ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVES (2024)

Tribal code

Ask Donna

What actually matters in this document.

Text

ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVES

ACOMITA DAY SCHOOL SITE

294 PUEBLO ROAD

PUEBLO OF ACOMA, NEW MEXICO

PREPARED FOR:

REMEDIATION OVERSIGHT SECTION

NEW MEXICO ENVIRONMENT DEPARTMENT

May 2024

TABLE OF CONTENTS

Table of Contents ....................................................................................................................... i

1.0

Introduction & Background ...................................................................................................... 1

1.1 Site History ........................................................................................................................ 1

1.1.1 Previous Environmental Investigations and Available Information ................... 1

1.2 Site Location ...................................................................................................................... 2

1.2.1 Project Goals (site reuse plan)............................................................................. 2

2.0

Current Environmental Concerns ............................................................................................. 3

2.1 Asbestos Regulations .......................................................................................................... 3

2.2 LBP Regulations................................................................................................................... 3

2.3 Cleanup Standards ............................................................................................................ 4

2.4 Cleanup Standards for Major Contaminants.................................................................... 5

2.5 Laws & Regulations Applicable to the Cleanup ................................................................ 5

3.0

Evaluation of Cleanup Alternatives .......................................................................................... 5

3.1 Alternative 1 - No Action .................................................................................................... 6

3.1.1 Short-Term Effectiveness ............................................................................................... 6

3.1.2 Long-Term Effectiveness .................................................................................................. 6

3.1.3 Implementability ............................................................................................................ 6

3.1.4 Costs ................................................................................................................................. 6

3.2 Alternative 2 - Implementation of an ACM and LBP O&M Program and Partial

Abatement.................................................................................................................... 6

3.2.1 Short-Term Effectiveness ............................................................................................... 7

3.2.2 Long-Term Effectiveness .................................................................................................. 7

3.2.3 Implementability ............................................................................................................ 7

3.2.4 Costs ................................................................................................................................. 7

3.3 Alternative 3 – Abatement ................................................................................................. 7

3.3.1 Short-Term Effectiveness ............................................................................................... 8

3.3.2 Long-Term Effectiveness .................................................................................................. 8

3.3.3 Implementability ............................................................................................................ 8

3.3.4 Costs ................................................................................................................................. 9

4.0

Recommended Alternative....................................................................................................... 9

5.0

References .............................................................................................................................. 10

Figures

Figure 1:

Figure 2:

Site Vicinity Map

Site Map

Tables

Table 1:

Table 2:

Table 3:

Summary of Asbestos Containing Material Results by Building

Summary of Lead-Based Paint Results by Building

Evaluation Criteria for Considered Alternatives

ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVES

Acomita Day School, Pueblo of Acoma, New Mexico

May 2024

1.0

Introduction & Background

This Analysis of Brownfields Cleanup Alternative (ABCA) h a s b e e n p r e p a r e d for the

former Acomita Day School on the Pueblo of Acoma in New Mexico (Project Activity Code

51573149). Brownfields are properties that have previously been developed which may result

in complication for reuse, redevelopment, or expansion by the presence of hazardous

substances, pollution, or contamination. This ABCA report describes asbestoscontaining materials (ACM) and lead-based paint (LBP) contamination issues associated with

the Acomita Day School (site), applicable cleanup standards and laws, and evaluate the

effectiveness, implementability, and costs of different cleanup options.

The Pueblo of Acoma plans to demolish all five buildings on the site and redevelop the

property. This cleanup project is being undertaken by the NMED Brownfields Program and the

Pueblo of Acoma. To ensure compliance with all applicable regulations the NMED and U.S.

Environmental Protection Agency (EPA) will be the key regulatory agencies overseeing this

project and will review all project documents prepared by SMA and any environmental

cleanup work. The NMED is funding the preparation of this Analysis of Brownfields Cleanup

Alternatives and the proposed cleanup work at the Acomita Day School Site. This ABCA

outlines site cleanup alternatives evaluated by the NMED, EPA, and Pueblo of Acoma during

the cleanup planning process. This ABCA will be available to the public for a period of 30 days.

The final ABCA will include any comments received during the 30-day public comment

period.

