BIA_Landfill_Inspection_Report_7-2022_0003.pdf

LANDFILL INSPECTION AND EVALUATION REPORT

33 BIA Landfills Across the Five Agencies Navajo Nation Indian Reservation, Arizona and New Mexico

July 2022

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.: 22-008-03 Contract No.: 140A0922Q0004

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION

TRANSPORTATION | INFORMATION TECHNOLOGY

2022 Landfill Inspection and Evaluation Report 33 BIA Landfills Across the Navajo Nation Indian Reservation

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

PURPOSE AND INTENT

LANDFILL INSPECTION REPORTS

Lukachukai School LF (N35-07) Many Farms HS LF #1 (N35-21) Many Farms HS LF #2 (N35-21) Many Farms HS LF #3 (N35-21) Nazlini Boarding School LF (N35-09) Rock Point Community School LF (N35-11) Black Mesa Community School LF (N35-11) Rough Rock Community School LF (N35-12) Jones Ranch School LF (N34-05) Crownpoint Community School LF (N34-23) Wingate Elementary School LF #1 (N34-20) Wingate Elementary School LF #2 & #3 (N34-20) Lake Valley School LF (N34-10) Torreon School LF (N34-18) Ojo Encino School LF (N34-13) Standing Rock School LF (N34-16) Chuska Boarding School LF (N36-03) Dilcon Boarding School LF (N36-06) Kinlichee Community School LF (N36-14) Pine Springs Day School LF (N36-18) Seba Dalkai Boarding School LF (N36-19) Aneth Community School LF (N32-02) Teec Nos Pos Community School LF (N32-10) Red Rock Day School LF (N32-07) Sanostee Day School LF (N32-09) Shiprock BIE HQ (North) LF (N32-01) Chilchinbeto Community School LF (#33-02) Dennehotso Boarding School LF (N33-04) Kaibeto Boarding School LF (N33-07) Old Navajo Mountain School LF (N33-11) New Navajo Mountain School LF (N33-11) New Shonto Boarding School LF (N33-16) Old Shonto Boarding School LF (N33-16)

APPENDIX A: FIGURES

Figure 1: Lukachukai School LF (N35-07) Figure 2: Many Farms HS LF #1 (N35-21) Figure 3: Many Farms HS LF #2 (N35-21) Figure 4: Many Farms HS LF #3 (N35-21) Figure 5: Nazlini Boarding School LF (N35-09) Figure 6: Rock Point Community School LF (N35-11) Figure 7: Black Mesa Community School LF (N35-11) Figure 8: Rough Rock Community School LF (N35-12) Figure 9: Jones Ranch School LF (N34-05) Figure 10: Crownpoint Community School LF (N34-23) Figure 11: Wingate Elementary School LF #1 (N34-20) Figure 12: Wingate Elementary School LF #2 & #3 (N34-20) Figure 13: Lake Valley School LF (N34-10) Figure 14: Torreon School LF (N34-18) Figure 15: Ojo Encino School LF (N34-13) Figure 16: Standing Rock School LF (N34-16) Figure 17: Chuska Boarding School LF (N36-03) Figure 18: Dilcon Boarding School LF (N36-06) Figure 19: Kinlichee Community School LF (N36-14) Figure 20: Pine Springs Day School LF (N36-18) Figure 21: Seba Dalkai Boarding School LF (N36-19) Figure 22: Aneth Community School LF (N32-02) Figure 23: Teec Nos Pos Community School LF (N32-10) Figure 24: Red Rock Day School LF (N32-07) Figure 25: Sanostee Day School LF (N32-09) Figure 26: Shiprock BIE HQ (North) LF (N32-01) Figure 27: Chilchinbeto Community School LF (#33-02) Figure 28: Dennehotso Boarding School LF (N33-04) Figure 29: Kaibeto Boarding School LF (N33-07) Figure 30: Old Navajo Mountain School LF (N33-11) Figure 31: New Navajo Mountain School LF (N33-11) Figure 32: New Shonto Boarding School LF (N33-16) Figure 33: Old Shonto Boarding School LF (N33-16)

APPENDIX B: INSPECTION FORMS

APPENDIX C: PHOTOGRAPHIC DOCUMENTATION OF CURRENT SITE CONDITIONS

Arizona, New Mexico, and Utah

EXECUTIVE SUMMARY

iiná bá, Inc., under Bureau of Indian Affairs (BIA) contract number 140A0922Q0004, has conducted site-specific inspections and has evaluated the current condition of 33 former BIA/BIE solid waste landfills across the Navajo Nation Indian Reservation in Arizona, New Mexico, and Utah. After performing data reduction, review, and evaluation from the performance of the subject site inspections, with further review and evaluation of the appropriate regulatory requirements for closed municipal solid waste landfills, a ranking of the seven (7) critical factors evaluated in order to determine if a landfill meets the acceptable closure criteria was prepared in the form of a color-coded Landfill Conditions Matrix Summary. The matrix is included on the following page of this summary. Conditions shown in red are considered as completely absent or deficient, requiring immediate action, with conditions shown in yellow as lacking or needing attention in the near future, and finally, conditions shown in green are currently acceptable or need no further action at this time.

