Phase_I_ESA-Many_Farms_0001.pdf

Phase I Environmental Site Assessment

Many Farms High School Buildings 1369, 1161 and Boiler Room and Vacant Land Loop Drive and Lake View Drive Many Farms, Arizona 86538

November 22, 2022

Phase I Environmental Site Assessment Many Farms High School Buildings 1369, 1161 and Boiler Room and Vacant Land Loop Drive and Lake View Drive

Page i

Site: Many Farms High School Buildings 1369, 1161 and

Boiler Room and Vacant Land Loop Drive and Lake View Drive, Many Farms, Arizona 86538

User: Seven Generations Architecture & Engineering 600 East Michigan Avenue, Suite B Kalamazoo, Michigan 49007

Site Reconnaissance Date: September 28, 2022 and November 15, 2022

Report Date: October 15, 2022

Report Prepared By:

Christie Pulvino Senior Project Manager

I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in § 312.10 of 40 C.F.R. § 312.

I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 C.F.R Part 312.

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Page ii

TABLE OF CONTENTS

1. SUMMARY

1.1. Findings and Conclusions Summary

2.1. Purpose

2.2. Scope of Services

2.3. Assumptions

2.4. Limitations and Exceptions

2.5. Special Terms and Conditions

2.6. User Reliance

2.7. Data Gap Summary

3. SITE DESCRIPTION

3.1. Location and Legal Description

3.2. Site and Vicinity General Characteristics

3.3. Current Site Use

3.4. Descriptions of Site Improvements

3.5. Current Uses of Adjoining Properties

4. USER PROVIDED INFORMATION

4.1. Title Records

4.2. Environmental Liens or Activity and Use Limitations

4.3. Specialized Knowledge

4.4. Commonly Known or Reasonably Ascertainable Information

4.5. Valuation Reduction for Environmental Issues

4.6. Owner, Property Manager, and Occupant Information

4.7. Reason for Performing Phase I

4.8. Other User Provided Information

5. RECORDS REVIEW

5.1. Standard Environmental Record Sources

5.2. Additional Environmental Record Sources

5.3. Physical Setting Sources(s)

5.3.1. Topography

5.3.2. Geology

5.3.3. Soils

5.3.4. Hydrogeology

5.4. Historical Use Information on the Site and Adjacent Properties

5.5. Review of Prior Environmental Reports

6. SITE RECONNAISSANCE

6.1. Methodology and Limiting Conditions

6.2. General Site Setting and Observations

7. INTERVIEWS

7.1. Interview with the Owner

7.2. Interview with the User

7.3. Interview with Site Manager

7.4. Interview with Occupants or Operators

7.5. Interview with Past Owner, Occupants, or Operators

7.6. Interview with State and/or Local Government Officials

8. ADDITIONAL SERVICES

9. FINDINGS, OPINIONS, AND CONCLUSIONS

10. DEVIATIONS

11. REFERENCES

12. QUALIFICATIONS OF ENVIRONMENTAL PROFESSIONAL

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Page iii

List of Attachments:

Tab 1: Figure and Photographs:

Figure 1 Site Diagram Photo 1 through 2 Site Photographs

Tab 2: Environmental Database Report Physical Setting Report

Tab 3: Historical Aerial Photographs

Historical Topographic Maps Historical Fire Insurance Maps Historical City Directory Listings

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1. SUMMARY

1.1. Findings and Conclusions Summary

Arc Environmental has completed this Phase I Environmental Site Assessment (ESA) in accordance with the American Society for Testing and Materials (ASTM) Standard E1527-21 (the ASTM Standard). This Phase I ESA has been performed by the Environmental Professional or conducted under the supervision or responsible charge of the named Environmental Professional.

Any exceptions to or deletions from this practice are described in Section 2 of this report. Data gaps are described in Section 2.7 of this report.

This assessment has revealed no evidence of recognized environmental conditions (RECs) in connection with Many Farms High School Buildings 1369, 1161 and the boiler room and vacant land addressed as Loop Drive and Lake View Drive, Many Farms, Arizona 86538 (Site).

2. INTRODUCTION

2.1. Purpose

The goal of the processes established by ASTM Standard E1527-21 is to identify recognized environmental conditions (RECs), including controlled recognized environmental conditions (CRECs), and historical recognized environmental conditions (HRECs). RECs are defined by the ASTM Standard as “(1) the presence of hazardous sub- stances or petroleum products in, on, or at the subject property due to a release to the environment; (2) the likely presence of hazardous substances or petroleum products in, on, or at the subject property due to a release or likely release to the environment; or (3) the presence of hazardous substances or petroleum products in, on, or at the subject property under conditions that pose a material threat of a future release to the environment. A de minimis condition is not a recognized environmental condition.”

CRECs are defined by the ASTM Standard as a “recognized environmental condition affecting the subject property that has been addressed to the satisfaction of the applicable regulatory authority or authorities with hazardous substances or petroleum products allowed to remain in place subject to implementation of required controls.”

HRECs are defined by the ASTM Standard as “a previous release of hazardous substances or petroleum products affecting the subject property that has been addressed to the satisfaction of the applicable regulatory authority or authorities and meeting unrestricted use criteria established by the applicable regulatory authority or authorities without subjecting the subject property to any controls.”

The ASTM Standard establishes a customary practice for completing an environmental site assessment of a parcel of commercial real estate with respect to the range of contaminants within the scope of CERCLA and petroleum products. As such, this report is intended to permit the user to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations on CERCLA liability (hereinafter, the

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"landowner liability protections" or "LLPs"). This report satisfies “all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice ... as provided by the ASTM Standard.” Controlled substances are not included within the scope of this standard.

2.2. Scope of Services

This Phase I ESA was conducted in accordance with ASTM Standard E1527-21, consistent with a level of care and skill ordinarily practiced by the environmental consulting profession currently providing similar services under similar circumstances. Significant additions, deletions, or exceptions to ASTM Standard E1527-21 are noted below or in the corresponding sections of this report. The scope of this assessment includes an evaluation of the following:

Information referenced in environmental agency databases and local environmental records within the approximate minimum search distance from the Site as specified in ASTM Standard E1527-21.

