MDNR Torch River Bridge BAS Specs Vol 3.pdf

Due Care Investigation and Preconstruction Recommendations

Torch River Pit Stop BAS – Copeland Acquisition 12929 Cherry Avenue & 12565 S West Torch Drive

Rapid City, Michigan

April 19, 2021

Prepared for:

Michigan Department of Natural Resources Parks and Recreation Division c/o Matt Lincoln, Land Liaison, Grant Coordinator, & Planning Analyst 525 W. Allegan Street Lansing, MI 48933

Prepared by:

363 W. South Airport Road Traverse City, Michigan 49686 Phone: (231) 264-3000 Fax: (231) 264-3001

Global Project # EE20009

Due Care Investigation and Preconstruction Recommendations April 19, 2021 Torch River Bridge BAS – Copeland Acquisition Global Job #EE20009

Global Environmental Engineering Inc. Table of Contents

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 DETAILED PROPERTY INFORMATION

2.1 PROPERTY DESCRIPTION

2.2 HISTORIC ENVIRONMENTAL INVESTIGATIONS AND REMEDIATION

2.3 ENVIRONMENTAL DUE DILIGENCE

2.4 DUE CARE INVESTIGATION

3.0 HAZARDOUS SUBSTANCE INFORMATION

3.1 SECTION 21304C(1)(C) SOIL AND GROUNDWATER COMPARISON TABLES

3.2 EXPOSURE PATHWAY ANALYSIS

4.0 PLAN FOR RESPONSE ACTIVITIES

5.0 EVALUATION AND DEMONSTRATION OF COMPLIANCE WITH SECTION 21304C(1)(C)

5.1 EXACERBATION

5.2 EXERCISE DUE CARE

5.3 REASONABLE PRECAUTIONS

5.4 REASONABLE COOPERATION, ASSISTANCE, AND ACCESS TO AUTHORIZED PERSONS

5.5 COMPLIANCE WITH AND EFFECTIVENESS/INTEGRITY OF LAND USE OR RESOURCE USE RESTRICTIONS

5.6 NOTIFICATION REQUIREMENTS

5.7 FUTURE USE CHANGES

6.0 RECOMMENDATIONS

Figures

Figure 1: Site Location Figure 2: Certificate of Survey Figure 3: Detected Compound Concentrations in Soil

Table

Table 1: Soil Analytical Summary Table 2: Groundwater Analytical Summary

Appendices

Appendix A: Soil Boring Logs Appendix B: Laboratory Report

Appendix C: GPRS Report Appendix D: Phase II Investigation

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1.0 INTRODUCTION

Global Environmental Engineering Inc. (Global) was retained by the Michigan Department of Natural Resources (MDNR) Parks and Recreation Division to complete a Due Dilligence Investigation and to provide Preconstruction recommendations for the property referred to as the Torch River Bridge BAS – Copeland Acquisition and located at 12929 Cherry Avenue and 12565 S West Torch Lake Drive, Rapid City, Michigan, hereafter referred to as the subject property (Figure 1). The MDNR acquired this property on January 31, 2020 and intends to redevelop the property to provide additional parking for a nearby boat access site.

The property historically operated as a refueling and service station. These operations and the historic presence of leaking underground storage tanks (LUST) resulted in petroleum impacts to soil and groundwater. A Phase I Environmental Site Assessment (Phase I ESA), a Phase II Investigation (Phase II), and a Baseline Environmental Assessment were prepared in 2020 for the subject property. Additional soil sampling was conducted on February 19, 2021 to guide the redevelopment of the property and allow for the compliance with Due Care Obligations. The results of this additional investigation are summarized herein. MDNR is non-liable owner/operator of the subject property.

A Documentation of Due Care Compliance (DDCC) is instrument to demonstrate compliance with Due Care obligations pursuant to Section 20107a(1)(c) or Section 21304c(1)(c). While this document in not a DDCC, it loosely follows the DDCC format. Due Care obligations exist for non-liable owner/operators of contaminated properties and generally ensure that unacceptable exposure scenarios for human receptors do not occur and that contamination is not made worse.

A DDCC can be submitted for the Michigan Department of Environment, Great Lakes, and Energy (EGLE) review and concurrence when the document represents current use conditions. The preparation of this document varies from that requirement in that it provides the information necessary for the MDNR to maintain compliance with relevant Due Care obligations during site redevelopment and for the anticipated future use. If EGLE concurrence is requested, the report will require revision to reflect the post-development conditions. This document is intended to guide the safe redevelopment of use of the property considering soil and groundwater impacts associated with a historic refueling station

Section 21304c(1)(c) rules provide that a person who owns or operates a property that he or she has knowledge is a facility, must do all the following:

• Undertake measures to prevent exacerbation of existing contamination;

• Exercise due care by undertaking response activities necessary to mitigate unacceptable exposures to hazardous substances, mitigate fire and explosion hazards due to hazardous substances, and allow for the intended use of the property in a manner that protects the public health and safety;

• Take reasonable precautions against the reasonably foreseeable acts or omissions of a third party and the consequences that could result from those acts or omissions;

• Provide reasonable cooperation, assistance, and access to the persons that are authorized to conduct response activities at the facility, including the cooperation and access necessary for the installation, integrity, operation, and maintenance of any complete or partial response activity at the facility. Nothing in this subdivision shall be interpreted to provide any right of access not

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• Comply with any land use or resource use restrictions established or relied on in connection with the response activities at the facility; and

• Not impede the effectiveness or integrity of any land use or resource use restriction employed at the facility in connection with response activities.

This report is based on information, regarding existing contamination and future site use, known at the time of the completion of this report.

2.0 DETAILED PROPERTY INFORMATION

2.1 Property Description

The subject property is comprised of two parcels:

• 12565 S West Torch Lake Drive was first developed in 1948 and has primarily been a lodge on the shore of Torch Lake with cabins also on the property for seasonal use (there are currently only two cabins on it, but there have been three in the past). The past few years it has been rented on a vacation rental website.

