B08__A18_Asbestos_Assessment_Survey_MC185_MC270_MC420.pdf

Geotechnical | Environmental | Construction Inspection & Testing | Forensic Engineering & Expert Witness

Geophysics | Engineering Geology | Laboratory Testing | Industrial Hygiene | Occupational Safety | Air Quality | GIS

Asbestos-Containing Material Survey Four Concrete Main Canal Structures

MC 420, MC 270, and MC 185 Colorado River Indian Reservation

Parker, Arizona

DOWL

1300 Cedar Street | Helena, Montana 59601

October 28, 2022 | Project No. 607351001

Geotechnical | Environmental | Construction Inspection & Testing | Forensic Engineering & Expert Witness

Geophysics | Engineering Geology | Laboratory Testing | Industrial Hygiene | Occupational Safety | Air Quality | GIS

3202 East Harbour Drive | Phoenix, Arizona 85034 | p. 602.243.1600 | www.ninyoandmoore.com

Asbestos-Containing Material Survey Four Concrete Main Canal Structures MC 420, MC 270, and MC 185 Colorado River Indian Reservation Parker, Arizona

Mr. Jeffrey Olsson

DOWL

1300 Cedar Street | Helena, Montana 59601

October 28, 2022 | Project No. 607351001

Christian Lewallen, RG Senior Project Geologist EPA Lead Inspector and AHERA Building Inspector

Mark J. Guatney, PE, CHMM Principal Engineer Environmental Operations Manager

CDL/MJG/tlp http://www.ninyoandmoore.com/

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 i

CONTENTS

EXECUTIVE SUMMARY 1

1 INTRODUCTION 3

2 PURPOSE AND SCOPE OF SERVICES 3

3 ASBESTOS SURVEY 4

3.1 Asbestos Sample Collection and Visual Survey 4

3.2 Asbestos Laboratory Analyses 4

3.3 Asbestos Analytical Results 5

3.4 Asbestos Conclusions and Recommendations 5

4 LIMITATIONS 5

TABLE

Table 1 – Asbestos Survey Results

FIGURES

1 – Site Location 2 – Asbestos Sample Locations – MC 185 3 – Asbestos Sample Locations – MC 270 4 – Asbestos Sample Locations – MC 420 5 – Asbestos Sample Locations – MC 420

APPENDICES

A – Certifications B – Laboratory Analytical Results and Chain-of-Custodies C – NESHAP Information Summary D – Photographs

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 1

EXECUTIVE SUMMARY

This report summarizes the findings of our asbestos survey of four concrete structure areas on the Colorado River Irrigation Project Main Canal including the Headwaters MC 420, MC 270, and MC 185, and one canal realignment located on the Colorado River Indian Reservation, in

Parker, Arizona. We understand that this US Bureau of Indian Affairs (BIA) project involves the rehabilitation on two irrigation headworks structures, replacing another headwork structure, and realigning a small segment of the Main Canal within the Colorado River Irrigation Project. The three headworks are concrete and the segment of canal to be realigned also has a concrete lining. The BIA has asked that the three headworks structures be tested for asbestos. For the concrete canal lining, the concrete may be removed or buried in place when the canal is realigned and the BIA has asked that this lining be tested for asbestos as well.

The asbestos survey field work was conducted on August 10, 2022 by Mr. Christian Lewallen of

Ninyo & Moore. Mr. Lewallen is trained as an Asbestos Hazard Emergency Response Act

Building Inspector for all Environmental Protection Agency (USEPA) Administered States, Tribes and Territories, which includes Arizona and the Colorado River Indian Reservation. A total of

35 bulk samples were collected for asbestos analysis, which represented 16 unique homogenous areas (HAs) of building material. The approximate locations of these 35 bulk asbestos samples are shown on Figures 2 through 5. All bulk samples collected of suspect asbestos-containing material (ACM) were hand delivered to EMSL Analytical, Inc. (EMSL) in

Phoenix, Arizona, under standard chain-of-custody protocol. The samples were analyzed by

EMSL for the presence and quantification of asbestos fibers, using polarized light microscopy with dispersion staining (PLM/ds), in general accordance with United States Environmental

Protection Agency Method 600/R-93/116. Copies of the laboratory analytical report and chain-of-custody record are provided in Appendix B.

