B08__A19_Asbestos_Assessment_Survey_Lateral_73.pdf

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140A1626R0014
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Department of the Interior Bureau of Indian Affairs Central Office

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This is an environmental assessment report documenting asbestos-containing material (ACM) and lead-based paint (LBP) survey results for a concrete check structure and concrete culvert located on the Colorado River Indian Reservation in La Paz County, Arizona. The survey was conducted on September 5, 2023, by Ninyo & Moore, an environmental consulting firm, at the request of the U.S. Bureau of Indian Affairs in preparation for potential demolition or repair of the structures.

The asbestos survey involved collection of eight bulk samples from three homogeneous areas of concrete material, analyzed by EMSL Analytical using polarized light microscopy with dispersion staining per EPA Method 600/R-93/116. All samples tested negative for asbestos content above the 1% threshold defining ACM. The lead-based paint survey utilized X-ray fluorescence (XRF) analysis on seven painted components and identified two areas exceeding the EPA/HUD threshold of 1.0 mg/cm² for LBP: white painted metal framing at the western end of the main vault (1.40 mg/cm²) and a white painted vertical I-beam at the eastern end (5.30 mg/cm²). The report recommends that if LBP components require removal or surface preparation, lead-trained workers should remove materials intact or use chemical means, followed by cleanup and composite sampling for TCLP analysis to determine if debris constitutes hazardous waste. The report includes laboratory certifications, analytical results, chain-of-custody documentation, NESHAP information summary, and site photographs.

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

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

Asbestos-Containing Material and Lead-Based Paint Survey

Concrete Check Structure and Concrete Culvert

Colorado River Indian Reservation La Paz County, Arizona

DOWL

1300 Cedar Street | Helena, Montana 59601

October 5, 2023 | Project No. 607351002

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 and Lead-Based Paint Survey Concrete Check Structure and Concrete Culvert Colorado River Indian Reservation La Paz County, Arizona

Mr. Jeffrey Olsson, PE, TSP

DOWL

1300 Cedar Street | Helena, Montana 59601

October 5, 2023 | Project No. 607351002

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, La Paz County, Arizona | 607351002 R | October 5, 2023 i

CONTENTS

EXECUTIVE SUMMARY 1

Asbestos Survey 1

LBP Survey 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 LBP SURVEY 5

4.1 LBP Survey Methodology 5

4.2 LBP Survey Findings 6

4.3 LBP Conclusions and Recommendations 6

5 LIMITATIONS 7

TABLE

Table 1 – Asbestos Survey Results Table 2 – Lead-Based Paint Survey Results

FIGURES

1 – Site Location 2 – Sample Locations

APPENDICES

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

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 | October 5, 2023 1

EXECUTIVE SUMMARY

This report summarizes the findings of our asbestos-containing material (ACM) and lead-based paint (LBP) survey of the concrete check structure and concrete culvert located on the Colorado

River Indian Reservation, in La Paz County, Arizona. We understand that the US Bureau of

Indian Affairs (BIA) has asked that the structures be tested for asbestos and lead-based paint, in preparation for demolition or repair.

Asbestos Survey The asbestos survey field work was conducted on September 5, 2023 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 eight bulk samples were collected for asbestos analysis, which represented three unique homogenous areas (HAs) of building material. The approximate locations of these eight bulk asbestos samples are shown on Figure 2. 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.

LBP Survey The LBP survey field work was conducted on September 5, 2023 by Mr. Lewallen of

Ninyo & Moore. Mr. Lewallen is trained and USEPA-Certified as an LBP Inspector/Risk

Assessor for all USEPA-Administered States, Tribes and Territories, which includes Arizona.

Copies of the inspector’s USEPA certifications are provided in Appendix A.

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 | October 5, 2023 2

Ninyo & Moore’s LBP survey was conducted using a handheld Niton XLp 300A X-ray

Fluorescence (XRF) analyzer, manufactured by Thermo Scientific Portable Analytical

Instruments. A total of seven XRF readings were collected from various painted components along the concrete check structure and concrete culvert. Two of the XRF readings were equal to or greater than the USEPA and Housing and Urban Development threshold standard for LBP by area of 1.0 mg/cm2. Results of the XRF testing performed are summarized in Table 2.

The areas considered to contain LBP include:

• White painted (with a red undercoating) metal framing of the western end of the main vault, (1.40 mg/cm2 lead content); and

• White painted vertical I-beam framing of the eastern end of the main vault (5.30 mg/cm2 lead content).

If these LBP components require removal or significant surface preparation for refinishing, then

Ninyo & Moore recommends that lead renovator or lead abatement trained workers be employed to remove the LBP components intact, or remove these LBP coatings from the metal substrates by chemical means. Prompt and thorough cleanup, and composite sampling of the

LBP debris should be conducted, with laboratory analysis for lead by Toxicity Characteristic

Leachate Procedure (TCLP), to assess if the debris is Toxic Lead Hazardous Waste.

