FULL MDNR_Hoeft State Park Contact Station_ACM LCP Survey Report (R).pdf

PRE-DEMOLITION ASBESTOS AND LIMITED LEAD-CONTAINING PAINT SURVEY

P.H. HOEFT STATE PARK- CONTACT STATION

5001 US-23 North.

Rogers City, MI 49779

Project #188BS22767

PREPARED FOR:

Michigan Department of Natural Resources

PREPARED BY:

Atlas Technical Consultants LLC 46555 Humboldt Drive, Suite 100 Novi, Michigan 48377 January 24, 2023

Page | 1

46555 Humboldt Drive, Suite 100 Novi, Michigan 48377

(248) 669-5147 | oneatlas.com

Subject: Pre-Demolition Asbestos and Limited Lead-Containing Paint Survey P.H. Hoeft State Park – Contact Station

5001 North US-23 Rogers City, MI 49779

Dear Mr. Dekett:

Atlas is pleased to present this report detailing the findings of the pre-demolition asbestos and limited lead-containing paint survey performed at the above referenced site. The purpose of this sampling was to identify and collect samples of suspect asbestos containing materials (ACMs) and lead-containing paint (LCP) prior to demolition activities.

The pre-demolition asbestos and lead-containing paint sampling was conducted on January 12, 2023 by Industrial Hygienist, Mr. Andrew DeLodder, State of Michigan certified asbestos inspector. The sampling was conducted in accordance with sampling criteria specified in the Occupational Safety and Health Administration’s (OSHA) Asbestos Construction Industry Standard (29 CFR 1926.1101), and the Asbestos Hazard and Emergency Response Act of 1987

(AHERA).

If you have any questions, please call us at 248.669.5140.

Respectfully submitted, Andrew DeLodder Martin Gamble State of Michigan Asbestos Inspector Project Manager Atlas Technical Consultants LLC Atlas Technical Consultants LLC

Atlanta, Michigan 49709 20500 M-33 North Clear Lake State Park Unit Supervisor Mr. David M Dekett

January 24, 2023

Page | i

CONTENTS

EXECUTIVE SUMMARY

1. INTRODUCTION

1.1 Purpose

1.2 Pre-Demolition Asbestos Survey

2. GENERAL SITE CONDITIONS

2.1 General Property and Building Information

2.2 Exterior Finish Descriptions

2.3 Interior Building Descriptions

3. PRE-DEMOLITION ASBESTOS SURVEY

3.1 Homogeneous Areas

3.2 Hazard Assessment Factors

3.3 Laboratory Analytical Methodology

3.4 Sampling Results

4. LEAD-CONTAINING PAINT SAMPLING

5. CONCLUSIONS AND RECOMMENDATIONS

5.1 Asbestos-Containing Materials

5.2 Lead-Containing Paint

6. ASSUMPTIONS AND LIMITATIONS

TABLES

Table 3-1 ACM Sampling Results

Table 4-1 Lead-Containing Paint Sampling Results

APPENDICES

Appendix A Asbestos Laboratory Report Appendix B Lead-Containing Paint Laboratory Report Appendix C Sample Location Maps

Page | 2

EXECUTIVE SUMMARY

Atlas representative Mr. Andrew DeLodder completed the pre-demolition asbestos and limited lead-containing paint survey of the Contact Station, located in P.H. Hoeft State Park at 5001 US-23 North, Rogers City, MI 49779 on January 12, 2023.

Thirty- Six (36) asbestos bulk samples, taken from Thirteen (13) homogenous areas, were collected from the Contact Station. Of the thirty-six (36) samples submitted, forty-three (43) sample layers were analyzed.

The results of laboratory testing indicated that two (2) of the suspect materials contained asbestos greater than 1%.

One (1) representative samples of paint, taken from interior and exterior areas of the Contact Station, were collected and submitted for analysis by Flame AAS. The results of laboratory testing indicated that all samples contained levels of lead greater than the laboratory reporting limits.