ACM is defined as any material with an asbestos content greater than 1%. Analytical results of the bulk asbestos samples submitted to EMSL found no asbestos in quantities detectable by

PLM analysis. A general description and location of each homogenous area sampled, along with analytical results and estimated quantities from this survey are summarized in Table 1 to follow.

The quantities shown in Table 1 are estimates, and should not be used for bidding or construction purposes.

A copy of this ACM survey report should be made available to the general contractor, and any other trades involved in the refurbishment or selective demolition of the structures. If additional suspect ACMs are discovered during the demolition, then Ninyo & Moore should be contacted

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 2 for further assessment and sampling before proceeding with renovation that would otherwise disturb these untested materials.

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 3

1 INTRODUCTION

Ninyo & Moore performed an Asbestos-Containing Material (ACM) survey of four concrete structure areas on the Colorado River Irrigation Project Main Canal including the Headwaters

MC 420, MC 270, and MC 185, and one canal realignment located on the Colorado River Indian

Reservation, in Parker, Arizona. (the Site). The survey was performed by a Ninyo & Moore staff member trained as an Asbestos Hazard Emergency Response Act (AHERA) Inspector. The following sections detail the purpose, the involved parties, the scope of services, the results, and the limitations and exceptions associated with the ACM survey.

2 PURPOSE AND SCOPE OF SERVICES

The purpose of the ACM surveys was to evaluate the four concrete structure areas on the

Colorado River Irrigation Project Main Canal including the Headwaters MC 420, MC 270, and

MC 185, and one canal realignment for the presence of ACM. The survey included suspected asbestos materials associated with the above-mentioned structures.

The scope of services for this survey included assessing visible areas of suspect ACMs within the above-mentioned main canal structure areas. Bulk samples for asbestos laboratory analysis were collected from convenient locations accessible to the inspector, and from randomly selected locations where required by AHERA protocols for friable surfacing finishes or thermal systems insulation.

Ninyo & Moore performed the following scope of services:

• Visual assessment of the main canal structure areas to assess homogeneous areas of suspect ACM, quantify suspect ACMs, and prepare a sampling scheme.

• Perform bulk sampling of each homogenous area of suspect ACM identified. If friable surfacing materials were identified, sampling methodology of this media was performed in accordance with AHERA protocols and is described in further detail in Section 3.1.

• The bulk samples for asbestos analysis were submitted to a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for analysis by polarized light microscopy with dispersion staining (PLM/ds). Sample analysis was conducted according to the USEPA protocol described in AHERA, Title 40 Code of Federal Regulations, Part 763 (40 CFR 763). All bulk samples collected were analyzed by the laboratory.

Specific protocols and findings of the ACM survey are discussed in the sections to follow.

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 4

3 ASBESTOS SURVEY

The asbestos survey field work was completed on August 10, 2022 by Mr. Christian Lewallen, Senior Project Geologist of Ninyo & Moore, with 35 bulk asbestos samples collected on this date. Mr. Lewallen is trained as an AHERA Building Inspector for all EPA-Administered States, Tribes and Territories, which includes Arizona and the Colorado River Indian Reservation. A copy of Mr. Lewallen’s EPA AHERA Building Inspector training certificate is provided in Appendix

A. Mr. Mark Guatney, Principal Engineer with Ninyo & Moore, provided project management and senior review of the asbestos survey activities, and Mr. Lewallen prepared this report. Copies of

Mr. Guatney’s AHERA Building Inspector and Management Planner training certifications are also presented in Appendix A.

