ATT 3 - Atlas Hazardous Material Report_5.21.25.pdf

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Parking Ramp Demolition
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ITB-KD-1025-ParkingRampDemo
Issued by
Genesee County, Michigan

About this file

This document is a Pre-Demolition Hazardous Materials Survey Report prepared by Atlas Technical Consultants LLC for Mott Community College, located at 1401 E. Court Street in Flint, Michigan. The survey was conducted from March 10-13, 2025, focusing on the closed parking garage and Ramp G, and was performed in accordance with federal, state, and local regulations for hazardous materials assessments. The comprehensive investigation included sampling and analysis of potential asbestos-containing materials (ACMs), polychlorinated biphenyls (PCBs), lead-containing paint, and an inventory of other regulated materials (ORM) throughout the parking structure.

The survey's key findings revealed ten asbestos-containing materials with chrysotile asbestos content ranging from 1.25% to 40%, including floor tiles, pipe fittings, caulk, and weather proofing. Additionally, one composite material sample tested positive for PCBs at 88.8 parts per million, and four of seven paint samples contained lead. The report recommends that all identified asbestos-containing and PCB materials be removed by licensed abatement contractors prior to renovation or demolition activities. Other regulated materials inventoried included six fire extinguishers, 70 fluorescent and HID light fixtures, bulbs, and ballasts, and one security alarm system. The survey also noted that additional hazardous materials might be present in inaccessible areas and should be sampled and addressed accordingly during future renovation efforts.

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Attachment 3

Hazardous Material Report

PRE-DEMOLITION HAZARDOUS MATERIALS SURVEY REPORT

MOTT COMMUNITY COLLEGE – CLOSED PARKING GARAGE / RAMP G

1401 E. Court Street Flint, MI 48503

188BS25141

PREPARED FOR:

Mott Community College

PREPARED BY:

Atlas Technical Consultants LLC 46555 Humboldt Drive, Ste. 100 Novi, MI 48377 May 21, 2025

Page | i

46555 Humboldt Dr., Ste. 100 Novi, MI 48377

(248) 669-5140 | oneatlas.com

May 21, 2025

MR. SHANE STEPHENSON

RISK MANAGEMENT COORDINATOR

MOTT COMMUNITY COLLEGE

1401 E. COURT STREET

FLINT, MICHIGAN 48503

Subject: Pre-Demolition Hazardous Materials Survey Report MCC Closed Parking Garage/Ramp G 1401 E. Court St Flint, MI 48503

Project #: 188BS25141

Dear Mr. Stephenson:

Atlas Technical Consultants (Atlas) is pleased to submit the enclosed pre-demolition hazardous materials survey report for the above-referenced location. The survey was conducted March 10- 13, 2025, in general accordance with Mott Community College’s standard operating procedures.

Please refer to the attached report, tables, and analytical results for additional information.

If you have questions or desire additional information, please contact Atlas at 248-669-5140.

Please refer to Atlas Project No. 188BS25141.

Respectfully submitted, Atlas Technical Consultants LLC

Michael Fountain Jennifer Fashbaugh Asbestos Inspector Project Manager Atlas Technical Consultants LLC Atlas Technical Consultants LLC

Page | ii

CONTENTS

1. EXECUTIVE SUMMARY

1.1 General Observations

1.2 Asbestos Analytical Results

1.3 Polychlorinated Biphenyls (PCB) Analytical Results

1.4 Lead-Containing Paint (LCP) Analytical Results

1.5 Other Regulated Materials (ORM) Inventory

1.6 Discussion and Recommendations

2. ASBESTOS SURVEY

2.1 Introduction

2.2 Sampling Methodology

2.3 Summary of Findings

2.4 Quality Control

3. POLYCHLORINATED BIPHENYLS SAMPLING

3.1 Laboratory Analytical Methodology

4. LEAD-CONTAINING PAINT SAMPLING

4.1 Laboratory Analytical Methodology

5. OTHER REGULATED MATERIALS (ORM) INVENTORY

6. DISCUSSION AND RECOMMENDATIONS

7. ASSUMPTIONS AND LIMITATIONS

APPENDICES

LABORATORY ANALYTICAL REPORTS

QUALITY ASSURANCE DOCUMENTATION

PHOTOGRAPHIC LOG

Page | 1

1. EXECUTIVE SUMMARY

1.1 General Observations

Atlas performed a pre-demolition hazardous materials survey including asbestos, lead and PCB sampling as well as a visual assessment to inventory Other Regulated Materials (ORM) for Mott Community College (MCC) at the closed parking garage and ramp G at 1401 E. Court Street, Flint, Michigan 48503. The hazardous materials survey included accessible areas of the parking garage and ramp as well as exterior areas and was conducted from March 10-13, 2025.

The survey was performed in general accordance with Federal, State and local rules for conducting hazardous materials surveys to meet Occupational Safety and Health Administration (OSHA) Asbestos for General Industry Standard (29 CFR 1910.1001(j)(2)(i)) and United States Environmental Protection Agency (EPA) / National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 61) requirements.

1.2 Asbestos Analytical Results

In summary, the asbestos analytical results indicated asbestos greater than 1% by weight was detected in ten (10) of the forty-seven (47) suspect materials collected and analyzed during the survey. One (1) material was found to contain asbestos but was <1% after point count analysis.

