DRAFT_Crownpoint_Phase_II_ESA_0002.pdf

DRAFT

LIMITED PHASE II ENVIRONMENTAL

SITE ASSESSMENT

East Navajo Agency Community Schools

Crownpoint, New Mexico

July 12, 2012

Prepared for:

Bureau of Indian Affairs

Karl Chiwiwi, COR

Bureau of Indian Affairs

1011 Indian School Rd NW

Albuquerque, NM 87104

505.563.5148

Prepared by:

E W Wells Group LLC

1221 South Lamar Street

Dallas, Texas 75215

DRAFT

LIMITED PHASE II ENVIRONMENTAL SITE ASSESSMENT

East Navajo Agency Community School

Crownpoint, New Mexico

EXECUTIVE SUMMARY ................................................................................................... i

1.0 INTRODUCTION

2.0 SOIL SURVEY

2.1 Exterior Paint in Soil

2.1.1 Soil Sampling Methods

2.1.2 Results

2.2 Heating Oil Releases

3.0 ASBESTOS INSPECTION

3.1 Bulk Sample Collection

3.2 Laboratory Analysis

3.3 Analytical Results

4.0 LEAD-BASED PAINT SURVEY

5.0 GENERAL HAZARDOUS MATERIALS SURVEY

6.0 CONCLUSIONS AND RECOMMENDATIONS

6.1 Soil Survey

6.2 Asbestos Survey

6.3 Lead Survey

6.4 Hazardous Materials Survey

6.4.1 Fluorescent Lamps, Incandescent Bulbs and Mercury Vapor Bulbs

6.4.2 PCB-Containing Ballasts

6.4.3 Paint Cans and Chemical Containers

7.0 REPORT USE AND LIMITATIONS

8.0 QUALIFICATIONS OF ENVIRONMENTAL PROFESSIONALSError! Bookmark not defined.

TABLES

Table 1 – Crownpoint Building Descriptions

Table 2 – GPS Sample Coordinates

Table 3 – XRF Soil Sampling Results For Lead

Table 4 – Summary of Analytical Results of Lead in Soil Samples

Table 5 – Summary of Field XRF Measurements of Paint Chip Samples

FIGURES

Figure 1 – Building Layouts and Approximate Property Location

Figure 2 – Building 3000 Soil Sampling Locations

Figure 3 – Buildings 3001 and 3002 Soil Sampling Locations

Figure 4 – Building 3003 Soil Sampling Locations

Figure 5 – Building 3004 Soil Sampling Locations

Figure 6 – Buildings 3005, 3006, and 3007 Soil Sampling Locations

Figure 7 – Building 3008 Soil Sampling Locations

Figure 8 – Building 3009 Soil Sampling Locations

Figure 9 – Building 3010 Soil Sampling Locations

Figure 10 – Buildings 3011 and 3012 Soil Sampling Locations

ATTACHMENTS

Attachment A – XRF Survey Results for Soils

Attachment B – Photographs of Building Exteriors

Attachment C – Laboratory Analytical Reports and Chain of Custody Forms for Soil Samples

Attachment D – Survey Report for Asbestos-Containing Materials and Lead Based Paint

Attachment E – Qualifications of Environmental Professionals i

EXECUTIVE SUMMARY

EW Wells Group, LLC (Wells) was contracted by the Bureau of Indian Affairs (BIA) to conduct a

Limited Phase II Environmental Site Assessment (ESA) of the old Community School at

Crownpoint, New Mexico, herein referred to as the “Property”. The Property is currently owned by the BIA and is being evaluated for demolition and/or transfer of ownership. The old Crownpoint

School property consists of a total of thirteen structures: one multi-purpose building, two school buildings, two dormitories, a gym, an office building, two storage buildings, two shops, a pump house, and a kitchen, which comprise 229,822 square feet (sf) combined. Crownpoint is approximately 38 miles north of Thoreau, NM via New Mexico Highway 371. This Limited ESA was conducted to address a specific environmental conditions identified in a statement of work issued by BIA. A Phase I ESA was not conducted prior to this Limited ESA.

On May 29, 2012, Wells personnel mobilized to the Property along with its subcontractor, ATC

Associates, Inc. (ATC). Field personnel met with Mr. Francis Morgan, Facilities Maintenance

Manager. Wells assessed soil conditions around the perimeters of Buildings 3000 through 3012 to determine the possible presence of lead in the soil. An XRF survey was conducted and grab soil samples were collected at seven locations adjacent to exterior walls of selected buildings for comparison purposes. Grab soil samples were submitted for laboratory analysis of total lead.

Random paint chip samples were also assessed in the field for lead content using an XRF analyzer.

Lead concentrations in soils, as detected by a field-portable XRF, ranged from below the instrument detection level (the lowest detectable concentration was 6.19 ppm) to 209.83 ppm. Of the 162 samples collected, none exceeded 400 ppm, which is equivalent to both the EPA-recommended risk-based screening level for residential soils and the U.S. Department of Housing and Urban Development’s standard for high-contact areas (such as play areas). Field analysis of paint chips indicated very low lead concentrations were present. For the most part, these results suggest that weathered paint, which has fallen off the exterior surfaces of buildings and come in contact with soils surrounding the building, does not appear to be lead-based paint and has not negatively impacted soil with respect to lead concentrations. As such, the potential risk to human health from direct exposure to lead in these soils is considered low.