• 12929 Cherry Avenue was first developed in 1951 and was historically a service station with underground storage tanks for retail gasoline sales. The retail gasoline store is referred to as the Torch River Pit Stop. There was a reported release from the gasoline tanks in 1990, again in 1999 and the site was included on the Part 213 list as a Leaking Underground Storage Tank (LUST) site.

Environmental concerns at the subject property are limited to the Torch River Pit Stop Property.

2.2 Historic Environmental Investigations and Remediation

Global submitted a request to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) pursuant to the Freedom of Information Act (FOIA) to review publicly available files for the subject property. The bulk of the information is correspondence and legal documents. Those documents related to the extent of the soil and groundwater contamination are limited and largely pre-date the early 2000s. There are references to work that occurred more recently, including for late 2000s, but those documents were not available for review. Based on correspondence and reports, there was an excavation and the subsequent collection of verification samples indicated soil impacts remained, including in the right-of-way. The extent of the excavation was evaluated at a later date by Compliance Inc. based on email chains, but a report was not available for review.

EGLE (formerly MDEQ and MDNRE) contracted groundwater monitoring from approximately 2009 to 2012. Monitoring also included the collection of samples from the catch basin located onsite and south of Cherry Avenue. It was noted that where elevated groundwater concentrations were observed in proximity to a catch basin, impacts within the catch basins were observed as well. In 2012, groundwater concentrations were significantly reduced, and there did not appear to be a risk to environmental or human receptors, specifically Torch Lake and Torch River. Based on groundwater concentrations identified in 2020, this may no longer be the case.

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Based on information available in EGLE files and the Phase II Investigation that occurred in February 2020, a Work Plan to delineate soil impacts considering site development has been developed and is described below.

2.3 Environmental Due Diligence

Global completed a Phase I Environmental Site Assessment (Phase I ESA) for the property on March 4, 2020, which revealed evidence of recognized environmental condition (REC) as follows:

• The subject property is an open Leaking Underground Storage Tank (LUST). The status is considered Approved Project Completion (APC), however, the groundwater still contained levels of compounds above state clean up criteria in at least one well in January 2012.

• During the site reconnaissance Global inspected the interior of the buildings which has a shop on the north side of the building. There was a circular grate over sump in the floor, which is assumed to have been used as a floor drain. The sump had a hard bottom but had an approximately four

(4) inch pipe leading to the north side of the building located about four (4) inches below the shop floor surface. The floor in the shop had heavy oil staining. There was no evidence of a tank on the north side and no information was found regarding the location of a septic tank or drain field.

The destination of the pipe is unknown. Oil other hazardous material associated with a service station may have drained into the crock and discharged to an unknown location outside of the building.

• The floor in the shop was oil stained and there were large cracks in the concrete. Oil and other hazardous material associated with a service station may have seeped into the site soils through the cracks.

• In the summer of 2019, during construction of a “lip” along the asphalt drive, along the south side of the subject property, the soils which were excavated and graded to install the curb had a strong petroleum odor. Samples were not collected.

Based on the findings of the Phase I ESA, a Phase II Investigation was completed. A total of ten (10) soil borings (SB), including SB-1 through SB-10, were advanced at the site on February 26, 2020 (Figure 2). Petroleum constituents were identified in soil and groundwater at concentrations in excess of Michigan Cleanup Criteria Requirements for Response Activity (Formerly the Part 201 Generic Cleanup Criteria and Screening Levels) (Table 1 and Table 2). Based on these exceedances, the property meets the definition of a “Property” pursuant to Part 213 of the Natural Resources and Environmental Protection Act, Public Act 451, of 1994, (1994 PA 451, Part 213) as amended. Therefore, a Baseline Environmental Assessment (BEA) was filed on behalf of the MDNR (BEA No.: 00034225-BEA-1).

2.4 Due Care Investigation

An additional environmental investigation was conducted on February 19, 2021. The intent of this investigation was to delineate impacted site soils in a manner that facilitates planning portion of redevelopment and allows for compliance with Due Care obligations. Ten (10) soil borings, SB-11 through SB-20, were advanced to 3-feet, which is the approximate depth to water. Soils were continuously screened with a Photoionization Detector (PID). Soil samples were collected at 18 to 24-inches, above the water table and above the capillary fridge/approximate smear zone. Boring locations and analytical results are depicted in Figure 2, Figure 3, and Table 1. Soil boring logs are depicted as Appendix A. The laboratory report is attached as Appendix B.

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In general, clean boundaries of contamination in vadose zone soils above the water table and capillary fringe were identified (Figure 3). In the areas outside of the depicted “Soil Contamination Extent” on Figure 3, impact soils are generally not encountered less than 18 inches below grade based on soil sampling data and PID readings. If excavation work extends beyond 18 inches, into or near the groundwater table, additional consideration will be required for soil and groundwater disposal, if applicable.

3.0 HAZARDOUS SUBSTANCE INFORMATION

Hazardous Substances Use MDNR intends to operate the property in support of nearby recreational activities. The property will serve as a parking lot as a primary function. Hazardous substances are not expected to be used in a significant capacity on the property.

Underground Storage Tanks (USTs) and Abandoned Containers Global subcontracted GPRS Inc. to conduct ground penetrating radar (GPR) at the subject property. This work was conducted to assess for the potential of abandoned USTs. Evidence of USTs was not identified (Appendix C)

Environmental Investigations Conducted

Historic work (pre-2020) is described in Section 2.2.

Global conducted a Phase I ESA for the property on March 4, 2020. The Phase I ESA identified recognized environmental concerns (RECs) related to the historic use as a refueling and service station and known historic groundwater and soil contamination. A Phase II Environmental Site Assessment (Phase II ESA) occurred on the subject property on February 20, 2020, and findings were summarized in a letter form report dated March 31, 2020 (Appendix D).