1.1 Site History

The buildings on the former Acomita Day School property are estimated to have been constructed

in the 1920’s or 1930’s. The property was operated as a school from 1955 to 1998 when the school

was taken over by the Head Start Program. The Head Start Program closed in 2004 and the buildings

have remained vacant since that time. Some vandalism of the site buildings has occurred

during their vacancy.

1.1.1 Previous Environmental Investigations and Available Information

Reports, data, and information from previous environmental investigation activities

completed to date at the site.

•

Phase I Environmental Site Assessment Vacant Former Acomita Day School (AECOM,

January 23, 2018): three recognized environmental conditions (RECs) or data gaps were

identified. Although considered unlikely, potential contamination was identified in the

southwest building formally used as a printing press with potential for vapor intrusion and

contamination migration via an on-site septic system. AECOM recommended asbestos

and lead-based paint surveys be performed prior to building demolition.

•

Phase II Environmental Site Assessment Acomita Day School (AECOM, December 2020):

no chemicals of concern were identified from the printing press formally located in the

southwest building. The investigation consisted of the collection and analysis of primary

media of concern associated with a drain-line and an on-site septic system. Subsurface

soil samples near the drain line and adjacent to the septic system as well as aqueous liquid

from within the septic were collected by AECOM to determine if a release had occurred.

•

Pre-Demolition Asbestos Investigation Reports for Buildings - Cafeteria, Classrooms,

Dispensary, Offices, and Printing Press (ACME Environmental, Inc., October 2021):

asbestos was identified in materials including plaster white VFT, linoleum flooring, roofing

paper, and exterior stucco.

•

Lead-based Paint Inspection Reports for Buildings - Cafeteria, Classrooms, Dispensary,

Offices, and Printing Press (ACME Environmental, Inc., October 2021): lead-based paint

was identified in all five buildings.

•

Limited Phase II Environment Site Assessment – Asbestos Containing Materials and Lead

Based Paint Survey Acomita Day School (SMA, December 2021): asbestos containing

materials and lead based paint was identified in all five site buildings.

1.2 Site Location

The former Acomita Day School is located on Pueblo Road approximately 0.55 miles southwest

of the intersection of Pueblo Road and Indian Service Route 25 in the Acomita area of the Pueblo

of Acoma (herein referred to as “the Site”). The site consists of approximately 1.1 acres of land

developed with five buildings and two sheds. Surrounding properties include residences,

agricultural fields, and undeveloped land. According to the U.S. Geological Survey (USGS) 7.5minute topographic map for Cubero, New Mexico, the site is located in Section 33, Township 10

North, Range 7 West, NMPM, at approximately 6,040 feet above mean sea level (amsl). Regional

topography slopes gently to the northwest in the site vicinity.

1.2.1 Project Goals (site reuse plan)

The Pueblo of Acoma plans to demolish all five site buildings to allow for redevelopment. There

are currently no plans to redevelop the site for residential use or child-occupied facilities.

2.0

Current Environmental Concerns

2.1 Asbestos Regulations

The Occupational Safety and Health Administration (OSHA) has defined asbestos as naturally

occurring mineral fibers that include chrysotile, amosite, crocidolite, tremolite, anthophyllite,

actinolite, and any of those minerals that have been chemically treated and or altered. These

fibrous silicate minerals were added to building materials for their thermal insulation, chemical

stability, and high tensile strength properties. Asbestos minerals were added to cement pipes,

brake shoes, duct insulation, flooring, mastic, gaskets, spray-applied textures, blown-in

insulation, wiring insulation, taping compounds, packing materials, roofing shingles, roofing felt,

ceiling panels, and other building products (OSHA, 2022).

The disturbance or dislocation of ACM may cause asbestos fibers to be released into the

building’s atmosphere, thereby creating a potential health hazard to workers and building

occupants. Exposure to airborne asbestos fibers appears to be associated with asbestosis, lung

cancer, and mesothelioma (U.S. EPA, 2022a and 2022b).

EPA National Emission Standards for Hazardous Air Pollution (NESHAP), Asbestos Hazard

Emergency Response Act (AHERA), NMED, and OSHA regulations require inspection of

commercial properties before any renovation or demolition to determine the presence of ACM,

including friable ACM and Category I and II non-friable ACM as defined in 40 CFR, Part 61, Subpart

M, Section 61.145.

