EXHIBIT_D_-_ACM_Survey_Report_11026127_A_Building_380221_Apr_2011.pdf

EcoSystems Environmental, Inc.

Environmental Consulting Services

03/22/2011

Mr. James Lanham

A-1 Environmental, Inc.

P. O. Box 477

Gatesville, Texas 76528

RE: Asbestos Survey of Target Areas at the Site Related to

Proposed Renovation/Demolition

B38022

Hell on Wheels between 75th and 76 Street

Fort Hood, Texas 76544

ESEI Project # 11026127.A

Dear Mr. Lanham:

EcoSystems Environmental, Inc. (ESEI) was retained by A-1 Environmental, Inc. (hereinafter, the Client) to conduct a limited asbestos survey at the Site within the following Target Areas, as identified by the Client:

B38022

The attached report summarizes these services in accordance with our discussions. Regulated amounts of asbestos were detected in the window glazing compound. The sample results summary is attached in Appendix A of this report. ESEI licenses are attached in Appendix B of this report. The laboratory analytical results are attached in Appendix C of this report. Site drawings are attached in Appendix D of this report. If you have any questions on this report or any other matter, please do not hesitate to call me at (512) 257-8788.

EcoSystems Environmental, Inc.

Wade Champion

Individual Asbestos Consultant

DSHS License No. 10-5410

Expiration Date: 8/25/2011

Justin Platukas

Asbestos Inspector

DSHS License No. 60-2747

Expiration Date: 8/31/2012

Sincerely, P.O. Box 685287 * Austin, Texas 78768 * P - (512) 257-8788 * F - (512) 257-8263

1.0 SERVICES

TABLE I

SERVICES SUMMARY

Client A-1 Environmental, Inc.

P. O. Box 477

Gatesville, Texas 76528

Site Address Hell on Wheels between 75th and 76 Street, Fort Hood, Texas 76544

Scope of Work

1. Conduct a preliminary visual reconnaissance of the renovation/demolition Target Areas identified by the Client to visually determine the presence of suspect

ACM

2. In the event suspect ACM is identified, visually assess suspect ACM for variations in color, texture, thickness, and other characteristics useful in determining the material's uniformity and homogeneous area

3. In the event suspect ACM is identified, evaluate current physical condition, friability and potential for damage, assign hazard ratings and estimate quantities

4. Collect samples of identified and reasonably accessible suspect ACM within Target Areas

5. Send suspect ACM samples to laboratory for analysis of asbestos content, if any

6. Prepare report summarizing results

Target Areas identified by Client:

B38022

Sample Date(s): 03/16/2011

Samples Collected: A total of 21 samples of suspect asbestos-containing materials were collected, as agreed with the Client, within reasonably accessible portions of the Target Areas

Analytical Lab: ESEI’s in-house asbestos laboratory accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) through the

National Institute for Standards and Technology (ID Code No. 101162) and licensed as a DSHS licensed asbestos bulk laboratory

(License No. 30-0117).

DSHS License #:

Inspector(s): Justin Platukas

60-2747

No. of Samples

Analyzed:

Report Date: 03/22/2011

Analyzed Date: 03/21/2011

Analytical Method: Polarized Light Microscopy (PLM) using the Environmental Protection Agency (EPA) "Interim Method for Determination of Asbestos in Bulk Insulation Samples" [40 CFR Chapter 1 (1-1-87 Edition) Part 763, Subpart F, Attachment III]

General information about suspect ACM

Asbestos has historically been a component of a wide variety of building materials. These types of building materials, which may potentially contain asbestos, are termed "suspect asbestos-containing materials” (or suspect ACM). Suspect ACM may or may not contain asbestos. The actual asbestos content of a suspect material can be determined only through proper sampling and analysis performed by a qualified building inspector and laboratory.

Pursuant to the National Emission Standards for Hazardous Air Pollutants (NESHAP) asbestos regulation (40 CFR §61.141, et seq.) ACM can be classified into two categories: friable ACM which can be reduced to powder or crumbled under light hand pressure (e.g., ceiling textures and thermal system insulation) and nonfriable ACM. which are materials that cannot be easily crumbled (e.g., floor tile and floor tile mastic).

Regulated asbestos containing materials (RACM) which are those materials containing over 1% asbestos as defined under asbestos NESHAP.

