Full MDNR_Hoeft State Park East West Restroom Bldgs_ACM LCP Survey Report_2023_0116.pdf

PRE-DEMOLITION ASBESTOS AND LIMITED LEAD-CONTAINING PAINT SURVEY

P.H. HOEFT STATE PARK

East & West Toilet Shower Buildings

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 16, 2023

Page | 1

46555 Humboldt Drive, Suite 100 Novi, Michigan 48377

(248) 669-5147 | oneatlas.com

January 16, 2023

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

Subject: Pre-Demolition Asbestos and Limited Lead-Containing Paint Survey P.H. Hoeft State Park - East & West Toilet Shower Buildings

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 December 8, 2022 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

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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 ............................................................................................5-6

Table 4-1 Lead-Containing Paint Sampling Results

APPENDICES

Appendix A Asbestos Laboratory Report Appendix B Lead-Containing Paint Laboratory Report

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EXECUTIVE SUMMARY

Atlas representative Mr. Andrew DeLodder completed the pre-demolition asbestos and limited lead-containing paint survey of the East and West Toilet Shower Buildings, located in P.H. Hoeft State Park at 5001 US-23 North, Rogers City, MI 49779 on December 8, 2022.

Forty-Five (45) asbestos bulk samples, taken from fifteen (15) homogenous areas, were collected from the

East Toilet Shower Building. Of the 45 samples submitted, fifty-nine (59) sample layers were analyzed.

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

Sixty (60) asbestos bulk samples, taken from twenty (20) homogenous areas, were collected from the West

Toilet Shower building. Of the 60 samples submitted, seventy-five sample layers were analyzed. The results of laboratory testing indicated that three (3) of the suspect materials contained asbestos greater than 1%.

Two (2) representative samples of paint, taken from interior and exterior areas of the East Toilet Shower

Building, and two (2) from the West Toilet Shower Building, were collected and submitted for analysis by

Flame AAS. The results of laboratory testing indicated that all four (4) 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.

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1. INTRODUCTION

1.1 Purpose

The purpose of this project was to conduct a pre-demolition asbestos and limited lead-containing paint survey the East and West Toilet Shower Buildings 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

The purpose of this project was to conduct a pre-demolition asbestos and limited lead-containing paint survey of the East and West Toilet Shower Buildings, located in P.H. Hoeft State Park at 5001 US-23 North, Rogers City, MI 49779.

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

General Property and Building Information

Date of Inspection: December 8, 2022

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 East and West Bathroom Buildings

2.2 Exterior Finish Descriptions

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

2.3 Interior Building Descriptions

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

3. PRE-DEMOLITION ASBESTOS SURVEY

Atlas representative Mr. Andrew DeLodder conducted the pre-demolition asbestos inspection of the property buildings as indicated above on December 8, 2022. Mr. DeLodder is a State of Michigan Certified Asbestos

Inspector’s (Certification No. A48677). The building was visually inspected for the presence of building materials that are suspected to contain asbestos. Bulk samples of suspect ACMs were collected and placed into individual containers for transport to a National Voluntary Lab Accreditation Program (NVLAP)-accredited laboratory for analysis. Materials typically known as non-asbestos items (i.e. fibrous glass, foam rubber, wood, etc.) were not sampled. The asbestos inspection consisted of the following three basic procedures:

Page | 4

> Conducting a visual inspection of the structures;

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

> 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. 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:

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Table 3-1 ACM Sampling Results

