FR2019-D6 Rosco - Missaukee List ACM reports.pdf

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

Norwich Cabin Missaukee Norwich Section 15 NENE T24N R5W hunting cabin 320 May-15 Cadillac MU

Roscommon Conservation Airport Roscommon Higgins 9408 Airport Dr aircraft hangar 1 2160 18-Jan

P.O. Box 13216

Lansing, MI 48901

Phone: 888.449.4566

Fax: 888.448.8739 www.redcedarconsulting.net

September 28, 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

Missaukee County, MI

Parcel ID: Norwich Cabin

Dear Ms. Conley:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at the Norwich Cabin Missaukee 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 an approximate 340 square foot

Cabin (the Building) along with two outhouses with an unknown construction date. The Building was constructed on a wood foundation with one aboveground floors The exterior walls of the Building were finished with Tar Paper while the roof was sealed with asphalt shingles.

VISUAL INSPECTION AND SAMPLING

Asbestos Containing Materials Inspection

Aaron Paquet of Red Cedar Consulting (Red Cedar), accredited State Of Michigan/EPA Asbestos Building Inspector (Accreditation Numbers A30955) who completed training per the Michigan Asbestos

Workers Accreditation Act 440, completed an inspection of the Subject Property on September 5, 2018 for suspected asbestos containing building materials.

Project No.: 18-1116

Michigan Department of Natural Resources

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

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

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

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

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

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

• Asphalt Roofing

• Tar Paper

• Vapor Barrier

• Fiberboard

• Drywall

• Green Vinyl

• Black Shingle

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

Hazardous Materials Inspection

On September 5, 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, sixteen 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

Asphalt roof samples collected during the completion of the inspection were found to contain up to 5%

Chrysotile asbestos. The assessment to quantify the extent of this material identified 410 sq. ft. of asphalt roofing materials on 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 roofing materials 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:

• No Hazardous Materials Identified

REGULATORY REQUIREMENTS

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

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

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

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

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

• Friable asbestos material.

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

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

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

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

Part 61).

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

NESHAP Asbestos Program MIOSHA-CSHD-Asbestos Program Department of Environmental Quality State of Michigan

Phone: 517-284-6777 Phone: 517-284-7680 Email: asbestos@michigan.gov

DISCLAIMER

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

This report was prepared at the request and for exclusive use by the 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)

Location:

Layer:

Location:

Layer:

Location:

Layer:

NVLAP Lab Code 102118-0

Material:

of 2

Shingle black,fibrous,homogenous black,fibrous,homogenous

Cellulose - 30%

Other - 65% Material:

Cust. #:

Asphalt Roofing

NC-HM-01B

79471 - 02

Appearance:

NOAsbestos Present:

YESAsbestos Present:

Asphalt Roofing black,fibrous,nonhomogenous

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

2of1

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Chrysotile - 5%

Lab ID #:

Appearance:

Lansing, MI 48901

Appearance:

Sample Information Asbestos Type/Percent Non-Asbestos

Cust. #:

79471 - 01 Cellulose - 30%

No Asbestos Observed

09/17/18

Lab ID #:

09/05/18 09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Other - 70%

Project: Norwich Cabin

Report To:

2of

Red Cedar Consulting

ARI Report # Date Collected:

18-79471 Mr. Aaron Paquet

Date Received:

Date Reported:

NC-HM-01A

NC-HM-01A

Lab ID #: Fiberglass - 30%

Other - 70%

Material:

Cust. #:

79471 - 01a Asbestos Present:

No Asbestos Observed

NO

Robert T. Letarte Jr., Laboratory Director

APEX Research Inc., 11054 Hi Tech Drive, Whitmore Lake, MI 48189 (734) 449-9990, Fax (734) 449-9991

09/05/18 09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Norwich Cabin

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79471 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer:

Robert T. Letarte Jr., Laboratory Director

NVLAP Lab Code 102118-0

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Appearance: black,fibrous,homogenous

79471 - 04 Asbestos Present:

Tar Paper

NO Cellulose - 30%

Tar Paper

Appearance: black,fibrous,homogenous

Material:

Asbestos Present: Lab ID #:

NC-HM-01B No Asbestos Observed

Sample Information Asbestos Type/Percent Non-Asbestos

Fiberglass - 30%

Material:

NC-HM-02A

79471 - 03

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

Lab ID #:

Material:

Cust. #: Other - 65%

Asbestos Present:

Other - 70%No Asbestos Observed

Cust. #:

NC-HM-02B

Lab ID #:

Cust. #:

1 of

Cellulose - 35%

NO79471 - 02a

Other - 70% Shingle

No Asbestos Observed

NO

black,fibrous,homogenousAppearance:

09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Norwich Cabin

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79471 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer:

NVLAP Lab Code 102118-0

Appearance: grey,fibrous,homogenous

Asbestos Present: NO Cellulose - 80%

Other - 20%No Asbestos Observed Material: Vapor Barrier

Lab ID #:

Material: Vapor Barrier

Appearance: brown,fibrous,homogenous

Cust. #: NC-HM-03A Other - 20%No Asbestos Observed

Cellulose - 80%Lab ID #: 79471 - 05 Asbestos Present: NO

Sample Information Asbestos Type/Percent Non-Asbestos

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Robert T. Letarte Jr., Laboratory Director

Appearance:

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

black,fibrous,homogenous

No Asbestos Observed Other - 65% Material:

Cust. #: NC-HM-04A

Asphalt Roofing

Cellulose - 35%Lab ID #: 79471 - 07 Asbestos Present: NO

79471 - 06

NC-HM-03BCust. #:

09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Norwich Cabin

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79471 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer:

NVLAP Lab Code 102118-0

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Appearance: black,fibrous,homogenous

Other - 35% Material: Fiberboard Cust. #: NC-HM-05B No Asbestos Observed

Asbestos Present: NO Cellulose - 65%79471 - 10Lab ID #:

Material: Fiberboard

Appearance: black,fibrous,nonhomogenous of 1

No Asbestos Observed Other - 35%

Asbestos Present: NO Cust. #: NC-HM-05A

No Asbestos Observed Other - 65%

Appearance: black,fibrous,homogenous

Cust. #: NC-HM-04B

Sample Information Asbestos Type/Percent Non-Asbestos

Asbestos Present:

Asphalt Roofing

Lab ID #: 79471 - 09 Cellulose - 65%

1 of

Material:

Lab ID #: Cellulose - 35%NO79471 - 08

09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Norwich Cabin

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79471 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer: 1 of

Robert T. Letarte Jr., Laboratory Director

NVLAP Lab Code 102118-0

No Asbestos Observed Material: Green Vinyl Cust. #: NC-HM-07A Other - 25%

Sample Information Asbestos Type/Percent Non-Asbestos

79471 - 11 Cellulose - 20%Lab ID #: Asbestos Present: NO

Cellulose - 20%79471 - 12 NO Cust. #:

Drywall NC-HM-06ACust. #:

Lab ID #: Asbestos Present:

Material:

Material:

1 of

No Asbestos Observed Other - 80%

Other - 80%

Appearance: grey,fibrous,homogenous

Drywall grey,fibrous,homogenous 11 of

Cellulose - 75%NOLab ID #: 79471 - 13 Asbestos Present:

Appearance:

No Asbestos ObservedNC-HM-06B

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 may not be used by the customer to claim product endorsement by NVLAP 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.

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

Appearance: brown,fibrous,homogenous

09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Norwich Cabin

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79471 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer:

Material: Green Vinyl

Sample Information Asbestos Type/Percent Non-Asbestos

Cust. #: NC-HM-07B No Asbestos Observed Other - 25%

Lab ID #: 79471 - 14 Asbestos Present: Cellulose - 75%

Appearance: brown,fibrous,homogenous

Lab ID #: 79471 - 15

NO

black,fibrous,homogenous

Asbestos Present: NO Cellulose - 30%

Appearance:

Cust. #: NC-HM-08A No Asbestos Observed Other - 70%

Material: Black Shingle

Lab ID #: 79471 - 16 of 1

Asbestos Present:

Cust. #: NC-HM-08B No Asbestos Observed Material: Black Shingle

Appearance: black,fibrous,homogenous

NO Cellulose - 30%

Other - 70%

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 may not be used by the customer to claim product endorsement by NVLAP 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.

NVLAP Lab Code 102118-0

Robert T. Letarte Jr., Laboratory Director

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

Attachment B Figure 1 Site Diagram

Note: Figure created by Red Cedar Consulting Asbestos Sample Locations

Norwich Cabin -Not To Scale- Missaukee County, MI

Tables

Table 1 - Summary of Hazardous Materials, Norwich Cabin Missaukee County, Michigan

Hazardous Materials Description and Location

Location Material Description Quantity

No Hazardous Materials Identified

Table 2 - Summary of Sample Descriptions and Asbestos Laboratory Results, Norwich Cabin Missaukee County, Michigan

Sample

Number Sample Description Friable

Material

Type

Material

Classification

% Asbestos

Laboratory

Result

Sample Location Approx. Material

Quantity

NC-HM-01A Asphalt Roofing No M Category I ND/ND Cabin Roof NA

NC-HM-01B Asphalt Roofing No M Category I 5%CH/ND Cabin Roof 410 sq. ft.