Table 1.2A below provides a summary of the 10 confirmed asbestos-containing materials (ACMs) and 1 material containing <1% asbestos from the building:

Table 1.2A Summary of ACM and Materials with <1% Asbestos

Sample ID Material Condition Friability:

RACM, Cat I, Cat II

Estimated Quantity

(SF/LF)

Asbestos Content

16-EC-A,B,C Brown Exterior Door Caulk Good Cat II 150 LF 3% Chrysotile

22-FT-A,B,C 12x12 Grey Floor Tile with Mastic Good Cat I 150 SF 2% Chrysotile (floor tile)

ND (mastic)

24-GP-A,B,C Black Glue Pod Good Cat II 148 SF 1.25% Chrysotile

(Point Count)

28-WP-A,B,C Grey/Black Weather Proofing Good Cat II 3,000 LF 4% Chrysotile

32-EC-A,B,C Grey Exterior Window Caulk Good Cat II NA 0.5% Chrysotile (Point Count)

37-PF-A,B,C White Pipe Fitting Good RACM 15 fittings 40% Chrysotile

38-PF-A,B,C White Pipe Fitting Good RACM 15 fittings 40% Chrysotile

39-PF-A,B,C White Pipe Fitting Good RACM 15 fittings 35% Chrysotile

40-WG-A,B,C Grey Window Glaze Good Cat II 500 LF 2% Chrysotile

41-IC-A,B,C Dark Grey Door Caulk Good Cat II 150 LF 2% Chrysotile

42-EC-A,B,C Brown Exterior Door Caulk Good Cat II 200 LF 2% Chrysotile

RACM – Regulated Asbestos Containing Material SF/LF – Square Foot/Linear Foot

CAT I – Category I Non-Friable CAT II – Category II Non-Friable

Page | 2

In the event additional suspect materials are discovered during abatement activities, this material should be treated as presumed asbestos-containing material (PACM) in accordance with OSHA regulations 29 CFR 1926.1101 and 1910.1001 and other applicable state and local regulations and either sampled to confirm or nullify asbestos content or be treated as ACM and handled accordingly.

One (1) material was assumed to contain asbestos due to potential electrical hazard. Table 1.2B below provides a summary of materials that are considered assumed to contain asbestos:

Table 1.2B Summary of Assumed ACM

Sample ID Material Condition

Friability:

RACM,

Cat I, Cat II

Estimated Quantity

(SF/LF)

Asbestos Content

NA

Wrap on Electrical Wiring in

North and South Electrical Rooms in Stairwells

Good Friable 100 LF Assumed

A complete list of suspect asbestos-containing materials identified in the subject building including those sampled and analyzed for asbestos content and found to not contain asbestos are summarized below in Table 2.3.

1.3 Polychlorinated Biphenyls (PCB) Analytical Results

Composite samples of caulks, glazes, and mastics or adhesives were collected and analyzed for PCBs. The laboratory analytical results for the limited PCB sampling conducted at the subject building indicated that the one (1) composite material sample was found to contain PCBs above 50 parts per million (PPM). Polychlorinated biphenyls should be removed by a licensed abatement contractor prior to renovation activities that would disturb these materials. Table 1.3 below provides a summary of the composite materials that were collected for PCB analysis:

Table 1.3 Summary of PCB Analytical Results

Sample ID Material Condition PCB Type: Content Total PCB Content

PCB1

Door & Window Caulks (Throughout Structure)

Good Aroclor 1,254: 88.8 ppm 88.8 ppm

If any additional materials are discovered during renovation or demolition activities, such materials must be assumed to contain PCBs until sampling and analysis proves otherwise.

1.4 Lead-Containing Paint (LCP) Analytical Results

Seven (7) paint chip samples were collected and submitted to Accurate Analytical Testing Laboratory, 30105 Beverly Road, Romulus, Michigan for lead analysis by Flame AAS. The results of laboratory analysis indicated that four (4) of the samples contained lead greater than the laboratory reporting limits. Table 1.4 below provides a summary of the paint chip samples that were collected for lead analysis:

Page | 3

Table 1.4 Summary of Lead Paint Chip Analytical Results

Sample

ID

Sample Location Areas Represented Color Lead

Content

Reporting Limit

1 Parking Structure (2nd floor) Throughout Parking Structure Yellow 0.000924 0.000565

2 Parking Structure (3rd floor) Throughout Parking Structure Blue <0.00273 0.00273

3 Parking Structure (1st floor) Throughout Parking Structure Red 0.00477 0.00111

4 Parking Structure (Basement) Throughout Parking Structure White <0.001161 0.00161

5 South Stairwell Throughout Stairwells White 0.247 0.000532

6 East Stairwell Throughout Stairwells Brown <0.00239 0.00239

7 North Stairwell Throughout Stairwells Yellow 0.00184 0.00141

The presence of lead-containing paint requires, under OSHA 1926.62 requirements, that the contractor performing renovation/demolition, surface preparation, and other activities that impact or potentially impact the lead-coated components, evaluate potential worker exposures to airborne lead. This evaluation can be based, for the specific activities denoted in 1926.62, on objective data obtained by the contractor on other, similar, worksites within the prior calendar year. In addition, lead-containing paint and lead-coated waste and construction debris must be evaluated and, on a case-by-case basis depending on this evaluation, quantitative analysis be performed on these waste steams to ensure compliance with EPA waste disposal regulations.

