215 Colfax Avenue, Benton Harbor, MI 49022 ♦PH: (269) 927-2434 ♦ rvilla@villaenv.com

Health & Safety Services ● Property Transactions ● Clean Air Act ● Indoor Air ● Asbestos and Lead ● Site Remediation

3 February 2023

Doug Montey, Facility Consultant Manistee Area Public Schools 550 Maple Street Manistee, MI 49660

Re: NESHAP Asbestos-Containing Materials Survey

Jefferson Elementary, 515 Bryant Ave.

Villa Environmental Consultants, Inc. Project No. 22-244

Dear Mr. Montey:

Villa Environmental Consultants, Inc. (VEC) completed a NESHAP survey for Asbestos- Containing Materials (ACM) for Jefferson Elementary, which is planned for demolition. Our asbestos consulting services were completed according to the accepted scope of our asbestos inspection services.

Purpose of the Survey

The purpose of this survey was to identify, locate, classify, analyze, and estimate quantities of ACM that must be removed or managed according to federal, state, and local agency requirements prior to or during the scheduled demolition activities.

VEC performed this survey in accordance with the United States Environmental Protection Agency (US EPA) National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR, Part 61, Subpart M guidelines. The NESHAP controls the release of air contaminants to the ambient air during renovation and demolition activities. The NESHAP requires the owner to submit a notification of intent to demolish to the appropriate regulatory authorities before the work begins. To provide the required information to the regulatory authorities, a comprehensive asbestos survey must be conducted on the property within the area(s) where renovation/demolition activities are scheduled. The survey must list all ACM that is present, the estimated quantities, and identify which materials must be removed prior to the planned demolition activities scheduled in the future at this site.

The interior locations were inspected physically by Homogeneous Areas (HA) to determine the presence of ACM. The inspection of the building included access to the requested survey areas and a listing of the determined Functional Spaces (FS). The visual inspection was conducted by Rick Villa (Accreditation No. A1157), a State of Michigan Asbestos Building Inspector.

- Table 2 Updated 17 April 2026

RENOVATION NESHAP ACM SURVEY-

515 Bryant Ave., Manistee, MI 3 February 2023

Villa Environmental Consultants, Inc. Page 2 VEC Project Number 22-244

Description of Building Surveyed

This building was constructed in 1953 with an addition in 1963. The building is estimated to be approximately 35,000 square feet, constructed of typical institutional materials such as ceramic tile, vinyl tile floors, carpet, acoustical ceilings, block interior walls, and drywall.

Limitations and Exceptions of Survey

Locating and identifying materials containing asbestos in buildings and structures is a difficult and time-consuming task. All buildings have hidden spaces that may not be obvious to a surveyor who is not intimately familiar with the building and who has only a limited time to inspect the facility.

Although VEC uses trained and licensed inspectors to locate and identify materials potentially containing asbestos, VEC cannot verify that all materials containing asbestos have been identified. It is possible that there are materials containing asbestos that were not found because they were not visible or accessible to the inspector.

The survey is designed to aid the building owner, Architects, Construction Managers, and asbestos abatement contractors in locating regulated building materials. All quantities reported are estimates. Any contractor using the information found in this report must quantify their own measurements. VEC is not responsible for any misrepresentation of quantities or any discrepancies with potential asbestos abatement budgeting. If potential variations are identified during demolition activities, it may be necessary to conduct additional sampling.

During the NESHAP site survey, the following limitations were encountered and described below:

1. We did not break into any walls, wall cavities, under casework, under the hallway ceramic tile and under white boards.

2. Only corners of carpet and/or carpet at thresholds were pulled back which revealed carpet installed directly on concrete and if any material was discovered, it was sampled.

3. The roofing materials were not sampled.

Asbestos-Containing Materials

VEC understands that information obtained from this survey will be used to assist in the proper removal and disposal of these materials before demolition activities. The following subsections describe the sampling plan and sample collection phases of the survey.

Building Walk Through and Inspection Activities

VEC performed a review of the interior of the building using guidelines established by the US EPA in the publication Guidance for Controlling Asbestos-Containing Materials in Buildings, Office of Pesticides and Toxic Substances, DOC No. 560/5-85-024 and 40 CFR Part 763, of the Asbestos Hazard and Emergency Response Act (AHERA). As required under AHERA, suspect

Villa Environmental Consultants, Inc. Page 3

ACM is categorized as thermal system insulation (TSI)1, surfacing materials (SM)2, or miscellaneous materials (MM)3.

