SOW_-_Sanostee_Cleanup_(2).pdf

SCOPE OF WORK

FORMER SANOSTEE SCHOOL

PHASE III ENVIRONMENTAL SITE ASSESSMENT (ESA)

SANOSTEE, SAN JUAN COUNTY, NEW MEXICO

Introduction:

This site is in the community of Sanostee, San Juan County, New Mexico, formerly the Sanostee

Boarding School which operated from the late 1960’s through 2014. The former school is surrounded by residences, along with Sanostee Chapter Buildings and other Navajo Nation tribal offices. The attached Map 1 displays the former buildings on the 91.4 acres, which have been removed except for the Indian Health Service Clinic (IHS) and a Frontier Communications buildings. It is unknown on the status of the IHS clinic or the Frontier Communications buildings.

Currently, there are no buildings present on site except the remnants of the former structures such as the concrete piers/footings, foundations, asphalt parking area, sidewalks and utility lines from school buildings and housing quarters. The site inspections were completed on December

14, 2021, by T.H.A.T. Consultants LC, Mr. Terry Holley, an accredited asbestos inspector, performed the asbestos sampling activities onsite. The inspections identified building materials contained asbestos fibers, thermal system insulation, surfacing materials, and other materials found on site. Other observations and sampling relative to ACBM findings include but are not limited to concrete materials of the sidewalks, footings/piers, concrete padding, debris piles, from former dormitories and buildings that were once onsite. Asphalt pavement material parking lot, flooring materials (fragments/small tiles), throughout 17 acres of the property. Additionally, cement pipe at one location was located and found to have asbestos, referred to as “transite” and used for water piping. Most of the asbestos containing building materials was found to have

Chrysotile asbestos.

The Sanostee Chapter and community members is requesting the Bureau of Indian Affairs (BIA) to relinquish the land back to the Navajo Nation for re-use. The land will be used by the community as cemetery, park or recreational area. Before the land can be relinquished, the property once used by the BIA requires cleanup.

Background:

In March 2020, BEM contractor conducted the ASTM Environmental Site Assessment (ESA)

Phase I and Phase II which is provided in the “Former Sanostee School Site Phase II ESA, March 2020”. The overall sampling of the environmental hazards and recommendations by the former contractor are provided in this report and available for review at the Bureau of Indian

Affairs (BIA) Navajo Region (NR), Branch of Environmental Management (BEM). The assessment included the former lagoon, which was closed by the Branch of Facilities and worked with Navajo Nation Environmental Protection Agency. The former sewer lagoon is located southeast of the residential homes of Sanostee, was closed by Facility Management through

Navajo Nation Environmental Protection Agency.

On January 13, 1965, the BIA through Advisory Committee Resolution No. ACO-145-64 approved a new federal school and health facilities on tribal lands located in Sanostee, New

Mexico dated October 27, 1964. The property description attached to said resolution describes four (4) parcels of land totaling 115.496 acres: Parcel A – Sanostee School and Housing Area

(110.400+ acres); Parcel B – Sewer Line (0.918+ acres); Parcel C – Sewer Lagoon Area

(3.673+ acres); and Parcel D – Sewer Outfall Line (0.505+ acres) - Property Description No. 35-

46-2 dated February 11, 1964, Revision No.1 September 15, 1964.

In November 18, 2018 – Memorandum from Navajo Region Facility Management Officer to BIE

New Mexico North Facility Management; BIA Navajo Region Property Management; Navajo

Region Environmental; Navajo Region Acquisition; Subject: Final Close-out Documents

Sanostee Demolition A17PD00511. The Memorandum provided documentation of demolition of old Sanostee Boarding School including well closure, elevated tank demolition and disposal of all material from the school.

Work Required: BEM is requesting the services of licensed environmental professional experience in remediation and site characterization work for the 17 acres of the former Sanostee

Boarding school area, that was once used by the BIA. To determine the impact of of the scattered ABCM using a site sampling characterization of the area, the removal of the contamination safely with minimal impacts to the community. No abatement of the environmental hazards was conducted before the demolition of these buildings occurred.

To assess the current utility lines and the concrete piers remaining onsite that impact land re-use.

It is unknown the depth of the concrete footings/piers remaining. No blueprints or information is available on the piers/footings or utility lines.

The work will be conducted in two options:

Option 1 is to conduct the site characterization of the 17 acres of the ACBM debris scattered throughout the site property. To determine the extent of surface and subsurface of ACBM onsite.