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

Page | 3

1. INTRODUCTION

1.1 Purpose

The purpose of this project was to conduct a pre-demolition asbestos and limited lead-containing paint survey the Contact Station located in P.H. Hoeft State Park at 5001 US-23 North, Rogers City, MI 49779 (herein referred to as “the property”).

1.2 Pre-Demolition Asbestos Survey

The scope of the pre-demolition asbestos survey included the following:

Review of existing asbestos reports for the building, if available;

Survey of the property building(s);

Identification of accessible suspect asbestos-containing materials (ACMs);

Collection and analysis of bulk samples of suspect friable and non-friable materials.

2. GENERAL SITE CONDITIONS

2.1 General Property and Building Information

General property and building information is presented in the following table:

General Property and Building Information

Date of Inspection: January 12, 2023

Inspectors Andrew Delodder, Inspector # A48677

Property Address: 5001 US-23 North, Rogers City, MI 49779

Property Owner Michigan Department of Natural Resources

Building Description: P.H. Hoeft State Park Contact Station miscellaneous materials; and

> Identifying homogeneous areas (HAs) of suspect surfacing, thermal system insulation, and

> Conducting a visual inspection of the structures;

procedures:

rubber, wood, etc.) were not sampled. The asbestos inspection consisted of the following three basic accredited laboratory for analysis. Materials typically known as non-asbestos items (i.e. fibrous glass, foam placed into individual containers for transport to a National Voluntary Lab Accreditation Program (NVLAP)-materials that are suspected to contain asbestos. Bulk samples of suspect ACMs were collected and Inspector’s (Certification No. A48677). The building was visually inspected for the presence of building building as indicated above on January 12, 2023. Mr. DeLodder is a State of Michigan Certified Asbestos Atlas representative Mr. Andrew DeLodder conducted the pre-demolition asbestos inspection of the property

3. PRE-DEMOLITION ASBESTOS SURVEY

The interior finishes of the buildings included plastered walls and ceiling, and floor tiled floors.

2.3 Interior Building Descriptions

The exterior of the buildings included brick and masonry with a shingled-sloped roof.

2.2 Exterior Finish Descriptions

Page | 4

> Sampling accessible, friable and non-friable suspect materials.

3.1 Homogeneous Areas

Prior to collecting any samples, homogenous areas (HAs) were identified. A homogeneous sampling area can be described as one or more areas of material that are similar in appearance and texture and that have the same apparent installation date, appearance and function. Actual number of samples collected from each homogeneous sampling area may vary, based on the type of material and professional opinion of the inspector.

3.2 Hazard Assessment Factors

From the list of suspect homogeneous areas, a physical assessment was performed for each material on the list. A physical assessment includes evaluating the condition, assessing the potential for disturbance, and determining the friability of each material. By definition, "friable" materials are those that can be crumbled or reduced to powder by hand pressure when dry. Each material identified was further classified into one of three categories: surfacing materials, thermal systems insulation (TSI) and miscellaneous materials. Each of the three categories have specific sampling requirements, outlined below.

Surfacing Materials: Refers to spray-applied or troweled surfaces such as plaster ceilings and walls, fireproofing, textured paints, textured plasters, and spray-applied acoustical surfaces.

Thermal System Insulation: Refers to insulation used to inhibit heat gain or loss on pipes, boilers, tanks, ducts, and various other building components.

Miscellaneous Materials: Refers to friable and non-friable products and materials that do not fit in any of the above two categories such as resilient floor covering, baseboards, mastics, adhesives, roofing material, caulking, glazing, and siding. This category also contains wallboard and ceiling tile.

All materials were assessed related to their condition in one of the three categories: good (intact), fair

(damaged) or poor (significantly damaged) per Title 40 Code of Federal Regulations Part 763. Material with localized, significant damage was also assessed as poor.

3.3 Laboratory Analytical Methodology

Bulk samples were analysed by Environmental Testing Laboratories, Inc. (ETL) using polarized-light microscopy (PLM) and dispersion staining (Method Reference: 40 CFR Part 763, Volume 47, No. 103, May

27, 1982 pg. 23376). This laboratory participates in the National Voluntary Laboratory Accreditation Program

(NVLAP #201028-0), a quality assurance program for PLM analysis, and is accredited by the National Institute of Standards and Technology (NIST) as well as accreditation requirements under 15 CFR Part 25.