AHERA sampling protocols states that the following number of samples must be collected for each material category:

• Three samples of TSI materials (i.e., pipe wrap insulation) must be collected and analyzed by PLM analysis.

• Surfacing materials (i.e., plaster, joint compound, textured ceiling materials, fire proofing, etc.) are sampled in accordance with the quantity of material present as measured by its square footage. If less than 1,000 square feet of material is present, a minimum of three bulk samples must be collected. If between 1,000 and 5,000 square feet of material is present, a minimum of five bulk samples must be collected. If greater than 5,000 square feet of material is present, a minimum of seven bulk samples must be collected. All bulk samples must be analyzed by PLM analysis.

• Miscellaneous materials (i.e., floor tile, mastics, roofing materials, gypsum drywall panels, ceiling tiles, etc.) need to be sampled “in a manner sufficient to determine” its asbestos content using professional judgement of the accredited asbestos building inspector. All bulk samples must be analyzed by PLM analysis.

Accessible locations within the survey areas were physically inspected to determine the presence of ACM. Suspect materials in each area were categorized prior to the collection of bulk samples.

During the inspection, the friable or non-friable nature of the suspect ACM was determined and cataloged.

Bulk Sample Collection

VEC conducted bulk sampling protocols of all accessible friable and non-friable suspected ACM in general accordance with the requirements of AHERA for bulk sampling (40 CFR 763.86) and with the scope of services outlined in VEC’s proposal. During the inspection, bulk samples of suspect ACM containing, in some cases, multiple layers of discrete materials were collected for analysis. Samples were assigned an identification number and Chain of Custody (COC) forms accompanied the samples to the laboratory.

Asbestos Laboratory Analytical Procedures and Methodologies

Laboratory analytical services using Polarized Light Microscopy (PLM), were performed by Environmental Testing Laboratories, Inc. (ETL) located at 37575 West Huron River Dr., Romulus, Michigan. ETL is an accredited National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos fiber analysis. Bulk samples of suspect ACM were analyzed by PLM Method

198.1 for the criteria set by the NESHAP, 40 CFR Part 61.

1 Thermal system insulation is defined as material(s) that is applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain.

2 Surfacing material is defined as a material(s) that is sprayed troweled-on or otherwise applied to surfaces.

3 Miscellaneous material is defined as a material(s) that is not classified as surfacing or thermal system insulation.

Villa Environmental Consultants, Inc. Page 4

Findings

This section presents the findings based on the results of the material sampling, field inspection and laboratory analyses. The attached function space drawing also provides a graphical depiction of the known and assumed asbestos containing material.

Methodology and Limiting Conditions

A survey of the building was performed to identify ACM that will require proper management prior to demolition/renovation of the building. NESHAP defines “demolition” as the means of wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations, or the intentional burning of any facility.

Conclusions and Recommendations

The following are the conclusions and recommendations:

• The known and assumed asbestos materials are listed in bold on the attached tables.

• All the materials currently and previously sampled are listed in the attached tables 2 and 3.

• There could be isolated areas that have asbestos floor tile under carpet and casework.

• Prior to demolition we recommend breaking into exterior walls to look for possible vermiculite, break into walls associated with plumbing to look for asbestos pipe insulation, look under exterior metal fascia in 1963 section to verify transite, demolish the roof skylights to look for possible transite, assure there is no insulation on pipes in the concrete floors (almost all) that have radiant heat in 1953 section, demolish the exterior upper renovated areas that are covering glass block and maybe transite, and look under the hallway ceramic floor tile.

• A non-asbestos related recommendation: verify that the 10,000 gallon underground heating oil tank installed by the 1953 boiler room has been removed.

Please feel free to contact me at (269) 927-2434 or via email to review or discuss any aspect of this report.