A copy of this ACM and LBP survey report should be made available to the lead abatement contractor, general contractor, and any other trades involved in the abatement or renovation of the structures. If additional suspect ACMs or LBPs are discovered during the renovation, then

Ninyo & Moore should be contacted for further assessment and sampling before proceeding with renovation that would otherwise disturb these untested materials.

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 | October 5, 2023 3

1 INTRODUCTION

Ninyo & Moore performed an asbestos-containing material (ACM) and lead-based paint (LBP) survey of a concrete check structure and concrete culvert located on the Colorado River Indian

Reservation, in La Paz County, Arizona (the Site). The survey was performed by a

Ninyo & Moore staff member trained as an Asbestos Hazard Emergency Response Act

(AHERA) Building Inspector, and USEPA-Certified LBP Inspector and Risk Assessor. 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 concrete check structure and concrete culvert located on the Colorado River Indian Reservation 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 concrete check structure and concrete culvert. 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, if present.

Ninyo & Moore performed the following scope of services:

• Visual assessment of the concrete check structure and concrete culvert 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.

• The bulk samples collected 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, La Paz County, Arizona | 607351002 | October 5, 2023 4

3 ASBESTOS SURVEY

The asbestos survey field work was completed on September 5, 2023 by

Mr. Christian Lewallen, Senior Project Geologist of Ninyo & Moore, with eight 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 homogeneous areas (HAs) associated with the concrete check structure and concrete culvert. 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. No friable surfacing or thermal system insulation HAs were identified during our asbestos survey.

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 Figure 2. A total of eight bulk samples were collected for asbestos analysis.

3.2 Asbestos Laboratory Analyses

Bulk samples collected of suspect ACM were hand carried by the inspector 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

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 | October 5, 2023 5 analyzed for the presence and quantification of asbestos fibers, using Polarized Light

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 eight 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.

3.4 Asbestos Conclusions and Recommendations

No ACMs were identified in samples collected from the structures or components scheduled for rehabilitation 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 LBP SURVEY

The following sections describe the LBP Survey methodology, findings, and conclusions and recommendations.

4.1 LBP Survey Methodology

Accessible painted surfaces on the interior and exterior of the structure were screened for lead content with the Niton™ XLp 300A XRF analyzer. The XRF analyzer was operated in accordance with the Performance Characteristic Sheet associated with the instrument. To ensure that the XRF analyzer was working properly and to comply with HUD guidelines, calibration checks were performed before and after operation of the analyzer and every four hours of operation. Calibration readings were taken on the Red, Standard Reference Material paint film developed by the National Institute of Standards and Technology, which has a lead

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 | October 5, 2023 6 content of 1.04 milligram per square centimeter (mg/cm2). The calibration checks were within the acceptable performance range prescribed by the XRF analyzer equipment manufacturer.

HUD and USEPA regulations stipulate painted surfaces containing lead in amounts equal to or greater than 1.0 mg/cm2, or greater than 0.5% by weight, constitute LBP.

4.2 LBP Survey Findings

A total of seven XRF readings were collected from the concrete check structure and concrete culvert structures. Two of the XRF readings were equal to or greater than the USEPA and HUD threshold standard for LBP by area of 1.0 mg/cm2. The areas considered to contain LBP include:

• White painted (with a red undercoating) metal framing of the western end of the main vault, (1.40 mg/cm2 lead content); and

• White painted vertical I-beam framing end of the of the eastern end of the main vault (5.30 mg/cm2 lead content).

Results of all XRF testing performed are summarized in Table 2. Photographs of the LBP materials identified are included in Appendix D.

4.3 LBP Conclusions and Recommendations

If the LBP components identified in this report require removal or significant surface preparation for refinishing, then Ninyo & Moore recommends that lead renovator or lead abatement trained workers be employed to remove the LBP components intact, or remove these LBP coatings from the metal substrates by chemical means.

Regardless of the LBP removal methods employed, prompt and thorough cleanup, and composite sampling of the LBP debris should be conducted, with laboratory analysis for lead by

Toxicity Characteristic Leachate Procedure (TCLP), to determine if the debris must be disposed as Toxic Lead Hazardous Waste.

Ninyo & Moore recommends that a copy of this report be made available to the lead abatement contractor, general contractor, and any other trades involved in the project, and maintained on-site by project personnel during future renovation or demolition activities, to serve as a record of assessment, as required by OSHA for hazard communication to workers.