Based on these results, and considering the frequency of each condition across the entire 33 landfills, the following conditions ranked the most significant or most frequent as being deficient (in order of decreasing frequency):

1. Lack of or absence of adequate signate.

2. Lack of or insufficient condition of security fencing.

3. Lack of or insufficient condition of vegetation.

4. Illicit or excessive dumping after landfill closure.

Based on these results, and considering the freque3ncy of each condition across the entire 33 landfills, the conditions that ranked as needing attention in the near future but are not currently a serious condition were (in order of decreasing frequency):

1. Erosional features through cover soils.

2. Lack of or insufficient cover vegetation.

Finally, it should be noted that several of the landfills are currently in a condition that immediately threatens human health or the environment due to extreme conditions of illicit dumping of surface debris; lack of proper or any cover soil during closure, or currently impacting sensitive receptors. These locations require immediate corrective actions, which include (in order of decreasing severity:

1. Old Shonto Landfill

2. Shiprock Landfill

3. Rock Point Landfill

4. Pine Springs Landfill

5. Kaibeto Landfill

6. New Shonto Landfill

It should be noted that other landfills are also in need of attention with regards to illicit dumping, but are currently on a scale many times smaller than these sites that should be addressed in the near future to be protective of human health and the environment.

This condition appears to be the most prevalent issue with regards to these closed landfills that is also probably one of the hardest conditions to monitor, prevent, and overcome. It has been recognized that the one factor that could potentially help reduce this condition is to have a readily accessible solid waste transfer station located in each Chapter community affected by these landfill locations. Giving residents the ability to dispose of their solid waste rather than tossing it out on reservation lands could be a viable option to reducing this occurrence.

LANDFILL CONDITIONS MATRIX SUMMARY

Landfill Fencing Signage Dumping Erosion Cover Thickness

Vegetation Receptors

CHINLE AGENCY

Lukachukai Many Farms #1 Many Farms #2 Many Farms #3 Nazlini Rock Point Black Mesa Rough Rock

EASTERN NAVAJO AGENCY

Jones Ranch Crownpoint Wingate #1 Wingate #2 & #3 Lake Valley Torreon Ojo Encino Standing Rock

FORT DEFIANCE AGENCY

Chuska Dilcon Kinlichee Pine Springs Seba Dalkai

SHIPROCK AGENCY

Aneth Teec Nos Pos Red Rock Sanostee Shiprock

WESTERN NAVAJO AGENCY

Chilchinbeto Dennehotso Kaibeto Old Navajo Mtn.

New Navajo Mtn.

New Shonto Old Shonto

Conditions Requiring Immediate Action Conditions Requiring Action in the near Future Conditions Requiring No Further Action at this Time

Arizona, New Mexico, and Utah

INTRODUCTION

iiná bá, Inc., under Bureau of Indian Affairs (BIA) contract number 140A0922Q0004, was contracted to perform site-specific inspection and evaluation of the current condition of 33 former BIA/BIE solid waste landfills across the Navajo Nation Indian Reservation in Arizona, New Mexico, and Utah (see Site Layout Maps in Appendix A). After performing data reduction, review, and evaluation from the performance of the subject site inspections, with further review and evaluation of the appropriate regulatory requirements for closed municipal solid waste landfills, an assessment report was to be prepared summarizing the current documented conditions against the seven (7) critical post-closure care evaluation criteria to determine what follow-up recommendations are appropriate for each landfill area. The following are the seven (7) evaluation criterion used for this inspection:

1. Fencing.

2. Signage.

3. Dumping (illicit).

4. Erosion.

5. Cover Soil Thickness.

6. Vegetation.

7. Sensitive Receptors.

Walking pedestrian surveys were conducted at each landfill with the collection of representative photographs depicting current site conditions with regards to the above-referenced criterion. The findings from these inspections were recorded on Landfill Inspection and Evaluation Forms (Appendix B) with Photographic Documentation of Current Site Conditions recorded on records contained within Appendix C. All work was performed in accordance with the Technical and Cost Proposal for Environmental Services, dated December 29, 2021.