Wells conducted an inspection of the property surrounding the buildings to identify the presence of spills or releases of heating oil from aboveground storage tanks (ASTs) or underground storage tanks (USTs). Wells did not identify ASTs or USTs associated with the buildings, therefore, no oil samples were collected for analysis of petroleum products.

ATC performed an inspection of the 13 structures on the Crown Point Community School campus for asbestos-containing building materials, Lead-Based Paint (LBP) and other hazardous, regulated materials. The inspection was performed from May 29, 2012 through June 8, 2012 to identify materials that may possibly impact the environment or cause unnecessary worker exposure as a result of demolition or renovation activities to the subject buildings. Other hazardous, regulated materials evaluated as part of this portion of the inspection included but were not limited to:

mercury thermostats, smoke detectors, radioactive exit signs, PCB ballasts, fluorescent light tubes

(FLTs), compact FLTs, HVAC units with CFCs/HCFCs, mercury vapor lights, and cleaning/maintenance supplies.

Asbestos-containing materials were identified on site and included (but are not limited to) floor tiles, mastics, Gypsum wallboard/joint compound, roof flashings, hard cementitious fittings, tank ii insulation, boiler insulation, window caulking/glazing, Transite panels, etc. In accordance with

EPA regulations, all regulated asbestos-containing materials (RACM) must be removed prior to demolition or renovation activities. Category I and II asbestos-containing materials may also need to be removed prior to demolition/renovation activities in the event these activities have the potential to be damaged or rendered friable during those activities.

A cursory LBP inspection was conducted as part of this project to alert bidders, the abatement contractor, and/or other trades engaged in renovation/demolition work so that they may properly execute their activities in accordance with applicable provisions of the OSHA lead standard for construction and any other applicable lead regulations. Both interior and exterior painted surfaces were inspected. However, much of the exterior painted surfaces were negative with respect to detectable lead. All of the structures inspected at the project site contain building materials coated with LBP.

The visual inspection for hazardous/regulated materials identified building components and materials other than ACM and LBP within the structures. Materials identified included: PCB-containing ballasts, fluorescent light bulbs, mercury-vapor bulbs, incandescent light bulbs, smoke detectors, computer equipment, and various cleaning chemicals. These materials will need to be properly handled, recycled or disposed of according to applicable State and Federal regulations.

1.0 INTRODUCTION

Wells was contracted by the Bureau of Indian Affairs (BIA) to conduct Limited Phase II

Environmental Site Assessments (ESAs) of old community school buildings on the East Navajo

Agency in Crownpoint, Pueblo Pintado, and Ojo Encino, New Mexico. This report focuses on the

Crownpoint Community School buildings, hereinafter referred to as the “Property” and summarizes field activities, observations, field screening and laboratory analytical results of the

Limited Phase II ESA. This Limited Phase II ESA addresses specific conditions identified in a

BIA statement of work and a scope of services prepared by Wells. A Phase I ESA was not conducted prior to performance of this Limited Phase II ESA.

Crownpoint is approximately 38 miles north of Thoreau, NM via New Mexico Highway 371. The

Property is located at approximately N 35.68439 W 108.14147, within the southwest ¼ of Section

20, Township 17 North, Range 12 West, New Mexico Principal Meridian in McKinley County, New Mexico. A vicinity map of the Property is provided as part of Figure 1.

The Property is currently owned by the BIA and is being evaluated for demolition and/or transfer of ownership. The old Crownpoint School facilities assessed for this Limited ESA consist of thirteen structures: one multi-purpose building, two school buildings, two dormitories, a gym, an office building, two storage buildings, two shops, a pump house, and a kitchen which comprise

229,822 square feet (sf) combined (Table 1). Figure 1 also shows the layout of these buildings on the Property. The purpose of the Limited ESA was to conduct asbestos and lead-based paint surveys and to assess surface soil conditions outside the perimeters of buildings. In addition, other potentially hazardous materials were inventoried during performance of this Limited ESA.

On May 29, 2012, Wells personnel mobilized to the Property along with its subcontractor, ATC

Associates, Inc. (ATC). Field personnel met with Mr. Francis Morgan, Facilities Maintenance

Manager to discuss the scope of the Limited ESA and to gain access to the buildings. Mr. Morgan also provided floor plans of the buildings, which were photocopied and returned to him. The scope of the Limited Phase II ESA included the following:

An Asbestos-Containing Materials (ACMs) Survey including Vinyl Asbestos Tile, Thermal System Insulation (TSI), Glazing Putty, and roofing materials;

A Lead-Based Paint (LBP) Survey including Painted Plaster Surfaces and Painted

Wood Trim; and

An assessment of other potentially Hazardous Materials of concern or impacted media including: PCB containing fluorescent light ballasts, mercury-containing electrical switches, stored paint and chemicals, soils potentially impacted by exterior painted surfaces (along drip lines), and possible releases of heating oil.

Wells prepared a Health & Safety Plan (HASP) prior to mobilizing to the site and followed the

Plan throughout the Limited ESA. A Sampling and Analysis Plan (SAP) was also prepared to guide the Phase II sampling activities.