Surface sampling was conducted, and it is unknown if there are ABCM dumpsites on the property. Identify any potential dump sites of construction debris onsite. Once the sampling characterization is completed, the contractor shall provide a site restoration or cleanup plan to

BIA.

Option 2, dependent on the availability of funds, is to remove approximately 100 concrete footings from the former buildings and quarters. To remove the former utility lines where subsidence occurred which may require consultation with excavators that can remove former facility utility lines. To remove the concrete sidewalks, asphalt parking lot, and concrete padding found onsite.

Both options shall require excavation to remove any contaminated soils and concrete piers.

Before any work is conducted the contractor shall contact the Navajo Nation Historic

Preservation Office for Cultural Resource Compliance Form Section 106 and the Navajo Nation

Fish and Wildlife Program for Endangered Species Biological Resource Compliance Form.

These forms are to be acquired before any earthmoving is conducted by the contractor. The contractor shall also coordinate with US Environmental Protection Agency Region IX on the asbestos removal from land areas to ensure BIA work activities are in compliance with environmental regulations.

The work may require a large amount of native vegetation and consultation shall be made with the Navajo Nation, which will be determined when the work for excavation is to be done. The area shall be re-seeded once the land is cleaned of ABCM.

The Bureau of Indian Affairs (BIA) intends to relinquish and return approximately 91.4 acres of

Navajo Trust land withdrawn for the former Sanostee School and the former housing area previously used by the Bureau of Indian Education. The Branch of Environmental Management

(BEM) is requesting the services of a qualified environmental contractor to conduct the ASTM

Environmental Site Assessment Phase 1 and II. The ASTM Phase 1 is required to conduct the survey of the 91.4 acres of land for recognized environmental hazards. If the survey conduct shows potential environmental hazards an ESA Phase II shall be conducted for future removal.

The work identified in this contract will be a performance-based contract. Successful bidder will be evaluated on the completion of identified tasks in accordance with the established standards.

The Period of Performance is May 1, 2023, through January 2024 or 270 days from the receipt of the Notice to Proceed.

TASK I Pre-Work Submittals for Options 1 and 2

A. The Contractor shall provide a site-specific Health and Safety Plan (HASP) to address worker protection in accordance with 29 CFR 1910.120. The HASP shall contain certifications/licensures of workers and describe the use of all and appropriate PPE. Known and potentially occurring environmental hazards are asbestos, PCBs, lead-based paint, biological hazards and venomous insects, snakes/reptiles, and mold. The HASP shall include

COVID-19 practices.

B. The plan shall include certificates of workers for HAZWOPER, asbestos and Lead.

C. Name of NVLAP certified laboratory which will be used to analyze samples, D. A list of all subcontractors, including qualifications and experience.

E. Prepare a Work Plan with Work Schedule for Bureau’s review and approval prior to commencement of work.

F. Sampling Analysis Plan outlining the methods, procedure, and analytical data to be collected for soil sampling.

G. Cultural and Biological Compliance Forms (Navajo Nation), the contractor shall obtain guidance on NEPA requirements, the biological and cultural compliance forms and surveys are required.

H. The contactor shall prepare a NESHAPS notification to the USEPA and the Navajo Nation

EPA in accordance with NESHAPS, once the clean up work is scheduled. B. Name of

NVLAP certified laboratory which will be used to analyze sample Name of Landfill(s) where waste will be disposed

OPTION 1-Site Characterization/Sampling/Geophysical of ABCM

Task I: Geophysical of ABCM Impacted area:

A. It is unknown during the building demolition if any ABCM buried wastes were buried onsite.

B. The geophysical and site sampling shall determine the extent of contamination and removal of contamination for future land re-use.

C. Contractor shall conduct geophysical of the ABCM impacted area that will be utilized to delineate if the area has buried dumpsites from the previous building demolition.

D. The ABCM area shall be divided into sections/areas to identify any buried wastes on site.

E. In the event of buried wastes is discovered, a technical meeting with BIA shall be conducted before moving forward on the project.

Task II: Site Sampling/Site Characterization

A. Prepare an asbestos sampling plan for the contaminated area using the ASTM ESA Phase II report to determine the areas for the site sampling characterization. Upon approval of the draft sampling plan, the sampling event can proceed.

B. This area has scatter ABCM throughout the 17 acres of the property which was visually assessed and ABCM were tested and confirmed in the ASTM ESA Phase II.

C. The subsurface of the ABCM has not been done, therefore it is unknown if the contamination extends beyond the soil surface.