PURPOSE AND INTENT

The purpose of this inspection and evaluation effort is to document current site conditions at the subject landfills in order to determine if they are in compliance with the necessary post-closure care requirements for closed municipal solid waste landfills to be protective of human health and the environment. Solid waste rules require periodic monitoring and inspection in an effort to identify any of the above-referenced conditions that may need further attention following landfill closure. These conditions are expected to be maintained accordingly for a period of 30 years following official landfill closure. Given the suspected closure date of most of these landfills in the early to mid-1990’s with their 30-year post-closure care period nearing completion, those landfills which do not currently meet the proper closure conditions must be corrected such that their 30-year monitoring and maintenance period be extended until these conditions are fully met. Obviously, those landfills which are deemed an immediate threat to human health or the environment must be remedied in order to meet the post-closure care requirements.

All documentation is summarized and listed by Agency in alphabetical order (Chinle, Eastern Navajo, Fort Defiance, Shiprock, and Western Navajo) within the reports, Figures, inspection forms, and photographic documentation.

WaterWastewaterSolid WasteRoadsStormwaterSubdivisionsSurveyingGIS

HydrologyAir QualityESASoil InvestigationsSPCCWater RightsLUST

PREPARED FOR:

BUREAU OF INDIAN AFFAIRS—NAVAJO REGION OFFICE

BRANCH OF ENVIRONMENTAL MANAGEMENT

P. O. BOX 1060

GALLUP, NM 87305-1060

SCALE: 1 INCH ≅ 70 FEET

iiná bá Project No.: 22-008-03

BIA Contract No.: 140A0922Q0004

N

FIGURE 1: SITE LAYOUT MAP

FORMER LUKACHUKAI SCHOOL LANDFILL N37-07

BUREAU OF INDIAN AFFAIRS – LANDFILL INSPECTIONS

LUKACHUKAI, APACHE COUNTY, NEW MEXICO

EXPLANATION

SOURCE: GOOGLE EARTH IMAGE

NORTH SAR AREA

WESTERN SAR

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

SB-

AB-3

AB-4

BLDG 319

AB-1

AB-2

LANDFILL BOUNDARY

SCALE: 1 INCH ≅ 90 FEET

FIGURE 2: SITE LAYOUT MAP

FORMER MANY FARMS SCHOOL LANDFILL #1 N35-21

MANY FARMS, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 45 FEET

FIGURE 3: SITE LAYOUT MAP

FORMER MANY FARMS SCHOOL LANDFILL #2 N35-21

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 82 FEET

FIGURE 4: SITE LAYOUT MAP

FORMER MANY FARMS SCHOOL LANDFILL #3 N35-21

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 82 FEET

FIGURE 5: SITE LAYOUT MAP

FORMER NAZLINI SCHOOL LANDFILL #3 N35-09

NAZLINI, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 140 FEET

FIGURE 6: SITE LAYOUT MAP

ACTIVE ROCK POINT LANDFILL N35-11

ROCK POINT, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

LIMITS OF STUDY AREA

SCALE: 1 INCH ≅ 120 FEET

FIGURE 7: SITE LAYOUT MAP

FORMER BLACK MESA SCHOOL LANDFILL N35-11

BLACK MESA, NAVAJO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 210 FEET

FIGURE 8: SITE LAYOUT MAP

FORMER ROUGH ROCK LANDFILL N35-12

ROUGH ROCK, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 70 FEET

FIGURE 9: SITE LAYOUT MAP

FORMER JONES RANCH SCHOOL LANDFILL N34-05

CHIL-CHIL TAH, MCKINLEY COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 300 FEET

FIGURE 10: SITE LAYOUT MAP

FORMER CROWNPOINT SCHOOL LANDFILL N34-23

CROWNPOINT, MCKINLEY COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 92 FEET

FIGURE 11: SITE LAYOUT MAP

FORMER FT. WINGATE SCHOOL LANDFILL #1 N34-20

FT. WINGATE, MCKINLEY COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 107 FEET

FIGURE 12: SITE LAYOUT MAP

FORMER FT. WINGATE SCHOOL LANDFILL #2 & #3 N34-20

FT. WINGATE, MCKINLEY COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 65 FEET

FIGURE 13: SITE LAYOUT MAP

FORMER LAKE VALLEY SCHOOL LANDFILL N36-10

LAKE VALLEY, SAN JUAN COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 34 FEET

FIGURE 14: SITE LAYOUT MAP

FORMER TORREON LANDFILL N34-18

TORREON, SANDOVAL COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 30 FEET

FIGURE 15: SITE LAYOUT MAP

FORMER OJO ENCINO LANDFILL N34-13

OJO ENCINO, SAN JUAN COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 60 FEET

