B08_Attachment_2_SLBE_318729_-_Project_Manual_Part_2_(reduced).pdf

SLEEPING BEAR DUNES NATIONAL LAKESHORE

COMPREHENSIVE FACILITY REHABILITATION

ON MANITOU ISLANDS

SLBE 318729

FINAL

CONSTRUCTION DOCUMENTS

PROJECT MANUAL

NATIONAL PARK SERVICE

DENVER SERVICE CENTER

MAY 2024

ST

AT E OF MICH IGAN

L ICENS ED PROF ES S IONAL ENG

I N

EE

R

ZACHARY

MORRIS

License No.

6201310992

Michael Ostendorf

6201313818

5/10/2024 5/10/2024

Appendices

A. Asbestos Inspection, Lead Paint Testing, and PCB Bulk Product Testing Report (June 2023)

B. Asbestos Inspection, Lead Paint Testing, and PCB Bulk Product Testing Report (October 2023)

C. Limited Site Investigation

D. Manitou Island Rehabilitation – Test Pits – Subsurface Exploration Report

E. Manitou Island Rehabilitation – Chicago Road – Geotechnical Engineering Report

F. Superintendent’s Compendium

G. Existing Dock Drawings

Appendix A

Asbestos Inspection, Lead Paint Testing, and PCB Bulk

Product Testing Report (June 2023)

Facilities | Environmental | Geotechnical | Materials

Asbestos Inspection, Lead Paint Testing, and PCB Bulk Product Testing Report Project: Comprehensive Facility Rehabilitation on

Manitou Islands

North and South Manitou Islands

Glen Arbor Township, Michigan

June 14, 2023 | Project Number: N6237175

Prepared for:

VHB Inc.

351 McLaws Circle, Suite 3 Williamsburg, Virginia 23185-5797

12460 Plaza Drive Cleveland, Ohio 44130

P (216) 459-8378 F (216) 459-8954

Terracon.com

Facilities | Environmental | Geotechnical | Materials

June 14, 2023

VHB Inc.

351 McLaws Circle, Suite 3 Williamsburg, Virginia 23185-5797

Attn: Mr. Vikrant Desai P: (757) 279-2832 E: vdesai@vhb.com

Re: Asbestos Inspection, Lead Paint Testing, and PCB Bulk Product Testing Report Project: Comprehensive Facility Rehabilitation on Manitou Islands North and South Manitou Islands Glen Arbor Township, Michigan Terracon Project No. N6237175

Dear Mr. Desai:

Terracon Consultants, Inc. (Terracon) is pleased to submit the attached report for the above-referenced project to VHB Inc. (Client). The purpose of this report is to present the results of an asbestos inspection, lead paint testing, and PCB bulk product testing scope of services which was conducted at the site on May 15, 16, and 17, 2023 prior to renovation activities regarding a rehabilitation project. The scope of services was limited to the planned rehabilitation project locations.

As a result of the completed scope of services, asbestos-containing materials, lead-containing paint, and PCB-containing bulk product materials were identified. Please see the attached report for further detail. The findings, results, recommendations, and conclusions presented in this report are based on conditions that existed at the time of the site visit.

Terracon appreciates the opportunity to provide this service to VHB, Inc. If you have any questions regarding this report, please contact the undersigned at (216) 459-8378.

Sincerely, Terracon Consultants, Inc.

Prepared By: Reviewed By:

Catherine Baney Joseph A. Tussey Department Manager Principal

Table Of Contents

INTRODUCTION

1.1 Asbestos Inspection

1.2 Lead PaintTesting

1.3 Polychlorinated Biphenyl (PCB) Bulk Product Testing

1.4 Reliance

PROJECT DESCRIPTION

Asbestos Inspection

3.1 Asbestos Visual Assessment

3.2 Asbestos Physical Assessment

3.3 Asbestos Sample Collection

3.4 Asbestos Sample Analysis

Lead Paint Testing

4.1 Lead Paint Visual Assessment

4.2 Lead Paint Physical Assessment

4.3 Lead Paint Sample Collection

4.4 Lead Paint Sample Analysis

PCB Bulk Product Testing

5.1 PCB Bulk Visual Assessment

5.2 PCB Bulk Sample Collection

5.3 PCB Bulk Sample Analysis

REGULATORY OVERVIEW

6.1 Asbestos Regulatory Overview

6.2 Lead Regulatory Overview

6.3 PCB Regulatory Overview

FINDINGS AND RECOMMENDATIONS

7.1 Asbestos Inspection Results

7.2 Lead Paint Testing Results

7.3 PCB Bulk Product Testing Results

7.4 Appendices

LIMITATIONS/GENERAL COMMENTS

APPENDIX A MATERIALS IDENTIFIED TO CONTAIN GREATER THAN 1% ASBESTOS

MATERIALS IDENTIFIED TO CONTAIN 1% ASBESTOS OR LESS

APPENDIX B B-1 –ASBESTOS INSPECTION SAMPLE & RESULTS SUMMARY

B-2 –PAINT SAMPLE & RESULTS SUMMARY

B-3 - PCB BULK PRODUCT SAMPLE & RESULTS SUMMARY

APPENDIX C C-1 – ASBESTOS ANALYTICAL LABORATORY REPORT & CHAIN-OF-CUSTODY

C-2 – LEAD PAINT ANALYTICAL LABORATORY REPORT & CHAIN-OF-CUSTODY

C-3 – PCB BULK PRODUCT ANALYTICAL LABORATORY REPORT & CHAIN-OF-CUSTODY

APPENDIX D LICENSES AND CERTIFICATIONS

APPENDIX E PHOTOGRAPHS

Facilities | Environmental | Geotechnical |Materials

ASBESTOS INSPECTION, LEAD PAINT TESTING,

AND PCB BULK PRODUCT TESTING REPORT

Project: Comprehensive Facility Rehabilitation on Manitou Islands North and South Manitou Islands Glen Arbor Township, Michigan