3.1 Asbestos Sample Collection and Visual Survey

The survey consisted of a visual assessment of the four concrete structure areas to assess homogeneous areas (HAs). An HA is a building material that is generally uniform in color, texture, construction or application date, and general appearance. Each HA was observed for material type, location, condition, and friability. A material is considered friable if it can be easily crumbled by hand pressure alone.

Following identification of HAs, bulk samples were collected of the suspect ACMs observed. The samples were collected in general accordance with Occupational Safety and Health

Administration, EPA National Emission Standard for Hazardous Air Pollutants (NESHAP), and

AHERA guidelines. Samples were generally collected in accessible areas (convenient locations) that were representative of the homogeneous area, except for friable surfacing and thermal system insulation, which were sampled randomly in accordance with AHERA protocols.

Each sample was collected in a manner that would minimize dust and/or fiber release. The samples were stored in re-sealable plastic bags. Each bag was labeled with the sample identification number and sealed to limit dust releases. Locations of samples collected for analysis are shown on Figures 2 through 5. A total of 35 bulk samples were collected for asbestos analysis.

3.2 Asbestos Laboratory Analyses

Bulk samples collected of suspect ACM were hand carried by the inspectors to EMSL Analytical, Inc. (EMSL) in Phoenix, Arizona, under standard chain-of-custody protocol. EMSL is a laboratory accredited by the NVLAP for bulk asbestos fiber analysis. The bulk samples were analyzed for the presence and quantification of asbestos fibers, using Polarized Light

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 5

Microscopy with dispersion staining (PLM/ds), in general accordance with EPA Method

600/R-93/116. Any material identified with greater than 1% asbestos is considered to be ACM by

EPA and OSHA standards.

3.3 Asbestos Analytical Results

Results of PLM/ds analysis did not identify asbestos fibers in any of the 35 bulk samples collected by Ninyo & Moore and analyzed by EMSL; and therefore, none of the HAs sampled are considered to be ACM by PLM/ds analysis.

A general description and location of each HA sampled, along with analytical results and estimated quantities from this survey are summarized in Table 1 to follow. Copies of the laboratory analysis reports and chain-of-custody records are presented in Appendix B. Copies of the laboratory analysis reports and chain-of-custody records are presented in Appendix B.

3.4 Asbestos Conclusions and Recommendations

No ACMs were identified in samples collected from the structures or components scheduled for rehabilitation, removal and replacement, or demolition. Therefore, the following recommendations are provided:

• We recommend that applicable construction worker laws and regulations be followed, including those provisions requiring notification to building contractors and workers of the presence of this asbestos survey.

• If additional suspect-ACM building materials are discovered during rehabilitation or demolition activities, which were not identified and sampled as part of this asbestos survey, then we recommend these materials be sampled and analyzed for asbestos prior to disturbance.

4 LIMITATIONS

Ninyo & Moore's opinions and recommendations regarding environmental conditions, as presented in this report, are based on bulk sampling and laboratory analysis of suspect-ACM.

The sample locations chosen for bulk sampling are believed to be representative of the materials and areas evaluated. However, if additional suspect ACMs are encountered during renovation activities, then these materials should be sampled by qualified personnel, and analyzed for asbestos content prior to disturbance.

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022 6

The environmental services described in this report have been conducted in general accordance with current regulatory guidelines and the standard-of-care exercised by environmental consultants performing similar work in the project area. No warranty, expressed or implied, is made regarding the professional opinions presented in this report. Variations in

Site conditions may exist and conditions not observed or described in this report may be encountered during subsequent activities.

This document is intended to be used only in its entirety. No portion of the document, by itself, is designed to completely represent any aspect of the project described herein. Ninyo & Moore should be contacted if the reader requires any additional information, or has questions regarding content, interpretations presented, or completeness of this document.

The environmental interpretations and opinions contained in this report are based on the results of laboratory tests and analyses intended to detect the presence and concentration of specific chemical or physical constituents in samples collected from the Site. The PLM bulk sample analyses have been conducted by an independent laboratory that is certified to conduct such tests. Ninyo & Moore has no involvement in, or control over, such analyses. Ninyo & Moore, therefore, disclaims responsibility for any inaccuracy in such laboratory results.

