SOW_Sanostee_School_Remediation.pdf

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SCOPE OF WORK

Former Sanostee School Site Remediation Sanostee, San Juan County, New Mexico

Introduction: The Bureau of Indian Affairs (BIA), Navajo Regional Office (NRO), Branch of Environmental Management (BEM) is seeking the services for a licensed environmental professional to remediate the contaminated site to ensure all the environmental hazards are removed for re-use of the land by Navajo Nation. BIA plans to return 91.4 acres of withdrawn trust land back to the Navajo Nation. The land was used by the former Bureau of Indian Education (BIE) Sanostee Boarding school which include associated school buildings and housing for school personnel. In 2018, the school, all associated buildings, and the residential housing were demolished and disposed of. The property is currently vacant. The Sanostee chapter requested the BIA to clean up the site for the community re-use the land as recreational area, a community wellness center or a community cemetery.

Background: The former Sanostee school site is in Sanostee, San Juan County, New Mexico.

The site is positioned immediately due west and southwest of the Sanostee Chapter House on the Navajo Nation in the SW ¼ of section 4 and SE ¼ of section 5, NM T25N R19W with coordinates of N36° 25’ 34.48”, W108° 52’ 41.51”. The property can be accessed from the intersection of Navajo Route 34 and Navajo Route 5010.

The BIE operated the school from the late 1960s to approximately 2014. In 2018, the Navajo Region Facility Management Officer provided a memorandum to BIA NRO with documentation of completion of the school demolition including well closure, demolition of the elevated tank, and disposal of all demolition material from the site.

In September 2022, the BIA received an official request from the Sanostee Chapter to relinquish the Sanostee Boarding School Compound. Due to various changes in land status over the years, a field survey was conducted by the BIA NRO Real Estate Services (RES) and the data was used to plot the area with legal land descriptions and withdrawals. Real Estate Services identified seven

(7) parcels withdrawn by BIA for a total of approximately 142.5 acres. Parcels B thru E were associated with the sewer system and previously remediated and returned to the Navajo Nation.

Parcel A Sanostee School and Housing Area encompasses approximately 110.40+ acres with 18.96 acres withdrawn for housing under the Navajo Housing Authority (NHA). The 18.96 acres for NHA and the two buildings on the property identified as the Indian Health Service (IHS) clinic and a Frontier Communication office are excluded from this scope of work. The 91.42 acres in Parcel A shall be remediated and free of any environmental hazards. (Figure 1 and 2)

An ASTM Environmental Site Assessment (ESA) E1527-21 Phase I and Phase II dated March 2022 was conducted concurrently on the 91.42 acres of the former school and former housing area to identify recognized environmental hazards. Remnants from former structures remain on site in the form of concrete rubble, footings, foundations, sidewalks, and asphalt pavement. Analytical results confirmed the presence of asbestos in the form of non-friable vinyl composition tile (VCT) scattered throughout the site from the demolition of the previous structures. The soil was sampled within the site for asbestos fibers and found no impact to the soil. One cementitious piping tested

2 | P a g e positive for asbestos; therefore, all cementitious piping shall be considered Asbestos Containing Building Material (ACBM). The report confirmed the occurrence of illicit dumping of solid waste such as building debris, fencing, empty containers, appliances, and automobile tires. No hazardous wastes, or universal waste were identified. An artesian well is located on site and has an active wellhead that is leaking. Analytical results conclude the quality of water is suitable for livestock and other domestic uses.

In April 2024, BEM selected a contractor to conduct an ASTM Phase III investigation and to develop a Remedial Action Plan to address the RECs on site. The report confirmed scattered ACBM VCT, solid waste, asphalt, concrete piers, and concrete rubble. A subsurface investigation was conducted to identify buried demolition debris but did not result in any findings except for minor shallow buried debris. Investigation confirmed the presence of non-friable ACBM in the form of VCT from previous structures. These pieces are very small, less than 4 inches and scattered throughout a large area of the site, over 725,000 square feet. Recommendations included removal of all forms of concrete, removal of solid waste scattered across the surface and shallow subsurface, address the artesian well, and reseed the area.