FIGURE 16: SITE LAYOUT MAP

FORMER STANDING ROCK LANDFILL N34-16

STANDING ROCK, MCKINLEY COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 58 FEET

FIGURE 17: SITE LAYOUT MAP

FORMER CHUSKA #1 AND #2 LANDFILL N36-03

TOHATCHI, MCKINLEY COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

AB-2

LANDFILL BOUNDARY

#1

#2

FIGURE 18: SITE LAYOUT MAP

FORMER DILKON SCHOOL LANDFILL N36-06

DILKON, NAVAJO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

FIGURE 19: SITE LAYOUT MAP

FORMER KINLICHEE SCHOOL LANDFILL N36-14

KINLICHEE, APACHEE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 65 FEET

FIGURE 20: SITE LAYOUT MAP

FORMER PINE SPRINGS LANDFILL N36-18

PINE SPRINGS, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 117 FEET

FIGURE 21: SITE LAYOUT MAP

FORMER SEBA DALKAI LANDFILL N36-19

SEBA DALKAI, NAVAJO COUNTYARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 100 FEET

FIGURE 2: SITE LAYOUT MAP

FORMER ANETH SCHOOL LANDFILL N32-02

ANETH, SAN JUAN COUNTY, UTAH

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 72 FEET

FIGURE 23: SITE LAYOUT MAP

FORMER TEEC NOS POS LANDFILL N32-10

TEEC NOS POS, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 88 FEET

FIGURE 24: SITE LAYOUT MAP

FORMER RED ROCK LANDFILL N32-07

RED VALLEY, APACHE COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

LIMITS OF STUDY AREA

SCALE: 1 INCH ≅ 245 FEET

FIGURE 25: SITE LAYOUT MAP

FORMER SANOSTEE LANDFILL N32-09

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 245 FEET

FIGURE 26: SITE LAYOUT MAP

FORMER SHIPROCK NORTH LANDFILL N32-01

SHIPROCK, SAN JUAN COUNTY, NEW MEXICO

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

FIGURE 27: SITE LAYOUT MAP

FORMER CHILCHINBETO SCHOOL LANDFILL N32-02

CHILCHINBETO, NAVAJO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 132 FEET

FIGURE 28: SITE LAYOUT MAP

FORMER DENNEHOTSO LANDFILL N33-04

DENNEHOTSO, NAVAJO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

FIGURE 29: SITE LAYOUT MAP

FORMER KAIBETO SCHOOL LANDFILL N33-07

KAIBETO, COCONINO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 48 FEET

FIGURE 30: SITE LAYOUT MAP

FORMER OLD NAVAJO MOUNTAIN LANDFILL N33-11

NAVAJO MOUNTAIN, SAN JUAN COUNTY, UTAH

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 120 FEET

FIGURE 31: SITE LAYOUT MAP

FORMER NEW NAVAJO MOUNTAIN LANDFILL N33-11

NAVAJO MOUNTAIN, SAN JUAN COUNTY, UTAH

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

SCALE: 1 INCH ≅ 160 FEET

FIGURE 32: SITE LAYOUT MAP

FORMER NEW SHONTO LANDFILL N33-16

SHONTO, NAVAJO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

FIGURE 33: SITE LAYOUT MAP

FORMER OLD SHONTO LANDFILL N33-16

SHONTO, NAVAJO COUNTY, ARIZONA

LUST NAV #120

LUST NAV # 046

LUST NAV #356

FIRE/EMS

AB-1

WaterWastewaterSolid WasteRoadsStormwaterSubdivisionsSurveyingGIS

HydrologyAir QualityESASoil InvestigationsSPCCWater RightsLUST

PREPARED FOR:

BUREAU OF INDIAN AFFAIRS—NAVAJO REGION OFFICE

BRANCH OF ENVIRONMENTAL MANAGEMENT

P. O. BOX 1060

GALLUP, NM 87305-1060

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Black Mesa Community School Landfill Landfill No.: N35-11 Location: Black Mesa, Apache County, Arizona Inspection Date: Monday, June 13, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 72° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office, the subject landfill is deemed “active”. Since landfilling on the Navajo Nation has been discontinued, this active status only means that the BIA records indicate the site has not gone through formal closure procedures. The basic principles for landfill closure include:

1. Provide viable alternative facility or a collection system for waste disposal.

2. Inform and educate the public on the need to close the landfill.

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

7. Maintain adequate drainage of surface water and mitigate any erosion that occurs immediately.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

Site Location/Layout:

The general layout of the subject landfill site is shown on the attached Figure 7 in Appendix A.

