BIA_Chinle_Land_Transfers_Phase_II_ESA_11-2022.pdf

PHASE II ENVIRONMENTAL SITE ASSESSMENT REPORT

Bureau of Indian Affairs Chinle Land Transfers Chinle, Apache County, Arizona

November 2022

Prepared For:

Bureau of Indian Affairs

301 W. Hill Avenue

Gallup, NM 87301

Prepared By:

1812 Schofield Lane

Farmington, NM 87401 iina ba, Inc. Project No.: 22-52-03 Contract No.: 140A0922P0041 http://www.iin%C3%A1b%C3%A1.com/

Phase II Environmental Site Assessment Report Chinle Land Transfers – Chinle, Apache County, Arizona i

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...................................................................................................... I

1.0 INTRODUCTION

1.1 SUMMARY OF RECS ASSESSED

1.2 DEFINITIONS

2.0 DESCRIPTION OF ASSESSMENT ACTIVITIES PERFORMED

2.1 BULK SAMPLE COLLECTION FOR ACBM

2.2 BULK SAMPLE COLLECTION FOR LBP

2.3 HAZARDOUS CHEMICALS

2.4 PETROLEUM HYDROCARBONS

2.5 POLYCHLORINATED BI-PHENOLS (PCBS)

2.6 ILLICIT DUMPING

2.6 IMPROPERLY ABANDONED UTILITIES

3.0 SUMMARY OF ASSESSMENT FINDINGS

4.0 RECOMMENDATIONS

5.0 PROJECT LIMITATIONS

APPENDICES

Appendix 1: Figures

Appendix 2: Tables

Appendix 3: Photographic Documentation

Appendix 4: Laboratory Analytical Reports

Appendix 5: Supporting Documentation i

EXECUTIVE SUMMARY

As requested by the Navajo Regional Office (NRO) of the Bureau of Indian Affairs (BIA) under Contract 140A0922P0041, the performance of a Phase II Environmental Site Assessment was conducted on properties located along Navajo Route 7 (Main Street) in Chinle, Apache County, Arizona (Townships 5N and 32N, Ranges 10 West and 26E, Sections 16 and 29, G.S.R.M), referred to herein as the “subject properties”). The subject properties consist of six (6) separate parcels of land (A-1-1 at 50.618 acres; A-1-2 at 11.431 acres; B-1-2 at 3.930 acres; E-1 at 14.619 acres; G-1 at 1.541 acres, and P-1 at 2.137 acres). iiná bá, Inc, (iiná bá) was retained by the BIA to perform this ESA to confirm various potential hazards associated with the recognized environmental conditions (RECs) previously documented in an ASTM Phase I Environmental Site Assessment (ESA) on the above-referenced properties that may pose risk to human health or the environment. The subject properties are Navajo Trust Lands that are to be relinquished back to the Navajo Nation. This ESA was written in accordance with the requirements of the American Society for Testing and Materials (ASTM) Standard E1903-19.

The following summarizes the recommendations for each parcel based either on the RECs from the Phase I ESA or the results of the Phase II ESA confirmation testing (as applicable):

Parcel A-1-1: Gather all pieces of ACP and transite panels from debris #1 and properly dispose of them at a permitted landfill as a Special Waste.

Gather all illicitly dumped miscellaneous surface debris items and properly dispose of them at a permitted landfill as solid waste.

Parcel A-1-2: Gather all pieces of ACP and properly dispose of them at a permitted landfill as a Special Waste.

Clean up remaining burned trailer and debris from the north end of the former housing area and properly dispose of materials at a permitted landfill or recycled (metal).

Have NTUA properly retire all of the remaining natural gas distribution piping stickups.

Parcel B-1-2: Gather miscellaneous discarded items/debris and dispose of at a permitted landfill as solid waste.

Parcel E-1: Clear and grub parcel of existing mature vegetation and backfill former lagoon cells to surrounding grade, compact, and re-seed/fertilize.

Parcel G-1: Properly abandon the water supply well in accordance with applicable regulations and remove well house structure, concrete, re-grade, and seed.

ii

Remove any past remnants of site development from south end of parcel and dispose or recycle at a permitted facility.

Parcel P-1: Properly abandon the water supply well in accordance with applicable regulations and remove well house structure following abatement of lead-based paint (and treatment shed), concrete, re-grade, and seed.

Remove miscellaneous pipe and any other debris and dispose of at a permitted facility (or recycle).

Estimated costs to perform any recommended cleanup or remediation of RECs cited above are included in Appendix 5. An estimate for the closure of the lagoon cells in Parcel E-1 could not be prepared without knowing calculation variables such as current size of lagoons and the topographic elevation differences between the bottom of the cells and the final desired ground elevation following restoration. Based on current estimates, the closure of these cells can be on the order of at least $500,000.00 or more for the approximately 6.75-acre area.