Terracon Project No. N6237175 June 14, 2023

INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted an asbestos inspection, lead paint testing, and PCB bulk product testing scope of services regarding the comprehensive facility rehibition on Manitou Islands project. The rehabilitation (i.e., renovation) project involves the exterior of 13 buildings located on South Manitou Island in Glen Arbor Township, Michigan and the exterior of nine (9) buildings on North Manitou Island in Glen Arbor Township, Michigan. The project also includes the interior (of two (2) of the nine (9) buildings located on North Manitou Island. The scope of services was conducted at the project site on May 15, 16, and 17, 2023, by Michigan Occupational Safety and Health Administration (MIOSHA) asbestos inspector Catherine Baney (#A54513).

We understand that our scope of services was requested due to the planned renovations of the specified exterior and interior areas of the selected buildings (noted above, and below in Section 2.0).

Asbestos inspections are required prior to renovation or demolition activities to satisfy requirements of the United States Environmental Protection Agency (USEPA) 40 Code of Federal Regulations (CFR) Part 61, Subpart M, the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation and state of Michigan asbestos regulations. For lead paint, contractors need to take appropriate precautions to comply with the Occupational Safety and Health Administration (OSHA) lead in construction regulation (29 CFR 1962.62) when disturbing paints with lead. For PCB bulk product materials, the Code of Federal Regulations (CFR) at 40 CFR 761, the Toxic Substances Control Act (TSCA) is applicable for material handling and disposal.

Please note that the scope of services was specific and limited to the project-specified building exteriors and included the interior of two (2) buildings, which Terracon understood are being planned for rehabilitation activities (i.e., renovation).

1.1 Asbestos Inspection

Homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented with respect to accessible building components pertaining to the rehabilitation project scope. Although a reasonable effort was made to identify readily accessible suspect materials, additional suspect but un-sampled materials could be located in walls, in voids, or in other concealed areas. Additional suspect materials may also exist in areas of buildings which were outside the scope of this inspection (e.g., areas not included in the rehabilitation scope). Bulk samples from suspect ACM within rehabilitation project areas were collected in general accordance with the sampling protocols outlined in USEPA 40 Code of Federal Regulations (CFR) Part 763, Subpart E – 763.86, known as the Asbestos Hazard Emergency Response Act (AHERA). Samples were delivered to an accredited laboratory for polarized light microscopy (PLM) analysis to determine asbestos content. When

Asbestos Inspection, PCB Bulk Product Testing, and Lead Paint Testing Report Project: Comprehensive Facility Rehabilitation on Manitou Islands | Glen Arbor Township, MI June 14, 2023 | Terracon Report No. N6237175

Facilities | Environmental | Geotechnical | Materials 2 applicable, the additional point count method (400 points) was utilized to accurately quantify samples identified by PLM analysis to contain low percentages of asbestos.

1.2 Lead Paint Testing

Paint chip/scraping samples were collected from accessible, representative, dominant-type painted components from accessible areas of the subject structures and locations included in the rehabilitation project. Sampling locations were chosen randomly to be representative of the homogeneous painted project areas. Although reasonable effort was made to inspect the substrate of the unique painting combinations, additional suspect but un-tested paint could be located at the site due to undetected changes in the paints or variations in lead concentrations in unique paint combinations, and in areas not included in the rehabilitation project scope. Collected paint chip/scraping samples were delivered to an accredited laboratory for lead content analysis by flame atomic absorption spectrophotometry

(FAAS).

1.3 Polychlorinated Biphenyl (PCB) Bulk Product Testing

The sampling scope of work was limited to readily accessible caulking, glazing and epoxy-type materials, if present, throughout the rehabilitation areas. Additional suspect materials may also exist in areas of buildings which were outside the scope of this inspection (e.g., areas not included in the rehabilitation scope). Sample collection was performed using a clean utility knife to remove caulking, glazing and epoxy-type materials from designated surfaces. Collected material samples were placed in sealable containers, labeled with unique sample numbers, and submitted under chain of custody for analysis by U.S. Environmental Protection Agency (USEPA) method SW8082.

1.4 Reliance

This report is for the exclusive use of VHB (Client) for the project being discussed. Reliance by any other party on this report is prohibited without the written authorization of Terracon and the Client.

Reliance on this report by the Client and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report, and the Agreement between Terracon and the Client. The limitation of liability defined in the Agreement is the aggregate limit of Terracon’s liability to the Client.

PROJECT DESCRIPTION

The rehabilitation project involves the following 11 structures and exterior/interior areas as noted located on North Manitou Island:

Hans Halseth House QTRS (exterior rehabilitation only) o Single-story structure on a concrete block foundation, with a pitched wooden shingled roof and painted exterior wood siding.

Additionally, an adjacent shed is on concrete pad with a sloped wooden shingled roof and painted exterior wood siding.

Howard Foote Cottage (exterior rehabilitation only)

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Facilities | Environmental | Geotechnical | Materials 3 o Single-story structure on a concrete block foundation, with a pitched asphalt shingled roof and painted exterior wood siding.

Newhall Cottage (exterior rehabilitation only) o Single-story structure on a concrete block foundation, with a pitched asphalt shingled roof and painted exterior wood siding.

Additionally, an adjacent shed structure constructed on concrete slab with a pitched asphalt shingled roof and painted exterior wood siding.

Riggs Cottage (exterior rehabilitation only) o Single-story structure on a concrete block foundation, with a pitched asphalt shingled roof, and painted exterior wood siding.