The Phase II involved collected soil and groundwater samples to address concerns related to impacts attributable to historic operations at the site. Petroleum constituents in soil and groundwater were found to exceed criteria. Analytical Results are summarized as Table 1, Table 2, Figure 3, and Figure 4.

Additionally, a BEA was completed for this property on April 10, 2020 on behalf of the MDNR.

Contaminant Fate and Transport Groundwater impacts identified at the subject property are attributable to historic refueling operations.

Groundwater represents a potential transport mechanism for groundwater contamination. Groundwater flow direction in the vicinity of impacts has been established as northeast, in the direction of Torch Lake.

Additionally, a storm sewer in the vicinity of impacts has the potential to convey impacts groundwater to Torch River. Petroleum constituents are biodegradable and with sufficient time, natural processes will degrade the concentrations.

3.1 Section 21304c(1)(c) Soil and Groundwater Comparison Tables

The contaminated status of the subject property was determined from the comparison of the soil and groundwater concentrations to the Cleanup Criteria Requirements for Response Activity

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(Formerly the Part 201 Generic Cleanup Criteria and Screening Levels) for Residential/ Nonresidential Cleanup Criteria (Criteria). Response Activities are included in Section 4.0 considering these exceedances.

Soil and groundwater concentrations are compared with applicable Criteria in Table 1 and Table 2, respectively. Sample locations, soil analytical results, and groundwater analytical results are depicted on Figure 2, Figure 3, and Figure 4, respectively.

3.2 Exposure Pathway Analysis

As shown in the comparison tables of Section 3.1, the maximum concentrations for soil resulted in the following pathway concerns.

Potential Receptors

Exposure Pathway

MDEQ Part 201 Cleanup Criteria

Exposure Pathway Complete or Incomplete

Onsite:

Recreational Use

Ingestion – drinking water

Nonresidential Drinking Water

Protection Criteria (DWP) and

Nonresidential Drinking Water Criteria (DWC)

Incomplete – groundwater wells are not utilized and cannot be installed in the future without further characterization.

Direct Contact with Soil

Residential Direct Contact Criteria

(DC)*

Incomplete – impacted soils with concentrations exceeding DC are located at 1-foot or greater depth.

Recreational users of the site are not likely to encounter soils at depth.

Volatilization to Indoor Air

Screening Values Published in EGLE Vapor Intrusion

Guidance Document**

Incomplete – site structures are intended to be removed or demolished. Future use cannot include the construction of structures in the vicinity of impacted soil or groundwater without additional characterization.

Onsite/Right-of- Way: Utility Worker

Direct Contact with Soil

Non-residential Direct Contact Criteria

Potentially Complete – Soil impacts exist onsite and in the right-of-way at concentrations that exceed non-residential direct contact criteria. This exposure pathway is potentially relevant for utility/construction conducted below grade in the vicinity of contamination. Response Activities are described in Section 4.

Surface Water Groundwater Impacting

Surface Water

Groundwater Surface Water Interface Criteria

(GSI)

Unknown – The GSI pathway was not characterized as part of this work. Based on historic characterization of the GSI pathway, it is not expected that the GSI pathway would result in an unacceptable exposure for human receptors (i.e., groundwater concentrations are not expected to impact surface waters in a manner that would result in a risk to recreational use, swimming, etc.)

* - While the property use will be nonresidential, or more appropriately recreational, nonresidential DC are developed for an adult worker and may not be protective of child receptors.

Unless site-specific recreational criteria are developed, it is appropriate to apply residential criteria for recreational exposure scenarios.

** - Screening Values published by EGLE reflect the best available science, and based on shallow groundwater characteristics, are more appropriate than Groundwater Volatilization to Indoor Air Criteria (GVIIC).

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4.0 PLAN FOR RESPONSE ACTIVITIES

The plan for response activities describes how a property owner will satisfy obligations under Section 21304c(1)(c) regarding the intended use of the property and addresses the intended response activities that will be or have been conducted.

Groundwater Well Installation As part of site redevelopment, remaining groundwater wells on the subject property should be properly abandoned pursuant to local and state requirements. The future use of the property will not include the use of a groundwater well for potable or non-potable use.

Direct Contact Soils – Notice of Migration Soil contaminant concentrations onsite and in the right-of-way are present at concentrations that exceed residential and non-residential direct contact criteria. Because these concentrations are found at 1-foot or greater, they are not expected to represent a concern for recreational use (child and adult receptors) at the site. However, the concentrations exceed non-residential direct contact criteria, protective of an adult work, and with the presence of utilities in these areas, it is possible that unacceptable exposures could occur.

Third parties with easements, rights-of-way, utilities, etc. will be notified via a Notice of Migration to inform of the existence of soil impacts at concentrations that require specific consideration. Work conducted by third parties cannot exacerbate contamination.

Volatilization to Indoor Air Pathway All structures onsite will be removed or demolished. Future structures cannot be located in the area of groundwater and or soil contamination without additional characterization or the implementation of a mitigation system.

Soil Relocation Impacted site soils remain on the subject property as depicted on Figure 3 and discussed in Section 2.0.

Impacted soils cannot be moved on the property and will require proper disposal pursuant to local, state and federal requirements.

5.0 EVALUATION AND DEMONSTRATION OF COMPLIANCE WITH SECTION 21304C(1)(C)

This section is an evaluation of the information in the previous sections that discuses and demonstrates how the proposed use satisfies obligations under Section 21304c(1)(b). The evaluation and demonstration of compliance is discussed below.

