ASTM_PHASE_III_Investigation_Report_2_0003.pdf

ASTM PHASE III INVESTIGATION REPORT

BIA Former Sanostee Day School, Sanostee, Arizona

April 2024

Prepared For:

Bureau of Indian Affairs

301 W. Hill Avenue

Gallup, NM 87301

Prepared By:

1812 Schofield Lane

Farmington, NM 87401 iina ba, Inc. Project No.: 23-088-03 Contract No.: 140A0923P0041

BIA Branch of Environmental Management Former BIA Sanostee Day School ASTM Phase III Report Revision 02

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION

TRANSPORTATION | INFORMATION TECHNOLOGY

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TABLE OF CONTENTS

DISCLAMER ....................................................................................................................................... iv

ACRONYMS AND ABBREVIATIONS ....................................................................................................... v

1.0 PROJECT INTRODUCTION AND DESCRIPTION

1.1 Problem Definition and Background

1.1.1 Purpose of the Investigation

1.1.2 Problem to be Solved

1.1.3 Facility Background

1.1.4 Site Description

1.1.5 Physical Setting

1.1.6 Summary of Previous Investigations

1.2 Project Description

1.3 Site-Specific Health & Safety Plan (with Work Plan)

1.4 Project Kick-Off

2.0 PHASE III INVESTIGATION ACTIVITIES

2.1 Geophysical Surveys

2.2 Soil Sampling for Asbestos Fibers

2.3 Artesian Well Sampling

2.4 Subsurface Investigation of Identified Anomalies

2.5 Investigation of Surficial Debris and Structural Remnants

2.6 Illicit Dumping

3.0 ASSESSMENT FINDINGS

3.1 Geophysical Surveys

3.2 Soil Sampling for Asbestos Fibers

3.3 Artesian Well Sampling

3.4 Subsurface Investigation of Identified Anomalies

3.5 Investigation of Surficial Debris and Structural Remnants

3.6 Illicit Dumping

4.0 CONCLUSIONS

4.1 Geophysical Surveys

4.2 Soil Sampling for Asbestos Fibers

4.3 Artesian Well Sampling

Revision 02

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION

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4.4 Subsurface Investigation of Identified Anomalies

4.5 Investigation of Surficial Debris and Structure Remnants

4.6 Illicit Dumping

5.0 RECOMMENDATIONS

6.0 REMEDIAL ACTION PLAN

6.1 Removal and Disposal of Surficial Debris

6.2 Removal and Disposal of Subsurface Concrete Piers

6.3 Removal and Recycling of Asphalt and Concrete Pavements

6.4 Removal of VCT Chips……………………………………………………………………………………………………….. 15

6.5 Capping of Abandoned Well

6.6 Estimated Quantities

6.7 Engineering Cost Estimate

7.0 REFERENCES

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ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION

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APPENDICES

Appendix A: Figures

Figure 1: Site Location Map Figure 2: Site Layout Map Figure 3: Site Artifacts Map

Appendix B: Tables

Summary of Drinking Water Sample Analytical Results – Artesian Well

Appendix C: Photographic Documentation

Appendix D: Laboratory Analytical Reports

A & B Laboratory – Artesian Well Sampling Eurofins EMLab P&K – Soil Sapling for Asbestos Fibers

Appendix E: Supporting Documentation

Geophysical Imaging Report HAZWOPER Certifications Daily Field Safety Sheets

Former BIA Sanostee Day School Investigation Report Revision 02

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION

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DISCLAMER

iina ba, Inc. shall not be held liable for any improper or incorrect use of the data or information described and/or contained in this report and assumes no responsibility for user's use of them. In no event shall iina ba, Inc. be liable for any direct, indirect, incidental, special, exemplary or consequential damages (including, but not limited to, procurement or substitute goods or services; loss of use, data, or profits; or business interruption) however caused and on any theory of liability, whether in contract, strict liability or tort (including negligence or otherwise) arising in any way out of the use of this report or data and information herein, even if advised of the possibility of such damage. This disclaimer of liability applies to any damages or injury, including but not limited to those caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft or destruction or unauthorized access to, alteration of, or use of record, whether for breach of contract, tortious behavior, negligence or under any other cause of action.

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ACRONYMS AND ABBREVIATIONS

ACBM asbestos-containing building materials ASTM American Society of Testing and Materials

BEM Bureau of Environmental Management bgs Below ground surface BIA Bureau of Indian Affairs

CFR Code of Federal Regulations COC Chain of Custody COPC contaminant of potential concern CPG Certified Professional geologist CY cubic feet

DBCP dibromo-chloropropane

ECE Engineering Cost Estimate EDB ethylene dibromide

GPR ground penetrating radar

HSP Health and Safety Plan

IBI iiná bá, Inc.