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 | October 5, 2023 7

5 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, and in situ XRF testing of suspected LBP. The sample locations chosen for bulk sampling and

XRF testing are believed to be representative of the materials and areas evaluated. However, if additional suspect ACMs or LBPs are encountered during renovation or demolition activities, then these materials should be sampled by qualified personnel, and analyzed for asbestos and lead content prior to disturbance.

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.

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, the US Bureau of Indian Affairs, and the

Colorado River Indian Community. Any use or reuse of the findings, conclusions, and/or recommendations of this report by other parties is undertaken at said parties’ sole risk.

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

TABLES

Sample No. HA HA Description Friable

(F, NF)

Misc, Surfacing, TSI

(M, S, T)

Location on Site Approximate

Quantity

(SF/LF/EA)

Asbestos Content

HA-01A NW Section HA-01B West Section HA-01C SW Section HA-02A NE Section HA-02B Middle Section HA-02C SE Section HA-03A Middle Section HA-03B Middle Section

Notes:

EA - Each NE - Northeast

ND - None detected NW - Northwest

SF - Square feet SE - Southeast

LF - Linear feet SW - Southwest

Concrete NF

ND330 SF03 Concrete MNF

M

HA - Homogenous Area

ND

NDConcrete NF

Table 1 - Asbestos Survey Results - Concrete Check Structure and Concrete Culvert, La Paz, Arizona

M 315 SF01

287 SF02

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023 1

Location Component Color Substrate Number of Replications

Test Location Test Date XRF Test

Lead Conc.

(mg/cm2)

LBP?

(Yes/No)

West End Vault Upper Framing White Metal 4 South End 9/5/2023 4 0.00 No

West End Main Vault West End Framing White (Red Undercoating) Metal 2 West End 9/5/2023 5 1.40 Yes

West End Main Vault West Vertical I-Beam White Metal 3 West End 9/5/2023 6 0.00 No East End Main Vault East End Framing White Metal 2 East End 9/5/2023 7 0.00 No East End Main Vault East End Vertical I-Beam White Metal 2 East End 9/5/2023 8 5.30 Yes

Walk Way Framing Brown/White Metal 5 West End 9/5/2023 9 0.00 No Walk Way Hand Rail White Metal 1 Middle 9/5/2023 10 0.00 No

Key

XRF = X=Ray Fluorescence LBP= Lead-based Paint, >1.0 mg/cm2.

mg/cm2 = millgrams per cubic centimeter

Bold - Lead-Based Paint

Table 2 - Lead-Based Paint Inspection Summary Concrete Check Structure and Concrete Culvert, La Paz, Arizona

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023 2

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

FIGURES

Geotechnical & Environmental Sciences Consultants

SITE LOCATION

FIGURE 1

FEET

2,000 4,000

ASBESTOS-CONTAINING MATERIAL AND LEAD BASED PAINT SURVEY

CONCRETE CHECK STRUCTURE AND CONCRETE CULVERT

COLORADO RIVER INDIAN RESERVATION, MARK ROAD AND 10TH AVENUE

LA PAZ COUNTY, ARIZONA

607351002 I 10/23

N

SITE

NOTE: DIMENSIONS, DIRECTIONS AND LOCATIONS ARE APPROXIMATE. I REFERENCE: USGS, 2021.

2A C

M

FI

G U

R

ES

3.

D W

G

/1 8/

A

O B

Geotechnical & Environmental Sciences Consultants

SAMPLE LOCATIONS

FEET

20 400

ASBESTOS-CONTAINING MATERIAL AND LEAD BASED PAINT SURVEY

CONCRETE CHECK STRUCTURE AND CONCRETE CULVERT

COLORADO RIVER INDIAN RESERVATION, MARK ROAD AND 10TH AVENUE

LA PAZ COUNTY, ARIZONA

607351002 I 10/23

FIGURE 2

N

1F

IG

U R

ES

.d w g

5/

/2

A O

B

NOTE: DIMENSIONS, DIRECTIONS AND LOCATIONS ARE APPROXIMATE. | REFERENCE: GOOGLE EARTH 2023.

LEGEND

ASBESTOS SAMPLE LOCATIONHA-3B

LEAD BASED PAINT LOCATION

SITE BOUNDARY

HA-01A

HA-01B HA-03A HA-03B HA-02A

HA-02B

HA-01C

HA-02C

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

Appendix A

Photographic Documentation

APPENDIX A

Certifications

Christian Lewallen

May 12, 2023

ON-4644-9299-051223

12-May-2023

12-May-2024

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

Mark Guatney

March 31, 2023

ON-4644-136-033123

31-Mar-2023

31-Mar-2024

Mark Guatney

March 31, 2023

ON-4651-136-033123

31-Mar-2023

31-Mar-2024

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

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

122305384EMSL 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 09/05/2023 3:37 PM