5.1 Exacerbation

The current and future site use is not expected to exacerbate the existing contamination or increase potential response costs. Additional delineation efforts took place as described in Section 2. Soil disturbances will consider the results of environmental investigations conducted to date and be conducted in accordance with applicable laws and regulations. Contaminated soils will remain onsite undisturbed, and disturbed soils in areas of known impact will be appropriately characterized and transported offsite by a licensed waste hauler for disposal at a licensed facility

Torch River Bridge BAS – Copeland Acquisition Global Job #EE20009

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5.2 Exercise Due Care

Information regarding the environmental condition of the property will be communicated and disclosed as is required by applicable local, state and federal law. The existence of the DDCC will also be communicated and a copy will be provided to subsurface workers and contractors upon request.

5.3 Reasonable Precautions

A copy of the Documentation of DDCC will be retained by the MDNR and be made available for review by third parties requiring information about site conditions. Copies of this document will be provided to future owners/operators or lessees of the site.

Based on the results of the soil and groundwater sampling at this site drinking water protection and groundwater surface water interface protection criteria were exceeded.

Additional safety measure for onsite works are not thought to be required.

5.4 Reasonable Cooperation, Assistance, and Access to Authorized Persons

The MDNR will provide reasonable cooperation, assistance, and access to the persons that are authorized to conduct response activities at the facility, including the cooperation and access necessary for the installation, integrity, operation, and maintenance of any complete or partial response activity at the facility.

5.5 Compliance with and Effectiveness/Integrity of Land Use or Resource Use Restrictions

At the time of this report, no recorded Land Use or Resource Use Restrictions are thought to exist at the subject property (i.e. restrictive covenants, etc.). Necessary response activities to avoid unacceptable exposure scenarios are described herein.

5.6 Notification Requirements

Rule 1013 – Notice of Discarded and/or Abandoned Containers

No evidence of discarded or abandoned containers were identified on the property;

therefore, no notice was filed.

Rule 1017 – Notice of Fire and Explosion Hazardous No known fire or explosion hazards exist on the property; therefore, no notice was filed.

Rule 1017 – Notice of Migration of Contamination Based on the potential for groundwater to migrate onto an adjoining parcel to the west and in an abundance of caution, a Notice of Migration of Contamination will be filed for the adjacent property to the east and to any easement holders.

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Soil Movement Notice The removal or relocation of contaminated soil at the subject property will be conducted in accordance with this document and consistent with EGLE requirements.

5.7 Future Use Changes

If the future use of the property changes in a manner that the obligations, response activities, or due care described within this report are no longer applicable to the site conditions, this report will be revised.

6.0 RECOMMENDATIONS

Based on the investigations conducted to date, response activities and measures for compliance with Due Care obligations as described herein will allow the safe redevelopment of the subject property. The recommendations for response activities are as follows:

Soil Disturbance/Relocation:

Figure 3 depicts the locations of known soil impacts on the subject property. The shaded areas are the estimated and known areas of impacted soil from near the surface and below. The remaining portion of the property is not believed to be impacted less than approximately 18-inches below grade. Impacted groundwater and soils below the water likely exist across the site.

Excavation activities that occur at greater than 18-inches or within the shaded portions of Figure 3 warrant additional characterization and proper disposal. Additional measures for worker safety are also warranted due to exceedances of direct contact criteria. These soils also cannot be relocated on the site. If evidence of soil impacts (i.e., staining, odor, etc.) are noted during excavation activities beyond the depiction of Figure 3 and the descriptions herein, additional characterization is needed.

Drinking Water Wells Because of exceedances for drinking water criteria, onsite drinking water wells should be properly abandoned and additional wells should not be installed.

Onsite Structures Due to soil and groundwater impacts, there are concerns related to the volatilization to indoor air pathway (VIAP). Therefore, buildings should not be constructed where impacts to soil and groundwater have been identified.

Global Environmental Engineering Inc. completed a Due Care Investigation and summarized the findings of past environmental work in this report to guide site development. All recommendations described herein are based on information available to Global at the time of this report.

Torch River Bridge BAS – Copeland Acquisition 12929 Cherry Ave & 12565 S West Torch Lake Dr.

Rapid City, Michigan

Torch River Bridge BAS – Copeland Acquisition

12929 Cherry Ave & 12565 S West Torch Lake Dr.

Rapid City, Michigan

AutoCAD SHX Text 16" Storm Drain

AutoCAD SHX Text Septic System

AutoCAD SHX Text House

AutoCAD SHX Text Approximate Extent of Excavation

AutoCAD SHX Text

MW-1

AutoCAD SHX Text Dispensers

AutoCAD SHX Text Former

AutoCAD SHX Text Former USTs

AutoCAD SHX Text

MW-11

AutoCAD SHX Text 16"

AutoCAD SHX Text

CB

AutoCAD SHX Text

CB

AutoCAD SHX Text 12"

AutoCAD SHX Text

MW-17

AutoCAD SHX Text

CB

AutoCAD SHX Text Former USTs

AutoCAD SHX Text (Destroyed)

AutoCAD SHX Text

MW-7

AutoCAD SHX Text

MW-2

AutoCAD SHX Text Asphalt Driveway

AutoCAD SHX Text

MW-5

AutoCAD SHX Text Fence

AutoCAD SHX Text Driveway

AutoCAD SHX Text West Torch

AutoCAD SHX Text Cabin

AutoCAD SHX Text

MW-4

AutoCAD SHX Text Gravel Driveway

AutoCAD SHX Text Building

AutoCAD SHX Text Trailer

AutoCAD SHX Text

MW-3

AutoCAD SHX Text (Destroyed)

