should be tested with SEM or TEM. This certificate of analysis relates only to the samples as submitted and to insure the integrity of the results, may only be reproduced in full. This certificate must not be used by the customer to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. Liability limited to cost of analysis.

NVLAP Lab Code 102118-0

APEX Research Inc., 7717 Kensington Ct., Brighton, MI 48116

(734) 449-9990, Fax (734) 449-9991 Page 2 of 2

Attachment B Figure 1 Site Diagram

Figure 1 Site Diagram

Note: Figure created by Red Cedar Consulting Asbestos Sample Locations 943 Wiliams St.

-Not To Scale- Jackson, MI

Tables

Table 1 - Summary of Hazardous Materials, 943 Williams St. Jackson, Michigan

Hazardous Materials Description and Location

Location Material Description Quantity

No Hazardous Materials Identified

Table 2 - Summary of Sample Descriptions and Asbestos Laboratory Results, 943 Williams St. Jackson, Michigan

Sample Number Sample Description Friable Material

Type Material

Classification

% Asbestos Laboratory

Result Sample Location Approx. Material

Quantity

WS-HM-01A Asphalt Shingle No M Category I ND Building Exterior NA

WS-HM-01B Asphalt Shingle No M Category I ND Building Exterior NA

WS-HM-02A Window Caulk No M Category II ND Building Exterior NA WS-HM-02B Window Caulk No M Category II ND Building Exterior NA

Notes:

Material Types Abbreviations

M = Miscellaneous building material NQ = Not quantified TSI = Thermal System Insulation NA = Not Analyzed S = Surfacing Material ND = Not detected. Laboratory result is less than 1 % asbestos PC = Point Count Analysis lin. ft. = linear feet CH = Chrysotile Asbestos sq. ft. = square feet

Asbestos Containing Material (ACM) is defined as any material containing more than 1 percent asbestos as determined utilizing Polarized Light Microscopy.

Table 3 - Summary of Presumed Asbestos Containing Materials, 943 Williams St. Jackson, Michigan

Asbestos Containing Material Description and Location

Location Material Description Friable Condition Material Type Approx. Quantity

No Presumed Asbestos Containing Materials Identified

Notes:

Material Types Abbreviations

M = Miscellaneous building material lin. ft. = linear feet TSI = Thermal System Insulation sq. ft. = square feet S = Surfacing Material

Table 4 - Summary of All Asbestos Containing Materials, 943 Williams St. Jackson, Michigan

Exterior/Interior - Asbestos Containing Materials

Location Material Description Friable Approx. Quantity

No Asbestos Containing Materials Identified

Notes:

Abbreviations lin. ft. = linear feet

sq. ft. = square feet

Shaded/Bolded = Friable ACM and any Category I and Category II non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder by the demolition or renovation activities that must be properly abated prior to commencement of any demolition/renovation activities.

Demolition/renovation activities completed with intact Category I non-friable ACM are regulated by OSHA and must be completed following the OSHA Asbestos Standards for Construction (29 CFR 1926.1101) which limits employee exposure to asbestos.

Please note that a Negative Pressure Enclosure must be utilized during abatement when Site Conditions Warrant. Examples of these conditions include the abatement of Plaster and Vermiculite insulation, HVAC Duct Wrap in Poor Condition, and Air-O-Cell/Mag Pipe Wrap. Conditions outside of these should be assessed on a case by case basis during the Asbestos Abatement Contractors site walk and Work Plan Preparation.