1.5 Other Regulated Materials (ORM) Inventory

Atlas conducted a visual assessment for Hazardous and/or Other Regulated Material (ORM) at the subject building and recorded the quantity and location of the items including but not limited to e-wastes, mercury devices or equipment, lights, ballasts, chemicals, etc. Table 1.5 below summarized the inventory of ORM listed in the subject building.

Table 1.5 Summary of Other Regulated Materials

Location Quantity

(each) Material

Throughout Stairwells 6 Fire Extinguishers

Throughout Stairwells 70 Fluorescent, HID Light Fixtures, Bulbs, Ballasts

3rd floor Security Office 1 Security Alarms/Systems

Page | 4

1.6 Discussion and Recommendations

The results of the asbestos survey conducted from March 10-13, 2025, at MCC closed parking structure and ramp G, indicated that ten (10) of the forty-seven (47) suspect materials sampled by Atlas were found to be ACM as defined by the EPA and State of Michigan Occupational Safety and Health Administration (MIOSHA) regulations. One (1) material was found to contain asbestos but was <1% after point count analysis. Due to the potential electrical hazard, one (1) material was assumed to contain asbestos and should be treated as ACM until sampling proves otherwise.

See Tables 1.2A and 1.2B above.

The results of laboratory testing during the limited PCB sampling conducted at the subject building indicated that the one (1) composite material sampled was found to contain concentrations of PCBs greater than 50 PPM. If any additional materials are discovered during renovation or demolition activities, such materials must be assumed to contain PCBs until sampling and analysis proves otherwise. See Table 1.3 above.

The results of laboratory testing during the limited lead-containing paint sampling conducted at the subject building indicated that four (4) of the seven (7) materials sampled were found to contain lead greater than the laboratory reporting limits. See Table 1.4 above.

It should be further noted that additional suspect asbestos, PCB, or lead paint materials beyond those identified during this survey, may be present in inaccessible areas or spaces concealed by practical and manual means of retrieval. These areas or spaces include, but are not limited to, buried piping, obstructed wall, ceiling, or floor cavities, interstitial spaces, concrete or mortar-entombed materials, mechanical pipe gaskets and packings, insulated electrical components, etc.

Atlas recommends any building materials not previously sampled which are suspected to contain asbestos, PCB, or lead-containing paint that are discovered during renovation or demolition activities be sampled to determine the content of the appropriate hazardous material and addressed accordingly.

Atlas also conducted a visual assessment for Hazardous and/or Other Regulated Material (ORM) at the subject building and recorded the quantity and location of materials/items including, but not limited to:

• E-Wastes

• Mercury Containing Devices or Equipment (switches, gauges, fluorescent lamps)

• Dielectric fluid in electrical equipment (transformers, capacitors, and light ballasts

• Fuels and Oils

• Tires

• Batteries

• Florescent Light Fixtures

• Miscellaneous containers of chemicals

Table 1.5 above summarizes the ORM inventory list from the subject building.

Page | 5

2. ASBESTOS SURVEY

2.1 Introduction

The survey was performed in accordance with Federal, State and local rules for conducting asbestos surveys to meet Occupational Safety and Health Administration (OSHA) Asbestos for General Industry Standard (29 CFR 1910.1001(j)(2)(i)) and United States Environmental Protection Agency (EPA) / National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 61) requirements.

2.2 Sampling Methodology

Bulk samples were collected of suspect asbestos-containing materials (ACMs) and grouped by homogeneous area (HA). An HA is characterized as surfacing material, thermal system insulation (TSI), or miscellaneous material that is uniform in use, colors, appearance, pattern, texture, and date of installation. The HA can be described within a single building (i.e., red floor tile in different buildings on the same complex, even if installed on the same day, compose different HAs).

Bulk samples were obtained with tools designed to penetrate a material without creating excessive dust. An effort was made to obtain samples that were representative of all layers of the material. The areas were pre-wetted to reduce potential dust generation during the sampling process.

Atlas’ sampling procedures incorporate the use of sealable containers labeled in a unique numbering sequence to store bulk samples. Information about bulk samples, including the sample numbers and materials’ descriptions, were noted on the chain-of-custody sheets after samples were collected. Laboratory analytical reports and chain-of-custody sheets are included in Appendix I. A photographic log can be found in Appendix III.

The site was inspected for the presence of material that may contain asbestos as per the State of Michigan Occupational Safety and Health Administration (MIOSHA) regulations. In accordance with the scope of work for the project, the survey areas included the roof, building exterior, and the building interior.

Several construction and finish materials were observed in the site building that were determined to be non-suspect materials. These materials may include:

Clay/terra-cotta Structural Block

Wood

Carpet

Wallpaper

Glass

Page | 6

2.3 Summary of Findings

Atlas collected one hundred and forty-nine (149) bulk samples comprising one hundred and sixty-six (166) sample layers from forty-seven (47) suspect materials from various areas throughout the interior and exterior of the building. These samples were packaged and delivered to Environmental Testing Laboratory (ETL) located in Romulus, Michigan. Samples were analyzed by Polarized Light Microscopy (PLM), utilizing dispersion staining techniques (EPA Method 600/R-93/116, July-1993) to assess the percentage of asbestos present on the basis of visual area estimation. ACMs are defined as materials that contain greater than 1% asbestos. PLM samples were further analyzed by Point Count Method when PLM results were <1% asbestos content by weight.