11026127 | B38022 | Hell on Wheels between 75th and 76 Street | Fort Hood, Texas 76544

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03/22/2011

2.0 STANDARD OF CARE AND LIMITATIONS:

This report was prepared for the exclusive use of the Client named herein to aid in the identification and management of ACM and RACM in the renovation/demolition Target Areas identified by the Client. ESEI performed its services in a manner consistent with the level of care and expertise exercised by asbestos professionals performing the same or similar services at the same time and in the same geographic area.

Samples for this asbestos survey were collected from discrete sample locations within the rooms and areas specifically identified herein (i.e., Target Areas). While attempts were made to obtain representative samples most likely to contain asbestos, findings and conclusions herein are necessarily limited by the number of samples taken and access provided for sampling activities. The results herein cannot guarantee that no asbestos is present in any area not sampled. This asbestos survey was not intended to be a comprehensive asbestos inspection of the site, nor was it intended to be used for evaluation of worker health and safety conditions. To determine whether regulated ACM is present at other locations not sampled herein, a comprehensive asbestos inspection of the site would be necessary.

Conclusions and recommendations herein represent the professional opinions of the ESEI personnel involved with the project. The results of this report should not be considered as legal interpretation of existing federal, state or local environmental, health and safety laws or regulations. ESEI assumes no responsibility or liability for errors in information or data provided by third party sources.

3.0 REPORT USE AND RELIANCE:

This report represents ESEI’s services as of the sampling date. As our final document, it may not be altered after final issuance. This study and report were prepared on behalf of and for the exclusive use of the Client solely for its use and reliance in determining the presence of RACM in identified Target Areas of the site. The Client was the only party to which ESEI explained the risks and was solely involved in shaping the scope of services. Accordingly, reliance on this report by any other party may involve assumptions leading to an unintended interpretation of findings and opinions. With the consent of ESEI and the Client, ESEI may offer reliance to third parties or contract with other parties to develop findings and opinions related to such party’s unique risk management concerns.

Notwithstanding the foregoing, any and all third party reliance upon this Report shall be limited to the fair market value of the services undertaken to perform this Report as of the report date.

4.0 METHODOLOGIES:

4.1 Sampling

This limited inspection was guided by the Texas Asbestos Health Protection Rules (TAHPR) (see 25 TAC §295.58) and generally in accord with AHERA (the Asbestos Hazard Emergency Response Act of 1986, Public Law 99-519) sampling protocols (see 40 CFR §§ 763.86 and 763.88). The AHERA sampling protocols are statistically-based and were originally developed to implement AHERA which amends the Federal Toxic Substances Control Act (see 15 USC, §2641, et seq.). These rules are often followed by the OSHA, and the Department of State Health Services (DSHS). ESEI generally followed these sampling protocols to in an effort to collect representative samples of the various suspect building materials in the Target Areas.

Suspect ACM samples were collected by physically removing a small portion (approximately one square inch) of the suspect material using a sharp instrument. All layers of the material samples were penetrated and registered as separate samples. Disturbance of adjacent material was minimized during the sampling activities. Each sample was placed into a separate labeled container and then sealed. Each sample was labeled with the sample number and collection location, and a chain-of-custody form was completed. The sampling instrument was cleaned between each sample collected to mitigate potential cross-contamination between samples collected.

11026127 | B38022 | Hell on Wheels between 75th and 76 Street | Fort Hood, Texas 76544

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4.2 Analytical Procedures

If the results of the bulk laboratory analysis reveal asbestos, the percentage of asbestos contained within the sample is compared with criteria outlined in the EPA definition of asbestos-containing material (and which value is also followed by OSHA and DSHS). If a concentration of greater than one percent (1%) asbestos is reported, it is defined by the Asbestos NESHAP as a positive identification and the material could be considered RACM depending upon the nature of the ACM and its coverage.

The Asbestos NESHAP states that RACM (as defined in 40 CFR §61.141) containing less than 10% asbestos should be verified by point counting. If bulk sampling analysis determines that asbestos content of a friable asbestos sample is less than 10%, the building owner may: (i) elect to assume the asbestos content to be greater than 1% and treat the material as RACM, or (ii) require verification of asbestos content by point counting. If a result obtained by point counting is different from a result obtained by visual estimation, the point count result is used.

5.0 RECOMMENDATIONS:

Based upon the foregoing results, if applicable, ESEI offers the recommendations presented below. Such recommendations should be implemented prior to the commencement of any renovation or demolition activities or other activities that would potentially disturb the identified ACM or RACM at the site.

