SAP_Tuba_City_Dump_0214098_08212026_F.pdf

www.haleyaldrich.com

SAMPLING AND ANALYSIS PLAN

TUBA CITY DUMP (TCD) WASTE REMOVAL

TUBA CITY, ARIZONA

by Haley & Aldrich Construction Services, Inc.

Phoenix, Arizona for

BUREAU OF INDIAN AFFAIRS

PHOENIX, ARIZONA

File No. 214098-000 July 2026

Table of Contents Page

List of Tables iii List of Figures iii

1. Field Activity’s Objective 1

1.1 WASTE SCREENING 1

1.2 COVER SOIL SCREENING 1

1.3 IMPORT SOIL SCREENING 1

2. Waste Staging Area 1

3. Sample Collection 2

3.1 WASTE STOCKPILE SAMPLING 2

3.2 RADIOLOGICAL SCREENING & SAMPLING 2

3.3 SAMPLE PACKING AND SHIPMENT 3

3.4 BORROW SOURCE SAMPLING 3

4. Analytical Methods 3

4.1 WASTE SOILS AND SAMPLES 3

iii

List of Tables

Table No. Title

I TCLP Metals 2 TCLP Volatile Organics 3 TCLP Semi-Volatile Organics 4 TCLP Organochlorine Pesticides 5 TCLP Chlorophenoxy Acid Herbicides

List of Figures

Figure No. Title

1 Sampling Analysis Plan

1. Field Activity’s Objective

The primary objectives of these sampling programs are:

Screening waste according to the U.S. Environmental Protection Agency (EPA) Toxic Characteristic Procedure (TCLP) guidelines, as modified by the waste acceptance criteria (WAC) for the receiving landfill [Painted Desert (Pen-Rob) Landfill in Joseph City, Arizona];

screening clean soils from the waste for use as remediation backfill; and screening imported soils for remediation backfill.

1.1 WASTE SCREENING

Excavated waste from the TCD will be screened to assure it is not hazardous and that it will meet the disposal criteria of the receiving landfill.

1.2 COVER SOIL SCREENING

Clean soil segregated from the TCD may be stockpiled and reserved for backfill of the excavations left by waste removal. This soil will be screened to make sure there is no re-emplacement of contaminated material.

1.3 IMPORT SOIL SCREENING

Soil from borrow sources will be screened for contamination, including high concentrations of naturally occurring radionuclides

2. Waste Staging Area

Haley & Aldrich (HA) will install a staging area for testing 20,000 loose cubic yards of material. The staging area will encompass approximately 4.7 acres (204,732 square feet) on the south side of the west disposal cell. The waste staging area will be constructed using 4-inches of hot mix asphalt underlain by a minimum of 8-inches of base course. The staging area will include areas for waste loading, waste unloading, waste staging, and storage of equipment and materials. The waste staging area will be graded to drain stormwater into the collection basin as shown in the contract engineering drawings. The asphalt staging area will be cleaned using a power broom and sealed prior to use. The area established for waste management is planned to accommodate eleven (11) 1,000 loose cubic yard waste piles.

HA will excavate and transport approximately 20,000 loose cubic yards (LCY) of waste to the newly constructed waste storage area for stockpiling and testing. Waste will be excavated and held in 1,000 cubic-yard stockpiles on the waste staging area. Stockpiled waste will be sampled and analyzed in accordance with procedures outlined below. Waste stockpiles containing approximately 1,000 loose cubic yards will be constructed in the staging area. Eleven (11), or more, stockpiles, measuring approximately 70 feet x 70 feet x 8 feet, as shown on Figure 1.

3. Sample Collection

HA will provide personnel capable of radiation screening and sampling of approximately 1,000 cubic yards of waste per day at the waste staging pad. HA will provide and perform the following items for this task:

Provide personnel to sample, store, and ship soil samples to the selected laboratory.

Provide onsite personnel to provide oversight of the excavation progress and verify waste removal.

Provide personnel to perform radiological screening of excavated waste as outlined in the Radiological Screening Plan.

3.1 WASTE STOCKPILE SAMPLING

Stockpiles withing the waste staging area will be sampled immediately upon their construction by HA. Samples will be taken from stockpiles using powered equipment or by hand. Hand tools and/or powered equipment buckets shall be decontaminated between sample stockpiles, or containers, with a deionized water rinse. Stockpile samples will consist of 6 grab samples, spaced out equally throughout the stockpile, homogenized into one composite sample per 1000 cubic yard stockpile.

3.2 RADIOLOGICAL SCREENING & SAMPLING

According to the Radiological Screening Plan, excavated soil will be screened as it is stockpiled on-site with a sodium-iodide probe, or equivalent, to determine if radiological contamination is present.

Material that is screened and reported as two times (2x) the natural background levels will be segregated and not sent to the selected municipal landfill until sampled for further analysis. Background level readings used for classification of soils will be 1.31 counts per minute (CPM) with a Geiger counter (2X background level equivalent to 2.62 CPM) and 1.0 picocuries per gram (pCi/g) with a sodium iodide probe (2X background level equivalent to 2.0 pCi/g). The materials will be analyzed for TCLP RCRA 8 Metals, TCLP Volatile Organic Compounds (VOCs), TCLP Sem-Volatile Organic Compounds (SVOCs), TCLP Organocholorine Pesticides, TCLP Chlorophenoxy Acid Herbicides, Total Furans, Total Dioxins, and Total Sulfate

Samples that fail initial radiological screening will be relayed to the engineer and owner. It is anticipated that samples that fail onsite screening will be analyzed for Isotopic Radium (Ra-226 and Ra-228), Thorium, Uranium, Gross Alpha/Beta Radioactivity, and Gamma Spectroscopy. Samples will be submitted to an Arizona Department of Health Services (AZDHS) accredited laboratory within 24 hours of identification. Material determined to not being suitable for disposal at the municipal landfill will be left in a discrete stockpile location in the excavation area and cordoned off.