Previous Inspection Findings and Recommendations:

The previous study performed by others (2005/2014) indicated the following:

1. The former landfill reportedly contained two (2) cells; one active measuring 235 feet by 20 feet by 12 feet deep and another measuring 50 feet by 11 feet by 3 feet deep, but was empty.

2. The area of the landfill site is reportedly 1.17 acres.

3. The landfill is fenced but without any signage.

4. There is an active cell measuring 170 feet long by 10 feet wide, and 4 feet high containing household trash, appliances, metal, and burned debris.

5. The landfill was left unsecured in order to prevent illicit dumping, but was not manned.

6. Areas within the landfill contained barren soils that was stated as a “traffic circle” for patrons.

7. A closed cell was reportedly acceptable with no subsidence, potholing, or erosion.

8. The remaining cell was recommended for closure with an evapotranspiration or other alternative cover and a locked gate installed to prevent post-closure dumping. Adequate signage was also recommended in additional to providing alternative receptacles or dumpsters.

Current Inspection Findings:

1. There has been illicit dumping of waste outside the fenced limits of the landfill.

2. Portions of the landfill fencing have been cut or removed to facilitate entry into the landfill.

3. Considerable wastes are present within the landfill area that are not covered at all by soil.

4. Evidence of subsidence and solution cavities are notable on the closed, covered portion of the landfill.

5. There is no signage located anywhere near this site.

Current Inspection Recommendations:

1. The use of this landfill should be discontinued immediately and plans made to properly close this location in accordance with applicable regulations.

2. The security fencing should be repaired and signage installed on all four side of the landfill indicating “No Trespassing or Dumping Allowed”.

3. The debris dumped outside ethe landfill should be gathered and placed inside as part of closure activities.

4. If receptacles are to be considered as an alternative, they must be done as part of a formal transfer station installation that is also fenced and maned daily during use.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of Current Site Conditions.

Landfill Inspection and Evaluation Report

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Lukachukai School Landfill No.: N35-07 Location: Lukachukai, Apache County, Arizona Inspection Date: Thursday, June 9, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 62° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill was closed in accordance with 40 CFR 241. The basic principles for landfill closure include:

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 1 in Appendix A.

The previous study performed by others (2014) indicated the following:

1. The former landfill contained five (5) waste cells.

2. The landfill contained adequate clean soil cover, minor erosional features, and negligible surface waste.

3. The landfill limits were not discernable nor fenced (secured).

4. Waste piles were recommended for removal from the northeast corner of the cemetery and have them properly disposed of.

Current Inspection Findings:

1. Several erosional features are present that cut into the cover soil by as much as one (1) foot or more.

2. No exposed buried wastes are present; cover soil thickness remains adequate.

3. Minimal surface debris was observed from illicit dumping after the landfill was closed. None appeared to be recent.

4. The landfill area is not fenced for security nor any signage.

5. Abundant, mature shrub vegetation was present, but minimal to no grasses.

Current Inspection Recommendations:

1. Remove any large areas of surficial debris for offsite disposal at a permitted solid waste facility.

2. Dress up (fill) any of the larger depressions or erosional features with native fill to prevent further undercutting into the cover soils to prevent buried waste exposure and re-seed.

3. If fencing the area is not feasible, place signage on all four (4) sides of the area indicating “No Trespassing or

Dumping Allowed”.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Many Farms High School Landfill #1 Landfill No.: N35-21 Location: Many Farms, Apache County, Arizona Inspection Date: Thursday, June 9, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 68° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 2 in Appendix A.

1. The former landfill began between 1965 and 1968.

2. The landfill was closed in 1990 under no standards.

3. The landfill contained either two (2) or three (3) waste cells spaced eight (8) to 10 feet apart.

4. The landfill had good vegetative cover.

5. The immediate landfill area is not fenced.

6. Some surface dumping was documented, but was not considered recent.

7. No signage existed at the site of the landfill.

8. The construction debris near the landfill needs to be disposed of properly.

9. A fence should be installed around the immediate landfill property.

Current Inspection Findings:

1. No security fencing is installed around the immediate landfill area.

2. No warning signage is installed around the immediate landfill area.

3. Cover soil is adequate and is sustaining mature shrubs (sage) with minimal grasses (stressed).

4. There is evidence of animal (livestock) and human activity within the landfill area.

5. There is minimal illicit surface dumping of debris on the surface of the landfill (not recent);

6. There is physical accessibility (two-track road) bisecting the landfill.

7. There is minimal surface erosion occurring as a result of some barren patches of cover soil.

Current Inspection Recommendations:

1. The immediate landfill area should be fenced to prevent further livestock access that can damage healthy vegetation and to prevent any illicit dumping.