D. Sampling shall be conducted 0-6” 6- 12” and 12-24” if required beyond 24” BIA shall be informed before further depths are sampled. The sampling data shall be used to determine the vertical contamination of ABCM fragments.

E. Sampling methods, procedures shall be provided in the draft Sampling Analysis Plan for asbestos.

F. No abatement was conducted before the buildings were demo. It is unknown if the building debris was removed from the site or buried onsite.

G. Soil samples shall be submitted to certified laboratory for analysis.

Task III. Sampling Results/Site Remediation The contractor shall prepare the findings, recommendations with a detailed cost estimate for cleanup and disposal of ABCM found to be present on the property.

Task IV: Remedial Action Plan: Provide a remedial action plan with the description of the activities to be performed to include whether excavation can be used, volume to excavate, and backfill material. The description to be cleaned up shall be presented in sections or areas to excavated and amount of clean fill for these areas to prevent ponding or subsidence. Native re-vegetation to be used if removal of the vegetation requires site restoration considerations.

B. The contractor shall prepare a waste profile for the BIA signature. The contractor may not sign the profile on behalf of the BIA.

C. The contractor shall construct containment to assure that no asbestos is released into the environment of causes cross contamination of the structure. Negative air shall be used to assure that no asbestos is released into the environment.

D. The contractor shall abate all asbestos identified in the Task 2 investigation following the 10-day notification rule for both friable and non-friable asbestos.

E. Following the abatement, PLM sampling will be conducted to assure that no asbestos fibers greater than 1fiber/cubic center is present.

F. The contractor shall prepare a disposal manifest for the BIA signature. The contractor may not sign the manifest on behalf of the BIA.

OPTION 2- Remediation of Site

Scope: The BIA requires the services of a licensed contractor to conduct environmental cleanup of the approximately 100 to 150 concrete piers, building concrete pads/foundations, asphalt parking lot, solid waste, former utility lines, creosote treated electric poles and ABCM contaminated areas. Following the sampling and analyses conducted in Option 1, the contractor shall provide site cleanup or restoration recommendations of the site, engineering cost estimate identifying location, quantities, volume, and cost for abating these hazards. This document will be used to conduct cleanup of the property in accordance with federal regulations.

The Contractor shall furnish the necessary personnel, materials, equipment, services, and facilities to perform the work that successfully completes the scope of the project.

There is no electric power or water to serve the area. The contractor shall be responsible for procuring water and power for the project, if required.

1. Concrete Piers: The concrete piers and foundations remaining onsite are from the former dormitories and education buildings previously present at the site. Some of the piers and foundation elements are covered by vegetation. It is estimated between one hundred (100) and one-hundred fifty (150) individual concrete piers are present. They vary in size from eight (8) to twenty-four (24) inches in diameter. Depths of the piers are unknown. Concrete pad structures exist at the location of underground water distribution components (pipes, valves, meters, etc.)

present at the site. From the ASTM ESA Phase II report, the concrete samples submitted for PLM analysis were determined to be non-asbestos. Concrete piers are to be removed and backfilled with clean soil.

2. Asphalt Pavement Material –A small section of the original paved parking area remains near the entrance to the site and uncovered manhole in the parking area.

3. Flooring Material Remnants – Small pieces of floor tile with floor tile mastic were scattered throughout the property which covered over 726,723 square feet from the buildings that were removed. The pieces are very small, less than 4 inches. Samples taken confirmed the presence of Chrysotile asbestos in both the tile and mastic.

4. Roofing Materials – are similar to the flooring materials which are in small pieces within the same former building areas. The roofing materials are present at locations of the floor file debris was observed. A total of four samples of roofing debris were collected . Three out of the four were found to be non-ACBM, but one (1) sample contained 40% Chrysotile asbestos.

All the roofing debris should be considered ACBM per the sampling protocol.

5. Cement Pipe-at one location a small piece of cementitious (transite) pipe was located and found to contain asbestos. The pipe was sampled and contained Chrysotile.

6. Aboveground Storage Tank (AST) Systems – One (1) aboveground storage tank is present at the subject site. This tank is used to hold liquefied petroleum gas for heating purposes at the Indian Health Service Clinic. There is no visible evidence of leaking in the immediate vicinity of this AST nor are there any signs of stressed vegetation associated with this AST. BIA will work with IHS is this AST requires removal.