1.0 INTRODUCTION

As requested by the Navajo Regional Office (NRO) of the Bureau of Indian Affairs (BIA) under Contract 140A0922P0041, the performance of a Phase II Environmental Site Assessment for the six (6) subject parcels was conducted in Chinle, Apache County, Arizona. The assessment efforts were performed between Tuesday, October 25, and Wednesday, October 26, 2022. The assessment consisted of documenting, evaluating, and sampling (as appropriate) of RECs for materials or conditions that were suspected of containing a potential hazardous condition. All work was performed in accordance with iiná bá, Inc. (IBI) Technical Proposal for ASTM Phase I and II Environmental Site Assessments, dated July 15, 2022, and the Site-Specific Health and Safety Plan (HSP) prepared by IBI, dated October 11, 2022.

1.1 Summary of RECs Assessed

The following summarizes the RECs identified on each of the subject parcels and the need to further confirm their existence through sampling/testing.

Parcel A-1-1: Discarded Category II Non-Friable suspected ACBM (cement pipe).

Discarded Category II Non-Friable suspected ACBM (transite panels).

Discarded Category I Non-Friable suspected ACBM (roofing shingles).

Discarded suspected ACBM (wall tape/texture/plaster).

Suspected ACBM (concrete flatwork).

Suspected ACBM (stucco).

Parcel A-1-2: NO RECs identified that required further testing.

Parcel B-1-2: No RECs identified that required further testing.

Parcel E-1: No RECs identified that required further testing.

Parcel G-1: Painted surface of structure with suspected lead-based paint (LBP).

Concrete/masonry flatwork suspected as ACBM.

Parcel P-1: Painted surface of structure with suspected LBP.

Concrete/masonry flatwork suspected as ACBM.

1.2 Definitions

The following definitions apply to the Recognized Environmental Conditions (RECs) covered under this site assessment effort.

Asbestos: includes chrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite or any of these minerals that have been chemically treated or altered.

Asbestos-Containing Material (ACM): includes any building material that contains any one or more of the asbestos minerals in the amount that is greater than 1%.

Category I Non-Friable ACM: materials such as packing, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos fibers.

Category II Non-Friable ACM: materials not covered under Category I that when dry cannot be crumbled, pulverized, or reduced to a power by hand pressure. This can include but is not limited to: asbestos cement siding and shingles, transite panels, and asbestos cement pipe (ACP).

Friable ACM: is defined as any material containing more than 1% asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Lead-Based Paint (LBP): any surface or building material that has been painted or coated with a product that contains greater than 1.0 milligram per square centimeter (mg/Cm2); 0.5%, or 5,000 parts per million (ppm) lead.

Polychlorinated Biphenyls (PCBs): A polychlorinated biphenyl is an organic chlorine compound with the formula C₁₂H10-ₓClₓ. Polychlorinated biphenyls were once widely deployed as dielectric and coolant fluids in electrical apparatus, carbonless copy paper and in heat transfer fluids.

Common items include fluorescent light tube starter ballasts.

Presumed Asbestos-Containing Material (PACM): Thermal System Insulation (TSI) and surfacing material found in buildings constructed before 1981 and floor tile installed in buildings through 1981 may contain asbestos. Although it is unlikely, some flooring installed after 1981 may contain asbestos. Until sampling demonstrates that the material has 1% or less asbestos, it should be considered as a PACM.

2.0 DESCRIPTION OF ASSESSMENT ACTIVITIES PERFORMED

2.1 Bulk Sample Collection for ACBM

In order to determine the presence or absence of suspected asbestos fibers in selected RECs within the affected parcels, bulk samples were collected between Tuesday, October 25, and Wednesday, October 26, 2022. The samples were placed into small Zip-lock baggies, labeled, and submitted with a Chain-of-Custody (COC) record to EMLab P&K (Eurofins) located in Phoenix, Arizona for analysis of asbestos fibers in accordance with Polarizing Light Microscopy by EPA Method 600/R-93-116. The results of this testing are summarized in Table 1 in Appendix 2 and the laboratory analytical report (with COC) are included in Appendix 4. The location of the suspect ACBM samples are shown on the figures in Appendix 1.

2.2 Bulk Sample Collection for LBP

In order to determine the presence or absence of suspected lead on painted surfaces within the affected parcels, bulk samples were collected between Tuesday, October 25, and Wednesday, October 26, 2022. The samples were placed into small Zip-lock baggies, labeled, and submitted with a Chain-of-Custody (COC) record to Green Analytical Laboratories located in Durango, Colorado for analysis of total lead in accordance with EPA Method 6010B. The results of this testing are summarized in Table 2 in Appendix 2 and the laboratory analytical report (with COC) are included in Appendix 4.