The original school demolition project filed documents for National Environmental Policy Act (NEPA) compliance and was approved by the BIA NRO on October 24, 2017. Additionally, a Biological Resource Compliance Form (BRCF) Section 7 was filed and reviewed under 17BIA20a3 on September 25, 2017, and a Cultural Resource Compliance Form (CRCF) Section 106 was filed and reviewed under NTM-85-007.5 on October 11, 2017. Under the guidance of the BIA NRO NEPA department, these documents will serve for compliance with NEPA regulations. During this project, the Contractor shall remain vigilant of any discovery both biological and cultural items. In the event of any cultural discovery, all operations in the immediate vicinity must cease. The Contractor shall notify the Contracting Officer (CO), Contracting Officer Representative (COR), and the Navajo Nation Historic Preservation Department immediately.

Work: The NRO BEM requires the services of licensed environmental professional to remediate the former Sanostee school site as provided in the ESA Phase III to ensure all environmental hazards are removed from the site.

The Phase III report confirmed the presence of hundreds to possibly thousands of pieces of VCT containing greater than 1% asbestos fibers scatter throughout the property. As reported these pieces are non-friable and have been determined to have no empirical evidence to cause undue risk to human health or the environment. However, BIA NRO BEM is required to remove all environmental contaminants before the transfer of land back to the Navajo Nation therefore, the Contractor shall provide a plan to gather and remove all pieces of ACBM VCT from the site.

All surficial and buried cementitious piping shall be gathered and properly disposed of. It is recommended all piping be considered ACBM.

All various forms of concrete shall be gathered and disposed of. Concrete includes, sidewalks, footings, a small pad, scattered rubble and approximately 150 concrete piers. Concrete piers vary in size from eight (8) to thirty-two (32) inches in diameter and up to 8 feet deep. The piers are reinforced with rebars that are ¼ to ½ inch in size.

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The asphalt pavement near the entrance of the site shall be removed and disposed of.

The local chapter has requested the artesian spring located on site to remain for livestock usage.

The Contractor will work with the Navajo Tribal Utility Authority (NTUA) and the Navajo Nation Water Department to ensure the wellhead complies and adheres to regulations to protect underground water sources.

The Contractor will work with appropriate utility programs such as NTUA and the Navajo Nation Water Department to remove all buried utility to include water lines, natural gas lines, and utility poles.

All solid waste shall be gathered and properly disposed of including tires.

Period of Performance: The period of performance shall be 180 days from the notice to proceed.

TASK I: Pre-Submittals All pre-work submittals shall be submitted to the NRO BEM within thirty (30) calendar days from the Notice to Proceed.

A. The Contractor shall provide a Health and Safety Plan (HASP) in accordance with 29 CFR

1910.120 to allow for the protection of workers, employers, and the public for the overall project.

a. The HASP shall contain certifications/licensures of workers.

b. The plan shall identify all required personnel protective equipment (PPE) for all tasks and provide procedures for proper usage.

c. The plan shall address task-specific physical hazards and other hazards that may be encountered during work at the site. There are known and potentially occurring environmental hazards including exposure to petroleum hydrocarbons, potentially explosive atmospheric conditions, and tripping/falling hazards, presence of heavy equipment, utility lines, biological hazards, chemical hazards, venomous insects, and snakes/spiders. Other known and potentially environmental hazards are asbestos, PCBs, lead-based paint, and mold.

d. The HASP should also address COVID-19 practice.

B. The Contractor shall prepare a detailed Work Plan with Project Schedule for BIA NRO BEM to review and approve prior to commencement of work. The work plan should document the proposed off-site disposal activities and certified landfill locations. Locations of any recycler for any recyclables. The work plan shall include traffic routes, dust control, and a communication plan with the public who live in this area. This area is surrounded by residents and Navajo Nation offices. Work plan should include listing of all sub-contractors and their certifications.

C. Due to the large, impacted area of the ACBM VCT pieces, a notification of the asbestos abatement must be filed with the US Environmental Protection Agency (EPA) Region 9 and Navajo Nation EPA (NNEPA) before work activities begin. If excavation is planned as part of the remediation, an abatement plan should be prepared in conjunction with the EPA/NNEPA to determine an acceptable depth of topsoil excavation required to remove the ACBM VCT debris.

The ACBM work should be completed by a licensed contractor. All waste materials must be properly containerized and transported to an approved landfill. Waste disposal manifests should

4 | P a g e be provided to the BIA.

The Contractor shall provide the best management practices for excavation and surface restoration for the site with the scattered ACBM VCT pieces throughout the property. By the removal of ACBM VCT materials this will address any potential human health risk and or to the environment.