Sample ID/Material

Location of Materials

Material Estimated Quantity

Asbestos Content

East Toilet Shower Building

1-RM-A,B,C EA-5

Roofing Material –

Asphalt Shingle

NA ND

2-CC-A,B,C EA-1,2,4

Concrete Chip –

Exterior Concrete

NA ND

3-GM-A,B,C FS-1,3

1" Multi- Color Tile-

Ceramic Tile, Grout, & Mortar NA ND

4-GM-A,B,C FS-1

6" Beige Tile-

Ceramic Tile, Grout, & Mortar

NA ND

5-WG-A,B,C EA-1

Window Glaze - Black, on Interior Side of

Windows windows PLM 2 % Chrysotile

6-CC-A,B,C FS-2

Concrete Chip –

Poured Concrete Pad Foundation

NA ND

7-BM-A,B,C EA-3

Brick Mortar –

Rock Garden Planters

NA ND

8-IC-A,B,C FS-1

Interior Caulk – Beige, on Perimeter of Ceiling Penetrations

NA ND

9-IC-A,B,C FS-1

Interior Caulk –

White, on Toilets & Sinks

NA ND

10-GM-A,B,C FS-1

16" Grey Wall Tile-

Ceramic Tile, Grout, & Mortar

NA ND

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

Vapor Paper – Black, on Walls of Mechanical Room

NA ND

12-PI-A,B,C FS-2

Pipe Insulation –

Canvas Wrapped Fiberglass

NA ND

13-PF-A,B,C FS-2 Pipe Fittings - Mudded Fittings 15 fittings PLM 6% Chrysotile

14-FB-A,B,C FS-2 Fire Brick -Under Water Heater NA ND

15-VP-A,B,C FS-4

Vapor Paper –

Black, on Floor of Attic

NA ND

West Toilet Shower Building

1-RM-A,B,C EA-5 Roofing Material- Original Portion NA ND

2-WG-A,B,C EA-1,2,4

Window Glaze- White, in Metal

Windows 6 windows PLM 2% Chrysotile

3-BM-A,B,C EA-1 Stone Foundation NA ND

4-EC-A,B,C EA-1,2,4

Exterior Caulk- Brown, on Door/Window Frames, and Roofline- on Original Portion

NA ND

5-CC-A,B,C EA-1 & FS-3

Concrete Chip-

Poured Concrete Foundation

NA ND

6-EC-A,B,C EA-2,3,4

Exterior Caulk- Brown, on Door/Window

Frames, and Roofline-on Additional Portion

130 LF PLM 2% Chrysotile

7-RM-A,B,C EA-5 Roofing Material- Additional Portion NA ND

8-GM-A,B,C FS- 1,6

6" Red Floor Tile-

Ceramic Tile, Grout, & Mortar

NA ND

9-GM-A,B,C FS- 1,6 1" Multi- Colored Tile, Counter- Ceramic Tile, Grout, & Mortar

NA ND

10-WBS-A,B,C FS- 1,6 Wallboard System NA ND

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Sample ID/Material

Location of Materials

Material Estimated Quantity

Asbestos Content

West Toilet Shower Building, continued

11-IC-A,B,C FS- 1,6

Interior Caulk- White, Perimeter of Ceiling, Toilets

NA ND

12-IC-A,B,C FS- 1,6 & EC Interior Caulk- Beige, Around Counter NA ND

13-GM-A,B,C FS-2,4,5

2" Beige Floor Tile-

Ceramic Tile, Grout, & Mortar

NA ND

14-GM-A,B,C FS-2,4,5

8" Beige Wall Tile-

Ceramic Tile, Grout, & Mortar

NA ND

15-RI-A,B,C FS-3

Rolled-in Insulation –

Pink with Brown Paper

NA ND

16-CB-A,B,C FS-3

Cement board - Walls of Showers Under

Ceramic Tile

NA ND

17-CA-A,B,C FS-3

Construction Adhesive, Beige, Between Wall Studs & Plywood

NA ND

18-RI-A,B,C FS-3

Rolled-in Insulation –

Yellow with Black and Brown

NA ND

19-FB-A,B,C FS-3 Fire brick - Under Water Heater NA ND

20-TS-A,B,C FS-3

Transite Panel –

Remnants Nailed to Joints Above Shower Areas

15 SF PLM 8% Chrysotile

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 the East and West Toilet Shower Buildings on December 8, 2022. The sampling included physical sampling of paint coatings that were deemed representative of the predominant paint coatings observed.

Four (4) paint chip samples were collected from east and west buildings 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.

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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

East Toilet Shower Building

1-LBP-Brown Exterior Paint Brown 0.0058

2- LBP-Beige Interior Paint Beige 0.0009

West Toilet Shower Building

1-LBP-Brown Exterior Paint Brown 0.0058

2- LBP-Black Window Paint Black 0.0050

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

East Toilet Shower Building

5-WG-A,B,C EA-1

Window Glaze - Black, on Interior

Side of Windows

Windows PLM 2% Chrysotile

13-PF-A,B,C FS-2 Pipe Fittings - Mudded Fittings 15 fittings PLM 6% Chrysotile

West Toilet Shower Building

2-WG-A,B,C EA-1,2,4

Window Glaze- White, in Metal

Windows 6 windows PLM 2% Chrysotile

6-EC-A,B,C EA-2,3,4

Exterior Caulk- Brown, on Door/Window Frames, & Roofline-On Additional Portion

130 LF PLM 2% Chrysotile

20-TS-A,B,C FS-3

Transite Panel –

Remnants Nailed to Joints Above Shower Areas

15 SF PLM 8% Chrysotile

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

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5.2 Lead-Containing Paint

Four (4) representative samples of paint, taken from interior and exterior areas at the east and west toilet shower buildings, were collected and submitted for analysis by Flame AAS. The results of laboratory testing indicated that four (4) samples 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.