Observations and interviews regarding current Site usage and conditions including the use, treatment, storage, disposal, or generation of hazardous substances, petroleum products, hazardous wastes, non-hazardous solid wastes, and waste water.

Usage of the Site, adjoining properties, and surrounding area through a review of referenced historical sources such as land title records, fire insurance maps, city directories, aerial photographs, prior reports, and interviews.

Usage of adjoining properties and surrounding area properties and the likely impact of known or suspected releases of hazardous substances or petroleum products from those properties onto the Site.

Physical setting characteristics of the Site through a review of referenced sources such as topographic maps and geologic, soils, and hydrogeologic reports.

In addition, Freedom of Information Act (FOIA) Request will be submitted for the Site and any adjoining properties as part of our Records Review if any of these properties are identified on one or more of the standard environmental record sources. Information available for review within 20 calendar days of our request is considered reasonably ascertainable per the ASTM Standard and should be reviewed. The User will need to approve in writing a review of available file information.

Available file information not reviewed will be considered a data gap.

Non-scope items that are beyond the scope of the ASTM E1527-21 practice and were not addressed as part of this report include, but are not limited to: asbestos-containing building materials unrelated to releases into the environment, biological agents, cultural and historic resources, ecological resources, endangered species, health and safety, indoor air quality unrelated to releases of hazardous substances or petroleum products into the environment, industrial hygiene, lead-based paint unrelated to releases into the environment, lead in drinking water, mold or microbial growth conditions, polychlorinated biphenyl (PCB)-containing building materials (for example, interior fluorescent light ballasts, paint, and caulk), naturally-occurring radon, regulatory compliance, substances not defined as hazardous substances (including some

Loop Drive and Lake View Drive substances sometimes generally referred to as emerging contaminants) unless or until such substances are classified as a CERCLA hazardous substance and wetlands. This list is not intended to be all-inclusive and no implication is intended regarding the importance of inquiry into non-scope considerations. Any use of this report by any party, beyond the scope and intent of the original parties, shall be at the sole risk and expense of such user.

2.3. Assumptions

No significant assumptions pertaining to the evaluation of RECs or potential recognized conditions were made while conducting this Phase I ESA. Arc Environmental makes no claim to the validity of information obtained by interviews related to the Site or RECs, and assumes full disclosure was provided pertaining to current and historical information.

2.4. Limitations and Exceptions

Arc Environmental has prepared this Phase I ESA report using reasonable efforts to identify RECs associated with hazardous substances or petroleum products at the property. Findings contained within this report are based on information collected from observations made during the Site reconnaissance and from reasonably ascertainable information obtained from certain public agencies and other referenced sources.

The ASTM E1527-21 Standard recognizes inherent limitations in the performance of a Phase I ESA, including, but not limited to:

• Uncertainty Not Eliminated: A Phase I ESA cannot completely eliminate uncertainty regarding the potential for recognized environmental conditions in connection with any site.

• Not Exhaustive: A Phase I ESA is not an exhaustive investigation of a property and environmental conditions on such property.

• Past Uses of the Site: The ASTM E1527-21 Standard requires review of standard historical sources at five-year intervals. Therefore, past uses of the Site at less than five-year intervals may not be discovered.

• No Phase I ESA can completely eliminate uncertainty regarding the potential for recognized environmental conditions in connection with the site. The findings of this Phase I ESA are not intended to serve as an audit for health and safety compliance issues pertaining to improvements or activities at the site. Arc Environmental is not liable for the discovery or elimination of hazards that may potentially cause damage, accidents or injury.

In addition: the Environmental Professional Statement on page i of this report does not “certify” the findings contained in this report and is not a legal opinion of such Environmental Professional. The Environmental Professional Statement is intended to document Arc Environmental’s opinion that an individual meeting the qualifications of an Environmental Professional was involved in the performance of the assessment and that the activities performed by, or under the supervision of, the Environmental Professional were performed in conformance with the standards and practices set forth in 40 C.F.R.

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Part 312 per the methodology in ASTM Standard E1527-21 and the scope of work for this assessment.

• Per ASTM Standard E1527-21, Section 6, User Responsibilities, the User of this assessment has specific obligations for performing tasks during this assessment that will help identify the possibility of RECs in connection with the property. Failure by the User to fully comply with the requirements may impact the User’s ability to use this report to help qualify for LLPs under CERCLA. Arc Environmental makes no representations or warranties regarding a User’s qualification for protection under any federal, state, or local laws, rules, or regulations.

• In accordance with ASTM Standard E1527-21, this report is presumed to be valid for a six month period beginning on the date of the Site reconnaissance or date of the environmental database, whichever is earlier. If the report is older than six months, the following information must be updated in order for the report to be valid: (1) regulatory review, (2) Site reconnaissance, (3) interviews, (4) specialized knowledge, and (5) environmental liens search. Reports older than one year do not meet the ASTM E1527- 21 Standard and therefore, the entire report must be updated to reflect current conditions and Site-specific information.

All observations, conclusions and/or recommendations pertaining to environmental conditions at the subject site are necessarily limited to conditions observed, and or materials reviewed at the time this study was undertaken. It was not the purpose of this study to determine the actual exploratory work, including sampling and laboratory analysis. No other warranty, expressed or implied, is made with regard to the conclusions and/or recommendations presented within this report.

2.5. Special Terms and Conditions

No special terms or conditions beyond those required in ASTM E1527-21 were performed or requested by the User.

2.6. User Reliance

Arc Environmental conducted this Phase I ESA of Many Farms High School Buildings 1369, 1161 and boiler room and vacant land addressed as Loop Drive and Lake View Drive, Many Farms, Arizona 86538 for the exclusive use and benefit of Seven Generations Architecture & Engineering (User). No other party is permitted to rely on this Phase I ESA without express written consent by the User and Arc Environmental.

