EXHIBIT_E_-_LBP_LetterReport_-_B38022__11026127_B1_Paint_Apr_2011.pdf

2812 TRINITY SQUARE DR., STE. 108 * CARROLLTON, TX 75006 * P – 972.416.0520 *F – 972.416.4512

LEAD-BASED PAINT INSPECTION REPORT

B38022 Fort Hood, Texas 76544

ESEI Project No. 11026127.B

Prepared For:

A-1 Environmental, Inc.

P.O. Box 477

Gatesville, Texas 76528

March 18, 2011

LEAD-BASED PAINT INSPECTION REPORT

B38022 Fort Hood, Texas 76544

Prepared By:

Justin Platukas Lead Inspector / Risk Assessor Certificate No. 2070901

Reviewed By:

Russ Gout, REM Operations Manager

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Standard of Care and Limitations

2.0 BUILDING SURVEY

2.1 General

2.2 Lead-Based Paint Analysis

APPENDICES

Appendix A Accreditation Appendix B Analytical Results Appendix C Assay Point Locations Appendix D Lead Based Paint Location Plan

EXECUTIVE SUMMARY1

EcoSystems Environmental, Inc. (ESEI) was retained by A-1 Environmental, Inc. to conduct a lead-based paint inspection of B38022, located at Fort Hood, Texas (hereinafter the Site). ESEI's approach to this assessment was to inspect the designated areas of the Site, including the exterior, for lead-based paint (LBP) by physically accessing the painted substrates throughout the selected areas of the Site and to verify the uniformity (homogeneity) of the paints used in the construction of the Site.

During the sampling event a total of 30 assay points, including calibration samples, of suspect paints from areas throughout the interior and exterior of the Site were analyzed for determination of lead content. An x-ray fluorescence (XRF) analyzer was utilized for LBP detection for this project. All operators of the XRF analyzer are certified for proper use by ESEI.

LBP is defined as any homogeneous paint that detects lead content at 1.0 milligrams per square centimeter (mg/cm2) or greater by the XRF Analyzer. LBP was indentified on exterior yellow concrete bollards of the painted substrates analyzed at the Site.

This is a summary of the contents of this report. Please refer to the full text for a complete explanation and supporting information.

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1.0 INTRODUCTION

EcoSystems Environmental, Inc. (ESEI) was contracted by A-1 Environmental, Inc. (the Client) to conduct a lead-based paint (LBP) inspection of B38022 at Fort Hood, Texas (hereinafter, the

Site). The purpose of this investigation was to identify LBP hazards by performing analysis of painted substrates at the Site.

ESEI conducted its sampling program at the Site utilizing an Innov-X Alpha X-Ray Fluorescence

(XRF) Analyzer. LBP is identified as those paints that were analyzed to have lead content at 1.0 milligram per square centimeter (mg/cm2) or greater.

1.1 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 LBP at the Site. ESEI performed its services in a manner consistent with the level of care and expertise exercised by environmental professionals performing the same or similar services at the same time and in the same geographic area.

Samples for this LBP sampling program were collected from discrete sample locations associated with the areas specifically identified herein (i.e., Target Areas). While attempts were made to obtain representative samples most likely to contain LBP, findings and conclusions herein are necessarily limited by the number of samples taken and access provided for sampling activities.

Conclusions and recommendations herein represent the professional opinions of the ESEI personnel involved with the project. ESEI assumes no responsibility or liability for errors in information or data provided by third party sources.

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2.0 BUILDING SURVEY

2.1 General

Mr. Justin Platukas, ESEI Project Manager and Lead Inspector/Risk Assessor, conducted ESEI’s sampling program. The LBP sampling inspection was of the interior and exterior substrates of the site for the identification of homogeneous areas accessible at the time of the site visits. Copies of

ESEI's certifications and licenses are located in Appendix A of this report.

2.2 Lead-Based Paint Analysis

The LBP sampling and analysis involved the physical inspection of the Site, a sampling program for suspect LBP, and field analysis utilizing a Innov-X Alpha XRF Analyzer to determine the lead content of each painted surface. Locations of components tested are designated as room locations (e.g., Room Numbers) and location within each room (e.g., North [N], East [E], South

[S], West [W]). ESEI identified substrates with homogeneous areas of suspect LBP that, based on historical uses, have the potential of containing lead. LBP was indentified on exterior yellow concrete bollards of the painted substrates analyzed at the Site.

All paints that contain any level of lead are regulated by the OSHA Lead in Construction Standard

29CFR 1926.62. Construction work covered by this standard includes demolition or salvage of structures where lead-containing materials are present; removal or encapsulation of lead-containing materials; renovation of structures, substrates, or portions thereof that have lead-containing materials; installation of materials containing lead; lead contamination cleanup;

transportation, storage, and disposal of lead-containing materials; and maintenance operations associated with these construction activities.

In performing these activities, OSHA requires an initial determination that the construction activities used at the job site do not create airborne emissions of lead above the Action Level of

30 g/m3 (i.e., negative exposure assessment). This exposure assessment may include initial exposure monitoring, historical data that meet certain requirements, or objective data demonstrating that a particular product or material containing lead or a specific process cannot

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During the exposure assessment the workers must be protected in the assumption that the work process is going to create airborne concentrations above the Permissible Exposure Level (PEL) of

50 g/m3. This requires medical monitoring (blood test) for blood lead levels, personal protective equipment (PPE), respiratory protection, a Hazard Communication Program, and a written

Compliance Program.

If a negative initial determination is achieved during a certain work process, no further monitoring is required. Additional exposure assessment and monitoring is required with any change in process, equipment, controls, or environmental conditions. Employers subject to these work conditions should refer to the OSHA Lead Standard for complete compliance.

APPENDIX A

ACCREDITATION

APPENDIX B

ANALYTICAL RESULTS

Lead Based Paint Inspection - B38022

ESEI Project # 11026127.B - 3/16/2011

Reading Color Substrate Component Area Direction Pb Pass/Fail

1 Standarization PASS

2 Calibration PASS

3 Calibration PASS

4 brown metal door frame exterior east 0.00 Negative

5 brown metal bay door frame exterior east 0.00 Negative

6 brown metal bay door frame exterior east 0.00 Negative

7 yellow concrete bollard exterior east 5.00 Positive

8 yellow concrete bollard exterior east 3.87 Positive

9 tan cmu wall exterior east 0.08 Negative

10 brown metal window exterior north 0.00 Negative

11 tan metal window exterior west 0.00 Negative

12 tan cmu wall exterior north 0.00 Negative

13 tan cmu wall exterior west 0.00 Negative

14 brown metal bay door exterior east 0.00 Negative

15 white wood door interior north 0.00 Negative

16 brown wood door frame interior south 0.00 Negative

17 white drywall wall interior center 0.00 Negative

18 white drywall wall interior west 0.00 Negative

19 gray concrete floor interior east 0.00 Negative

20 white cmu wall interior north 0.00 Negative

21 white cmu wall interior east 0.01 Negative

22 white cmu wall interior south 0.11 Negative

23 white cmu wall interior west 0.08 Negative

24 tan metal window interior south 0.17 Negative

25 brown metal door frame interior east 0.00 Negative

26 tan wood overhang exterior east 0.00 Negative

27 tan concrete window ledge exterior north 0.00 Negative

28 tan concrete window ledge exterior south 0.00 Negative

29 Calibration PASS

30 Calibration PASS

APPENDIX C

ASSAY POINT LOCATIONS

APPENDIX D

LEAD BASED PAINT LOCATIONS