AutoCAD SHX Text Garage

AutoCAD SHX Text

MW-6

AutoCAD SHX Text

MW-8

AutoCAD SHX Text Cabin

AutoCAD SHX Text Approximate scale in feet

AutoCAD SHX Text

MW-10

AutoCAD SHX Text

MH

AutoCAD SHX Text

CB

AutoCAD SHX Text

CB

AutoCAD SHX Text

MW-16

AutoCAD SHX Text Real Estate Office

AutoCAD SHX Text

MW-12

AutoCAD SHX Text MW-12d

AutoCAD SHX Text Cherry Avenue

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text DNR Torch Lake Access

AutoCAD SHX Text DNR Boat Ramp

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text

MW-15

AutoCAD SHX Text Torch Lake

AutoCAD SHX Text

MW-13

AutoCAD SHX Text Fence

AutoCAD SHX Text

MW-9

AutoCAD SHX Text

MW-18

AutoCAD SHX Text

MW-14

AutoCAD SHX Text MW-13d

AutoCAD SHX Text

SB-1

AutoCAD SHX Text

SB-2

AutoCAD SHX Text

SB-3

AutoCAD SHX Text

SB-4

AutoCAD SHX Text

SB-7

AutoCAD SHX Text

SB-8

AutoCAD SHX Text

SB-5

AutoCAD SHX Text

SB-6

AutoCAD SHX Text

SB-10

AutoCAD SHX Text

SB-9

AutoCAD SHX Text Approximate Location of

AutoCAD SHX Text Asphalt Curb

AutoCAD SHX Text Global Job:EE20009

AutoCAD SHX Text Date:03/26/20

AutoCAD SHX Text N

AutoCAD SHX Text Note: Adapted from a drawing by Compliance, Inc. dated 2/22/09 and Global field observations.

AutoCAD SHX Text Figure 3

AutoCAD SHX Text Scaled Site Map with Detected Groundwater Contaminant Concentrations

AutoCAD SHX Text Historic MW Location

AutoCAD SHX Text PH II Soil Boring

AutoCAD SHX Text Legend

AutoCAD SHX Text Phase II Investigation

AutoCAD SHX Text (Abandoned 9/19/12)

AutoCAD SHX Text All samples analyzed for VOCs

AutoCAD SHX Text & PNAs-only those compounds

AutoCAD SHX Text detected are depicted

AutoCAD SHX Text All units are ug/L or PPB

AutoCAD SHX Text Highlighted/Bold Exceed Criteria

AutoCAD SHX Text (02/26/2020)

May 19, 2021

Jill A. Auger, P.E.

Senior Project Manager

363 W. South Airport Road

Traverse City, MI 49686

RE: Visual Inspection and Final Clearance Testing, 12565 S. West Torch Lake Drive, Rapid City, Michigan;

ERG Project # 5714.001

Dear Ms. Auger:

On Tuesday, April 27, 2021, Environmental Resources Group, LLC. (ERG) performed a visual inspection and final clearance sampling after the removal of the following asbestos containing materials from the Garage:

36 square feet (s.f.) of window glazing compound, 260 s.f. of red linoleum and associated mastic, 53 s.f.

of drywall joint compound (and the associated non‐asbestos containing drywall), 210 s.f. of grey cement board, 25 s.f. of blue 9” x 9” floor tile and 15 s.f. of roof caulk. Additionally, a visual inspection was conducted in the Lodge when ACM was removed. The abatement was conducted by Mid‐State Asbestos

Removal (MAR) of St. Louis, Michigan.

The asbestos‐containing material from the Garage had been removed, the visual inspection successfully completed and clearance sampling conducted in the Garage. In the Lodge, the white window and door frame caulk had been successfully removed, but residue from the caulk on the glass blocks remained and the visual inspection was not considered successful inside the Lodge.

The final clearance air samples were collected and analyzed on‐site pursuant to the requirements of the modified NIOSH 7400 Method, Issue # 3. The analysis indicated that the airborne fiber concentrations within the Garage were below 0.05 fibers per cubic centimeter of air (f/cc), which is below the State of

Michigan requirement. In fact, airborne fiber concentrations were below 0.01 f/cc. As a point of reference, airborne fiber concentrations following asbestos removal in a K‐12 school building (where the most stringent EPA rules apply) must be below 0.01 f/cc. As such, the Garage may be safely re‐occupied.

In the Lodge, the contractor must return to reclean the glass block, paying particular attention to the mortar joints between the blocks. Your firm may conduct the visual inspection, and if successful, may release the building for re‐occupancy. As the caulk is not friable, no clearance testing is recommended or required.

5714.001

May 19, 2021

The Air Sample Data Sheet and a Digital Photograph Log have been enclosed for your records. Please contact my if you have any questions.

Respectfully, Phillip A. Peterson

Senior Project Manager

Enclosures

PROJECT NUMBER 5714.001 DATE 4/27/2021 DATE COLLECTED:

PROJECT SAMPLED BY

CLIENT ANALYZED BY

AIR SAMPLE DATA SHEET

SAMPLE FLOW ON

DESCRIPTION TIME ON TIME FLOW OFF AVERAGE VOLUME CONC.

SAMPLE # TYPE (NAME, TASK, LOCATION) TIME OFF (MIN) (L/MIN) FLOW (LITERS) FIBERS FIELD F/MM

FIBERS/CC

11:02 13.5

12:25 13.5

11:03 11.5

12:26 11.5

SAMPLE TYPES: AF ‐ AGGRESSIVE FINAL CLEARANCE

AM ‐ AREA MONITORING, DURING REMOVAL

SAMPLE FIBERS FIELDS FIBERS/ BL ‐ BASELINE

TYPE DESCRIPTION OF SAMPLE COUNTED COUNTED MM2

HE ‐ HEPA EXHAUST, DURING REMOVAL

CR ‐ CLEAN ROOM, DURING REMOVAL

EL ‐ EXCURSION LIMIT

IE ‐ INSIDE ENCLOSURE, DURING REMOVAL

RE ‐ REPRESENTATIVE EXPOSURE

P ‐ PERIMETER

PA ‐ POST ABATEMENT AREA SAMPLE

PF ‐ PASSIVE FINAL CLEARANCE

* ‐ SAMPLE OCCLUDED

# ‐ SAMPLE DAMAGED

AB ‐ ANALYTICAL BLANK

QC ‐ QUALITY CONTROL SAMPLE

DC ‐ DUPLICATE SAMPLE

ANALYST: FB ‐ FIELD BLANK

FB 100

Field Blank

Field Blank

FB 100

<0.005

<0.005

4.5

955.0

13.5

11.5

12565 S. West Torch Lake Drive, Rapid City, MI

Global Environmental Engineering

SIGNATURE

4/27/2021

Phillip A. Peterson

Phillip A. Peterson

QUALITY CONTROL DATA

PF

PF Main garage bay

East side office (main entrance)

Site: 12565 South West Torch Lake Drive ERG Project #: 5714.001

1. The Garage at 12565 South

West Torch Lake Drive as viewed from South West Lake

Drive.