The remainder of this report summarizes field activities and the results of the soil survey, asbestos inspection, lead based paint survey, and general hazardous materials survey. Conclusions and recommendations are provided and the report use and limitations are discussed. Supporting documentation is provided in Tables, Figures and as Attachments to this report.

2.0 SOIL SURVEY

Wells personnel visually assessed the perimeters of Buildings 3000 through 3012 to identify indications of paint flaking off exterior building surfaces and to identify any indications of heating oil spills on the ground surface adjacent to aboveground storage tanks and underground storage tanks associated with each building. A sampling and analysis plan (SAP) was prepared prior to conducting Limited Phase II ESA field activities. The SAP was used to develop quality assurance objectives for the project and assess if those objectives have been met by the data collection and analysis methods.

2.1 Exterior Paint in Soil

To evaluate soil conditions around the perimeter of Buildings 3000 through 3012, Wells personnel conducted an XRF survey. A Thermo Scientific Niton XL3T 600 field-portable X-Ray

Fluorescence (XRF) instrument was used to assess metals concentration in surface soils. Although the instrument was calibrated to detect approximately 17 metals, lead was the primary metal of concern. Attachment A contains the results for all metals analyzed with the XRF. Lead concentrations are provided in Table 3. The exterior painted surfaces of all buildings showed signs of significant weathering. Painted surfaces were pealing and flaking and paint chips were visually apparent in soils surrounding exterior walls. If lead-based paint had been used on exterior building surfaces, there was a concern that this material will become finely disseminated in soils and create lead concentrations that exceed human health risk standards.

2.1.1 Soil Sampling Methods

XRF analysis involved lightly brushing away any surface debris including sticks, grass and other organic material; rocks; and large paint chips. The XRF was then placed on the ground surface with the Kapton measurement window in contact with the soil. A direct in-situ measurement was then taken by the instrument operator in accordance with the manufacturer’s user manual. Wells personnel collected a minimum of one XRF measurement along each exterior building wall, except where prohibited by concrete or asphalt ground surfaces. Figures 2 through 10 show the approximate locations from which XRF measurements were collected. GPS coordinates for the

XRF measurements are provided in Table 2.

During collection of the in-situ XRF measurements, Wells personnel collected grab samples from selected locations at the site. These samples were intended to provide an independent quality control check of field measurements. The physical samples were collected using a decontaminated, stainless steel spoon and placed in a 2-ounce glass jar provided by the laboratory selected to perform the soil analysis. The soil sample included the target area measured with the XRF. A second XRF measurement was taken of the soil that was placed in each sample jar.

In addition to assessment of lead in soils, Wells personnel randomly collected several paint chip samples from the site. The paint chip samples were scanned in the field with a portable XRF to assess lead content.

2.1.2 Results

Table 3 contains the results of 162 in-situ direct soil measurements collected using the Niton XL3T

600 XRF. Metals concentrations are reported in parts per million (ppm). Lead concentrations ranged from less than the level of detection (LOD) to 209.83 ppm. The LOD is different for each measurement. It is defined by the manufacturer as 1.5 times the precision. The precision of each measurement is 2 times the standard deviation and is shown under the error column in Table 3. The highest result should therefore be read as 209.83 ppm plus or minus 11.09 ppm, for example. The lowest detectable concentration recorded was 6.19 ppm. None of the 162 samples collected exceeded 400 ppm, which is equivalent to both the EPA-recommended risk-based screening level for residential soils and the U.S. Department of Housing and Urban Development’s standard for high-contact areas (such as play areas). Only two direct soil measurements exceeded 150 ppm; one around Building 3004 and one around Building 3005. Given the correlation between analytical data and the direct soil measurements, and relatively low recoveries for lead analyses by the analytical laboratory, these direct soil measurements may be indicative of lead concentrations approaching or slightly exceeding the risk-based standards. While widespread lead concentrations above the standards were not observed, there may be localized areas, such as the drip lines around Building

302, where these standards are exceeded.

Wells collected 12 surface soil samples selected randomly from soils around buildings at

Crownpoint, Pueblo Pintado, and Ojo Encino for laboratory analysis. Soil samples were submitted to American West Analytical Laboratories in Salt Lake City, UT for analysis of total lead according to EPA Method 6010C. Table 4 provides a summary of laboratory analysis of lead in soil samples. Field XRF measurements of each sample are also provided for comparison. Analytical results of soil sample analysis indicated that lead concentrations ranged from 7.22 ppm to 62.2 ppm at the three properties. These concentrations are below risk-based screening levels that represent a potential risk of human health exposure to lead.

Wells reviewed the laboratory reports to assess data quality in terms of the project objectives. The purpose of this investigation was to characterize near surface lead concentrations in soils surrounding exterior building walls. This effort was accomplished using field-portable XRF instrumentation supplemented by physical samples submitted for laboratory analysis. This investigation is considered to be a screening level assessment supported by confirmatory laboratory analysis. The corresponding level of QA/QC is considered Level 1/Level 2.