The analytical results indicated asbestos was detected in ten (10) of the forty-seven (47) suspect materials. One (1) material was found to contain <1% asbestos after point count analysis. One

(1) material was assumed to contain asbestos but was not sampled due to a potential electrical hazard. This material should be treated as ACM until sampling proves otherwise.

Table 2.3 below provides a summary of accessible suspect materials sampled or assumed as well as confirmed ACMs from the Site building(s):

Table 2.3 Summary of Asbestos Bulk Sampling

Sample ID Material Condition

Friability:

RACM,

Cat I, Cat II

Estimated Quantity

(SF/LF)

Asbestos Content

1-CC-A,B,C 2nd Floor Parking Structure Grey Concrete Good Cat II NA ND

2-CC-A,B,C 2nd Floor South Stairwell Grey Concrete Good Cat II NA ND

3-CC-A,B,C 3rd Floor East Stairwell Grey Concrete Good Cat II NA ND

4-CC-A,B,C 4th Floor North Stairwell Grey Concrete Good Cat II NA ND

5-CC-A,B,C South Bridge Grey Concrete Good Cat II NA ND

6-CC-A,B,C North Bridge Grey Concrete Good Cat II NA ND

7-EJ-A,B,C 3rd Floor Parking Garage Expansion Joint 2" Good Cat II NA ND

8-EC-A,B,C Grey Exterior Crown Caulk Good Cat II NA ND

9-EC-A,B,C Grey Exterior Crown Caulk Good Cat II NA ND

10-EC-A,B,C Grey Exterior Crown Caulk Good Cat II NA ND

11-CBA-A,B,C Covebase with Grey Adhesive Good Cat I NA ND

12-CA-A,B,C Brown Construction Adhesive Good Cat II NA ND

13-WBS-A,B,C Beige Drywall with Tape and Joint Compound Good RACM NA ND

Page | 7

Table 2.3 Summary of Asbestos Bulk Sampling

Sample ID Material Condition

Friability:

RACM,

Cat I, Cat II

Estimated Quantity

(SF/LF)

Asbestos Content

14-CP-A,B,C 2x4 White Ceiling Panel Fair RACM NA ND

15-IC-A,B,C Grey Window Frame Caulk Good Cat II NA ND

16-EC-A,B,C Brown Exterior Door Caulk Good Cat II 150 LF 3% Chrysotile

17-TP-A,B,C Grey Transite Panel Good Cat II NA ND

18-RM-A,B,C Black Rubber Coating with Beige Adhesive and Insulation Good Cat I NA ND

19-M-A,B,C Black Mastic Good Cat I NA ND

20-M-A,B,C Black Mastic Good Cat I NA ND

21-M-A,B,C Black Mastic Good Cat I NA ND

22-FT-A,B,C 12x12 Grey Floor Tile with Mastic Good Cat I 150 SF 2% Chrystotile

(floor tile) ND (mastic)

23-GP-A,B,C Beige Glue Pod Good Cat II NA ND

24-GP-A,B,C Black Glue Pod Good Cat II 148 SF 1.25% Chrysotile

(PC)

25-GP-A,B,C Beige Glue Pod under CP Good Cat II NA ND

26-PM-A,B,C White Penetration Mud Good RACM NA ND

27-PG-A,B,C Black Pipe Gasket Good Cat II NA ND

28-WP-A,B,C Grey/Black Weather Proofing Good Cat II 3,000 SF 4% Chrysotile

29-EJ-A,B,C Black 1"Expansion Joint Good Cat II NA ND

30-CT-A,B,C Beige Ceramic Tile w/ Mortar (cove Base) Good Cat I NA ND

31-IC-A,B,C Brown/Yellow Interior Door Caulk Good Cat II NA ND

32-EC-A,B,C Grey Exterior Window Caulk Good Cat II NA 0.5% Chrysotile

(PC)

33-IC-A,B,C Grey Interior Window Caulk Good Cat II NA ND

34-PW-A,B,C White Pipe Wrap with Insulation Good RACM NA ND

35-PW-A,B,C White Pipe Wrap with Insulation Good RACM NA ND

36-PW-A,B,C White Pipe Wrap with Insulation Good RACM NA ND

37-PF-A,B,C White Pipe Fitting Good RACM 15 fittings 40% Chrysotile

38-PF-A,B,C White Pipe Fitting Good RACM 15 fittings 40% Chrysotile

Page | 8

Table 2.3 Summary of Asbestos Bulk Sampling

Sample ID Material Condition

Friability:

RACM,

Cat I, Cat II

Estimated Quantity

(SF/LF)

Asbestos Content

39-PF-A,B,C White Pipe Fitting Good RACM 15 fittings 35% Chrysotile

40-WG-A,B,C Grey Window Glaze Good Cat II 500 LF 2% Chrysotile

41-IC-A,B,C Dark Grey Door Caulk Good Cat II 150 LF 2% Chrysotile

42-EC-A,B,C Brown Exterior Door Caulk Good Cat II 200 LF 2% Chrysotile

43-RM-A,B,C Black Rubber Coating with Beige Adhesive and Insulation Good Cat II NA ND