NC-HM-02A Tar Paper No M Category I ND Cabin Wall NA

NC-HM-02B Tar Paper No M Category I ND Cabin Wall NA

NC-HM-03A Vapor Barrier Yes M Category II ND Outhouse 1 Wall NA

NC-HM-03B Vapor Barrier Yes M Category II ND Outhouse 1 Wall NA

NC-HM-04A Asphalt Roofing No M Category I ND Outhouse 2 Roof NA

NC-HM-04B Asphalt Roofing No M Category I ND Outhouse 2 Roof NA

NC-HM-05A Fiberboard Yes M Category II ND Bunkroom Floor NA

NC-HM-05B Fiberboard Yes M Category II ND Bunkroom Floor NA

NC-HM-06A Drywall No M Category II ND Bunkroom Wall NA

NC-HM-06B Drywall No M Category II ND Bunkroom Wall NA

NC-HM-07A Green Vinyl No M Category I ND Kitchen Area NA

NC-HM-07B Green Vinyl No M Category I ND Kitchen Area NA

NC-HM-08A Black Shingle No M Category I ND Pile on E Side of Cabin NA

NC-HM-08B Black Shingle No M Category I ND Pile on E Side of Cabin NA

Notes:

Material Types Abbreviations

M = Miscellaneous building material NQ = Not quantified

TSI = Thermal System Insulation NA = Not Analyzed

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

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

CH = Chrysotile Asbestos sq. ft. = square feet

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

Table 3 - Summary of Presumed Asbestos Containing Materials, Norwich Cabin Missaukee 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, Norwich Cabin Missaukee County, Michigan

Exterior - Asbestos Containing Materials

Location Material Description Friable Approx. Quantity

Cabin Roof (Structurally Unstable) Asphalt Roofing/Shingles No 410 sq. ft.

Total 410 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

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

Phone: 888.449.4566

Fax: 888.448.8739 www.redcedarconsulting.net

September 28, 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

Roscommon County, MI

Parcel ID: Roscommon Conservation Airport

Dear Ms. Conley:

Red Cedar Consulting has completed an asbestos-containing material (ACM) and hazardous materials inspection at Roscommon Conservation Airport Roscommon 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 an approximate 2,550 square foot

Aircraft Hanger (the Building) with an unknown construction date. The Building was constructed on a concrete slab with one aboveground floor. The exterior walls of the Building were finished with Transite

Siding over felt paper while the roof was sealed with asphalt shingles.

VISUAL INSPECTION AND SAMPLING

Asbestos Containing Materials Inspection

Aaron Paquet of Red Cedar Consulting (Red Cedar), accredited State Of Michigan/EPA Asbestos Building Inspector (Accreditation Numbers A30955) who completed training per the Michigan Asbestos

Workers Accreditation Act 440, completed an inspection of the Subject Property on September 5, 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.

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

• Transite Siding/Felt

• Fiberboard

Red Cedar staff collected six samples of suspect ACBM separated into three 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 six samples is included as

Attachment A.

Hazardous Materials Inspection

On September 5, 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, six 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

Transite siding over Felt Paper located on the exterior of the Building was sampled and found to contain up to 20% asbestos following analysis. The visual assessment to quantify the extent of this material identified approximately 2,000 sq. ft. of cementitious (Transite) siding on the Building.

RECOMMENDATIONS

Asbestos Containing Materials

Transite siding and Felt Paper underlayment was identified on the exterior of the Building and must be abated prior to completion of any demolition activities at the Subject Property. In demolition, all cementitious ACM must be removed prior to demolition due to the likelihood of becoming regulated due to the demolition process.

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

Hazardous Materials

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

• No Hazardous Materials Identified

REGULATORY REQUIREMENTS

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

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

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

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

Subject Property.

• Friable asbestos material.

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

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

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

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

Part 61).