Friable ACM, Category I and II ACM in poor condition, or Category I and II ACM that becomes

friable during renovation or demolition and is present in quantities greater than 160 square feet,

260 linear feet, or 35 cubic feet are subject to the regulations pertaining to removal and disposal.

NMED requires that asbestos removal contractors comply with the remediation and 40-hour

contractor supervisor training requirements of the NESHAP, 40 CFR 61 Subpart M, and to have a

GB-98 general contractor’s license and a GS-29 special contractor’s license from the New Mexico

Regulation & Licensing Department (NMRLD) Construction Industries Division.

2.2 LBP Regulations

Lead is a natural occurring inorganic malleable heavy metal that can be highly toxic to humans if

absorbed into the body, especially in young children. The primary cause of human exposure to

lead is from deteriorating old lead-based paint (LBP). OSHA regulations in 29 CFR 1926.62 and 29

CFR 1910.1025 lists the permissible exposure limit (PEL) for workers to lead at a construction of

50 micrograms per cubic meter (µg/m3) of air averaged over an 8-hour period. Engineering and

work practice controls are prescribed in 20 CFR 1926.62 to reduce and maintain exposure to lead

at or below the PEL or reduce exposure to the lowest feasible level with supplemental respiratory

protection.

In accordance with EPA LBP regulations 40 CFR Part 745, which apply to residential properties

and child-occupied facilities, the site is exempt from EPA regulations as the site is planned for

demolition.

2.3 Cleanup Standards

Based on the Limited Phase II Environment Site Assessment report (SMA, December 2021), each

of the five buildings contained ACM and LBP. Approximate quantities and concentrations of ACM

and LBP are summarized in Table 1 and 2 below.

Table 1. Summary of Asbestos Containing Material Results by Building

Building

Cafeteria

Classrooms

Dispensary

Building Material

Plaster System (interior)

12"x12" Floor tiles w/ mastic

Exterior Stucco

Roofing Paper w/ Tar

Linoleum Flooring

12"x12" Floor tiles w/ mastic

Roofing Paper w/ Tar

Offices

Printing

Press

Roofing Paper w/ Tar

Exterior Stucco

Roofing Paper w/ Tar

Approximate Area

(ft2)

Asbestos

Type

Percent

Asbestos

2,500

1,600

2,000

4,200

1,800

500

1,000

Chrysotile

2,3

3,3

1,800

2,250

1,400

Chrysotile

Table 2. Summary of Lead-Based Paint Results by Building

Building

Cafeteria

Classrooms

Dispensary

Painted Material

Lead

(mg/cm2)

Interior walls and ceiling

Interior and exterior window components

Interior door

Baseboards

Interior walls

Exterior walls

1.6

7.3-17.5

19.3

1.1 - 9.6

1.0 – 12.1

3.7

Interior and exterior window component

1.0 - 15.8

Interior and exterior door and doorway components

1.4 - 5.1

Front porch components

Rafters/joints

Interior and exterior window components

Exterior door components

8.2

1.0

1.4 - 1.7

3.9 - 12.8

Exterior canales and fascia

14.5

Offices

Exterior window components

4.7 - 8.4

Exterior door components

10.5

Front porch ceiling

Interior and exterior window components

Interior and exterior door components

Printing Press

6.5

5.6 - 20.1

6.6 - 16.2

Exterior fireplace components

1.0

North kitchen wall

1.1

Baseboards of Room #2

14.0

Door jamb of shed

2.9

2.4 Cleanup Standards for Major Contaminants

The US EPA has jurisdiction over demolition and remediation activities on Native American lands.

The Pueblo of Acoma anticipates federal standards for recreational use will be sufficient for

cleanup standards. Cleanup activities will be overseen by the New Mexico Environment

Department Ground Water Quality Bureau (NMED GWQB).

2.5 Laws & Regulations Applicable to the Cleanup

Laws and regulations that are applicable to this cleanup include the Brownfields Revitalization

Act, Asbestos Hazard, Emergency Response Act (AHERA), NESHAP, and OSHA worker protection

requirements apply including contractor and employee training, notice of intent, protection of

workers and the public.