The data reported by the laboratory included: a method blank (MB) and laboratory control sample

(LCS) results; and matrix spike (MS) / matrix spike duplicate (MSD) results for site specific samples. Samples were collected and transported in the proper sample containers provided by the laboratory. Sample login documentation indicates that samples arrived at the laboratory within the holding times specified by the analytical methods. One sample was incorrectly labeled; however, this was a simple number substitution that was resolved. One container arrived broken, but Wells instructed the laboratory to perform the requested analysis. Reporting limits (RLs) were adequate to evaluate sample concentrations relative to regulatory screening levels. A method blank was analyzed to evaluate possible contamination introduced by reagents and laboratory equipment used in the analysis. Lead was not detected in the method blank. An LCS was analyzed to monitor the accuracy of the analytical procedure, independent of sample matrix effects. The LCS was within control limits with respect to lead. One MS and one MSD were prepared and analyzed to evaluate the effect of the sample matrix on the accuracy of the analytical procedure. MSDs are also analyzed to evaluate the precision of the analytical procedure. Spike recoveries were slightly below the laboratory control limits suggesting results may be biased low due to sample inhomogeneity. The relative percent difference (%RPD) was below the analytical control limit indicating acceptable reproducibility. Laboratory data provide a reasonable basis for assessing lead in soils and correlation with field XRF data.

In-situ field XRF measurements appear to agree well with field measurements taken of the soil samples collected in jars. although laboratory data are generally higher than field data, field measurements of In-Situ soil samples submitted for laboratory analysis correlate well with analytical results reported by the laboratory. A linear regression plot was prepared for these results.

A correlation coefficient of >0.75 generally indicates a positive correlation. With an R of 0.97, the regression analysis suggests a statistically strong agreement between field and laboratory data (see

Table 4). The precision of XRF measurements (error column in Table 3) provides additional information on which to evaluate XRF measurements that are close to an action level.

Field XRF analysis of paint chip samples collected from beneath exterior walls at all three school properties indicated that lead concentrations ranged from less than the instrument detection limit

(the lowest detectable reading was 0.01 ppm) to 6.40 ppm (Table 5). While this was not an extensive evaluation of paint that was used on exterior building surfaces, these results support the results of field and laboratory soil analysis, which suggest that paint chips on the exterior building walls are not derived from lead-based paint.

2.2 Heating Oil Releases

Wells personnel inspected above-ground storage tanks (ASTs) on the Property. Eight ASTs were observed at the Crownpoint school: one outside each of the following buildings: 3000, 3001, 3003, 3004, 3008, 3009, 3010, and 3012. All above ground tanks appeared to be in good condition and showed no signs of leaks or heating oil releases. Therefore no samples were collected for analysis of petroleum hydrocarbons. During inspection of Building 3010, Wells personnel noted the presence of what appeared to be exploratory boreholes adjacent to the area where the northwest and northeast wings of the building meet. The presence of bluish-gray soils adjacent to one of these boreholes suggested that the soils were drill cuttings that had been reduced by subsurface petroleum contamination. Mr. Francis Morgan indicated that former underground tanks were removed from outside all buildings in 2000, at about the same time that the above ground tanks were installed. Mr. Morgan indicated that the reports of tank removal and subsurface investigation are kept at the BIA regional office in Gallup. Wells did not review these reports or obtain any information about future environmental actions at the former underground storage tank sites.

Wells also contacted Ms. Rose Delanie of the Division of Environmental, Cultural and Safety

Management (ECSM), Navajo Regional Division of BIA, regarding impacts from heating oil tanks.

Ms. Delanie indicated that two buildings at the old Crownpoint School (Bldgs 3009 and 3010) had significant impacts from the heating oil tanks that were removed in 2000. Impacts from filler ports and underground piping were also identified in other locations however these locations were not shared with Wells by ECSM. These impacts have been identified for future remedial action and are being addressed by ECSM.

3.0 ASBESTOS INSPECTION

Upon arrival at the site, ATC inspectors conducted a walk-through inspection of each structure.

Accessible areas were visually evaluated for the presence of building materials with the potential to contain asbestos. During the inspection, the inspectors looked for suspect asbestos-containing materials on building components such as pipes, tanks, ceilings, etc.. Suspect materials were touched to determine if they were friable, and sampling areas containing homogeneous materials were identified. A homogeneous area is defined by the U.S. Environmental Protection Agency

(EPA) as an area of surfacing material, thermal system insulation, or miscellaneous material that is uniform in color and texture (Asbestos Hazard Emergency Response Act [AHERA] 40 CFR 763

Subpart E). Quantities of suspect materials identified were determined using visual estimation techniques. The EPA and Occupational Safety and Health Administration (OSHA) defines friable materials as those materials that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure.

ATC did not utilize destructive methods of inspection to confirm the presence or absence of suspect ACM concealed behind intact finished surfaces (e.g., plaster or drywall-enclosed wall chases and ceiling plenums). Additional quantities of ACM may be located within these inaccessible areas.

3.1 Bulk Sample Collection

During the asbestos inspection, samples of suspect materials were randomly collected from each structure in accordance with AHERA Section 763.86. For friable surfacing materials, three bulk samples were collected for each homogeneous area less than or equal to 1,000 square feet. If the homogeneous area was greater than 1,000 square feet but less than 5,000 square feet, five bulk samples were collected. For homogeneous areas that were greater than 5,000 square feet, seven bulk samples were collected. Sample locations for each homogeneous area of suspect surfacing material were determined by the inspectors during the initial inspection.

Three samples were randomly collected from homogeneous areas of thermal system insulation such as pipe or duct insulation. Miscellaneous materials such as floor tile or ceiling tile were sampled in a manner sufficient to determine whether the material in question contained asbestos.

