Analysis of Brownfield Cleanup Alternatives Former Mt. Pleasant Center, 1400 West Pickard Street, Mt. Pleasant, Michigan 48858

Transcription

1 Analysis of Brownfield Cleanup Alternatives Former Mt. Pleasant Center, 1400 West Pickard Street, Mt. Pleasant, Michigan City of Mt. Pleasant 2012 Cleanup Grant Cooperative Agreement No: BF-00E PREPARED FOR: PROJECT #: DATE: City of Mt. Pleasant 320 West Broadway Street Mt. Pleasant, Michigan s July 26, 2013

2 Table of Contents 1.0 INTRODUCTION BACKGROUND SITE DESCRIPTION SITE HISTORY PREVIOUS ENVIRONMENTAL INVESTIGATIONS CURRENT ENVIRONMENTAL CONCERNS CLEANUP STANDARDS / APPLICABLE LAWS PROPOSED CLEANUP OBJECTIVES POTENTIAL CLEANUP ALTERNATIVES Option No. 1 No Action Option No. 2 Asbestos Abatement RECOMMENDED CLEANUP ALTERNATIVE CONCLUSION...7 FIGURES Figure 1... Subject Property Location Map Figure 2... Topographic Location Map Figure 3... Site Map APPENDICES Appendix A... Notification of Intent to Renovate/Demolish I

3 ANALYSIS OF BROWNFIELD CLEANUP ALTERNATIVES Former Mt. Pleasant Center, 1400 West Pickard Street, Mt. Pleasant, Michigan AKT Peerless Project No. 6386s City of Mt. Pleasant 2012 Cleanup Grant Cooperative Agreement No: BF-00E Introduction This Analysis of Brownfield Cleanup Alternatives (ABCA) was prepared by AKT Peerless Environmental & Energy Services LLC (AKT Peerless) for the City of Mt. Pleasant. The ABCA is a required element of the United States Environmental Protection Agency (USEPA) Hazardous Substance Brownfield Cleanup (HSBC) Grant awarded to the City of Mt. Pleasant by the USEPA in The HSBC Grant was awarded to start environmental remediation at a brownfield site and eligible property within the City of Mt. Pleasant. The property is identified as the Former Mt. Pleasant Regional Center, 1400 West Pickard Street, Mt. Pleasant, Michigan that is located in the east ½ of Section 9 in Mt. Pleasant (T.14N/R.4W), Isabella County, Michigan. The City of Mt. Pleasant is the current owner of the subject property. In preparing the ABCA, the City of Mt. Pleasant considered environmental factors, various site characteristics, surrounding properties, land use restrictions, potential future uses, and cleanup goals. 2.0 Background 2.1 Site Description The subject property address is 1400 West Pickard Street in Mt. Pleasant, Isabella County, Michigan. The property is located in the east ½ of Section 9 in Mt. Pleasant (T.14N/R.4W), Isabella County, Michigan. The property is situated north of Pickard Road, east of South Bamber Road, south of East River Road, and west of South Crawford Road. The site contains approximately 295 acres. Refer to Figure 1, the Subject Property Location Map. According to City of Mt. Pleasant Zoning Department, the subject property is zoned AG Agricultural. The Subject Property is located in an area of Mt. Pleasant that is characterized by undeveloped, agricultural, commercial, industrial, and residential properties, a creek, surface roadways, municipal water, sanitary sewer services, electrical and gas utilities. ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 1

