Correspondence: AMEC E&I, Inc. Traverse City 41 Hughes Drive Traverse City, MI 49696 United States Tel: (231) 922-9050 Fax: (231) 922-9055

February 9, 2012 Mr. Bob Coles City of Traverse City Department of Public Works 625 Woodmere Avenue Traverse City, MI 49684 Subject: Hazardous Materials Building Survey

Brown Bridge Dam Powerhouse East Bay Township, Grand Traverse County, Michigan AMEC Project Number: 3310110027 Dear Mr. Coles: AMEC Environment & Infrastructure, Inc. (AMEC) was retained by the Boardman River Dams Settlement Agreement Implementation Team (IT) to perform a hazardous materials building survey (building survey) at the Brown Bridge Dam powerhouse located on the Boardman River in East Bay Township, Grand Traverse County, Michigan (Site). The powerhouse consists of a one-story, brick structure that was formerly used for the generation of hydroelectric power. AMEC understands the powerhouse will be partially razed during the breaching of the dam in 2012. Prior to demolition, AMEC performed a limited asbestos survey, a lead-based paint evaluation and a hazardous material inventory to identify materials that may need to be removed and/or properly managed as part of proposed dam removal activities. The building survey was conducted on October 31, 2011 and December 8, 2011 by Mr. R. Scott Rought, Certified Hazardous Materials Manager (CHMM) and accredited State of Michigan Asbestos Inspector, and Mr. Jeffrey Doerr of AMEC (October 31, 2011). AMEC personnel conducted the building survey in a systematic fashion on the interior and exterior portions of the powerhouse; however, due to safety concerns (close proximity of overhead electrical wires and nearby steep embankments), an inspection of the structure’s roof was not performed. AMEC personnel also did not assess any areas of the dam embankment located in close proximity to the spillway or behind fenced areas and/or railings adjacent to the spillway, including the mechanical equipment currently located in the spillway (e.g., trash racks, etc.) or any areas beneath the powerhouse due to associated safety concerns. Although AMEC personnel has made a good faith effort to assess these areas as part of the building survey, these areas may require further inspection once the water level is lowered as part of the proposed dam removal activities. AMEC did not enter the fenced interior area of the powerhouse which surrounds the electrical wiring, switches and other components necessary for the generation of electricity. The dam has not generated hydropower since the previous operator, Traverse City Light and Power relinquished their license in 2006. A review of construction plans indicate that the insulation of the wiring is asbestos-containing which was confirmed by the City of Traverse City (City). Access to the property was provided by Mr. Ken Gregory of the City’s Department of Public Services. The following sections provide a summary of the scope of work, field observations and a summary of the analytical laboratory results.

Mr. Bob Coles February 9, 2012 Page 2 of 5

SCOPE OF WORK AMEC’s scope of work consisted of the following:

• Conduct a National Emission Standards for Hazardous Air Pollutants (NESHAPs) pre-demolition asbestos survey of the building with sampling and analysis of suspect asbestos-containing materials (ACM).

• Conduct a lead-based paint evaluation of the building with sampling and analysis of interior and exterior painted surfaces.

• Conduct a hazardous material inventory for the presence of equipment/building components that may contain polychlorinated biphenyls (PCBs), mercury, chlorofluorocarbons (CFCs), refrigerants and other potentially hazardous materials.

• Prepare a letter report summarizing the field observations, sampling collection and analytical results of the aforementioned work including AMEC’s conclusions.