Copies of the laboratory analytical report and corresponding chain-of-custody forms are included in

Appendix A and sample location drawings are provided in Appendix C. Positive sample results are reported in percent asbestos by volume of the sample and the type of asbestos material within the sample.

Other common non-asbestos components may also be noted on the analytical reports.

3.4 Sampling Results

Bulk samples were collected from the site building and analysed by polarized light microscopy (PLM), EPA

Method 600/R-93/116.

The following table provides a summary of accessible suspect and confirmed ACMs from the Site buildings:

Page | 5

Table 3-1 ACM Sampling Results

P.H. Hoeft State Park Contact Station

Sampled On: January 12, 2023

Sample ID/Material

Location of Materials

Material Estimated Quantity

Asbestos Content

1-RM-A,B,C EA-5 Roofing Materials- Asphalt Shingle NA ND

2-CC-A,B,C EA-1,4 Concrete Chip- Exterior Concrete NA ND

3-CC-A,B,C EA-1,2,3 Concrete Chip- Poured Concrete Foundation NA ND

4-EC-A,B,C EA-4 Exterior Caulk- Brown, along Wood Trim, Roofline NA ND

5-EC-A,B,C EA-2

Exterior Caulk- Beige, Intermittently Along Window Frames, on Electrical Penetration

PLM 5% Chrysotile

6-EC-A,B,C EA-2 Exterior Caulk- Gray on Electrical Utility Conduit NA ND

7-WG-A,B,C FS-1 Window Glaze- Multi-Pane Fold Down Windows NA ND

8-WBS-A,B,C FS-1,2 Wallboard Ceiling NA ND

9-FT-A,B,C FS-1,2 Floor Tile 12” Mottled Beige, Gray, & Red Colors NA ND

10-IC-A,B,C FS-2 Interior caulk - Beige, on AC Window Insert NA ND

11-IC-A,B,C FS-2

Interior Caulk - Grey, Around Base of Toilet & Plumping Penetration

NA ND

12-IC-A,B,C FS-1 Interior Caulk - White, Seams of Cabinets NA ND

13 FS-3 Vermiculite

EA=Exterior Area FS Functional Space NA=Not Applicable ND= None Detected

In the event additional suspect material is discovered during renovation activities, this material should be treated as presumed asbestos-containing material (PACM) in accordance with regulations 29 CFR

1926.1101 and 1910.1001 and other applicable state and local regulations and either sampled to confirm or nullify asbestos content or be treated as ACM and handled accordingly.

4. LEAD-CONTAINING PAINT SAMPLING

Atlas representative Mr. Andrew DeLodder conducted the lead-containing paint (LCP) sampling of Contact

Station on January 12, 2023. The sampling included physical sampling of paint coatings that were deemed representative of the predominant paint coatings observed.

One (1) paint chip sample was collected from the contact station and submitted to Accurate Analytical

Testing Laboratory, 30105 Beverly Road, Romulus, Michigan for lead analysis. Bulk samples were analyzed using the Environmental Protection Agency's Test Method SW 846 -7420 and 3050B using Flame

AAS to determine lead concentration in percent (%) by weight. Copies of the laboratory analytical report and corresponding chain-of-custody forms are included in Appendix B.