2. Windows at the Garage were removed in their entirety to accommodate removal of the window glazing compound.

Window openings were boarded up for security reasons.

3. A variety of asbestos containing materials were removed from within the

Garage, including: linoleum, drywall joint compound (and drywall), cement board and floor tile. Debris visible on the floor below the window is not

ACM, but rather, sawdust, paint chips and cinderblock debris.

4. Following the visual inspection, final clearance air sampling was conducted. This sample was collected in the East office area of the Garage.

5. The Lodge as viewed looking

North.

6. The Lodge had window and door frame caulk which was removed from the large outside windows.

7. The Lodge has asbestos containing caulk. This material was not completely removed, out the contractor was asked to return to the site to remove this residue.

8. A Phase Contrast Microscopy

(PCM) laboratory was set up inside the Lodge to accommodate preparation and analysis of the clearance samples from the

Garage.

9. A Phase Contrast Microscope was set up and calibrated in the

Lodge for clearance sample analysis.

363 W. South Airport • Traverse City, MI 49686 • Bus: (231) 264- 3000 • Fax: (231) 264-3001 10312 N. Holly Road • Holly, MI 48442 •

Bus: (810) 238-9190 • Fax: (810) 238-9195

May 28, 2021

Matt Lincoln Land Liaison, Grants Coordinator, Planning Analyst Parks and Recreation Division Michigan Department of Natural Resources Constitution Hall 525 W. Allegan Street Lansing, MI 48933 lincolnm@michigan.gov

Re: Visual Inspection and Final Clearance Teting Report (Asbestos) 12565 W. Torch Lake Drive & 12929 Cherry Avenue, Rapid City, Michigan

Dear Mr. Lincoln, Asbestos abatement was completed at the Torch River Bridge BAS – Copeland Acquisition, located at 12565 W. Torch Lake Drive & 12929 Cherry Avenue, Rapid City, Michigan on April 26, 2021. An Asbestos Visual Inspection and Final Clearance Testing was completed on April 27, 2021. The inspection report, attached, indicates that all asbestos-containing material was successfully removed from the garage with one exception described below. The air clearance sampling in the garage was conducted and airborne fiber concentrations were below the State of Michigan requirement.

Following the asbestos removal, a glass black wall in the lodge had asbestos containing caulk residue in the mortar joints. The asbestos abatement contactor returned to the site on approximately April 28, 2021 and removed the residue. Staff Scientist, Marnie Lawrence of Global Environmental Engineering Inc.

returned to the site on May 2, 2021 and confirmed the residue had been completely removed.

The asbestos removal and inspection are complete at this site.

Please contact me with any questions.

Sincerely, GLOBAL ENVIRONMENTAL ENGINEERING INC.

Jill A. Auger, P.E.

Senior Project Manager

Attachment

Revision Date: 3/2022

APPENDIX X

PREVAILING WAGES

STATE OF MICHIGAN

Wage and Hour Division PO Box 30476

Lansing, MI 48909 517-284-7800

Informational Sheet: Prevailing Wages on DTMB Projects

WHD 9918 (2/22)

REQUIREMENTS

The purpose of establishing prevailing rates is to provide minimum rates of pay that must be paid to workers on Department of Technology, Management and Budget (DTMB) construction projects that are financed or financially supported by the state Prevailing rates are compiled from the rates contained in collectively bargained agreements which cover the locations of the state projects. Whi le the DTMB prevai l ing wage rates are compi led though surveys of col lect ive ly bargained agreements, a col lect ive bargain ing agreement is not required for contractors to be on or be awarded state pro jects. The prevailing rate schedule provides an hourly rate which includes wage and fringe benefit totals for designated construction mechanic classifications. The overtime rates also include wage and fringe benefit totals.

Please pay special attention to the overtime and premium pay requirements. The DTMB prevailing wage is satisfied when wages plus fringe benefits are equal to or greater than the required rate.

State of Michigan responsibilities:

• The department establishes the prevailing rate for each classification of construction mechanic requested by DTMB prior to contracts being let out for bid on a state project.

DTMB responsibilities

• If a contract is not awarded or construction does not start within 90 days of the date of the issuance of rates, a re- determination of rates must be requested by DTMB

• Rates for classifications needed but not provided on the DTMB Prevailing Rate Schedule, must be obtained prior to contracts being let out for bid on a state project.

Contractor responsibilities:

• Every contractor and subcontractor shall keep posted on the construction site, in a conspicuous place, a copy of all prevailing rates prescribed in a contract.

• Every contractor and subcontractor shall keep an accurate record showing the name and occupation of and the actual wages and benefits paid to each construction mechanic. This record shall be available for reasonable inspection by DTMB or the department.

• Each contractor or subcontractor is separately liable for the payment of the prevailing rate to its employees.

• The prime contractor is responsible for advising all subcontractors of the requirement to pay the prevailing rate prior to commencement of work.

• A construction mechanic shall only be paid the apprentice rate if registered with the United States Department of Labor, Bureau of Apprenticeship and Training and the rate is included in the contract.