44-RM-A,B,C Black Rubber Coating with Beige Adhesive and Insulation Good Cat II NA ND

45-CT-A,B,C 12x12 Beige Ceramic Tile with Mortar Good Cat I NA ND

46-TP-A,B,C Grey Transite Panel Good Cat II NA ND

47-EC-A,B,C Grey Ceiling Caulk Good Cat II NA ND RACM – Regulated Asbestos Containing Material

SF/LF – Square Foot/Linear Foot CAT I – Category I Non-Friable

CAT II – Category II Non-Friable NA – Not Applicable

ND – Non-Detect

In the event additional suspect material is discovered during abatement activities, this material should be treated as presumed asbestos-containing material (PACM) in accordance with regulations 29 CFR 1926.1101 and 1910.1001 and other applicable state and local regulations and either sampled to confirm or nullify asbestos content or be treated as ACM and handled accordingly.

2.4 Quality Control

The bulk samples collected by Atlas were submitted for PLM analysis to Environmental Testing Laboratory, Inc. (ETL). located in Romulus, Michigan. ETL performs bulk PLM analysis conforming with EPA-prescribed methodologies, operates in accordance with a written Standard Operating Procedure and maintains compliance with a formal Quality Assurance (QA) Program. This program follows quality guidelines as documented in third-party accreditation authorities including the NIST National Voluntary Laboratory Accreditation Program (NVLAP). ETL is accredited by NVLAP (Lab Code 201028-0). ETL’s internal Quality Control (QC) program includes 10% quality control on all samples received for analysis, proficiency testing and round- robin protocols. A copy of ETL’s NVLAP-accreditation certificate is included in Appendix II.

Atlas’s inspectors maintain their Asbestos Building Inspector accreditation in compliance with the EPA requirements under 40 CFR 763 and Michigan Compiled Laws (MCL) 338.3403, Sec.3(1)(a) of the Michigan Asbestos Workers Accreditation Act (Act 440, P.A. 1988, as amended). Under authority of Michigan’s Department of Licensing and Regulatory Affairs (LARA), MIOSHA’s Asbestos Program administers asbestos accreditations. A copy of Atlas’ inspectors’ Asbestos Building Inspector accreditation is included in Appendix II.

Page | 9

3. POLYCHLORINATED BIPHENYLS SAMPLING

Atlas representative Mr. Michael Fountain conducted the limited PCB sampling of caulks, mastics, and glazes at the MCC closed parking garage and ramp G on March 11, 2025. The PCB inspection consisted of conducting a visual inspection to identify materials and the sample collection of accessible suspect PCB containing materials.

Materials which are found to contain concentrations of PCBs greater than fifty (50) parts per million (PPM) are regulated under the Toxic Substances Control Act (TSCA) PCB regulations (40 CFR part 761).

The EPA, TSCA regulations prohibit the use of PCBs in caulk and other building materials manufactured with PCBs at levels greater than or equal to 50 ppm, including the continued use of such materials that are already in place. EPA published materials state that “Although the EPA does have enforcement tools that it can use as appropriate where the PCB concentration in the caulk or other materials is above the regulatory limit, EPA is most interested in ensuring that school districts and other building owners undertake the recommended actions to limit exposures to PCBs” and that the “EPA believes that enforcement may not be the most effective tool to reduce health risks when school districts and other building owners follow these recommendations. Thus, such buildings will in most cases be a low priority for enforcement”.

3.1 Laboratory Analytical Methodology

Composite samples of caulks, glazes, and mastics or adhesives were collected and analyzed for PCBs. Bulk samples were submitted under chain-of-custody to Quantum Laboratories, Inc. and analyzed per SW-846 utilizing Test Method 8082A.

The laboratory analytical results for the limited PCB sampling conducted at the subject building indicated that the one (1) composite material sample was found to contain PCBs above 50 parts per million (PPM). Polychlorinated biphenyls should be removed by a licensed abatement contractor prior to renovation activities that would disturb these materials. Table 1.3 above provides a summary of the composite materials that were collected for PCB analysis. Sample results are reported in parts per million (PPM). A copy of the laboratory analytical report and chain-of-custody form is included in Appendix I.

If any additional materials are discovered during renovation/demolition activities, such materials must be assumed to contain PCBs until sampling and analysis proves otherwise.

4. LEAD-CONTAINING PAINT SAMPLING

Atlas representative Mr. Michael Fountain conducted the lead-containing paint (LCP) sampling of the closed parking garage and ramp G on March 11, 2025. The sampling included physical sampling of paint coatings that were deemed representative of the predominant paint coatings observed.

Page | 10

4.1 Laboratory Analytical Methodology

Seven (7) paint chip samples were collected and submitted to Accurate Analytical Testing Laboratory, 30105 Beverly Road, Romulus, Michigan for lead analysis. Bulk samples were analyzed using the Environmental Protection Agency's Test Method SW 846-7420 and 3050B using Flame AAS to determine lead concentration in percent (%) by weight. Table 1.4 above provides a summary of the paint chip samples that were collected for lead analysis. A copy of the laboratory analytical report and chain-of-custody form are included in Appendix I. A copy of Accurate’s NLLAP-accreditation certificate is included in Appendix II.

5. OTHER REGULATED MATERIALS (ORM) INVENTORY

Atlas conducted a visual assessment for Hazardous and/or Other Regulated Material (ORM) at the subject building and recorded the quantity and location of the items including but not limited to e-waste, mercury devices or equipment, lights, ballasts, chemicals, etc.

