Black Falls Water Project Policy Findings

THE BLACK FALLS WATER PROJECT:

POLICY FINDINGS AND RECOMMENDATIONS

RITA SEBASTIAN, MA: SID

THE CAPACITY BUILDING INITIATIVE; HELLER SCHOOL FOR SOCIAL POLICY; BRANDEIS
UNIVERSITY

RITA@BRANDEIS.EDU 857-204-5653

CONTRIBUTING CONSULTANTS: RONALD TOHANNIE; BILL SEBASTIAN

SEPTEMBER 30, 2009

PREFACE

This paper presents findings and policy recommendations resulting from the Black Falls Water Project. The project was a
collaboration that began in July, 2008, between the US EPA and a coalition of families in the Black Falls region of the Navajo
Nation. The coalition was organized and supported by Forgotten People CDC (FP CDC), a community organization based in
Tuba City, AZ, with guidance from an academic partner, which was the Capacity Building Initiative at the Heller School for
Social Policy, Brandeis University. The project was primarily funded from a grant from the EPA Environmental Justice Small
Grants Program.

The project addressed the issues faced by families that do not have access to piped water. In particular, it examined how
sanitation and safe drinking water can be provided sustainably to families who will never have access to piped water due to
their remote location. Prior federal and tribal programs were mostly focused on extending the network of pipelines, so that
a need existed for an effective plan to address this population. Many of the water sources previously used by the families
were contaminated by uranium, so that the project also addressed health issues related to this exposure.

In the process of managing the project, the authors of this paper gained insight as to how the needs of this unique
population may be effectively addressed. This data may be useful to a variety of stakeholders involved in programs to
provide safe drinking water and sanitation services to off-grid families as well as the mitigation of uranium contamination
on the Navajo Nation. In particular, serving this population is a key part of meeting the US commitment to reduce the
number of American Indian and Native Alaskan households without access to sanitation and safe drinking water by 50% by
2015. Hopefully, some of these findings and policy recommendations will be of use to legislators as well as federal and
tribal agencies that are creating the programs to meet these goals.

Black Falls Project: Policy Findings & Recommendations Rev 1.0 September 30, 2009 2

CONTENTS

The Black Falls Water Project:.......................................................................................................................................................1

Policy Findings and Recommendations.........................................................................................................................................1

Rita Sebastian, MA: SID.........................................................................................................................................................1

The Capacity Building Initiative; Heller School for Social Policy; Brandeis University........................................................1

rita@brandeis.edu 857-204-5653......................................................................................................................................1

Contributing Consultants: Ronald Tohannie; Bill Sebastian............................................................................................1

September 30, 2009..............................................................................................................................................................1

Preface...........................................................................................................................................................................................2

1. Summary of Findings and Recommendations:..........................................................................................................................6

1.1 Community outreach:..........................................................................................................................................................6

1.2 Water delivery:....................................................................................................................................................................6

1.3 Sanitation:............................................................................................................................................................................7

1.4 Temporary water storage system:.....................................................................................................................................7

1.5 Health care: ........................................................................................................................................................................8

2. Overview of the Black Falls Water Project................................................................................................................................8

2.1 Participants in the Project...................................................................................................................................................9

2.2 Problems faced by the water haulers...............................................................................................................................10

2.3 Efforts to Improve Access to Water..................................................................................................................................11

2.4 Access to Water as an Environmental Justice Issue..........................................................................................................11

3. Community Outreach..............................................................................................................................................................13

3.1 Explanation of Findings:....................................................................................................................................................13

3.1.1 Isolation of Population..............................................................................................................................................13

3.1.2 Fragmentation of delivery networks..........................................................................................................................13

3.2 Details of Recommendations:...........................................................................................................................................14


4. Water Delivery ........................................................................................................................................................................15

4.1 Explanation of Findings & Recommendations..................................................................................................................15

4.2 Costs of current delivery options .....................................................................................................................................16

4.3 Ways to reduce delivery costs..........................................................................................................................................16

4.3.1 Road improvements and maintenance:.....................................................................................................................16

4.3.2 Home Storage Tank Size: ..........................................................................................................................................17

4.3.3 Water Delivery Coops:................................................................................................................................................17

4.4 Demand Reduction...........................................................................................................................................................18

5. Sanitation.................................................................................................................................................................................18

5.1 Explanation of Findings & Recommendations.................................................................................................................19

5.1.1 Design Considerations................................................................................................................................................19

5.1.2 Service Model.............................................................................................................................................................19

5.2 Design of Sanitation Systems...........................................................................................................................................20

6. Temporary Water Storage and Distribution System...............................................................................................................21

6.1 Explanation of Findings & Recommendations.................................................................................................................21