To avoid disturbing the material more than necessary and potentially causing the release of asbestos fibers, bulk sampling of suspect materials was performed in accordance with generally accepted procedures outlined in current EPA Guidance Documents and in EPA-approved Asbestos

Building Inspector certification course manuals. Each sample was collected with a clean sampling tool and placed in a clean, sealable container and labeled with a unique sample identification number. This sample number was recorded on a Bulk Sample Log Sheet and on the sample container to permit easy identification of the sample. Supplemental information was also recorded on the Bulk Sample Log Sheet, including date of inspection, name of the inspector, the building name (or number), a brief description and location of the sample, and type of material sampled

(e.g., thermal insulation, floor tile, construction mastic, etc.). Upon completion of the inspection, bulk samples were submitted to ATC’s NVLAP-accredited Bulk Asbestos Laboratories in

Cincinnati, Ohio and Centennial, Colorado. Attachment D, Table 1 and Figures 1 through 14 present a summary of the sampling locations. Table 1 in Attachment D also contains the analytical results for the suspect materials tested.

3.2 Laboratory Analysis

The bulk samples were analyzed for asbestos content by polarized-light microscopy (PLM) and dispersion staining methods (Method Reference: EPA 600/R-93/116, July 1993). This analytical method, which the EPA currently accepts for the determination of asbestos in bulk samples, can be used for qualitative identification of six morphologically different types of asbestos fibers:

chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite asbestos.

The method specifies that the asbestos content in a bulk sample be estimated and reported as a finite percentage (rounded to the nearest percent) within the range of 0 and 100. Minute quantities of asbestos in bulk samples may be reported as "trace" or less than 1 percent (<1%). The analytical method determines the "area percent" asbestos or the percentage of the area of a microscopic field of view that is occupied by asbestos fibers.

The results of bulk sample analyses are reported in a standard written laboratory report. This written report includes the client name, the laboratory identification numbers assigned to each bulk sample upon receipt by the laboratory sample custodian, and the field number assigned to each bulk sample during the building inspection. The composition of the bulk sample is reported in percentage of asbestos (i.e., chrysotile, amosite, crocidolite, or other) and non-asbestos (i.e., cellulose, fiberglass, synthetic, or other) components. Attachment D, Table 2 presents an inventory of the ACM located within the accessible areas of the 13 structures. Additional quantities of ACM may be located within inaccessible areas (i.e. wall cavities, ceiling plenums, etc.). Copies of the laboratory reports from ATC’s asbestos laboratory and completed chain-of-custody forms are presented in Attachment D, Appendix B. The EPA defines an ACM as any material or product, which contains greater than 1 percent (>1%) asbestos by weight. When the visual estimate of a sample is less than 10 percent (10%) asbestos, the sample may be reanalyzed using the PLM point-count method. The PLM point-count method is a systematic, objective method that more accurately determines the percentage of small amounts of asbestos in a given sample. None of the samples collected were analyzed using the point-count method. However, point-count analysis could be performed upon request to possibly reduce abatement requirements and therefore demolition costs.

3.3 Analytical Results

A total of 363 bulk samples were collected from 160 homogeneous areas of suspect ACM found within and on the 13 structures. The results of the analyses of all samples that were suspected to contain asbestos are summarized in the Bulk Sample Data Summary (Attachment D, Table 1). This table lists:

a description of the material sampled, the location sampled, the identification number assigned to the sample by the inspector in the field, the percentage and type of asbestos present in the sample, if identified, and the homogeneous area from which the sample was collected.

The following building materials were analyzed and found to contain asbestos concentrations greater than one percent (>1.0%). A complete breakdown of the location and quantities of ACM within each structure is summarized in Attachment D, Table 2. Asbestos-containing materials were identified in all buildings except Buildings 3005 and 3011.

Interior Building Materials

9-in.

Floor Tile and Underlying Mastic – (Buildings 3001, 3002, 3003, 3006, 3008, 3010, 3012)

12-in.

Floor Tile and Underlying Mastic – (Buildings 3001, 3008, 3012)

Hard Cementitious Fittings – (Buildings 3001, 3002, 3003, 3006, 3008, 3009, 3010, 3012)

Transite Panels – (Building 3007)

Window Glaze – (Buildings 3003, 3008, 3009)

Door Caulking – (Building 3008)

Boiler Paper – (Buildings 3003, 3010)

Boiler Brick and Mortar – (Building 3012)

Tank Insulation – (Buildings 3002, 3003, 3012)

Gypsum wallboard/joint compound – (Building 3003)

Exterior Building Materials:

Roof Flashing – (Buildings 3001, 3003, 3006, 3008, 3012)

Roof Exhaust Caulking – (Building 3012)

Window Caulking – (Buildings 3001, 3003, 3009)

4.0 LEAD-BASED PAINT SURVEY

ATC Associates, Inc. (ATC) conducted a cursory survey for lead-based paint (LBP) on interior and exterior surfaces of each of the 13 structures located at the BIA Crown Point Community School

Campus using a portable Niton XL Spectrum XRF lead-based paint (LBP) analyzer. The LBP sampling strategy was based on the procedures outlined by the U.S. Department of Housing and

Urban Development (HUD) "Guidelines for the Evaluation and Control of Lead- Based Paint

Hazards in Housing," but was not a comprehensive survey and is not compliant with the HUD sampling requirements. Specifically, the LBP screening consisted of measuring lead concentrations of interior and exterior painted surface that were predominant at each building. Paint was considered predominant when it covered approximately 80% or more of the total interior or exterior building finish surface.