Yours truly, Richard Villa, President rvilla@villaenv.com

Tables Table 1: Description of Functional Spaces Table 2: Summary of Homogeneous Areas Table 3: Summary of ACM and Material Characteristics Appendices Appendix A: Asbestos Laboratory Analytical Reports Appendix B: Photo plate Figures Figure 1: Site Sketch/Functional Space Diagram

Table 1 Description of Functional Spaces

515 Bryant Ave, Manistee VEC Project No. 22-244

Functional Space No. Functional Space Description Floor 1 Boiler Room 1 2 Gym 1 3 Stage 1 4 Stage AHU Room 1 5 Sensory (Old Locker) 1 6 Kitchen & Pantry 1 7 Lost & Found 1 8 Lounge 1 9 Offices #1 1 10 Custodial #1 1 11 Boys/Girls Restrooms 1 12 Room #1 & ISD 1 13 Room #11/ GSRP #2 1 14 Room #12/ GSRP #1 1 15 Room #12/ Grade 1 1 16 1953 Corridor & 1963 Corridor 1 17 Recovery Room 1 18 (1953 Section ) Building Exterior 1 19 Room #14 1 20 Room #15 1 21 Room #16 1 22 Room #17 1 23 Custodial #2 1 24 Room 21 1 25 Room #22 1 26 Room #23 1 27 Room #24 1 28 Room #25 1

Villa Environmental Consultants, Inc.

Table 1; Page 1 of 2

515 Bryant Ave, Manistee VEC Project No. 22-244

Functional Space No. Functional Space Description Floor 29 (1963 Section) Room #18 1 30 (1963 Section) Room #19 1 31 (1963 Section) Room #20 1 32 (1963 Section) Copy Room 1 33 (1963 Section) Building Exterior 1

Table 1; Page 2 of 2

Table 2 Summary of Homogeneous Areas

Summary of Homogenous Areas- APRIL 17, 2026

515 Bryant Ave, Manistee

VEC Project No. 22-244

HA No. Homogenous Area Description Functional Space Locations (FS#) Asbestos Content Estimated Quantity

1 Pipe Insulation Fittings FS1 ND Removed

2 Unknown FS1 ND Removed

3 Mag-Insulation

FS9, possibly in wall cavities supplying water to sinks or the former showers

(requires further investigation or provide a bid allowance cost /LF)

40% AM 20 LF

4 Pipe Insulation Fittings FS1 ND Removed

5 Mill-board Insulation FS1 ND Removed

6 Mill-board Insulation FS1 ND Removed

7 Mill-board Insulation FS1 ND Removed

8 Mag-Insulation FS1 ND Removed

9 Unknown FS1 ND Unknown

10 Unknown FS1 ND Unknown

11 Mag-Insulation FS1 ND Removed

12 9"x9" Floor Tile with non asbestos mastic-1953 section

FS2, FS6, FS9,F12-FS15, FS19-FS22

FS24-FS31

3% CH (mastic ND) 14,600 SF

13 Exterior Transite Soffit-1963 section FS33 25% CH 550 SF

14 Mag-Insulation FS1 ND Removed

15 Mill-board Insulation FS1 ND Removed

16 Mag-Insulation FS1 ND Removed

17 Boiler Jacket Insulation FS1 ND Removed

18 Water Tank Insulation FS1 ND Removed

19 Duct Insulation FS1 ND Removed

20 Anti-Vibration Cloth FS4, ND 12 SF

21 12"x12" Floor Tile FS3, ND 36 SF

22 Boiler Room Ceiling FS1 ND 875 SF

23 Boiler Flue Liner in Chimney FS1 ND 250 SF

24 Green Ceramic Tile Grout FS8 ND 675 SF

25 12"x12" Green Tile FS9 ND 200 SF

Table 2; Page 1 of 2

Summary of Homogenous Areas- APRIL 17, 2026

515 Bryant Ave, Manistee

VEC Project No. 22-244

HA No. Homogenous Area Description Functional Space Locations (FS#) Asbestos Content Estimated Quantity

