BIA_Eastern_Agency_Debris_Pile_Sampling_Letter_Report_4-2023_(1).pdf

DEBRIS PILE CHARACTERIZATION REPORT

Bureau of Indian Affairs Eastern Agency Roads Crownpoint, McKinley County, New Mexico

April 2023

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.: 23-022-03 Contract No.: NA

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION | TRANSPORTATION

Maintaining Harmony Between Man and His Environment iiná bá, Inc. 1812 Schofield Lane, Farmington, NM 87401 PO Box 2606 Farmington, NM 87499

Phone: (505) 327-1072 Fax: (505) 327-1517 www.iinaba.com

April 10, 2023

Ms. George Padilla – Regional Environmental Scientist Bureau of Indian Affairs – Navajo Regional Office P. O. Box 1060 Gallup, NM 87305-1060

RE: Debris Pile Characterization Report BIA Eastern Agency Roads Yard Navajo Route 9 Crownpoint, McKinley County, New Mexico iiná bá, Inc. Project No. 23-022-03

Dear Ms. Padilla:

iiná bá, Inc. (IBI), at the request of the Bureau of Indian Affairs (BIA), Navajo Regional Office (NRO), conducting a hazardous materials characterization of a debris pile located at the above-referenced facility located in Crownpoint, NM (see Site Layout Map attached). We understand that the subject material was generated at another location that was originally planned for disposal at a landfill when the landfill operator refused to accept the material that had not been characterized for the presence or absence of hazardous building materials such as asbestos-containing materials (ACM) or lead-based painted (LBP) materials. It was the intent of our characterization to determine whether these hazardous materials were actually present in the subject debris pile. Our efforts were conducted in accordance with our Technical Proposal for Debris Screening and Disposal, dated March 10, 2023.

On Friday, March 31, 2023, IBI inspected the subject debris pile to investigate the potential for hazardous building materials to be mixed within the debris. Typical items searched for included flooring materials, mastics, caulking, glazing, TSI, roofing materials, wall materials, etc. When identified, a small portion of the material was extracted from the pile and placed into a small zip-lock baggie and labeled with material type. Photographs of the debris pile were also obtained and are attached to this report.

The bulk materials were submitted under the appropriate Chain-of-Custody (COC) procedures to EMLab P&K located in Phoenix, Arizona for asbestos fiber analysis in accordance with USEPA Method 600- R93/116. A total of 11 bulk material samples were analyzed for the presence or absence of asbestos fibers. The attached Table 1 summarizes the results. For reference, any material with 1% or greater asbestos fibers is considered an asbestos-containing building material (ACBM) subject to regulations. A copy of the laboratory report of analysis is attached to this report.

In addition, any building material identified with a painted surface was also characterized for the presence or absence of lead in the paint used. Five (5) different colored painted surfaces were readily identified within the debris pile (green, tan, red, white, brown). A small portion of the material was extracted from the pile and placed into a small zip-lock baggie and labeled with paint color. The bulk

ENVIRONMENTAL | ENGINEERING | SURVEYING | CONSTRUCTION | TRANSPORTATION

Maintaining Harmony Between Man and His Environment iiná bá, Inc. 1812 Schofield Lane, Farmington, NM 87401 PO Box 2606 Farmington, NM 87499

Phone: (505) 327-1072 Fax: (505) 327-1517 www.iinaba.com materials were submitted under the appropriate Chain-of-Custody (COC) procedures to EMLab P&K located in Phoenix, Arizona for lead analysis utilizing Flame Atomic Adsorption Spectrophotometry methods. The attached table summarizes the results. A copy of the laboratory report of analysis is attached to this report.

Conclusions

Based on the results of the 11 bulk building material samples analyzed for the presence or absence of asbestos fibers, the following materials were identified as positive for asbestos:

Yellow/cream sheet flooring: 10% Chrysotile Black roofing mastic: 7% Chrysotile

Based on the results of the five (5) bulk building material samples analyzed for the presence or absence of lead, the following paint colors were identified as positive for lead:

None, all lead concentrations in paint were well below the regulatory limit of 5,000 ppm.

iiná bá, Inc. appreciates the opportunity to provide environmental services for the subject site. If you have any questions, please contact me or Duane Aspaas at (505) 327-1072.