The XRF nondestructively analyzes for the presence of lead on painted surfaces. Portable XRF instruments expose a painted building component to X-rays, which cause lead to fluoresce with a characteristic frequency or energy. The instrument’s internal microprocessor and software then measure the intensity of this radiation. LBP is defined as paint having a lead content >1.0 mg/cm2 as determined by XRF, or > 0.5 percent by weight (5,000 ppm) as determined by laboratory analysis. OSHA does not define lead-containing paint or materials, or specify a minimum lead content for materials that could cause occupational airborne exposures to lead above permissible limits.

The XRF is considered an excellent screening instrument that can detect relatively high concentrations of lead in paint. The XRF, however, cannot always accurately detect lead in paint at concentrations below 0.5 percent by weight (5,000 ppm). ATC conducted XRF tests at 682 different locations; the results of these tests are presented in Attachment D, Table 3. The findings of the investigation revealed that all of the buildings contained components/materials which are considered lead-based paint or are lead-containing. However, the XRF results also indicate that much of the exterior painted wall surfaces do not contain detectable lead concentrations, which may help to explain the results of the XRF soil survey.

5.0 GENERAL HAZARDOUS MATERIALS SURVEY

ATC conducted a survey of each structure to identify and inventory heavy metal-containing fluorescent lamps, PCB-containing ballasts, CFC-containing refrigeration and air conditioning equipment, containers of chemical products and other hazardous/ regulated or potentially hazardous building components that may need to be removed and properly disposed, reclaimed, or recycled as required by current EPA regulations and best environmental practices if the materials will be adversely impacted by the future renovation/demolition plans.. These materials include:

Fluorescent lamps (mercury-containing);

Incandescent bulbs (heavy-metal containing);

Mercury-vapor bulbs (mercury-containing);

Light ballasts (possible PCB-containing);

Smoke detectors (possible radiological sources);

Computer equipment (heavy-metal containing); and, Various containers of cleaners, solvents, oils, and paints

A detailed breakdown of this inventory by building is presented in Attachment D, Table 4 and could change if any of these items are removed by the Property Owner or others prior to the start of renovation/demolition activities. If any of the materials identified Attachment D, Table 4 will be adversely impacted by the planned renovation/demolition activity, they should be properly removed, transported, recycled, and/or disposed in accordance with all applicable regulations.

In addition to compiling an inventory of hazardous or otherwise regulated materials as discussed above, ATC collected composite bulk samples of building materials from each of the structures and submitted them to Hygeia Laboratories Inc. in Sierra Madre, California, for analyses in accordance the EPA’s Toxicity Characteristic Leaching Procedure. The analytical results of the 15 bulk samples submitted for analyses are summarized in Attachment D, Table 5. A copy of the Hygeia analytical reports and completed Chain-of Custody forms are located in Attachment D, Appendix

C.

The analytical results indicate that the building materials that would comprise debris generated during the eventual demolition of the structures do not exceed the TCLP regulatory thresholds and should be able to be handled as a non-hazardous waste stream.

6.0 CONCLUSIONS AND RECOMMENDATIONS

6.1 Soil Survey

Wells assessed soil conditions at the perimeter of Buildings 3000 through 3012 to determine the possible presence of lead in the soil. An XRF survey was conducted and grab soil samples were collected at seven locations adjacent to exterior walls of selected buildings for comparison purposes. Grab soil samples were submitted for laboratory analysis of total lead. Random paint chip samples were also assessed in the field for lead content using an XRF analyzer.

Lead concentrations in soils, as detected by a field-portable XRF ranged from below the instrument detection level to 209.83 ppm. The lowest detectable concentration was 6.19 ppm. None of the 162

XRF measurements collected exceeded 400 ppm, which is equivalent to both the EPA-recommended risk-based screening level for residential soils and the U.S. Department of Housing and Urban Development’s standard for high-contact areas (such as play areas). Field analysis of paint chips indicated very low lead concentrations. These results suggest that weathered paint, which has fallen off the exterior surfaces of buildings and come in contact with soils surrounding the building, does not appear to be lead-based paint and has not negatively impacted soil with respect to lead concentrations. The results of the XRF building inspection indicate that much of the exterior painted wall surfaces do not appear to contain LBP. As such, the potential risk to human health from direct exposure to lead in these soils is considered low.

6.2 Asbestos Survey

Wells recommends that all the ACMs identified in this report be maintained under a written O&M program, by suitably trained personnel, until renovation necessitates removal or until the buildings are demolished. Subcontractors and employees working within the structures at the site should be made aware of the locations of the ACMs and the possibility of concealed ACMs that could be found during renovation/demolition activities.

Non-Friable and undamaged ACM are classified as National Emission Standards for Hazardous

Air Pollutants (NESHAP) Category I or Category II, non-friable ACMs by the EPA. In accordance with the NESHAP, as long as such materials remains in a non-friable state and are not subjected to mechanical drilling, sanding, abrading, grinding, or sawing during renovation and/or demolition activities, they do not have to be removed, provided no visible emissions are generated during the demolition process.