4 The following table presents additional information regarding the subject property. For ease of reference in this report, AKT Peerless has designated each of the subject property parcels with a letter. These designations have no relevance to legally recorded data about the subject property. Table 2.1 Subject Property Information Parcel Address Tax Identification Number Owner of Record Approximate Acreage A 1400 West Pickard Street Portion of City of Mt. Pleasant ~275 acres B N/A City of Mt. Pleasant ~20 acres The property is developed with 20 structures. General information regarding the on-site buildings (the subject buildings) is presented in the following table. Note that only readily available construction dates are included in the table. Building Number Building Common Name Table 2.2 Subject Building Descriptions Parcel General Description Construction And Other Improvement Dates #4 Cottage 4 Parcel A Dormitory 1958 #5 Cottage 5 Parcel A Dormitory 1966 #7 Cottage 7 Parcel A Dormitory 1954 #8 Cottage 8 Parcel A Dormitory 1954 #9 Cottage 9 PARCEL A Dormitory 1954 #10 Cottage 10 Parcel A Dormitory 1954 #11 Cottage 11 Parcel A Dormitory 1954 #12 Cottage 12 Parcel A Dormitory 1954 #35 Power Plant Parcel A Steam Generation Plant 1956 #36 Laundry Parcel A Laundry Services 1955 #37 Service Building Parcel A Kitchen/Receiving/Storage Services 1956 #38 Maintenance Building (Partially off-site) Parcel A Maintenance Services 1966 #39 Water Tower and Cell Building Parcel A Water Tower And Cell Building Unknown ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 2

5 Building Number Building Common Name Parcel General Description Construction And Other Improvement Dates #40 Admin/Training Parcel A Administration, Hospital, And Training 1966 #75 Mechanical Parcel A Storage And Backup Generator Unknown #79 Incinerator Parcel A Incinerator 1964 #99 Employee Residence (house) Parcel A Residence 1957 #100 Employee Residence (house) Parcel A Residence 1957 #111 Implement Shed Parcel A Storage 1931 #113 Cottage Storage Shed Parcel A Storage Unknown Various other structural developments are located throughout the subject property and include, but are not limited to, underground tunnels, tunnel access structures, pavilion/picnic canopies, fencing, a bridge across Mission Creek, a public emergency tower/siren structure, chiller units, electrical transformers, and sidewalks. Asphalt and concrete-paved areas are located throughout the subject property including roadways and parking lots. Three main roadways: West Wind Drive, Winding Lane, and Woodside Drive are located throughout the site. Remaining portions of the subject property consist of open space, agricultural land, wooded areas, Mission Creek, wetland areas, lowland areas, grassy lawn, and landscaped areas. The agricultural portion of the subject property is leased to a local farmer. Refer to Figure 2 for a Topographic Location Map and Figure 3 for a Site Map depicting subject property features and subject building locations. 2.2 Site History The original buildings and grounds belonged to the Federal Government and operated as the Mt. Pleasant Indian Industrial School from 1891 until 1933 for students of American Indian ancestry. Mission Creek Cemetery, formerly part of the Michigan Home grounds, is located along the western Property boundary on South Bamber Road. The original school buildings, now owned by the Saginaw Chippewa Indian Tribe are located along the eastern Property boundary along South Crawford Street. The adjacent Mission Creek Cemetery (Indian Cemetery), as well as the original Indian Industrial School Chapel are historical landmarks. The facility was deeded to the State of Michigan in 1933, and in early 1934 was renamed the Boys Vocational Department of the Michigan Home and Training School (the Michigan Home). Known as inmates, the first disabled patients were admitted to the Michigan Home at this time. The Michigan Home operated as a medium security institution. In 1934, and for more than a decade beyond, the only hospital in the Mt. Pleasant community was located on the institution's grounds. In later years, the ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 3