NESHAPS ASBESTOS SURVEY Observations AMEC personnel conducted a NESHAPs pre-demolition asbestos survey of the powerhouse structure in general accordance with 40 CFR 61, Subpart M, to identify and sample any suspect ACM. The powerhouse construction consists of a brick exterior with a poured in-place concrete floor and foundations, painted brick interior walls and a concrete ceiling. Several windows were observed with window panes; window putty/caulk was observed around the perimeter of each pane. AMEC did not observe the presence of any insulation materials. There was no evidence of a heating and vitalization system within the powerhouse. Piping observed within the powerhouse was not insulated. As previously discussed, AMEC personnel did not access the building’s roof. It was reported by the City that the roof was of concrete construction and was not shingled. Insulation was observed around the electrical wiring within the powerhouse and for the purpose of this survey was assumed to be asbestos-containing as indicated on existing facility drawings. The insulation on the electrical wiring appeared in good condition. Suspect ACM identified in association with the building included interior/exterior window putty/caulking material, brick mortar and an interior electrical panel (board). No suspect ACM was identified in association with any items (i.e., railings, fencing, powerhouse related equipment, etc.) located immediately adjacent to the powerhouse. It should be noted that the insulation observed on the electrical wiring inside the fenced-in area is also considered a suspect ACM; however, due to safety concerns and the presence of high voltage signage, the wiring was not inspected or sampled by AMEC. Three bulk samples were collected and identified as sample numbers S-1 through S-3. A description of each sample location is included in Table 1 – Brown Bridge Dam Powerhouse Asbestos Sample Results. Analytical Results The bulk samples of the aforementioned suspect ACM were collected and submitted to AMEC’s in-house asbestos laboratory located in Atlanta, Georgia for asbestos fiber analysis using United States Environmental Protection Agency (EPA) Method 600, Polarized Light Microscopy (PLM). AMEC’s laboratory is an accredited laboratory in the National Voluntary Laboratory Accreditation Program (NVLAP). The analytical laboratory results did not detect the presence of asbestos fibers in the samples submitted for laboratory analysis at concentrations greater than 1% (concentration at which EPA regulates the material as asbestos-containing); therefore, all samples submitted for laboratory analysis were non-detect for asbestos. Table 1 provides a summary of the materials sampled, their location within the powerhouse and the analytical laboratory result. The analytical laboratory results and chain-of-custody form are provided as Attachment A.

Mr. Bob Coles February 9, 2012 Page 3 of 5

LEAD-BASED PAINT EVALUATION Observations A visual survey of the interior and exterior of the powerhouse and apparatus (i.e., railings, fencing, and water gates/equipment) was performed to provide information regarding the presence of lead-based paint to facilitate contractor compliance with the Occupational Safety and Health Administration (OSHA) Standard 29 CFR Part 1926.62 (Lead in Construction) during the partial demolition of the powerhouse. Observations of the various representative surface coatings were documented and representative paint chip samples were collected. A total of 13 paint chip samples (LS-1 through LS-13) were collected from various interior and exterior locations of the powerhouse. The location and description of the samples are presented in Table 2 – Brown Bridge Dam Powerhouse Paint Sample Results. The paint chip samples were submitted to EMSL Analytical, Inc. (EMSL) of Indianapolis, Indiana for lead analysis using Atomic Absorption Spectroscopy (AAS) in accordance with EPA Method SW 846, 3050B/7040B. EMSL is accredited through the American Industrial Hygiene Association (AIHA) Environmental Lead Laboratory Approval Program (ELLAP). As previously discussed, AMEC did not assess the areas beneath the powerhouse main floor or any areas of the dam embankment located in close proximity to the spillway or behind fenced areas and/or railings adjacent to the spillway. According to Mr. Gregory, a masonry water proofing sealant/coating (Thoroseal) was applied to areas of exposed concrete approximately 15 years ago. A review of the material on the website by AMEC indicates that the material is manufactured by BASF Corporation and does not contain a concentration of lead sufficient to deem this product a lead-based paint. Aside from the water control gates and associated equipment, Mr. Gregory was not aware of any painted surfaces beneath the water level or powerhouse. Analytical Results The analytical results identified elevated concentrations of lead in eight of the thirteen samples. Lead was identified in these eight samples at concentrations of 0.5% by weight or greater, which meets the definition of lead-based paint as defined under the Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing and the EPA’s Requirements for Lead-Based Paint Activities in Target and Child-Occupied Facilities (40 CFR Part 745). Table 2 provides a summary of the paint chip samples that were identified as containing lead-based paint. Based on the analytical results, the building’s interior walls (south and east walls), floor and main entry door are coated with lead-based paint. Additionally, the painted surfaces of the safety railings exterior to the building, the water gates located in the spillway and the two generators located within the building were also identified as being coated with lead-based paint. It should be noted that although only two interior walls (south and east walls) were identified as containing lead-based paint, the same paint is believed to have been used to paint the north and west interior walls. The analytical laboratory results (0.45% by weight on the north wall and 0.48% by weight on the west wall) indicate that the levels of lead in these surface coatings are at concentrations just below the HUD/EPA definition of lead-based paint (0.5% by weight). Based on AMEC’s observations and the analytical laboratory results, the surface coatings on these walls should also be considered lead-based paint. The analytical laboratory results and the chain-of-custody form are provided as Attachment B.