2.7. Data Gap Summary

A data gap is defined by ASTM Standard E1527-21 as a lack of, or inability to obtain, information required by the practice, despite good faith efforts by the environmental professional. Data gaps can be significant or insignificant based on the manner in which they occur. A data gap is only significant if other information and/or professional experience raise a reasonable concern involving the data gap, which would then warrant comment.

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Due to the lack of historical resources prior to 1949 and between 1955 and 1964, 1970 and 1974, 1985 and 1989 and 2002 and 2004 and absence of an environmental lien search and Site owner and manager interviews, data gaps regarding past Site uses exist. However, these data gaps are not considered significant since the Site uses are well documented.

3. SITE DESCRIPTION

The Many Farms High School Buildings 1369, 1161 and boiler room and vacant land are located on the Many Farms boarding school campus. The Site consists of the 1369, 1161 and boiler room buildings only and an approximate 17-acre portion of vacant land on the Many Farms school campus and not the surrounding area. Many Farms, Arizona is located along State Highway 191, in the central part of the Navajo Nation in Northeastern Arizona, approximately 15 miles north of Chinle, Arizona in Apache County. Building 1369 is utilized as class rooms for the high school which was constructed in 2001 and is 59,496 square feet in size. Building 1161 is utilized as the industrial arts buildings (e.g. wood shop, metal shop, etc.) and was constructed in 1968 and is 13,535 square feet in size. The boiler room provides heating for the main school campus and was constructed in 1968 and is 1,811 square feet in size. All buildings are single story and constructed with crawl spaces. The approximate 17-acre portion of vacant land is unimproved.

Prior to development in the late 1960s as the Many Farms Boarder School, the Site and surrounding area consisted of farm land.

3.1. Location and Legal Description

The Site consists of Many Farms High School Buildings 1369, 1161 and boiler room and is addressed as Loop Drive, Many Farms, Arizona 86538 and an unaddressed approximate 17-acre portion of vacant land east of the school buildings.

3.2. Site and Vicinity General Characteristics

The Site is located within the Many Farms Boarding School campus. The campus consists of school buildings, athletic fields, houses, apartments and various other community buildings.

Beyond the Many Farms campus, the surrounding area consists of desert land with limited residential and commercial development.

3.3. Current Site Use

The Site currently operates as the high school class room building, industrial arts building and boiler room for the Many Farms Boarding School Campus and vacant land.

3.4. Descriptions of Site Improvements

The Site consists of only buildings 1369, 1161 and boiler room of the Many Farms boarding school campus and an unaddressed approximate 17-acre portion of vacant land east of the school buildings. Building 1369 is utilized as class rooms for the high school which was constructed in 2001 and is 59,496 square feet in size. Building 1161 is utilized as the industrial arts buildings

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(e.g. wood shop, metal shop, etc.) and was constructed in 1968 and is 13,535 square feet in size.

The boiler room provides heating for the main school campus and was constructed in 1968 and is 1,811 square feet in size. All buildings are single story and constructed with crawl spaces.

The approximate 17-acre portion of vacant land east of the school buildings is unimproved.

3.5. Current Uses of Adjoining Properties

The current uses of the adjoining properties were observed to be as follows:

Direction from Site Current Use

North Campus buildings and the trash collection yard.

South Loop Drive beyond which are residences.

East Campus buildings and vacant land.

West Loop Drive beyond which are campus buildings.

4. USER PROVIDED INFORMATION

The ASTM Standard E1527-21 defines several responsibilities for the User in order to assist the environmental professional identify RECs in connection with the property. The following information was requested by Arc Environmental of the User to assist in preparing this report:

• Environmental Lien Search

• Fair Market Value Price

As of the date of this submission, the User has not provided Arc Environmental with a copy of the environmental lien search for the Site.

4.1. Title Records

Title records provide information regarding current and prior property ownership. The User did not provide title records information.

4.2. Environmental Liens or Activity and Use Limitations

A search for environmental liens and activity use limitations can identify conditions or restrictions placed on a deed regarding environmental concerns at the Site. The User did not provide information regarding environmental liens or activity and use limitations.

The environmental database report provided by ERIS performs a search of properties listed in federal and state institutional and engineering control databases within a half-mile radius of the Site, including the Site. These databases often list activity and use limitations, if recent.

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Information listed in the ERIS database did not identify the Site in either database. A copy of the ERIS report is attached in Tab 2.

4.3. Specialized Knowledge

Specialized knowledge is considered to be information describing environmentally suspect operations, conditions, etc. that cannot be reasonably ascertained or identified during this assessment nor is commonly known. The User did not provide any specialized knowledge for the Site.

4.4. Commonly Known or Reasonably Ascertainable Information

The User did not provide any commonly known or reasonably ascertainable information for the Site.

4.5. Valuation Reduction for Environmental Issues

Valuation reduction for environmental issues is not applicable given that the Phase I ESA is not be completed as part of a real estate transaction, rather a building renovation and construction of a dormitory.

4.6. Owner, Property Manager, and Occupant Information

The school is owned by the Bureau of Indian Affairs and managed by the Bureau of Indian Education through the United States Department of the Interior.

4.7. Reason for Performing Phase I

This Phase I ESA is being completed as part of building renovations and construction of a dormitory.

4.8. Other User Provided Information

No other significant User provided information was provided.

5. RECORDS REVIEW

5.1. Standard Environmental Record Sources

The purpose of the Environmental Records Review is to obtain and review Federal, State, and Tribal records that will help identify RECs in connection with the Site and to identify operations at the Site or on properties located within the study radius which have operations, releases or hazardous materials that would result in a vapor migration/ intrusion concern. Arc Environmental reviewed or requested the records listed below, which were obtained from ERIS. In addition, Arc Environmental conducted a review of properties that could not be mapped by ERIS, referred to as “orphan sites”. Arc Environmental reviewed these sites to determine if 1.) the Site was listed

Loop Drive and Lake View Drive under an alias or different address and 2.) if any of these properties have the potential to impact the Site.

Based on our review, Arc Environmental did not identify activities at the Site or neighboring properties that would indicate a significant potential for RECs or that would result in a vapor mitigation/intrusion concern. In addition, Arc Environmental has determined that the Site does not appear to be listed in the orphan site directory and of the listed sites none appear to have the potential to significantly impact the Site.