Riggs Generator Building (exterior rehabilitation only) o Single-story structure on a concrete block foundation, with a pitched asphalt shingled roof and painted exterior wood siding.

Riggs Shed (exterior rehabilitation only) o Single-story structure on a concrete block foundation, with a wood-shingled roof and wood siding.

Trude Cottage (interior and exterior rehabilitation) o Single-story structure on a concrete block foundation, with a pitched asphalt shingled roof and painted exterior wood siding. The interior is finished with wood panel walls and wood floors. A water heating tank was observed with no heating or cooling systems.

USLSS Dwelling QTRS (exterior rehabilitation only) o Two-story structure with full basement on a concrete floor with masonry foundation walls, a pitched wooden shingled roof, and painted exteriors.

USLSS Lifeboat Station (exterior rehabilitation only) o Two-story structure constructed on concrete blocks, a pitched wooden shingled roof, and painted exteriors.

Village Barn (interior and exterior rehabilitation) o One-story split-level structure, concrete floors, masonry foundation walls, wood interior and exterior finishes with a sloped metal roof. No observed heating or cooling systems.

Generator Building (exterior rehabilitation only) o Single-story concrete block and masonry stone building constructed slab-on-grade with a sloped newly installed asphalt shingled roof.

The rehabilitation project involves the exterior of the following 13 buildings on South Manitou Island:

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Facilities | Environmental | Geotechnical | Materials 4

Beck Theodore Farmhouse (exterior rehabilitation only) o Two-story structure on a concrete block foundation, pitched asphalt shingled roof and painted exteriors.

Beck Theodore Shed (exterior rehabilitation only) o Single-story wooden shed structure with a pitched asphalt shingled roof and painted exteriors.

Benth Johnson/Kelderhouse QTRS (exterior rehabilitation only) o Two-story slab-on-grade structure with a rear porch, pitched wood shingled roof, and painted exteriors.

Hutzler, George C & Mary Ann House (exterior rehabilitation only) o Two-story slab-on-grade structure with a rear porch, pitched wood shingled roof, and painted exteriors.

Hutzler, George C & Mary Ann Barn (exterior rehabilitation only) o One-story slab-on-grade structure with wood exteriors not painted.

Hutzler, George C & Mary Shed (exterior rehabilitation only) o One-story slab-on-grade structure with wood exteriors not painted.

Hutzler, George I & Selma QTRS (exterior rehabilitation only) o Two-story slab-on-grade structure with a rear porch, pitched wood shingled roof, and painted exteriors.

Hutzler, George J & Margaretha Pig Barn (exterior rehabilitation only) o Two-story slab-on-grade structure with a rear porch, pitched asphalt shingled roof, and painted exteriors. The adjacent barn is a wood shingled roof and wood siding (not painted).

Johnsom, Benth House QTRS (exterior rehabilitation only) o Single-story slab-on-grade structure with a front porch, pitched wooden shingled roof, and painted exteriors.

Keeler, Ory & Betty House QTRS (exterior rehabilitation only) o Two-story slab on grade structure, with a pitched wooden shingled roof with painted exterior.

Maintenance Shop (exterior rehabilitation only) o One-story slab on grade structure, with a pitched asphalt shingled roof and painted exteriors.

Tobin, John & Lottie House QTRS (exterior rehabilitation only)

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Facilities | Environmental | Geotechnical | Materials 5 o Two-story slab-on-grade with a front porch, pitched wooden shingled roof and painted exteriors.

USLSS Dwellings QTRS (exterior rehabilitation only) o Two-story with an attic and full basement, and a wooden shingled roof and painted exteriors.

ASBESTOS INSPECTION FIELD ACTIVITIES

The project-specific asbestos inspection was conducted at the site on May 15, 16, and 17, 2023 by MIOSHA-certified Asbestos Inspector Catherine E. Baney (#A54513). A copy of her asbestos inspector credential is attached in Appendix D. The asbestos inspection was conducted in general accordance with the sample collection protocols established in USEPA 40 CFR Part 763, Subpart E, Section 763.86, AHERA. A summary of the asbestos inspection activities is provided below.

3.1 Asbestos Visual Assessment

Inspection activities began with visual observations of accessible exterior areas of the 13 project buildings on South Manitou Island, and the nine (9) project buildings on North Manitou Island which included the exterior areas of all nine (9) and also the interior areas of two (2) of the nine (9) project buildings on North Manitou Island to identify homogeneous areas of suspect ACMs. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application. Building materials identified as concrete, glass, wood, masonry, metal, or rubber were not considered suspect ACM.

3.2 Asbestos Physical Assessment

A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.3 Asbestos Sample Collection

Based on the results of the visual observation, bulk samples from suspect ACM were collected in general accordance with USEPA AHERA sampling protocols. Samples of suspect materials were collected from randomly selected locations in each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. The selection of sample locations and frequency of sampling was based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content.

With respect to the project-specific scope, Terracon collected a total of 93 bulk samples from 31 homogeneous areas of suspect ACM. A summary table of samples collected with analytical results is included in Appendix B.

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Facilities | Environmental | Geotechnical | Materials 6

3.4 Asbestos Sample Analysis

Bulk samples were submitted under chain-of-custody to International Asbestos Testing Laboratories (IATL) of Mount Laurel, New Jersey for analysis by PLM with dispersion staining techniques per USEPA Method for Determination of Asbestos in Bulk Building Materials (600/R-93/116). The percentage of asbestos, where applicable, was determined by microscopic visual estimation using PLM analysis. The additional point count method (400 points) was utilized to accurately quantify samples identified by PLM analysis to contain low percentages of asbestos. IATL is accredited for PLM analysis under the National Voluntary Laboratory Accreditation Program (NVLAP), accreditation number 101165-0. The laboratory analytical report and sample chain-of-custody are included in Appendix C.