Inc. incorporated

LF linear feet LLC Limited Liability Company

M million MSL mean sea level

N north NN Navajo Nation No. number NTP Notice to Proceed

OSHA Occupational Safety and Health Administration

PCBs

Polychlorinated bi-phenols Percent vi

PPE personal protective equipment

RAP Remedial Action Plan RECs RedOx

Recognized Environmental Conditions Reduction/Oxidation

SOS

Scope of Services

VCT

VOCs vinyl composition tile volatile organic compounds

W west

Former BIA Sanostee Day School Phase III Report

1.0 PROJECT INTRODUCTION AND DESCRIPTION

iiná bá, Inc. (IBI) was contracted under Bureau of Indian Affairs (BIA) Contract No. 140A0923P0041 to perform an American Society of Testing and Materials (ASTM) Phase III Environmental Site Assessment (ESA) in order to develop a Remedial Action Plan (RAP) to address any remaining Recognized Environmental Concerns (RECs) from the previous demolition of school structures/infrastructures to ensure the subject property is relinquished back to the Navajo Nation (NN) in a manner that is recognized as being protective of human health and the environment. All assessment activities were conducted in accordance with IBI’s Revised Technical and Cost Proposal for Environmental Services dated June 27, 2023 under the guidelines of a Site-Specific Health & Safety Plan (HSP) dated October 17, 2023.

1.1 Problem Definition and Background

The BIA has a former day school property (17 acres +/-) that previously experienced structure demolition several years ago. However, the BIA Branch of Environmental Management (BEM) has previously stated that the demolition of the site was performed by another BIA agency and that there is suspicion that the former structures were not abated of their hazardous building materials and may have also subsequently been buried onsite. Before property can be relinquished back to the Navajo Nation, it must be deemed free of all hazardous wastes or conditions from the previous site occupation and use. Therefore, a detailed assessment of all possible remaining hazardous materials or conditions is required in order to develop a detailed RAP to address any confirmed hazardous conditions.

1.0.1 Purpose of the Investigation

The purpose of this investigation is to perform adequate data collection at the subject site to determine the presence or absence of remaining RECs such that a RAP can be prepared to successfully address (remediate) the hazards rendering the subject property safe for human health and the environment.

1.0.2 Problem to be Solved

The subject property has been vacant for many years, even prior to the cited demolition.

Previous assessments have determined the presence of asbestos-containing building materials (ACBM) within the subject property in the form of non-friable vinyl composition tile (VCT) from previous structures. While there is no empirical evidence to date that this material has caused undo risk to human health or the environment, it is the intent of the subject investigation to determine if there is undue risk to human health or the environmental resulting from this previous discovery. There are also other recognized conditions that remain onsite that include modular building pier/column concrete supports, miscellaneous scattered surface debris, metal pipes, possible transite pipe (surficial and buried), as well as remnants of concrete sidewalks, curbs and gutters, and minor asphalt pavement that should have been previously removed during past demolitions. The general magnitude of these artifacts/features need to be quantified in order to prepare an estimated cost for final site remedial actions.

1.0.3 Facility Background

The federal Bureau of Indian Affairs (BIA) operated a day school from the late 1960s to approximately 2014. Following the closure of the school, it sat abandoned until about 2017 when the school buildings and infrastructure were demolished from the subject site.

The BIA has stated that this effort was done internally through another BIA agency (BIA Roads Force Account). However, IBI located a project description that was prepared by the Doyon Government Group located in Federal Way, WA. that cites their Cherokee General Corporation was awarded a $1.6M project with the BIA to demolish for former Sanostee Boarding School. The project description further states that the buildings, utilities (water lines, sewer lines, electrical conduit, gas lines and propane lines) and elevated water towers were removed as part of the project. Further details indicate that all hazardous building materials were also removed prior to demolition and properly disposed of as hazardous and non-hazardous materials.

1.0.4 Site Description

The subject site can be accessed at the intersection of Navajo Route 34 and Navajo route 5010 and is positioned immediately due west and southwest of the Sanostee Chapter complex in San Juan County, New Mexico on the Navajo Indian Reservation (36°25’ 34.48” N; 108°52’ 41.51” W). The location of the subject site is shown on Figure 1 in Appendix A with a general site layout map (as of October 2016) shown on Figure 2 in Appendix A.

The property is currently vacant and is covered by various grasses and scrub brush with unimproved secondary roads running through and around the perimeter. The property is mostly flat with some irregular areas resulting from the previous development and demolition activities. The elevation of the site is approximately 6,020 feet above mean seal level (MSL). There is a capped, but accessible artesian well located near the only remaining stand of trees that is currently used by local residents to obtain water for livestock use.

1.0.5 Physical Setting

The former BIA Sanostee Day School is situated in a mixed-use area near the Sanostee Chapter Government Complex with light residential homesite areas, and open rangeland that is on the eastern side of Beautiful Mountain.

1.0.6 Summary of Previous Investigations

A previous Phase II Environmental Site Assessment Report prepared by T.H.A.T Consultants LLC of Ganado, Arizona (T.H.A.T., March 2022) reported the following RECs at the subject site:

• ACBM VCT remnants (chips) containing greater than 1% asbestos fibers;

• Asphalt and concrete remnants from previous infrastructure;

• Piece of Transite pipe containing 18% asbestos;

• Minor dumping of miscellaneous debris (including tires); and,

• Capped, artesian water well (not an REC nor “domestic” as cited by T.H.A.T).

1.2 Project Description

The following pre-work activities were performed during the execution of this Phase III investigation based on our Scope of Services (SOS) dated June 27, 2023:

1. Preparation of a Site-Specific Health and Safety Plan (HSP); and,

2. Preparation of a Work Plan.

The following field activities were performed during the execution of this Phase III investigation based on our SOS dated June 27, 2023:

1. Performance of a geophysical survey of suspected areas within the subject site where there was belief of possible buried demolition debris; and,

2. Site Sampling and Characterization.

Based on the results and findings from the field activities performed, IBI developed a RAP with estimated engineering costs to remove the RECs from the subject site to render the property protective of human health and the environment.