Enforcement:

A person who has information of an alleged prevailing wage violation on a DTMB project may file a complaint with the State of Michigan. The department will investigate and attempt to resolve the complaint informally.

During the course of an investigation, if the requested records and posting certification are not made available in compliance with contractual requirements, the State may consider the Contactor to be in material breach of the contract and may terminate the contract for cause at the States sole discretion.

Informational Sheet: DTMB Prevailing Wages on State Projects

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General Information Regarding Fringe Benefits

Certain fringe benefits may be credited toward the payment of the Prevailing Wage Rate:

o If a fringe benefit is paid directly to a construction mechanic o If a fringe benefit contribution or payment is made on behalf of a construction mechanic o If a fringe benefit, which may be provided to a construction mechanic, is pursuant to a written contract or policy o If a fringe benefit is paid into a fund, for a construction mechanic

When a fringe benefit is not paid by an hourly rate, the hourly credit will be calculated based on the annual value of the fringe benefit divided by 2080 hours per year (52 weeks @ 40 hours per week).

The following is an example of the types of fringe benefits allowed and how an hourly credit is calculated:

Vacation 40 hours X $14.00 per hour = $560/2080 = $.27 Dental insurance $31.07 monthly premium X 12 mos. = $372.84 /2080 = $.18 Vision insurance $5.38 monthly premium X 12 mos. = $64.56/2080 = $.03 Health insurance $230.00 monthly premium X 12 mos. = $2,760.00/2080 = $1.33 Life insurance $27.04 monthly premium X 12 mos. = $324.48/2080 = $.16 Tuition $500.00 annual cost/2080 = $.24 Bonus 4 quarterly bonus/year x $250 = $1000.00/2080 = $.48 401k Employer Contribution $2000.00 total annual contribution/2080 = $.96

Total Hourly Credit $3.65 Other examples of the types of fringe benefits allowed:

• Sick pay

• Holiday pay

• Accidental Death & Dismemberment insurance premiums

The following are examples of items that will not be credited toward the payment of the Prevailing Wage Rate o Legally required payments, such as:

• Unemployment Insurance payments

• Workers’ Compensation Insurance payments

• FICA (Social Security contributions, Medicare contributions) o Reimbursable expenses, such as:

• Clothing allowance or reimbursement

• Uniform allowance or reimbursement

• Gas allowance or reimbursement

• Travel time or payment

• Meals or lodging allowance or reimbursement

• Per diem allowance or payment o Other payments to or on behalf of a construction mechanic that are not wages or fringe benefits, such as:

• Industry advancement funds

• Financial or material loans

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OVERTIME PROVISIONS for MICHIGAN PREVAILING WAGE RATE COMMERCIAL SCHEDULE

1. Overtime is represented as a nine character code. Each character represents a certain period of time after the first 8 hours Monday thru Friday.

Monday thru Friday

Saturday

Sunday & Holidays

Four 10s First 8 Hours 4

8 9 9th Hour 1 5 10th Hour 2 6 Over 10 hours 3 7

Overtime for Monday thru Friday after 8 hours:

the 1st character is for time worked in the 9th hour (8.1 - 9 hours) the 2nd character is for time worked in the 10th hour (9.1 - 10 hours) the 3rd character is for time worked beyond the 10th hour (10.1 and beyond)

Overtime on Saturday:

the 4th character is for time worked in the first 8 hours on Saturday (0 - 8 hours) the 5th character is for time worked in the 9th hour on Saturday (8.1 - 9 hours) the 6th character is for time worked in the 10th hour (9.1 - 10 hours) the 7th character is for time worked beyond the 10th hour (10.01 and beyond)

Overtime on Sundays & Holidays The 8th character is for time worked on Sunday or on a holiday

Four Ten Hour Days The 9th character indicates if an optional 4-day 10-hour per day workweek can be worked between Monday and Friday without paying overtime after 8 hours worked, unless otherwise noted in the rate schedule. To utilize a 4 ten workweek, notice is required from the employer to employee prior to the start of work on the project.

2. Overtime Indicators Used in the Overtime Provision:

H - means TIME AND ONE-HALF due X - means TIME AND ONE-HALF due after 40 HOURS worked D - means DOUBLE PAY due Y - means YES an optional 4-day 10-hour per day workweek can be worked without paying overtime after 8 hours worked N - means NO an optional 4-day 10-hour per day workweek cannot be worked without paying overtime after 8 hours worked

3. EXAMPLES:

HHHHHHHDN - This example shows that the 1½ rate must be used for time worked after 8 hours Monday thru Friday (characters 1 - 3); for all hours worked on Saturday, 1½ rate is due (characters 4 - 7). Work done on Sundays or holidays must be paid double time (character 8). The N (character 9) indicates that 4 ten-hour days is not an acceptable workweek at regular pay.

XXXHHHHDY - This example shows that the 1½ rate must be used for time worked after 40 hours are worked Monday thru Friday (characters 1-3); for hours worked on Saturday, 1½ rate is due (characters 4 – 7). Work done on Sundays or holidays must be paid double time (character 8). The Y (character 9) indicates that 4 ten-hour days is an acceptable alternative workweek.

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ENGINEERS - CLASSES OF EQUIPMENT LIST

UNDERGROUND ENGINEERS

CLASS I

Backfiller Tamper, Backhoe, Batch Plant Operator, Clam-Shell, Concrete Paver (2 drums or larger), Conveyor Loader (Euclid type), Crane (crawler, truck type or pile driving), Dozer, Dragline, Elevating Grader, End Loader, Gradall (and similar type machine), Grader, Power Shovel, Roller (asphalt), Scraper (self propelled or tractor drawn), Side Broom Tractor (type D-4 or larger), Slope Paver, Trencher (over 8’ digging capacity), Well Drilling Rig, Mechanic, Slip Form Paver, Hydro Excavator.