6.2 Construction details..........................................................................................................................................................21

6.3 System Cost Details:.........................................................................................................................................................22

7. Health Care..............................................................................................................................................................................23

7.1 Medical outreach performed in the project.....................................................................................................................23

7.2 Explanation of Findings and Recommendations...............................................................................................................24

7.2.1 Fragmentation of response and Community Outreach:............................................................................................24

7.2.2 Training of health care providers..............................................................................................................................24

7.2.3. Research on uranium contamination.......................................................................................................................24

7.2.4. Programs to address uranium contamination of drinking water.............................................................................25

8. Conclusion...............................................................................................................................................................................25

Bibliography.................................................................................................................................................................................26

Appendix :....................................................................................................................................................................................28


Appendix A: Community Mapping Project..............................................................................................................................28

Homes where water systems Abandoned uranium mines:................................................................................................28

installed in the project ......................................................................................................................................................28

Truck access points: Potential depot site for storing water ................................................................................28

Appendix B: Project Partners and Contributors......................................................................................................................29

Appendix C: Water Delivery Costs - Analysis of Data from St Bonaventure Mission.............................................................32

Appendix D: Water Delivery Costs - Analysis of costs to service individual homes in Black Falls..........................................33

Appendix E: Cost of Supplying Water for Flush Toilets in Black Falls.....................................................................................34


1. SUMMARY OF FINDINGS AND RECOMMENDATIONS:

The Black Falls project brought together technical experts, government stakeholders, and the affected families for a
comprehensive and holistic examination of multiple services, including providing safe drinking water, sanitation, and
uranium-related health services. The findings and recommendations are organized into five sections. The first examines the
service delivery model for providing families with sanitation, drinking water, and uranium-related health services. By
working intimately with the families in need of these services, this project provides a unique bottom-up view of the process
through which people interface with the federal and tribal agencies providing the services. The remaining sections look at
details of individual services. The second section examines how the design of sanitation systems needs to be adjusted for
off-grid systems. The third covers strategies for providing cost effective and sustainable water hauling services. The fourth
use of the temporary water storage system designed in the project as an immediate and economical way to provide safe
drinking water to these families. The final section looks at the need to improve access to health services for families that
have been exposed to drinking water containing uranium and other contaminants.

1.1 COMMUNITY OUTREACH:

Black Falls may be typical in that the people most in need of services were not integrated into the existing mechanisms for
delivering these services. The families had little contact with chapter houses or federal/tribal agencies working on the issues
related to drinking water and uranium contamination. Most of the people in the community did not know what assistance
was possible or how to go about interfacing with the various programs. The delivery of these services tends to be
fragmented and non-transparent. These problems result from a top-down service delivery architecture in which each
federal and tribal agency conducts its own outreach program, selects the beneficiaries of its services, and decides what
services to provide and when to provide them.

A more effective service delivery model would use a bottom-up approach to assess the needs of each family and then use
the various federal and tribal resources to meet these requirements using an integrated and holistic approach. This
program would serve as the community point of presence for several related services: supplying water, uranium
contamination and compensation programs, sanitation, and health care with respect to drinking water contamination. The
program needs to be integrated into the inter-agency planning so that the consumer perspective is integrated into the
planning process. It needs to be empowered so as to enforce the required coordination between the agencies providing the
various services. It needs to be adequately financed so as to enable the delivery of the required services to all the families in
the affected population.

In the Navajo Nation, the chapter houses typically serve as a facilitator for community services. While the chapters could
work closely with this program, the program needs to be independently staffed and managed. Operation of the program
requires in-depth familiarity with many different agencies and technical issues, and the chapter staffs can not be expected
to fill this role. The program forms the centerpiece of an integrated and efficient means of service delivery spanning
multiple federal and tribal agencies as well as a way to empower the local communities and chapter houses in the
achievement of environmental justice.

1.2 WATER DELIVERY:

The recent grant from the EPA to the Navajo Department of Water Resources to support a pilot water delivery program is a
positive step toward providing assistance to families that will never be able to be connected to pipelines because of their


remote location. A program to deliver water using 2000+ gallon tankers may be able to solve the problem for families in
close proximity to the maintained roads. The more remote families face additional challenges. Many of these homes can
not be reached by tanker trucks unless road repairs are performed and ongoing road maintenance is provided. For one
home in Black Falls, the access is currently so difficult that it can not be reached using a pickup truck carrying more than 100
gallons of water.

Recommended approaches for addressing the needs of the more remote homes include:

• Develop sustainable strategies for maintaining access roads to remote homes.

• Install the temporary home storage systems described in section 6, as the savings in delivery costs from the
increased storage capacity can pay for the system cost within a year.