A copy of the ERIS report is attached to this report in Tab 2. Results of the record review are summarized in the following table:

RECORD SOURCE DISCUSSION OF FINDINGS SEARCH

RADIUS

National Priorities List (NPL) (Superfund)

There are no NPL properties listed within the established search radius. 1.0 mile

Delisted NPL There are no delisted NPL properties listed within the established search radius. 0.5 mile

Superfund Enterprise Management System

(SEMS)/Comprehensive Environmental

Response, Compensation and Liability Information System (CERCLIS)

There are no SEMS properties listed within the established search radius. 0.5 mile

SEMS/CERCLIS NFRAP The Site and adjoining properties are not listed in the SEMS/CERCLIS NFRAP databases.

Site and Adjoining

Resource Conservation and Recovery Act (RCRA) Corrective

Report (CORRACTS)

There are no RCRA CORRACTS properties listed within the established search radius. 1.0 mile

RCRA Treatment Storage and Disposal

Facility (TSD)

There are no RCRA TSD properties listed within the established search radius. 0.5 mile

RCRA Generator (GEN) The Site and adjoining properties are not listed in the RCRA GEN database.

Site and Adjoining

Emergency Response Notification System

(ERNS)

The Site is not listed in the ERNS database. Site

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RECORD SOURCE DISCUSSION OF FINDINGS SEARCH

RADIUS

Federal Engineering and Institutional

(ENG/INST) Controls The Site is not an ENG/INST property. Site

Facility Index System (FINDS) The Site is not listed in the FINDS database. Site

State CERCLA There are no State CERCLA properties listed within the established search radius. 0.5 mile

LANDFILL There are no LANDFILL properties listed within the established search radius. 0.5 mile

Underground Storage Tank (UST)/HIST UST

The Site and adjoining properties are not listed in the UST/HIST UST database.

Site and Adjoining

Leaking UST (LUST) There are no LUST properties listed within the established search radius. 0.5 mile

Brownfields/ Voluntary Cleanup Program (VCP)

There are no VCP properties listed within the established search radius. 0.5 mile

State and Tribal Engineering and

Institutional (ENG/INST) Controls

The Site is not listed in the State ENG/INST database. Site

5.2. Additional Environmental Record Sources

Arc Environmental checks additional local records and/or state or tribal records when, in the judgment of the Environmental Professional, such additional records (1) are reasonably ascertainable, (2) are sufficiently useful, accurate and complete in light of the objective of the records review, and (3) are generally obtained, pursuant to local good commercial or customary practice, in initial environmental site assessments in the type of real estate transaction involved.

No local agencies/databases were identified for contact/review as part of this ESA.

5.3. Physical Setting Sources(s)

5.3.1. Topography

Based on a review of the United States Geological Survey (USGS) 7.5-Minute Quadrangle topographic map for the Site and vicinity, the grade of the Site slopes to the northeast. The Site elevation is approximately 5,306 feet above mean sea level. Copies of the current and historical topographic maps are included in Tab 3.

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5.3.2. Geology

According to the ERIS Physical Setting Report, the Site is underlain by both the Chinle and Holocene formations. These formations consist of alluvial deposits and mud stone and sand stone.

5.3.3. Soils

According to the United States Department of Agriculture Web Soil Survey, Site soils are mapped as Urban land. Soils consist of sands, clays and loams.

5.3.4. Hydrogeology

Based on the general topography of the surrounding area, it appears that the groundwater in the vicinity of the Site would generally flow to the northeast. Therefore, groundwater flow for the properties bordering the site to the southeast and northwest would be considered cross-gradient, while properties bordering the subject Site to the southwest would be considered upgradient and properties to the northeast would be considered downgradient.

Based on the general topography of the surrounding area, it appears that Site storm water runoff follows Site topography and likely drains towards the northeast.

5.4. Historical Use Information on the Site and Adjacent Properties

The objective of historical research is to develop a history of the previous uses of the Site, starting from current use back to the origin of development. This research is used to help identify the likelihood of past uses that may have led to RECs in connection with the Site. The following historical sources were reviewed:

• Historical aerial photographs of the area were provided by ERIS and reviewed for the following years: 1952, 1967, 1979, 1981, 1992, 1997, 2007, 2010, 2013, 2015, 2017, 2019 and 2021. Copies of each photograph are attached to this report (Tab 3).

• Historical topographical maps of the Site were provided by ERIS and reviewed for the following years: 1968, 2014, 2018 and 2018. Copies of each map are attached to this report (Tab 3).

• A city directory search was provided by ERIS. The results of the directory search are attached to this report (Tab 3).

• A search of available Fire Insurance Maps was also completed as part of our historical research; however, no information for the Site was identified and the “No Coverage” report is attached in Tab 3.

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The results of the review of historical use information are summarized in the following table:

YEAR SITE AND ADJACENT/SURROUNDING PROPERTY USE

Prior to 1940 No records.

1940-1944 No records.

1945-1949 No records.

1950-1954 The 1952 aerial photograph shows the Site and surrounding area as farmland.

1955-1959 No records.

1960-1964 No records.

1965-1969

The 1967 aerial photograph shows the Site mostly unimproved. Small ancillary structures are observed in the area of the future high school building footprint. However, the Site area has been developed with what appears to be the Many Farms Boarding School campus.

The 1968 topographic map shows the Site and surrounding area as a school.

1970-1974 No records.

1975-1979

The 1979 aerial photograph shows the Site improved with the boiler building and industrial arts buildings; however, a grassy field is observed in the area of the current high school building. The Site area has been developed with what appears to be the Many Farms Boarding School campus.

1980-1984

The 1981 aerial photograph shows the Site improved with the boiler building and industrial arts buildings; however, a grassy field is observed in the area of the current high school building. The Site area has been developed with what appears to be the Many Farms Boarding School campus.

1985-1989 No records.