26 Black Sink Undercoating-1953 section FS8,FS13-FS15, FS19-FS22 FS24-FS31 ND 225 SF

27 Linoleum on Classroom Sink Counter FS13-FS15, FS19-FS22 FS24-FS31 ND 540 SF

28 Louvre Caulk FS1 ND 20 LF

29 Exterior Door Caulk-1953 Section FS18 (4 Exit doors of 1963 section) 5% CH 8 SF

30 6"x6" Ceramic Tile Grout FS7,FS11, FS16, ND 6,870 SF

31 Cement plaster ceiling FS18 ND 1,600 SF

32 Hard/Smooth Plaster Ceiling FS5, FS8 ND 390 SF

33 (1953 Section) 2'x4' Acoustical Ceiling Tile FS16, FS20 ND 6,100 SF

34 (1963 Section) 2'x4' Acoustical Ceiling Tile FS29,FS31 ND 810 SF

35 9"x9" Beige Floor Tile-1963 section FS29-FS31 3% CH/ mastic ND 2,500 SF

36 (1963 Section) Black Sink Undercoating FS29-FS31 ND 4 SF

37 Removable Wall FS30 ND 240 SF

38 4-Inch Cove Base FS29-FS31 ND 145 SF

39 Potential vermiculite in the exterior walls FS18, FS33 Owner cut openings and none found, ND

8,500 SF+

40 Glazing for entry to classrooms entrys to 1953 rooms ND 4 SF

41 Glazing for aluminum framed windows at corridor wall of classrooms upper windows of 1953 clasrooms ND 5.5 SF

42 Glue pods for tackboards and chalkboards -1953 section classrooms ND 1,100 SF

43 Caulk for glass block windows FS2 3% CH 3.5 SF

44 Flashing perimeter of roof ND 6,900 SF

45 Top layer of roofing roof ND 28,000 SF

46 Exterior window caulk and glazing-1953 section Reviewd by owner, no suspect material ND 3500 SF

47 Exterior window caulk and glazing-1963 section Reviewd by owner, no suspect material ND 600 SF

48 Chalkboards-1953 section requires further destructive investigation

49 Chalkboards- 1963 section requires further destructive investigation

50 Glue pods for tackboards and chalkboards -1956 section requires further destructive investigation

51 Material under hallway ceramic floor-1963 section requires further destructive investigation

Table 2; Page 2 of 2

Table 3 Summary of ACM and Material Characteristics

Table 3 Summary of ACM and Material Characteristics

515 Bryant Ave, Manistee VEC Project No. 22-244

HA No. Homogenous Area Description Condition Friable (Yes/No)

EPA

Category Estimated Quantity

3 Mag-Insulation G Y II 20 LF

12 9"x9" Floor Tile G N I 16,840 SF 13 Exterior Transite Soffit-1963 section G N II 550 SF

23 Boiler Flue Liner in Chimney-Assumed ACM G N II 250 SF

29 Exterlior Door Caulk-1953 Section G N I 8 SF

37 Removable Wall-Assumed ACM G N II 240 SF

39 Vermiculite in the exterior walls- Assumed G N II 8500 SF

4. Asbestos is a group of fibrous minerals that include: actinolite, amostie, anthophllite, chrysotile, crocidolite, and tremolite

3. SF = Square Feet; LF = Linear Feet; CF = Cubic Feet; EA = Each

Table 3 Notes and Acronyms:

1. Homogeneous Area (HA) is defined as an area of surfacing materials, thermal surface insulation, or miscellaneous material that is uniform in color and texture.

2. EPA Category I non-friable ACM consist of asbestos containing packings, gaskets, resilient floor coverings, and asphalt roofing materials. These materials can be left in-place during demolition if materials remain intact and non-friable. If concrete is planned to be recycled as part of demolition activities, all Category I non-friable flooring materials must be removed.

Table 3; Page 1 of 1

Appendix A Asbestos Laboratory Analytical Report

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

To:

Attention:

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Benton Harbor, Michigan 49022

Project Location:

Jefferson Elem.