3.0

Evaluation of Cleanup Alternatives

To address contamination at the site, three different alternatives were considered including

Alternative 1: No Action, Alternative 2: Implementation of an Operations and Maintenance

(O&M) program, Alternative 3: Abatement. In accordance with EPA requirements each

alternative is evaluated using the following criteria:

•

Short-Term Effectiveness: Addresses the effects of the alternative during the construction

and implementation of remedial action objectives (RAO). Under this criterion,

alternatives are evaluated for their effects on human health and the environment during

implementation of the remedial action.

•

Long-Term Effectiveness and Permanence: Addresses the risks that remain at the site

after the RAO have been met. Ther primary focus of this evaluation is the extent and

effectiveness of controls used to manage the risk posed by treatment residuals or

untreated wastes.

•

Implementability: Addresses the technical and administrative feasibility of implementing

an alternative and the availability of various services and materials that may be required

during its implementation. The following factors were considered: technology

construction ability, monitoring requirements, equipment availability, and regulatory

agency approvals.

•

Costs: Intended for planning purposes to compare cost estimates.

To satisfy NMED GWQB and EPA requirements, the success, feasibility, and costs of each

alternative was considered before selecting a recommended cleanup alternative. The following

alternatives were considered:

1. No action

2. Implementation of an Operations and Maintenance (O&M) program

3. Abatement

3.1 Alternative 1 - No Action

Under this alternative, no action would be undertaken to reduce exposure to ACM and LBP. The

building on the site would remain in the current state of disrepair.

3.1.1 Short-Term Effectiveness

There is no short-term effectiveness associated with this alternative. Future workers for all

construction and demolition tasks would be exposed to unacceptable risks.

3.1.2 Long-Term Effectiveness

There is no long-term effectiveness associated with this alternative. Potential exposure risks

would not be mitigated.

3.1.3 Implementability

There would be no required actions or technology necessary to implement this option. This

alternative would result in no administrative burden. No permits or approvals would be required.

Because site risks are not mitigated under the No Active alternative, regulatory acceptance would

not be achieved, and the buildings would not be demolished to allow future redevelopment.

3.1.4 Costs

There are no costs associated with this alternative.

3.2 Alternative 2 - Implementation of an ACM and LBP O&M Program and Partial Abatement

This alternative would leave all ACM and LBP in place and monitored to ensure ACM and LBP

degradation does not occur. An O&M Program is a formulated plan of training, cleaning, work

practices, and surveillance to maintain ACM and LBP within buildings in good conditions. The goal

is to minimize exposure of all building occupants to related hazards.

3.2.1 Short-Term Effectiveness

To accomplish this objective, EPA Setting up an Asbestos Operations and Maintenance (O&M)

Program | US EPA recommends that an O&M program includes:

•

Maintain ACM and LBP in good condition

Ensure proper cleanup of contaminants previously released

Prevent further releases of contaminants

Monitor the condition of ACM and LBP

Impacts during implementation of an O&M program would include possible exposure of workers

within the buildings to ACM and LBP.

3.2.2 Long-Term Effectiveness

An ACM and LBP O&M program and partial abatement would not be an effective treatment for

the site because several buildings are in poor condition. This alternative assumes that only

minimal inspection and maintenance is required (i.e., flooring, plaster, stucco, painting, etc.)

3.2.3 Implementability

The administrative burden of implementing this alternative would be high. This alternative would

require significant amounts of staff time to oversee ongoing O&M program activities at the site.

Although an O&M program could be implemented, the Pueblo of Acoma does not intend to

redevelop the site for reuse.

3.2.4 Costs

The cost of implementing an O&M program has not been detailed. Given the conditions of the

five site buildings, especially concerning the cafeteria building, significant initial costs are

anticipated. The O&M program activities could be performed by trained staff at the site, and

material costs to maintain the integrity of the ACM and LBP are low, annual O&M costs are likely

to be less than $2,000 per year when considering both materials and labor. Costs the first year

would be substantially higher, while trending downward for several years after the initial

assessment. Estimated cost for 30 years of O&M at $2,000 per year total $60,000.