Mr. Bob Coles February 9, 2012 Page 4 of 5

HAZARDOUS MATERIALS INVENTORY Observations AMEC conducted a visual survey of the interior and exterior areas of the powerhouse to identify sources or equipment that may contain PCB-containing fluids, mercury, CFCs and other potential hazardous materials. Table 3 presents a list of the materials observed during the building survey. It should be noted that AMEC personnel did not enter the fenced area located inside the powerhouse for safety reasons, but did identify the presence of two pad-mounted electrical transformers inside the fenced area. Both transformers were affixed with labels (e.g., “non-PCB”). Numerous electrical gauges, meters and switches were identified on electrical panels inside the fenced area. Although these instruments could not be inspected by AMEC, they are considered to be mercury containing and should be managed as such unless documented otherwise. AMEC collected one sample of caulk from an interior window pane located on the north side of the building to determine whether the caulk contains PCBs. The sample collected is representative of the caulk used on the interior and exterior portions of each window and elsewhere in the building. The sample was submitted to Brighton Analytical, Inc. of Brighton, Michigan for the presence of PCBs via EPA Method 8081. The analytical laboratory results did not identify the presence of PCBs in the sample submitted at concentrations above their respective laboratory detection limits. A copy of the analytical laboratory report and chain-of-custody form is provided as Attachment C. AMEC did not observed any equipment or materials labeled or marked as containing mercury during the building survey; however, four high intensity lamps mounted on the exterior of the building are believed to be mercury-containing based on their age and shape. No other mercury-containing sources were identified during the building survey. AMEC observed other materials or equipment that may contain hazardous or non-hazardous materials within the powerhouse which included a fire extinguisher, cans of paint, a box of salt, batteries, gear oil, lubricants and other related items. It should be noted that equipment inside the building (both generators and related equipment) are also assumed to contain gear oil, grease and other lubricants. Furthermore, based on the presence of high pressure hoses in connection with the spillway water gates, it is assumed these gates contain hydraulic oils. No CFC-containing equipment or refrigerants were observed during the survey. CONCLUSIONS AMEC conducted a NESHAPs asbestos survey, lead-based paint evaluation and hazardous material building survey at the Site on October 31 and November 8, 2011. Laboratory PLM test results did not detect the presence of asbestos fibers in the samples submitted for analysis at a concentration greater than 1%; therefore, all materials sampled are non-detect for asbestos. It is important to note that although no asbestos was identified in the samples collected, a Notification of Intent to Renovate/Demolish form must be submitted to the Michigan Department of Environmental Quality (MDEQ) Air Quality Division and the Michigan Department of Labor and Economic Growth – Asbestos Program at least 10 working days prior to demolition activities. The lead-based paint evaluation identified the presence of lead-based paint on the building’s interior walls and floors, on the two generators located within the building, safety railings exterior to the building and on the water gates located in the spillway. Based on the presence of lead-based paint, contractors performing work that could impact (i.e., sand, abrade, chip, etc.) these surface coatings during building

Table 1 Brown Bridge Dam Powerhouse Asbestos Sample Results

AMEC Project Number: 3310110027

Sample Number Location/Description Asbestos

Result

S-1 Interior of powerhouse/gray/white caulk on windows; sample collected from lower window panes near northeast corner of the powerhouse. None Detected

S-2 Exterior of powerhouse/gray/white brick mortar; sample collected from southwest corner of the powerhouse adjacent to window sill plate. None Detected

S-3 Interior of powerhouse/gray electrical panel enclosure. None Detected Note: Samples collected on October 31, 2011.

Table 2 Brown Bridge Dam Powerhouse Paint Sample Results

AMEC Project Number: 3310110029

Sample Number

Location/Description Lead Result (% weight)

LS-1 Interior of the powerhouse from the north wall, sample collected beneath center window/white paint over gray/green paint. 0.45

LS-2 Interior of the powerhouse from the west wall, sample collected near northwest corner of room beneath window/white paint over gray/green paint.

