FR2019 D4 Alpena 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) for a property located in Alpena County, Michigan. 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). The inspection focused on a cabin and outhouse, with the primary objectives of identifying and documenting asbestos-containing and hazardous materials prior to potential demolition activities.

The inspection revealed friable asbestos-containing window glazing on four windows in the kitchen and main room, which requires professional abatement before any renovation or demolition. Additionally, hazardous materials were identified, including one smoke detector, two 1-gallon containers, one 4' fluorescent light fixture with ballast, and four 4' fluorescent bulbs. The report mandates that 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 activities, and all asbestos abatement must be performed by a certified contractor following OSHA and USEPA standards.

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

Wilson Twp Sec 14 SW 1/4 NW 1/4 T30N R07E at the end of Dann Rd cabin & outhouse 2 720 May-16 Atlanta

Wilson Twp Sec 26 NW 1/4 NE 1/4 T31N R07E at Alpena field office new shed (double wide) 1 1080 May-16 Atlanta

FRD Demo FR2019-D4 Alpena

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

Alpena County, MI

Parcel ID: Souva Cabin

Dear Ms. Conley:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at the Souva Cabin Alpena 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

• Linoleum

• 1x1 Ceiling Tile

• Fiberboard

• Glazing

Red Cedar staff collected twelve samples of suspect ACBM separated into six 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 twelve 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, twelve 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

A window glazing sample collected from a window in the Main Room was found to contain up to 2% asbestos following analysis. The assessment to quantify the extent of this material identified four windows at the following locations that would fall into the same homogenous group. The locations of the windows are listed below:

• Kitchen (1 window 44” wide x 28” tall)

• Main Room (1 window 44” wide x 54” tall)

• Main Room (2 windows 44” wide x 36” tall)

Category I ACM

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

Category II ACM

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

RECOMMENDATIONS

Asbestos Containing Materials

Friable asbestos containing window glazing was identified on four windows throughout the Building.

The locations of these windows that should be abated prior to demolition/renovation activities are listed below:

• Kitchen (1 window 44” wide x 28” tall)

• Main Room (1 window 44” wide x 54” tall)

• Main Room (2 windows 44” wide x 36” tall)

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:

• Smoke Detector (1)

• 1-Gallon Container Misc. (2)

• 4’ Fluorescent Light (Fixture and Ballast Only) (1)

• 4’ Fluorescent Bulb (4)

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 # 18-79958 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 09/27/18 Lansing, MI 48901 Date Reported: 10/01/18

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79958 - 01 Asbestos Present: NO Cellulose - 15%

Cust. #: SC-HM-01A No Asbestos Observed Other - 85% Material: Asphalt Shingles Location: Cabin Appearance: black,fibrous,nonhomogenous Layer: 1 of 1

Lab ID #: 79958 - 02 Asbestos Present: NO Cellulose - 15% Cust. #: SC-HM-01B No Asbestos Observed Other - 85% Material: Asphalt Shingles Location: Cabin Appearance: black,fibrous,nonhomogenous Layer: 1 of 1

Lab ID #: 79958 - 03 Asbestos Present: NO Cellulose - 20% Cust. #: SC-HM-02A No Asbestos Observed Synthetic - 5% Material: White Linoleum Other - 75% Location:

Appearance: white,fibrous,nonhomogenous 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.

Project : Souva Cabin

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 4

Report To: ARI Report # 18-79958 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 09/27/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Souva Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79958 - 04 Asbestos Present: NO Cellulose - 20%

Cust. #: SC-HM-02B No Asbestos Observed Synthetic - 5% Material: White Linoleum Other - 75% Location:

Appearance: white,fibrous,nonhomogenous Layer: 1 of 1

Lab ID #: 79958 - 05 Asbestos Present: NO Cellulose - 20% Cust. #: SC-HM-03A No Asbestos Observed Fiberglass - 10% Material: White 1x1 Ceiling Tile Other - 70% Location:

Appearance: white,fibrous,nonhomogenous Layer: 1 of 1

Lab ID #: 79958 - 06 Asbestos Present: NO Cellulose - 20% Cust. #: SC-HM-03B No Asbestos Observed Fiberglass - 10% Material: White 1x1 Ceiling Tile Other - 70% Location:

Appearance: white,fibrous,nonhomogenous 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 2 of 4

Report To: ARI Report # 18-79958 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 09/27/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Souva Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79958 - 07 Asbestos Present: NO Cellulose - 75%

Cust. #: SC-HM-04A No Asbestos Observed Other - 25% Material: Fiberboard Location:

Appearance: brown,fibrous,nonhomogenous Layer: 1 of 1

Lab ID #: 79958 - 08 Asbestos Present: NO Cellulose - 75% Cust. #: SC-HM-04B No Asbestos Observed Other - 25% Material: Fiberboard Location:

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

Lab ID #: 79958 - 09 Asbestos Present: YES Other - 98% Cust. #: SC-HM-05A Chrysotile - 2% Material: Glazing Location:

Appearance: beige,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 4

Report To: ARI Report # 18-79958 Mr. Aaron Paquet Date Collected: 09/26/18 Red Cedar Consulting Date Received: 09/28/18 P.O. Box 13216 Date Analyzed: 09/27/18 Lansing, MI 48901 Date Reported: 10/01/18

Project : Souva Cabin

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79958 - 10 Asbestos Present: YES Other - 98%

Cust. #: SC-HM-05B Chrysotile - 2% Material: Glazing Location:

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

Lab ID #: 79958 - 11 Asbestos Present: NO Cellulose - 15% Cust. #: SC-HM-06A No Asbestos Observed Other - 85% Material: Asphalt Shingles Location: Outhouse Appearance: black,fibrous,nonhomogenous Layer: 1 of 1

Lab ID #: 79958 - 12 Asbestos Present: NO Cellulose - 15% Cust. #: SC-HM-06B No Asbestos Observed Other - 85% Material: Asphalt Shingles Location: Outhouse Appearance: black,fibrous,nonhomogenous 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 4

Attachment B Figure 1 Site Diagram

Note: Figure created by Red Cedar Consulting Asbestos Sample Locations

Souva Cabin -Not To Scale- Alpena County, MI

Tables

Table 1 - Summary of Hazardous Materials, Souva Cabin Alpena County, Michigan

Hazardous Materials Description and Location

Location Material Description Quantity

Bunk Room Smoke Detector 1

Bunk Room 1-Gallon Container Misc. 2

Front Porch 4’ Fluorescent Light (Fixture and Ballast Only) 1

Front Porch 4’ Fluorescent Bulb 4

Table 2 - Summary of Sample Descriptions and Asbestos Laboratory Results, Souva Cabin Alpena County, Michigan

Sample

Number Sample Description Friable

Material

Type

Material

Classification

% Asbestos

Laboratory

Result

Sample Location Approx. Material

Quantity

SC-HM-01A Asphalt Shingles Cabin No M Category I ND Cabin Roof NA

SC-HM-01B Asphalt Shingles Cabin No M Category I ND Cabin Roof NA

SC-HM-02A White Linoleum No M Category I ND Bunk Area NA

SC-HM-02B White Linoleum No M Category I ND Bunk Area NA

SC-HM-03A White 1x1 Ceiling Tile Yes M Category II ND Main Room Ceiling NA

SC-HM-03B White 1x1 Ceiling Tile Yes M Category II ND Bunk Area Ceiling NA

SC-HM-04A Fiberboard Yes M Category II ND Bunk Area Ceiling NA

SC-HM-04B Fiberboard Yes M Category II ND Bunk Area Ceiling NA

SC-HM-05A Glazing Yes M Category II 2% Ch Main Room Window 4 Windows

SC-HM-05B Glazing Yes M Category II 2% CH Main Room Window NA

SC-HM-06A Asphalt Shingles Outhouse No M Category I ND Outhouse Roof NA

SC-HM-06B Asphalt Shingles Outhouse No M Category I ND Outhouse Roof 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, Souva Cabin Alpena 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, Souva Cabin Alpena County, Michigan

Interior - Asbestos Containing Materials

Location Material Description Friable Approx. Quantity

Kitchen (1 window 44” wide x 28” tall) Glazing Yes 1 Window

Main Room (1 window 44” wide x 54” tall) Glazing Yes 1 Window

Main Room (2 windows 44” wide x 36” tall) Glazing Yes 2 Windows

Total 4 Windows

Abbreviations lin. ft. = linear feet

sq. ft. = square feet

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

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

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

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

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

Alpena County, MI

Parcel ID: Net Shed-Alpena

Dear Ms. Conley:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at the Net Shed Alpena 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 commercial parcel which contains a storage shed (the Building) with an unknown construction date.

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.

Parcel ID: Net Shed

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:

• Rolled Roofing

• Fiberboard

• Window Caulk

• Window Flashing

Red Cedar staff collected eight samples of suspect ACBM separated into four 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 eight 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, eight 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

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

Category II ACM

Non-friable asbestos containing window flashing was identified on two windows throughout the Building.

The locations of these windows that should be abated prior to demolition/renovation activities are listed

• Shed South Wall (2 windows, 18 lin. ft.)

RECOMMENDATIONS

Asbestos Containing Materials

Non-friable asbestos containing window flashing was identified on two windows throughout the Building.

The locations of these windows that should be abated prior to demolition/renovation activities are listed

• Shed South Wall (2 windows, 18 lin. ft.)

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

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:

• Pallet of Paint Cans (1)

• Thermostat (1)

• 8’ Fluorescent Light (Fixture and Ballast Only) (2)

• 8’ Fluorescent Bulb (4)

• 4’ Fluorescent Light (Fixture and Ballast Only) (4)

• 4’ Fluorescent Bulb (8)

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 # 18-79959 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 #: 79959 - 01 Asbestos Present: NO Cellulose - 15%

Cust. #: NS-HM-01A No Asbestos Observed Other - 85% Material: Rolled Roofing Location:

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

Lab ID #: 79959 - 01a Asbestos Present: NO Cellulose - 50% Cust. #: NS-HM-01A No Asbestos Observed Other - 50% Material: Felt Location:

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

Lab ID #: 79959 - 02 Asbestos Present: NO Cellulose - 15% Cust. #: NS-HM-01B No Asbestos Observed Other - 85% Material: Rolled Roofing Location:

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.