6 Regional Center operated under the Michigan Department of Mental Health. At its peak population in the 1960s, more than 1,400 patients lived at the Regional Center. It was closed in 2009 by the State of Michigan. The State began shutting buildings down during the 2000s and the last residents vacated the subject property in September Since that time, building maintenance has been neglected and the buildings have quickly fallen into a significant state of disrepair. The State of Michigan sold the property to the City of Mt. Pleasant in April The property remains vacant. 2.3 Previous Environmental Investigations Below is a list of environmental site assessments (ESAs) and characterization activities that were conducted at the subject property from 2005 through October 2005 Asbestos Building Inspection Reports, prepared by Fibertec Industrial Hygiene Services, Inc. on behalf of the State of Michigan Department of Community Health October 2009 Phase I ESA, prepared by Materials Testing Consultants on behalf of the Michigan Department of Management and Budget March 2011 Phase I ESA, prepared by AKT Peerless Environmental & Energy Services on behalf of the City of Mt. Pleasant Baseline Environmental Assessment (BEA)/Phase II ESA Report, prepared by AKT Peerless Environmental & Energy Services on behalf of the City of Mt. Pleasant Due Care Plan, prepared by AKT Peerless Environmental & Energy Services on behalf of the City of Mt. Pleasant Copies of all reports are on file with the City of Mt. Pleasant and are available upon request. All reports, except for the Due Care Plan are also on-file with the State of Michigan. 2.4 Current Environmental Concerns Subject building construction dates range from 1927 to 1966, with 16 of the 20 buildings built in the 1950s and 1960s. This era was a time of boom construction when asbestos was liberally used, as was the case in buildings on the property. Extensive applications of asbestos containing materials (ACMs) have been identified in the buildings. The asbestos is a serious impediment to demolition and redevelopment of the property. Since 2005, when the asbestos surveys were performed, many of the buildings have fallen into significant disrepair. With roof and piping leaks and no heat or maintenance, the buildings have deteriorated. In several buildings ACMs have fallen onto the ground. The City of Mt. Pleasant s proposed cleanup plan includes the removal and disposal of asbestos located in Building #40 (former main hospital building), Building #4 (former residence cottage), and connecting tunnel. These buildings were selected based on: 1) presence of significant ACM, including materials in poor deteriorated condition, 2) need to prepare these highly visible large blighted structures for demolition, which currently serve as an attractive nuisance, 3) proximity to prime redevelopment areas, 4) location near existing infrastructure, 5) plans to begin demolition from south to north towards the interior of the property, 6) size of the structures, 7) quantities and condition of ACMs present, 8) these buildings contain friable asbestos materials, and 9) need for removal of threats to human health and the environment. ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 4

7 ACMs identified in these buildings are in poor condition and present a threat to human health and the surrounding area. Asbestos debris was identified within each structure as early as Furthermore, these materials continue to deteriorate and could become airborne threatening to impact the surrounding properties. ACMs within the tunnels consist primarily of pipe insulation. Building 40 is the former Hospital and Administration Unit and is vacant. The two story building is 55,110 square feet with a basement area. The building was constructed in ACMs include: plaster, floor tile, insulation cloth and heat shields, sink undercoating, fire doors, laboratory tables, roofing products, and pipe insulation. Building 4 is a former Resident Cottage. The one story building is 32,079 square feet with a basement area. The building was constructed in ACMs include: pipe insulation, roofing/flooring materials, ceiling tiles, window caulk and glazing, and fire doors and frames. 3.0 Cleanup Standards / Applicable Laws Currently two federal agencies have been principally responsible for generating regulations for asbestos control. The two agencies are the United States Occupational Safety and Health Administration (OSHA) and the United States Environmental Protection Agency (USEPA). The OSHA Construction Industry Standard (29 CFR ) covers employees engaged in demolition and construction activities likely to involve asbestos exposure. In Michigan the Michigan Occupational Safety and Health Administration (MIOSHA) Asbestos Program enforces the federal standards. The EPA regulates asbestos application, removal, and disposal of ACMs, under the National Emission Standards for Hazardous Air Pollutants (NESHAP). The asbestos NESHAP protects the public and environment by minimizing the release of asbestos fibers during renovation and demolition activities. In Michigan the Air Quality Division (AQD) of the Michigan Department of Environmental Quality (MDEQ) has been delegated authority to implement the NESHAP program for asbestos. MIOSHA and MDEQ are made aware of and provide oversight of asbestos removal projects by receiving and reviewing the Notification of Intent to Renovate/Demolish forms, which are required to be submitted a minimum of 10 working days prior to starting work. Other agencies promulgating regulations on asbestos include the Department of Transportation (DOT) establishing regulations regarding the transport of asbestos; and the National Institute of Standards and Technology (NIST) establishing standards and protocols for laboratory accreditation. All cleanup work proposed at the property will comply with the above regulations and notification requirements. The proposed cleanup project will comply with all other applicable local, state, and federal regulations not specifically mentioned. 4.0 Proposed Cleanup Objectives The City of Mt. Pleasant intends to use the HSBC Grant to fund the cleanup/abatement of identified ACMs in select buildings and tunnels located at 1400 West Pickard Street, Mt. Pleasant, Michigan. Removing the regulated ACMs from the subject property will protect human health and the ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 5