Ninyo & Moore’s conclusions, recommendations and opinions are based on an analysis of the observed conditions at the Site. It should be understood that conditions at the Site can change with time, as a result of natural processes or activities of man at the Site. In addition, changes to the applicable laws, regulations, codes, and standards of practice may occur due to government action or the broadening of knowledge. The findings of this report may, therefore, be invalidated over time, in part or in whole, by changes over which Ninyo & Moore has no control.

This report is intended exclusively for use by the client. Any use or reuse of the findings, conclusions, and/or recommendations of this report by parties other than the client is undertaken at said parties’ sole risk.

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

TABLE

Sample No. HA HA Description Friable

(F, NF)

Misc, Surfacing, TSI

(M, S, T)

Location on Site Approximate

Quantity

(SF/LF/EA)

Asbestos Content

MC185-01A South Section ND MC185-01B Middle Section ND MC185-01C North Section ND MC185-02A East Section ND MC185-02B Middle Section ND MC185-02C West Section ND MC185-03A SE Corner ND MC185-03B NE Corner ND MC185-03C NW Corner ND MC185-04A NE Corner MC185-04B SE Corner

MC185-05A 05

Upstream Hoist

Platform Grout/Concrete

NF M East Corner 2 SF ND

MC270-01A North Section ND MC270-01B Middle Section ND MC270-01C Southern Section ND MC270-02A South Section ND MC270-02B Middle Section ND MC270-02C North Section ND

MC270-03A 08

Spillway Channel Sealant

NF M North Section 100 SF ND

MC270-04A 09 Concrete Channel Lining NF M South Section 200 SF ND

MC420-01A Electric Enclosure ND MC420-01B NW Wall/Wingwall ND MC420-01C Hoist Platform ND MC420-02A SE Section ND MC420-02B Central East Section ND MC420-02C NE Section ND

MC420-03A 12 Hoist Motor Gasket NF M Hoist Platform Motor 2 SF ND

MC420-04A 13 Grout on Channel Lining NF M North of Spillway 75 SF ND

MC420-05A 14 Grout/Leveler on Spillway NF M Center of Spillway 30 SF ND

MC420-06A NE Portion of NW Canal ND MC420-06B Central Portion of NW Canal ND

MC420-06C SW Portion of NW Canal ND

MC420-07A ND

MC420-07B ND

MC420-07C ND

Notes:

CY - Cubic Yards NE - Northeast

EA - Each NW - Northwest G - Good

ND - None detected SE - Southeast F - Fair

SF - Square feet SW - Southwest P - Poor

LF - Linear feet C - Center Bold - Asbestos-Containing Material

M

M

ND16 SF

NF

Upstream Hoist

Platform Concrete

MNF

M 1,700 SF

720 SF01

240 SF

03 Concrete Electrical Box 285 SF

Concrete Pier Wall NF

NF M

Table 1 - Asbestos Survey Results - CRIP Main Canal Structure Areas, Parker, Arizona

Concrete Access Walkway and Spillway Weir

Wall

NF M

Concrete Spillway Channel

NF

35,000 SF

HA - Homogenous Area

Curved Weir

Wall/Bulkhead Wall

NF M 1,130 SF

1,100 SF

10 Concrete Check Structures 1,200 SF

Concrete Spillway Channel

NF M

15 Downstream Canal Concrete NF M 49,000 SF

NW Portion of Canal16 Upstream Canal Concrete NF M

Ninyo & Moore | Colorado River Irrigation Project Main Canal, Parker, Arizona | 607351001 | October 28, 2022 1

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

FIGURES

MC 185"