2.3 Hazardous Chemicals

No visual evidence of discarded hazardous chemicals was observed during the site reconnaissance of the subject parcels between Tuesday, October 25 and Wednesday, October 26, 2022.

2.4 Petroleum Hydrocarbons

No visual evidence of stained or discolored soils as a result of a release of petroleum-based products was observed during the site reconnaissance of the subject parcels between Tuesday, October 25 and Wednesday, October 26, 2022. There were numerous types of vehicles parked within Parcels A-1-1 and A-1-2 that belonged to local residents that currently reside on these lands. While this condition could become an REC should there be any significant release to the soil beneath a vehicle, the assessment of whether this has actually occurred cannot be accurately assessed until all vehicles are removed to gain full access for visual inspection and possible testing. Should these residents vacate these lands in the future, this assessment can be performed at that time.

2.5 Polychlorinated Bi-Phenols (PCBs)

As cited in the Phase I ESA, several pole and pad-mounted transformers were observed within several of the parcels (A-1-1, A-1-2, and G-1). All of the transformers documented did not contain PCBs with the exception of the pole-mounted transformers on NTUA pole located at the former housing area of Parcel A-1-2. However, visual observations determined that none of these transformers were found to be compromised or have staining signifying a past release of oil.

Therefore, unless one of these transformers becomes damaged, no further action regarding this REC is required. The location of these transformers are shown on the figures in Appendix 1.

2.6 Illicit Dumping

There were several occasions of illicit dumping documented on select parcels with the predominant occurrence happening on Parcel A-1-1. The size and number of items dumped on other parcels (B-1-2, P-1) are small in comparison. Suspect materials identified within the debris piles on Parcel A-1-1 were evaluated under the assessment activities cited in Section 2.1. Most of the items discarded appear to be related to household use (building materials, discarded belongings, scrap metal items, and burned items/debris). No industrial, commercial, or chemical wastes were observed in any of the piles. Many of these were dumped in areas of storm water runoff or drainage features which can result in affecting the quality of the stormwater runoff leaving the subject parcels. Therefore, these occurrences are considered an REC, but do not require further assessment. See photographs in Appendix 3 as reference, with the location of the largest dumpsites shown on the figures in Appendix 1.

2.6 Improperly Abandoned Utilities

The improper abandonment of certain utilities can be considered an REC is they have the ability of affect the human population or the environment. There are two (2) out-of-service drinking water supply wells located on parcels G-1 and P-1. The supply well on parcel G-1 is old and has been inactive for quite some time. The current well casing is open at ground level and a static water level can be seen a few tens of feet below ground level. Given this condition, the open well is an active conduit directly to the groundwater that was being used as a drinking water source and is potentially at risk unless the well is properly abandoned in accordance with applicable regulations (seal by grouting to surface and removing structure). The well on Parcel P-1 has a better current condition in that the well casing has a metal plate welded to the top such that the well is sealed.

However, with the well bore remaining open beneath the plate, this is also not a proper abandonment method. This well should also be properly abandoned and the structure(s) removed in order to better protect the groundwater environment.

The other recognized utility that has not been properly abandoned (retired) is the former natural gas distribution network that once serviced the residential and other structures located on the northern side of Parcel A-1-2. Numerous gas service lines are present about 12 inches above grade with a small cap on the pipe that was once connected to a gas meter. It has been our experience during previous tribal demolition contracts that this was a short-cut to proper retirement when a structure was removed and that these occurrence are likely to still be under pressure with gas if the nearby domestic curb stops or main service line disconnections were not made. Local residents have marked these identified location with various objects to prevent them from being hit or damaged. It is strongly believed that if one were to become damage, there would be a natural gas leak that could threaten human life. A representative photograph of this occurrence is included in Appendix 3. All of these occurrences should be properly abandoned (retired) in accordance with NTUA requirements (NTUA Natural Gas Program completes the retirement). The location of many of these occurrences are shown on the figure in Appendix 1.

3.0 SUMMARY OF ASSESSMENT FINDINGS

Based on the results of this Phase II Environmental Site Assessment, the following summarizes the findings:

There are several occurrences of discarded cement pipe that contain asbestos fibers on Parcels A-1-1 and A-1-2.

None of tested suspect building materials from the various debris piles or structures on Parcels A-1-1, G-1, or P-1 contain asbestos fibers, with the exception of a few pieces of transite panel siding in debris area #1.

