FR2019-D3 CheboyganPresqueIsle Demo List - ACM Reports.pdf

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Attached to
751/19361. AGY Various Counties - Demo and Asbestos Abatement
Solicitation number
RFQ-171-190000000546-3
Issued by
Presque Isle County, Michigan

About this file

This document is an Asbestos Containing Material (ACM) and Hazardous Materials Inspection Report prepared by Red Cedar Consulting for the Michigan Department of Natural Resources (MDNR), focusing on the Kowalski Cabin located in Presque Isle County. The inspection was conducted on September 26, 2018, to comply with United States Environmental Protection Agency (USEPA) requirements for demolition and renovation under the National Emissions Standards for Hazardous Air Pollutants (NESHAP) and Occupational Safety and Health Administration (OSHA) Asbestos Standards for Construction. The inspection involved a comprehensive visual assessment and sampling of the cabin and outhouse, with eighteen samples collected and analyzed for potential asbestos-containing materials.

The inspection results revealed one Category I non-friable asbestos-containing material: stone linoleum located in the main room, covering approximately 255 square feet and containing up to 35% Chrysotile asbestos. Additionally, one mercury thermostat was identified as a hazardous material requiring proper removal and disposal. The report recommends that asbestos abatement should only be performed by a certified asbestos abatement contractor and mandates filing a Notification of Intent to Renovate/Demolish form with the Michigan Department of Environmental Quality-Air Quality Division at least 10 working days prior to any renovation or demolition activities.

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Name County TWP Sec T/R Site Access Description # Buildings Bldg Desc. Photos

Kowalski cabin Presque Isle Moltke Sec 31 NESW & SESW T35N R04E Plains Hwy - access 2 track drive cabin & outhouse 2 450 May-16 Atlanta

Cudlip cabin complex Cheboygan Ellis 2 track off Afton Rd cabins and storage bldg 3 1500 +480+320 18-Jan Indian River

FO

Castle Tract Cheboygan Forest Section 25 NWNW T33N R1E multiple structures- main living quarters, garage, bunk house, pole barn, lean to, sauna bldg 5+ 5850 May-15

Pigeon River Country

NO PHOTOS AVAILABLE

Demo Pkg FR 2019 D3 Cheboygan & Presque Isle Counties

P.O. Box 13216

Lansing, MI 48901

Phone: 888.449.4566

Fax: 888.448.8739 www.redcedarconsulting.net

October 1, 2018

Ms. Sharon Conley

Forest Resources Division Facilities & Equipment Coordinator

P.O. Box 30452

Lansing, MI 48909

RE: Asbestos Containing Material and Hazardous Materials Inspection

Presque Isle County, MI

Parcel ID: Kowalski Cabin

Dear Ms. Conley:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at the Kowalski Cabin Presque Isle County, Michigan (Subject Property). This inspection was completed at the request of the Michigan Department of Natural Resources to comply with the United States Environmental Protection Agency (USEPA) requirements for demolition and renovation set forth under the National Emissions Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 61). This inspection was also completed to comply with the Occupational Safety and Health Administration

(OSHA) Asbestos Standards for Construction (29 CFR 1926.1101) which limits employee exposure to asbestos.

SUBJECT PROPERTY

The Subject Property is comprised of a residential parcel which contains a cabin and outhouse (the

Buildings).

VISUAL INSPECTION AND SAMPLING

Asbestos Containing Materials Inspection

Aaron Paquet of Red Cedar Consulting (Red Cedar), accredited State Of Michigan/EPA Asbestos

Building Inspectors (Accreditation Number A30955) who completed training per the Michigan Asbestos

Workers Accreditation Act 440, completed an inspection of the Subject Property on September 26, 2018 for suspected asbestos containing building materials.