!o 0 4,000 8,000

FEET

¬«95

¬«10

¬«62

¬«78

MAP INDEX

La Paz Co unty

1_

1_

SL

.m xd

/3 0/

AO

B

NOTE: DIRECTIONS, DIMENSIONS AND LOCATIONS ARE APPROXIMATE. | SOURCE: USGS, 2022

SITE LOCATION

FIGURE 1

607351001 | 10/22

ASBESTOS CONTAINING MATERIAL SURVEY

FOUR CONCRETE STRUCTURES ON THE MAIN CANAL

COLORADO INDIAN RESERVATION, PARKER, ARIZONA

MC 270"

MC 420"

A R

IZ

O

N A

C A

LI

F

O R

N

IA

Geotechnical & Environmental Sciences Consultants

ASBESTOS SAMPLE LOCATIONS - MC 185

FEET

20 40

ASBESTOS-CONTAINING MATERIAL SURVEY

FOUR CONCRETE STRUCTURES ON THE MAIN CANAL

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

607351001 I 10/22

N

FIGURE 2

NOTE: DIMENSIONS, DIRECTIONS AND LOCATIONS ARE APPROXIMATE. | REFERENCE: DOWL, DATED APRIL 2022.

1F

IG

U R

ES

.D

W G

/3

0/

A O

B

LEGEND

ASBESTOS SAMPLE LOCATIONMC185-05A

MC185-05A

MC185-04B

MC185-04A

MC185-03C

MC185-03B MC185-03A

MC185-01C

MC185-01B

MC185-01A

MC185-02A

MC185-02B

MC185-02C

ASBESTOS SAMPLE LOCATIONS - MC 270

FEET

20 40

ASBESTOS-CONTAINING MATERIAL SURVEY

FOUR CONCRETE STRUCTURES ON THE MAIN CANAL

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

607351001 I 10/22

N

FIGURE 3

NOTE: DIMENSIONS, DIRECTIONS AND LOCATIONS ARE APPROXIMATE. | REFERENCE: DOWL, DATED APRIL 2022.

1F

IG

U R

ES

.D

W G

/3

0/

A O

B

LEGEND

ASBESTOS SAMPLE LOCATIONMC270-04A

MC270-01B

MC270-01A

MC270-03A

MC270-02C

MC270-02B

MC270-01C

MC270-04A

MC270-02A

ASBESTOS SAMPLE LOCATIONS - MC 420

FEET

20 40

ASBESTOS-CONTAINING MATERIAL SURVEY

FOUR CONCRETE STRUCTURES ON THE MAIN CANAL

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

607351001 I 10/22

N

FIGURE 4

NOTE: DIMENSIONS, DIRECTIONS AND LOCATIONS ARE APPROXIMATE. | REFERENCE: DOWL, DATED APRIL 2022.

1F

IG

U R

ES

.D

W G

/1

6/

A O

B

LEGEND

ASBESTOS SAMPLE LOCATIONMC420-04A

MC420-02C MC420-02B

MC420-05A

MC420-04A

MC420-01C

MC420-03A

MC420-02A

MC420-01B

MC420-01A

MC420-06C

MC420-06B

MC420-06A

MC420-07A

MC420-07C

MC420-07B

Geotechnical & Environmental Sciences Consultants

ASBESTOS SAMPLE LOCATIONS - MC 420

FEET

30 600

ASBESTOS-CONTAINING MATERIAL SURVEY

FOUR CONCRETE STRUCTURES ON THE MAIN CANAL

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

607351001 I 10/22

FIGURE 5

N

1F

IG

U R

ES

.D

W G

/3

0/

A O

B

NOTE: DIMENSIONS, DIRECTIONS AND LOCATIONS ARE APPROXIMATE. | REFERENCE: DOWL, DATED APRIL 2022.