There was a security system noted in the Security Office and 6 fire extinguishers, and 70 lights noted throughout the parking garage. Table 1.5 above summarizes the inventory of ORM listed in the subject building.

6. DISCUSSION AND RECOMMENDATIONS

Asbestos

The results of the pre-demolition hazardous materials survey conducted from March 10-13, 2025, at the MCC closed parking garage and ramp G in Flint, Michigan 48503, indicated that of the suspect asbestos-containing materials sampled by Atlas, ten (10) were found to be ACMs (>1%) as defined by the EPA and MIOSHA regulations. One (1) material was found to contain asbestos but was <1% after point count analysis. One (1) material was assumed to contain asbestos. See Tables 1.2A and 1.2B above for further details. Asbestos laboratory analytical reports and chain-of-custody forms are included in Appendix I. ACMs should be removed by a State of Michigan licensed asbestos abatement contractor prior to renovation or demolition activities that would disturb these materials.

It should be noted that additional suspect ACMs, beyond those identified during this survey, may be present in inaccessible areas or spaces concealed by practical and manual means of retrieval.

These areas or spaces include, but are not limited to, buried piping, obstructed wall, ceiling, floor cavities, interstitial spaces, concrete or mortar-entombed materials, mechanical pipe gaskets and packings, insulated electrical components, etc. Atlas recommends any suspect ACMs not previously sampled, that are discovered during renovations be sampled to determine asbestos content and addressed accordingly.

Page | 11

PCB

The laboratory analytical results for the limited PCB sampling conducted at the subject building indicated that the one (1) composite material sample of door and window caulks were found to contain PCBs above 50 parts per million (PPM). See Table 1.3 above for further details. The laboratory analytical report and chain-of-custody are included in Appendix I.

Polychlorinated biphenyls should be removed by a licensed abatement contractor prior to renovation activities that would disturb these materials. Several door caulk materials and window glazing were also positive for asbestos and window caulk material contained <1% asbestos by Point Count, so it is recommended that these materials are removed by a State of Michigan licensed asbestos abatement contractor as ACM prior to demolition activities. The PCB requirements would become secondary to the asbestos abatement and conducted concurrently.

Lead Paint

Seven (7) representative samples of paint, taken from the building, were collected, and submitted for analysis by Flame AAS. The results of laboratory analysis indicate that four (4) of the samples contained levels of lead greater than the laboratory reporting limits. See Table 1.4 above for further details. The laboratory analytical report and chain-of-custody are included in Appendix I.

The presence of lead-containing paint requires, under OSHA 1926.62 requirements, that the contractor performing renovation/demolition, surface preparation, and other activities that impact or potentially impact the lead-coated components, evaluate potential worker exposures to airborne lead.

This evaluation can be based, for the specific activities denoted in 1926.62, on objective data obtained by the contractor on other, similar, worksites within the prior calendar year. In addition, lead-containing paint and lead-coated waste and construction debris must be evaluated and, on a case-by-case basis depending on this evaluation, quantitative analysis be performed on these waste steams to ensure compliance with EPA waste disposal regulations.

The presence of Lead-Containing Paint (LCP) and/or Lead-Based Paint (LBP) does not, in itself, trigger regulatory compliance actions. However, when these materials are disturbed, the requirements of OSHA (1926.1101) and EPA may become operative. Appropriate actions in terms of removal methods, emissions control, worker protection, and waste disposal should be considered by the general contractor and applicable subcontractors while completing renovation/demolition activities.

ORM

Atlas conducted a visual assessment for Hazardous and/or Other Regulated Material (ORM) at the subject building and recorded the quantity and location of the items. Table 1.5 above summarizes the inventory of ORM listed in the subject building.

Page | 12

7. ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during the NESHAP inspection conducted from March 10-13, 2025 performed by Atlas. Selection of sample locations and frequency of sampling were based on EPA Guidance documents, Atlas’s observations, and the assumption that building vintage and demolition history information presented to Atlas allowed the proper designation of homogenous materials for each building. This document does not contain the elements necessary for an Abatement Work plan, and this document does not contain, nor should it take the place of technical specifications for ACM removal.

This report is designed to aid the building owner, architect, construction manager, general contractors, and potential asbestos abatement contractors in locating ACM. Under no circumstances is the report to be utilized as a bidding document or as a project specification document.

Our professional services have been performed, our findings obtained, and our conclusions and recommendations prepared in accordance with customary principles and practices in the fields of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against changes to material from future operations or conditions, nor does it warrant against operations or conditions against present ACM material in locations not investigated.

The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users and use or re-use of this document or the findings, conclusions, or recommendations is at the risk of said user.