The following recommendations should be followed for demolition projects including contracting the services of an environmental consultant to monitor/document that the demolition contractor activities comply with the New Mexico Department of Environmental Quality, OSHA, EPA, and

NESHAP requirements:

The non-friable ACMs shall not be subjected to abrasion, grinding, sanding or any other processes during demolition, which will render these non-friable materials friable.

Subcontractors and employees working within the structures at the site should be made aware of the locations of the ACMs and the possibility of concealed ACMs that could be found during renovation/demolition activities.

Friable and Category I and Category II Non-friable materials (such as resilient floor coverings) that have a propensity to become friable during renovation/demolition, are recommended for removal by New Mexico-licensed personnel in accordance with applicable regulations, prior to building renovation/demolition. Any Person intending to either abate asbestos-containing materials in any amount, or demolish a structure shall, on a form supplied by the New Mexico Environment Department of Air Quality Bureau, provide a written notice of the intent to conduct asbestos abatement or demolition. No person shall commence an abatement project in which the amount of friable asbestos containing material exceeds any amount without first obtaining a permit from the New

Mexico Environment Department of Air Quality Bureau. Permit fees will be required for asbestos abatement projects.

If the substrate (such as concrete) on which non-friable ACMs are installed are intended for recycling, the non-friable ACMs should be removed prior to the recycling process, by a state-licensed asbestos abatement contractor prior to initiating substrate recycling activities.

6.3 Lead Survey

The survey for lead-based paint was conducted as part of this project to alert bidders, the abatement contractor, and/or other trades engaged in renovation/demolition work so that they may properly execute their activities in accordance with applicable provisions of the OSHA lead standard for construction and any other applicable lead regulations.

Although much of the exterior painted wall surfaces do not appear to contain detectable lead concentrations, lead-based paint has been found in a majority of the buildings associated with the project. Any planned renovation/demolition work (e.g., manual demolition of or modifications to building components coated with lead-containing paint) must be conducted in accordance with all applicable requirements of the OSHA lead standard. The OSHA lead standard has specific training requirements and work practices for activities involving the disturbance of lead paint, and requires that the contractor(s) that disturb lead-containing materials conduct exposure assessments of their employees during disturbance and/or manual demolition of lead-containing materials to determine worker exposures to lead.

The applicability of specific sections of the standard and the need to comply with specific requirements depend on the actual levels of exposure that employees experience when performing renovation/demolition activities in or on buildings where lead-containing materials are present.

Therefore, OSHA requires that the Contractor performing operations covered by this standard conduct exposure assessments to determine if their employees are exposed to lead above the action level (AL, 30μg/m3) or the permissible exposure limit (PEL, 50 μg/m3). Worker exposures above the AL and PEL trigger specific actions that the Contractor must take to control and limit exposures to lead and to comply with OSHA requirements.

Until lead exposure assessments have been conducted and the results evaluated, the standard requires the Contractor to treat their employees as though they are being exposed to lead in excess of the PEL, and to provide the following [per 29 CFR 1926.62(d)(2)(v)(A-F)]:

Respiratory protection;

Protective work clothing and equipment;

Change areas and hand washing facilities;

Biological monitoring; and, Training.

If the exposure assessments indicate that no employee is exposed above the AL, the Contractor may discontinue monitoring. Further exposure testing is not required unless there is a change in processes or controls that may result in additional employees being exposed to lead at or above the

AL, or may result in employees already exposed at or above the AL being exposed above the PEL.

The Contractor must keep a written record of the determination, including the date, location within the work site, and the name and social security number of each monitored employee.

6.4 Hazardous Materials Survey

ATC conducted a survey of each building to identify and inventory heavy metal-containing fluorescent lamps, PCB-containing ballasts, CFC-containing refrigeration and air conditioning equipment, containers of chemical products and other hazardous/regulated or potentially hazardous building components. This inventory is presented as Attachment D, Table 4 and could change if any of these items are removed by the Property Owner or others prior to the start of renovation/demolition activities. If any of the materials identified on Attachment D, Table 4 will be adversely impacted by the planned renovation/demolition activity, they should be properly removed, transported, recycled, and/or disposed in accordance with all applicable regulations.

6.4.1 Fluorescent Lamps, Incandescent Bulbs and Mercury Vapor Bulbs

Contractors responsible for the removal and recycling of fluorescent lamps, incandescent bulbs and mercury vapor bulbs shall handle and manage them in accordance with the Environmental

Protection Agency’s “Universal Waste Rules” as well as applicable State and Local regulations.

Some guidelines for the proper handling and recycling of fluorescent lamps include:

Carefully remove lamps and bulbs from fixtures. Lamps and bulbs shall remain intact

(unbroken) and shall be carefully placed into cardboard containers designed to hold them

(preferably original boxes obtained from the manufacturer or special boxes obtained from a lamp recycler).

Broken lamps and bulbs should still be recycled. However, if they are not acceptable to the recycling facility, they must be evaluated to determine if they are hazardous waste.

Remove and discard residues from broken lamps and bulbs promptly. Personnel cleaning up spills should have appropriate training and cleanup equipment, and wear appropriate personal protective equipment. Acceptable storage for broken, damaged, or leaking lamps and bulbs include a closed 55-gallon steel drum or a closed wax fiberboard drum.