LEAD PAINT TESTING ACTIVITIES

Terracon representative Catherine E. Baney collected paint chip/scraping samples at the project site on May 15, 16, and 17, 2023. A summary of the lead paint testing activities is provided below.

4.1 Lead Paint Visual Assessment

Terracon’s lead paint activities began with visual observations of accessible areas of the project specific structures and areas to identify unique combinations of dominant-type paints. A unique combination of paint consists of paint that is applied to a building material and has similar color, substrate, and component.

Paint that was applied to equipment, furniture, or other movable objects was not included in the lead paint testing scope.

4.2 Lead Paint Physical Assessment

A physical assessment of each unique combination of paint was conducted to assess the condition of the paint. Paint was visually assessed and assigned a condition of intact (good), fair, or poor (top-layer failure, multi-layer failure, and substrate failure).

4.3 Lead Paint Sample Collection

Based on the results of the visual assessment, randomly selected locations of unique dominant-type combinations of paint were sampled. Painted surfaces comprising equipment, furniture, or other movable objects were not sampled. Paint chip/scraping samples were collected using a clean straight-edge razor to remove paint from accessible, representative, dominant-type painted components for lead-in paint analysis.

With respect to the project-specific scope, Terracon collected a total of 36 paint chip/scraping samples from dominant-type paint coatings at various random project locations. A summary table of samples collected with analytical results is included in Appendix B.

4.4 Lead Paint Sample Analysis

Paint chip/scraping samples were submitted under chain-of-custody to IATL of Mount Laurel, New Jersey for analysis by FAAS per USEPA Method SW 846-7000B (ASTM D3335-85A). The laboratory reports the analytical result for each sample as a percent of lead by weight (% by weight) and lead

June 14, 2023 | Terracon Report No. N6237175

Facilities | Environmental | Geotechnical | Materials 7 parts per million (ppm). IATL is accredited for lead analysis by the EPA National Lead Laboratory Accreditation Program (NLLAP), and the American Industrial Hygiene Association – Laboratory Accreditation Programs, LLC (AIHA-LAP, LLC), accreditation number 100188. The laboratory analytical report and sample cchain of custodyare included in Appendix C.

PCB BULK PRODUCT TESTING ACTIVITIES

Terracon representative Catherine E. Baney collected PCB bulk product samples from the project site on May 15, 16, and 17, 2023. A summary of the PCB bulk testing activities is provided below.

5.1 PCB Bulk Visual Assessment

Terracon identified accessible caulking, glazing, and epoxy-type materials (suspect to contain PCBs) where present relative to the project areas for sampling and laboratory analysis.

5.2 PCB Bulk Sample Collection

Sample collection was performed using a clean utility knife to remove caulking, glazing and epoxy-type materials from designated surfaces. Collected material samples were placed in sealable containers, labeled with unique sample numbers, and submitted under chain of custody to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey for analysis by U.S. Environmental Protection Agency (USEPA) method SW8082. EMSL is a certified laboratory under the National Environmental Laboratory Accreditation Program (NELAP).

With respect to the project-specific scope, Terracon collected a total of 22 bulk product samples (i.e., glazing and caulking materials) for analysis of PCB content. A summary table of samples collected with analytical results is included in Appendix B.

5.3 PCB Bulk Sample Analysis

Collected material samples were placed in sealable containers, labeled with unique sample numbers, and submitted under chain of custody to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey for analysis by U.S. Environmental Protection Agency (USEPA) method SW8082. EMSL is a certified laboratory under the National Environmental Laboratory Accreditation Program (NELAP). The laboratory analytical report and sample chain of custody are included in Appendix C.

REGULATORY OVERVIEW

6.1 Asbestos Regulatory Overview

The federal asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. All friable ACM is considered RACM.

The asbestos NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or Category II non-friable ACM. RACM includes all friable ACM, along with Category I and Category II

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Facilities | Environmental | Geotechnical | Materials 8 non-friable ACM that has become friable, will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder during renovation or demolition activity. Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. Category II non-friable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

In Michigan, the federal asbestos NESHAP regulation has been delegated to the Michigan Department of Environment, Great Lakes, and Energy (EGLE). Notifications for removal of certain types of ACM (>160 square feet and/or >260 linear feet in quantities) must be submitted to EGLE at least 10 business days prior to work commencement and prior to building demolitions. The EGLE should be contacted for discussion regarding specific instructions on completion of these forms. The EGLE contact information is as follows: NESHAP Asbestos Program, EGLE Air Quality Division, P.O. Box 30260, Lansing, Michigan 48909-7760; telephone (517) 284-6777.

In Michigan, asbestos regulations are also enforced by LEO/MIOSHA. The LEO/MIOSHA Asbestos Program is responsible for the enforcement of most Michigan asbestos regulations including the Asbestos Abatement Contractors Licensing Act (Act 135, P.A. 1986, as amended), the Asbestos Workers Accreditation Act (Act 440, P.A. 1988, as amended), the Michigan Occupational Safety and Health Act (Act 154, P.A. 1974, as amended), and for meeting the state of Michigan’s mandated responsibilities under the EPA AHERA regulation. The LEO/MIOSHA Asbestos Program has the following six major areas of responsibility: 1) approval of asbestos training courses, 2) accreditation of workers,

3) licensing of asbestos abatement contractors, 4) processing of asbestos abatement project notifications (requires project notification at least 10 days prior to any non-emergency abatement project exceeding 10 linear feet or 15 square feet or both of friable ACM), 5) compliance investigations, and 6) EPA AHERA management plan review. The LEO/MIOSHA Asbestos Program contact information is as follows: State of Michigan, MIOSHA-CSHD-Asbestos Program, P.O. Box 30671, Lansing, Michigan 48909; telephone: (517) 284-7680; email: asbestos@michigan.gov.