8 environment, allow for demolition of the subject buildings and prepare the subject property for future redevelopment. The potential cleanup alternatives are evaluated with respect to the following objectives: 1. Compliance with local, state, and federal regulatory requirements. 2. Reduction of threats to human health and the environment. 3. Facilitate the productive redevelopment / repurposing of the subject property to the benefit of the local community. 4.1 Potential Cleanup Alternatives Option No. 1 No Action A No Action alternative would be the lowest cost; however, the No Action alternative will not mitigate the threats to human health and the environment that are known to exist on the subject property and will not facilitate the demolition of the subject buildings and redevelopment of the subject property. The No Action alternative is not recommended as it is not compatible with regulatory requirements or the goals of reducing the environmental threats to human health and the environment and future redevelopment of the subject property Option No. 2 Asbestos Abatement The Asbestos Abatement alternative would be the highest cost, will mitigate the threats to human health and the environment that are known to exist on the subject property, will comply with regulatory requirements, and will facilitate demolition of the subject buildings and redevelopment of the subject property. Asbestos abatement would include the scope of work described below. Before planned demolition, an approved, state-licensed asbestos abatement contractor will remove and properly dispose of ACMs listed in the Pre-Demolition Asbestos Building Inspection Reports. The following example ACMs were identified at the property: Thermal pipe insulation (TSI) and mud fittings on heating and domestic water systems 9 x 9 Vinyl asbestos floor tile (VAT) and associated mastic 12 x 12 Resilient floor tile (RFT) and associated mastic Sheet linoleum Heating duct insulation Ceiling tile glue pods Window glazing compound Smooth plaster Spray-on acoustical plaster Transite cement panels Asbestos abatement work will be performed according to the Occupational Safety and Health Administration (OSHA) requirements of Code of Federal Regulation 29 CFR , the Asbestos Construction Standard, adopted by reference in Michigan as Rule Work activities will also meet the criteria of the Michigan Department of Licensing and Regulatory Affairs Public Act 135, of 1986 (LARA) and the National Emission Standard for Hazardous Air Pollutants 40 CFR Part 61 (NESHAP) for regulatory notification of intent to renovate or demolish. The NESHAP requirements for asbestos ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 6

9 identification, adequate wetting, no visible emissions, and proper waste packaging for disposal will also be followed. Abatement contractors will be licensed (ACT 135 of 1986) and contractor personnel will be accredited (Public Act 440 of 1988) through the LARA Asbestos Program. A biddable specification package will be prepared to include all necessary design drawings, technical specifications, and general requirements. The package will be suitable for bidding purposes to secure a contractor to implement the corrective action, as applicable. As necessary, subsequent investigation may be conducted by the City of Mt. Pleasant to further characterize ACMs prior to release of the specification. The approved contractor will submit a joint Notification of Intent to Renovate/Demolish (Notification) form to the MDEQ, Air Quality Division and the LARA Asbestos Program in advance of asbestos abatement. The Notification will be submitted ten working days prior to on-site activities. The Notification summarizes the project description, schedule, approved contractor, facility owner, disposal location, and engineering controls, etc. Refer to Appendix A for a blank copy of this form. After asbestos abatement activities are completed, final air clearance samples will be collected to verify adequate abatement activities. The final air clearance criterion established by specification for this project is the level referenced in 40 CFR Part 763, Subpart E, of the EPA Asbestos in Schools Rule of 0.01 fibers per cubic centimeter of air or the background level measured before the start of abatement. Clearance samples will be analyzed by phase contrast optical microscopy. Properly trained and equipped personnel shall perform all work. Estimated Cost: The cost to complete ACM abatement activities with the EPA Brownfield Cleanup grant will be $200,000. The City of Mt. Pleasant acknowledges that additional funds will be necessary to complete the asbestos abatement and cleanup at the structures prior to demolition. The Asbestos Abatement alternative is recommended as it is compatible with regulatory requirements, the goals of reducing the environmental threats to human health and the environment, as well as future redevelopment of the subject property. 4.2 Recommended Cleanup Alternative Option No. 2, Asbestos Abatement is recommended for implementation at the subject property, as it is easily implemented, will mitigate risks to human health and the environment, is compatible with regulatory requirements, and will provide a long term cleanup response supporting redevelopment of the subject property. Although easily implemented, it has been determined that Option No. 1 the No Action alternative is not compatible with regulatory requirements or the goals of reducing the environmental threats to human health and the environment and future redevelopment of the subject property. 5.0 Conclusion Remedial alternatives were evaluated based on the proposed cleanup objectives as well as effectiveness, ease of implementation, and cost. ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 7