20 SF

NOT SAMPLED

ASSUMED,330 SF

Page | 6

The following table provides a summary of the LCP sampling:

Table 4-1 Lead-Containing Paint Sampling Results

Sample ID Sample Location Color Lead

Content

1-LBP-Brown Exterior Paint Brown 0.0003

5. CONCLUSIONS AND RECOMMENDATIONS

5.1 Asbestos-Containing Materials

The results of laboratory testing during the pre-renovation asbestos survey conducted at the property indicate that the following materials sampled were found to contain asbestos:

Sample ID/Material Location of Materials

Material Estimated Quantity

Asbestos Content

5-EC-A,B,C EA-2

Exterior Caulk- Beige, Intermittently Along Window Frames, on Electrical Penetration

PLM 5% Chrysotile

13 FS-3 Vermiculite

ASSUMED,

NOT SAMPLED

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

5.2 Lead-Containing Paint

One (1) representative sample of paint, taken from interior and exterior areas at the Contact Statiom, were collected and submitted for analysis by Flame AAS. The results of laboratory testing indicated that one (1) sample contained levels of lead greater than the laboratory reporting limits.

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

The presence of Lead-Containing Paint (LCP) and/or Lead-Based Paint (LBP) does not, in itself, trigger regulatory compliance actions. However, when these materials are disturbed, the requirements of OSHA

(1926.1101) and EPA may become operative. Appropriate actions in terms of removal methods, emissions control, worker protection, and waste disposal should be considered by the general contractor and applicable subcontractors while completing renovation activities.

20 SF

330 SF

Page | 7

6. ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during the NESHAP inspections conducted on January 12, 2023 performed by

Atlas. Selection of sample locations and frequency of sampling were based on EPA Guidance documents, Atlas’s observations, and the assumption that building vintage and renovation history information presented to Atlas allowed the proper designation of homogenous materials for each building.

This document does not contain the elements necessary for an Abatement Work plan, and this document does not contain, nor should it take the place of technical specifications for ACM removal.

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

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

APPENDIX A

ASBESTOS LABORATORY REPORT

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

(734) 955-6600

Fax: (734) 955-6604

To:

Attention:

Atlas - Novi

46555 Humboldt Dr. Suite 100

Novi, Michigan 48377

Project Location:

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

Client Project: 188BS22767

254189ETL Job:

Report Date: 1/23/2023

Robert Smith

Lab Sample Number Client Sample Number Sample Type Completed

1446198 Asbestos1-RM-A 01/20/2023

1446199 Asbestos1-RM-B 01/20/2023

1446200 Asbestos1-RM-C 01/20/2023

1446201 Asbestos2-CC-A 01/20/2023

1446202 Asbestos2-CC-B 01/20/2023

1446203 Asbestos2-CC-C 01/20/2023

1446204 Asbestos3-CC-A 01/20/2023

1446205 Asbestos3-CC-B 01/20/2023

1446206 Asbestos3-CC-C 01/20/2023

1446207 Asbestos4-EC-A 01/20/2023

1446208 Asbestos4-EC-B 01/20/2023

1446209 Asbestos4-EC-C 01/20/2023

1446210 Asbestos5-EC-A 01/20/2023

1446211 Asbestos5-EC-B 01/20/2023

1446212 Asbestos5-EC-C 01/20/2023

1446213 Asbestos6-EC-A 01/20/2023

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

Lab Sample Number Client Sample Number Sample Type Completed

1446214 Asbestos6-EC-B 01/20/2023

1446215 Asbestos6-EC-C 01/20/2023

1446216 Asbestos7-WG-A 01/20/2023

1446217 Asbestos7-WG-B 01/20/2023

1446218 Asbestos7-WG-C 01/20/2023

1446219 Asbestos8-WBS-A 01/20/2023

1446220 Asbestos8-WBS-B 01/20/2023

1446221 Asbestos8-WBS-C 01/20/2023

1446222 Asbestos9-FT-A 01/20/2023

1446223 Asbestos9-FT-B 01/20/2023

1446224 Asbestos9-FT-C 01/20/2023

1446225 Asbestos10-IC-A 01/20/2023

1446226 Asbestos10-IC-B 01/20/2023

1446227 Asbestos10-IC-C 01/20/2023

1446228 Asbestos11-IC-A 01/20/2023

1446229 Asbestos11-IC-B 01/20/2023

1446230 Asbestos11-IC-C 01/20/2023

1446231 Asbestos12-IC-A 01/20/2023

1446232 Asbestos12-IC-B 01/20/2023

1446233 Asbestos12-IC-C 01/20/2023

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

Lab Sample Number Client Sample Number Sample Type Completed

Reviewed by:

