Department of the Interior - Indian Affairs 2013 Environmental Management Assessment and Performance Program

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1 Department of the Interior - Indian Affairs 2013 Environmental Management Assessment and Performance Program Division of Environmental and Cultural Resources Management Sunrise Valley Drive Reston, Virginia Audit Start Date 4/30/2013 : Audit Completion Date 5/ F53-15 Fond du Lac Ojibwa School (K-12)-GD Audit Report Print Date 5/1/2013 Auditor Certification Tony Wes tbrook,certify thatto the best of my knowledge and belief, I do not have any personal, financial, or organizational contlicts of interest that will compromise, in any way, the performance of this Audit, including but not limited to, current or previous employment at the facility being audited. Additionally, if applicable, I meet the requirements set forth in 18 U.S.C. 207, Post-Employment Restrictions. If a conflict of interest is determined to exist, I will immediately remove myself from the audit process with full disclosure of the interest, direct or indirect, to the IA Contractor Officer's Representative. /s/ 5/1/13 Auditor Date Facility Acceptance Jennifer Johnson have been briefed on the results ofthis EMAP Audit to include both environmental compliance and environmental management system (EMS) conformance findings. I have also been provided a copy of the EMAP report. /s/ principal 5/1/13 Signature Title Date OSACE OF VII'.CINIA.

Location Information F53-15 Fond du Lac Ojibwa School (K-12)-GD F50-01a Minneapolis ELO Name and Position of On-Site Representatives Michael Rabideux, Superintendent, 218-878-7571,

2 Location Information F53-15 Fond du Lac Ojibwa School (K-12)-GD F50-01a Minneapolis ELO Name and Position of On-Site Representatives Michael Rabideux, Superintendent, , Daniel Anderson, GranUAccountability Manager, , Andrea Junker, FDL EHS, , Jennifer Trotterchaude, Administrative Secretary, Everett Bad Wound, Minneapolis ELO, , Purpose and Assessment Time Frame Senior Line Official, Address and Phone Number Michael Rabideux, Superintendent 105 University Road Cloquet, MN Date of Last EPA Inspection (if known) 2008 Pesticide/TSCA The purpose of the environmental assessment is to verify environmental compliance status. The assessment timeframe is from the present to the past five years. Priority Ranking of Assessment Findings and Timeframe P5: Emergency Action - Immediate response to protect health, safety or environment; 24-hour action with DECRM approval P1: Health or Safety Concerns - Fully corrected 0-90 days; CAP to EPA in 0-30 days if under EPA CAFO P2: Regulatory Liability (Criminal/Civil Penalties) - Fully corrected 0-90 days; CAP to EPA in 0-30 days if under EPA CAFO P3: E.O. Statutory, Administrative or Mission - Fully corrected days P4: Good Engineering/Best Mgt Practice - Fully corrected days Auditor Comments (Include a description of the information reviewed, the on-site activities conducted, a description of any problems or difficulties in conducting the assessment, and measures taken to address the problems)

Fond du Lac (FDL) Ojibwe School is located in Cloquet, MN and is a Grant Day School that serves approximately students in grades K-12.

3 Fond du Lac (FDL) Ojibwe School is located in Cloquet, MN and is a Grant Day School that serves approximately students in grades K Personnel were very accommodating and supportive during the audit. Mr. Everett Bad Wound, Minneapolis ELO, acted as the auditor's federal escort for the audit. The GranUAccountability Manager, Dan Anderson, is the FDL School POC for EMAP and was available throughout the audit. The last EMAP audit was conducted on September 16,2010. Prior to the audit, the auditor reviewed a pre-visit questionnaire and reviewed the school's EMS SharePoint website. During the audit, additional environmental documents and records, which were available in hard copy format in various environmental manuals maintained by the GranUAccountability Manager, were reviewed. Documents reviewed included: The Asbestos Management Plan, which is maintained in the Grant/Accountability Manager's office; Standard Operating Procedures (SOPs) and associated training records for SOPs; manifests and associated records for used lamp recycling, used oil recycling, used oil filter recycling, and disposal of oil and water from bus garage holding tank (from vehicle washing activities). The auditor performed a detailed walkthrough and review of the school's operations and activities. The school includes the main school building (22) and 2 Family and Child Education buildings (20 & 21),2 garages (19 & 25), and a bus maintenance garage (18). School operations include administration, classrooms, computer lab, library, kitchen/cafeteria, building maintenance, janitorial services, grounds maintenance, outdoor recreation areas, and bus maintenance. The school does not have any underground or aboveground storage tanks (UST/AST). Drinking water is supplied by the City of Cloquet and no drinking water treatment is performed onsite. Wastewater is discharged to the City of Cloquet and Minnesota Power provides electricity to the school. The school has implemented its EMS and the GranUAccountability Manager accesses and updates the EMS website. The school has done an excellent job of using the EMS SharePoint website as the repository for the school's environmental information. The school has identified 18 environmental aspects (none rank as significant) and 4 objectives and targets that have been reviewed and updated annually. EMS, environmental compliance, and sustainability information is communicated annually at the school's staff and faculty orientation meeting. The most recent orientation was conducted August 27,2012 and included the Indian Affair's Environmental Policy, EMS, the Asbestos Management Plan, SOPs for waste disposal (antifreeze, batteries, paint, electronics, fluorescent lamps, used oil, etc.), documentation of green purchasing and the Green Purchasing Policy, recycling, chemical inventories, vermicomposting, and green cleaning supplies. The Indian Affairs Environmental Policy is posted throughout the school. The school has a robust recycling program and has diverted over 10,000 pounds of waste from the landfill. Recycling streams include plastic, paper, aluminum, cardboard, ink cartridges, and paper. The school has minimized chemicals used in janitorial operations, purchases non-toxic cleaning supplies and maintains a chemical inventory with Material Safety Data Sheets that are reviewed and updated annually. Used oil drums were properly labeled and used oil filters were properly drained and collected for recycling. Used lamps were properly labeled and stored in appropriate, closed containers. The floor drains in the Bus Garage vehicle wash bay are connected a holding tank which is emptied by Safety-Kleen. The school has implemented several energy/water conservation measures to include lighting retrofits, an occupancy-sensing blower in the gymnasium, motion operated sinks, and an energy management software system for the school building. The school has two natural gas fired boilers and an emergency diesel generator. With the assistance of the FDL Natural Resource Department, calculations to determine if the boilers or generator require registration under the New Source Performance Standards (NSPS) have been done and the appropriate minor sources have been registered with the EPA. Several teachers are involved in a sustainability group outside of the school and plan to incorporate sustainable practices into their curriculum. The FDL Natural Resource Department also educated the school children on environmental topics and supports the school in several environmental areas. Facilities personnel have significantly improved environmental 2010 EMAP audit. compliance and implementation of the EMS since the