Sincerely, iiná bá, Inc.

John R. Isham, CPG Environmental Manager/Senior Hydrogeologist

Attachments: Figure 1 – Site Layout Map Table 1 – Summary of Bulk Samples for Asbestos Fiber Analysis Table 2 – Summary of Bulk Samples for Lead Paint Analysis Photographic Documentation of Well Abandonment Activities Laboratory Report of Analysis – Asbestos Laboratory Report of Analysis – Lead Paint Job Site Safety Meeting Form

Z:\06-Projects\03-Environmental\BIA Navajo Regional Office\23-022-03 Eastern Agency Roads Debris PIle Testing\Padilla BIA Eastern Agency Debris Pile Sampling Letter Report 4-2023.doc

SCALE: 1 INCH ≅ 155 FEET

iiná bá Project No.: 23-022-03 BIA Contract No.: NA

N

FIGURE 1: SITE LAYOUT MAP

DEBRIS PILE CHARACTERIZATION REPORT

BUREAU OF INDIAN AFFAIRS – EASTERN AGENCY ROADS

CROWNPOINT, MCKINLEY COUNTY, NEW MEXICO

DEBRIS PILE LOCATION (APPROXIMATE)

EXPLANATION

SOURCE: GOOGLE EARTH IMAGE 10/2016

TABLE 1: SUMMARY OF BULK SAMPLES FOR ASBESTOS FIBER ANALYSIS

BIA EASTERN AGENCY DEBRIS PILE

Crownpoint, McKinley County, New Mexico iina ba , Inc. Project No.: 23-022-03

Sample Name Wall Code Bulk Sample Material Interior/Exterior Functional Space Condition1 Color Substrate Results Yellow TSI #1 NA Thermal Insulation Interior Unknown Poor Yellow Unknown ND Brown TSI #2 NA Thermal Insulation Interior Unknown Poor Brown Unknown ND White Covebase NA Covebase Interior Unknown Poor White Sheetrock ND Roof Felt #1 NA Roofing Material Exterior Roof Poor Gray Wood ND Wall Board - White NA Wall Material Interior Unknown Poor White Wood ND Wall Board - Gray NA Wall Material Interior Unknown Poor Gray Wood ND Roof Felt #2 NA Roofing Material Exterior Roof Poor Gray Wood ND Gray Covebase NA Covebase Interior Unknown Poor Gray Sheetrock ND Black Roof Mastic NA Roofing Material Exterior Roof Poor Black/Gray Wood 7%* Roof Felt with Mastic NA Roofing Material Exterior Roof Poor Gray/Black Wood ND Sheet Flooring NA Flooring Interior Unknown Poor Yellow/Cream Concrete 10%* 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

TABLE 2: SUMMARY OF BULK SAMPLES FOR LEAD PAINT ANALYSIS

BIA EASTERN AGENCY DEBRIS PILE

Crownpoint, McKinley County, New Mexico iina ba , Inc. Project No.: 23-022-03

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

Green Paint 3/31/2023 0:00 NA NA Wood Board NA Poor Green 390 ppm

Tan Paint 3/31/2023 0:00 NA NA Wood Board NA Poor Tan 400 ppm

Red Paint 3/31/2023 0:00 NA NA Wood Board NA Poor Red <40 ppm

White Paint 3/31/2023 0:00 NA NA Wood Board NA Poor White 600 ppm

Brown Paint 3/31/2023 0:00 NA NA Wood Board NA Poor Brown 570 ppm

FOOTNOTES:

NA - not available.

ppm - parts per million.

Less than symbol (<) indicates compound analyzed for but not detected at indicated quantification limit.

Lead-based paint contains a concentration of 5,000 ppm or greater.