Project : Net Shed- Alpena

(734) 449-9990, Fax (734) 449-9991 Page 1 of 4

Report To: ARI Report # 18-79959 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 : Net Shed- Alpena

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79959 - 02a Asbestos Present: NO Cellulose - 50%

Cust. #: NS-HM-01B No Asbestos Observed Other - 50% Material: Felt Location:

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

Lab ID #: 79959 - 03 Asbestos Present: NO Cellulose - 75% Cust. #: NS-HM-02A No Asbestos Observed Other - 25% Material: Fiberboard Location:

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

Lab ID #: 79959 - 04 Asbestos Present: NO Cellulose - 75% Cust. #: NS-HM-02B No Asbestos Observed Other - 25% Material: Fiberboard Location:

Appearance: brown,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 2 of 4

Report To: ARI Report # 18-79959 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 : Net Shed- Alpena

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79959 - 05 Asbestos Present: NO Other - 100%

Cust. #: NS-HM-03A No Asbestos Observed Material: Tan Window Caulk Location:

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

Lab ID #: 79959 - 06 Asbestos Present: NO Other - 100% Cust. #: NS-HM-03B No Asbestos Observed Material: Tan Window Caulk Location:

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

Lab ID #: 79959 - 07 Asbestos Present: YES Other - 90% Cust. #: NS-HM-04A Chrysotile - 10% Material: Black Window Flashing 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 4

Report To: ARI Report # 18-79959 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 : Net Shed- Alpena

Sample Information Asbestos Type/Percent Non-Asbestos Material

Lab ID #: 79959 - 08 Asbestos Present: YES Other - 90%

Cust. #: NS-HM-04B Chrysotile - 10% Material: Black Window Flashing Location:

Appearance: black,fibrous,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 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 4

Attachment B

Note: Figure created by Red Cedar Consulting Asbestos Sample Locations

Net Shed Alpena -Not To Scale- Alpena County, MI

Table 1 - Summary of Hazardous Materials, Net Shed Alpena County, Michigan

Hazardous Materials Description and Location

Location Material Description Quantity

Exterior behind Shed Pallet of Paint Cans 1

Living Room Thermostat 1

Living Room 8’ Fluorescent Light (Fixture and Ballast Only) 2

Living Room 8’ Fluorescent Bulb 4

Living Room 4’ Fluorescent Light (Fixture and Ballast Only) 4

Living Room 4’ Fluorescent Bulb 8

Tables

Table 2 - Summary of Sample Descriptions and Asbestos Laboratory Results, Net Shed Alpena County, Michigan

Sample

Number Sample Description Friable

Material

Type

Material

Classification

% Asbestos

Laboratory

Result

Sample Location Approx. Material

Quantity

NS-HM-01A Rolled Roofing No M Category I ND/ND Cabin Roof NA

NS-HM-01B Rolled Roofing No M Category I ND/ND Cabin Roof NA

NS-HM-02A Fiberboard Yes M Category II ND West Room NA

NS-HM-02B Fiberboard Yes M Category II ND East Room NA

NS-HM-03A Tan Window Caulk No M Category II ND South West Window NA

NS-HM-03B Tan Window Caulk No M Category II ND North East Window NA

NS-HM-04A Black Window Flashing No M Category II 10% CH Shed South Wall

Window 2 Windows

NS-HM-04B Black Window Flashing No M Category II 10% CH Shed South Wall

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, Net Shed Alpena County, Michigan

Asbestos Containing Material Description and Location

Location Material Description Friable Condition Material

Type Approx. Quantity

No Presumed Asbestos Containing Materials Identified

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, Net Shed Alpena County, Michigan

Exterior - Asbestos Containing Materials

Location Material Description Friable Approx. Quantity

Window Exterior Black Window Flashing (18 lin. ft) No 2 Windows

Total 2 Windows

Abbreviations lin. ft. = linear feet

sq. ft. = square feet

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

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

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

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

Souva Cabin Asbestos Containing Materials Report 100118.pdf
Souva Cabin Asbestos Containing Materials Report.pdf
Attachments
1879958 Souva
1879958 COC Souva
Figure 1 Final Site Diagram ACM.xls
Souva Cabin Table 1
Souva Cabin Tables 2, 3, and 4
Net Shed Asbestos Containing Materials Report 100118.pdf
Net Shed Asbestos Containing Materials Report.pdf
Attachments
187995904 Net Shed
1879959coc Net Shed
Figure 1 Final Site Diagram ACM.xls
Net Shed Table 1
Net Shed Tables 2, 3, and 4

File details come from the government source that posted it. Updated .