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

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

Project No.: 18-1116

Michigan Department of Natural Resources

During the completion of the inspection, each area of the Subject Property was visually inspected for asbestos containing building materials (ACBM). Following the completion of the visual inspection, Red Cedar staff identified each suspect area of friable and non-friable ACBM and sorted them into one of three homogenous categories for sampling purposes. AHERA defines friable as a material that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. A homogenous area is defined by OSHA as an area of surfacing, thermal system insulation (TSI) or miscellaneous material that is uniform in color and texture. Surfacing materials are most commonly found in sprayed-on, troweled-on or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members. TSI refers to materials applied to pipes, fittings, boilers, ductwork, or other components to prevent heat loss or gain, or condensation. Any material that does not fall under the surfacing or TSI category, such as floor tile, drywall, and acoustical ceiling tile are placed into the miscellaneous materials category.

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

• Asphalt Shingle

• Rolled Roofing Siding

• Linoleum

• Drywall and Joint Compound

• Window Glazing

Red Cedar staff collected eighteen samples of suspect ACBM separated into nine distinct homogenous groups for laboratory analysis. Samples were collected and submitted to APEX Research Inc.

Laboratories (APEX) (Accreditation Number 102118-0) for laboratory analysis. Analysis was completed utilizing polarized light microscopy (PLM) which is the Environmental Protection Agency (EPA) approved method for analysis of bulk materials for asbestos. PLM analysis completed pursuant to method (EPA 600/M4-82-020) identifies asbestos fiber bundles by the visual properties displayed when the sample is treated with various dispersion staining liquids. The laboratory report completed following the sample analysis indicates if asbestos is present, and at what percentage along with a description and percentage of other fibrous and non-fibrous materials and sample color. Chain-of-custody documentation was followed from sample collection through shipping and receiving of the samples at the designated laboratory. The documentation assures that samples will meet the quality assurance/quality control measures defined by AHERA. The laboratory analytical report prepared by APEX for the eighteen samples is included as Attachment A.

Hazardous Materials Inspection

On September 26, 2018 the Subject Property was also inspected for the presence of hazardous materials which include but are not limited to polychlorinated biphenyls (PCBs) and potential mercury containing equipment and any items or containers that may contain or be classified as a hazardous or regulated material. Each material, if identified, was documented along with the approximate location. Any materials identified as hazardous are included in Table 1.

INSPECTION RESULTS AND RECOMMENDATIONS

During the completion of the asbestos inspection, eighteen samples of suspect ACM were collected and are documented in Table 2 along with the Red Cedar sample number, description, friability, material type, ACM classification, sample location, material quantity and laboratory analytical results. A Site Diagram was prepared which provides the general building layout and sample locations and is included as

Attachment B.

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

Light Microscopy”.

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

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

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

Presumed Asbestos Containing Material

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

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

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

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

Friable ACM’s

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

Category I ACM

One type of resilient floor covering (Stone Linoleum) located within the main room was found to contain up to 35% Chrysotile asbestos. The assessment to quantify the extent of this material identified approximately 255 sq. ft. of this material within the Building.

Category II ACM

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

RECOMMENDATIONS

Asbestos Containing Materials

The Category I resilient floor coverings (Stone Linoleum) are non-friable ACM’s that may be left in place as long as the demolition/renovation activities are completed following the OSHA Asbestos Standards for

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

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

Hazardous Materials

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

• Mercury Thermostat (1)

REGULATORY REQUIREMENTS

A Notification of intent to Renovate/Demolish form must be filed with the Michigan Department of Environmental Quality- Air Quality Division at least 10 working days prior to any renovation or demolition activities at a site.

The Notification of Intent to Renovate/Demolish form must also be completed and submitted to the MIOSHA-Asbestos Program whenever demolition, encapsulation and/or renovation activities at a site involving greater than ten lineal feet and/or fifteen square feet of ACM will be completed.

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

• Friable asbestos material.

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

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

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

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

Part 61).

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

NESHAP Asbestos Program MIOSHA-CSHD-Asbestos Program

Department of Environmental Quality State of Michigan

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

Email: asbestos@michigan.gov

DISCLAIMER

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

This report was prepared at the request and for exclusive use by the Michigan Department of Natural

Resources and may not be reproduced or sold without written permission from Red Cedar Consulting.