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YEAR SITE AND ADJACENT/SURROUNDING PROPERTY USE

1990-1994

The 1992 aerial photograph shows the Site improved with the boiler building and industrial arts buildings; however, a grassy field is observed in the area of the current high school building. The Site area has been developed with what appears to be the Many Farms Boarding School campus.

1995-1999

The 1997 aerial photograph shows the Site improved with the boiler building and industrial arts buildings; however, a grassy field is observed in the area of the current high school building. The Site area has been developed with what appears to be the Many Farms Boarding School campus.

2000-2004 No records.

2005-2009

The 2007 aerial photograph shows the Site improved with the boiler building, industrial arts buildings and high school building. The Site area is developed with what appears to be the Many Farms Boarding School campus.

2010-2014

The 2010 and 2013 aerial photographs show the Site improved with the boiler building, industrial arts buildings and high school building. The Site area is developed with what appears to be the Many Farms Boarding School campus.

The 2014 topographic map shows the Site and surrounding area as a school.

2015-2019

The 2018 topographic map shows the Site and surrounding area as a school.

The 2015, 2017 and 2019 aerial photographs show the Site improved with the boiler building, industrial arts buildings and high school building. The Site area is developed with what appears to be the Many Farms Boarding School campus.

2020-Present

The 2021 aerial photograph shows the Site improved with the boiler building, industrial arts buildings and high school building. The Site area is developed with what appears to be the Many Farms Boarding School campus.

The 2021 topographic map shows the Site and surrounding area as a school.

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5.5. Review of Prior Environmental Reports

The following environmental reports were reviewed as part of this assessment and pertinent information summarized below:

6. SITE RECONNAISSANCE

6.1. Methodology and Limiting Conditions

On September 28, 2022 and November 15, 2022, Arc Environmental and Terracon, Inc.

conducted a Site reconnaissance of the property. The objective of the Site reconnaissance is to obtain information indicating the likelihood of identifying RECs in connection with the Site. Visual limitations were encountered during our inspection and include:

• Limited observations of the Site buildings interiors due to class being in session.

6.2. General Site Setting and Observations

This section provides a detailed discussion of the Site reconnaissance information as required by

ASTM E1537-21.

Roads: Loop drive surrounds the school buildings Site and Lake View Drive is south of the vacant land portion of the Site.

Heating/Cooling: The Site is heated by natural gas and cooled by electricity.

Potable Water Supply: Potable water is publicly supplied throughout the community via potable wells.

Sewage Disposal System: Sewage is conveyed off-Site to a community treatment facility.

Drains and Sumps: No drains not connected to the public sewer system were observed at the Site.

Wells: No wells were observed at the Site.

Septic Systems: No septic systems were observed at the Site.

Stains or Corrosion within Building Interiors: No stains or corrosion within building systems were observed.

Odors: No unusual odors were observed.

Stained Soil or Pavement: No stained soil or pavement was observed.

Stressed Vegetation: No stressed vegetation was observed.

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Drums: No drums were observed.

Hazardous Substances and Petroleum Containers: No hazardous substances or petroleum containers were observed other than acetylene and oxygen for welding in the industrial arts building. These compressed gas cylinders were stored upright and in sound condition.

Unidentified Substance Containers: No unidentified containers were observed.

Polychlorinated Biphenyls (PCBs): Two pad-mounted transformers were observed at the Site.

One transformer was located next to the high school building and one was located next to the boiler room. The transformers were not labeled with regard to their PCB content, if any. The transformers appeared sound and no evidence of staining or leaking was observed.

Storage Tanks: No storage tanks were observed.

Solid Waste: No illegal dumping of solid waste was observed.

Pits, Ponds or Lagoons: No pits, ponds or lagoons were observed.

7. INTERVIEWS

7.1. Interview with the Owner

No Owner was interviewed as part of this assessment.

7.2. Interview with the User

No User was interviewed as part of this assessment.

7.3. Interview with Site Manager

The facility engineer was interviewed during the inspection and information obtained is discussed herein.

7.4. Interview with Occupants or Operators

No occupants were interviewed as part of this assessment.

7.5. Interview with Past Owner, Occupants, or Operators

No past owners, operators or occupants of the Site, who likely would have material information regarding the potential for contamination at the Site were identified.

7.6. Interview with State and/or Local Government Officials

Details of interviews with local and state officials are discussed in Section 5.2 of this report.

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8. ADDITIONAL SERVICES

No additional services beyond those required in ASTM E1527-21 were performed or requested by the User.

9. FINDINGS, OPINIONS, AND CONCLUSIONS

We have performed a Phase I Environmental Site Assessment in conformance with the scope and limitations of the ASTM Practice E1527-21 of the Site. Any exceptions to, or deletions from, this practice are described in Section 2.0 of this report.

This assessment has revealed no evidence of recognized environmental conditions (RECs) in connection with Many Farms High School Buildings 1369, 1161 and the boiler room and vacant land addressed as Loop Drive and Lake View Drive, Many Farms, Arizona 86538 (Site).

10. DEVIATIONS

There were no deviations to the Scope of Work or ASTM E1527-21 Standard during completion of this Phase I ESA.

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11. REFERENCES

ERIS. Database Report, Order Number: 22100705965. October 2022.

ERIS. Fire Insurance Maps, Order Number: 22100705965. October 2022.

ERIS. Historical Aerials, Order Number: 22100705965. October 2022.

ERIS. City Directory, Order Number: 22100705965. October 2022.

ERIS. Topographic Maps, Order Number: 22100705965. October 2022.

ERIS. Physical Setting Report, Order Number: 22100705965. October 2022.

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12. QUALIFICATIONS OF ENVIRONMENTAL PROFESSIONAL

Christie Pulvino

Christie has twenty-three years of experience in the environmental field and holds a B.S. in Environmental Science with a minor in Chemistry from Wesley College. Throughout her career, Christie has conducted hundreds of Phase I Environmental Site Assessments (ESAs) of residential, commercial and industrial properties throughout the continental United States.