LEGEND

ASBESTOS SAMPLE LOCATIONMC420-07C

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

Appendix A

Photographic Documentation

APPENDIX A

Certifications

Christian Lewallen

May 02, 2022

ON-4644-9299-050222

2-May-2022

02-May-2023

Powered by TCPDF (www.tcpdf.org) http://www.tcpdf.org

Mark Guatney

April 01, 2022

ON-4644-136-040122

1-Apr-2022

01-Apr-2023

Mark Guatney

April 01, 2022

ON-4651-136-040122

1-Apr-2022

01-Apr-2023

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

APPENDIX B

Laboratory Analytical Results and Chain-of-Custodies

EMSL Analytical, Inc.

3356 West Catalina Drive Phoenix, AZ 85017

Tel/Fax: (602) 276-4344 / (602) 276-4053 http://www.EMSL.com / phoenixlab@emsl.com

122204164EMSL Order:

Customer ID: NINY78

Customer PO:

Project ID:

Attention: Phone:Christian Lewallen (509) 438-1039

Fax:Ninyo & Moore (602) 243-2699

Received Date:3202 East Harbour Drive 08/10/2022 2:20 PM

Analysis Date:Phoenix, AZ 85034 08/13/2022 - 08/16/2022

Collected Date: 08/10/2022

Project: 607351001

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

MC185-01A

122204164-0001

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC185-01B

122204164-0002

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC185-01C

122204164-0003

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC185-02A-Concrete 1

122204164-0004

None DetectedNon-fibrous (Other)98%Fibrous (Other)2%Tan

Non-Fibrous

Homogeneous

Concrete

MC185-02A-Concrete 2

122204164-0004A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC185-02B-Concrete 1

122204164-0005

None DetectedNon-fibrous (Other)97%Fibrous (Other)3%Tan

Non-Fibrous

Homogeneous

Concrete

MC185-02B-Concrete 2

122204164-0005A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC185-02C-Concrete 1

122204164-0006

None DetectedNon-fibrous (Other)98%Fibrous (Other)2%Tan

Non-Fibrous

Homogeneous

Concrete

MC185-02C-Concrete 2

122204164-0006A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC185-03A

122204164-0007

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC185-03B

122204164-0008

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC185-03C-Concrete 1

122204164-0009

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC185-03C-Concrete 2

122204164-0009A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC185-04A

122204164-0010

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

Initial report from: 08/17/2022 14:28:03

Page 1 of 3ASB_PLM_0008_0001 - 1.78 Printed: 8/17/2022 11:28 AM

Tel/Fax: (602) 276-4344 / (602) 276-4053 http://www.EMSL.com / phoenixlab@emsl.com

122204164EMSL Order:

Customer ID: NINY78

Customer PO:

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

MC185-04B

122204164-0011

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC185-05A

122204164-0012

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC270-01A

122204164-0013

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Homogeneous

Concrete

MC270-01B

122204164-0014

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Homogeneous

Concrete

MC270-01C

122204164-0015

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Heterogeneous

Concrete

MC270-02A

122204164-0016

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC270-02B

122204164-0017

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC270-02C

122204164-0018

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC270-03A

122204164-0019

None DetectedNon-fibrous (Other)100%Green

Non-Fibrous

Homogeneous

Sealant

MC270-04A

122204164-0020

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC420-01A

122204164-0021

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC420-01B

122204164-0022

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Paint excluded.

MC420-01C

122204164-0023

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Heterogeneous

Concrete

Paint excluded.

Concretes are inseparable.

MC420-03A-Gasket

122204164-0024

None DetectedNon-fibrous (Other)90%Synthetic10%White/Blue

Fibrous

Heterogeneous

Gasket / Sheeting

MC420-03A-Caulk

122204164-0024A

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Gasket / Sheeting

MC420-02A

122204164-0025

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC420-02B

122204164-0026

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC420-02C

122204164-0027

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Page 2 of 3ASB_PLM_0008_0001 - 1.78 Printed: 8/17/2022 11:28 AM

Tel/Fax: (602) 276-4344 / (602) 276-4053 http://www.EMSL.com / phoenixlab@emsl.com

122204164EMSL Order:

Customer ID: NINY78

Customer PO:

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

MC420-04A

122204164-0028

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Heterogeneous

Spray Grout

Grouts are inseparable.