The end goal for this project is to transfer land that is reduce or remove the current negative impacts that may impede the transfer of the land back to the Navajo Nation.

TASK II: Abatement of Hazardous Constituents

Asbestos Abatement:

A. The Contractor shall prepare a National Emission Standards for Hazardous Air Pollutants (NESHAPS) notification to the EPA Region 9 and the NNEPA in accordance with 40 CFR 61 Subpart M National Emission Standard for Asbestos for asbestos-containing materials as material or product that contains greater than 1% asbestos.

B. The Contractor shall abate all asbestos identified in ASTM Phase II Report investigation following the 10-day notification rule for both friable and non-friable asbestos.

C. Following the abatement all surfaces in the room where ACM has been removed will be cleaned, double wet-wiped and High-Efficiency Particulate Air (HEPA) vacuumed accordance with the Asbestos Hazards Emergency Response Act (AHERA) protocol, 40 CFR 763 and NESHAPS 40 CFR 61.

D. The Contractor shall conduct a visual inspection of the area to assure that the abatement is complete, and no ACBM remains. Following the inspection, the Contractor shall contact the BIA CO or COR or their technical representative to conduct a visual inspection of the area to assure that the ACBM has been removed. In the event deficiencies are identified in the work, the Contractor shall again abate/clean the area at their expense. The Contractor shall again notify the CO when the project area can be inspected following the completion of the work.

E. The Contractor shall obtain and prepare a disposal manifest for BIA signature. The Contractor may not sign the manifest on behalf of the BIA. Contractor will provide to the CO, in writing, the location of disposal of asbestos waste prior to any commitment for disposal.

All manifests for disposal of all ACM waste shall be submitted in the final report. Contractor shall obtain and submit copies of transportation certifications. Any variation to this task shall be pre-approved by the BIA NRO BEM Regional Environmental Scientist.

F. While the Contractor is performing field work, the Contractor shall maintain a daily log to document the activities of the abatement action. The Contractor shall also record all events relevant to a project. The log will be signed and closed daily. The log shall become the property of BIA. A copy of all bills, receipts, time sheets and the inventory of disposed materials shall be maintained and submitted in the final report.

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G. Any proposed changes to the contract scope of work shall be approved in advance by the CO. Any deviations from the statement of work (SOW) will result in non-payment. Any discovery not outlined in the SOW will require the Contractor to notify the CO immediately.

H. Water and utilities for the asbestos abatement project shall be the responsibility of the Contractor.

TASK III: Mobilization and Labor A. The Contractor shall mobilize to the site with sufficient qualified staff to conduct the work for the project within 15 days of from approval of HASP and Work Plan. The Contractor is responsible for providing personnel with the necessary level of expertise to support the work and requirements.

No additional mobilization cost shall be allowed.

B. The Contractor shall provide a Project Manager for the life of the contract. The Project Manager shall be on site for the entire duration of the project to conduct, to assist, to oversee the project and to ensure the safety of the technicians or other junior grade environmental professional.

C. The Contractor shall ensure that all documentation requiring signatures be signed, such as disposal manifests. All original documents shall be retained and made part of the record and provided in the final report. Only a BIA NRO BEM official or designated appointee selected by BIA NRO BEM shall sign off on manifests. The Contractor or subcontractor may not sign the manifests on behalf of a BIA. Any variation to this task shall be pre-approved by the BIA NRO BEM Regional Environmental Scientist.

TASK IV: Remediation A. Asbestos Containing Building Materials

a. The Contractor shall gather and properly dispose of all ACBM in the form of non-friable VCT. These pieces are very small, less than 4 inches and scattered throughout a large area of the site, over 725,000 square feet.

b. The Contractor shall conduct a visual inspection of the area to assure that no ACBM remains.

c. The Contractor shall contact the CO or their technical representative to conduct a visual inspection of the area to assure that the ACBM has been removed. In the event, the CO or their technical representative finds deficiencies in the work, the Contractor shall again clean the area at the Contractor’s expense. The Contractor shall again notify the CO or their technical representative when the project area can be reinspected.

B. Cementitious Piping

a. All cementitious piping (surficial and buried) shall be gathered and properly disposed of.

b. All cementitious piping shall be treated as ACBM.