10 The No Action alternative (Option No.1) will not mitigate the threats to human health and the environment that are known to exist on the subject property and will not facilitate/meet project goals. The City of Mt. Pleasant has recommended not proceeding with Option No.1. The Asbestos Abatement (Option No. 2) alternative is easily implemented, will mitigate risks to human health and the environment, and will provide a long term cleanup response. This option is easily implemented, will mitigate risks to human health and the environment, and will provide a long term cleanup response. In addition, this alternative is necessary to support the redevelopment/intended future use of the property. The City of Mt. Pleasant has recommended proceeding with Option No. 2 Asbestos Abatement. ABCA FORMER MT. PLEASANT CENTER, 1400 WEST PICKARD STREET, MT. PLEASANT, MI DATE: JULY 26, 2013 Page 8

11 Figures

12 AKTPEERLESS environmental & energy services CHICAGO DETROIT FARMINGTON LANSING SAGINAW SUBJECT PROPERTY LOCATION MAP FORMER MT. PLEASANT CENTER 1400 WEST PICKARD ROAD MT. PLEASANT, MICHIGAN PROJECT NUMBER : 6386s LEGEND DRAWN BY: OGO DATE: FIGURE 1

13 MOUNT PLEASANT QUADRANGLE MICHIGAN - ISABELLA COUNTY 7.5 MINUTE SERIES (TOPOGRAPHIC) MILE FEET KILOMETER CONTOUR INTERVAL 10 FEET DATUM IS MEAN SEA LEVEL MICHIGAN QUADRANGLE LOCATION IMAGE TAKEN FROM 1973 U.S.G.S. TOPOGRAPHIC MAP AKTPEERLESS environmental & energy services CHICAGO DETROIT FARMINGTON LANSING SAGINAW TOPOGRAPHIC LOCATION MAP FORMER MT. PLEASANT CENTER 1400 WEST PICKARD ROAD MT. PLEASANT, MICHIGAN PROJECT NUMBER : 6386s DRAWN BY: OGO DATE: FIGURE 2

14 EAST FORMER DUMP AREA BUILDINGS NUMBER NAME Farm/Trucking 1460 South Bamber Road South Cemetery 12 Mission Creek 2 Cottage 2 4 Cottage 4 5 Cottage 5 7 Cottage 7 8 Cottage 8 9 Cottage 9 10 Cottage Cottage Cottage Power Plant 36 Laundry 37 Service Building 38 Maintenance Building 39 Water Tower & Cell Tower Building 40 Hospital Administration Building 75 Block Garage 79 Incinerator Building 99 Residence 100 Residence 111 Implement Shed 113 Cottage Storage LOCATION OF FOUR 20,000 GALLON USTs Woodside Drive Winding Lane Mt. Pleasant Community Education Center 1651 Bamber Road 7 West Wind Drive 5 75 SOUTH Coyne Oil Corporation 1300 North Harris Street Coyne Oil Corporation & Citgo Gasoline Station 914 West Pickard Street (UST, LUST,AST) WEST Wolverine Pipeline 2 LEGEND = PROPERTY LINE = BUILDING IDENTIFICATION NUMBER ALL BUILDINGS TO BE DEMOLISHED Credit Union (SHWS) 1101 Hams Street AKTPEERLESS environmental & energy services CHICAGO DETROIT FARMINGTON LANSING SAGINAW SITE MAP FORMER MT. PLEASANT CENTER 1400 WEST PICKARD ROAD MT. PLEASANT, MICHIGAN PROJECT NUMBER : 6386s DRAWN BY: DATE: OGO SCALE: 1" = 450' 0 FIGURE 3