3.3 Alternative 3 – Abatement

The Abatement alternative would require the removal of all ACM and LBP. Prior to the demolition

of any building, all ACM and LBP materials would be transported and disposed of at a licensed

disposal facility.

3.3.1 Short-Term Effectiveness

Adverse impact to human health and the environment during implementation can be avoided

given that the contractor will be required to comply with all health and safety requirements for

demolition and renovation projects, which are oversaw by NESHAP, OSHA, and the State of New

Mexico including air monitoring, temporary pressure differential and air circulation system

implementation, installation of temporary enclosures, use of respiratory protection, use of

decontamination units, and site cleaning and decontamination.

3.3.2 Long-Term Effectiveness

Abatement will provide long-term permanent effectiveness. All identified ACM and LBP material

will be removed from the site, eliminating the potential health hazard to building occupants,

visitors, and demolition workers.

3.3.3 Implementability

This alternative is easily implemented using currently available construction technology and

equipment. A qualified contractor will be retained to complete the removal, disposal, and

encapsulation.

The NMED Solid Waste Bureau (SWB) regulations require that all waste ACM (more than 1%

asbestos) should be disposed of at a special waste landfill, which requires removal of ACM and

separation from non-asbestos materials. NESHAP guidelines must be followed. When ACM are

to be removed, the following procedures should be adhered to:

•

Comply with requirements for asbestos demolition and renovation projects, which are

oversaw by NESHAP, OSHA, and the State of New Mexico.

•

Retain the services of an independent analytical testing laboratory or consulting firm to

monitor the performance of the abatement contractor, the completeness of the removal

work, and air quality before, during and after the removal work, ensuring the contractor

meets project is compliant with EPA and OSHA standards.

•

Conduct a final visual inspection and air clearance sampling prior to occupying the work

area.

•

Document and store all correspondence documents from the abatement contractor and

the testing laboratory.

•

Notify local, state, and federal air pollution officials by letter prior to ACM removal, as

required by the NESHAP regulations.

Considering the number of impacted buildings, the administrative burden of implementing this

alternative is considered moderate to high. Oversight and documentation from the NMED and

the Pueblo of Acoma is required during and after the cleanup process. Project management of

document review and storage, abatement contractor coordination and oversight, and site

inspections are required to comply with EPA standards.

3.3.4 Costs

The cost of the abatement is estimated at approximately $385,990.00. This cost includes

construction costs implemented by the abatement contractor.

4.0

Recommended Alternative

The considered alternatives are summarized in Table 3 below. The recommended alternative is

Alternative 3, abatement. The no action alternative is not an option because ACM and LBP have

been identified in the all five site buildings, and no action would not allow redevelopment of the

site. The administrative burden of implanting Alternative 2 would be high. This alternative would

require significant amounts of staff time to oversee continued O&M activities. Given that several

buildings are in dilapidated conditions and will no longer be suitable for human occupancy,

Alternative 2 will still require the abatement significant quantities of ACM and LBP materials.

Alternative 3 is feasible as there is a manageable administrative burden and will yield significant

environmental and human health benefits through elimination of hazards from the site prior to

redevelopment.

Table 3. Evaluation Criteria for Considered Alternatives

Alternative

Short-Term

Effectiveness

Long-Term

Effectiveness

No Action

None: future site None: future residents

workers exposed to and visitors would be

exposed to

unacceptable risk

unacceptable risks

associated with ACM,

and LBP.

Long-Term

O&M

Ongoing impacts

during

implementation of

an O&M program

would include

possible ACM, and

LBP exposure to

Moderate: Long term

effectiveness would

only be attained if

very active monitoring

was performed and

localized

mitigation (sealing,

etc.) was performed

Implementability

Easily implemented, as

no action is taken.

Because site risks are

not mitigated under the

No Action alternative,

regulatory acceptance

would not be achieved,

and the site would not

be able to be

redeveloped.

The administrative

burden for

implementing this

alternative would be

high. This alternative

would require

significant amounts of

staff time to

Costs

None

$60,000

Abatement

5.0

workers within the

building.