1.3 Site-Specific Health and Safety Plan (with Work Plan)

IBI personnel who worked at the subject site met the Occupational Safety and Health Administration (OSHA) training requirements defined in Title 29 Code of Federal Regulations (29 CFR) Part 1910.120(e). These requirements include: (1) 40 hours of formal off-site instruction; (2) a minimum of 3 days of actual on-site field experience under the supervision of a trained and experienced field supervisor; and (3) 8 hours of annual refresher training. Field personnel who directly supervise employees engaged in hazardous waste operations also receive at least 8 additional hours of specialized supervisor training. The supervisor training covers health and safety program requirements, training requirements, personal protective equipment (PPE) requirements, spill containment program, and health-hazard monitoring procedures and techniques. At least one (1) member of every IBI field team had a current certification in the American Red Cross “Multimedia First Aid” and “Cardiopulmonary Resuscitation (CPR) Modular,” or equivalent. Copies of IBI’s health and safety training records, including course completion certifications for the refresher health and safety trainings are included in Appendix E along with copies of the daily Jobsite Safety Meeting Forms prepared each day of field activities. A copy of the October 17, 2023 HSP (with Work Plan) is on file and available upon request. The subject document was issued to the BIA via e-mail on October 27, 2023.

1.4 Project Kick-Off

On August 23, 2023, a teleconference kick-off meeting was conducted between IBI and the BIA to discuss the final details regarding the proposed SOS and to receive a Notice to Proceed (NTP) for implementing the subject work.

2.0 PHASE III INVESTIGATION ACTIVITIES

This section describes the field activities conducted as part of this assessment:

• Geophysical Survey for Anomaly Identification

• Soil Sampling for Asbestos Fiber Assessment

• Artesian Well Sampling for Water Quality Determination

• Subsurface Investigation of Identified Anomalies

• Investigation of Surficial Debris and Structural Remnants

• Illicit Dumping

2.1 Geophysical Surveys

On November 20, 27, and December 29, 2023, the 17-acre property was scanned for the presence of absence of geophysical anomalies that could be interpreted as indicating buried demolition debris from past site activities. The subject effort was conducted by Southwest Geophysical Consulting, LLS from Albuquerque, New Mexico, with additional aerial drone survey support provided by Drone Geoscience, LLC of Denver, Colorado. The use of ground-penetrating radar (GPR) and electromagnetic induction survey was selected based on the type of ground terrain and suspected target anomalies requiring mapping. A detailed description of the subject geophysical methodologies is included in the Geophysical Imaging Report, dated February 9, 2024, in Appendix E. All field data collection was supervised and supported by IBI personnel, Mr. John R. Isham, CPG and/or Mr. Leotis Denetclaw.

As indicated in the cited report, the subject property was subdivided into four (4) different areas, depending upon the previously documented site activities or former property use by the BIA. This included Area 1 for the former residential housing area; Area 2-3 for the southernmost residential housing area and the former access road (buried Transite water pipe suspected), and Area 4 where the ACBM and suspected demolition debris burial are located (see report in Appendix E). The GPR effort was conducted on foot by a systematic transect of data segments and the electromagnetic induction survey was conducted using an un-manned aerial drone. Representative photographs of the geophysical survey operations are included in Appendix C.

2.2 Soil Sampling for Asbestos Fibers

On February 29, and March 5, 2024, the marking out of sample locations and the collection of representative soil samples from Area 4 where the previous discovery of VCT chips containing asbestos fibers in excess of 1% was performed by IBI personnel Mr. John R. Isham, CPG, and Leotis Denetclaw.

The collection of representative soil samples from a gridded area measuring 300 feet long by 300 feet wide were collected using a stainless steel hand auger from depths representing 0 to 6 inches below ground surface (bgs) and 6 to 12 inches bgs. A total of 44 separate locations were sampled for a total of 97 samples analyzed. Each sample was placed into a small zip-lock baggie, labeled, and submitted under the appropriate Chain-of-Custody (COC) procedures to Eurofins EMLab P&K of Phoenix, Arizona via overnight FedEx®. A total of 49 individually-spaced sample on an approximately 50-foot center grid, were submitted for analysis of the presence or absence of asbestos fibers in accordance with ASTM Method D7521. A copy of the Laboratory Report with COC is included in Appendix D. Representative photographs of the sampling event are included in Appendix C.

2.3 Artesian Well Sampling

The capped artesian well located on the subject property was thoroughly sampled for drinking water analyses on February 29, 2024 by Mr. John R. Isham, CPG and Mr. Leotis Denetclaw. During the sampling effort, there were several local residents obtaining livestock water before and after the event, which indicates the well is highly utilized and known by the community. A brass barbed sampling fitting with a polyethylene hose was threated onto an existing sample port fitted to the cased wellhead. Laboratory-prepared sample containers were filled in accordance with appropriate IBI SOPs (see Appendix E) for the following analyses: alkalinity, nitrate, nitrite, fluoride, sulfate, chloride, color, total dissolved solids, cyanide, MBAs, VOCs, EDB/DBCP, SVOCs, pesticides, PCBs, chlorinated acids, carbamates, glyphosate, endothall, diquat/paraquat, aluminum, antimony, arsenic, barium, beryllium, cadmium, chromium, copper, iron, lead, manganese, mercury, nickel, selenium, silver, sodium, thallium, zinc, uranium gross alpha, gross beta, Radium 226, Radium 228, and hardness. Each sample was labeled and placed into a zip-lock baggie and submitted under the appropriate Chain-of-Custody (COC) procedures to A & B Lab of Tucson, Arizona via overnight FedEx®. A copy of the Laboratory Report with COC is included in Appendix D. Representative photographs of the sampling event are included in Appendix C. In addition, field measurements during sampling were also obtained using a field-calibrated water quality meter for pH, temperature, specific conductance, dissolved oxygen, and oxidation-reduction potential (RedOx). The results of the field and laboratory analyses are summarized in Table 1 in Appendix B.