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 December 8, 2022 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 - East Building

5001 US-23, Rogers City MI

Client Project: 188BS22767

253483ETL Job:

Report Date: 12/30/2022

Robert Smith

Lab Sample Number Client Sample Number Sample Type Completed

1435962 Asbestos1-RM-A 12/30/2022

1435963 Asbestos1-RM-B 12/30/2022

1435964 Asbestos1-RM-C 12/30/2022

1435965 Asbestos2-CC-A 12/30/2022

1435966 Asbestos2-CC-B 12/30/2022

1435967 Asbestos2-CC-C 12/30/2022

1435968 Asbestos3-GM-A 12/30/2022

1435969 Asbestos3-GM-B 12/30/2022

1435970 Asbestos3-GM-C 12/30/2022

1435971 Asbestos4-GM-A 12/30/2022

1435972 Asbestos4-GM-B 12/30/2022

1435973 Asbestos4-GM-C 12/30/2022

1435974 Asbestos5-WG-A 12/30/2022

1435975 Asbestos5-WG-B 12/30/2022

1435976 Asbestos5-WG-C 12/30/2022

1435977 Asbestos6-CC-A 12/30/2022

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

1435978 Asbestos6-CC-B 12/30/2022

1435979 Asbestos6-CC-C 12/30/2022

1435980 Asbestos7-BM-A 12/30/2022

1435981 Asbestos7-BM-B 12/30/2022

1435982 Asbestos7-BM-C 12/30/2022

1435983 Asbestos8-IC-A 12/30/2022

1435984 Asbestos8-IC-B 12/30/2022

1435985 Asbestos8-IC-C 12/30/2022

1435986 Asbestos9-IC-A 12/30/2022

1435987 Asbestos9-IC-B 12/30/2022

1435988 Asbestos9-IC-C 12/30/2022

1435989 Asbestos10-GM-A 12/30/2022

1435990 Asbestos10-GM-B 12/30/2022

1435991 Asbestos10-GM-C 12/30/2022

1435992 Asbestos11-VP-A 12/30/2022

1435993 Asbestos11-VP-B 12/30/2022

1435994 Asbestos11-VP-C 12/30/2022

1435995 Asbestos12-PI-A 12/30/2022

1435996 Asbestos12-PI-B 12/30/2022

1435997 Asbestos12-PI-C 12/30/2022

1435998 Asbestos13-PF-A 12/30/2022

1435999 Asbestos13-PF-B 12/30/2022

1436000 Asbestos13-PF-C 12/30/2022

1436001 Asbestos14-FB-A 12/30/2022

1436002 Asbestos14-FB-B 12/30/2022

1436003 Asbestos14-FB-C 12/30/2022

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

1436004 Asbestos15-VP-A 12/30/2022

1436005 Asbestos15-VP-B 12/30/2022

1436006 Asbestos15-VP-C 12/30/2022

Reviewed by:

Summary

Sample Layer MasticMethod

PLM 59Emily 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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435962

1-RM-A

PLM 96% OtherPLM 4% CelluloseBrown/BlackRoofing Material

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435963

1-RM-B

PLM 96% OtherPLM 4% CelluloseBrown/BlackRoofing Material

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435964

1-RM-C

PLM 96% OtherPLM 4% CelluloseBrown/BlackRoofing Material

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435965

2-CC-A

PLM 99% OtherPLM 1% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435966

2-CC-B

PLM 99% OtherPLM 1% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435967

2-CC-C

PLM 99% OtherPLM 1% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435968

3-GM-A

PLM 99% OtherPLM 1% CelluloseMulti ColorCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435968

3-GM-A

PLM 99% OtherPLM 1% CelluloseRedGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435968

3-GM-A

PLM 99% OtherPLM 1% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435969

3-GM-B

PLM 99% OtherPLM 1% CelluloseMulti ColorCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435969

3-GM-B

PLM 99% OtherPLM 1% CelluloseRedGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435969

3-GM-B

PLM 99% OtherPLM 1% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435970

3-GM-C

PLM 99% OtherPLM 1% CelluloseMulti ColorCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435970

3-GM-C

PLM 99% OtherPLM 1% CelluloseRedGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435970

3-GM-C

PLM 99% OtherPLM 1% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435971

4-GM-A

PLM 98% OtherPLM 2% CelluloseBeigeCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435971

4-GM-A

PLM 98% OtherPLM 2% CelluloseRedGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435971