• Demand reduction strategies - the amount of water that needs to be hauled can be reduced by appropriate design
of sanitation systems and off-loading consumption to more accessible locations such as micro-small washeterias
with showers and other facilities.

• Explore alternative delivery approaches that can reduce delivery costs, such as the use of coops to reduce labor
costs.

The community outreach program discussed in section 3 would enhance the effectiveness of the water hauling service by
providing monitoring and evaluation of the program, as well as cost-effective outreach and integration with other services.

1.3 SANITATION:

The experience at Black Falls identified two problems with respect to the deployment of sanitation systems in communities
similar to Black Falls. The first issue is that the current designs are poorly suited for families that have to haul water. For
example, the cost of hauling water for a flush toilet in some extreme cases can exceed $5000/year, and neither the families
nor the Navajo Nation have the resources to sustain this cost on a long term basis. Local U.S. Indian Health Service (IHS)
engineers have to work within requirements defined by the national office which did not take these challenges into
consideration.

To solve the first issue, the national IHS should provide funding and support for innovative designs that can provide
sustainable and healthy solutions at reasonable costs for water haulers. A program should deploy test installations to
evaluate the costs, operation, and sustainability for multiple competing designs. Furthermore, the sanitation designs for
each family need to be worked out using an integrated strategy that looks at the short and long term options for water
delivery .

The second issue is that the service delivery network for sanitation is fragmented and non-transparent. Families have to
interface separately with multiple agencies for different components such as plumbing, infrastructure, and funding. The
point of contact and process for each agency is not advertised, and once they have applied for services a family receives
little feedback about the status of their case. The proposed community outreach program would help address these issues.

1.4 TEMPORARY WATER STORAGE SYSTEM:

During the Black Falls water project, local residents designed and deployed a temporary water storage system using an
elevated external water storage tank and kitchen sink. The tank provides high-capacity storage as needed to support
efficient water delivery services and replaces the unsafe system of buckets currently in widespread use. The system can


provide an immediate and low cost means to provide safe access to drinking water to a large population. Minimal training
is needed to perform the on-site work, so that rapid up-scaling can be achieved using local labor. Deployment of the
systems links the people into the provider network for health care, water delivery, and other related services. The system
design is well suited for deployment via a community cooperative approach, which can reduce cost, improve sustainability,
and further enhance the integration of families into the service provider network.

1.5 HEALTH CARE:

The Black Falls project identified several problems in the health care services provided to families where the drinking water
may be affected by uranium and other contaminants:

• Fragmentation of the response: research, treatment, training of health care providers, and community outreach
tend to be provided by separate agencies without adequate integration

• Training of local health care providers training has begun, but is at an early stage and lacks funding as well as
monitoring and evaluation.

• Research on the impact of drinking uranium contaminated drinking water is incomplete, and little has been done
on issues such as consumption of contaminated livestock.

• No program provides compensation and treatment for uranium contamination of drinking water in the same way
as programs for down-winders and miners.

• Little community outreach has been done. For example, prior to the project, none of the families in Black Falls had
ever been screened for uranium issues or asked by a physician about their water supply.

Recommendations include providing more funding for these programs and using the funding to create a higher level of
service integration. In particular, the community outreach needs to be increased and a unified point of presence
established for these services.

2. OVERVIEW OF THE BLACK FALLS WATER PROJECT

The project was part of an effort to provide safe drinking water to communities in the former Bennett Freeze area on the
Navajo Reservation. Over 90% of the homes in this area do not have access to piped water, so that the families must haul
their water from other locations (HR5168, 2004). While health risks exist in the storage and transportation methods, the
main concerns are the sources being used. While some regulated sources are available, thousands of unregulated water
sources (EPA01) are also used on the reservation. These are subject to a variety of chemical and bacteriological
contaminants, but most attention was focused on uranium contamination. While this can occur from natural sources, the
major threat was contamination arising from the legacy of uranium mining in the region. Resolving that specific threat
required a comprehensive solution to providing safe water supply systems for the communities, and this in turn was
complicated by the other developmental issues affecting the communities, such as inadequate housing, roads, and
poverty. Because the environmental harm was impacting minority communities, the developmental problems were treated
as an Environmental Justice issue by the federal government.


While initially funded as a planning grant, the project expanded using additional private donations to include the
construction of water storage and distribution systems for 10 homes, creation of a community water hauling service, and
working with both the EPA and Indian Health Service (IHS) to design sanitation systems for the homes. A map of the
community showing the locations of homes, water sources, and abandoned uranium mines is provided in Appendix A. The
interactive map is available on-line at

http://maps.google.com/maps/ms?
hl=en&ie=UTF8&msa=0&msid=101202413487214467098.00045a91e3fe06498fccd&ll=35.703032,-111.242752&sp
n=0.320058,0.591888&z=11

A more detailed key to the map can be accessed at:

http://www.box.net/shared/static/s422miu7qm.doc

The completion of the construction and launching of the water hauling service was celebrated in a ribbon-cutting ceremony
on February 24, 2009 attended by representatives of the partner agencies as well as representatives of the Navajo Nation.
In June, 2009, the project received an Environmental Excellence award from the Navajo Nation EPA.