2.4 Subsurface Investigation of Identified Anomalies

On March 11, 2024, a total of 16 geophysical anomalies identified by the GPR and electromagnetic induction surveys were investigated to determine the source of each anomaly using a tracked mini-excavator. The sitework was conducted by Mr. John R.

Isham, CPG and IBI equipment operator Mr. Waltson Bradley. Using the GPS coordinates for the center of each anomaly obtained during the geophysical surveys, the excavator was used to remove the overburden at each location to identify any feature or condition that might have resulted in the anomaly being recorded. Eleven electromagnetic anomalies were identified (A1 to A11) and were investigated in order of most likely buried debris zones (A1) to least likely (A11). In addition, three (3) high-conductivity anomalies (A14-A16) were also recorded and investigated. The location of the anomalies are shown in the Geophysical Imaging Report in Appendix E with representative photographs of each anomaly during investigation included in Appendix C. All anomaly areas were excavated to a total depth of approximately six (6) feet or until the identification of the “anomalous” feature was encountered.

2.5 Investigation of Surficial Debris and Structural Remnants

On December 4, 2023, IBI evaluated the subject property in order to identify and document significant surficial features and debris remnants for quantifying waste materials for disposal during the remedial action phase. A sub-meter GPS unit was utilized to obtain a coordinate of each major surficial debris item encountered with an additional representative photograph of the item. High-visibility orange paint was used to temporarily mark each item and a subsequent location map was prepared, with a coordinate table for future reference (see Figure 3 in Appendix A). All sitework was overseen by Mr. John R.

Isham, CPG, with additional support provided by Ms. Amelia Fuller, and survey technician Mr. Izack Joe. Photographs of some of the more prolific features encountered are included in Appendix C.

On March 11, 2024, a representative concrete pier from a large area of piers in Area 4 was investigated to better understand the nature and extent of these features for estimation of concrete debris for recycling. Mr. Waltson Bradley of IBI, (under the guidance of Mr.

John R. Isham, CPG) using a tracked mini-excavator, removed the overburden soils around a pier to document their condition. Representative photographs of the excavation process and resulting findings are included in Appendix C. After removing the subject pier from the subsurface, the void was backfilled and the grade around the pier was restored.

2.6 Illicit Dumping

On April 3, 2024, several areas of past illicit dumping were investigated to determine the relative size, magnitude, and composition of the debris in order to evaluate the areas for removal and proper disposal requirements. The work was conducted by Mr. John R.

Isham, CPG. The areas are located at the southwestern corner and perimeter of the former school property (see photographs in Appendix C). The debris is the result of dumping from the adjacent residential homesites that are south of the former school property. The largest area is at the southern fence line where a drainage feature has been filled offsite and the debris has been pushed and discarded through the fence line to inside the school property. Other isolated areas are located inside the school property at various locations nearby. There is actually an excavated trench inside the former school property oriented north-south that has a small amount of debris located within. All of the debris appears to be household in nature including wood, metal, plastic, tires, and other non-hazardous materials. No liquids or suspect building materials that might contain hazardous constituents (asbestos or lead) were observed. All of it was highly weathered and degraded, indicating it has been deposited there for quite some time.

3.0 ASSESSMENT FINDINGS

The following summarizes the findings from the investigation efforts summarized above.

3.1 Geophysical Surveys

The results of the geophysical surveys reported a total of 16 areas or anomalies across the subject site that were subsequently investigated and assessed for the presence or absence of buried demolition debris or remnant site features.

3.2 Soil Sampling for Asbestos Fibers

The results of the surficial and near-surface sampling of soils within Area 4 that was believed to be the location of buried demolition debris that was not properly abated of ACBM revealed the absence of detectable fibers that can be attributed to destructive demolition activities where non-friable ACBM was likely involved. It must be further noted that the entire area sampled appears to contain hundreds to possibly thousands of very small pieces of weathered VCT that appear to have been present for a very long time, prior to the cited demolition activities that occurred in the most recent event.

3.3 Artesian Well Sampling

The results of the comprehensive sampling of the existing artesian water well on the subject property for the suite of drinking water parameters indicated that the quality of the groundwater being produced by the subject well is excellent in quality, and while the current wellhead completion is not sanitary in nature, the water itself is safe for human consumption as well as its current use for livestock consumption.

3.4 Subsurface Investigation of Identified Anomalies

The results of the subsurface investigation of the identified geophysical anomaly areas revealed that only two (2) anomalies could be attributed to the shallow burial of demolition debris. This included Anomaly 6 and Anomaly 8-9. However, even these buried items were limited in extent and nature and do not indicate the presence of a more significant burial of demolition debris, but rather random, scattered buried debris items.