The United States Occupational Safety and Health Administration (USOSHA) asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The USOSHA standard requires that employee exposure to airborne asbestos must not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight-hour time-weighted average (TWA) and not exceed 1.0 fibers per cubic centimeter of air (1.0 f/cc) over a 30-minute period known as an excursion limit (EL). The TWA and EL are known as USOSHA’s asbestos permissible exposure limits (PELs). The USOSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

6.2 Lead Regulatory Overview

The U.S. Consumer Safety Product Commission (CSPC) sets the maximum level of lead allowed in consumer paints at 0.009% by weight or 90 ppm. State regulations, federal EPA regulations, and the US Department of Housing and Urban Development (HUD) guidelines define “lead-based paint” (LBP) as a paint or other surface coating which contains a lead concentration equal to or exceeding 0.5% by weight or 5,000 ppm (5,000 mg/kg); and any surface like a surface tested that has a lead concentration equal to or exceeding that level.

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By contrast, the mission of OSHA with respect to lead-containing paint is to protect workers during construction activities that could result in hazardous exposures. OSHA states that construction work (including renovation, maintenance, and demolition) performed on structures coated with paint that contains lead at concentrations lower than HUD and CPSC standards can still result in exposures that exceed the regulatory limits. For this reason, OSHA has not defined a lower threshold lead concentration for lead-containing paint, but states that paint with any measurable level of lead may pose a significant potential for overexposure.

OSHA regulation 29 CFR 1926.62 (Lead Exposure in Construction) specifies that employers are responsible for ensuring that their employees are not exposed to airborne lead concentrations exceeding the OSHA permissible exposure limit (PEL) of fifty micrograms per cubic meter or air (50 µg/m3) averaged over an 8-hour period, and to take appropriate precautions when exposures reach an Action Level of 30 µg/m3 averaged over an 8-hour period. The standard was written to require initial exposure monitoring or the use of historical or objective data to ensure that employee exposures do not exceed the Action Level. If certain construction activities are being performed (e.g., torch cutting, manual demolition, sanding, grinding, etc.), employers must assume their employees are overexposed to lead and must provide personal protective equipment – including respiratory protection – until an exposure assessment proves otherwise.

The presence of lead in demolition debris from non-residential buildings has the potential to impose limitations on where and how the debris may be disposed. The Resource Conservation and Recovery Act (RCRA) requires each waste generator to determine if the wastes are hazardous. This can be determined either through generator knowledge or by testing. Toxicity Characteristic Leaching Procedure (TCLP) testing is the preferred method for determining if wastes are hazardous.

6.3 PCB Regulatory Overview

Current PCB regulations can be found in the Code of Federal Regulations (CFR) at 40 CFR 761, the Toxic Substances Control Act (TSCA). Under TSCA, PCB-containing caulk/glazing is considered PCB bulk product waste if the concentration of PCBs in the caulk/glazing is greater than or equal to (>) 50 ppm (40 CFR § 761.3). Caulk with PCB concentrations > 50 ppm must be disposed of as PCB bulk product waste according to 40 CFR § 761.62.

PCB-containing caulk/glazing is considered PCB bulk product waste if the concentration of PCBs in the caulk is greater than or equal to ( ) 50 ppm (see, 40 CFR § 761.3). PCB bulk product waste includes waste derived from manufactured products containing PCBs in a non-liquid state where the concentration at the time of designation for disposal is > 50 ppm PCBs (see, 40 CFR §§ 761.3 & 761.62). Caulk/glazing with PCB concentrations > 50 ppm is not authorized for use and must be disposed of as PCB bulk product waste according to 40 CFR § 761.62. Additionally, the definition of PCB bulk product waste includes building materials that have been coated or serviced with PCBs. That is, masonry, wood, metals, and other building materials that are purposely coated with PCB-containing caulk/glazing are regulated as PCB bulk product waste if the caulk coating the building materials contains PCBs at concentrations > 50 ppm. If your abatement plan states that you intend to dispose of the PCB caulk/glazing and any contaminated building materials together and the PCB caulk/glazing becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB bulk product waste. EPA realizes that the PCB caulk/glazing may need to be separated during removal from adjacent contaminated building materials due to the presence of other hazardous materials or may accidentally be separated during the removal process.

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If the PCB caulk/glazing has been removed from the adjacent building materials and disposed of separately, any contaminated adjacent building materials are considered PCB remediation waste. Also, if PCBs have contaminated the adjacent soil, the soil is considered PCB remediation waste. PCB remediation waste is subject to the cleanup and disposal requirements according to 40 CFR § 761.61.

FINDINGS AND RECOMMENDATIONS

Please note that this scope of services was specific and limited to the exterior areas of all buildings identified by the Client for inclusion in the rehabilitation project. In addition to all exterior areas of the project specific buildings, the interior of the Trude Cottage and the Village Barn located on North Manitou Island are also included in the rehabilitation project, therefore these two (2) interior areas were also included in our scope of services.

7.1 Asbestos Inspection Results

One (1) accessible material was confirmed to contain greater than 1% asbestos by PLM and point count (400 points) analysis.

The gray window glazing on the exterior windows of the Riggs Cottage were determined to contain 1.4% chrysotile by point count asbestos. Approximately 12 square feet of glazing located on 11 windows: a Category II non-friable asbestos material in fair condition.

Two (2) accessible materials were confirmed to contain less than 1% asbestos by PLM and point count (400 points) analysis.