515 Bryant Ave, Manistee, MI

Client Project: 22-244 254380ETL Job:

Report Date: 1/26/2023

Rick Villa

Lab Sample Number Client Sample Number Sample Type Completed

1448142 Asbestos12-02 01/25/2023

1448143 Asbestos12-03 01/25/2023

1448144 Asbestos12-04 01/26/2023

1448145 Asbestos12-05 01/26/2023

1448146 Asbestos12-06 01/26/2023

1448147 Asbestos12-07 01/26/2023

1448148 Asbestos20-01 01/26/2023

1448149 Asbestos21-01 01/26/2023

1448150 Asbestos22-01 01/26/2023

1448151 Asbestos24-01 01/26/2023

1448152 Asbestos24-02 01/26/2023

1448153 Asbestos25-01 01/26/2023

1448154 Asbestos26-01 01/26/2023

1448155 Asbestos26-02 01/26/2023

1448156 Asbestos27-01 01/26/2023

1448157 Asbestos28-01 01/26/2023

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

Lab Sample Number Client Sample Number Sample Type Completed

1448158 Asbestos29-01 01/26/2023

1448159 Asbestos30-01 01/26/2023

1448160 Asbestos30-02 01/26/2023

1448161 Asbestos30-03 01/26/2023

1448162 Asbestos31-01 01/26/2023

1448163 Asbestos32-01 01/26/2023

1448164 Asbestos32-02 01/26/2023

1448165 Asbestos33-01 01/26/2023

1448166 Asbestos33-02 01/26/2023

1448167 Asbestos34-01 01/26/2023

1448168 Asbestos34-02 01/26/2023

1448169 Asbestos01-01 01/26/2023

1448170 Asbestos02-01 01/26/2023

Reviewed by:

Emily 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 :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM 2% Chrysotile1448142 12-02

PLM 98% OtherGray9x9 Floor Tile & Mastic - Floor Tile Non-Fibrous

HomogenousFS12-15D Area Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/25/2023

PLM None Detected 1448142 12-02

PLM 100% OtherBrownMastic Non-Fibrous HomogenousFS12-15D Area

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/25/2023

PLM 3% Chrysotile1448143 12-03

PLM 97% OtherTan9x9 Floor Tile & Mastic - Floor Tile Non-Fibrous

HomogenousFS15-Room 13 Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/25/2023

PLM None Detected 1448143 12-03

PLM 100% OtherBlackMastic Non-Fibrous HomogenousFS15-Room 13

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/25/2023

PLM None Detected 1448144 12-04

PLM 98% OtherPLM 2% CelluloseBlack9x9 Mastic Non-Fibrous HomogenousFS24-Room 24

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448145 12-05

PLM 98% OtherPLM 2% CelluloseBlack9x9 Mastic Non-Fibrous HomogenousFS28-Media Center

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM 2% Chrysotile1448146 12-06

PLM 98% OtherBrown9x9 Tile & Mastic - Floor Tile Non-Fibrous HomogenousFS6-Kitchen

Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448146 12-06

PLM 98% OtherPLM 2% CelluloseBrownMastic Non-Fibrous HomogenousFS6-Kitchen

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM 2% Chrysotile1448147 12-07

PLM 98% OtherGray9x9 Tile & Mastic - Floor Tile Non-Fibrous HomogenousFS-27

Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448147 12-07

PLM 98% OtherPLM 2% CelluloseBlackMastic Non-Fibrous HomogenousFS-27

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448148 20-01

PLM 20% OtherPLM 80% CelluloseBlackAnti Vibration Cloth Fibrous HomogenousFS4

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM None Detected 1448149 21-01

PLM 98% OtherPLM 2% CelluloseTan12x12 Floor Tile Non-Fibrous HomogenousFS2-Gym Stage Landing

Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448149 21-01

PLM 100% OtherYellowAdhesive Non-Fibrous HomogenousFS2-Gym Stage Landing

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448150 22-01

PLM 98% OtherPLM 2% CelluloseWhiteCeiling Non-Fibrous HomogenousFS1

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448151 24-01

PLM 100% OtherGreenCeramic Tile & Grout - Ceramic Tile Non-Fibrous

HomogenousFS8 Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448151 24-01

PLM 98% OtherPLM 2% CelluloseGrayGrout Non-Fibrous HomogenousFS8

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM None Detected 1448152 24-02

PLM 100% OtherGreenCeramic Tile & Grout - Ceramic Tile Non-Fibrous

HomogenousFS8 Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448152 24-02

PLM 98% OtherPLM 2% CelluloseGrayGrout Non-Fibrous HomogenousFS8

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM Trace Chrysotile1448153 25-01