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

Sincerely, Red Cedar Consulting

Aaron Paquet

Michigan/EPA Certified Asbestos Building Inspector

(A30955)

©2018 Red Cedar Consulting, LLC.

Attachment A

APEX Research Laboratory Analytical Results

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

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 01 Asbestos Present: NO Fiberglass - 15%

Cust. #: KC-HM-01A No Asbestos Observed Other - 85% Material: Asphalt Shingle Location: Cabin Appearance: black,fibrous,homogenous Layer: 1 of 2

Lab ID #: 79957 - 01a Asbestos Present: NO Cellulose - 50% Cust. #: KC-HM-01A No Asbestos Observed Other - 50% Material: Tar Paper Location: Cabin Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 79957 - 02 Asbestos Present: NO Fiberglass - 15% Cust. #: KC-HM-01B No Asbestos Observed Other - 85% Material: Asphalt Shingle Location: Cabin Appearance: black,fibrous,homogenous Layer: 1 of 2

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

Robert T. Letarte Jr., Laboratory Director

Project : Kowalski Cabin

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

NVLAP Lab Code 102118-0

APEX Research Inc., 11054 Hi Tech Drive, Whitmore Lake, MI 48189

(734) 449-9990, Fax (734) 449-9991 Page 1 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 02a Asbestos Present: NO Cellulose - 50%

Cust. #: KC-HM-01B No Asbestos Observed Other - 50% Material: Tar Paper Location: Cabin Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 79957 - 03 Asbestos Present: NO Cellulose - 25% Cust. #: KC-HM-02A No Asbestos Observed Other - 75% Material: Rolled Roofing Siding- Brick Location:

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

Lab ID #: 79957 - 03a Asbestos Present: NO Cellulose - 50% Cust. #: KC-HM-02A No Asbestos Observed Other - 50% Material: Tar Paper Location:

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

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 2 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 04 Asbestos Present: NO Cellulose - 25%

Cust. #: KC-HM-02B No Asbestos Observed Other - 75% Material: Rolled Roofing Siding- Brick Location:

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

Lab ID #: 79957 - 04a Asbestos Present: NO Cellulose - 50% Cust. #: KC-HM-02B No Asbestos Observed Other - 50% Material: Tar Paper Location:

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

Lab ID #: 79957 - 05 Asbestos Present: NO Cellulose - 20% Cust. #: KC-HM-03A No Asbestos Observed Other - 80% Material: Rolled Roofing Siding- Brown Location:

Appearance: black,fibrous,homogenous Layer: 1 of 1

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 3 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 06 Asbestos Present: NO Cellulose - 20%

Cust. #: KC-HM-03B No Asbestos Observed Other - 80% Material: Rolled Roofing Siding- Brown Location:

Appearance: black,fibrous,homogenous Layer: 1 of 1

Lab ID #: 79957 - 07 Asbestos Present: NO Cellulose - 25% Cust. #: KC-HM-04A No Asbestos Observed Other - 75% Material: Rolled Roofing Siding- Smooth Location:

Appearance: black,fibrous,homogenous Layer: 1 of 1

Lab ID #: 79957 - 08 Asbestos Present: NO Cellulose - 25% Cust. #: KC-HM-04B No Asbestos Observed Other - 75% Material: Rolled Roofing Siding- Smooth Location:

Appearance: black,fibrous,homogenous Layer: 1 of 1

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 4 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 09 Asbestos Present: YES Other - 65%

Cust. #: KC-HM-05A Chrysotile - 35% Material: Stone Linoleum Location:

Appearance: beige,fibrous,homogenous Layer: 1 of 2

Lab ID #: 79957 - 09a Asbestos Present: NO Cellulose - 95% Cust. #: KC-HM-05A No Asbestos Observed Other - 5% Material: Fiberboard Location:

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

Lab ID #: 79957 - 10 Asbestos Present:

Cust. #: KC-HM-05B Material: Stone Linoleum Location: NOT ANALYZED Appearance:

Layer: 1 of 2

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 5 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 10a Asbestos Present: NO Cellulose - 95%