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

NESHAP Asbestos Program MIOSHA-CSHD-Asbestos Program

Department of Environmental Quality State of Michigan

Phone: 517-284-6777 Phone: 517-284-7680 Email: asbestos@michigan.gov

DISCLAIMER

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

This report was prepared at the request and for exclusive use by the 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

Location:

Layer:

Location:

Layer:

Location:

Layer:

NVLAP Lab Code 102118-0

Material:

of 1

Rolled Roofing black,fibrous,homogenous black,fibrous,homogenous

Other - 80%

Material:

Cust. #:

Felt Paper/Transite

RC-HM-02A

79468 - 03

Appearance:

NOAsbestos Present:

YESAsbestos Present:

Rolled Roofing grey,fibrous,homogenous

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

2of1

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Chrysotile - 20%

Lab ID #:

Appearance:

Lansing, MI 48901

Appearance:

Sample Information Asbestos Type/Percent Non-Asbestos

Cust. #:

79468 - 01 Cellulose - 40%

No Asbestos Observed

Lab ID #:

09/05/18 09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Other - 60%

Project: Roscommon Construction Airport

Report To:

1of

Red Cedar Consulting

ARI Report # Date Collected:

18-79468 Mr. Aaron Paquet

Date Received:

Date Reported:

RC-HM-01A

RC-HM-01B

Lab ID #: Cellulose - 40%

Other - 60%

Material:

Cust. #:

79468 - 02 Asbestos Present:

No Asbestos Observed

NO

Robert T. Letarte Jr., Laboratory Director

09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Roscommon Construction Airport

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79468 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer:

Robert T. Letarte Jr., Laboratory Director

NVLAP Lab Code 102118-0

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Appearance: brown,fibrous,homogenous

79468 - 05 Asbestos Present:

Fiberboard

NO Cellulose - 80%

Felt Paper

Appearance:

NOT ANALYZED

Material:

Asbestos Present: Lab ID #:

RC-HM-02A No Asbestos Observed

Sample Information Asbestos Type/Percent Non-Asbestos

Cellulose - 30%

Material:

RC-HM-02B

79468 - 04

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

Lab ID #:

Material:

Cust. #:

Asbestos Present:

Other - 20%No Asbestos Observed

Cust. #:

RC-HM-03A

Lab ID #:

Cust. #:

of

NO79468 - 03a

Other - 70% Felt Paper black,fibrous,homogenousAppearance:

09/10/18 09/14/18P.O. Box 13216 Date Analyzed:

Project: Roscommon Construction Airport

Report To:

Red Cedar Consulting

ARI Report # Date Collected:

18-79468 Mr. Aaron Paquet

Date Received:

Date Reported:

Location:

Layer:

Location:

Layer:

Location:

Layer:

NVLAP Lab Code 102118-0 of Appearance:

Asbestos Present:

Material:

Lab ID #:

Material: Fiberboard

Appearance: brown,fibrous,homogenous

Cust. #: RC-HM-03B Other - 20%No Asbestos Observed

Cellulose - 80%Lab ID #: 79468 - 06 Asbestos Present: NO

Sample Information Asbestos Type/Percent Non-Asbestos

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 may not be used by the customer to claim product endorsement by NVLAP 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.

Robert T. Letarte Jr., Laboratory Director

Appearance:

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

of

Material:

Cust. #:

Lab ID #: Asbestos Present:

Cust. #:

Attachment B

Note: Figure created by Red Cedar Consulting Asbestos Sample Locations

Roscommon Conservation Airport -Not To Scale- Roscommon County, MI

Tables

Table 1 - Summary of Hazardous Materials, Roscommon Conservation Airport Roscommon County, Michigan

Hazardous Materials Description and Location

Location Material Description Quantity

No Hazardous Materials Identified

Table 2 - Summary of Sample Descriptions and Asbestos Laboratory Results, Roscommon Conservation Airport Roscommon County, Michigan

Sample

Number Sample Description Friable

Material

Type

Material

Classification

% Asbestos

Laboratory

Result

Sample Location Approx. Material

Quantity

RC-HM-01A Rolled Roofing No M Category I ND Roof N Side NA

RC-HM-01B Rolled Roofing No M Category I ND Roof S Side NA

RC-HM-02A Transite/Felt Paper Yes M Category II 20%CH/ND NE Corner 2,000 sq. ft.

RC-HM-02B Transite/Felt Paper Yes M Category II NA/ND SW Corner NA

RC-HM-03A Fiberboard Yes M Category II ND SE Wall NA

RC-HM-03B Fiberboard Yes M Category II ND SW Wall NA

Notes:

Material Types Abbreviations

M = Miscellaneous building material NQ = Not quantified

TSI = Thermal System Insulation NA = Not Analyzed

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

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

CH = Chrysotile Asbestos sq. ft. = square feet

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

Table 3 - Summary of Presumed Asbestos Containing Materials, Roscommon Conservation Airport Roscommon 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, Roscommon Conservation Airport Roscommon County, Michigan

Exterior - Asbestos Containing Materials

Location Material Description Friable Approx. Quantity

Building Exterior Transite Siding/Felt Paper No 2,000 sq. ft.

Total 2,000 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

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.