PLM 98% OtherPLM 2% CelluloseGreen12x12 Tile Non-Fibrous HomogenousFS9-W. Office

Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448153 25-01

PLM 98% OtherPLM 2% CelluloseBlackMastic Non-Fibrous HomogenousFS9-W. Office

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448153 25-01

PLM 100% OtherYellowMastic Non-Fibrous HomogenousFS9-W. Office

Layer-3 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448154 26-01

PLM 100% OtherBlackSink Undercoating Non-Fibrous HomogenousFS13

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM None Detected 1448155 26-02

PLM 100% OtherBlackSink Undercoating Non-Fibrous HomogenousFS24

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448156 27-01

PLM 20% OtherPLM 80% CelluloseBrownSink Linoleum Non-Fibrous HomogenousFS13

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448157 28-01

PLM 97% OtherPLM 3% CelluloseBrownCaulk Non-Fibrous HomogenousFS1

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM 5% Chrysotile1448158 29-01

PLM 95% OtherGrayDoor Caulk Non-Fibrous Non-HomogenousFS16-Entry 3

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448159 30-01

PLM 98% OtherPLM 2% CelluloseGrayGrout Non-Fibrous HomogenousFS16-by lost and found

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448160 30-02

PLM 100% OtherGray/BrownGrout Non-Fibrous Non-HomogenousFS16-by Entry 3

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM None Detected 1448161 30-03

PLM 95% OtherPLM 5% CelluloseBrown/WhiteGrout Non-Fibrous Non-HomogenousFS16-by Entry 4

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448162 31-01

PLM 100% OtherGrayCement Plaster Ceiling Non-Fibrous HomogenousFS18-by Entry 4

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448163 32-01

PLM 100% OtherGrayPlaster Ceiling Non-Fibrous HomogenousFS5-E. Storage

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448164 32-02

PLM 100% OtherGrayPlaster Ceiling Non-Fibrous HomogenousFS8-Paper Storage

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448165 33-01

PLM 50% OtherPLM 50% CelluloseGray2x4 ACT Fibrous HomogenousFS16

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448166 33-02

PLM 50% OtherPLM 50% CelluloseGray2x4 ACT Fibrous HomogenousFS20

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

Date Collected :

Date Received :

PLM None Detected 1448167 34-01

PLM 50% OtherPLM 50% CelluloseGray2x4 ACT Fibrous HomogenousFS29

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448168 34-02

PLM 50% OtherPLM 50% CelluloseGray2x4 ACT Fibrous HomogenousFS31

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448169 01-01

PLM 98% OtherPLM 2% CelluloseBrown12x12 Floor Tile Non-Fibrous HomogenousA Bldg E Portable

Layer-1 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448169 01-01

PLM 100% OtherBrownMastic Non-Fibrous HomogenousA Bldg E Portable

Layer-2 Analyst: Emmett Zainea Date Analyzed : 01/26/2023

PLM None Detected 1448170 02-01

PLM 48% OtherPLM 50% Cellulose PLM 2% Fiberglass

Brown2'x4' ACT Fibrous HomogenousA Bldg E Portable

Analyst: Emmett Zainea Date Analyzed : 01/26/2023

Lab Supervisor/Other Signatory

Emmett Zainea

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 :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Jefferson Elem.

515 Bryant Ave, Manistee, MI

ETL Job :

Client Project :

254380 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/22/2023 01/24/2023

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.

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

To:

Attention:

Villa Environmental Consultants, Inc.

215 Colfax Ave.

Benton Harbor, Michigan 49022

Project Location: 515 Bryant St., Manistee, MI

Client Project: 22-244 254565ETL Job:

Report Date: 2/1/2023

Rick Villa

Lab Sample Number Client Sample Number Sample Type Completed

1451404 Asbestos35-01 02/01/2023

1451405 Asbestos36-01 02/01/2023

1451406 Asbestos38-01 02/01/2023

Reviewed by:

Emily 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

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

515 Bryant St., Manistee, MI

ETL Job :

Client Project :

254565 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/16/2023 01/31/2023

Date Collected :

Date Received :