The lead on the abandoned pump house structure located on Parcel P-1 contains a lead concentration that exceeds the 5,000 mg/Kg threshold indicating it is lead-based paint.

There are several areas of elicit dumping on various parcels that should be addressed to prevent them from being a threat to human health or the environment.

There are several transformers on various parcels that predominantly do not contain PCBs, with the exception of Parcel A-1-2. However, these transformers do not currently pose a threat to human health or the environment.

There are two (2) out-of-service water supply wells on Parcels G-1 and P-1 that currently pose a threat to the environment from not being properly abandoned; and, There are numerous out-of-service natural gas connections on Parcel A-1-2 that currently pose a threat to human health from not being properly abandoned (retired).

4.0 RECOMMENDATIONS

Based on the performance of this Phase II Environmental Site Assessment, the following recommendations are offered for each of the subject parcels.

Parcel A-1-1: Gather all pieces of ACP and transite panels from debris #1 and properly dispose of them at a permitted landfill as a Special Waste.

Gather all illicitly dumped miscellaneous surface debris items and properly dispose of them at a permitted landfill as solid waste.

Parcel A-1-2: Gather all pieces of ACP and properly dispose of them at a permitted landfill as a Special Waste.

Clean up remaining burned trailer and debris from the north end of the former housing area and properly dispose of materials at a permitted landfill or recycled (metal).

Have NTUA properly retire all of the remaining natural gas distribution piping stickups.

Parcel B-1-2: Gather miscellaneous discarded items/debris and dispose of at a permitted landfill as solid waste.

Parcel E-1: Clear and grub parcel of existing mature vegetation and backfill former lagoon cells to surrounding grade, compact, and re-seed/fertilize.

Parcel G-1: Properly abandon the water supply well in accordance with applicable regulations and remove well house structure, concrete, re-grade, and seed.

Remove any past remnants of site development from south end of parcel and dispose or recycle at a permitted facility.

Parcel P-1: Properly abandon the water supply well in accordance with applicable regulations and remove well house structure after abatement of lead-based paint (and treatment shed), concrete, re-grade, and seed.

Remove miscellaneous pipe and any other debris and dispose of at a permitted facility (or recycle).

5.0 PROJECT LIMITATIONS

This report is for the exclusive use of the BIA for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of iiná bá’ or the BIA. Reliance on this report by the BIA and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report and iiná bá’s Agreement for Services. The limitations of liability defined in iiná bá’s proposal is the aggregate limit of iiná bá’s liability to the BIA.

This Project was performed using, as a minimum, practices consistent with standards acceptable within the industry at this time, and a level of diligence typically exercised by industrial hygiene and environmental consultants performing similar services.

The procedures used in this assessment effort attempt to establish a balance between the competing goals of limiting investigative and reporting costs and time, and reducing the uncertainty about unknown conditions. Therefore, because the findings of this report were derived from the scope, costs, time, and other limitations, the conclusions should not be construed as a guarantee that all environmental or occupational hazards have been identified and fully evaluated. Where sample collection and testing have been performed, iiná bá’s professional opinions are based in part on the interpretation of data from discrete sampling locations that may not represent conditions at non-sampled locations. Areas inaccessible to iiná bá’ are to be assumed as asbestos containing until such time access is achieved and the appropriate testing of suspect materials is performed. Iiná bá assumes no responsibility for omissions or errors resulting from inaccurate information, or data, provided by sources outside of iiná bá or from omissions or errors in public records.

Furthermore, it is emphasized that the final decision on how much risk to accept always remains with the client since Iiná bá is not in a position to fully understand all of the client's needs. Clients with a greater aversion to risk may want to take additional actions while others, with less aversion to risk, may want to take no further action.

WaterWastewaterSolid WasteRoadsStormwaterSubdivisionsSurveyingGIS

HydrologyAir QualityESASoil InvestigationsSPCCWater RightsLUST

PREPARED FOR:

BUREAU OF INDIAN AFFAIRS

DIVISION OF ENVIRONFMENTAL MANAGEMENT

301 WEST HILL STREET

GALLUP, NEW MEXICO 87301

SCALE: 1 INCH ≅ 470 FEET

iiná bá Project No.: 22-052-03 BIA Contract No.: 140A0922P0041

N

FIGURE 1: SITE LAYOUT MAP

PARCELS A-1-1 AND A-1-2

BUREAU OF INDIAN AFFAIRS LAND TRANSFERS

CHINLE, APACHE COUNTY, ARIZONA

PARCEL LIMITS (APPROXIMATE)

PHOTOGRAPH WITH NUMBER WITH

LOCATION (SEE APPENDIX 3)