15 Appendix A Notification of Intent to Renovate/Demolish

16 NOTIFICATION OF INTENT TO RENOVATE/DEMOLISH MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY (MDEQ) AIR QUALITY DIVISION NESHAP, 40 CFR Part 61, Subpart M DEQ/LARA USE ONLY Postmark Date / / Emergency Date / / Rec d Date / / Valid No. OK Send Def Ltr. Date of Def Ltr. / / FOLLOW UP / / Spoke w/ Comments: Notification No. Trans No. Calculate LARA Asbestos Project Fee: Total Project Cost: x 0.01 = Type of Contractor: License No.: Licensing Authority: (1% Project Fee) 1. NOTIFICATION: Date of Notification: Date of Revision(s): Notification Type: Original Revised Canceled Annual Mark appropriate boxes: (both DEQ and LARA may apply): DEQ (NESHAP) [260 ln. ft./160 sq. ft. or more is threshold] Planned Renovation 10 working days notice Emergency Renovation Scheduled Demolition 10 working days notice Intentional Burn 10 working days notice Ordered Demolition LARA (MIOSHA) [Will not accept annual notifications] Demo, Reno, Encap. (>10 ln. ft./15 sq. ft.) 10 calendar days notice Emergency Renovation/Encapsulation 2. PROJECT SCHEDULE: START DATE END DATE * Renovation +Asb. Removal +Demolition: Encapsulation: Work Schedule: Please indicate the anticipated days of the week and work hours for the purpose of scheduling a compliance inspection. Days of the Week Work Hours Asb. Removal: Demolition: Encapsulation: * Includes setup, build enclosure, asbestos removal, demobilizing, etc. +Include only those dates you are conducting asbestos removal/demo. Check here if this is a multi-phased project, attach a schedule showing the start/end date of each phase. MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS (LARA), ASBESTOS PROGRAM, P.A. 135 OF 1986, AS AMENDED, Section 220 (1-4) or (8) 3. ABATEMENT CONTRACTOR: Internal Project #: Name: Mailing Address: City/State/Zip: Contact: Phone: 4. DEMOLITION CONTRACTOR: Internal Project #: Name: Mailing Address: City/State/Zip: Contact: Phone: 5. FACILITY OWNER: ( Facility includes Bridges) Name: Mailing Address: City/State/Zip: Contact: Phone: 6. FACILITY DESCRIPTION: Facility Name: Location Address/Description: If Apt. # of units: City/Twp. State: Zip Code: County: Nearest Crossroad: Size: (sq. ft.) No. of Floors: Floor No.: Age: Present Use: Prior Use: Specific Location(s) in Facility: 7. DISPOSAL SITE: Name: Location Address: City/State/Zip: 8. WASTE TRANSPORTER 1: Name: Address: City/State/Zip: Phone: WASTE TRANSPORTER 2: 9. ORDERED DEMOLITIONS: (See NESHAP regulations for definition of Ordered Demolition. ) A copy of the official Order must accompany this notification. Gov t Agency Ordering Demo: Name/Title of Person Signing Order: Date of Order: Date Ordered to Begin: 10. IS ASBESTOS PRESENT? Yes No Estimate the amount of asbestos: Include RACM (Regulated Asbestos Containing Material) to be removed, encapsulated, etc. Also include the amount and type (floor tile, roofing, etc.) of non-friable Category I and/or Category II ACM that will not be removed prior to demolition. (NOTE: In a demolition, cementatious ACM cannot remain in a structure, as it is likely to become regulated in the demolition/handling process. It must be removed prior to demolition.) To be removed prior to demolition RACM to be Removed RACM to be Encapsulated Non-friable ACM not removed prior to demo. Category I Category II Units of Measure Ln. Ft. Ln. M. Sq. Ft. Sq. M. Cu. Ft.* Cu.M.* *Volume (cubic ft./meters) should be used only if unable to measure by linear/square measure (example: asbestos has fallen off of surface). (continued on reverse side)

