LD267090 Kent ISD Dutton Hazardous Materials Letter Report.pdf

400 Ann Street NW Suite 204

Grand Rapids, Michigan 49504 P (616) 226-8180

Terracon.com

Facilities | Environmental | Geotechnical | Materials 1

May 11, 2026

Kent Intermediate School District 2930 Knapp Street NE Grand Rapids, Michigan 49525

Attn: Mr. Russell Bray P: (616) 447-2444 E: russellbray@kentisd.org

Re: Observations for Hazardous Materials Report Former Dutton Elementary School 3820 68th Street Caledonia, Michigan 49316 Terracon Proposal No. LD267060

Dear Mr. Bray:

Terracon Consultants, Inc. (Terracon) appreciates the opportunity to submit this letter report to Kent Intermediate School District (Client) regarding observations made for hazardous material items at the former Dutton Elementary School located at 3820 68th Street in Caledonia, Michigan.

Asbestos-containing materials (ACMs) and lead paint are addressed and discussed in separate companion reports prepared by Terracon for this project. The purpose of this letter report is to discuss other potential hazardous material items readily observed to be associated with the former elementary school which is to be demolished.

On April 1, 2, and 8, 2026, Terracon representatives Mr. Jeff Fusee, CIH, CSP conducted field observations for other hazardous material items. Observations were made for the following items in association with the building:

Universal wastes (e.g., mercury-containing equipment, lamps, batteries), Potential polychlorinated biphenyl (PCB)-containing equipment, Ozone depleting substances (refrigerants), and Other hazardous material items (i.e., appliances, chemical containers, smoke detectors with potential radioactive sources, etc.).

Observations for Hazardous Material Items Former Dutton Elementary School | 3820 68th St., Caledonia, MI May 11, 2026 | Terracon Project No. LD267060

Facilities | Environmental | Geotechnical | Materials 2

HAZARDOUS MATERIAL ITEMS OBSERVATION SUMMARY

The following sections summarize items and/or potential items observed during the site visit.

A. Universal Wastes (UW)

Universal wastes (UW) are specific hazardous waste streams that a generator can choose to manage in an alternative manner in place of the more complex hazardous waste requirements. The federal universal waste regulations are found in Title 40 of the Code of Federal Regulations (CFR) in Part 273 and apply to five types of UW: lamps, mercury-containing equipment, batteries, pesticides, and aerosol cans. These types of waste are generated by numerous businesses, typically in small quantities and they present low hazards. The Universal Waste Rules (UWR) under 40 CFR Part 273 are intended to promote recycling as well as proper disposal by easing certain regulatory requirements. A waste must be a hazardous waste before it can be a universal waste. If a hazardous waste stream is not managed as a universal waste, then the waste must be managed as a hazardous waste under the applicable hazardous waste regulations.

It should be noted that any materials resulting from the release or clean-up of spills or breakage of any universal waste is not itself universal waste. It must be determined whether or not such materials are a hazardous waste as identified in 40 CFR Part 261, and the material must then be managed and disposed of in accordance with applicable hazardous or solid waste regulations.

During the site visit, universal waste lamps were observed as well as potential universal waste batteries and are further discussed below.

A1. Lamps (UW) The UW lamp category is slightly broader in that it includes lamps that are hazardous for any characteristic, not just for mercury. However, fluorescent light bulbs remain the most common item in this category of UW. This category does not include associated light fixture components such as ballasts. Hazardous waste lamps become subject to this rule if they are hazardous waste under 40 CFR Part 261, and when they are permanently removed from a fixture or determined to be discarded. A note about crushing: crushing of hazardous waste bulbs is considered treatment, which is explicitly prohibited under the UW Rule (40 CFR 273.11(b) and 273.31(b)). The only circumstance where hazardous waste lamps may be allowed to be crushed is when they are managed as fully regulated hazardous waste (rather than as UW) which is treated (i.e., crushed) in tanks or containers by the generator of the waste under the implied generator treatment allowance in 40 CFR 262.34, and in conformance with all applicable hazardous waste management standards.

The following table is a general summary of lamps readily observed in association with the building (additional quantities may be present which weren’t readily observable).

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Equipment Description General Locations Approximate Quantities

Lamps in 4’ and 2’ Light Fixtures

Throughout the Building ~ 1,400 (+/-) total

A2. Batteries (UW)

This UW category includes discarded primary (non-rechargeable) and secondary (rechargeable) batteries that contain elements such as cadmium, lead, or mercury, which would render them as RCRA hazardous wastes. Examples are nickel-cadmium (Ni-Cad), sealed lead-acid, or mercury-oxide batteries. Lead-acid batteries (such as automotive batteries) that are generated, transported, or collected to be reclaimed, or regenerated, but not reclaimed where stored, under provisions of 40 CFR 266, Subpart G, “Spent Lead-Acid Batteries Being Reclaimed,” do not need to be managed as UW. However, waste lead-acid batteries not managed, or eligible for management, under 40 CFR 266, Subpart G, are subject to the UW Rule requirements. Lead-acid batteries that are stored at facilities that reclaim them are subject to RCRA regulation as specified in 40 CFR 266.80(b). Many commonly generated waste batteries, such as dry cell zinc-carbon and alkaline (“long life”) batteries, typically do not contain appreciable amounts of the hazardous elements of concern, and hence would not be required to be managed as UW. However, they may be managed along with UW batteries, and this is encouraged in the interest of diverting them from less desirable disposal destinies such as incineration or disposal in solid waste landfills.