Christie has experience completing all components of Phase I ESAs including conducting the site reconnaissance, researching historical records and environmental databases, completing interviews with knowledgeable personnel and report preparation. Christie has prepared Phase I ESAs using the following standards and guidelines: American Society of Testing and Materials (ASTM) Standard E1527-21, Housing and Urban Development (HUD) Multifamily Accelerated Processing (MAP), Fannie Mae Delegated Underwriting and Servicing (DUS) and Freddie Mac.

Christie meets the requirements of an Environmental Professional as defined in §312.10 of 40 C.F.R. 312 and is responsible for creating report templates and providing oversight and review of all Phase I ESAs generated at Arc Environmental.

TAB 1

Many Farms High School Buildings 1369, 1161 and Boiler Room and Vacant Land

Loop Drive and Lake View Drive Many Farms, Arizona 86538

1311 Haubert Street, Baltimore, Maryland 21230 | P 410. 659.9971 F 410.962.1065

FIGURE 1 Date: September 28, 2022 and November 15, 2022

Site Outlined in Yellow

Building 1369

Building 1161

Boiler

Transformers

1311 Haubert Street, Baltimore, Maryland 21230 | P 410. 659.9971 F 410.962.1065

PHOTO

Transformer Natural gas

Crawl spaceHousekeeping

Date: September 28, 2022 and November

15, 2022

Many Farms High School Buildings 1369, 1161 and Boiler

Room and Vacant Land Loop Drive and Lake View Drive

Many Farms, Arizona 86538

Many Farms High School Buildings 1369, 1161 and Boiler

Room Loop Drive, Many Farms, Arizona 86538

1311 Haubert Street, Baltimore, Maryland 21230 | P 410. 659.9971 F 410.962.1065

PHOTO 2 Date: September 28, TransformerCompressed gas cylinders

PHOTO

Date: September 28, 2022 and November

15, 2022

Many Farms High School Buildings 1369, 1161 and Boiler

Room and Vacant Land Loop Drive and Lake View Drive

Many Farms, Arizona 86538

Transformer

Vacant Site area Vacant Site area

TAB 2

Project Property: Many Farms High School, Loop Dr, Many Farms, AZ 86538 Many Farms High School, Loop Dr, Many Farms, AZ 86538 Many Farms AZ 86538

Project No: 988-22 Report Type: Database Report Order No: 22100705965 Requested by: Arc Environmental Date Completed: October 11, 2022

2 erisinfo.com | Environmental Risk Information Services Order No: 22100705965 h-Table of Contents

Notice: IMPORTANT LIMITATIONS and YOUR LIABILITY

Reliance on information in Report: This report DOES NOT replace a full Phase I Environmental Site Assessment but is solely intended to be used as database review of environmental records.

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Table of Contents

Table of Contents Executive Summary

Executive Summary: Report Summary

Executive Summary: Site Report Summary - Project Property

Executive Summary: Site Report Summary - Surrounding Properties

Executive Summary: Summary by Data Source

Map Aerial Topographic Map Detail Report Unplottable Summary Unplottable Report Appendix: Database Descriptions Definitions http://www.erisinfo.com

3 erisinfo.com | Environmental Risk Information Services Order No: 22100705965 h-Executive Summary

Property Information:

Project Property: Many Farms High School, Loop Dr, Many Farms, AZ 86538 Many Farms High School, Loop Dr, Many Farms, AZ 86538 Many Farms AZ 86538

Project No: 988-22

Coordinates:

Latitude: 36.36919374 Longitude: -109.62603876 UTM Northing: 4,025,746.79 UTM Easting: 623,308.64 UTM Zone: UTM Zone 12S

Elevation: 5,306 FT

Order Information:

Order No: 22100705965 Date Requested: October 7, 2022 Requested by: Arc Environmental Report Type: Database Report

Historicals/Products:

Aerial Photographs Historical Aerials (with Project Boundaries) City Directory Search CD - 2 Street Search ERIS Xplorer ERIS Xplorer Excel Add-On Excel Add-On Fire Insurance Maps US Fire Insurance Maps Physical Setting Report (PSR) Physical Setting Report (PSR) Topographic Map Topographic Maps

Executive Summary https://order.erisinfo.com/xplorer/map.html?q=WAnKFFpDpZwhLLBUzftuHYPXBATqBFjXAGlTNtpk

4 erisinfo.com | Environmental Risk Information Services Order No: 22100705965 h-Executive Summary: Report Summary

Database Searched Search Radius

Project Property

Within 0.12mi

0.125mi to 0.25mi

0.25mi to 0.50mi

0.50mi to 1.00mi

Total

Standard Environmental Records

Federal rr-DOE FUSRAP-aa Y 1 0 0 0 0 0 0 rr-NPL-aa Y 1 0 0 0 0 0 0 rr-PROPOSED NPL-aa Y 1 0 0 0 0 0 0 rr-DELETED NPL-aa Y 0.5 0 0 0 0 - 0 rr-SEMS-aa Y 0.5 0 0 0 0 - 0 rr-ODI-aa Y 0.5 0 0 0 0 - 0 rr-SEMS ARCHIVE-aa Y 0.5 0 0 0 0 - 0 rr-CERCLIS-aa Y 0.5 0 0 0 0 - 0 rr-IODI-aa Y 0.5 0 0 0 0 - 0 rr-CERCLIS NFRAP-aa Y 0.5 0 0 0 0 - 0 rr-CERCLIS LIENS-aa Y PO 0 - - - - 0 rr-RCRA CORRACTS-aa Y 1 0 0 0 0 0 0 rr-RCRA TSD-aa Y 0.5 0 0 0 0 - 0 rr-RCRA LQG-aa Y 0.25 0 0 0 - - 0 rr-RCRA SQG-aa Y 0.25 0 0 0 - - 0 rr-RCRA VSQG-aa Y 0.25 0 0 0 - - 0 rr-RCRA NON GEN-aa Y 0.25 0 0 0 - - 0 rr-RCRA CONTROLS-aa Y 0.5 0 0 0 0 - 0 rr-FED ENG-aa Y 0.5 0 0 0 0 - 0 rr-FED INST-aa Y 0.5 0 0 0 0 - 0 rr-LUCIS-aa Y 0.5 0 0 0 0 - 0 rr-NPL IC-aa Y 0.5 0 0 0 0 - 0 rr-ERNS 1982 TO 1986-aa Y PO 0 - - - - 0 rr-ERNS 1987 TO 1989-aa Y PO 0 - - - - 0 rr-ERNS-aa Y PO 0 - - - - 0 rr-FED BROWNFIELDS-aa Y 0.5 0 0 0 0 - 0 rr-FEMA UST-aa Y 0.25 0 0 0 - - 0