2.1 PARTICIPANTS IN THE PROJECT

The Black Falls Water Project was a collaboration between government, grassroots, and academic partners:

Forgotten People Community Development Corporation (FP CDC) is a grassroots organization representing communities in
the western half of the Navajo Nation. The communities are spread over almost 2 million acres of remote desert terrain in
the northeast of Arizona. From 1966 through 2007, the communities were subject to the Bennett Freeze, which was issued
by Bureau of Indian Affairs Commissioner Robert Bennett and prevented constructing or repairing homes, water supplies,
roads, and other facilities on land that was subject to a land dispute with the Hopi Tribe. President Obama signed a law
officially lifting the Bennett Freeze on May 8, 2009.

The EPA is involved in a major effort to improve access to safe water on the Navajo Nation as a result of two pressures. The
first is a commitment made by the EPA at the 2002 United Nations World Summit on Sustainable Development held in
Johannesburg, South Africa, in which the US pledged to reduce the number of its citizens lacking access to safe drinking


water and sanitation by 50% by 2015 (US 01, 2002). The largest concentration of such people was on the Navajo Nation,
especially in the communities served by FP CDC. The second is pressure by Congress for the EPA to redress problems
resulting from the legacy of uranium mining in the 1950s and 60s. The EPA has identified 520 abandoned uranium mines
and the leeching of uranium from the slag piles into drinking water supplies is damaging water supplies (McSwain, 2007). In
Congressional hearings, Chairman Henry Waxman, D-Calif., decried the lack of work on restoring the land on the Navajo
reservation.

If a fraction of the deadly contamination the Navajos live with every day had been in Beverly Hills or any wealthy
community, it would have been cleaned up immediately. But there's a different standard applied to the Navajo
land... To one of the Chairman's questions, your answer was, we need time. I can understand that, but while time
passes, Mr. Nastri, people get sick, people die, people develop kidney disease, children, babies are born with birth
defects, bone cancer develops and gets worse, lung cancer, leukemia, while we wait (Waxman, 2008, 65).

The project manager was from the Capacity Development Initiative from the Heller School for Social Policy at Brandeis
University. The Heller School teaches a participatory "bottom-up" model for community development in which the directly
affected people play a central role in every aspect of a development project from the initial needs assessment through the
final monitoring and evaluation. This approach was used for the project. In weekly meetings, the families developed their
strategy, designed the home water system, and developed relationships with partners based on finding solutions to
achieving shared objectives. This model was new to the federal and tribal partners, and an analysis of the approach can be
found in "Assisting The Water Haulers: Using Grassroots Driven Development to Secure Environmental Justice" available at
http://www.box.net/shared/static/ssh9zigful.doc.

In addition to the three main partners, other federal and tribal agencies participated, as well as corporate and private
groups. Appendix B provides a table listing all the participants and their role in the project.

2.2 PROBLEMS FACED BY THE WATER HAULERS

Families forced to haul their own water suffer both economic and health impacts. Water hauling serves to trap residents in
a circle of poverty. The cost to haul water on the reservation has been estimated in previous studies at $113 per 1,000
gallons, whereas a Phoenix homeowner pays less than 70 cents for the same amount (Helms, 2007). The constant struggle
to meet the most basic human need diverts the human resources needed to overcome poverty in communities where most
people live below the poverty line. Some of the health impacts derive from the methods used to transport and store the
water. The containers used for transportation are often used for both livestock and drinking water, so that the
contaminants in the unsafe sources can be introduced into the drinking water even if the drinking water was collected from
a safe source. High levels of bacteriological contaminants are often introduced in the improvised storage systems used at
the homes, and the containers themselves may be recycled drums formerly used for hazardous chemicals.

The greatest health risks arise from the use of unregulated water sources (EPA02, 2008). A polluted spring or an 80 year-old
livestock well may be functioning as an unregulated public water supply. The ability to reach safe watering points will vary
according to weather, access to transportation, or health problems, forcing families to rely on unsafe alternatives. Livestock
wells are sometimes used for drinking water despite contamination with livestock feces and urine as well as volatile
chemicals (NN EPA, 2008).