2. Signage should be installed on all four (4) sides of the landfill area indicating “No Trespassing or Dumping Allowed”.

3. The abundant demolition debris dumped on other areas near the lagoons on campus should be removed and properly disposed of at a permitted off-site facility.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Many Farms High School Landfill #2 Landfill No.: N35-21 Location: Many Farms, Apache County, Arizona Inspection Date: Thursday, July 30, 2022 Inspectors: John R. Isham, CPG Weather: Cloudy, breezy, 82° F, rain

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 3 in Appendix A.

1. The former landfill began between 1965 and 1968.

2. The landfill was closed in 1990 under no standards.

3. The landfill contained two (2) cells on a one (1)-acre tract.

4. The landfill had no fenced boundaries.

5. Two (2) large dirt mounds and surface debris were noted onsite.

6. A shallow drainage feature is encroaching on the site.

7. No trash was visible on the site.

Current Inspection Findings:

1. No security fencing is installed around the immediate landfill area.

2. No illicit dumping activities were noted.

3. No warning signage is installed around the immediate landfill area.

4. The entire landfill area is depressed with lack of positive drainage and is devoid of vegetation.

5. There is evidence of recent human access into the landfill area.

Current Inspection Recommendations:

1. The immediate landfill area should be fenced to prevent further human (or animal) access.

2. Signage should be installed on all four (4) sides of the landfill area indicating “No Trespassing or Dumping

Allowed”.

3. The landfill area drainage should be restored to a positive drainage condition and re-seeded with a mixture appropriate for the region.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Many Farms High School Landfill #3 Landfill No.: N35-21 Location: Many Farms, Apache County, Arizona Inspection Date: Thursday, June 9, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 68° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 4 in Appendix A.

1. The former landfill began between 1965 and 1968.

2. The landfill was closed when the construction of the athletic field complex began.

3. There is no data on the size or number of waste cells in this landfill area.

4. The area did not warrant any further investigation or maintenance.

Current Inspection Findings:

1. The athletic field is still in use at this location.

2. No visual evidence suggesting issues regarding the presence of the landfill (e.g., ground subsidence, stressed vegetation due to methane gas, exposed wastes, etc.) were observed.

Current Inspection Recommendations:

1. The sports complex grounds and structures should be routinely inspected for any issues that may relate to the former landfill area (structural cracks or separating pavement, unusual odors, subsiding ground, stressed vegetation not due to drought conditions).

2. Any suspected deficiencies should be immediately investigated and remedied.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Nazlini Boarding School Landfill Landfill No.: N35-09 Location: Nazlini, Apache County, Arizona Inspection Date: Monday, June 13, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 68° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 5 in Appendix A.

1. The former landfill was an open cell with a 0.46-acre footprint.

2. The landfill contained adequate clean soil cover, with minor erosional features, and negligible surface waste.

3. Continue to maintain the fence blocking access to the site.

Current Inspection Findings:

1. A BLM-style fence blocks access to the entrance road leading to the landfill off Navajo Route 21.

2. The landfill is not immediately fenced with a security fence and any signage is badly weathered and illegible.

3. Some differential settlement of cover soils is present resulting in slight erosional channels and surface cracking.

4. Minor surface debris is present that may have not been fully buried upon closure.

5. Vegetative cover is sparse and struggling to maintain growth.

Current Inspection Recommendations:

1. If the fencing along Navajo Route 21 is maintained, immediate fencing around the landfill area is not needed.

2. Signage on all four (4) sides of the landfill area should be installed indicating “No Trespassing or Dumping

Allowed”.

3. Continue to monitor site conditions on a no more than an annual basis.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Rock Point Community School Landfill Landfill No.: N35-12 Location: Rock Point, Apache County, Arizona Inspection Date: Monday, June 13, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 82° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office, the subject landfill is deemed “active”. Since landfilling on the Navajo Nation has been discontinued, this active status only means that the BIA records indicate the site has not gone through formal closure procedures. The basic principles for landfill closure include:

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 6 in Appendix A.

1. The former landfill contained four (4) waste cells.

2. The area of the landfill site is reportedly 3.12 acres.

3. The landfill was broken down into a lower portion of former “active” cells and an upper portion of surface dumping.

4. None of the landfill areas have security fencing or signage.

5. Some waste was being carried downslope into a nearby drainage feature.

6. The upper surface dumping was spread over a 6-acre area.

7. There is between 5,000 and 8,000 cubic yards of uncovered waste at this site; and,

8. All wastes from the lower and upper portions need to be gathered and transported off-site for disposal at a permitted facility.