Debris Pile Characterization Report – Eastern Agency Debris Pile, Crownpoint, McKinley County, NM Page 1

PHOTOGRAPHIC DOCUMENTATION OF SITE ACTIVITIES

Bureau of Indian Affairs – Eastern Agency Roads Yard

Crownpoint, McKinley County, New Mexico

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

Photograph Period: Friday, March 31, 2023

BIA Contract: NA

Contract Owner: Bureau of Indian Affairs (Navajo Region Office)

Debris Pile Characterization Report – Eastern Agency Debris Pile, Crownpoint, McKinley County, NM Page 2

Photograph 1: View of debris pile looking west-northwest.

Photograph 2: View of debris pile looking north.

Photograph 3: View of debris pile looking east. Abundant timbers painted white and red

Debris Pile Characterization Report – Eastern Agency Debris Pile, Crownpoint, McKinley County, NM Page 3

Photograph 4: View of debris pile looking southeast.

Photograph 5: Close-up view of debris pile showing variety of items (wood, metal, ceramics, plastics).

Photograph 6: View of unknown gas bottle in debris pile.

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: Debris Pile Characterization; BIA Eastern Agency Debris

EML ID: 3216268

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: 04-05-2023

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: 3216268, 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/BuiltClient: iina' ba', Inc.

C/O: John R. Isham Re: Debris Pile Characterization; BIA Eastern Agency Debris

Date of Sampling: 03-31-2023 Date of Receipt: 04-03-2023 Date of Report: 04-05-2023

ASBESTOS PLM REPORT

Total Samples Submitted: 11 Total Samples Analyzed: 11

Total Samples with Layer Asbestos Content > 1%: 2

Location: 1, Yellow TSI #1 Lab ID-Version‡: 15580537-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 99% Glass Fibers Sample Composite Homogeneity: Good

Location: 2, Brown TSI #2 Lab ID-Version‡: 15580538-1

Sample Layers Asbestos Content Brown Insulation ND

Composite Non-Asbestos Content: 99% Glass Fibers Sample Composite Homogeneity: Good

Location: 3, White Cove Base Lab ID-Version‡: 15580539-1

Sample Layers Asbestos Content White Baseboard ND

Sample Composite Homogeneity: Good

Location: 4, Roof Felt #1 Lab ID-Version‡: 15580540-1

Sample Layers Asbestos Content Black Roofing Felt ND

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

EMLab ID: 3216268, 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/BuiltClient: iina' ba', Inc.

C/O: John R. Isham Re: Debris Pile Characterization; BIA Eastern Agency Debris

Date of Sampling: 03-31-2023 Date of Receipt: 04-03-2023 Date of Report: 04-05-2023

ASBESTOS PLM REPORT

Location: 5, Wallboard White Lab ID-Version‡: 15580541-1

Sample Layers Asbestos Content White Drywall ND

Sample Composite Homogeneity: Good

Location: 6, Wallboard Gray Lab ID-Version‡: 15580542-1

Sample Layers Asbestos Content Gray Fiberboard ND

Composite Non-Asbestos Content: 99% Cellulose Sample Composite Homogeneity: Good

Location: 7, Roof Felt #2 Lab ID-Version‡: 15580543-1

Sample Layers Asbestos Content Brown/Black Roofing Felt ND

Composite Non-Asbestos Content: 40% Cellulose Sample Composite Homogeneity: Good

Location: 8, Gray Cove Base Lab ID-Version‡: 15580544-1

Sample Layers Asbestos Content Gray Baseboard ND

Tan Mastic ND Gray Cementitious Material ND

Sample Composite Homogeneity: Poor

EMLab ID: 3216268, 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/BuiltClient: iina' ba', Inc.