The major concern is contamination of water sources by uranium. Uranium ore is widespread in the geologic formations
underneath the ground, but this poses little health risk because the rocks between the formations and the surface serve as
a natural shield. Mine operators extracted nearly 4 million tons of uranium ore from 1944 to 1986 across the NN, which
brought the ore to the surface (EPA 02, 2008). When the mines were later abandoned, slag piles were left on the surface,


where wind and rain break apart the rocks and the uranium then leeches into the water supplies. The US EPA Region 9
Superfund reports the presence of 520 abandoned uranium mines on reservation land (EPA 08, 2009). Up to 25 percent of
the unregulated sources in the western Navajo reservation exceed drinking water standard for kidney toxicants including
uranium (deLemos, 2007).

Uranium in the drinking water causes multiple health impacts, including lung cancer from inhalation of radioactive particles,
as well as bone cancer and impaired kidney function from exposure to radionuclides in drinking water (EPA02, 2008).
Before the cause was known, doctors in the region thought they had discovered a genetic disease caused “Navajo
Neuropathy”, which was associated with muscular degeneration, ulcers, vision weakness, and other severe health issues
and which subsequently was associated with drinking uranium contaminated water (Pasternak, 2006).

2.3 EFFORTS TO IMPROVE ACCESS TO WATER

Little relief is in sight for the people forced to rely upon water hauling. While some efforts are underway to expand the
network of pipelines and attach homes to the grid, many of the homes are too remote ever to be connected. The Navajo
Tribal Utility Authority requires at least 3 meters per mile of piping added (Leeper,2003).

Efforts to improve access to water are complicated by other factors. Climate change has already brought about the most
severe droughts recorded in the 20th century, and climate models suggest the region will become increasingly arid (USGS,
2006). This affects the livestock on which the subsistence economy depends and requires a water supply solution to
address the needs of livestock as well as drinking water. Poverty is a problem that can cause conventional water supply
approaches to fail. For example, pipelines were brought to some homes at the expense of thousands of dollars, but the
families still haul water because they do not have cash to pay monthly water bills.

2.4 ACCESS TO WATER AS AN ENVIRONMENTAL JUSTICE ISSUE

Environmental Justice (EJ) has served as a framework for understanding and prioritizing the problem of access to safe
drinking water. The EJ movement began when a grassroots organization in Warren County, North Carolina, complained
that poor and minority communities suffered disproportionately from environmental harm from pollution and toxic wastes
(London & Sze, 2008). Subsequent academic and governmental studies confirmed this relationship and EJ became
understood as a fundamental civil rights issue (Bullard, 1993) (Bullard, 2001) (Gibbs, 2002) (Kuzmiak, 1991) ( Ringquist,
1999) (Villanova, 1994) (Wakefield, 2003). In 1986, President Clinton signed Executive 12898 on February 11, 1994
mandating all federal agencies to incorporate EJ into their operations (Clinton, 1994).

Since the communities without access to safe drinking water are largely poor and minority, EJ became a framework for
understanding the problem, and this elevated its priority in the federal government. The national drinking water safety
program was explicitly directed to identify and improve EJ issues (Grumbles, 2006). Safe drinking water is an essential part
of the Office of Enforcement and Compliance Assurance's (OECA's) commitment to transparent, measurable, and
accountable environmental justice in its Strategic Plan for 2006-2011 (Nakayama, 2007). The EPA has made the provision of
safe drinking water one of the three priorities for Indian Country for 2008-2010 (EPA 03, 2007). At the UN World Summit on
Sustainable Development in Johannesburg, 2004, the EPA signed the agreement and set as its targets the reduction of
American Indian and Native Alaskan households without access by 50% by 2015 (Ferguson, 2008).

To achieve these goals, an interagency task force was created that included the EPA, the Indian Health Services, the
Department of Housing and Urban Development, and USDA. A preliminary assessment by this group suggested that over
$3 billion might be needed to meet the targets for providing drinking water and sanitation (Ferguson, 2008).


The Navajo Nation became a focus of these efforts, as 54,000 of its people lack access to a public water system (EPA03,
2008). This was the highest number for any region, and the percentage of homes without this access is highest in the
former Bennett Freeze communities served by FP CDC.


3. COMMUNITY OUTREACH

As various federal and tribal agencies increase their commitment to providing services for the remote water haulers, a
delivery mechanism is needed for a diverse range of services including water hauling services, sanitation, and health care
relating to uranium contamination. To provide a single point of presence for all the related services would reduce costs to
the agencies involved in these services and provide a more effective consumer interface.

3.1 EXPLANATION OF FINDINGS:

By living and working for six months within the Black Falls community, the authors of this paper received a bottom-up view
of the service delivery system. The two key findings include the extreme isolation of the population from the existing
service delivery networks and the fragmentation of these networks.