Current Inspection Findings:

1. The landfill remains without a perimeter security fence on ether portion as well as appropriate signage.

2. Significant surface dumping is evident across all portions of the landfill site, with very little evidence of burial that is less than adequate.

3. Some debris has entered the nearby drainage feature and would be in direct contract with stormwater.

4. Waste is now scattered off the top of the upper portion of the landfill area down the side slopes due to wind and other transport mechanisms that is now affecting lands not associated with the landfill.

5. The site can still be access from Navajo Route 35 with a truck (2WD and 4WD) that can result in further illicit dumping (no recent dumping could be readily identified).

Current Inspection Recommendations:

1. Until remedial actions can be performed, perimeter fencing is recommended as not only a measure of security but a means of stopping the spread of debris from the site.

2. Signage on all four (4) sides of the landfill area should be installed indicating “No Trespassing or Dumping Allowed”.

3. If there is identifiable space or room on the upper level of the landfill, direct bury the surface debris and cover with the appropriate thickness of cover soil with positive slope for drainage.

4. If not applicable, all wastes should be removed from the subject site (especially from the drainage feature) and transported off-site to a permitted facility able to accept solid waste.

5. Continue to monitor site conditions on a no more than an annual basis until remedial actions are performed.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Chinle Agency Landfill Name: Rough Rock Community School Landfill Landfill No.: N35-12 Location: Rough Rock, Navajo County, Arizona Inspection Date: Monday, June 13, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 82° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill was closed in accordance with 40 CFR 258.60(a). The basic principles for landfill closure include:

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 8 in Appendix A.

1. The date of landfill construction is unknown.

2. The former landfill was closed in September 1991 with a compacted clay cover.

3. The landfill was in marginal condition with areas of subsidence, some exposed waste, minimal vegetation, and some surface dumping.

Current Inspection Findings:

1. The landfill remains without a perimeter security fence as well as appropriate signage.

2. Access to the landfill is restricted by being separated by a deep arroyo from the former access road.

3. There is illicit dumping of wastes outside the limits of the former landfill as well as within the limits of the former landfill, likely when there was still reasonable access.

4. There is evidence of waste subsidence that has caused depressions in the final cover.

5. Some subsidence is significant enough to expose some waste

Current Inspection Recommendations:

1. A perimeter fence with signage should be installed unless it can be confirmed that no access to the site can be achieved from directions on the landfill side of the arroyo.

2. Signage on all four (4) sides of the landfill area should be installed indicating “No Trespassing or Dumping Allowed”.

3. All surface wastes dumped outside and inside the limits of the landfill area should be removed and disposed of off-site at a permitted facility.

4. Areas with subsidence should be filled with native soils to restore positive drainage.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Eastern Agency Landfill Name: Chil-Chil Tah/Jones Ranch School Landfill Landfill No.: N34-04 Location: Chil-Chiltah, McKinley County, New Mexico Inspection Date: Tuesday, June 7, 2022 Inspectors: John R. Isham, CPG & Lance Aspaas Weather: Sunny, breezy, 72° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 9 in Appendix A.

1. The former landfill was constructed during the late 1950s and early 1960’s.

2. The former landfill was closed prior to 1993.

3. There was reportedly one (1) closed trench at the site.

4. Drawings indicated the landfill area was approximately 0.75 acres in size.

5. The landfill was in marginal condition with thin cover, areas of subsidence, potholes, and lacked fencing or gates around the boundary.

6. Minimal surface debris of green waste was observed dumped on the surface of the landfill.

7. Increase cover soil thickness and backfill potholes and areas of subsidence.

8. Fence and gate the landfill boundaries to prevent access and install signs prohibiting dumping.

Current Inspection Findings:

1. The landfill was secured with 8-foot fencing that connected to the perimeter fencing of the Jones Ranch School.

2. Access to the landfill was not available as the school was closed with gates locked that were the only access routes into the landfill area from within the campus.

3. The landfill area appeared to display a depressed surface with only some green waste dumped on the surface after closure (not recent).

4. There were no signs on the fencing.

Current Inspection Recommendations:

1. Signage should be installed on all four (4) side of the landfill area indicating “No Trespassing or Dumping Allowed”.

2. Should there still be areas of subsidence and potholing, backfill and cover these areas to prevent further waste subsidence that could lead to exposing wastes to the public or the environment.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Eastern Agency Landfill Name: Crownpoint Community School Landfill Landfill No.: N34-23 Location: Crownpoint, McKinley County, New Mexico Inspection Date: Tuesday, June 7, 2022 Inspectors: John R. Isham, CPG & Lance Aspaas Weather: Sunny, breezy, 72° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 10 in Appendix A.