17 NOTIFICATION OF INTENT TO RENOVATE/DEMOLISH (continued) 11. PROJECT DESCRIPTION: Complete A) for Renovation (asbestos removal/encapsulation) and/or B) for Demolition: A) RENOVATION: Mark all surfaces/types of RACM to be removed: Encapsulation (for LARA): Mark surfaces/types to be encapsulated: Piping Fittings Boiler(s) Tanks(s) Piping Fittings Boiler(s) Tank(s) Beam(s) Duct(s) Tunnel(s) Ceiling Tile(s) Beam(s) Duct(s) Tunnel(s) Ceiling Tile(s) Mag Block Other (describe) Other (describe) Method of removal: Describe how the asbestos will be removed from the surface (example: glove bag, scrape with hand tools, cut in sections and carefully lower, etc.): B) DEMOLITION: Describe the method of demolition of facility, bridge, etc., and indicate if complete or partial. If partial, describe which part of facility bridge, etc., will be demolished: 12. ENGINEERING CONTROLS: Describe work practices and engineering controls used to prevent visible emissions before, during, and after removal, and until proper disposal: 13. UNEXPECTED ASBESTOS: Describe the steps you intend to follow in the event that unexpected RACM is found or previously non-friable asbestos becomes friable (crumbled, pulverized, reduced to powder, etc.) and therefore regulated: 14. PROCEDURE(S) USED TO DETECT THE PRESENCE OF ASBESTOS: A) Indicate how you determined whether or not asbestos is in the facility. If analytical sampling was used, describe method of analysis. (The determination of the presence or absence of asbestos must be made prior to submitting a renovation/demolition notification.): B) Name, address, and phone number of company performing asbestos survey: C) Name, accreditation number of inspector, and date of inspection: 15. EMERGENCY RENOVATIONS: Date/time of emergency: Describe the sudden, unexpected event: Explain how the event caused unsafe conditions, and/or would cause equipment damage and/or an unreasonable financial burden: 16. I certify that an individual trained in the provisions of 40 CFR Part 61, Subpart M, will be on-site during the renovation and during demolition involving RACM above the threshold and/or during an ordered demolition. Evidence that this person has completed the required training will be available for inspection at the renovation or demolition site. Signature of Owner or Abatement Contractor Date Signature of Owner or Demolition Contractor Date 17. Signature Requirements for Projects with Negative Pressure Enclosures: (required by LARA) Per Section 221(1)(2) of P.A. 135 of 1986, as amended, clearance air monitoring is required for any asbestos abatement project involving 10 linear feet/15 square feet or more of friable material which is performed within a negative pressure enclosure. I (the building owner or lessee) have been advised by the contractor of my responsibility under Act 135 to have clearance air monitoring performed on this project. Signature of Building Owner or Lessee Date Signature of Asbestos Abatement Contractor Representative Date NOTE: It is not mandatory that a signed copy be sent to LARA unless requested. For affected projects, this section of the notification form must be completed, signed, and made part of your records before the project begins. 18. I certify that the above information is correct: Printed Name of Owner/Operator Date Signature of Owner/Operator Date MAILING ADDRESSES/PHONE NUMBERS: (See Item 1 to determine which agency requirements/regulations are applicable to your project.) For Public Act 135 of 1986, as amended, Section 220 (1-4) or (8), mail to address below. For more info visit: MIOSHA Asbestos Program LARA, CSHD P.O. Box Lansing, MI For NESHAP Demolitions/Renovations, 40 CFR, Part 61, Subpart M, mail notifications to the appropriate address below (by county of subject facility): For more info visit click on Air, then Asbestos NESHAP Program. All Counties (except Wayne County) Wayne County Only NESHAP Asbestos Program NESHAP Asbestos Program DEQ, AQD Detroit Field Office, DEQ, AQD P.O. Box Cadillac Place, Suite Lansing, MI West Grand Boulevard Detroit, MI (Office) (office), (fax) (Revision Line) (Office) (Revision Line) EQP5661 (rev. 04/12) MIOSHA-CSH 142 (rev. 04/12)