Identified ACM, including nonfriable ACM, that will be disturbed by renovation or demolition activities should be removed as soon as feasibly possible by appropriately licensed personnel and in accordance with applicable laws and regulations.

Identified ACM which will not be disturbed by renovation or demolition activities but which is damaged, should be repaired or encapsulated (by appropriately licensed personnel and in accordance with applicable laws and regulations) to prevent future damage.

ACM to remain in place should be enclosed in airtight impermeable barrier or encapsulated to prevent damage.

An Asbestos Operation and Maintenance Program should be implemented to manage existing ACM in place.

In the event renovation or demolition activities are slated for portions of the site outside of the Target Areas, an asbestos survey should be performed for those portions of the site—prior to the initiation of renovation or demolition activities.

11026127 | B38022 | Hell on Wheels between 75th and 76 Street | Fort Hood, Texas 76544

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APPENDICES

11026127 | B38022 | Hell on Wheels between 75th and 76 Street | Fort Hood, Texas 76544 03/22/2011

APPENDIX A

SAMPLE RESULTS SUMMARY

TABLE II

RESULTS SUMMARY

(Condition/Friability Codes are listed below table)

Sample

No.

Asbestos

%age

Description of Sampled Material Location Condition/

Friability

Estimated

Quantity

1 White/Tan / (Friable) / 2 x 4 Wormhole

Ceiling Tile

At Front Door N/A N/A0

2 White/Tan / (Friable) / 2 x 4 Wormhole

Ceiling Tile

Center, Office N/A N/A0

3 White/Tan / (Friable) / 2 x 4 Wormhole

Ceiling Tile

Northwest, Office N/A N/A0

4 White / (Friable) / Wallboard Northeast, Work Out Room N/A N/A0

5 White / (Friable) / Wall Texture Northeast, Work Out Room N/A N/A0

6 White / (Friable) / Joint Compound Northeast, Work Out Room N/A N/A0

7 White / (Friable) / Wallboard Center, Divider Wall N/A N/A0

8 White / (Friable) / Wall Texture Center, Divider Wall N/A N/A0

9 White / (Friable) / Joint Compound Center, Divider Wall N/A N/A0

10 White / (Friable) / Wallboard West, Office N/A N/A0

11 White / (Friable) / Wall Texture West, Office N/A N/A0

12 White / (Friable) / Joint Compound West, Office N/A N/A0

13 White / (Friable) / Exterior CMU Texture South, Wall N/A N/A0

14 White / (Friable) / Exterior CMU Texture North, Wall N/A N/A0

15 White / (Friable) / Exterior CMU Texture West, Wall N/A N/A0

16 Gray / (Non-Friable) / Window Glazing

Compound

South 1 10 Each5

17 Gray / (Non-Friable) / Window Glazing

Compound

West 1 Same as No.

18 Gray / (Non-Friable) / Window Glazing

Compound

North 1 Same as No.

19 Beige / (Non-Friable) / Interior CMU Wall

Texture

East, Wall N/A N/A0

20 Beige / (Non-Friable) / Interior CMU Wall

Texture

South, Wall N/A N/A0

21 Beige / (Non-Friable) / Interior CMU Wall

Texture

North, Wall N/A N/A0

Friability Codes:

1 – Friable: ACM that, when dry, can be crumbled, pulverized, or reduced to powder by normal hand pressure.

2 – Category I Nonfriable: ACM packings, gaskets, resilient floor covering, and asphalt roofing products.

3 – Category II Nonfriable: ACM, excluding Category I Nonfriable ACM, that, when dry, cannot be crumbled, pulverized, or reduced to powder by normal hand pressure.

APPENDIX B

LICENSES

APPENDIX C

LABORATORY ANALYTICAL RESULTS

Sample # /

Lab

PLM BULK ASBESTOS ANALYSIS Report Date: 03/22/2011

Client:

Project: B38022

Hell on Wheels between 75th and 76 Street

Fort Hood, Texas 76544

A-1 Environmental, Inc.