EXPLANATION

SOURCE: GOOGLE EARTH IMAGE 6/2017

PARCEL A-1-1

PARCEL A-1-2

CHINLE #2 NTUA CENTER WELL

CHINLE #3 NTUA SOUTH WELL

2, 3, 4

5, 6

9 8

12, 13

14 15, 16

28 27

29, 30 31, 32, 33

48, 49

51 50

SCALE: 1 INCH ≅ 114 FEET

PARCEL B-1-2

BUREAU OF INDIAN AFFAIRS LAND TRANSFERS

CHINLE, APACHE COUNTY, ARIZONA

PARCEL LIMITS (APPROXIMATE)

PHOTOGRAPH LOCATION WTH

NUMBER (SEE APPENDIX 3)

1, 3

SCALE: 1 INCH ≅ 205 FEET

PARCEL E-1

BUREAU OF INDIAN AFFAIRS LAND TRANSFERS

CHINLE, APACHE COUNTY, ARIZONA

PARCEL LIMITS (APPROXIMATE)

PHOTOGRAPH LOCATION WITH

NUMBER (SEE APPENDIX 3)

1, 2, 3

SCALE: 1 INCH ≅ 135 FEET

BIA Contract No.: 140A0922P0041

N

FIGURE 1: SITE LAYOUT MAP

PARCELS P-1 AND G-1

BUREAU OF INDIAN AFFAIRS LAND TRANSFERS

CHINLE, APACHE COUNTY, ARIZONA

PARCEL LIMITS (APPROXIMATE)

PHOTOGRAPH LOCATION WITH

NUMBER (SEE APPENDIX 3)

EXPLANATION

SOURCE: GOOGLE EARTH IMAGE 6/2017

PARCEL G-1

PARCEL P-1

CHINLE #3 WELL

6, 7

2 4

16, 17

PREPARED FOR:

BUREAU OF INDIAN AFFAIRS

DIVISION OF ENVIRONFMENTAL MANAGEMENT

TABLE 1: SUMMARY OF SUSPECT BULK MATERIAL SAMPLE LOCATIONS

BIA CHINLE LAND TRANSFERS

Chinle, Apache County, Arizona iina ba , Inc. Project No.: 22-052-03

Building/Sample No. Wall Code Bulk Sample Material Interior/Exterior Functional Space Condition1 Color Substrate Results Misc. Debris Pile - Roofing NA Shingle Exterior Debris Pile Poor Black/Gray NA ND Pump House P-1 Concrete A Concrete Interior Pump House Fair Gray NA ND Misc. Debris Pile - Plaster NA Plaster Exterior Debris Pile Poor White NA ND Misc. Debris Pile - Siding NA Transite Panel Exterior Debris Pile Fair Gray/Green NA 4%/4%* Misc. Debris Pile 2 - Stucco NA Stucco Exterior Debris Pile Por White NA ND Pump House G-1 Concrete A Concrete Interior Pump House Fair Gray NA ND Footnotes:

1 - Condition represents either the condition of the "parent" bulk material sample (e.g. , floor tile) or the associated material such as a mastic, glue, or adhesive if sampled independent from the parent material.

NA - Not applicable.

ND - Non detect.

* - Positive detection for asbestos included Chrysotile/Crocidolite.

TABLE 2: LEAD-BASED PAINT CHIP SCREENING ANALTICAL RESULTS

BIAN CHINLE LAND TRANFERS

Chinle, Apache County, Arizona iina ba , Inc. Project No.: 22-052-03

Sample No. Date & Time Floor Room Component Wall Code Condition Color Concentration Units

P-1 Pump House 10/26/2022 11:15 First Main Wooden Siding A Poor Tan 1,100 mg/Kg

G-1 Pump House 10/26/2022 10:30 First Main Cinder Block B Poor Blue 42,500 mg/Kg

FOOTNOTES:

Entries in red exceed the regulatory limit of 5,000 mg/Kg and are considered lead-based paint.

PREPARED FOR:

BUREAU OF INDIAN AFFAIRS

DIVISION OF ENVIRONFMENTAL MANAGEMENT

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 1

PHOTOGRAPHIC DOCUMENTATION

OF

RECOGNIZED ENVIRONMENTAL CONDITOINS

Bureau of Indian Affairs Parcels A-1-1, A-1-2, B-1-2, E-1, G-1, and P-1

Chinle, Apache County, Arizona

Photographed By: John R. Isham (iiná bá, Inc.)

Photograph Period: Tuesday, October 25 and Wednesday, October 26, 2022

Project No.: 22-052-03

Contract Owner: Bureau of Indian Affairs – Branch of Environmental Management

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 2

Photograph 1: View of asbestos cement pipe on slope below NTUA water tanks on Parcel A-1-1.

