Department of the Interior - Indian Affairs2013 Environmental Management Assessment and Performance Program

Division of Environmental and Cultural Resources Management12220 Sunrise Valley Drive

Reston, Virginia 20191

Audit Start Date 4/30/2013 : Audit Completion Date 5/212013

F53-15 Fond du Lac Ojibwa School (K-12)-GD

Audit Report

Print Date 5/1/2013Auditor 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 anyway, the performance of this Audit, including but not limited to, current or previous employment at thefacility 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 removemyself from the audit process with full disclosure of the interest, direct or indirect, to the IA ContractorOfficer's Representative.

/s/ 5/1/13Auditor Date

Facility Acceptance

Jennifer Johnson have been briefed on the results ofthis EMAP Audit to includeboth environmental compliance and environmental management system (EMS) conformance findings. Ihave also been provided a copy of the EMAP report.

/s/ principal 5/1/13Signature Title Date

OSACEOF VII'.CINIA.

Location Information Senior Line Official, Address and Phone Number

Michael Rabideux, Superintendent105 University RoadCloquet, MN 56359218-878-7571Date of Last EPA Inspection (if known)

2008 Pesticide/TSCA

F53-15 Fond du Lac Ojibwa School (K-12)-GDF50-01a Minneapolis ELO

Name and Position of On-Site Representatives

Michael Rabideux, Superintendent, 218-878-7571,mikerabideux@fdlrez.comDaniel Anderson, GranUAccountability Manager,218-878-7242, danderson@fdlrez.comAndrea Junker, FDL EHS, 218-878-7242,andreajunker@fdlrez.comJennifer Trotterchaude, Administrative Secretary,jennifertrotterchaude@fdlrez.comEverett Bad Wound, Minneapolis ELO, 952-851-5421,everet.badwound@bie.eduPurpose and Assessment Time Frame

The purpose of the environmental assessment is to verify environmental compliance status. The assessmenttimeframe 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 withDECRM approvalP1: Health or Safety Concerns - Fully corrected 0 - 90 days; CAP to EPA in 0 - 30 days if under EPA CAFOP2: Regulatory Liability (Criminal/Civil Penalties) - Fully corrected 0 - 90 days; CAP to EPA in 0 - 30 days ifunder EPA CAFOP3: E.O. Statutory, Administrative or Mission - Fully corrected 0 - 120 daysP4: Good Engineering/Best Mgt Practice - Fully corrected 0 - 180 days

Auditor Comments (Include a description of the information reviewed, the on-site activities conducted, adescription of any problems or difficulties in conducting the assessment, and measures taken to address theproblems)

Fond du Lac (FDL) Ojibwe School is located in Cloquet, MN and is a Grant Day School that serves approximately 272students in grades K-12.

Personnel were very accommodating and supportive during the audit. Mr. Everett Bad Wound, Minneapolis ELO, actedas the auditor's federal escort for the audit. The GranUAccountability Manager, Dan Anderson, is the FDL School POCfor 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 variousenvironmental 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 OperatingProcedures (SOPs) and associated training records for SOPs; manifests and associated records for used lamprecycling, used oil recycling, used oil filter recycling, and disposal of oil and water from bus garage holding tank (fromvehicle washing activities).

The auditor performed a detailed walkthrough and review of the school's operations and activities. The school includesthe main school building (22) and 2 Family and Child Education buildings (20 & 21),2 garages (19 & 25), and a busmaintenance garage (18). School operations include administration, classrooms, computer lab, library, kitchen/cafeteria,building maintenance, janitorial services, grounds maintenance, outdoor recreation areas, and bus maintenance. Theschool 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 isdischarged 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'senvironmental information. The school has identified 18 environmental aspects (none rank as significant) and 4 objectivesand targets that have been reviewed and updated annually. EMS, environmental compliance, and sustainabilityinformation is communicated annually at the school's staff and faculty orientation meeting. The most recent orientationwas conducted August 27,2012 and included the Indian Affair's Environmental Policy, EMS, the Asbestos ManagementPlan, 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. Recyclingstreams include plastic, paper, aluminum, cardboard, ink cartridges, and paper.The school has minimized chemicals used in janitorial operations, purchases non-toxic cleaning supplies and maintainsa 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 lampswere properly labeled and stored in appropriate, closed containers. The floor drains in the Bus Garage vehicle wash bayare connected a holding tank which is emptied by Safety-Kleen.

The school has implemented several energy/water conservation measures to include lighting retrofits, anoccupancy-sensing blower in the gymnasium, motion operated sinks, and an energy management software system forthe school building.

The school has two natural gas fired boilers and an emergency diesel generator. With the assistance of the FDL NaturalResource Department, calculations to determine if the boilers or generator require registration under the New SourcePerformance 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 practicesinto their curriculum. The FDL Natural Resource Department also educated the school children on environmental topicsand supports the school in several environmental areas.

Facilities personnel have significantly improved environmental compliance and implementation of the EMS since the2010 EMAP audit.

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

P2

Finding #F53-15_ 4-2013_HW_1

Root Causes Days of N.C. Location

Unknown Building 19, Bus Garage40 CFR 261.31-33 &

262.11 (a-d)Finding

1. Failure to conduct hazardous waste determination(s). 40 CFR 261.31-33; 262.11 (a-d) (RCRA)

3. No Procedures (EMS

Element 10)

Bldg Construction Date

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 261-31-33. 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.

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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

P2

Finding #F53-15_ 4-2013_ TS_23

Root Causes Days of N.C. Location

Unknown School-Wide40 CFR 763.93(g)(3) 4. Not Following

Procedures (EMS

Element 10)Finding

23. Failure to maintain a complete, updated copy of the Asbestos Management Plan at the School's

administrative office. 40 CFR 763.93(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

Bldg Construction Date

N/A

administrative office, leaving the AMP incomplete.Recommended Corrective Actions

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

763.93(g)(3). Maintain a copy of the Asbestos Management Plan in the EMS.

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