The gray window glazing on the exterior window of the Hutzler, George J and Margaretha Pig Barn building was determined to contain 0.5% chrysotile by point count analysis.

Approximately 11 square feet of glazing on 10 windows, not regulated by NESHAP since contains 1% or less asbestos.

The gray window glaze on the exterior window of the USLSS Dwelling QTRS building was determined to contain 0.75% chrysotile by point count analysis. Approximately 48 square feet of glazing on 36 windows, not regulated by NESHAP since contains 1% or less asbestos.

If the identified ACM containing greater than 1% asbestos will be impacted by rehabilitation activities (i.e., renovation), it would need to be properly removed and disposed prior to renovation activities by a state-licensed asbestos abatement contractor in accordance with applicable federal, state, and local asbestos regulations. If the material will not be impacted by renovation activities, it is recommended to manage the material in place in good condition under an asbestos operations and maintenance (O&M) plan.

Materials containing 1% asbestos or less are not regulated by federal or state EPA NESHAP regulations; however, such materials are regulated under the OSHA Asbestos Construction Standard regulation (29 CFR 1926.1101). If these materials will be impacted by rehabilitation activities (i.e., renovation), it is recommended that they also be properly removed and disposed prior to renovation activities by a state-licensed asbestos abatement contractor in accordance with the OSHA asbestos regulation. If the materials will not be impacted by renovation activities, it is recommended to manage these materials in place in good condition under an asbestos operations and maintenance (O&M) plan.

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Facilities | Environmental | Geotechnical | Materials 11

If additional suspect materials (other than those sampled during this project-specific inspection) are revealed/encountered during renovation activities, those material(s) must be assumed asbestos-containing and work should cease until the material(s) can be sampled by a state-certified asbestos inspector and analytical results refute the positive assumption.

7.2 Lead Paint Testing Results

Analytical results indicated that lead was detected above the analytical method’s reporting limit in 28 of the 36 samples collected and analyzed. See the table in Appendix B for a listing of painted building components tested and their analytical results. The results apply to all building components of the same testing combination (i.e., building, building component, substrate, and paint color).

Although a reasonable effort was made to inspect the substrate of the unique painting combinations, additional suspect but un-tested paint(s) could be present due to undetected changes in the paints or variations in lead concentrations in unique paint combinations.

Please note that un-tested paint(s), if any, should be assumed to contain lead above the analytical method’s reporting limit unless sampled and laboratory analysis can refute the positive assumption.

Additionally, please note the lead sampling scope of services was not a surface-by-surface investigation for compliance with EPA lead renovation repair and painting (RRP), or US Housing and Urban Development (HUD) regulations or guidelines. The aforementioned regulations pertain to residential housing and child-occupied (<6 years old) facilities.

7.3 PCB Bulk Product Testing Results

Three (3) of the 22 bulk product samples (i.e., glazing and caulking materials) collected during this project, were report by the laboratory to contain PCBs (utilizing EPA Method SW8082) at concentrations above the analytical method’s reporting limit. These correspond to the following materials:

Exterior gray window glazing at the Hutzler, George C & Mary Ann House on the South Manitou Island was determined to contain 0.52 mg/kg total PCB.

Exterior gray window caulk at the Hutzler, George C & Mary Ann House on the South Manitou Island was determined to contain 0.27 mg/kg total PCB.

Exterior gray window glazing at the USLSS Dwelling QTRS was determined to contain 0.35 mg/kg total PCB.

However, none of these three (3) bulk materials were detected at concentrations above 50 mg/kg and therefore would not require disposal under TSCA. See Appendix B for a sample and results summary table.

7.4 Appendices

Summary tables with the materials containing are included in Appendix A. Summary tables of asbestos, PCB, and paint samples collected with analytical results are included in Appendices B-1, B- 2, and B-3. The asbestos, lead, and PCB laboratory analytical reports and sampled chain-of-custody forms are included in AppendicesC-1, C-2, and C-3. Licenses and certifications are included in Appendix D. Photographs are included in Appendix E.

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LIMITATIONS/GENERAL COMMENTS

In addition to any limitations noted in the previous sections of this report, Terracon did not perform sampling which jeopardized the safety of the inspector(s) or required demolition or destructive activities such as knocking large holes in walls, the dismantling of equipment, or removing of protective coverings. Reasonable efforts to access suspect materials within known areas of restricted access (e.g., crawl spaces) were made; however, confined spaces or areas that may pose a health or safety risk to Terracon personnel were not sampled. Sampling did not include suspect materials which could not be safely reached with available ladders/man-lifts.

This scope of services was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during our site visit. The information contained in this report is relevant to the date on which this inspection was performed and may not represent conditions later. This report has been prepared on behalf of and exclusively for use by VHB for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding reported quantities and any further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories, or other third parties supplying information that may have been used in the preparation of this report. No warranty, express or implied is made.

APPENDIX A

Project: Comprehensive Facility Rehabilitation on Manitou Island South and North Manitou Islands Glen Arbor Township, Michigan

MATERIALS IDENTIFIED TO CONTAIN GREATER THAN 1% ASBESTOS

(LISTED BY HOMOGENEOUS AREA)

HA Material Description Material Locations % and Type

Asbestos*

EPA NESHAP

Classification Condition Estimated

Quantities**

AG Gray exterior window glazing compound

Exterior windows of Riggs Cottage on North Manitou Island

1.4% chrysotile by Point Count (PC)

Category II Non-Friable Fair

11 windows ~12 square feet

The materials listed in this table have been sampled and determined by laboratory analysis to contain asbestos >1% (or assumed as noted above). When disturbed, various federal, state, and local asbestos regulations apply. Until removal is necessary, these materials should be maintained in good condition, monitored for damage over time, and repaired as necessary by appropriately trained personnel (recommend managing through implementation of an asbestos operations and maintenance [O&M] plan). Removal may be necessary before renovations and in most cases before demolition.