3.1.1 ISOLATION OF POPULATION

The families served by the Black Falls water project were not integrated into the existing service delivery network. Most
had not seen doctors except for emergency treatment or long-term care provided by Navajo Community Health
Representatives (CHR) as follow up to hospital visits. None of the families were aware of any of the radiation programs such
as RESEP, ATSDR, or home radon testing by NN EPA. The remote locations made home visits by various agencies difficult.
The families lacked telephones, making communication difficult in both directions. Only two of the 10 families had cell
phones, and one of those two did not have reception at home.

A key finding is that the chapter houses were not serving as an effective communication link or service delivery agent. The
chapters are used as the point of presence for many federal and tribal programs. The families in Black Falls did not attend
regular chapter meetings although most had visited the chapter houses at least once in the past year for various reasons.
At the chapter houses visited during the project, no one was familiar with the radiation programs or knew how to contact
the agencies. When asked why contamination signs were not posted on some wells, an official at Cameron chapter house
said that driving to the wells was too time consuming and damaging to their cars. They said that the signs were instead
posted at the chapter house, but no signs were there.

3.1.2 FRAGMENTATION OF DELIVERY NETWORKS

The project required families to interface with many tribal and federal agencies for various radiation and sanitation
programs and services. Each agency has created its own outreach program and delivery system, and the people have to
establish independent relationships with each. This requires each individual to discover that a program exists, to find and
contact the agency, to navigate the program admission policies, and to monitor the status of their account and insure they
receive the target services. This process is repeated separately for each agency. The process is more difficult for a remote
population like Black Falls, who are isolated from the media used to advertise program availability, are unfamiliar with
government protocols, do not know what performance to expect from the agencies, and do not speak English. They have
difficulties in contacting agencies due to lack of phones and the need to travel long distances. All these problems are
compounded by the devastating poverty in the region.


Incidents from Black Falls illustrate the fragmentation:

• In order to obtain sanitation systems, the families had to fill out extensive applications to IHS for the plumbing
work. Then they had to fill out another set of paperwork with NN Environmental Engineers to provide
construction services. The families needed to obtain funding, and various officials suggested they could apply to
USDA or a community block grant program for funding for the services, but they were not told where or how to do
so.

• Multiple agencies are involved in radiation-related health issues. RESEP does radiation exposure screening as part
of the downwinders compensation, while a separate program exists for miners' compensation. NN EPA has a radon
testing program. Hospital and health workers are learning about uranium exposure symptoms. The EPA tracks the
location of contaminated water sources. Each program does its own intake and does not provide information
about the other programs. A consumer must independently discover the existence of each program and determine
its applicability to them.

Adequate service delivery systems have not been established for the various federal and tribal programs created in
response to uranium contamination. This problem will be compounded as federal and tribal agencies engage in new
services such as hauling water or providing sanitation on the scale needed to address the US commitment to reduce by 50%
the number of Native American families lacking sanitation and safe drinking water. None of the federal agencies has been
mandated to provide a large consumer service delivery system for these services, and the chapter houses lack the expertise
needed to administer this program.

3.2 DETAILS OF RECOMMENDATIONS:

The federal and tribal agencies should create a service delivery program that provides a single point of presence to
consumers for various programs relating to drinking water, sanitation, and uranium contamination. The program can also
assist the agencies with educational outreach and reduce the costs of these efforts. By establishing a closer relationship to
the affected population, the various agencies can better achieve their mandates by allocating their resources more
efficiently.

While the chapter houses can serve as an entry point for consumers into the program, the expertise required to understand
each of the constituent programs can not be effectively dispersed to each of the 110 chapter houses. Instead, the chapter
houses can promote the program and direct inquiries about any uranium or water-related issue to this program.

This program should be integrated into the inter-agency planning so that the field workers fully understand all the services
available to the constituents. At these meetings, the program representatives can serve as a consumer advocate, providing
data about the problems being faced by the constituents and the status of program implementation in the field. This
participation will insure that the program representatives have a clear understanding about various initiatives so that timely
and accurate information is pushed out into the community. Access to information is a critical element of environmental
justice that needs to be ensured.

The program needs to be empowered so as to enforce the required coordination between the agencies providing the
various services. Agencies may need to modify their processes for outreach, admission, and consumer feedback. Policies
such as sanitation guidelines may need to be modified to address the unique requirements of this community.
Coordination may need to be established between services such as road maintenance and water delivery. Coordination
may be required both on both tribal and national levels. Multiple federal and tribal agencies are already coordinating
efforts to address some of these problems. The difference being recommended here is to create an agency in direct contact
with the affected population and enable it to adjust the programs as needed to address their needs.