C. Concrete

a. All various forms of concrete shall be gathered and disposed of or recycled at a permitted facility. Concrete includes sidewalks, footings, a small pad, and scattered concrete rubble. Weigh tickets shall be included in the final report.

D. Concrete Piers

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a. All concrete piers shall be excavated and disposed of or recycled at a permitted facility.

Weigh tickets shall be included in the final report.

b. After removal of piers, any void shall be backfilled with clean fill and graded to existing terrain.

c. Any highly disturbed area shall be re-seeded and fertilized.

E. Asphalt pavement

a. The asphalt pavement near the entrance of the site shall be removed and disposed of or recycled at a permitted facility. Weigh tickets shall be included in the final report.

b. After removal of asphalt, any void shall be backfilled with clean fill and graded to existing terrain.

c. Any highly disturbed area shall be re-seeded and fertilized.

F. Artesian Spring

a. The Contractor shall work with the Navajo Tribal Utility Authority (NTUA) and the Navajo Nation Water Department to ensure the wellhead complies with and adheres to regulations to protect underground water sources.

G. Utility

a. The Contractor shall work NTUA to address the proper abandonment of all utilities onsite.

b. The Contractor shall work with appropriate utility programs such as NTUA, Navajo

Nation Water Department, and the Communication companies to remove all buried utility to include abandoned water lines, abandoned natural gas lines, abandoned communication lines, and abandoned utility poles. Water and gas lines were not addressed in prior demolition project. Note: Water distribution lines may contain asbestos.

H. Solid Waste

a. All solid waste across the surface and shallow subsurface shall be gathered and properly disposed of to include any tires.

I. Any proposed changes to the contract scope of work shall be approved in advance by the CO.

Any deviations from the SOW will result in non-payment. Any discovery not outlined in the SOW will require the Contractor to notify the CO immediately.

J. No hazardous wastes, universal wastes or evidence of petroleum leaks or spills were noted in the Phase III report.

Task 4: Reports All reports are the property of the BIA.

A. All written deliverables shall be submitted in electronic draft format for the COR’s review and comments.

B. Final copies will be due within ten (10) working days after receipt of COR’s comments. Final copies shall be submitted in two (2) final bound copies and two (2) electronic versions (one pdf and one MSWord). Other quantities and formats may requested from the COR. BIA shall be the owner of all documents prepared by the Contractor. The Contractor shall not copyright or write protect any documents or utilize any data from the project without consent of the Government.

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C. If reports are lost, the Contractor shall reissue copies at their expense.

D. At the conclusion of the period of performance, the final report shall summarize objectives achieved, significant issues, and any recommendations. The final report shall include drawings, abated locations (ACM, LBP, and Universal Wastes), quantities and other pertinent data generated in the performance of the contract. Profiles and manifests of disposed items at permitted landfills are to be included in the final report. The volume and weigh tickets of recycled materials.

E. All final reports shall be signed and stamped by a Professional Engineer.

F. All correspondence shall be protected and secured. It shall not be made available to the public or any other agency without the permission of the BIA NRO.

G. Other written and technical deliverables shall be submitted according to their schedules.

a. The Contractor shall submit a weekly report of progress and expenditures to the CO and COR. Report shall be submitted in an electronic pdf format.

Environmental Professional Certification: The report shall be stamped and certified by an environmental professional that the work was conducted in accordance with the Work Plan and in accordance with all applicable environmental federal regulations and construction standards.

Special Conditions:

The Contractor shall 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 remediation.

The Contractor is responsible for any utilities that are damaged during the work and shall repair them immediately at no cost to the Government. Any damages to property of the BIA or employees shall be repaired or paid by the Contractor if caused by the company or their employees.

Be advised that regulatory agencies may provide additional direction and guidance, the Contractor shall notify the CO immediately. The Contractor is 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 NRO. No information may be released without the written consent of the BIA NRO.

The Contractor shall be aware of residents in the area. The Contractor shall not donate any materials to the local public due to potential liability issues for BIA and the Contractor. Residential homes are located near the property boundaries and any work or removal actions that creates dust is to be wetted down to eliminate fugitive dust. Traffic control and signage should be clearly visible for the health and safety of the public.

Requirements Pre-work conference Weekly written status report to CO and COR Attend meetings with regulatory agencies as required Submittal of draft and final documents

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Reference Material T.H.A.T. Consultants LLC., Phase II Environmental Site Assessment Report iina ba, Inc., ASTM Phase III Investigation Report