P. O. Box 477

Gatesville, Texas 76528

ESEI Project #: 1102 6127

Sample Location /

Material Sampled Layer % Non-Fibrous Material

Non-Asbestos

Fibrous Material Asbestos Type

(NVLAP CODE NO. 101162, TDSHS LAB LICENSE NO. 30-0117)

Client Project #:

11-33735 A

At Front Door

2 x 4 Wormhole Ceiling Tile

White/Tan/Friable

A None Det. 0 %Cellulose 50 %

Mineral Wool 30 %

Paint/Perlite 20 %

Total 0 %

11-33735 A

Center, Office

2 x 4 Wormhole Ceiling Tile

White/Tan/Friable

A None Det. 0 %Cellulose 45 %

Mineral Wool 35 %

Paint/Perlite 20 %

Total 0 %

11-33735 A

Northwest, Office

2 x 4 Wormhole Ceiling Tile

White/Tan/Friable

A None Det. 0 %Cellulose 50 %

Mineral Wool 30 %

Paint/Perlite 20 %

Total 0 %

11-33735 A

Northeast, Work Out Room

Wallboard

White/Friable

A None Det. 0 %Cellulose 8 %Binder/Gypsum 92 %

Total 0 %

11-33735 A

Northeast, Work Out Room

Wall Texture

White/Friable

A None Det. 0 %Cellulose 6 %Binder/Paint 94 %

Total 0 %

11-33735 A

Northeast, Work Out Room

Joint Compound

White/Friable

A None Det. 0 %Cellulose 2 %Binder/Carbonate 98 %

Total 0 %

11-33735 A

Center, Divider Wall

Wallboard

White/Friable

A None Det. 0 %Cellulose 6 %Binder/Gypsum 94 %

Total 0 %

ESEI Project #: 11026127 Lab #: 11-33735 A Page 1 of 4

2812 Trinity Square Dr., Suite 108 * Carrollton, Texas 75006 * P - 972.416.0520 * F - 972.416.4512

Sample # /

Lab

PLM BULK ASBESTOS ANALYSIS Report Date: 03/22/2011

Client:

Project: B38022

Hell on Wheels between 75th and 76 Street

Fort Hood, Texas 76544

A-1 Environmental, Inc.

P. O. Box 477

Gatesville, Texas 76528

ESEI Project #: 1102 6127

Sample Location /

Material Sampled Layer % Non-Fibrous Material

Non-Asbestos

Fibrous Material Asbestos Type

(NVLAP CODE NO. 101162, TDSHS LAB LICENSE NO. 30-0117)

Client Project #:

11-33735 A

Center, Divider Wall

Wall Texture

White/Friable

A None Det. 0 %Cellulose 10 %Binder/Paint 90 %

Total 0 %

11-33735 A

Center, Divider Wall

Joint Compound

White/Friable

A None Det. 0 %Cellulose 2 %Binder/Carbonate 98 %

Total 0 %

11-33735 A

West, Office

Wallboard

White/Friable

A None Det. 0 %Cellulose 8 %Binder/Gypsum 92 %

Total 0 %

11-33735 A

West, Office

Wall Texture

White/Friable

A None Det. 0 %Cellulose 5 %Binder/Paint 95 %

Total 0 %

11-33735 A

West, Office

Joint Compound

White/Friable

A None Det. 0 %Cellulose 2 %Binder/Carbonate 98 %

Total 0 %

11-33735 A

South, Wall

Exterior CMU Texture

White/Friable

A None Det. 0 %Talc 5 %Binder/Carbonate 95 %

Total 0 %

11-33735 A

North, Wall

Exterior CMU Texture

White/Friable

A None Det. 0 %Cellulose 1 %

Talc 4 %

Binder/Carbonate 95 %

Total 0 %

11-33735 A

West, Wall

Exterior CMU Texture

White/Friable

A None Det. 0 %Talc 6 %Binder/Carbonate 94 %

Total 0 %

ESEI Project #: 11026127 Lab #: 11-33735 A Page 2 of 4

Sample # /

Lab

PLM BULK ASBESTOS ANALYSIS Report Date: 03/22/2011

Client:

Project: B38022

Hell on Wheels between 75th and 76 Street

Fort Hood, Texas 76544

A-1 Environmental, Inc.

P. O. Box 477

Gatesville, Texas 76528

ESEI Project #: 1102 6127

Sample Location /

Material Sampled Layer % Non-Fibrous Material

Non-Asbestos

Fibrous Material Asbestos Type

(NVLAP CODE NO. 101162, TDSHS LAB LICENSE NO. 30-0117)

Client Project #:

11-33735 A

South

Window Glazing Compound

Gray/Non-Friable

A Chrysotile 5 %Cellulose 1 %Binder/Carbonate 94 %

Total 5 %

11-33735 A

West

Window Glazing Compound

Gray/Non-Friable

A Chrysotile 4 %Cellulose 1 %Binder/Carbonate 95 %

Total 4 %

11-33735 A

North

Window Glazing Compound

Gray/Non-Friable

A Chrysotile 6 %Cellulose 2 %Binder/Carbonate 92 %

Total 6 %

11-33735 A

East, Wall

Interior CMU Wall Texture

Beige/Non-Friable

A None Det. 0 %Cellulose 1 %Binder/Paint 95 %

Quartz 4 %

Total 0 %

11-33735 A

South, Wall

Interior CMU Wall Texture

Beige/Non-Friable

A None Det. 0 %Cellulose 2 %Binder/Paint 88 %

Quartz 10 %

Total 0 %

11-33735 A

North, Wall

Interior CMU Wall Texture

Beige/Non-Friable

A None Det. 0 %Cellulose < 1 %Binder/Paint 90 %

Quartz 10 %

Total 0 %

ESEI Project #: 11026127 Lab #: 11-33735 A Page 3 of 4

BACKGROUND:

EcoSystems Environmental, Inc. (ESEI) is accredited by the National Voluntary Laboratory Accreditation Program, NVLAP Lab Code 101162-0 through the National Institute of Standards and Technology (NIST). ESEI is also licensed and authorized to perform as an asbestos laboratory by the Texas Department of State Health Services (License No. 30-0117). This report may not be used to claim product certification approval or endorsement by NVLAP, NIST, or any agency of the federal government.

METHOD & LAYERING:

Bulk samples are prepared and analyzed in accordance with the polarized light microscopy procedures outlined in the EPA-600/M4-82-020: Interim Method for the Determination of Asbestos in Bulk Insulation Samples and alternate EPA/600/R-93/116. The test reports cannot be reproduced except in full and with ESEI's permission.

When a sample consists of two or more distinct layers or materials, each layer is analyzed and reported separately. Any layer containing more than 1% asbestos is declared by the National Emission Standards for Hazardous Air Pollutants (NESHAP) as an asbestos-containing material (ACM).

PERCENTAGES & POINT COUNTING

Reported percentages of asbestos are visual estimates by volume; quantitation is achieved by utilizing a stereobinocular microscope. The Asbestos NESHAP Revision Final Rule states that regulated asbestos-containing materials (as defined in 40 CFR Section 61.141) containing less than 10% asbestos (including the samples that contain a trace or less than 1% asbestos which are considered by the EPA as asbestos-containing materials if analyzed by Polarized Light Microscopy (PLM) may be verified by point counting. If the lab detects the asbestos content of a sample to be <10%, the client may: 1) elect to assume the amount to be greater than 1% and treat the material as asbestos containing or 2) require the verification of the amount by point counting. If a result obtained by point counting is different from a result obtained by visual estimation, the point count result will be used. Samples for which no asbestos is detected by the PLM do not need to be point counted.

TYPES OF ASBESTOS:

Asbestos is a general term to one of several naturally occurring fibrous minerals. These are divided into two categories: serpentine and amphiboles.

Chrysotile, a serpentine, is the most commonly found form of asbestos. The five other types are all amphiboles. These include Amosite, (fibrous grunerite), Crocidolite (fibrous riebeckite), fibrous Anthophyllite, fibrous Tremolite and fibrous Actinolite.

BACKGROUND MATERIALS:

Materials which do not contain Asbestos are reported for each sample. These background materials are divided into Fibrous and non-fibrous types.

Common Fibrous materials include glass, mineral wool, cellulose, paper, and synthetics (nylon, rayon, Dacron). Common non-fibrous materials include binder (glues), mica, quartz, vermiculite, clays, lizardite and talc.

SAMPLE STORAGE:

Bulk samples are double bagged and stored for 90 days unless otherwise arranged with the client. Samples can be returned within 90 day period upon receipt of written authorization and payment of a return fee.

Cindy Watkins - Analyst

EcoSystems Environmental, Inc.

Enviromental Consulting Services

Report Date: 03/22/2011

Client:

Project: B38022

Hell on Wheels between 75th and 76 Street

Fort Hood, Texas 76544

A-1 Environmental, Inc.

P. O. Box 477

Gatesville, Texas 76528

ESEI Project #: 1102 6127

PLM BULK ASBESTOS ANALYSIS

(NVLAP CODE NO. 101162, TDSHS LAB LICENSE NO. 30-0117)

Client Project #:

ESEI Project #: 11026127 Lab #: 11-33735 A Page 4 of 4

APPENDIX D

SITE DRAWINGS