Alternative poses the

greatest short-term

risks unless all work

is performed by a

certified contractor

implementing all

appropriate

requirements.

by highly trained

personnel.

This alternative would

provide the greatest

long-term

effectiveness and

permanence, as all

ACM and LBP would

be removed.

oversee ongoing O&M

activities at the site.

Routinely implemented

at sites throughout the

U.S. by certified

asbestos contractors.

$385,990.00

References

AECOM. 2018. Phase I Environmental Site Assessment Vacant Former Acomita Day School, 294 Pueblo

Road, Pueblo of Acoma, Cibola County, New Mexico 87034, April 23, 2018

AECOM. 2018. Phase II Environmental Site Assessment Acomita Day School, 294 Pueblo Road, Pueblo of

Acoma, Cibola County, New Mexico 87034, December 10, 2020

SMA. 2018. Limited Phase II Environment Site Assessment Acomita Day School, 294 Pueblo Road, Pueblo

of Acoma, Cibola County, New Mexico 87034, December 16, 2021

Occupational Safety and Health Administration (OSHA). 2022. Safety and Health Topics/Asbestos.

Accessed February 1, 2024. https://www.osha.gov/asbestos

U.S. Environmental Protection Agency (EPA). 1988. Guidance for conducting remedial investigations and

feasibility studies under CERCLA. Interim Final. EPA/540/G 89/004. October 1988.

U.S. EPA. 2022. Learn about asbestos. <https://www.epa.gov/asbestos/learn-aboutasbestos#

exposed>. Accessed February 1, 2024.

U.S. EPA. 2022. Setting up an asbestos operations and maintenance (O&M) program. Accessed

February 1, 2024. <https://www.epa.gov/asbestos/setting-asbestos-operations-andmaintenanceom-program>.

Figures

SUBJECT PROPERTY

500

1000

SCALE: 1"=1,000 FT.

Basemap from Cubero, NM, USGS Quadrangle (1971)

SOUDER, MILLER & ASSOCIATES

SMA

Engineering Environmental

Surveying

5454 VENICE AVENUE NE, SUITE D

Albuquerque, NM 87113

Phone (505) 299-0942 Fax (505) 293-3430

www.soudermiller.com

Serving the Southwest & Rocky Mountains

Albuquerque, Farmington, Las Cruces, Roswell, Santa Fe, NM

Cortez - Grand Junction, CO - Safford, AZ - Moab, UT, El Paso, TX

Drawn

Checked

Approved

AJE

SAM

Date:

ACOMITA DAY SCHOOL - VICINITY MAP

FEBRUARY 2024

Scale: Horiz: 1= 1,000'

Vert: NA

Project No:

Sheet:

1432164

FIGURE 1

P:\1-NMED Acomita Day School (1430152)\CAD\Civil\2024-02 Brownfields Docs.dwg, 2/13/2024 1:14:35 PM mjk

CLASSROOMS

ADMINISTRATIVE

OFFICES

CAFETERIA

DISPENSARY

PRINTING PRESS

SHEDS

250

500 FT.

SCALE: 1"= 500 FT.

Legend

Approximate Property Boundary

Building Material with % Asbestos Content

Aerial Photo Courtesy of Google Earth (Image date: 4/7/2019)

SOUDER, MILLER & ASSOCIATES

SMA

Engineering Environmental

Surveying

5454 VENICE AVENUE NE, SUITE D

Albuquerque, NM 87113

Phone (505) 299-0942 Fax (505) 293-3430

www.soudermiller.com

Serving the Southwest & Rocky Mountains

Albuquerque, Farmington, Las Cruces, Roswell, Santa Fe, NM

Cortez - Grand Junction, CO - Safford, AZ - Moab, UT, El Paso, TX

ACOMITA DAY SCHOOL - ASBESTOS DATA

Drawn

Checked

Approved

AJE

SAM

Date:

FEBRUARY 2024

Scale: Horiz: 1= 500'

Vert: NA

Project No:

Sheet:

1432164

FIGURE 2

P:\1-NMED Acomita Day School (1430152)\CAD\Civil\2024-02 Brownfields Docs.dwg, 2/13/2024 1:15:32 PM mjk

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.