3.5 Investigation of Surficial Debris and Structural Remnants

The results of the surficial debris identification and subsurface evaluation of structural elements remaining onsite revealed the following estimated quantities:

• Concrete items: 182+

• Rebar: 8+

• Pipe (metal/sewer): 10+

• Trash/Plastic: 6+

• Wood: 2+

• Asphalt: 6,670 CF (247 CY)

• Concrete Curb/Gutter: 1,915 LF

• Concrete Sidewalk: 2,550 SF (50 CY)

It should be noted that in addition to the major items identified above, the entire project site also contains many more much smaller pieces and occurrence of these features that were easily identifiable and mapped during this investigation. Furthermore, during the surficial investigation, it was determined that a capped water supply well is present on the site located off the southeastern corner of the intersecting perimeter roads (see Figure 3 in Appendix A and photograph in Appendix C).

3.6 Illicit Dumping

Based on the evaluation of the illicit dumping areas within the subject property, it has been determined that no hazardous wastes, universal wastes, or suspect building materials that might contain asbestos or lead are included in the waste piles. All of the materials are on the surface and readily accessible and can be disposed of as general household trash or demolition debris.

4.0 CONCLUSIONS

The following summarizes the conclusions drawn from the results of the investigation and assessment of the subject site.

4.1 Geophysical Surveys

The performance of GPR and electromagnetic surveys across the 17-acre subject site did not result in the identification of any anomalous feature that resulted in the confirmation of significant buried demolition debris from the previous efforts performed. Only minor occurrences of isolated debris were determined to be present.

4.2 Soil Sampling for Asbestos Fibers

The performance of shallow and near-surface soil sampling for the presence or absence of asbestos fibers in soil due to the potential for destructive demolition activities to have been conducted without proper abatement of ACBM (VCT) have not impacted the site soils.

Since no detectable asbestos fibers can be detected, the remnant chips of VCT on the subject site do not pose an immediate threat to human health or the environment.

4.3 Artesian Well Sampling

The performance of water quality sampling and analysis of groundwater from this water source has concluded that the quality of the water is highly suitable for livestock and other domestic uses (gardening). If the current configuration of the wellhead assembly is retrofitted for a more sanitary access to the groundwater, the well can be turned into a domestic watering point for local residents that do not have running water (e.g., cisterns).

4.4 Subsurface Investigation of Identified Anomalies

The performance of subsurface investigations to identify the source or cause of a geophysical anomaly revealed that only two (2) isolated (Anomalies 6 and 8-9) areas were caused by very shallow surface debris discarded from past use of the subject site. There is no evidence indicating that large quantities of buried demolition debris from the former school buildings or infrastructure have been buried.

4.5 Investigation of Surficial Debris and Structure Remnants

The performance of investigative actions to document and determine the nature and extent of surficial debris and structural remnants has concluded that there are numerous concrete, metal, and minor wooden items remaining onsite from the previous demolition efforts that can create a significant volume of debris once removed and consolidated. Remaining concrete and asphalt materials make up the highest percentage of materials requiring removal and disposal.

4.6 Illicit Dumping

Areas of illicit dumping have occurred, mainly in one (1) general area of the subject property (SW quadrant) from the adjacent residential homesite lease holders, with other minor (isolated) occurrences within the subject property, as well as from general windblown trash. None of the items dumped are hazardous in nature by definition but should be removed from the subject site to prevent any potential harm to human health or the environment.

5.0 RECOMMENDATIONS

The following summarizes the recommendations drawn from the conclusions drawn of the investigation and assessment of the subject site.

Notify the Sanostee Chapter of the acceptable results of the water quality sampling and analyses from the capped artesian well currently being utilized by local residents for livestock water;

Remove all concrete, asphalt, metal, wood, plastic, tires, etc. that are either scattered across the surface and shallow subsurface of the subject property for either disposal or recycling at permitted facilities;

Remove the area containing the surficial VCT chips containing asbestos fibers to prevent any potential exposure to human occupations or livestock;

Remove and properly dispose of all illicitly dumped debris on the subject property for offsite disposal at a permitted facility;

Properly close (abandon) the identified capped water supply well in accordance with regulations set forth by the New Mexico State Engineer’s Office; and, Re-seed and fertilize the highly disturbed areas of the subject property resulting from the removal of remnant concrete piers.

6.0 REMEDIAL ACTION PLAN

The following Remedial Action Plan (RAP) was prepared utilizing the results of this ASTM Phase III investigation in order to eliminate the potential for any remaining Recognized Environmental Conditions (RECs) that may pose a threat to either human health or the environment. The following sections are broken down by the specific remedial action to be performed under this RAP, with any further conditions or assumptions used in the preparation of an Engineering Cost Estimate (ECE) for the completion of the subject work.

6.1 Removal and Disposal of Surficial Debris

Under this effort, the identified surface debris scattered across the surface of the subject site will be collected and hauled to a permitted landfill for proper disposal as general solid waste debris. This will include metal, wood, plastic, and tires. This effort will best be facilitated by a front-end loader and laborers on the ground hand gathering the items in a systematic grid pattern starting from the north side of the subject site to the south. The gathered debris will be further facilitated using a small, tracked excavator to pick up and load debris that is too heavy to lift by hand or the volume is significant (e.g., illicit dump areas). Scale tickets for each load of debris removed from the subject site will be generated and will become a record in a final summary report. Based on the investigation, it has been estimated that there can be at least 175 cubic yards (CY) of debris requiring disposal. Any tires removed (estimated at no more than 25) will require separate disposal from the primary debris. There is also a small, narrow trench that was created off the southwestern quadrant of the subject property. It only contains very minor debris that should be removed prior to backfilling this trench to grade with imported material.