Photograph 2: View of miscellaneous elicit dumping of debris on Parcel A-1-1.

Photograph 3: View of another elicit dumping area with miscellaneous debris on Parcel A-1-1

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 3

Photograph 4: View of third elicit dumping of miscellaneous debris on Parcel A-1-1.

Photograph 5: View of discarded truck tires on Parcel A-1-1.

Photograph 6: View of concrete debris discarded on slope below NTUA water tanks on Parcel A-1-1.

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 4

Photograph 7: View of discarded steel pipe on ground within Parcel A-1-2.

Photograph 8: View of discarded asbestos cement pipe on ground within Parcel A-1-2.

Photograph 9: View of another discarded section of asbestos cement pipe on ground within Parcel A-1-2.

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 5

Photograph 10: View of yet another discarded section of asbestos cement pipe on Parcel A-1-2.

Photograph 11: View of remnants of burned modular structure on Parcel A-1-2.

Photograph 12: View of one of several NTUA natural gas service distribution lines on Parcel A-1-2.

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 6

Photograph 13: View of elicit dumping of miscellaneous debris (#1) on Parcel A-1-1.

Photograph 14: View of elicit dumping of miscellaneous debris (#2) on Parcel A-1-1.

Photograph 15: View of elicit dumping of miscellaneous debris (#3) on Parcel A-1-1.

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 7

Photograph 16: View of another elicit dumping of miscellaneous debris (#4) on Parcel A-1-1.

Photograph 17: View of elicit dumping of miscellaneous debris (#5) on Parcel A-1-1.

Photograph 18: View of improperly abandoned water supply well on Parcel G-1.

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 8

Photograph 19: View of improperly abandoned water supply well on Parcel P-1.

Photograph 20: View of discarded metal pipe on Parcel P-1.

Photograph 21: View of discarded traffic delineator panel on Parcel B-1-2..

ASTM Phase II Environmental Site Assessment – BIA Land Transfers, Chinle, Apache County, Arizona Page 9

Photograph 22: View of discarded stone and asphalt waste on Parcel B-1-2.

Photograph 23: View of discarded miscellaneous NTUA overhead power pole components on Parcel B-1-2.

PREPARED FOR:

BUREAU OF INDIAN AFFAIRS

DIVISION OF ENVIRONFMENTAL MANAGEMENT

75 Suttle Street

Durango, CO 81303

970.247.4220 Phone

970.247.4227 Fax

www.greenanalytical.com iina ba, Inc

RE: Total Lead

Farmington, NM 87401

1812 Schofield Lane

John R Isham

Jeremy D Allen

Laboratory Director

Enclosed are the results of analyses for samples received by the laboratory on 10/28/22 10:45. The data to follow was performed, in whole or in part, by Green Analytical Laboratories. Any data that was performed by a subcontract laboratory is included within the GAL report, or with an additional report attached.

If you need any further assistance, please feel free to contact me.

Sincerely, 07 November 2022

All accredited analytes contained in this report are denoted by an asterisk (*). For a complete list of accredited analytes please do not hesitate to contact us via any of the contact information contained in this report. All of our certifications can be viewed at http://greenanalytical.com/certifications/

Green Analytical Laboratories is NELAP accredited through the Texas Commission on Environmental Quality. Accreditation applies to drinking water and non-potable water matrices for trace metals and a variety of inorganic parameters. Green Analytical Laboratories is also accredited through the

Colorado Department of Public Health and Environment and EPA region 8 for trace metals, Cyanide, Fluoride, Nitrate, and Nitrite in drinking water.

TNI Certificate Number: T104704514-22-15

Our affiliate laboratory, Cardinal Laboratories, is also NELAP accredited through the Texas Commission on Environmental Quality for a variety of organic constituents in drinking water, non-potable water and solid matrices. Cardinal is also accredited for regulated VOCs, TTHM, and HAA-5 in drinking water through the Colorado Department of Public Health and Environment and EPA region 8. TNI Certificate Number: T104704398-22-15

Page 1 of 6 2210256 GAL FINAL 11 07 22 1438 11/07/22 14:38:33

Project:

Project Name / Number:

Project Manager:

Reported:

iina ba, Inc

1812 Schofield Lane BIA Chinle Land Transfer

John R Isham

Total Lead

11/07/22 14:38Farmington NM, 87401 jeremy.allen@greenanalytical.com p: 970.247.4220 f: 970.247.4227 75 Suttle Street Durango, CO 81303 www.GreenAnalytical.com

Sample ID Laboratory ID Date Sampled

ANALYTICAL REPORT FOR SAMPLES

Date ReceivedMatrix Notes

P-1 Pump House 2210256-01 Solid 10/26/22 11:15 10/28/22 10:45

G-1 Pump House 2210256-02 Solid 10/26/22 10:30 10/28/22 10:45

Jeremy D Allen, Laboratory Director

Green Analytical Laboratories The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. In no event shall Green Analytical Laboratories be liable for incidental or consequential damages.