Cust. #: KC-HM-05B No Asbestos Observed Other - 5% Material: Fiberboard Location:

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

Lab ID #: 79957 - 11 Asbestos Present: NO Cellulose - 20% Cust. #: KC-HM-06A No Asbestos Observed Other - 80% Material: Drywall Location:

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

Lab ID #: 79957 - 11a Asbestos Present: NO Other - 100% Cust. #: KC-HM-06A No Asbestos Observed Material: Joint Compound Location:

Appearance: white,nonfibrous,nonhomogenous Layer: 2 of 2

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 6 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 12 Asbestos Present: NO Cellulose - 20%

Cust. #: KC-HM-06B No Asbestos Observed Other - 80% Material: Drywall Location:

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

Lab ID #: 79957 - 12a Asbestos Present: NO Other - 100% Cust. #: KC-HM-06B No Asbestos Observed Material: Joint Compound Location:

Appearance: white,nonfibrous,nonhomogenous Layer: 2 of 2

Lab ID #: 79957 - 13 Asbestos Present: NO Fiberglass - 15% Cust. #: KC-HM-07A No Asbestos Observed Other - 85% Material: Asphalt Shingle Location: Outhouse Appearance: black,fibrous,homogenous Layer: 1 of 2

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 7 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 13a Asbestos Present: NO Cellulose - 50%

Cust. #: KC-HM-07A No Asbestos Observed Other - 50% Material: Tar Paper Location: Outhouse Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 79957 - 14 Asbestos Present: NO Fiberglass - 15% Cust. #: KC-HM-07B No Asbestos Observed Other - 85% Material: Asphalt Shingle Location: Outhouse Appearance: black,fibrous,homogenous Layer: 1 of 2

Lab ID #: 79957 - 14a Asbestos Present: NO Cellulose - 50% Cust. #: KC-HM-07B No Asbestos Observed Other - 50% Material: Tar Paper Location: Outhouse Appearance: black,fibrous,homogenous Layer: 2 of 2

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 8 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 15 Asbestos Present: NO Cellulose - 25%

Cust. #: KC-HM-08A No Asbestos Observed Other - 75% Material: Rolled Roofing Siding- Blue Location:

Appearance: black,fibrous,homogenous Layer: 1 of 1

Lab ID #: 79957 - 16 Asbestos Present: NO Cellulose - 25% Cust. #: KC-HM-08B No Asbestos Observed Other - 75% Material: Rolled Roofing Siding- Blue Location:

Appearance: black,fibrous,homogenous Layer: 1 of 1

Lab ID #: 79957 - 17 Asbestos Present: NO Other - 100% Cust. #: KC-HM-09A No Asbestos Observed Material: Window Glazing Location:

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

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 9 of 10

Report To: ARI Report # 18-79957 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 10/01/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Kowalski Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79957 - 18 Asbestos Present: NO Other - 100%

Cust. #: KC-HM-09B No Asbestos Observed Material: Window Glazing Location:

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

Lab ID #: Asbestos Present:

Cust. #:

Material:

Location:

Appearance:

Layer: of

Lab ID #: Asbestos Present:

Cust. #:

Material:

Location:

Appearance:

Layer: of

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

Robert T. Letarte Jr., Laboratory Director

Test Method EPA 600/R-93/116 was used to analyze the above samples. Matrix interference and/or resolution limits may yield false/negative results in certain circumstances. Suspect floor tiles containing <1% should be tested with SEM or TEM. This certificate of analysis relates only to the samples tested and to insure the integrity of the results, may only be reproduced in full. This certificate must not be used by the customer to claim product certification,approval, or endorsement by NVLAP, NIST, or any agency of the US Government. APEX Research Inc. is not responsible for the accuracy of the results for layered samples or samples comprising multiple materials. Liability limited to cost of analysis.