6.2 Removal and Disposal of Subsurface Concrete Piers

Under this effort, the identified subsurface concrete piers, that were associated with previous modular structures onsite, will be physically removed from the ground for proper recycling of the concrete at an off-site permitted facility. Due to the large number and variable size of these features, it will require two (2) excavators operating simultaneously that will highly disturb the ground within the areas of excavation. Since it has been determined that many of these piers are sizable in nature (18 to 32 inches in diameter and up to 8 feet deep), this remedial effort will be the most time-consuming and costly to perform. In addition, many of the piers were documented as containing significant rebar for structural reinforcement at between ¼ to ½-inch in size. This will require that the piers be “processed” onsite by the breaking and physical removal of the rebar before hauling the concrete to a recycling facility.

Once the removal of all piers has been performed, there will be the need for some supplemental backfill to be imported to fill in any remaining voids created. In addition, due to the nature of the work resulting in the areas being highly disturbed, they should be reclaimed to an extent practicable by re-seeding and mulching.

6.3 Removal and Recycling of Asphalt and Concrete Pavement

There is an area just inside the entrance to the subject property that still contains some remnants of the former asphalt pavement with curb and gutters, and a section of concrete sidewalk. These pavement items will be removed for proper off-site recycling at a permitted facility using a tracked skid-steer and a tracked mini-excavator. After removal, the remaining ground will be graded uniform with the surrounding grade.

6.4 Removal of VCT Chips

While the area containing a small number of VCT chips containing asbestos fibers does not pose an immediate threat to human health or the environment, they should be removed from the subject site to return this area to as close as possible to its original condition prior to development. The surficial soil containing the chips (0 to 4 inches) can be scraped and consolidated for off-site disposal as non-friable asbestos waste at a permitted landfill under a Special Waste Manifest. Due to no previous analytical confirmation of a asbestos fiber release, the area can be regraded level and seeded and mulched with a seed mixture comparable to the natural area to re-establish vegetation and prevent any erosion.

6.5 Capping of Abandoned Well

The capped well discovered during the ASTM Phase III investigation should be properly abandoned in accordance with applicable regulations. This can be accomplished by adding a common off-the-shelf chlorination product to the well to eliminate any possible bacterial growth that might have occurred as a result of the well’s previous use or lack of a proper sanitary surface seal. The upper 20 feet of the well casing should be sealed to the ground surface with a mixture of Portland Type I/II cement and potable water. An inflatable packer seal (plug) can be set at a depth of 20 feet and the annular grout seal is placed on top to ground surface.

6.6 Estimated Quantities

Based on the information gathered during this ASTM Phase III investigation, the following estimated quantities of materials have been determined for either off-site disposal, recycling, or site restoration activities:

General solid waste: 175 CY (220 tons)

Vehicle tires: 25+/- (all passenger sized)

Concrete piers waste: 675 CY (1,350 tons)

Non-friable asbestos soil waste: 125 CY (170 tons)

Asphalt waste: 250 CY (3.5 tons)

Concrete curb/gutter and sidewalk: 125 CY (250 tons)

Area to restore post-remediation: 3.0 acres

Imported backfill: 175 CY (219 tons)

Well abandonment seal: 20.5 gallons

7.0 REFERENCES

T.H.A.T. Consultants LLC. 2022. “Phase II Environmental Site Assessment Report” Former Sanostee School Site, San Juan County, Sanostee, New Mexico. Bureau of Indian Affairs, Gallup, New Mexico. March, 48 pp.

Southwest Geophysical Consulting, LLC. 2024. “Geophysical Imaging Report” Sanostee School, Sanostee, New Mexico. February 9, 14 pp.

Water Wastewater Solid Waste Roads Stormwater Subdivisions Surveying GIS

Hydrology Air Quality ESA Soil Investigations SPCC Water Rights LUST

APPENDIX A – FIGURES

BIA Former Sanostee Day School

Sanostee, San Juan County, New Mexico

BIA Contract No.: 140A0923P0041

Prepared For:

Bureau of Indian Affairs Branch of Environmental Management 301 W. Hill Avenue Gallup, NM 87301

Prepared By:

iiná bá, Inc.

1812 Schofield Lane

Farmington, NM 87401 www.iinaba.com

Phone: (505) 327-1072 Fax: (505) 327-1517 http://www.iinaba.com/

SOURCE: GOOGLE EARTH IMAGE 10/2016

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FIGURE 1: SITE LOCATION MAP

ASTM PHASE III INVESTIGATION REPORT

BUREAU OF INDIAN AFFAIRS – FORMER SANOSTEE DAY

SCHOOL

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

SOURCE: USGS 7.5-MINUTE SANOSTEE WEST, NM (2017)

EXPLANATION

APPROXIMATE FACILITY BOUNDARY

SCALE: 1” = 1,595’

iiná bá, Inc. Project No.: 23-088-03 BIA Contract No.: 140A0923P0041

ILLICIT DUMP

CAPPED WELL

ARTESIAN WELL

ANOMALY 8-9

SOURCE: GOOGLE EARTH IMAGE 10/2016

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FIGURE 2: SITE LAYOUT MAP

ASTM PHASE III REPORT

BUREAU OF INDIAN AFFAIRS – FORMER SANOSTEE DAY

SCHOOL

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

SOURCE: GOOGLE EARTH IMAGE – 6/2017

EXPLANATION

APPROXIMATE FACILITY BOUNDARY

ACBM SOIL SAMPLING AREA

DEBRIS DUMPING AREA (METAL AND MIXED)