Audit Report F53-15 Fond du Lac Ojibwa School (K-12)-GD on 4/30/2013-5/2/2013 (EMAP (v 1)) by Westbrook, Tony Hazardous Waste Management Reference Priority Finding # Root Causes Days of N.C. Location 40 CFR 261.

4 Audit Report F53-15 Fond du Lac Ojibwa School (K-12)-GD on 4/30/2013-5/2/2013 (EMAP (v 1)) by Westbrook, Tony Hazardous Waste Management Reference Priority Finding # Root Causes Days of N.C. Location 40 CFR & P2 F53-15_ _HW_1 3. No Procedures (EMS Unknown Building 19, Bus Garage (a-d) Element 10) Finding Bldg Construction Date 1. Failure to conduct hazardous waste determination(s). 40 CFR ; (a-d) (RCRA) 1996 Assessor's Comments Six (6) aerosol cans with broken nozzles and containing product and propellant were stored in a flammable cabinet in the bus garage. The aerosol cans are not usable. The contents are under pressure, and the contents may meet the definition of a hazardous waste. Because of these risks, the can and their contents must be disposed of properly. Recommended Corrective Actions Waste is any liquid, solid or gaseous material that can no longer be used for its originally intended purpose, or any material which is still usable but is being discarded. Hazardous waste is defined two ways: 1) Listed Hazardous Waste, and 2) Characteristic Hazardous Waste. Prepare an inventory of all chemical wastes. Determine if the wastes are 1) Listed Hazardous Wastes or 2) Characteristic Hazardous Waste 1) For "Listed Hazardous Wastes" these are specific wastes that are classified in the 40 CFR Regulations, see List at 40 CFR If your waste is on this List, it is a Listed Hazardous Waste and this is your determination. 2) For "Characteristic Hazardous Wastes," these wastes have hazardous characteristics-both physical hazards (corrosive, ignitable, reactive) or adverse health effects (toxic). If you have the Material Safety Data Sheet (MSDS) for the solid waste stream, review the MSDS to see if it is listed as a hazardous waste. If your waste has any of the characteristics, it is hazardous and this is your determination. Maintain the record of your hazardous waste determination on your EMS SharePoint site. If you cannot make a determination, prepare your chemical waste inventory and request a Contract for a hazardous waste determination, removal and disposal. Keep a copy of the contract, hazardous waste determination, and removal/disposal manifests on your EMS SharePoint site. Four of the six cans in the bus garage that are not usable due to broken nozzles. QSA~.E OF VIJr...e; IN 1)0.. 4

5 Audit Report F53-15 Fond du Lac Ojibwa School (K-12)-GD on 4/30/2013-5/2/2013 (EMAP (v 1)) by Westbrook, Tony Toxic Substances Management Reference Priority Finding # Root Causes Days of N.C. Location 40 CFR (g)(3) P2 F53-15_ _ TS_23 4. Not Following Unknown School-Wide Procedures (EMS Element 10) Finding 23. Failure to maintain a complete, updated copy of the Asbestos Management Plan at the School's Bldg Construction N/A administrative office. 40 CFR (g)(3) (AHERA) Assessor's Comments A complete, updated copy of the Asbestos Management Plan was not available for review at the time of the audit. The most recent AHERA required information was available on the EMS SharePoint website, but was not included with the Asbestos Management Plan located in the administrative office, leaving the AMP incomplete. Recommended Corrective Actions Date Ensure that a complete, updated copy of the Asbestos Management Plan is at the School's administrative offices. The plan must be available to workers before they start work in any part of the school. The plan must also be available for inspection by parties as designated in 40 CFR (g)(3). Maintain a copy of the Asbestos Management Plan in the EMS. QSA~.E OF VIJr...e; IN 1)0.. 5

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