Full MDNR_Otsego State Park_Restroom Bldg_ACM LCP Survey Report_2023_0116.pdf

PRE-DEMOLITION ASBESTOS AND LIMITED LEAD-CONTAINING PAINT SURVEY

OTSEGO STATE PARK

TOILET AND SHOWER BUILDING

7136 OLD HIGHWAY 27 SOUTH,

GAYLORD, MI 49735

Project #188BS22768

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 Otsego State Park Toilet and Shower Building 7136 Old Highway 27 South Gaylord, MI 49735

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 limited lead-containing paint sampling was conducted on December 9, 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

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-Based Paint Laboratory Report

Page | 2

EXECUTIVE SUMMARY

Atlas representative Mr. Andrew DeLodder completed the pre-demolition asbestos and limited lead-containing paint survey of the Toilet and Shower Building, located in Otsego State Park, at 7136 Old

Highway 27 S, in Gaylord, Michigan, on December 9, 2022.

Thirty-three (33) asbestos bulk samples, taken from eleven (11) homogenous areas, were collected and submitted for analysis by Polarized Light Microscopy (PLM). Of the 33 samples submitted forty-one (41) sample layers were analyzed. The results of laboratory testing indicated that two (2) of the suspect materials contained greater than 1 percent asbestos.

Three (3) representative samples of paint, taken from interior and exterior areas of the building, were collected and submitted for analysis by Flame AAS. The results of laboratory testing of the paint chip samples indicated that all three (3) 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 of the Toilet and Shower Building at Otsego State Park located at 7136 Old Highway 27 S, in

Gaylord, Michigan.

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: December 9, 2022

Inspectors Andrew Delodder, Inspector # A48677

Property Address: 7136 Old Highway 27 S, in Gaylord, Michigan 49735

Property Owner Michigan Department of Natural Resources

Building Description:

2.2 Exterior Finish Descriptions

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

2.3 Interior Building Descriptions

The interior finishes of the building 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 building on December 9, 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:

> 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.

Otsego State Park - Toilet Shower Building

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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 analyzed 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 analyzed 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

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

Roofing Materials –

Beige Asphalt Shingle

NA ND

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

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

Concrete Chip -

Poured Concrete Pad Foundation

NA ND

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

Exterior Caulk -

White Caulk , Painted Beige, on Wood Siding, Roofline

NA ND

5-GTM-A,B,C EA-1,3

Gasket Material - White Gasket, Around Glass of Recessed Lighting 4 SF 50% Chrysotile

6-CA-A,B,C EA-1,3

Construction Adhesive - Dark Grey, Under Concrete Pylons

NA ND

7-GM-A,B,C FS-1,9

12” Beige Tiles-

Ceramic tile, Grout, & Mortar

NA ND

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

1” Multi-Colored Tiles-

Ceramic tile, Grout, & Mortar 1,250

8% Chrysotile (Grout Layer Only)

9-IC-A,B,C FS-1,3

Interior Caulk: White, Soft-

Around Toilets, Sinks, Urinals

NA ND

10-GM-A,B,C FS-5,6,7

8" Beige Tile-

Ceramic tile, Grout, & Mortar

NA ND

11-FC-A,B,C FS-5,6,8 Floor Covering - Red Epoxy NA ND

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 property building on December 9, 2022. The sampling included physical sampling of paint coatings that were deemed representative of the predominant paint coatings observed.

Three (3) paint chip samples were collected 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.

The following table provides a summary of the LCP sampling:

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Table 4-1 Lead-Containing Paint Sampling Results

Sample ID Sample Location Color Lead

Content

1-LBP-Beige Exterior Paint Beige 0.0041

2-LBP-White Interior Paint White 0.0004

3-LBP-Beige Interior Paint Beige 0.0004

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-GTM-A,B,C EA-1,3

Gasket Material -

White Gasket, Around Glass of Recessed Lighting

4 SF 50% Chrysotile

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

1” Multi-Colored Tiles-

Ceramic tile, Grout, & Mortar

1,250 SF

8% Chrysotile (Grout Layer

Only)

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

Three (3) representative samples of paint, taken from interior and exterior areas of the buildings, were collected and submitted for analysis by Flame AAS. The results of laboratory testing during the limited lead-containing paint sampling conducted at the property indicate that three (3) 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.