SCALE: 1” = 357’

iiná bá, Inc. Project No.: 23-088-03 BIA Contract No.: 140A0923P0041

ILLICIT DUMP

CAPPED WELL

ARTESIAN WELL

ANOMALY 8-9

© 2023 Microsoft Corporation © 2023 Maxar ©CNES (2023) Distribution Airbus DS © 2023 Microsoft Corporation © 2023 Maxar ©CNES (2023) Distribution Airbus DS

Phone: (505) 327-1072 Fax: (505) 327-1517 www.iinaba.com

1812 Schofield Lane, Farmington, NM 87401

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION | TRANSPORTATION

PROJECT# 23-088-03

DRAWN: IWJDATE: 12/20/2023

BUREAU OF INDIAN AFFAIRS

FORMER SANOSTEE DAY SCHOOL

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

FILE:23-088-03.DWG CHECK:

FIGURE 3: SITE ARTIFACTS MAP

SHT #1 of 3

LEGEND:

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POINT(S) #178-255

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GRID NORTH SCALE: NTS

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CONCRETE

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REBAR

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DEBRI

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TRASH

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PIPE

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WOOD

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SCO

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SEWER CLEANOUT

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WELL

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POINT(S) #273-307

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POINT(S) #153-173

www.iinaba.com

1812 Schofield Lane, Farmington, NM 87401

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION | TRANSPORTATION

PROJECT# 23-088-03

CHECK: SHT #2 of 3

NOTES:

DRAWN: IWJDATE: 12/20/2023

FILE:23-088-03.DWG

SITE ARTIFACTS POINT TABLE

SANOSTEE DAY SCHOOL, SAN JUAN COUNTY,

NEW MEXICO

BUREAU OF INDIAN AFFAIRS

FORMER SANOSTEE DAY SCHOOL

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

AutoCAD SHX Text

1. COORDINATES SHOWN ARE IN LATITUDE & LONGITUDE (WGS84) & IN DMS FORMAT COORDINATES SHOWN ARE IN LATITUDE & LONGITUDE (WGS84) & IN DMS FORMAT LATITUDE & LONGITUDE (WGS84) & IN DMS FORMAT & LONGITUDE (WGS84) & IN DMS FORMAT www.iinaba.com

1812 Schofield Lane, Farmington, NM 87401

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION | TRANSPORTATION

PROJECT# 23-088-03

DRAWN: IWJDATE: 12/20/2023

FILE:23-088-03.DWG CHECK: SHT #3 of 3

SANOSTEE DAY SCHOOL, SAN JUAN COUNTY,

NEW MEXICO

SITE ARTIFACTS POINT TABLE

BUREAU OF INDIAN AFFAIRS

FORMER SANOSTEE DAY SCHOOL

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

APPENDIX 2 – TABLES

BIA Former Sanostee Day School

Farmington, NM 87401 www.iinaba.com

Phone: (505) 327-1072

SUMMARY OF DRINKING WATER SAMPLE ANALYTICAL RESULTS

BIA FORMER SANOSTEE DAY SCHOOL ARTESIAN WELL

iiná bá, Inc. Project No. – 23-088-03

Well No.

Well Depth

(ft. bgs)

Sample Date

Sample Time

Alkalinity (mg/L)

Nitrate (mg/L)

Nitrite (mg/L)

Fluoride (mg/L)

Sulfate (mg/L)

Chloride (mg/L)

Color (color units)

TDS

(mg/L)

Cyanide (mg/L)

MBAs (mg/L)

VOCs (µg/L)

EDB/DBCP

(µg/L)

SVOCs (µg/L)

Pesticides (µg/L)

PCBs (µg/L)

Chlorinated Acids (mg/L)

Carbamates (mg/L)

Glyphosate (mg/L)

Unknown 2/29/2024 09:15 130 <0.050 <0.050 0.64 10 2.3 5.0 167 ND ND ND ND ND ND ND ND ND ND

USEPA Primary Maximum Contaminant Level NE 10 1.0 4.0 ---- ---- ---- ---- 0.2 ---- Varies 0.00005/0.0002 Varies Varies Varies Varies Varies 0.70

USEPA Secondary Maximum Contaminant Level1 20-2002 ---- ---- ---- 250 250 15 500 ---- 0.5 ---- ---- ---- ---- ---- ---- ---- ----

Well Depth

(ft. bgs)

Sample Date

Sample Time

Endothall (mg/L)

Diquat/Paraquat (mg/L)

Aluminum (mg/L)

Antimony (mg/L)

Arsenic (mg/L)

Barium (mg/L)

Beryllium (mg/L)

Cadmium (mg/L)

Calcium (mg/L)

Chromium (mg/L)

Copper (mg/L)

Iron (mg/L)

Lead (mg/L)

Manganese (mg/L)

Mercury (mg/L)

Nickel (mg/L)

Selenium (mg/L)

Silver (mg/L)

Unknown 2/29/2024 09:15 ND ND <0.01 <0.005 0.001 0.062 <0.001 <0.001 4.33 <0.001 0.001 0.136 <0.001 0.002 <0.0001 <0.001 0.018 <0.001