GALs liability, and clients exclusive remedy for any claim arising, shall be limited to the amount paid by client for analyses. All claims, including those for negligence and any other cause whatsoever, shall be deemed waived unless made in writing and received within thirty days after completion of the applicable service.

Page 2 of 6 2210256 GAL FINAL 11 07 22 1438 11/07/22 14:38:33

Project Manager:

Reported:

iina ba, Inc

1812 Schofield Lane BIA Chinle Land Transfer

John R Isham

Total Lead

11/07/22 14:38Farmington NM, 87401 jeremy.allen@greenanalytical.com p: 970.247.4220 f: 970.247.4227 75 Suttle Street Durango, CO 81303 www.GreenAnalytical.com

ResultAnalyte RL Analyzed Method Notes DilutionUnits

P-1 Pump House

2210256-01 (Other)

AnalystMDL

Total Metals by ICP

11/04/22 16:07100 mg/kg dry 1000 6010B AES1110 40.2Lead

Jeremy D Allen, Laboratory Director

Green Analytical Laboratories The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. In no event shall Green Analytical Laboratories be liable for incidental or consequential damages.

GALs liability, and clients exclusive remedy for any claim arising, shall be limited to the amount paid by client for analyses. All claims, including those for negligence and any other cause whatsoever, shall be deemed waived unless made in writing and received within

Page 3 of 6 2210256 GAL FINAL 11 07 22 1438 11/07/22 14:38:33

Project Manager:

Reported:

iina ba, Inc

1812 Schofield Lane BIA Chinle Land Transfer

John R Isham

Total Lead

11/07/22 14:38Farmington NM, 87401 jeremy.allen@greenanalytical.com p: 970.247.4220 f: 970.247.4227 75 Suttle Street Durango, CO 81303 www.GreenAnalytical.com

ResultAnalyte RL Analyzed Method Notes DilutionUnits

G-1 Pump House

2210256-02 (Other)

AnalystMDL

Total Metals by ICP

11/04/22 16:171000 mg/kg dry 10000 6010B AES42500 402Lead

Jeremy D Allen, Laboratory Director

Green Analytical Laboratories The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. In no event shall Green Analytical Laboratories be liable for incidental or consequential damages.

GALs liability, and clients exclusive remedy for any claim arising, shall be limited to the amount paid by client for analyses. All claims, including those for negligence and any other cause whatsoever, shall be deemed waived unless made in writing and received within

Page 4 of 6 2210256 GAL FINAL 11 07 22 1438 11/07/22 14:38:33

Project Manager:

Reported:

iina ba, Inc

1812 Schofield Lane BIA Chinle Land Transfer

John R Isham

Total Lead

11/07/22 14:38Farmington NM, 87401 jeremy.allen@greenanalytical.com p: 970.247.4220 f: 970.247.4227 75 Suttle Street Durango, CO 81303 www.GreenAnalytical.com

Result Limit

Reporting

Units Level

Spike

Result

Source

%REC

%REC

Limits RPD

RPD

Limit Notes Analyte

Total Metals by ICP - Quality Control

Batch B223056 - EPA 3050

Prepared: 11/03/22 Analyzed: 11/04/22 Blank (B223056-BLK1)

Lead ND 10.0 mg/kg dry

Prepared: 11/03/22 Analyzed: 11/04/22 LCS (B223056-BS1)

Lead 187 10.0 200 80-12093.4mg/kg dry

Prepared: 11/03/22 Analyzed: 11/04/22 LCS Dup (B223056-BSD1)

Lead 184 10.0 200 2080-12092.0 1.52mg/kg dry

Notes and Definitions

DET

Sample results reported on a dry weight basis

Relative Percent DifferenceRPD dry

Not ReportedNR

Analyte NOT DETECTED at or above the reporting limitND

Analyte DETECTED

*Results reported on as received basis unless designated as dry.

Laboratory Control Sample (Blank Spike)LCS

RL

MDL

Report Limit

Method Detection Limit

Jeremy D Allen, Laboratory Director

Green Analytical Laboratories The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety. In no event shall Green Analytical Laboratories be liable for incidental or consequential damages.