MATERIALS IDENTIFIED TO CONTAIN 1% ASBESTOS OR LESS

(LISTED BY HOMOGENEOUS AREA)

HA Material Description Material Locations % and Type Asbestos* Condition Estimated Quantities**

H Gray exterior window glazing compound

South Manitou Island Hutzler George J, and Margaretha

Pig Barn 0.5% Chrysotile by PC Fair

10 windows ~11 square feet

R Gray Exterior window glazing compound

South Manitou Island USLSS Dwelling QTRS 0.75% chrysotile by PC Fair

36 windows ~48 square feet Materials containing 1% asbestos or less are not regulated by EPA NESHAP; however, the OSHA personal exposure limits (0.1 f/cc of air as an eight-hour time-weighted average or 1.0 f/cc of air over 30 minutes) for asbestos apply when materials containing 1% asbestos or less are disturbed. A table listing the materials that contain 1% asbestos or less is provided above to enable the renovation contractor to make appropriate decisions concerning compliance issues with applicable federal and state OSHA regulations.

See Appendix B for a summary table of samples collected with analytical results. See Appendix C for detailed analytical results and chain of custody.

*% & Type Asbestos = This column contains both the analytical result of the sample with the highest concentration of asbestos detected in the samples that make up the HA and the types of asbestos identified.

**Estimated quantities are based on a cursory field evaluation and actual quantities may vary significantly, especially if asbestos-containing materials are present in hidden and/or inaccessible areas not evaluated as part of this inspection. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding reported quantities and any further investigation or remediation deemed necessary.

APPENDIX B-1

Project: Comprehensive Facility Rehabilitation on Manitou Island South and North Manitou Islands Glen Arbor Township, Michigan

LIMITED ASBESTOS INSPECTION SAMPLE & RESULTS SUMMARY

HA Sample Number Material Description HA Locations Sample

Location Lab Result

(% and Type Asbestos)

SOUTH MANITOU ISLAND PROJECT BUILDINGS

A

A-01

Asphalt Roof Shingles Beck Theodore

Farmhouse (lodge)

Front of house Black shingle – ND None

Detected (ND) Adhesive - ND

A-02 Middle house Black shingle – ND Adhesive - ND

A-03 Back of house Black shingle – ND Adhesive - ND

B

B-04

Asphalt Roof Shingles Beck Theodore Shed

Front of shed Black shingle – ND Adhesive - ND

B-05 Middle shed Black shingle – ND Adhesive - ND

B-06 Back of shed Black shingle – ND Adhesive - ND

C

C-07

Gray door caulk Beck Theodore

Farmhouse (lodge)

Front porch door ND

C-08 Back porch door ND

C-09 Front porch door ND

D

D-10

Gray window glazing compound

Hutzler, George C & Mary Ann

House

Window left of boarded door ND

D-11 Front of house first floor window

ND

D-12 Barn facing first floor window

ND

E

E-13

Gray window caulking compound

Hutzler, George C & Mary Ann

House

Front entrance door ND

E-14 Front entrance door ND

E-15 Rear entrance door ND

F

F-16

Gray window glazing compound

Hutzler, George I & Selma

QTRS, QMIS

Porch entrance window ND

F-17 Bump out window ND

F-18 Kitchen window ND

G

G-19

Gray window caulking compound

Hutzler, George J and

Margaretha Pig Barn

First floor window front entrance

ND

G-20 First floor window rear porch

ND

G-21 First floor single window ND

LIMITED ASBESTOS INSPECTION SAMPLE & RESULTS SUMMARY –

Continued

Facilities | Environmental | Geotechnical | Materials

HA Sample Number Material Description HA Locations Sample

Location Lab Result

(% and Type Asbestos)

H

H-22

Gray window glazing compound

Hutzler, George J and Margaretha

Pig Barn

First floor window front entrance

0.5% chrysotile by Point Count (PC)

H-23 Rear porch left window 0.25% chrysotile by PC

H-24 Rear porch middle window

ND

I

I-25 Gray door – glazing compound on window inserts

Hutzler, George J and

Margaretha Pig Barn

Front entrance door ND

I-26 Front entrance door ND

I-27 Rear entrance door ND

J

J-28

Gray door caulk

Hutzler, George J and

Margaretha Pig Barn

Front entrance door ND

J-29 Front entrance door ND

J-30 Rear entrance door ND

K

K-31

Asphalt exterior siding

Hutzler, George J and

Margaretha Pig Barn

Porch ND

K-32 Porch ND

K-33 Shed ND

L

L-34

Gray window glazing compound

Johnsom,Benth House QTRS, QMIS

Front porch window right ND

L-35 Front porch window left ND

L-36 Bump out window ND

M

M-37

Gray door caulk Johnsom,Benth House QTRS, QMIS

Left front door ND

M-38 Right front door ND

M-39 Left front door ND

N

N-40

Roof shingles Maintenance Shop

Roof ND

N-41 Roof ND

N-42 Roof ND

O

O-43

Gray window caulking compound

Maintenance Shop

Overhead door left ND

O-44 Overhead door middle ND

O-45 Left front window ND

P

P-46

Gray window caulking compound

Tobin, John & Lottie House

QTRS, QMIS

Front porch window ND

P-47 Back porch window ND

P-48 First floor window ND

Q

Q-49

Gray door caulk Tobin, John & Lottie House

QTRS, QMIS

Front door ND

Q-50 Front door ND

Q-51 Front door ND

R R-52 Gray window glazing compound

USLSS

Dwellings

QTRS, SMIS

Window south bump out

ND

Facilities | Environmental | Geotechnical | Materials

HA Sample Number Material Description HA Locations Sample

Location Lab Result

(% and Type Asbestos)