1. The northern area (#1) of the landfill was closed prior to 1992.

2. This area of the landfill reportedly have eight (8) cells.

3. The southern (#2) area of the landfill was closed in 1995.

4. This area of the landfill reportedly had two (2) active cells.

5. The landfill areas are in marginal condition with major subsidence in both sections.

6. Vegetation is insufficient to prevent erosion of the soil cover.

7. Implement a Rehabilitation Plan for area #1 with the proper disposal of dumped wastes, recontour and revegetate the surface of the landfills.

Current Inspection Findings:

1. The landfill areas were secured by fencing and a locked gate. However, current signage is illegible and there is a section of downed fencing with tire tracks indicating unwanted access.

2. Current vegetation is sparse and also stressed (drought).

3. Significant settlement in areas due to waste subsidence from water infiltration.

4. Potholes are present from surface water infiltration into waste areas.

5. Areas of illicit dumping of debris present in the northern area of the landfill.

6. Entire landfill area (mostly northern) is very uneven and undulating making stormwater drainage difficult.

Current Inspection Recommendations:

1. Legible should be installed on all four (4) side of the landfill area indicating “No Trespassing or Dumping Allowed”.

2. Areas of downed or cut fencing should be secured.

3. The surface of the landfill should be restructured to achieve positive drainage from the inside outward and new vegetation established.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Bureau of Indian Affairs Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Eastern Agency Landfill Name: Lake Valley School Landfill Landfill No.: N34-10 Location: Lake Valley, San Juan County, New Mexico Inspection Date: Monday, June 7, 2022 Inspectors: John R. Isham, CPG & Lance Aspaas Weather: Sunny, breezy, 60° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 13 in Appendix A.

1. The landfill was constructed in 1963 when the former boarding school was constructed.

2. BIA records indicated the landfill had six (6) trenches that were closed in June of 1993.

3. The trenches were reportedly covered with two (2) feet of compacted soil.

4. The landfill was found to be in poor condition near an encroaching arroyo, with exposed surface waste, widespread subsidence, and evidence of waste being transported downstream.

5. It was recommended that the remaining waste be transported to a permitting landfill to eliminate the encroaching arroyo.

Current Inspection Findings:

1. There is no security fencing or signage at this landfill location.

2. There were minor occurrences of surface debris (metal) scattered across the area.

3. Significant portions of the landfill area are void of vegetation (barren).

4. Areas of surface erosion and channeling were observed immediately adjacent to an arroyo, with exposed metal debris.

5. Areas of significant cover soil subsidence from waste compaction of over a foot or more, possibly able to expose buried waste.

Current Inspection Recommendations:

1. The landfill area should be fenced on all sides for security and to prevent further illicit dumping.

2. Appropriate signage should be placed on all four (4) sides of the landfill area indicating “No Trespassing or

Dumping Allowed”.

3. Areas of significant subsidence and channeling (erosion) should be repaired with additional cover soil, stabilized with appropriate BMPs and re-seeded with a mixture of seed applicable to the region.

See Appendix B for Landfill Inspection and Evaluation Forms and Appendix C for Photographic documentation of

Arizona, New Mexico, and Utah Navajo Nation Contract No.: 140A0922Q0004 iiná bá, Inc. Project No.: 22-008-03

BIA Agency: Eastern Agency Landfill Name: Ojo Encino School Landfill Landfill No.: N34-13 Location: Ojo Encino, Sandoval County, New Mexico Inspection Date: Wednesday, June 8, 2022 Inspectors: John R. Isham, CPG Weather: Sunny, breezy, 65° F, dry

Regulatory Framework:

According to documentation provided by the Bureau of Indian Affairs (BIA), Navajo Region Office), the subject landfill

3. Close access to the site (fence and gate site must be maintained.

4. Place signs to notify the public that the facility is closed (should specify appropriate provisions or penalties against trespassing or dumping).

5. Enforce closure of the site as appropriate.

6. Place 24 inches of a clay-rich soil over compacted waste with 12 inches of soil to protect against erosion, plant roots, vehicular traffic, and a final vegetative layer of six (6) inches is recommended.

8. Post-closure monitoring and maintenance to continue for 30 years after closure on at least an annual basis.

The general layout of the subject landfill site is shown on the attached Figure 15 in Appendix A.

1. The landfill construction date is unknown but was never formally withdrawn for this purpose.

2. The landfill was reportedly closed in 1991.

3. It is presumed to have an administrative cover since the landfill pre-dates engineered covers.

4. The landfill was later re-opened by the BIA with four (4) trenches utilized until later closed in 1995.

5. Two (2) trenches were reportedly active in 1997, which were…