Summary

Sample Layer MasticMethod

PLM 40 3Emily Nowacki

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

Certificate of Analysis

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446198

1-RM-A

PLM 97% OtherPLM 3% CelluloseBlackAsphalt Shingle

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446199

1-RM-B

PLM 97% OtherPLM 3% CelluloseBlackAsphalt Shingle

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446200

1-RM-C

PLM 97% OtherPLM 3% CelluloseBlackAsphalt Shingle

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446201

2-CC-A

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446202

2-CC-B

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446203

2-CC-C

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446204

3-CC-A

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446205

3-CC-B

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446206

3-CC-C

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446207

4-EC-A

PLM 98% OtherPLM 2% CelluloseBrownExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446208

4-EC-B

PLM 98% OtherPLM 2% CelluloseBrownExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446209

4-EC-C

PLM 98% OtherPLM 2% CelluloseBrownExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM 5% Chrysotile1446210

5-EC-A

PLM 93% OtherPLM 2% CelluloseBeigeExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

1446211

5-EC-B

Positive Stop

Analyst: Alex Noble

Date Analyzed : 01/20/2023

Sample Not Analyzed

1446212

5-EC-C

Positive Stop

Analyst: Alex Noble

Date Analyzed : 01/20/2023

Sample Not Analyzed

PLM None Detected 1446213

6-EC-A

PLM 98% OtherPLM 2% CelluloseGrayExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446214

6-EC-B

PLM 98% OtherPLM 2% CelluloseGrayExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446215

6-EC-C

PLM 98% OtherPLM 2% CelluloseGrayExterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446216

7-WG-A

PLM 97% OtherPLM 3% CelluloseGrayWindow Glaze

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446217

7-WG-B

PLM 97% OtherPLM 3% CelluloseGrayWindow Glaze

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446218

7-WG-C

PLM 97% OtherPLM 3% CelluloseGrayWindow Glaze

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446219

8-WBS-A

PLM 98% OtherPLM 2% CelluloseWhiteWallboard System

Non-Fibrous

Homogenous Layer-1 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446219

8-WBS-A

PLM 4% OtherPLM 96% CelluloseBeigeTape

Fibrous

Homogenous Layer-2 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446219

8-WBS-A

PLM 97% OtherPLM 3% CelluloseWhiteJoint Compound

Non-Fibrous

Homogenous Layer-3 Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446220

8-WBS-B

PLM 98% OtherPLM 2% CelluloseWhiteWallboard System

Non-Fibrous

Homogenous Layer-1 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446220

8-WBS-B

PLM 4% OtherPLM 96% CelluloseBeigeTape

Fibrous

Homogenous Layer-2 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446220

8-WBS-B

PLM 97% OtherPLM 3% CelluloseWhiteJoint Compound

Non-Fibrous

Homogenous Layer-3 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446221

8-WBS-C

PLM 98% OtherPLM 2% CelluloseWhiteWallboard System

Non-Fibrous

Homogenous Layer-1 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446221

8-WBS-C

PLM 4% OtherPLM 96% CelluloseBeigeTape

Fibrous

Homogenous Layer-2 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446221

8-WBS-C

PLM 97% OtherPLM 3% CelluloseWhiteJoint Compound

Non-Fibrous

Homogenous Layer-3 Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446222

9-FT-A

PLM 98% OtherPLM 2% CelluloseBeige12" Floor Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446222

9-FT-A

PLM 97% OtherPLM 3% CelluloseBlackMastic

Non-Fibrous

Homogenous Layer-2 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446223

9-FT-B

PLM 98% OtherPLM 2% CelluloseBeige12" Floor Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446223

9-FT-B

PLM 97% OtherPLM 3% CelluloseBlackMastic

Non-Fibrous

Homogenous Layer-2 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446224

9-FT-C

PLM 98% OtherPLM 2% CelluloseBeige12" Floor Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446224