Analysis Date:Phoenix, AZ 85034 09/07/2023 - 09/08/2023

Collected Date: 09/05/2023

Project: 607351002

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

HA-01A

122305384-0001

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

Non-Fibrous

Homogeneous

Concrete

HA-01B

122305384-0002

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

Non-Fibrous

Homogeneous

Concrete

HA-01C

122305384-0003

None DetectedNon-fibrous (Other)100%Various

Non-Fibrous

Homogeneous

Concrete

HA-02A-Concrete 1

122305384-0004

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Concrete

HA-02A-Concrete 2

122305384-0004A

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

HA-02B

122305384-0005

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

HA-02C

122305384-0006

None DetectedNon-fibrous (Other)100%Various

Non-Fibrous

Homogeneous

Concrete

HA-03A

122305384-0007

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Concrete

HA-03B

122305384-0008

None DetectedNon-fibrous (Other)100%Various

Non-Fibrous

Heterogeneous

Concrete

Analyst(s)

Emma Campbell (3)

Erica Furphy (6)

Jillian Gessner, Asbestos 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

Initial report from: 09/11/2023 16:52:00

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 9/11/2023 1:52 PM

OrderID: 122305384

OrderID: 122305384

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

APPENDIX C

NESHAP Information Summary

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

NESHAP Information Summary

Property Name Concrete Check Structure and Concrete Culvert

Property Address Concrete Check Structure and Concrete Culvert, La Paz County, Arizona

Areas Subject to Survey Concrete Check Structure, Concrete Culvert, and/or precast concrete pipe on the main or lateral canals near Mark Road and 10th Avenue

Property Owner Concrete Check Structure and Concrete Culvert/ Colorado River Indian Tribe

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

Number of Samples Collected 8

Number of Samples Analyzed 8

Date of Inspection 9/5/2023

Dates of Analysis 9/07/2023 – 9/08/2023 AHERA Building Inspectors Chris Lewallen

Inspector Training Provider The Asbestos Institute

Training Cert, Date, Expiration Cert #ON-4644-9299-050222, 05/12/2023, expires 05/12/2024

Description of ACM Identified Location NESHAP Category Quantity

None N/A N/A N/A

Ninyo & Moore | Colorado River Indian Reservation, La Paz County, Arizona | 607351002 R | October 5, 2023

APPENDIX D

Photographs

PHOTOGRAPHS

ASBESTOS-CONTAINING MATERIAL SURVEY ON THE MAIN CANAL

COLORADO RIVER INDIAN RESERVATION, LA PAZ COUNTY, ARIZONA

607351002 | 10/23

FIGURE D-1

Photograph 1: View looking northwest of the concrete check structure (homoge-nous area HA-03).

Photograph 2: View looking northeast at the culvert and check structures.

COLORADO RIVER INDIAN RESERVATION, LA PAZ COUNTY, ARIZONA

FIGURE D-2

Photograph 3: View looking southeast at the culvert and check structures.

Photograph 4: Asbestos sample location HA-01B.

COLORADO RIVER INDIAN RESERVATION, LA PAZ COUNTY, ARIZONA

FIGURE D-3

Photograph 5: Asbestos sample location HA-01C.

Photograph 6: Asbestos sample location HA-02A.

COLORADO RIVER INDIAN RESERVATION, LA PAZ COUNTY, ARIZONA

FIGURE D-4

Photograph 7: Asbestos sample location HA-02B.

Photograph 8: Asbestos sample location HA-02C.

COLORADO RIVER INDIAN RESERVATION, LA PAZ COUNTY, ARIZONA

FIGURE D-5

Photograph 9: Photo of identified LBP location on the western portion of the struc-ture framing.

Photograph 10: Photo of identified LBP location of the vertical beam on the western portion of the structure framing.

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

ARIZONA | CALIFORNIA | COLORADO | NEVADA | TEXAS | UTAH

ninyoandmoore.com https://ninyoandmoore.com/

CONTENTS
EXECUTIVE SUMMARY
Asbestos Survey
LBP Survey
1 INTRODUCTION
2 PURPOSE AND SCOPE OF SERVICES
3 ASBESTOS SURVEY
3.1 Asbestos Sample Collection and Visual Survey
3.2 Asbestos Laboratory Analyses
3.3 Asbestos Analytical Results
3.4 Asbestos Conclusions and Recommendations
4 LBP SURVEY
4.1 LBP Survey Methodology
4.2 LBP Survey Findings
4.3 LBP Conclusions and Recommendations
5 LIMITATIONS
TABLES
TABLE 1
TABLE 2
FIGURES
FIGURE 1 - SITE LOCATION
FIGURE 2 - SAMPLE LOCATIONS
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D

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