(734) 449-9990, Fax (734) 449-9991 Page 10 of 10

Attachment B Figure 1 Site Diagram

Note: Figure created by Red Cedar Consulting Asbestos Sample Locations

Kowalski Cabin -Not To Scale- Presque Isle County, MI

Tables

Table 1 - Summary of Hazardous Materials, Kowalski Cabin Presque Isle County, Michigan

Hazardous Materials Description and Location

Location Material Description Quantity

Front Porch Mercury Thermostat 1

Table 2 - Summary of Sample Descriptions and Asbestos Laboratory Results, Kowalski Cabin Presque Isle County, Michigan

Sample

Number Sample Description Friable

Material

Type

Material

Classification

% Asbestos

Laboratory

Result

Sample Location Approx. Material

Quantity

KC-HM-01A Asphalt Shingle Cabin No M Category I ND/ND Cabin Roof NA

KC-HM-01B Asphalt Shingle Cabin No M Category I ND/ND Cabin Roof NA

KC-HM-02A Rolled Roofing Siding-Brick No M Category I ND/ND Cabin Exterior NA

KC-HM-02B Rolled Roofing Siding-Brick No M Category I ND/ND Cabin Exterior NA

KC-HM-03A Rolled Roofing Siding-Brown No M Category I ND Cabin Exterior NA

KC-HM-03B Rolled Roofing Siding-Brown No M Category I ND Cabin Exterior NA

KC-HM-04A Rolled Roofing Siding-Smooth No M Category I ND Cabin Exterior NA

KC-HM-04B Rolled Roofing Siding-Smooth No M Category I ND Cabin Exterior NA

KC-HM-05A Stone Linoleum No M Category I 35% CH/ND Main Room 255 sq. ft.

KC-HM-05B Stone Linoleum No M Category I NA/ND Main Room NA

KC-HM-06A Drywall and Joint Compound No M Category II ND/ND Main Room Ceiling NA

KC-HM-06B Drywall and Joint Compound No M Category II ND/ND Main Room Wall NA

KC-HM-07A Asphalt Shingle Outhouse No M Category I ND/ND Outhouse Roof NA

KC-HM-07B Asphalt Shingle Outhouse No M Category I ND/ND Outhouse Roof NA

KC-HM-08A Rolled Roofing Siding-Blue No M Category I ND Outhouse Exterior NA

KC-HM-08B Rolled Roofing Siding-Blue No M Category I ND Outhouse Exterior NA

KC-HM-09A Window Glazing Yes M Category II ND/ND Bunk Room Window NA

KC-HM-09B Window Glazing Yes M Category II ND/ND Kitchen Window NA

Notes:

Material Types Abbreviations

M = Miscellaneous building material NQ = Not quantified

TSI = Thermal System Insulation NA = Not applicable

S = Surfacing Material ND = Not detected. Laboratory result is less than 1 % asbestos

PC = Point Count Analysis lin. ft. = linear feet

CH = Chrysotile Asbestos sq. ft. = square feet

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

Table 3 - Summary of Presumed Asbestos Containing Materials, Kowalski Cabin Presque Isle County, Michigan

Asbestos Containing Material Description and Location

Location Material Description Friable Condition Material

Type Approx. Quantity

No Presumed Asbestos Containing Materials Identified

Notes:

Material Types Abbreviations

M = Miscellaneous building material lin. ft. = linear feet

TSI = Thermal System Insulation sq. ft. = square feet

S = Surfacing Material

Table 4 - Summary of All Asbestos Containing Materials, Kowalski Cabin Presque Isle County, Michigan

Interior - Asbestos Containing Materials

Location Material Description Friable Approx. Quantity

Main Room Stone Linoleum No 255 sq. ft.

Total 255 sq. ft.

Abbreviations lin. ft. = linear feet

sq. ft. = square feet

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

Demolition/renovation activities completed with intact Category I non-friable ACM are regulated by OSHA and must be completed following the OSHA Asbestos Standards for

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

Phone: 888.449.4566

September 28, 2018

Facilities & Equipment Coordinator

Cheboygan County, MI

Parcel ID: Cudlip Cabin inspection at Cudlip Cabin Cheboygan County, Michigan (Subject Property). This inspection was completed at the request of the Michigan Department of Natural Resources to comply with the United States Environmental Protection Agency (USEPA) requirements for demolition and renovation set forth under the National Emissions Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 61). This inspection was also completed to comply with the Occupational Safety and Health Administration

The Subject Property is comprised of a residential parcel which contains a Garage, Red Cabin and Main

Cabin (the Buildings). In general, the Buildings were finished with half log siding while the roofs were finished with asphalt shingles.