Screening for potential hazardous materials and recyclables is outlined in the Radiological Screening Plan.

The selected landfill will determine the frequency of the testing for disposal purposes. Haley & Aldrich has assumed that one test for every 1,000 CY will be required for disposal. The characteristic radiological sample taken from each of the 1000 loose cubic yard stockpiles will be sent to an offsite laboratory for analysis. Haley & Aldrich is planning on testing 144 samples (sidewall and floor samples) during the course of this phase of project work.

3.3 SAMPLE PACKING AND SHIPMENT

Soil and waste screening samples will be packed for holding in a polyethylene, picnic-type, shipping cooler provided by the analytical laboratory. The cooler contents will contain cushioning material (including bubble packs), to protect samples and absorb spillage. Samples will be bagged in bubble packs or Ziploc® plastic bags. Ice will be placed in the shipping cooler to keep the samples at 4°C. A chain-of-custody form will be included in each cooler documenting the samples collected.

After samples are packaged for shipment, the cooler will be closed, latched, and sealed with strong, clear tape. Drain plugs will be taped shut, initialed, and dated custody seal will be placed across the cooler lid and body. The cooler will then be shipped or delivered to the contract analytical laboratory. The laboratory selected for waste characterization analysis is Pace Analytical Services out of Mt. Juliet, Tennessee.

3.4 BORROW SOURCE SAMPLING

Borrow sites shall be sampled by auger drilling, with powered equipment, or by hand.

4. Analytical Methods

4.1 WASTE SOILS AND SAMPLES

TCD waste, segregated cover soil, and borrow source soils will be analyzed using the TCLP, an EPA method used to screen materials for hazardous waste characteristics (EPA 1992). The TCLP analytes are listed in Tables 1 through 5. Additional testing will be performed for Total Furans, Total Dioxins, and Total Sulfate which on not listed on the tables below.

Table 1. TCLP Metals

Analyte TCLP Regulatory Limit (mg/L) Arsenic 5.0 Barium 100

Cadmium 1.0 Chromium 5.0

Lead 5.0 Mercury 0.2 Selenium 1.0

Silver 5.0

Table 2. TCLP Volatile Organics

Benzene 0.5

Carbon Tetrachloride 0.5 Chlorobenzene 100.0

Chloroform 6.0 1,4-Dichlorobenzene 7.5 1,2-Dichloroethane 0.5

1,1-Dichloroethylene 0.7 Methyl Ethyl Ketone 200.0

Tetrachloroethylene 0.7 Trichloroethylene 0.5

Vinyl Chloride 0.2

Table 3. TCLP Semi-Volatile Organics o-Cresol 1 200 m-Cresol 1 200 p-Cresol 1 200 Cresol 1 200

2,4-Dinitrotoluene 0.13 Hexachlorobenzene 0.13

Hexachlorobutadiene 0.5 Hexachloroethane 3.0

Nitrobenzene 2.0 Pentachlorophenol 100.0

Pyridine 25.0 2,4,5-Trich lorophenol 400.0 2,4,6-Trichlorophenol 2.0

Table 4. TCLP Organochlorine Pesticides

Chlordane 0.03 Endrin 0.02

Heptachlor (and its Epoxide) 0.008 Lindane 0.4

Methoxychlor 10.0 Toxaphene 0.5

Table 5. TCLP Chlorophenoxy Acid Herbicides

2,4-D 10.0 2,4,5-TP (Silvex) 1.0

FIGURES

CP-02

N=1863442.93 E=911481.78

ELEV=4890.00

80 48

4865486548

Horizontal Control Point Table

SITE PLAN

GENERAL NOTES:

1. FENCE REMOVAL INCIDENTAL TO GRADING

EFFORTS SHALL BE REPLACED IN KIND AT

CONTRACTORS EXPENSE.

2. CONTRACTOR SHALL PROVIDE EROSION

PROTECTION DURING GRADING EFFORTS PER

SPECIFICATIONS.

3. NOT ALL KEYED NOTES USED ON THIS SHEET.

KEY NOTES:

LIMITS OF GRADING

ASPHALT PAVING PER DETAIL 3, DWG C-32

INSTALL 18" ROUND CMP CULVERT PER DETAIL 5,

DWG C-32

12" THICK GRAVEL PER SPECIFICATIONS

INSTALL LINED DETENTION POND PER DWG C-33 AND

SPECIFICATIONS

CONTRACTOR OFFICES/STAGING

WASTE STAGING

BORROW STAGING AREA PER DETAIL 6, DWG C-32

EARTHEN BERM PER DETAIL 6, DWG C-32

RIP RAP EROSION CONTROL, PER DETAIL 2, DWG C-34

8' TALL FENCE (MATCH EXISTING FENCE IN KIND)

13 NEW 8' SECURITY FENCING (MATCH EXISTING IN KIND)

12' DOUBLE WIDE SWING GATE

KEY NOTES:

REV. NO. DATE DESCRIPTION APPROVED BY

JOB NO.

SHEET OF 64

DWG NO.

DB23.1091

TUBA CITY DUMP CLEAN CLOSURE

TUBA CITY, AZTHE HOPI TRIBE

KYKOTSMOVI, AZ

06/13/2025

KH

JA/LP

JH

MO

800-933-3105 www.dbstephens.com

C-10

≈ 232ft x 175ft

BOP = 4872'

MSL = 4877'

VOL = 1,303,488 GAL

cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Rectangle cVanCoillie Text Box = Waste Stockpile cVanCoillie Callout Road Leading to Waste Excavation Area cVanCoillie Callout Haul Route Offsite