MC420-05A-Leveler 1

122204164-0029

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Leveler

MC420-05A-Leveler 2

122204164-0029A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Leveler

MC420-06A

122204164-0030

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Concrete

MC420-06B

122204164-0031

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Heterogeneous

Concrete

Concretes are inseparable.

MC420-06C

122204164-0032

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Concrete

MC420-07A

122204164-0033

None DetectedNon-fibrous (Other)100%Gray/Beige

Non-Fibrous

Heterogeneous

Concrete

Concretes are inseparable.

MC420-07B-Concrete 1

122204164-0034

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Concrete

MC420-07B-Concrete 2

122204164-0034A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

MC420-07C

122204164-0035

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

Analyst(s)

Erica Furphy (26)

Nathan Stancik (16)

Michelle Wilson, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Phoenix, AZ NVLAP Lab Code 200811-0, AZ0937, CO AL-19027, CA 2761, TX 300484, HI L-14-004, LA 05113

Page 3 of 3ASB_PLM_0008_0001 - 1.78 Printed: 8/17/2022 11:28 AM

OrderID: 122204164

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

APPENDIX C

NESHAP Information Summary

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

NESHAP Information Summary

Property Name Colorado River Irrigation Project Main Canal

Property Address Colorado River Irrigation Project Main Canal, Parker, Arizona

Areas Subject to Survey Concrete Structural Areas of the Headwaters MC 420, MC 270, and MC 185, and one canal realignment.

Property Owner Colorado River Irrigation Project/ Colorado River Indian Tribe

Laboratory Information EMSL Analytical 3356 West Catalina Drive, Phoenix, Arizona 85017

Number of Samples Collected 35

Number of Samples Analyzed 35

Date of Inspection 8/10/2022

Dates of Analysis 8/13/2022-8/16/2022 AHERA Building Inspectors Chris Lewallen

Inspector Training Provider The Asbestos Institute

Training Cert, Date, Expiration Cert #ON-4644-9299-050222, 05/02/2022, expires 05/02/2023

Description of ACM Identified Location NESHAP Category Quantity

None N/A N/A N/A

Ninyo & Moore | Colorado River Indian Reservation, Parker, Arizona | 607351001 R | October 28, 2022

APPENDIX D

Photographs

PHOTOGRAPHS

ASBESTOS-CONTAINING MATERIAL SURVEY ON THE MAIN CANAL

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

607351001 | 10/22

FIGURE D-1

Photograph 1: Photo of hoist motor gasket material (MC420-03A).

Photograph 2: Photo grout lining of northern portion of spillway (MC420-04A).

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

FIGURE D-2

Photograph 3: Photo of the MC 420 spillway grout/leveler (MC420-05A).

Photograph 4: Photo of the MC 185 upstream hoist platform grout underneath the mounting (MC185-05A).

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

FIGURE D-3

Photograph 5: Photo of the MC 185 upstream portion of the concrete pier wall (MC185-01B and MC-185-01C).

Photograph 6: Photo of MC 270 spillway channel concrete (MC185-02C) and sealant

(MC270-03A).

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

FIGURE D-4

Photograph 7: Photo looking west at the downstream portion of MC 270 showing spillway (MC270-02) with sealant (MC270-03), curved weir wall (MC270-01), and concert channel lining (MC270-04) just left of the spillway.

Photograph 8: Photo of the downstream portion of the concrete pier wall (MC185- 01A).

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

FIGURE D-5

Photograph 9: Photo MC 270 northern curved weir wall sample (MC270-01A).

Photograph 10: Photo of MC 185 concrete access walkway/spillway weir concrete (MC185-02A and MC185-02B).

COLORADO RIVER INDIAN RESERVATION, PARKER, ARIZONA

FIGURE D-6

Photograph 11: Photo looking north at MC 420 from sample MC420-06A location.

Photograph 12: Photo looking south at MC 420 from sample MC420-07C location.

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