PLM None Detected 1451404 35-01

PLM 97% OtherPLM 3% CelluloseBeige9"x9" Floor Tile Non-Fibrous HomogenousFS31

Layer-1 Analyst: Alex Noble Date Analyzed : 02/01/2023

PLM None Detected 1451404 35-01

PLM 97% OtherPLM 3% CelluloseTanMastic Non-Fibrous HomogenousFS31

Layer-2 Analyst: Alex Noble Date Analyzed : 02/01/2023

PLM Trace Chrysotile1451405 36-01

PLM 98% OtherPLM 2% CelluloseBlackSink Undercoating Non-Fibrous HomogenousFS29

Analyst: Alex Noble Date Analyzed : 02/01/2023

PLM None Detected 1451406 38-01

PLM 98% OtherPLM 2% CelluloseBeige4" Cove Base Non-Fibrous HomogenousFS32

Layer-1 Analyst: Alex Noble Date Analyzed : 02/01/2023

PLM None Detected 1451406 38-01

PLM 97% OtherPLM 3% CelluloseBrownAdhesive Non-Fibrous HomogenousFS32

Layer-2 Analyst: Alex Noble Date Analyzed : 02/01/2023

PLM Trace Chrysotile1451406 38-01

PLM 98% OtherPLM 2% CelluloseWhiteBrittle Material Non-Fibrous HomogenousFS32

Layer-3 Analyst: Alex Noble Date Analyzed : 02/01/2023

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Polarized Light Microscopy Asbestos Analysis Report

Location :

To :

Benton Harbor,Michigan 49022

Villa Environmental Consultants, Inc.

215 Colfax Ave.

515 Bryant St., Manistee, MI

ETL Job :

Client Project :

254565 22-244

Environmental Testing Laboratories, Inc.

37575 W Huron River Drive Romulus, Michigan 48174

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

Sample Description Appearance % Fibrous % Non-Fibrous % Asbestos

01/16/2023 01/31/2023

Date Collected :

Date Received :

Lab Supervisor/Other Signatory

Alex Noble

Analyst:

400 Point Count Results by EPA 600/R-93/116 PLM (denoted by "PC") Item 198.1: PLM Methods for Identifying and Quantitating Asbestos in Bulk Samples Item 198.6: PLM Methods for Identifying and Quantitating Asbestos in Non-Friable Organically Bound Bulk Samples EPA 600/R-93/116: Method for Determination of Asbestos in Bulk Building Materials EPA 600/M4-82-020: Interim Method for Determination of Asbestos in Bulk Insulation Samples A % Asbestos result of "Trace" indicates that the analyzed material was found to contain less than 1% asbestos and would not be considered an Asbestos Containing Material (ACM).

ETL, Inc. maintains liability limited to cost of analysis. This report relates only to the samples reported and may not be reproduced without written approval by ETL, Inc. Test Method EPA 600/R-93-116 & EPA 600/M4-82/020 or NYSDOH-ELAP item 198.1 and/or 198.6 was used to analyze all samples. Matrix interference and/or resolution limits (i.e. detecting asbestos in non-friable organically bound materials) may yield false results in certain circumstances. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing. Interpretation and use of test results are the responsibility of the client. ETL, Inc. is not responsible for the accuracy of the results when requested to physically separate and analyze layered samples. Any PLM results below 10% should be re-analyzed using the EPA recommended Point Count method. Any material that has greater than 1% asbestos content is considered to be an Asbestos Containing Material (ACM). These materials are regulated by both OSHA and the EPA and must be treated accordingly. Results are related to only to samples that were tested. An estimate of uncertainty can be provided at the client's request.

Appendix B Photographic Record of ACM

Project:

Project No: 22-244

Scale: NA

Figure No: 1

515 Bryant Ave.

Manistee, MI

Jefferson Elementary School ACM Sampling

HA#3 Mag insulation riser in office closet

Date: 3 February 2023

HA#12- Typical 9”x9” floor tile

Figure 1 Functional Space Diagram

15 Bryant, Manistee

Learning Resource

Stage

RR RR

9"x9" floor tile

9"x9" asbestos floor tile asbestos door caulk

Mag (asbestos) pipe insulation riser that may also be in wall cavities and in isolated areas

Transite soffit

Assumed asbestos vermiculite insulation in exterior wall cavities.

Not all ACM noted on this sketch, refer to the most current NESHAP tables.

April 17,2026

Function spaces used in the NESHAP: 1, 2, etc.

glass block caulk upper part of gym

33 18

16 16