DOE FUSRAP

NPL

PROPOSED NPL

DELETED NPL

SEMS

ODI

SEMS ARCHIVE

CERCLIS

IODI

CERCLIS NFRAP

CERCLIS LIENS

RCRA CORRACTS

RCRA TSD

RCRA LQG

RCRA SQG

RCRA VSQG

RCRA NON GEN

RCRA CONTROLS

FED ENG

FED INST

LUCIS

NPL IC

ERNS 1982 TO 1986

ERNS 1987 TO 1989

ERNS

FED BROWNFIELDS

FEMA UST

Executive Summary: Report Summary

5 erisinfo.com | Environmental Risk Information Services Order No: 22100705965

Database Searched Search Radius

Project Property

Within 0.12mi

0.125mi to 0.25mi

0.25mi to 0.50mi

0.50mi to 1.00mi

Total rr-FRP-aa Y 0.25 0 0 0 - - 0 rr-DELISTED FRP-aa Y 0.25 0 0 0 - - 0 rr-HIST GAS STATIONS-aa Y 0.25 0 0 0 - - 0 rr-REFN-aa Y 0.25 0 0 0 - - 0 rr-BULK TERMINAL-aa Y 0.25 0 0 0 - - 0 rr-SEMS LIEN-aa Y PO 0 - - - - 0 rr-SUPERFUND ROD-aa Y 1 0 0 0 0 0 0

State rr-SHWS-aa Y 1 0 0 0 0 0 0 rr-SHWS ACIDS-aa Y 1 0 0 0 0 0 0 rr-WQARF-aa Y 1 0 0 0 0 0 0 rr-DELISTED SUPERFUND-aa Y 1 0 0 0 0 0 0 rr-SWF/LF-aa Y 0.5 0 0 0 0 - 0 rr-LUST-aa Y 0.5 0 0 0 0 - 0 rr-DELISTED LUST-aa Y 0.5 0 0 0 0 - 0 rr-UST-aa Y 0.25 0 0 0 - - 0 rr-AST-aa Y 0.25 0 0 0 - - 0 rr-AST2-aa Y 0.25 0 0 0 - - 0 rr-DELISTED TANKS-aa Y 0.25 0 0 0 - - 0 rr-AUL-aa Y 0.5 0 0 0 0 - 0 rr-RDT OTHER-aa Y 0.5 0 0 0 0 - 0 rr-VCP-aa Y 0.5 0 0 0 0 - 0 rr-BROWNFIELDS-aa Y 0.5 0 0 0 0 - 0

Tribal rr-BROWNFIELDS WMAT-aa Y 0.5 0 0 0 0 - 0 rr-SRPMIC BROWNFIELDS-aa Y 0.5 0 0 0 0 - 0 rr-INDIAN LUST-aa Y 0.5 0 0 0 0 - 0 rr-INDIAN UST-aa Y 0.25 0 0 0 - - 0 rr-DELISTED ILST-aa Y 0.5 0 0 0 0 - 0 rr-DELISTED IUST-aa Y 0.25 0 0 0 - - 0

County No County databases were selected to be included in the search.

Additional Environmental Records

Federal

FRP

DELISTED FRP

HIST GAS STATIONS

REFN

BULK TERMINAL

SEMS LIEN

SUPERFUND ROD

SHWS

SHWS ACIDS

WQARF

DELISTED SUPERFUND

SWF/LF

LUST

DELISTED LUST

UST

AST

AST2

DELISTED TANKS

AUL

RDT OTHER

VCP

BROWNFIELDS

BROWNFIELDS WMAT

SRPMIC BROWNFIELDS

INDIAN LUST

INDIAN UST

DELISTED ILST

DELISTED IUST

6 erisinfo.com | Environmental Risk Information Services Order No: 22100705965

Radius

Project Property

Within 0.12mi

0.125mi to 0.25mi

0.25mi to 0.50mi

0.50mi to 1.00mi

Total rr-FINDS/FRS-aa Y PO 0 - - - - 0 rr-TRIS-aa Y PO 0 - - - - 0 rr-PFAS TRI-aa Y 0.5 0 0 0 0 - 0 rr-PFAS NPL-aa Y 0.5 0 0 0 0 - 0 rr-PFAS WATER-aa Y 0.5 0 0 0 0 - 0 rr-PFAS SSEHRI-aa Y 0.5 0 0 0 0 - 0 rr-ERNS PFAS-aa Y 0.5 0 0 0 0 - 0 rr-HMIRS-aa Y 0.125 0 0 - - - 0 rr-NCDL-aa Y 0.125 0 0 - - - 0 rr-TSCA-aa Y 0.125 0 0 - - - 0 rr-HIST TSCA-aa Y 0.125 0 0 - - - 0 rr-FTTS ADMIN-aa Y PO 0 - - - - 0 rr-FTTS INSP-aa Y PO 0 - - - - 0 rr-PRP-aa Y PO 0 - - - - 0 rr-SCRD DRYCLEANER-aa Y 0.5 0 0 0 0 - 0 rr-ICIS-aa Y PO 0 - - - - 0 rr-FED DRYCLEANERS-aa Y 0.25 0 0 0 - - 0 rr-DELISTED FED DRY-aa Y 0.25 0 0 0 - - 0 rr-FUDS-aa Y 1 0 0 0 0 0 0 rr-FORMER NIKE-aa Y 1 0 0 0 0 0 0 rr-PIPELINE INCIDENT-aa Y PO 0 - - - - 0 rr-MLTS-aa Y PO 0 - - - - 0 rr-HIST MLTS-aa Y PO 0 - - - - 0 rr-MINES-aa Y 0.25 0 0 0 - - 0 rr-SMCRA-aa Y 1 0 0 0 0 0 0 rr-MRDS-aa Y 1 0 0 0 0 0 0 rr-URANIUM-aa Y 1 0 0 0 0 0 0 rr-ALT FUELS-aa Y 0.25 0 0 0 - - 0 rr-CONSENT DECREES-aa Y 0.25 0 0 0 - - 0 rr-AFS-aa Y PO 0 - - - - 0 rr-SSTS-aa Y 0.25 0 0 0 - - 0 rr-PCBT-aa Y 0.5 0 0 0 0 - 0 rr-PCB-aa Y 0.5 0 0 0 0 - 0