7. Polychlorinated Biphenyls (PCB) – One power pole transformer is located on the eastern edge the property near the IHS Clinic. This pole and transformer are owned by the Navajo Tribal Utility Authority (NTUA). The transformer number is G2018 and it is labelled “No PCBs”. There is another power pole transformer near but outside of the subject property line which is connected to the same series of overhead wiring. The labeling on this transformer was not clearly visible from the ground. (ASTM ESA Phase II report).

8. Solid Waste/Uncontrolled Dumping Sites – There are some isolated uncontrolled dump sites on the subject property. There are also isolated piles of concrete debris left over from the previous demolition of the buildings at the site. A wash through the property has likely carried debris onto the subject property. Within the debris piles such things as metal/plastic containers, portions of appliances, automotive tires, concrete, and metal debris are present.

9. Lead and Lead Based Paint: Soil samples were collected from surface to 2” in depth and the analytical results showed these samples below the detection limit of 25 parts per million

(ppm).

10. Domestic Water Well-an active domestic water wellhead is present onsite. There is no pump associated with the wellhead as the natural water pressure within the well casing is adequate to provide flow. There were shut off valves connected to the wellhead but doesn’t stop the flow and water is flowing onto the ground creating a pond of water. The Navajo Nation

Water Department of Water Resources shall be informed.

Task III. Engineer Cost Estimate:

The contractor shall prepare a report certified by a Professional Engineer for the disposal of all identified waste identified in the ASTM Phase II. This document shall contain sufficient information to allow BIA to solicit bid proposals to conduct removal of hazardous materials and/or chemicals from the former Sanostee School and housing area.

1. Submit the draft report for BIA review and comment.

2. The report shall be certified by a P.E. that the cost estimate is provided based on best management practices and to the best of his/her ability.

3. Discussions may be necessary to address any concerns identified by the BIA in the SOW.

IV. Reports:

A. Reports for this work shall describe the work done in the cleanup Phase III and include, but is not limited to, the following information:

1. Narrative of the work performed

2. Plotting of areas of contamination that were disposed

3. The nature and extent of contamination in soils and recommendation to remove or restoration of the area.

4. Analytical Results

5. Engineer Cost Estimate to conduct disposal of the identified target analytes, which includes the excavation, backfill with clean soil, re-seeding or restoration plan.

B. A draft report will be submitted for review to BIA within 15 days following completion of the field work. Two copies of the draft report shall be submitted to BIA for review.

C. Following the final review and approval of the draft document by BIA, the contractor shall prepare the final report for the cleanup Phase III certified by a professional engineer that the work was done in accordance with the approved sampling plan and federal regulations.

Five copies, three CD will be prepared two CD are to be read only and one CD editable version in MS Word and all tables in Excel. Drawings shall be provided to BIA. The one CD editable version shall be labeled for “BIA Use Only.” All documents collected or prepared for this project are the property of the Bureau of Indian Affairs and must be submitted to the government. The Contractor may not copyright or duplicate the documents without the written permission of the Bureau of Indian Affairs, Navajo Region.

Evaluation Criteria:

Proposals from contractors shall contain the following information:

1. A Summary of:

▪ Qualifications and related asbestos, lead based paint remediation experience, hazardous waste disposal, universal waste disposal, remedial/restoration work.

▪ Project Manager Resume

▪ Documentation of work conducted on the Navajo Nation lands

▪ Knowledge of the Navajo Indian Reservation for services and supplies to allow the contractor to function independently without the assistance of an initial escort and ability to work with local community members or school administrators successfully

INSTRUCTIONS, CONDITIONS, AND NOTICES TO CONTRACTORS

Special Conditions

The Contractor will adhere to all applicable federal and tribal laws and regulations, and payment of tribal taxes. The contractor shall be required to furnish electrical power and procure water to perform investigation, sampling, and cleanup.

Other: Contractors who wish to bid on the project must attend the site visit the site prior to bidding on the project. No compensation will be made to contractors for attendance at the site visit.

The Contractor is responsible for any utilities that are damaged while the work and shall repair them immediately at no cost to the Government.

As data is developed and regulatory agencies provide direction and guidance, contractors shall be expected to provide timely and quality response to issues raised by the regulators. All contact with the public, private or regulatory community shall be made through the BIA, Navajo Region.

No information may be released without the written consent of the BIA Navajo Region.

Cleanup Phase III will be awarded based on best technical approach and a responsive bid package which meets the needs of the government and not on lowest price.

Requirements

Mandatory Site Visit

Pre-Work conference

Written weekly status report to COR

Submittal of Draft and Final documents

Reference Material

Former Sanostee School Map