GALs liability, and clients exclusive remedy for any claim arising, shall be limited to the amount paid by client for analyses. All claims, including those for negligence and any other cause whatsoever, shall be deemed waived unless made in writing and received within

Page 5 of 6 2210256 GAL FINAL 11 07 22 1438 11/07/22 14:38:33

Page 6 of 6 2210256 GAL FINAL 11 07 22 1438 11/07/22 14:38:33

Approved by:

Approved Signatory Renee Luna-Trepczynski

Report for:

John R. Isham iina' ba', Inc.

1812 North Schofield Lane PO Box 2606 Farmington, NM 87401

Regarding:

Eurofins Aerotech Built Environment Testing, Inc.

Project: 22-052-03; BIA Land Transfers

EML ID: 3069351

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received and tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

Eurofins Aerotech Built Environment Testing, Inc. ("the Company"), a member of the Eurofins Built Environment Testing group of companies, shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 11-01-2022

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267) NVLAP Lab Code 500031-0

EMLab ID: 3069351, Page 1 of 4Eurofins Aerotech Built Environment Testing, Inc.

Eurofins Aerotech Built Environment Testing, Inc.

1501 West Knudsen Drive, Phoenix, AZ 85027

(800) 651-4802 www.eurofinsus.com/Built Client: iina' ba', Inc.

C/O: John R. Isham Re: 22-052-03; BIA Land Transfers

Date of Sampling: 10-26-2022 Date of Receipt: 10-27-2022 Date of Report: 11-01-2022

ASBESTOS PLM REPORT

Total Samples Submitted: 9 Total Samples Analyzed: 9

Total Samples with Layer Asbestos Content > 1%: 2

Location: 1, Miscellaneous Debris Pile-Roofing Lab ID-Version‡: 14807825-1

Sample Layers Asbestos Content Black Roofing Shingle with Brown Pebbles ND

Composite Non-Asbestos Content: 15% Glass Fibers Sample Composite Homogeneity: Moderate

Location: 2, Pump House P-1 Concrete Lab ID-Version‡: 14807826-1

Sample Layers Asbestos Content Gray Concrete ND

Sample Composite Homogeneity: Moderate

Location: 3, Miscellaneous Debris Pile-Plaster Lab ID-Version‡: 14807827-1

Sample Layers Asbestos Content White Drywall with Brown Paper ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Moderate

EMLab ID: 3069351, Page 2 of 4Eurofins Aerotech Built Environment Testing, Inc.

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".

(800) 651-4802 www.eurofinsus.com/Built Client: iina' ba', Inc.

C/O: John R. Isham Re: 22-052-03; BIA Land Transfers

Date of Sampling: 10-26-2022 Date of Receipt: 10-27-2022 Date of Report: 11-01-2022

ASBESTOS PLM REPORT

Location: 4, A-1-1 ACP Lab ID-Version‡: 14807828-1

Sample Layers Asbestos Content Gray Transite 4% Chrysotile

4% Crocidolite Sample Composite Homogeneity: Moderate

Location: 5, Miscellaneous Debris Pile 2-Stucco Lab ID-Version‡: 14807829-1

Sample Layers Asbestos Content Off-White Stucco ND

Composite Non-Asbestos Content: 2% Glass Fibers Sample Composite Homogeneity: Moderate

Location: 6, Pump House G-1 Concrete Lab ID-Version‡: 14807830-1

Sample Layers Asbestos Content Gray Concrete ND

Sample Composite Homogeneity: Moderate

EMLab ID: 3069351, Page 3 of 4Eurofins Aerotech Built Environment Testing, Inc.

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(800) 651-4802 www.eurofinsus.com/Built Client: iina' ba', Inc.

C/O: John R. Isham Re: 22-052-03; BIA Land Transfers

Date of Sampling: 10-26-2022 Date of Receipt: 10-27-2022 Date of Report: 11-01-2022

ASBESTOS PLM REPORT

Location: 7, A-1-2 Pipe Wrap Lab ID-Version‡: 14807831-1

Sample Layers Asbestos Content Tan Wrap 60% Chrysotile Composite Non-Asbestos Content: 5% Cellulose Sample Composite Homogeneity: Good

Location: 8, BIA #135-Roofing Lab ID-Version‡: 14807832-1

Sample Layers Asbestos Content Black Roofing Shingle with Tan Pebbles ND

Black Roofing Mastic ND Composite Non-Asbestos Content: 12% Glass Fibers

2% Cellulose Sample Composite Homogeneity: Moderate

Location: 9, Miscellaneous Debris Pile-Transite Lab ID-Version‡: 14807833-1

Sample Layers Asbestos Content Gray Fiberboard ND

Composite Non-Asbestos Content: 30% Cellulose Sample Composite Homogeneity: Good

EMLab ID: 3069351, Page 4 of 4Eurofins Aerotech Built Environment Testing, Inc.

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is