Workers Accreditation Act 440, completed an inspection of the Subject Property on September 13, 2018

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

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

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

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

• 9”x9” Vinyl Tile

• Fiberboard

• Glazing

• Rolled Roofing

• 12x12 Vinyl Tile

• Linoleum

• Exterior Chinking

Red Cedar staff collected twenty three samples of suspect ACBM separated into eleven distinct homogenous groups for laboratory analysis. Samples were collected and submitted to APEX Research Inc. Laboratories (APEX) (Accreditation Number 102118-0) for laboratory analysis. Analysis was completed utilizing polarized light microscopy (PLM) which is the Environmental Protection Agency

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

On September 13, 2018 the Subject Property was also inspected for the presence of hazardous materials which include but are not limited to polychlorinated biphenyls (PCBs) and potential mercury containing equipment and any items or containers that may contain or be classified as a hazardous or regulated

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

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

Light Microscopy”.

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

Non-friable asbestos-containing material is defined as “material containing more than 1 percent asbestos

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

Presumed Asbestos Containing Material

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

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

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

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

Friable ACM’s

A window glazing sample collected from a window in the Red Cabin was found to contain up to 1.75% asbestos following analysis. The assessment to quantify the extent of this material identified five windows at the following locations that would fall into the same homogenous group. The locations of the windows are listed below:

• Red Cabin (2 windows 44” wide x 42” tall)

• Red Cabin (1 window 24” wide x 52” tall)

• Red Cabin (1 window 28” wide x 28” tall)

• Red Cabin (1 window 32” wide x 28” tall)

Category I ACM

Two types of resilient floor covering (9”x9" Gray Vinyl Floor Tile and 12”x12” Mottled Vinyl Tile) located within the Red Cabin and Main Cabin were found to contain up to 5% Chrysotile asbestos. The assessment to quantify the extent of this material identified approximately 510 sq. ft. of this material within the Buildings.

Rolled roofing samples collected during the completion of the inspection were found to contain up to 10% Chrysotile asbestos. The assessment to quantify the extent of this material identified 225 sq. ft. of rolled roofing materials on the Rear Shed of the Red Cabin.

Category II ACM

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

RECOMMENDATIONS

Asbestos Containing Materials

Friable asbestos containing window glazing was identified on five windows throughout the Building. The locations of these windows that should be abated prior to demolition/renovation activities are listed below:

• Red Cabin (2 windows 44” wide x 42” tall)

• Red Cabin (1 window 24” wide x 52” tall)

• Red Cabin (1 window 28” wide x 28” tall)

• Red Cabin (1 window 32” wide x 28” tall)

Please note: Other different sized windows are located throughout the Building but these windows were assessed and found to be constructed either without window glazing or were sampled and found to not contain asbestos and therefore are not required to be removed.

The Category I roofing materials and resilient floor coverings (9”x9" Gray Vinyl Floor Tile and 12”x12” Mottled Vinyl Tile) are non-friable ACM’s that may be left in place as long as the demolition/renovation activities are completed following the OSHA Asbestos Standards for Construction (29 CFR 1926.1101) which limits employee exposure to asbestos.

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

Hazardous Materials

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

• Television (1)

• Thermostat (1)

REGULATORY REQUIREMENTS

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

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

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

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

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

• Friable asbestos material.

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

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

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

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

Part 61).

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

NESHAP Asbestos Program MIOSHA-CSHD-Asbestos Program

Department of Environmental Quality State of Michigan Phone: 517-284-6777 Phone: 517-284-7680

Email: asbestos@michigan.gov

DISCLAIMER

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

This report was prepared at the request and for exclusive use by the Michigan Department of Natural

Resources and may not be reproduced or sold without written permission from Red Cedar Consulting.