C/O: John R. Isham Re: Debris Pile Characterization; BIA Eastern Agency Debris

Date of Sampling: 03-31-2023 Date of Receipt: 04-03-2023 Date of Report: 04-05-2023

ASBESTOS PLM REPORT

Location: 9, Black Roof Mastic Lab ID-Version‡: 15580545-1

Sample Layers Asbestos Content Gray/Black Roofing Mastic 7% Chrysotile Black Roofing Tar and Felt ND

Composite Non-Asbestos Content: 10% Glass Fibers Sample Composite Homogeneity: Moderate

Location: 10, Roof Felt/Mastic Lab ID-Version‡: 15580546-1

Sample Layers Asbestos Content Black Roofing Tar and Felt ND

Composite Non-Asbestos Content: 25% Glass Fibers Sample Composite Homogeneity: Good

Location: 11, Sheet Flooring Lab ID-Version‡: 15580547-1

Sample Layers Asbestos Content Cream Sheet Flooring with Fibrous Backing 10% Chrysotile

Sample Composite Homogeneity: Good

EMLab ID: 3216268, 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

Approved by:

Laboratory Manager Danny Li

Report for:

John R. Isham iina' ba', Inc.

1812 North Schofield Lane PO Box 2606 Farmington, NM 87401

Regarding:

Eurofins EPK Built Environment Testing, LLC Project: Debri Pile Characterization; Bia Eastern Agency Debirs

EML ID: 3216275

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. Due to the nature of the analyses performed, field blank correction of results is not applied. The results relate only to the samples as received and tested. Sample size, as it relates to Wipe samples only, is supplied by the client.

Eurofins EPK Built Environment Testing, LLC ("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:

Lead - Flame AA: 04-10-2023

Service SOPs: Lead - Flame AA (EM-BC-S-8443) AIHA-LAP, LLC accredited service, Lab ID #178697

Eurofins EPK Built Environment Testing, LLC's LabServe® reporting system includes automated fail-safes to ensure that all AIHA- LAP, LLC quality requirements are met and notifications are added to reports when any quality steps remain pending.

EMLab ID: 3216275, Page 1 of 2Eurofins EPK Built Environment Testing, LLC

Eurofins EPK Built Environment Testing, LLC 2841 Dow Avenue, Suite 300, Tustin, CA 92780

(866) 888-6653 www.eurofinsus.com/BuiltClient: iina' ba', Inc.

C/O: John R. Isham Re: Debri Pile Characterization; Bia Eastern Agency Debirs

Date of Sampling: 03-31-2023 Date of Receipt: 04-03-2023 Date of Report: 04-10-2023

LEAD: FLAME ATOMIC ABSORPTION SPECTROMETRY

Location: 1:

Green Paint 2:

Tan Paint 3:

Red Paint 4:

White Paint 5:

Brown Paint Comments (see below) None None None None None

Lab ID-Version‡: 15579079-1 15579080-1 15579081-1 15579082-1 15579083-1

Analysis Date: 04/10/2023 04/10/2023 04/10/2023 04/10/2023 04/10/2023

Sample type Paint Chip sample Paint Chip sample Paint Chip sample Paint Chip sample Paint Chip sample

Method* NIOSH 7082 & EPA 7000B modified

NIOSH 7082 & EPA

7000B modified

NIOSH 7082 & EPA

7000B modified

NIOSH 7082 & EPA

7000B modified

NIOSH 7082 & EPA

7000B modified

† Method Reporting Limit 39 ppm 40 ppm 40 ppm 40 ppm 40 ppm

Sample size 0.2584 grams 0.2515 grams 0.2509 grams 0.2530 grams 0.2505 grams

§Total Lead Result 390 ppm 400 ppm < 40 ppm 600 ppm 570 ppm

Comments:

EMLab ID: 3216275, Page 2 of 2Eurofins EPK Built Environment Testing, LLC

Sample results have not been corrected for blank values.

Bulk samples are not covered under the AIHA-LAP, LLC service accreditation.

Wipe samples must meet ASTM E1792 criteria. Method Reporting Limits may not be valid for non-ASTM E1792 wipe samples.

*Sample preparation and analytical methods are based upon NIOSH 7082 and EPA 7000B.

† The Method Reporting Limit is the minimum concentration of Lead that the laboratory can confidently detect in the sample.

§ Total Lead Result has been rounded to two significant figures to reflect analytical precision.

‡ 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