9-FT-C

PLM 97% OtherPLM 3% CelluloseBlackMastic

Non-Fibrous

Homogenous Layer-2 Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446225

10-IC-A

PLM 98% OtherPLM 2% CelluloseTanInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446226

10-IC-B

PLM 98% OtherPLM 2% CelluloseTanInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446227

10-IC-C

PLM 98% OtherPLM 2% CelluloseTanInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446228

11-IC-A

PLM 98% OtherPLM 2% CelluloseGrayInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446229

11-IC-B

PLM 98% OtherPLM 2% CelluloseGrayInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446230

11-IC-C

PLM 98% OtherPLM 2% CelluloseGrayInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

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

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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Novi,Michigan 48377

Atlas - Novi

46555 Humboldt Dr. Suite 100

P.H. Hoeft State Park-Contact Station

5001 US-23, Rogers City, MI

ETL Job :

Client Project :

254189

188BS22767

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive

Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/12/2023

01/18/2023

Date Collected :

Date Received :

PLM None Detected 1446231

12-IC-A

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446232

12-IC-B

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

PLM None Detected 1446233

12-IC-C

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Analyst: Alex Noble

Date Analyzed : 01/20/2023

Lab Supervisor/Other Signatory

Alex Noble

Analyst:

400 Point Count Results by EPA 600/R-93/116 PLM (denoted by "PC")

Item 198.1: PLM Methods for Identifying and Quantitating Asbestos in Bulk Samples

Item 198.6: PLM Methods for Identifying and Quantitating Asbestos in Non-Friable Organically Bound Bulk Samples

EPA 600/R-93/116: Method for Determination of Asbestos in Bulk Building Materials

EPA 600/M4-82-020: Interim Method for Determination of Asbestos in Bulk Insulation Samples

A % Asbestos result of "Trace" indicates that the analyzed material was found to contain less than 1% asbestos and would not be considered an Asbestos Containing Material (ACM).

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

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

APPENDIX B

LEAD-CONTAINING PAINT LABORATORY REPORT

Client Project :

874035

01/16/2023

01/17/2023

Date Reported :

Date Analyzed :

Date Received :

AAT Project :

Phone :

Email :

Fax : 248-669-5147 dawn.lecesne@oneatlas.com

248-669-5140

Dawn LeCesne

Atlas Technical Consultants

Attn :

Client :

PH HOEFT STATE PARK - CONTACT STATIONProject Location :

188BS22767

Novi, MI 48377

46555 Humboldt Dr.

30105 Beverly Road

Romulus, MI 48174

Ph: 734-629-8161; Fax: 734-629-8431

Sampling Date : 01/12/2023

01/18/2023

Certificate of Analysis: Lead In Paint by EPA SW-846 Method 7000B/3050B*

Lab Sample ID Result Lead

(% by weight) PPMSample DescriptionClient Code

Calculated R L

(% by weight)

1-LBP-BROWN EXTERIOR BROWN PAINT8081781 3 0.0003 0.0006

Analyst Signature

Comment: Both laboratory controls are out of range.

Richard Laugal

874035 AAT Project:Date Printed: 01/18/2023 3:01PM

ND = Not Detected, N/A = Not Available, RL = Reporting Limit, Analytical Reporting Limit is 5 ug/sample. For true values assume (2) significant figures.

The method, batch, and sample Quality Control are acceptable unless otherwise stated. AAT internal SOP S218. The laboratory operates in accord with

ISO 17025 guidelines and holds limited scopes of accreditation under AIHA-LAP and NY State DOH ELAP programs. These results are submitted pursuant to AAT, LLC current terms and conditions of sale, including the company's standard warranty and limitation of liability provisions. Analytical results relate to the samples as received by the lab. Results in mg/cm2 are calculated based on sample area dimensions supplied by the client.AAT will not assume any liability or responsibility for the manner in which the results are used or interpreted. Reproduction of this document other than in its entirety is not authorized by AAT, LLC. AAT does not blank correct reported values. Sample data apply only to items analyzed. Current EPA/HUD Interim