The program needs to be financed so as to enable the delivery of the required services. It needs to be large enough to
provide the necessary support to all the families in the affected population. The interagency task force looking at the
fulfillment of the Johannesburg commitments estimated expenses over $3 billion (Ferguson, 2008). Providing an effective
and coordinated delivery system for these services is a critical component of the success of this effort, and appropriate
resources need to be invested in it.

4. WATER DELIVERY

The Black Falls project did not perform a comprehensive needs assessment for the Navajo Nation, but rather examined the
water delivery options available for the 10 homes serviced by the project. These homes had different levels of accessibility
that make different approaches advantageous, so they present a cross-section of the problems that will be encountered in
providing these services across the Navajo Nation.

The recent grant from the EPA to the Navajo Department of Water Resources to support a pilot water delivery program is a
positive step toward providing assistance to families that will never be able to be connected to pipelines because of their
remote location. A program to deliver water using 2000+ gallon tankers may be able to solve the problem for families in
close proximity to the maintained roads. The more remote families face additional challenges. Many of these homes can
not be reached by tanker trucks unless road repairs are performed and ongoing road maintenance is provided. Access is
currently so difficult that some homes can not be reached using pickup trucks carrying more than 100 gallons of water.

4.1 EXPLANATION OF FINDINGS & RECOMMENDATIONS

Most of the recommendations relate to the need to integrate the water hauling services with solutions to other problems.
The key findings and recommendations include:

• Interdependency with storage systems: The cost of servicing a home is inversely proportional to the size of the
storage tank at the site: a smaller tank requires more deliveries. Reaching some of the remote homes in Black Falls
from the nearest neighbor can require up to 30 minutes, and labor costs are the same regardless of the number of
gallons being delivered. The infrastructure decisions need to be coordinated with the delivery challenges. For
example, it might be advantageous to increase the size of the underground cistern to the tank size of the biggest
truck that can reach a site, such as 2000 gallons. Similarly, the savings in delivery costs may cover the construction
costs of the temporary home storage discussed in section 6. The design of the storage system also needs to include
a user-feedback mechanism that makes it easy for people to see the amount in storage so as to allow them to
regulate their usage evenly over the long intervals between deliveries.

• Integrated road maintenance: The cost of servicing homes, either by tanker truck or pickup truck, is affected by
the road conditions. The cost of upgrading and maintaining the primitive roads for the most remote families might
be subsidized by the savings to the water hauling services. In addition, integrated and innovative community-based
solutions might reduce costs using local labor and resources. For example, in Black Falls, one resident recently
bought a tractor to help maintain the roads for some of the families that currently can not be reached to supply
water.

• Demand reduction strategies: The completion of the Black Falls Church watering point has greatly reduced the
cost for supplying water to homes near the maintained road. However, even at the lowered rates, investments in


water efficiency technologies are cost-efficient and are discussed in section 5. For the more remote homes, these
investments become mandatory. Section 4.4 discusses innovative strategies to offload demand, such as providing
laundry, showers, and other services in locations where water is more accessible. The key finding here is that
solutions must be holistic and individualistic: they must integrate sanitation, water access, and other services and
adapt to the unique requirements of each home.

• Point of presence: The community outreach program discussed in section 3 can simplify the management of the
delivery program, improve monitoring and evaluation of program performance, and support the other related
services.

4.2 COSTS OF CURRENT DELIVERY OPTIONS

Baseline costs were established by reviewing accounting information provided by St Bonaventure Indian Mission and
School, which has been delivering water to homes on the eastern Navajo Nation for 20 years. This information was
sufficient to breakdown the costs by mileage, time, and gallons delivered as shown in Appendix C. The full interactive
WaterDeliveryCosts.xls workbook is available online at http://www.box.net/shared/static/v7s3fnko0t.xls

Their average cost/gallon of $0.138 is similar to findings in earlier studies performed by/for the Navajo Nation: $0.113
reported by Helms(2007); $0.055 reported by Leeper(2003).

The mileage and time costs were then applied to the 10 homes in Black Falls, and a similar average cost of $0.12/gallon was
obtained. The table in Appendix D1 applies the component costs for time and mileage to the routes needed for each family
in Black Falls. It looks at the distance from each house to the maintained roads and whether tanker trucks are currently able
to traverse these roads. Where a tanker truck is used, additional savings from using delivery routes are taken into
consideration. One home can currently be reached only by a pickup truck carrying at most 100 gallons.

The costs were increased because the average distances travelled on non-maintained roads in Black Falls are higher, but
this was partially offset by the savings from assuming 700 gallon deliveries at the homes accessible to tanker trucks instead
of 110 gallon deliveries used in the St Bonaventure service model. In addition, St Bonaventure brings water from a well at
their facility, which is located a great distance from the service area, whereas Black Falls can now be served from a nearby
watering point at Black Falls Church. These and other observations can be verified within the WaterDeliveryCosts.xls
workbook.