CLASS II

Boom Truck (power swing type boom), Crusher, Hoist, Pump (1 or more 6" discharge or larger gas or diesel powered by generator of 300 amps or more, inclusive of generator), Side Boom Tractor (smaller than type D-4 or equivalent), Tractor (pneu-tired, other than backhoe or front end loader), Trencher (8’ digging capacity and smaller), Vac Truck.

CLASS III

Air Compressors (600 cfm or larger), Air Compressors (2 or more less than 600 cfm), Boom Truck (non-swinging, non-powered type boom), Concrete Breaker (self-propelled or truck mounted, includes compressor), Concrete Paver (1 drum, ½ yard or larger), Elevator (other than passenger), Maintenance Man, Mechanic Helper, Pump (2 or more 4" up to 6" discharge, gas or diesel powered, excluding submersible pump), Pumpcrete Machine (and similar equipment), Wagon Drill Machine, Welding Machine or Generator (2 or more 300 amp or larger, gas or diesel powered).

CLASS IV

Boiler, Concrete Saw (40HP or over), Curing Machine (self-propelled), Farm Tractor (w/attachment), Finishing Machine (concrete), Firemen, Hydraulic Pipe Pushing Machine, Mulching Equipment, Oiler (2 or more up to 4", exclude submersible), Pumps (2 or more up to 4" discharge if used 3 hrs or more a day-gas or diesel powered, excluding submersible pumps), Roller (other than asphalt), Stump Remover, Vibrating Compaction Equipment (6’ wide or over), Trencher (service) Sweeper (Wayne type and similar equipment), Water Wagon, Extend-a-Boom Forklift.

HAZARDOUS WASTE ABATEMENT ENGINEERS

CLASS I

Backhoe, Batch Plant Operator, Clamshell, Concrete Breaker when attached to hoe, Concrete Cleaning Decontamination Machine Operator, Concrete Pump, Concrete Paver, Crusher, Dozer, Elevating Grader, Endloader, Farm Tractor (90 h.p. and higher), Gradall, Grader, Heavy Equipment Robotics Operator, Hydro Excavator, Loader, Pug Mill, Pumpcrete Machines, Pump Trucks, Roller, Scraper (self-propelled or tractor drawn), Side Boom Tractor, Slip Form Paver, Slope Paver, Trencher, Ultra High Pressure Waterjet Cutting Tool System Operator, Vactors, Vacuum Blasting Machine Operator, Vertical Lifting Hoist, Vibrating Compaction Equipment (self-propelled), and Well Drilling Rig.

CLASS II

Air Compressor, Concrete Breaker when not attached to hoe, Elevator, End Dumps, Equipment Decontamination Operator, Farm Tractor (less than 90 h.p.), Forklift, Generator, Heater, Mulcher, Pigs (Portable Reagent Storage Tanks), Power Screens, Pumps (water), Stationary Compressed Air Plant, Sweeper, Water Wagon and Welding Machine.

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CARPENTER CRAFT JURISDICTION

Michigan recognizes the Carpenters for any and all work related to weatherization that has historically been the work of the Carpenter. This work shall include, but not be limited to: all work defined under the Federal Weatherization Assistance Program.

The jurisdiction of Carpenters, as to all work that has historically and traditionally been performed consisting of the milling, fashioning, joining, assembling, erecting, fastening or dismantling of all materials of wood, plastic, metal, fiber, cork, or composition and all other substitute materials, as well as the handling, cleaning, erecting, installing and dismantling of all machinery, equipment and all materials used by Carpenters.

The jurisdiction, therefore, extends over the following divisions and subdivisions of the trade: Carpenters and Joiners, Millwrights, Pile Drivers, Bridge, Dock and Wharf Carpenters, Underpinners, Timbermen, and Core-drillers, Shipwrights, Boat Builders, Ship- hand, Stair-Builders, Millmen, Wood and Resilient Floor Decorators, Floor Finishers, Carpet-layers, Shinglers, Siders, Insulators, Acoustic and Drywall Applicators, Sharers and House Movers, Loggers, Lumber and Sawmill Workers, Reed and Rattan Workers, Shingle Weavers, Casket and Coffin Makers, Railroad Carpenters and Car Builders, regardless of material used and all those engaged in the operation of woodworking or other machinery required in fashioning, milling or manufacturing of products used in the trade, and the handling, erecting and installing materials on any of the above divisions or sub-divisions, burning, welding and rigging incidental to the trade. When the term "Carpenter and Joiner" is used, it shall mean all the subdivisions of the trade. The trade autonomy of Carpenters therefore extends over the divisions and subdivisions of the trade, which are set forth as follows:

(a) The framing, erecting and prefabrication of roofs, partitions, floors and other parts of buildings of wood, metal, plastic or other substitutes; application of all metal flashing used for hips, valleys and chimneys; the erection of Stran Steel section or its equal. The building and setting of all forms and centers for brick and masonry. The fabrication and erection of all forms for concrete and decking, the dismantling of same (as per International Agreement) when they are to be re-used on the job or stored for re-use. The cutting and handling of all falsework for fireproofing and slabs. Where power is used in the setting or dismantling of forms, all signaling and handling shall be done by carpenters. The setting of templates for anchor bolts for structural members and for machinery, and the placing, leveling and bracing of these bolts. All framing in connection with the setting or metal columns. The setting of all bulkheads, footing forms and the setting of and fabrication of, screeds and stakes for concrete and mastic floors where the screed is notched or fitted, or made up of more than one member. The making of forms for concrete block, bulkheads, figures, posts, rails, balusters and ornaments, etc.

(b) The handling and erecting of rough material and drywall, the handling, assembly, setting and leveling of all fixtures, display cases, all furniture such as tables, chairs, desks, coat racks, etc., all de-mountable or moveable partitions such as Von wall, E Wall, Steel Case, Herman Miller, Haworth, American Seating, Westinghouse, Lazy Boy, rosewood, etc.