0.48

LS-3 Interior of the powerhouse from the south wall, sample collected near center of wall beneath metal cleanout/white paint over gray/green paint. 0.77

LS-4 Interior of the powerhouse from the east wall, sample collected near main door adjacent to electrical box/white paint over gray/green paint. 0.56

LS-5 Interior of the powerhouse from closet door near northwest corner of main room/white paint over gray/green paint. 0.12

LS-6 Interior of the powerhouse floor, sample collected near center of room between generators/gray paint. 1.1

LS-7 Interior of the powerhouse, closet near northwest corner of room, sample collected from southeast corner of closet wall/silver paint. 0.27

LS-8 Interior of the powerhouse, generator located on south side of room, sample collected from east side of generator/green paint (two layers) over orange paint.

2.7

LS-9 Interior of the powerhouse, generator located on north side of room, sample collected from southeast corner of generator/green paint (two layers) over orange paint.

2.4

LS-10 Exterior of powerhouse, main door/multiple layers of paint (interior and exterior sides of door). 2.9

LS-11 Exterior of the powerhouse, window sill on south wall, sample collected near center of sill plate/gray paint over green paint. 0.046

LS-12 Exterior of the powerhouse, railing on west side of building, sample collected from top rail/multiple layers of paint. 0.79

LS-13 Exterior of the powerhouse, water gates on east side of building/multiple layers of paint. 1.8

Notes: Shading indicates result exceeds the Department of Housing and Urban Development Guidelines for the evaluation and Control of Lead-Based Paint Hazards in Housing and the United States Environmental Protection Act definition of lead-based paint (0.5% by weight). Samples collected on October 31, 2011.

Table 3 Brown Bridge Dam Hazardous and Non-Hazardous Survey Results

AMEC Project Number: 3310110027

Hazard Category Material Location/Description Approximate

Quantity

Other Hazardous/Non-Hazardous Materials

Lead-based paint

Powerhouse interior/white paint over gray/green paint on powerhouse walls.

Unknown quantities

Powerhouse interior/gray floor paint on powerhouse floor. Powerhouse interior/green paint (two layers) over orange paint covering both generators. Powerhouse interior/multiple layers of paint covering interior/exterior sides of main door to powerhouse. Powerhouse exterior/multiple layers of paint covering safety railing exterior to powerhouse. Powerhouse exterior/multiple layers of paint covering water gates exterior to powerhouse.

Propane cylinders Powerhouse interior. Two, 20-pound cylinders (unknown amount remaining)

Gear oil Powerhouse interior/Texaco Rando Oil HD-68 (68 weight oil) located adjacent to generators.

Three, 5-gallon containers (unknown amount remaining in each container)

Grease Powerhouse interior/west side of room. One, 30-pound can (nearly empty)

Hydraulic oil/gear oil Powerhouse interior/generators. Unknown quantity in

each generator

Paint (cans) Powerhouse interior/storage shelf units located in northwest and southwest corners of the powerhouse.

Eleven, 1-gallon containers (each container approx. one-half full)

Paint (spray cans) Powerhouse interior/storage shelf units located in northwest and southwest corners of the room.

Six spray paint cans (unknown quantity in each can)

Fire extinguisher Powerhouse interior. Full extinguisher WD-40 and assorted lubricants in spray cans

Powerhouse interior, workbench/WD-40, Liquid Wrench, spray lube and chain/cable fluid.

One or two cans of each item (unknown quantity in each can)

Salt Powerhouse interior. One, 12-pound box

Hydraulic fluid Powerhouse exterior/water control gates (hydraulic lines and mechanisms). Unknown quantity

Batteries Powerhouse interior. Ten automotive batteries

Mercury Sources

Mercury vapor lamps Powerhouse exterior near roof line. Four vapor lamps

Electric switches and gauges Powerhouse interior within fenced-in area. Numerous switches,

gauges, and meters Note: Field survey performed by AMEC on October 31, 2011.

ATTACHMENT A

ASBESTOS ANALYTICAL LABORATORY REPORT AND CHAIN-OF-CUSTODY FORM

ATTACHMENT B

LEAD-BASED PAINT ANALYTICAL LABORATORY REPORT AND CHAIN-OF-CUSTODY FORM

ATTACHMENT C

PCB ANALYTICAL LABORATORY REPORT AND CHAIN-OF-CUSTODY FORM