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

Sincerely, Aaron Paquet

Michigan/EPA Certified Asbestos Building Inspector (A30955)

©2018 Red Cedar Consulting, LLC.

Attachment A

APEX Research Laboratory Analytical Results

Report To: ARI Report # 18-79679 Mr. Aaron Paquet Date Collected: 09/13/18 Red Cedar Consulting Date Received: 09/18/18 P.O. Box 13216 Date Analyzed: 09/24/18 Lansing, MI 48901 Date Reported: 09/25/18

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79679 - 01 Asbestos Present: NO Cellulose - 15%

Cust. #: CC-HM-01A No Asbestos Observed Other - 85% Material: Asphalt Shingles Location: Garage Appearance: black,fibrous,homogenous Layer: 1 of 2

Lab ID #: 79679 - 01a Asbestos Present: NO Cellulose - 50% Cust. #: CC-HM-01A No Asbestos Observed Other - 50% Material: Felt Location: Garage Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 79679 - 02 Asbestos Present: NO Cellulose - 15% Cust. #: CC-HM-01B No Asbestos Observed Other - 85% Material: Asphalt Shingles Location: Garage Appearance: black,fibrous,homogenous Layer: 1 of 2

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

Robert T. Letarte Jr., Laboratory Director

Project : Cudlip Cabin Complex

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

(734) 449-9990, Fax (734) 449-9991 Page 1 of 17

Report To: ARI Report # 18-79679 Mr. Aaron Paquet Date Collected: 09/13/18 Red Cedar Consulting Date Received: 09/18/18 P.O. Box 13216 Date Analyzed: 09/24/18 Lansing, MI 48901 Date Reported: 09/25/18

Project : Cudlip Cabin Complex

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79679 - 02a Asbestos Present: NO Cellulose - 15%

Cust. #: CC-HM-01B No Asbestos Observed Other - 85% Material: Shingle Location: Garage Appearance: black,fibrous,homogenous Layer: 2 of 2

Lab ID #: 79679 - 03 Asbestos Present: NO Cellulose - 10% Cust. #: CC-HM-02A No Asbestos Observed Other - 90% Material: Asphalt Shingles Location: Red Cabin Appearance: black,fibrous,homogenous Layer: 1 of 3

Lab ID #: 79679 - 03a Asbestos Present: NO Fiberglass - 10% Cust. #: CC-HM-02A No Asbestos Observed Other - 90% Material: Shingle Location: Red Cabin Appearance: black,fibrous,homogenous Layer: 2 of 3

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

Robert T. Letarte Jr., Laboratory Director

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

(734) 449-9990, Fax (734) 449-9991 Page 2 of 17

Report To: ARI Report # 18-79679 Mr. Aaron Paquet Date Collected: 09/13/18 Red Cedar Consulting Date Received: 09/18/18 P.O. Box 13216 Date Analyzed: 09/24/18 Lansing, MI 48901 Date Reported: 09/25/18

Project : Cudlip Cabin Complex

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79679 - 03b Asbestos Present: NO Cellulose - 40%

Cust. #: CC-HM-02A No Asbestos Observed Other - 60% Material: Roofing Location: Red Cabin Appearance: black,fibrous,nonhomogenous Layer: 3 of 3

Lab ID #: 79679 - 04 Asbestos Present: NO Cellulose - 10% Cust. #: CC-HM-02B No Asbestos Observed Other - 90% Material: Asphalt Shingles Location: Red Cabin Appearance: black,fibrous,homogenous Layer: 1 of 3

Lab ID #: 79679 - 04a Asbestos Present: NO Fiberglass - 10% Cust. #: CC-HM-02B No Asbestos Observed Other - 90% Material: Shingle Location: Red Cabin Appearance: black,fibrous,homogenous Layer: 2 of 3

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

Robert T. Letarte Jr., Laboratory Director

Test Method EPA 600/R-93/116 was used to analyze the above samples. Matrix interference and/or resolution limits may yield false/negative results in certain circumstances. Suspect floor tiles containing <1% should be tested with SEM or TEM.

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