APPENDIX I

LABORATORY ANALYTICAL REPORTS

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

(734) 955-6600

Fax: (734) 955-6604

To:

Attention:

Atlas - Novi

46555 Humboldt Dr. Suite 100

Novi, Michigan 48377

Project Location: Mott Parking Structure

Client Project: N/A

278637ETL Job:

Ryan Rae

Lab Sample Number Client Sample Number Sample Type Completed

1787082 Asbestos1-CC-A 05/12/2025

1787083 Asbestos1-CC-B 05/12/2025

1787084 Asbestos1-CC-C 05/12/2025

1787085 Asbestos2-CC-A 05/12/2025

1787086 Asbestos2-CC-B 05/12/2025

1787087 Asbestos2-CC-C 05/12/2025

1787088 Asbestos3-CC-A 05/12/2025

1787089 Asbestos3-CC-B 05/12/2025

1787090 Asbestos3-CC-C 05/12/2025

1787091 Asbestos4-CC-A 05/12/2025

1787092 Asbestos4-CC-B 05/12/2025

1787093 Asbestos4-CC-C 05/12/2025

1787094 Asbestos5-CC-A 05/12/2025

1787095 Asbestos5-CC-B 05/12/2025

1787096 Asbestos5-CC-C 05/12/2025

1787097 Asbestos6-CC-A 05/12/2025

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this information in error, please notify ETL immediately. Thank you.