4-GM-A

PLM 98% OtherPLM 2% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435972

4-GM-B

PLM 98% OtherPLM 2% CelluloseBeigeCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435972

4-GM-B

PLM 98% OtherPLM 2% CelluloseRedGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435972

4-GM-B

PLM 98% OtherPLM 2% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435973

4-GM-C

PLM 98% OtherPLM 2% CelluloseBeigeCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435973

4-GM-C

PLM 98% OtherPLM 2% CelluloseRedGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435973

4-GM-C

PLM 98% OtherPLM 2% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM 2% Chrysotile1435974

5-WG-A

PLM 96% OtherPLM 2% CelluloseGrayWindow Glaze

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

1435975

5-WG-B

Positive Stop

Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

Layer Not Analyzed

1435976

5-WG-C

Positive Stop

Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

Layer Not Analyzed

PLM None Detected 1435977

6-CC-A

PLM 99% OtherPLM 1% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435978

6-CC-B

PLM 99% OtherPLM 1% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435979

6-CC-C

PLM 99% OtherPLM 1% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435980

7-BM-A

PLM 99% OtherPLM 1% CelluloseGrayBrick Mortar

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435981

7-BM-B

PLM 99% OtherPLM 1% CelluloseGrayBrick Mortar

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435982

7-BM-C

PLM 99% OtherPLM 1% CelluloseGrayBrick Mortar

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435983

8-IC-A

PLM 98% OtherPLM 2% CelluloseBeigeInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435984

8-IC-B

PLM 98% OtherPLM 2% CelluloseBeigeInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435985

8-IC-C

PLM 98% OtherPLM 2% CelluloseBeigeInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435986

9-IC-A

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435987

9-IC-B

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435988

9-IC-C

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435989

10-GM-A

PLM 99% OtherPLM 1% CelluloseGrayCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435989

10-GM-A

PLM 99% OtherPLM 1% CelluloseGrayGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435989

10-GM-A

PLM 99% OtherPLM 1% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435990

10-GM-B

PLM 99% OtherPLM 1% CelluloseGrayCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435990

10-GM-B

PLM 99% OtherPLM 1% CelluloseGrayGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435990

10-GM-B

PLM 99% OtherPLM 1% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435991

10-GM-C

PLM 99% OtherPLM 1% CelluloseGrayCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435991

10-GM-C

PLM 99% OtherPLM 1% CelluloseGrayGrout

Non-Fibrous

Homogenous Layer-2 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435991

10-GM-C

PLM 99% OtherPLM 1% CelluloseGrayMortar

Non-Fibrous

Homogenous Layer-3 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1435992

11-VP-A

PLM 1% OtherPLM 99% CelluloseBlackVapor Paper

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435993

11-VP-B

PLM 1% OtherPLM 99% CelluloseBlackVapor Paper

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435994

11-VP-C

PLM 1% OtherPLM 99% CelluloseBlackVapor Paper

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435995

12-PI-A

PLM 1% OtherPLM 1% Cellulose

PLM 98% Fiberglass

WhitePipe Insulation

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435996

12-PI-B

PLM 1% OtherPLM 1% Cellulose

PLM 98% Fiberglass

WhitePipe Insulation

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1435997

12-PI-C

PLM 1% OtherPLM 1% Cellulose

PLM 98% Fiberglass

WhitePipe Insulation

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM 6% Chrysotile1435998

13-PF-A

PLM 91% OtherPLM 3% CelluloseYellowPipe Fitting

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

1435999

13-PF-B

Positive Stop

Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

Layer Not Analyzed

1436000

13-PF-C

Positive Stop

Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

Layer Not Analyzed

PLM None Detected 1436001

14-FB-A

PLM 98% OtherPLM 2% CelluloseGrayFire Brick

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1436002

14-FB-B

PLM 98% OtherPLM 2% CelluloseGrayFire Brick

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1436003

14-FB-C

PLM 98% OtherPLM 2% CelluloseGrayFire Brick

Non-Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

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 - East Building

5001 US-23, Rogers City MI

ETL Job :

Client Project :

253483

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

12/08/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436004

15-VP-A

PLM 20% OtherPLM 80% CelluloseBlackVapor Paper

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1436005

15-VP-B

PLM 20% OtherPLM 80% CelluloseBlackVapor Paper

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

PLM None Detected 1436006

15-VP-C

PLM 20% OtherPLM 80% CelluloseBlackVapor Paper

Fibrous

Homogenous Layer-1 Analyst: Dawson Bradley

Date Analyzed : 12/30/2022

Lab Supervisor/Other Signatory

Dawson Bradley

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.