USEPA Primary Maximum Contaminant Level 0.10 0.02 ---- 0.006 0.010 2.0 0.004 0.005 NE 0.10 1.3 ---- 0.015 ---- 0.002 0.10 0.05 ----

USEPA Secondary Maximum Contaminant Level1 ---- ---- 0.20 ---- ---- ---- ---- ---- 502 ---- 1.0 0.30 ---- 0.05 ---- ---- ---- 0.10

Well Depth

(ft. bgs)

Sample Date

Sample Time

Sodium (mg/L)

Thallium (mg/L)

Zinc (mg/L)

Uranium (µg/L)

Gross Alpha (pCi/L)

Gross Beta (pCi/L)

Radium 226 (pCi/L)

Radium 228 (pCi/L) pH* (su)

Conductance* (µS/cm)

Temp.* (°F)

Dissolved Oxygen* (mg/L)

REDOX*

(mV)

Turbidity*

(NTU)

Hardness (as mg CaCO3)

Total Coliform

(CFU)

Unknown 2/29/2024 09:15 57.37 <0.001 0.035 7 9.4 3.2 0.5 <0.8 8.50 398 50.3 1.79 -221 NA 5.0 NA

USEPA Primary Maximum Contaminant Level NE 0.002 ---- 30 15 15 5.0 combined 226/228 ---- NE NE NE NE ---- ---- 0.00

USEPA Secondary Maximum Contaminant Level1 30-602 ---- 5.0 ---- ---- ---- ---- ---- 6.5 - 8.5 NE NE NE NE 1.0 <602 ----

Footnotes:

bgs – below ground surface.

CFU – colony forming units.

ft. – feet.

µg/L – micrograms per liter (ppb).

mg/L – milligrams per liter (ppm).

DBCP – 1,2-Dibromo-3-chloropropane.

EDB – ethylene dibromide.

MBAS – methylene blue active substances (foaming agents).

NE – not established by the USEPA.

pCi/L – picocuries per liter.

PCBs – polychlorinated biphenyls.

su – standard units.

µS/cm – micro-Siemens per centimeter.

mV – millivolts.

NA – not analyzed.

ND - none detected.

NTU – Nephelometric Turbidity Units.

TDS – total dissolved solids.

REDOX – reduction/oxidation potential.

SVOCs – semi-volatile organic compounds.

VOCs – volatile organic compounds.

Bold value indicates exceedence in Maximum Contaminant Level.

*Measured in the field during sample collection.

1Secondary MCLs are recommended levels and are not enforceable by the USEPA.

2Recommended value for drinking water.

APPENDIX C – PHOTOGRAPHIC DOCUMENTATION

BIA Former Sanostee Day School

Farmington, NM 87401 www.iinaba.com

Phone: (505) 327-1072

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 1

PHOTOGRAPHIC DOCUMENTATION OF SITE ACTIVITIES AND CONDITIONS

Photographed By: John R. Isham, CPG and Leotis Denetclaw (iiná bá, Inc.)

Photograph Period: November 20-21 and December 4, 2023 and March 5, 11, and April 3, 2024

Contract Owner: Bureau of Indian Affairs Branch of Environmental Management

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 2

Photograph 1: View looking southwest across Area 4 at GPR transects with boundary target flags as reference.

Photograph 2: View looking west at active GPR data collection.

Photograph 3: View of electromagnetometer being set up and calibrated prior to survey.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 3

Photograph 4: View looking south at electromagnetometer in flight during data collection.

Photograph 5: View of typical soil sample location marking with residual hole where samples were collected.

Photograph 6: View looking north during sub-meter surveying of surface remnants and features.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 4

Photograph 7: View of typical larger concrete remnant left following demolition activities at the school.

Photograph 8: View of typical concrete pier remnant left after modular structure demolition.

Photograph 9: View typical metal rebar remnant left after structure demolition.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 5

Photograph 10: View of typical metal pipe (sewer) left on ground after site demolition activities.

Photograph 11: View of in-place sewer cleanout along former roadway in housing area left after demolition.

Photograph 12: View looking west at remnant asphalt drive land with concrete curb and gutter.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 6

Photograph 13: View looking west at remnant asphalt parking lot with concrete curb and gutter.

Photograph 14: View of typical geophysical anomaly subsurface exploration using a mini-ex.

Photograph 15: View of remnants discovered at Anomaly 8-9.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 7

Photograph 16: View depicting typical anomaly exploration result of hard, compacted, dense undisturbed soils.

Photograph 17: View of exploration of a typical concrete pier left in place following demolition of modular structure.

Photograph 18: View of remnant concrete pier removed from subsurface to determine length and width.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 8

Photograph 22: View of area of excessive subsidence of soils from past excavation or removal of subsurface feature.

Photograph 23: View of illicit trash dumping inside school grounds from adjacent homesites containing demolition debris.

Photograph 24: View looking east at southern property fence line at illicit trash dumping.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 9

Photograph 25: View of frequent tire dumping on property from adjacent residential homesites.

Photograph 26: View looking north at open trench on school property with minor trash dumped.

Photograph 27: View of previously unidentified capped water supply well on school property.

BIA Former Sanostee Day School ASTM Phase III Report – Sanostee, New Mexico Page 10

Photograph 28: View of remnant Transite pipe fragment (minor) near former school building area.

Photograph 29: View of capped artesian well on school property used by local residents for livestock water.

Photograph 30: View of typical scrap metal items (fuel tank) discarded on school property from nearby residents.