Lab Sample Number Client Sample Number Sample Type Completed

1787098 Asbestos6-CC-B 05/12/2025

1787099 Asbestos6-CC-C 05/12/2025

1787100 Asbestos7-EJ-A 05/12/2025

1787101 Asbestos7-EJ-B 05/12/2025

1787102 Asbestos7-EJ-C 05/12/2025

1787103 Asbestos8-EC-A 05/12/2025

1787104 Asbestos8-EC-B 05/12/2025

1787105 Asbestos8-EC-C 05/12/2025

1787106 Asbestos9-EC-A 05/12/2025

1787107 Asbestos9-EC-B 05/12/2025

1787108 Asbestos9-EC-C 05/12/2025

1787109 Asbestos10-EC-A 05/12/2025

1787110 Asbestos10-EC-B 05/12/2025

1787111 Asbestos10-EC-C 05/12/2025

1787112 Asbestos11-CBA-A 05/12/2025

1787113 Asbestos11-CBA-B 05/12/2025

1787114 Asbestos11-CBA-C 05/12/2025

1787115 Asbestos12-CA-A 05/12/2025

1787116 Asbestos12-CA-B 05/12/2025

1787117 Asbestos12-CA-C 05/12/2025

1787118 Asbestos13-WBS-A 05/12/2025

1787119 Asbestos13-WBS-B 05/12/2025

1787120 Asbestos13-WBS-C 05/12/2025

1787121 Asbestos14-CP-A 05/12/2025

1787122 Asbestos14-CP-B 05/12/2025

1787123 Asbestos14-CP-C 05/12/2025

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this

1787124 Asbestos15-IC-A 05/12/2025

1787125 Asbestos15-IC-B 05/12/2025

1787126 Asbestos15-IC-C 05/12/2025

1787127 Asbestos16-EC-A 05/12/2025

1787128 Asbestos16-EC-B 05/12/2025

1787129 Asbestos16-EC-C 05/12/2025

1787130 Asbestos17-TP-A 05/12/2025

1787131 Asbestos17-TP-B 05/12/2025

1787132 Asbestos17-TP-C 05/12/2025

1787133 Asbestos18-RM-A 05/12/2025

1787134 Asbestos18-RM-B 05/12/2025

1787135 Asbestos18-RM-C 05/12/2025

1787136 Asbestos19-M-A 05/12/2025

1787137 Asbestos19-M-B 05/12/2025

1787138 Asbestos19-M-C 05/12/2025

1787139 Asbestos20-M-A 05/12/2025

1787140 Asbestos20-M-B 05/12/2025

1787141 Asbestos20-M-C 05/12/2025

1787142 Asbestos21-M-A 05/12/2025

1787143 Asbestos21-M-B 05/12/2025

1787144 Asbestos21-M-C 05/12/2025

1787145 Asbestos22-FT-A 05/12/2025

1787146 Asbestos22-FT-B 05/12/2025

1787147 Asbestos22-FT-C 05/12/2025

1787148 Asbestos23-GP-A 05/12/2025

1787149 Asbestos23-GP-B 05/12/2025

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this

1787150 Asbestos23-GP-C 05/12/2025

1787151 Asbestos24-GP-A 05/12/2025

1787152 Asbestos24-GP-B 05/12/2025

1787153 Asbestos24-GP-C 05/12/2025

1787154 Asbestos25-GP-A 05/12/2025

1787155 Asbestos25-GP-B 05/12/2025

1787156 Asbestos25-GP-C 05/12/2025

1787157 Asbestos26-PM-A 05/12/2025

1787158 Asbestos26-PM-B 05/12/2025

1787159 Asbestos26-PM-C 05/12/2025

1787160 Asbestos27-PG-A 05/12/2025

1787161 Asbestos27-PG-B 05/12/2025

1787162 Asbestos27-PG-C 05/12/2025

1787163 Asbestos28-WP-A 05/12/2025

1787164 Asbestos28-WP-B 05/12/2025

1787165 Asbestos28-WP-C 05/12/2025

1787166 Asbestos29-EJ-A 05/12/2025

1787167 Asbestos29-EJ-B 05/12/2025

1787168 Asbestos29-EJ-C 05/12/2025

1787169 Asbestos30-CT-A 05/12/2025

1787170 Asbestos30-CT-B 05/12/2025

1787171 Asbestos30-CT-C 05/12/2025

1787172 Asbestos31-IC-A 05/12/2025

1787173 Asbestos31-IC-B 05/12/2025

1787174 Asbestos31-IC-C 05/12/2025

1787175 Asbestos32-EC-A 05/12/2025

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this

1787176 Asbestos32-EC-B 05/12/2025

1787177 Asbestos32-EC-C 05/12/2025

1787178 Asbestos33-IC-A 05/12/2025

1787179 Asbestos33-IC-B 05/12/2025

1787180 Asbestos33-IC-C 05/12/2025

1787181 Asbestos34-PW-A 05/12/2025

1787182 Asbestos34-PW-B 05/12/2025

1787183 Asbestos34-PW-C 05/12/2025

1787184 Asbestos35-PW-A 05/12/2025

1787185 Asbestos35-PW-B 05/12/2025

1787186 Asbestos35-PW-C 05/12/2025

1787187 Asbestos36-PW-A 05/12/2025

1787188 Asbestos36-PW-B 05/12/2025

1787189 Asbestos36-PW-C 05/12/2025

1787190 Asbestos37-PF-A 05/12/2025

1787191 Asbestos37-PF-B 05/12/2025

1787192 Asbestos37-PF-C 05/12/2025

1787193 Asbestos38-PF-A 05/12/2025

1787194 Asbestos38-PF-B 05/12/2025

1787195 Asbestos38-PF-C 05/12/2025

1787196 Asbestos39-PF-A 05/12/2025

1787197 Asbestos39-PF-B 05/12/2025

1787198 Asbestos39-PF-C 05/12/2025

1787199 Asbestos40-WG-A 05/12/2025

1787200 Asbestos40-WG-B 05/12/2025

1787201 Asbestos40-WG-C 05/12/2025

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this

1787202 Asbestos41-IC-A 05/12/2025

1787203 Asbestos41-IC-B 05/12/2025

1787204 Asbestos41-IC-C 05/12/2025

1787205 Asbestos42-EC-A 05/12/2025

1787206 Asbestos42-EC-B 05/12/2025

1787207 Asbestos42-EC-C 05/12/2025

1787208 Asbestos43-RM-A 05/12/2025

1787209 Asbestos43-RM-B 05/12/2025

1787210 Asbestos43-RM-C 05/12/2025

1787211 Asbestos44-RM-A 05/12/2025

1787212 Asbestos44-RM-B 05/12/2025

1787213 Asbestos44-RM-C 05/12/2025

1787214 Asbestos45-CT-A 05/12/2025

1787215 Asbestos45-CT-B 05/12/2025

1787216 Asbestos45-CT-C 05/12/2025

1787217 Asbestos46-TP-A 05/12/2025

1787218 Asbestos46-TP-B 05/12/2025

1787219 Asbestos46-TP-C 05/12/2025

1787220 Asbestos47-EC-A 05/12/2025

1787221 Asbestos47-EC-B 05/12/2025

1787222 Asbestos47-EC-C 05/12/2025

Reviewed by:

Summary

Sample Layer MasticMethod

PLM 149 17

Point Count 3

Dawson Bradley

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this

This report is intended for use solely by the individual or entity to which it is addressed. This report may not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this

Certificate of Analysis

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

Mott Parking Structure

ETL Job :

Client Project :

278637

N/A

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

(734) 955-6600, Fax: (734) 955-6604

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

05/06/2025

05/07/2025

Date Collected :

Date Received :

PLM None Detected 1787082

1-CC-A

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787083

1-CC-B

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787084

1-CC-C

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787085

2-CC-A

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787086

2-CC-B

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787087

2-CC-C

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any

PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

Mott Parking Structure

ETL Job :

Client Project :

278637

N/A

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

(734) 955-6600, Fax: (734) 955-6604

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

05/06/2025

05/07/2025

Date Collected :

Date Received :

PLM None Detected 1787088

3-CC-A

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787089

3-CC-B

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787090

3-CC-C

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787091

4-CC-A

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787092

4-CC-B

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787093

4-CC-C

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any

PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

Mott Parking Structure

ETL Job :

Client Project :

278637

N/A

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

(734) 955-6600, Fax: (734) 955-6604

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

05/06/2025

05/07/2025

Date Collected :

Date Received :

PLM None Detected 1787094

5-CC-A

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787095

5-CC-B

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787096

5-CC-C

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787097

6-CC-A

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787098

6-CC-B

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787099

6-CC-C

PLM 100% OtherGrayConcrete

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any

PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

Mott Parking Structure

ETL Job :

Client Project :

278637

N/A

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

(734) 955-6600, Fax: (734) 955-6604

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

05/06/2025

05/07/2025

Date Collected :

Date Received :

PLM None Detected 1787100

7-EJ-A

PLM 99% OtherPLM 1% CelluloseGrayExpansion Joint

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787101

7-EJ-B

PLM 99% OtherPLM 1% CelluloseGrayExpansion Joint

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787102

7-EJ-C

PLM 99% OtherPLM 1% CelluloseGrayExpansion Joint

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787103

8-EC-A

PLM 99% OtherPLM 1% CelluloseGrayExterior Crown Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787104

8-EC-B

PLM 99% OtherPLM 1% CelluloseGrayExterior Crown Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

PLM None Detected 1787105

8-EC-C

PLM 99% OtherPLM 1% CelluloseGrayExterior Crown Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Teagan Murphy

Date Analyzed : 05/12/2025

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any

PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

Mott…

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