State rr-SPILLS-aa Y 0.125 0 0 - - - 0

FINDS/FRS

TRIS

PFAS TRI

PFAS NPL

PFAS WATER

PFAS SSEHRI

ERNS PFAS

HMIRS

NCDL

TSCA

HIST TSCA

FTTS ADMIN

FTTS INSP

PRP

SCRD DRYCLEANER

ICIS

FED DRYCLEANERS

DELISTED FED DRY

FUDS

FORMER NIKE

PIPELINE INCIDENT

MLTS

HIST MLTS

MINES

SMCRA

MRDS

URANIUM

ALT FUELS

CONSENT DECREES

AFS

SSTS

PCBT

PCB

SPILLS

7 erisinfo.com | Environmental Risk Information Services Order No: 22100705965

Radius

Project Property

Within 0.12mi

0.125mi to 0.25mi

0.25mi to 0.50mi

0.50mi to 1.00mi

Total rr-DRYCLEANERS-aa Y 0.25 0 0 0 - - 0 rr-PFAS-aa Y 0.5 0 0 0 0 - 0 rr-AIR PERMITS-aa Y 0.25 0 0 0 - - 0 rr-DRYWELLS-aa Y 0.125 0 0 - - - 0 rr-DRYWELLS HIST-aa Y 0.125 0 0 - - - 0 rr-DRUG LAB REMEDIATION-aa Y 0.125 0 0 - - - 0 rr-CDL-aa Y 0.125 0 0 - - - 0 rr-TIER 2-aa Y 0.125 0 0 - - - 0 rr-BIO HAZ WASTE-aa Y 0.25 0 0 0 - - 0

Tribal No Tribal additional environmental record sources available for this State.

County No County additional environmental record sources available for this State.

Total: 0 0 0 0 0 0

* PO – Property Only

* 'Property and adjoining properties' database search radii are set at 0.25 miles.

DRYCLEANERS

PFAS

AIR PERMITS

DRYWELLS

DRYWELLS HIST

DRUG LAB REMEDIATION

CDL

TIER 2

BIO HAZ WASTE

8 erisinfo.com | Environmental Risk Information Services Order No: 22100705965 h-Executive Summary: Site Report Summary - Project Property

Map Key

DB Company/Site Name Address Direction Distance (mi/ft)

Elev Diff (ft)

Page Number

No records found in the selected databases for the project property.

Executive Summary: Site Report Summary - Project Property

9 erisinfo.com | Environmental Risk Information Services Order No: 22100705965 h-Executive Summary: Site Report Summary - Surrounding Properties

Map Key

DB Company/Site Name Address Direction Distance (mi/ft)

Elev Diff (ft)

Page Number

No records found in the selected databases for the surrounding properties.

Executive Summary: Site Report Summary - Surrounding Properties

10 erisinfo.com | Environmental Risk Information Services Order No: 22100705965 h-Executive Summary: Summary by Data Source

No records found in the selected databases for the project property or surrounding properties.

Executive Summary: Summary by Data Source

Many FarmsMany Farms

US

-1

BIA-59

Navajo Indian Reservation

Lake Rd

BIA-8086

BIA-8085

Ash Ave

Birch Ave

B I A-

County Road 621

Cedar Ave1st St

C irc le Dr Lo op Dr

Pa rk

Av e

Circle Dr

UV59

UV8086

UV8085

UV8082

£¤191

109°36'30"W109°37'W109°37'30"W109°38'W109°38'30"W

°2

3' N

°2

3' N

°2

2'

"N

°2

2'

"N

°2

2' N

°2

2' N

°2

1'

"N

°2

1'

"N

0.3 0 0.30.15 Miles

Order Number: 22100705965 Map: 1.0 Mile Radius

1:19900

Address: Many Farms High School, Loop Dr, Many Farms, AZ 86538, Many Farms, AZ

Source: © 2021 ESRI StreetMap Premium © ERIS Information Inc.

Project Property Buffer Outline #* Sites with Higher Elevation

") Sites with Same Elevation

Sites with Lower Elevation

( Sites with Unknown Elevation

Areas with Higher Elevation

Areas with Same Elevation

Areas with Lower Elevation

Areas with Unknown Elevation

National Wetland

Indian Reserve Land

100 Year Flood Zone

500 Year Flood Zone

FWS Special Designation AreasFreeways; Highways

Traffic Circle; Ramp

Major & Minor Arterial

Traffic Circle; Ramp

Local Road

Rail

Country

State

Plume

National Priorities List (Active, Delisted, Proposed, Institutional Control) cpulvino Polygonal Line

Many FarmsMany Farms

BIA-59 US

-1

Navajo Indian Reservation

Lake Rd

Ash Ave

Birch Ave

Cedar Ave

1st St Lo op D r

Circle D r

Pa rk

Av e

Pinion St

Circle Dr

UV59

£¤191

109°37'W109°37'30"W109°38'W

°2

2'

"N

°2

2'

"N

°2

2' N

°2

2' N

0.15 0 0.150.075 Miles

Order Number: 22100705965 Map: 0.5 Mile Radius

1:10900

") Sites with Same Elevation

Sites with Lower Elevation

( Sites with Unknown Elevation

Areas with Higher Elevation

Areas with Same Elevation

Areas with Lower Elevation

Areas with Unknown Elevation

National…