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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 9, 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:

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

Client Project: 188BS22768

253484ETL Job:

Report Date: 12/30/2022

Robert Smith

Lab Sample Number Client Sample Number Sample Type Completed

1436007 Asbestos1-RM-A 12/29/2022

1436008 Asbestos1-RM-B 12/29/2022

1436009 Asbestos1-RM-C 12/29/2022

1436010 Asbestos2-CC-A 12/29/2022

1436011 Asbestos2-CC-B 12/29/2022

1436012 Asbestos2-CC-C 12/29/2022

1436013 Asbestos3-CC-A 12/29/2022

1436014 Asbestos3-CC-B 12/29/2022

1436015 Asbestos3-CC-C 12/29/2022

1436016 Asbestos4-EC-A 12/29/2022

1436017 Asbestos4-EC-B 12/29/2022

1436018 Asbestos4-EC-C 12/29/2022

1436019 Asbestos5-GTM-A 12/29/2022

1436020 Asbestos5-GTM-B 12/29/2022

1436021 Asbestos5-GTM-C 12/29/2022

1436022 Asbestos6-CA-A 12/29/2022

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

1436023 Asbestos6-CA-B 12/29/2022

1436024 Asbestos6-CA-C 12/29/2022

1436025 Asbestos7-GM-A 12/29/2022

1436026 Asbestos7-GM-B 12/29/2022

1436027 Asbestos7-GM-C 12/29/2022

1436028 Asbestos8-GM-A 12/29/2022

1436029 Asbestos8-GM-B 12/29/2022

1436030 Asbestos8-GM-C 12/29/2022

1436031 Asbestos9-IC-A 12/29/2022

1436032 Asbestos9-IC-B 12/29/2022

1436033 Asbestos9-IC-C 12/29/2022

1436034 Asbestos10-GM-A 12/29/2022

1436035 Asbestos10-GM-B 12/29/2022

1436036 Asbestos10-GM-C 12/29/2022

1436037 Asbestos11-FC-A 12/29/2022

1436038 Asbestos11-FC-B 12/29/2022

1436039 Asbestos11-FC-C 12/29/2022

Reviewed by:

Summary

Sample Layer MasticMethod

PLM 41Emily 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

Lab Sample Number Client Sample Number Sample Type Completed

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436007

1-RM-A

PLM 96% OtherPLM 2% Cellulose

PLM 2% Fiberglass

BeigeShingle

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436008

1-RM-B

PLM 92% OtherPLM 4% Cellulose

PLM 4% Fiberglass

BeigeShingle

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436009

1-RM-C

PLM 96% OtherPLM 2% Cellulose

PLM 2% Fiberglass

BeigeShingle

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436010

2-CC-A

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436011

2-CC-B

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436012

2-CC-C

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436013

3-CC-A

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436014

3-CC-B

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436015

3-CC-C

PLM 98% OtherPLM 2% CelluloseGrayConcrete Chip

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436016

4-EC-A

PLM 98% OtherPLM 2% CelluloseGrayExterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436017

4-EC-B

PLM 98% OtherPLM 2% CelluloseGrayExterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436018

4-EC-C

PLM 98% OtherPLM 2% CelluloseGrayExterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM 50% Chrysotile1436019

5-GTM-A

PLM 10% OtherPLM 40% CelluloseGrayGasket Material

Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

1436020

5-GTM-B

Positive Stop

Analyst: Chris Canilao

Date Analyzed : 12/29/2022

Sample Not Analyzed

1436021

5-GTM-C

Positive Stop

Analyst: Chris Canilao

Date Analyzed : 12/29/2022

Sample Not Analyzed

PLM None Detected 1436022

6-CA-A

PLM 98% OtherPLM 2% CelluloseBrownConstruction Adhesive

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436023

6-CA-B

PLM 98% OtherPLM 2% CelluloseBrownConstruction Adhesive

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436024

6-CA-C

PLM 98% OtherPLM 2% CelluloseBrownConstruction Adhesive

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436025

7-GM-A

PLM 98% OtherPLM 2% CelluloseRedCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436025

7-GM-A

PLM 98% OtherPLM 2% CelluloseBrownMortar

Non-Fibrous

Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM 8% Chrysotile1436025

7-GM-A

PLM 90% OtherPLM 2% CelluloseWhiteGrout

Non-Fibrous

Homogenous Layer-3 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436026

7-GM-B

PLM 98% OtherPLM 2% CelluloseRedCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436026