Store boxed lamps and bulbs in a secure area and limit access to personnel qualified to handle them.

Contact an EPA-approved lamp recycler and arrange for transport of the properly packaged and labeled lamps and bulbs to the recycler.

Submit copies of the original shipment records documenting proper transport, recycling, and proper disposal of any unrecycled components to the Property Owner upon project completion.

6.4.2 PCB-Containing Ballasts

A limited visual inspection of ballast labels indicates that some of the fluorescent fixtures contain

PCB ballasts. The Contractor should be required to inspect all ballasts in each fixture and visually verify that all ballasts are labeled “No PCBs”, or if the ballast is unlabeled it should be presumed to contain PCBs.

Any PCB-containing ballast removed from light fixtures should be placed into a 55-gallon steel drum (17C or 17H) or other DOT-approved container appropriately labeled in accordance with

EPA and DOT regulations. Any leaking PCB-containing ballasts should be wrapped and sealed in

6-mil plastic disposal bags and placed in a separate steel drum or other approved container. Each disposal drum or container should have a sufficient amount of oil-absorbent material placed in the bottom to absorb any oil from ballasts that are leaking or may leak during transport.

The Contractor should then arrange for the transport of all properly containerized PCB-containing ballasts to an EPA-approved ballast recycling facility. Copies of completed original waste shipment records/manifests documenting the proper transport, recycling, or incineration of unrecycled components should be provided to the Property Owner upon project completion. The Contractor should also be required to obtain and provide documentation to the Property Owner that the ballast and lamp recycling facility has all the required permits and approvals necessary for operations involving recycling mercury-containing lamps and disposing of PCB-containing lightballasts.

6.4.3 Paint Cans and Chemical Containers

The Contractor should be required to remove from the premises all paint cans, fire extinguishers, pressurized containers, and other containers containing chemicals or products and arrange to have them properly containerized, transported, and disposed in accordance with applicable local, state, and federal regulations. Empty containers (e.g., cans, bottles, buckets, drums, etc.) that once may have contained liquids or solids shall also be removed. The Contractor should provide to the

Property Owner documentation demonstrating that all paint cans, fire extinguishers, and chemical containers have been properly removed, transported, and disposed.

In addition to compiling an inventory of hazardous or otherwise regulated materials as discussed above, ATC collected composite bulk samples of building materials from each of the structures and submitted them for analyses in accordance the EPA’s Toxicity Characteristic Leaching Procedure.

The analytical results indicate that the building materials comprising debris expected to be generated during the eventual demolition of the structures do not exceed the TCLP regulatory thresholds and should be able to be handled as a non-hazardous waste stream.

7.0 REPORT USE AND LIMITATIONS

This Limited Phase II ESA has been prepared for the exclusive use of the BIA, and is intended to provide an understanding of the potential recognized environmental conditions at the Property.

The scope of services performed in execution of this assessment may not be appropriate to satisfy the needs of other users, and any use or re-use of this document of the findings, conclusions, or recommendations presented herein are at the sole risk of the user.

Environmental services associated with this assessment were not intended to be comprehensive or to fully evaluate on or off-site extent of any contamination that may be present in soil and groundwater. Assessment findings such as presented in this report are by nature non-comprehensive and subject to limitations.

Selection of potential ACM sample locations and frequency of sampling was based on visual observations and the assumption that like materials in the same area are homogeneous in content.

Destructive investigation in the building was not authorized as part of this limited assessment. All unsampled suspect asbestos materials should be treated as assumed ACM in accordance with 40

CFR 763.

This report is not intended to serve as a bidding document or as a project specification document.

Actual site conditions may change over time and quantities are general estimates and should be field verified prior to making cost assumptions. Although reasonable efforts have been made to identify suspect asbestos in the areas identified, the limits of the scope of work and inspection techniques used is inherently limited in the sense that only full demolition procedures will reveal all building materials of a structure.

This assessment was conducted and the subsequent report was prepared in general accordance with customary principals, practices, and the accepted standard of care in the fields of environmental science and engineering including ASTM E1903-97 format and 40 CFR 312. However, the scope of this assessment was specifically defined by the BIA Statement of Work and limited to Asbestos

Inspection, Lead-based Paint Inspection and a General Hazardous Materials Survey, which was further defined by the Wells Scope of Work dated March 30, 2012. A Phase I ESA was not conducted for the Property. Therefore, this report is not intended to address all recognized environmental conditions (RECs) that could be present on the Property and is limited to those environmental conditions identified herein. No other warranty, expressed or implied, is given. The results, findings and conclusions expressed in this report are based only on conditions that were observed during Wells and ATC's inspection of the Site. Both Wells and ATC reserve the right to modify this report should additional data become available indicating such modifications are needed to more accurately reflect the conditions discovered. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated.

8.0 QUALIFICATIONS OF ENVIRONMENTAL PROFESSIONALS

Qualifications of the environmental professionals involved in the preparation and review of this report are presented in Attachment E. By signing this document, the undersigned declare that to the best of our professional knowledge and belief we meet the definition of an Environmental

Professional as defined in 40 CFR Part 312. In addition, we have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. We have developed and performed the project in general conformance with the standards and practices set forth in 40 CFR Part 312.