The following table is a general summary of apparent equipment readily observed which is assumed to contain batteries (unknown types) associated with the building. Terracon did not disassemble equipment but rather assumed that the equipment is not hardwired but contains batteries; additional quantities and equipment may be present.

Equipment Description General Locations Approximate Quantities

Exit Signs – Assumed to Contain Backup Batteries Throughout the Building ~30 (+/-) total

B. Potential PCB-Containing Equipment

During the site visit, fluorescent light fixtures were observed, which are assumed to contain ballasts with potential Polychlorinated biphenyls (PCBs).

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Facilities | Environmental | Geotechnical | Materials 4

PCBs are regulated under the federal Toxic Substance Control Act (TSCA) and were banned from production in the U.S. in 1978. If light ballasts are present from pre-1978, there is a potential they may contain PCBs. Light ballasts without “No PCBs” labels must be assumed to contain PCBs. Terracon did not open light fixture to determine if “No PCBs” labels were present. More modern light ballasts may also contain other potential hazardous constituents, and therefore, it is recommended that all light ballast be properly removed and recycled prior to demolition.

The following table is a general summary of apparent light ballasts associated with the subject building. As noted above, Terracon did not disassemble equipment but rather assumed that light fixtures contained ballast (additional quantities may be present).

Equipment Description General Locations Approximate Quantities

Light Ballasts Throughout the Building ~ 700 (+/-)

C. Refrigerants

Under Section 608 of the Clean Air Act (CAA), U.S. EPA has established regulations (40 CFR Part 82, Subpart F) concerning refrigerants. The highlights of these regulations include:

Require service practices that maximize recovery and recycling of ozone-depleting substances (both chlorofluorocarbons [CFCs] and hydrochlorofluorocarbons [HCFCs] and their blends) during the servicing and disposal of air-conditioning and refrigeration equipment.

Set certification requirements for refrigerant recycling and recovery equipment, technicians, and refrigerant reclaimers.

Restrict the sale of refrigerant to certified technicians.

Require persons servicing or disposing of air-conditioning and refrigeration equipment to certify to EPA that they have acquired refrigerant recovery and/or recycling equipment and are complying with the requirements of the rule.

Require the repair of substantial leaks in air-conditioning and refrigeration equipment with a refrigerant charge greater than 50 pounds.

Establish safe disposal requirements to ensure removal of refrigerants from goods that enter the waste stream with the charge intact.

The following table presents a summary of equipment observed which appeared likely to have associated refrigerants (additional quantities and items may be present). Terracon did not disassemble any equipment as part of this task.

May 11, 2026 | Terracon Project No. LD267060

Facilities | Environmental | Geotechnical | Materials 5

Equipment Description General Locations Approximate Quantities

Walk-In Refrigerator Room 4109 1 total

Drinking Fountains Throughout the Building ~20 (+/-) total

D. Other Items

Hazardous waste under RCRA includes:

Abandoned by being disposed of burned or incinerated, or accumulated, stored or treat (but not recycled) before or instead of being abandoned by being disposed of, burned, or incinerated.

A listed hazardous waste.

A hazardous waste that is listed because it may contain dioxins or dibenzofurans and other toxic constituents and has hazardous waste codes F020, F021, F022, F023, F026, or F028 when it is recycled in any manner.

Smoke detectors are assumed to contain radioactive constituents that would make them hazardous for disposal under the Nuclear Regulatory Commission (NRC). Dishwashers and other installed appliances may also contain constituents that would make them hazardous for disposal. The following table presents a summary of other items observed regarding the building (additional quantities and items may be present which weren’t readily observable).

Equipment Description General Locations Approximate Quantities

Smoke Detectors Throughout the Building ~60 (+/-) units

Dishwasher Room 4117 1 unit

Stove Room 4109 1 unit

Hot Water Heater Mechanical Room 1 unit

Boiler Mechanical Room 2 units

Large Stage and Cafeteria Light Bulbs Room 4110 ~70 (+/-) units

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Facilities | Environmental | Geotechnical | Materials 6

Unit Heaters Throughout the building ~30 (+/-) units

Cleaning Chemicals

Custodial Closets Room 4102

Room 4109 (Kitchen) Room 4110 (Cafeteria)

~21 (+/-) units

CONCLUSIONS

The above items should be taken into consideration regarding he demolition project as they should be first properly addressed and not improperly disposed of with demolition debris or otherwise released to the environment. If items have not reached their useful service life, they should first be considered for removal and reuse, or a service provider or manufacturer may be consulted for potential “take back” programs. Otherwise, if no longer useful or have reached the end of their service life, they should next be considered for recycling if feasible to the particular item. Items such as refrigerants must be reclaimed by an EPA-certified technician. If reuse or recycling are not feasible for particular items, then such items must be properly disposed/treated as applicable under federal RCRA, TSCA, NRC, and/or state regulations. Additionally, please note that Owner may have additional requirements regarding reuse, recycling, treatment, and disposal options.

Terracon appreciates the opportunity to provide this service to Kent ISD. If you have any questions regarding this report or require additional services, please give us a call.

Sincerely, Terracon Consultants, Inc.

Jeff Fusee, CIH, CSP Joseph A. Tussey, CHMM Project Industrial Hygienist Principal