7-GM-B

PLM 98% OtherPLM 2% CelluloseBrownMortar

Non-Fibrous

Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

1436026

7-GM-B

Positive Stop

Layer-3 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

Layer Not Analyzed

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436027

7-GM-C

PLM 98% OtherPLM 2% CelluloseRedCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436027

7-GM-C

PLM 98% OtherPLM 2% CelluloseBrownMortar

Non-Fibrous

Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

1436027

7-GM-C

Positive Stop

Layer-3 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

Layer Not Analyzed

PLM None Detected 1436028

8-GM-A

PLM 98% OtherPLM 2% CelluloseBlueCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436028

8-GM-A

PLM 98% OtherPLM 2% CelluloseBrownGrout and Mortar

Non-Fibrous

Non-Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436029

8-GM-B

PLM 98% OtherPLM 2% CelluloseGrayCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436029

8-GM-B

PLM 98% OtherPLM 2% CelluloseBrownGrout and Mortar

Non-Fibrous

Non-Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436030

8-GM-C

PLM 98% OtherPLM 2% CelluloseGrayCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436030

8-GM-C

PLM 98% OtherPLM 2% CelluloseBrownGrout and Mortar

Non-Fibrous

Non-Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436031

9-IC-A

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436032

9-IC-B

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436033

9-IC-C

PLM 98% OtherPLM 2% CelluloseWhiteInterior Caulk

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436034

10-GM-A

PLM 98% OtherPLM 2% CelluloseBrownCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436034

10-GM-A

PLM 95% OtherPLM 5% CelluloseBrownGrout and Mortar

Non-Fibrous

Non-Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436035

10-GM-B

PLM 98% OtherPLM 2% CelluloseBrownCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436035

10-GM-B

PLM 95% OtherPLM 5% CelluloseBrownGrout and Mortar

Non-Fibrous

Non-Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

PLM None Detected 1436036

10-GM-C

PLM 98% OtherPLM 2% CelluloseBrownCeramic Tile

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436036

10-GM-C

PLM 95% OtherPLM 5% CelluloseBrownGrout and Mortar

Non-Fibrous

Non-Homogenous Layer-2 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436037

11-FC-A

PLM 98% OtherPLM 2% CelluloseWhite/RedFloor Covering Epoxy

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436038

11-FC-B

PLM 98% OtherPLM 2% CelluloseWhite/RedFloor Covering Epoxy

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

PLM None Detected 1436039

11-FC-C

PLM 98% OtherPLM 2% CelluloseWhite/RedFloor Covering Epoxy

Non-Fibrous

Homogenous Layer-1 Analyst: Chris Canilao

Date Analyzed : 12/29/2022

Lab Supervisor/Other Signatory

Chris Canilao

Analyst:

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

Otsego State Park

7136 Old Highway 27 S., Gaylord, MI 49735

ETL Job :

Client Project :

253484

188BS22768

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

12/09/2022

12/27/2022

Date Collected :

Date Received :

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

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

Client Project :

868387

12/22/2022

12/23/2022

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 :

7136 OLD HIGHWAY 27 GAYLORD MIProject Location :

188BS22768

Novi, MI 48377

46555 Humboldt Dr.

30105 Beverly Road

Romulus, MI 48174

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

Sampling Date : 12/09/2022

12/23/2022

Lab Sample ID Result Lead

(% by weight) PPMSample DescriptionClient Code

Calculated R L

(% by weight)

1-LBP-BEIGE EXT BEIGE PAINT8066978 41 0.0041 0.0031

2-LBP-WHITE INT WHITE PAINT8066979 4 0.0004 0.0009

3-LBP-BEIGE INT BEIGE PAINT8066980 4 0.0004 0.0005

Analyst Signature

Tom Hamlin

868387 AAT Project:Date Printed: 12/23/2022 12:00PM

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

868387

188BS22768

7136 OLD HIGHWAY 27 GAYLORD MI

46555 Humboldt Dr.

Novi, MI 48377

30105 Beverly Road

Romulus, MI 48174

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

12/23/2022

Sample CompletedAnalysis RequestedClient Code Analyst

8066978 12/23/2022Lead Paint1-LBP-BEIGE Tom Hamlin

8066979 12/23/2022Lead Paint2-LBP-WHITE Tom Hamlin

8066980 12/23/2022Lead Paint3-LBP-BEIGE Tom Hamlin

Quality Assurance Coordinator

Reviewed By Elyse Bidle

868387 AAT Project:Date Printed: 12/23/2022 12:00PM

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