R-53

Window behind radio tower west facing

0.75% Chrysotile by PC

R-54 North porch window ND

NORTH MANITOU ISLAND PROJECT BUILDINGS

AA

AA-55

Gray window glazing compound

Hans Halseth House QRTS

QMIS

First floor porch north window

ND

AA-56

First floor porch south window

ND

AA-57

First floor southeast window

ND

AB

AB-58

Asphalt Roof Shingles Howard Foote Cottage

Roof ND

AB-59 Roof ND

AB-60 Roof ND

AC

AC-61

Gray window glazing compound

Howard Foote Cottage

Window left of porch door ND

AC-62 Window right of porch door ND

AC-63

Window next to boarded window first floor

ND

AD

AD-64

Gray window glazing compound

Newhall Cottage

Front porch window ND

AD-65

Rear of house northeast window

ND

AD-66

Rear of house northwest window

ND

AE

AE-67

Asphalt Roof Shingles Newhall Cottage

Roof ND

AE-68 Roof ND

AE-69 Roof ND

AF

AF-70

Asphalt Roof Shingles Riggs Cottage

Roof ND

AF-71 Roof ND

AF-72 Roof ND

AG

AF-73

Gray window glazing compound Riggs Cottage

Window north of front door 1.4% Chrysotile by PC

AF-74

Window south of front door 1.2% Chrysotile by PC

AF-75

Window south of back door

1.4% Chrysotile by PC

AH

AH-76

Asphalt Roof Shingles Riggs Generator Building

Roof ND

AH-77 Roof ND

AH-78 Roof ND

Facilities | Environmental | Geotechnical | Materials

HA Sample Number Material Description HA Locations Sample

Location Lab Result

(% and Type Asbestos)

AI

AI-79

Gray window glazing compound Trude Cottage

Interior windows ND

AI-80 Interior windows ND

AI-81 Interior windows ND

AJ

AJ-82

Asphalt Roof Shingles Trude Cottage

Roof Shingle – ND Tar - ND

AJ-83 Roof Shingle – ND Tar - ND

AJ-84 Roof Shingle – ND Tar - ND

AK

AK-85

Gray window glazing compound

USLSS Lifeboat Station QTRS

QMIS

Southwest window ND

AK-86 West facing window ND

AK-87 Southeast facing window ND

AL

AL-88

Gray window glazing compound

USLSS Dwelling

QTRS QMIS

East facing porch middle window

ND

AL-89

East facing porch north window

ND

AL-90 West facing south window ND

AM

AM-91

Gray window glazing compound Village Barn

Lower-level window – sliding barn door west side

ND

AM-92

Lower level – window southeast

ND

AM-93

Lower-level window northeast

APPENDIX B-2

Project: Comprehensive Facility Rehabilitation on Manitou Island South and North Manitou Islands

Glen Arbor Township, Michigan Project:

LIMITED PAINT SAMPLE & RESULTS SUMMARY

Sample Number Component Color Substrate Sample Location Condition

Lab Result (% lead and lead in mg/kg)

South Manitou Island Project Buildings

LP-01

Window and building trim

Green Wood Beck Theodore

Farmhouse (lodge) Window trim

Fair 0.038%

LP-02 Exterior siding White Wood

Beck Theodore Farmhouse (lodge)

Building exterior Good 1.5%

15,000

LP-03 Exterior siding White Wood Beck Theodore Shed

Building exterior Good 0.052%

LP-04

Window and building trim

Green Wood Beck Theodore Shed Building corner trim Good 0.099%

LP-05 Porch and steps Blue Wood

Benth Johnson/Kelderhouse

QTRS QMIS

Front porch

Good 3.2% 32,000

LP-06 Trim Green Wood

Benth Johnson/Kelderhouse

QTRS QMIS

First floor window

Good 0.0050%

LP-07 Siding White Wood

Benth Johnson/Kelderhouse

QTRS QMIS

Building exterior

Good 0.0060%

LP-08 Siding White Wood Hutzler, George C &

Mary Ann House Building exterior

Good 0.027%

LP-09 Siding White Wood Hutzler, George I & Selma QTRS, QMIS Building exterior

Good 0.044%

LP-10 Trim Green Wood Hutzler, George I & Selma QTRS, QMIS First floor window

Good 0.11% 1,100

LP-11 Siding White Wood Hutzler, George J & Margaretha Pig Barn

Exterior siding Good 0.48%

4,800

LP-12 Porch and steps Blue Wood

Johnson, Benth House

QTRS QMIS

Front porch

Good <0.00052%

LP-13 Trim Green Wood Johnson, Benth

House QTRS QMIS First floor window

Good 0.0071%

LP-14 Siding White Wood Johnson, Benth

House QTRS QMIS Building Exterior

Good 1.0% 10,000

Sample Number Component Color Substrate Sample Location Condition

Lab Result (% lead and lead in mg/kg)

South Manitou Island Project Buildings

LP-15 Trim Green Wood Keeler, Ory & Betty House QTRS, QMIS Frist floor window

Good <0.0071% <71

LP-16 Siding White Wood Keeler, Ory & Betty House QTRS, QMIS Building exterior

Good 0.35%

LP-17 Siding Beige Wood Maintenance Shop Good <0.0055% <55

LP-18 Trim Green Wood Tobin, John & Lottie House QTRS QMIS First floor window

Good <0.0046% <46

LP-19 Siding Yellow Wood Tobin, John & Lottie House QTRS QMIS Building exterior

Good 6.1% 61,000

LP-20 Wall White…