Standard for lead in paint samples is: 5000 PPM (parts per million) or ug/g which is equivalent to 0.5% by weight. EPA definition of lead-based paint: 1.0 mg/cm2. New York City Regulatory Limits: 0.25% by weight or 0.5 mg/cm2 for investigations for a child. MD and Philadelphia definition of lead-based paint: 0.7 mg/cm2. Note: Samples are stored for 15 days following report date. *= Validated modified method

AIHA LAP- Lab ID #100986, NY State DOH ELAP -Lab ID #11864, State of Ohio- Lab ID # 10042

Atlas Technical ConsultantsTo :

Attn :

Phone :

AAT Project :

Client Project :

Date Reported :

Project Location :

Email :Dawn LeCesne

248-669-5140 dawn.lecesne@oneatlas.com

874035

188BS22767

PH HOEFT STATE PARK - CONTACT STATION

46555 Humboldt Dr.

Novi, MI 48377

30105 Beverly Road

Romulus, MI 48174

Ph: 734-629-8161; Fax: 734-629-8431

01/18/2023

Sample CompletedAnalysis RequestedClient Code Analyst

8081781 01/17/2023Lead Paint1-LBP-BROWN Richard Laugal

Quality Assurance Coordinator

Reviewed By Elyse Bidle

874035 AAT Project:Date Printed: 01/18/2023 3:01PM

This report is intended for use solely by the individual or entity to which it is addressed. It may contain information that is privileged, confidential and otherwise exempt by law from disclosure. If the reader of this information is not the intended recipient or an employee of its intended recipient, you are herewith notified that any dissemination, distribution or copying of this information is strictly prohibited. If you have received this information in error, please notify AAT immediately. Thank you.

NY State DOH ELAP -Lab ID #11864, Michigan State Lab # 9996

APPENDIX C

SAMPLE LOCATION MAPS

Asbestos bulk

Sampling Location Map

P.H. Hoeft State Park

Contact Station – ground level

PROJECT NUMBER: 188BS22767

DRAWN BY: AHD REVIEWED BY Atlas

FIGURE:

DATE: 1.12.2023

4 6 5 5 5 H u m b o l d t D r i v e , S u i t e 1 0 0

N o v i , M i c h i g a n 4 8 3 7 7

P h : ( 2 4 8 ) 6 6 9 - 5 1 4 0 ~ F a x : ( 2 4 8 ) 6 6 9 - 5 1 4 7

## = Sample Number

= Sample Location

P.H. Hoeft State Park

Contact Station

5001 US-23,

Rogers City, MI 49779

Map Key

EA-1

EA-2

EA-3

EA-4

Roof: EA-5

FS-1

FS-2

1-RM-A

1-RM-B

1-RM-C

2-CC-A

3-CC-B

3-CC-C

2-CC-B

2-CC-C

3-CC-A

4-EC-A

4-EC-B

4-EC-C

5-EC-A

5-EC-B

5-EC-C

6-EC-A,B,C

7-WG-A,B

7-WG-C

8-WBS-A

8-WBS-B

8-WBS-C

9-FT-A

9-FT-B

9-FT-C

10-IC-A,B,C

11-IC-A,B,C

12-IC-A,B,C

Asbestos bulk

Sampling Location Map

P.H. Hoeft State Park

Contact Station - attic

PROJECT NUMBER: 188BS22767

DRAWN BY: AHD REVIEWED BY Atlas

FIGURE:

DATE: 1.12.2023

4 6 5 5 5 H u m b o l d t D r i v e , S u i t e 1 0 0

N o v i , M i c h i g a n 4 8 3 7 7

P h : ( 2 4 8 ) 6 6 9 - 5 1 4 0 ~ F a x : ( 2 4 8 ) 6 6 9 - 5 1 4 7

## = Sample Number

= Sample Location

P.H. Hoeft State Park

Contact Station

5001 US-23,

Rogers City, MI 49779

Map Key

EA-1

EA-2

EA-3

EA-4

Roof: EA-5

FS-3

13-VER