The costs vary substantially among families depending on the access requirements. The costs for families located further
from the maintained roads can be over 8 times higher than for the families that are closest to those roads, so that the
delivery cost to the most remote family would be $0.42/gallon.

4.3 WAYS TO REDUCE DELIVERY COSTS

The spreadsheet models suggest that the two most effective ways to reduce costs are improving the access roads and
increasing the size of the home storage tanks. In addition, the service delivery model should be carefully chosen and
effectively monitored. These solutions require an integrated approach from multiple agencies, which may require high-
level policy adjustments to provide the necessary mandates and/or funding.

4.3.1 ROAD IMPROVEMENTS AND MAINTENANCE:


The initial delivery cost model assumes that 5 of the 10 homes can not be serviced by tanker trucks at current road
conditions. In some cases, the truck would not be able to reach the home. The others were excluded because traversing
these rough roads could unreasonably increase their maintenance costs. Substantial cost savings could be achieved if road
improvements and maintenance allowed these homes to be reached by tanker truck. For one home, the savings could be
as high as $3,700 annually, based on the costs of delivering 1,000 gallons/month. The average cost for the 5 remote homes
would decrease 40%, as shown in Appendix D2.

If an integrated approach to road maintenance and water delivery is adopted, the savings for water hauling might subsidize
road maintenance and improve the quality of life for these residents by improving access to their homes. The cost of
solving the problems may be reduced by supporting efforts within the community to address these issues. For example, in
Black Falls, one resident is purchasing a tractor to provide road improvements for some of the families.

4.3.2 HOME STORAGE TANK SIZE:

For Black Falls, the size of the home storage tank has a major impact on water delivery costs. Because of the proximity of
the new watering point, most of the delivery time is spent reaching individual homes rather than on routes shared by
multiple homes. Consequently, the total number of miles traveled can be reduced by using storage tanks at the homes as
large as the size of the tank on the delivery truck. If a 2,000 gallon tanker truck is used, then increasing the size of the home
storage tank to a matching 2,000 gallons will reduce the costs of operating the delivery system by an additional 33% over
the cost of using a 1100 gallon tank. Overall, the combination of improved road access and large storage tanks reduces the
average cost for servicing all homes in the community from $0.121/gallon to $0.036, as shown in Appendix D3.

The savings from larger home storage systems can offset the costs of installing the temporary home water systems
discussed in section 6. In Black Falls, 210 gallon tanks were used in the initial demo project, but the revised design attached
specifies a 405 gallon tank. This would allow average deliveries of 300 gallons, which would reduce the annual delivery cost
per home by over $1000 over the costs using the 110 gallon deliveries used in the St Bonaventure service model.

4.3.3 WATER DELIVERY COOPS:

A water delivery service can be provided in several ways:

• a centrally managed tribal agency

• managed by chapter houses

• private entities such as St Bonaventure

• community coops such as the Black Falls Water coop

The coops have the potential for achieving the lowest operating costs, in that volunteer drivers or schedulers might be
used. As shown in Appendix D1, labor makes up 40% of the budget. However, these potential savings have to be balanced
against potential increases in costs for insurance, program administration, or other problems, as well as against the impact
of shifting this burden to the families. The costs may also be affected by administrative efficiency - how well the routes are
scheduled, how well the drivers protect and maintain the trucks, and charges for other expenses such as vehicle
maintenance and administrative overhead. In addition to controlling costs, the program must also insure that all families
requiring the service receive timely deliveries.


Establishing and enforcing clear benchmarks for monitoring and evaluation is critical for any proposed service delivery
model. In addition, a pilot program might include multiple service delivery models so as to test whether community-based
coops or private organizations may provide more effective and lower cost service.

4.4 DEMAND REDUCTION

As shown in Appendix D1, the water delivery costs can currently be as high as $0.42/gallon and will be at least $0.06 for
some homes even under the most optimistic scenarios. These prices force a re-examination of the approaches used to
provide various residential services, so as to provide equivalent services while hauling less water. The two general
strategies are using alternative technologies within the home and off-loading services to locations with better access to
water. The recommendations for sanitation system design in Section 5 cover the home technology alternatives.

The second option is to offload some home services to locations with better access to water. The location might be a coop
unit shared by a few families, which allows the costs to be amortized over more families while retaining a sense of personal
ownership. The services include those which are available to families with piped water but are difficult for water haulers.
Examples include:

• Laundry: The nearest laundromats to Black falls are over an hour away, and the lack of electricity and water limits
the options in the home.

• Showers: While in-home showers are part of the proposed sanitation system design, the costs are lower in a
facility with better access to water and where hot water might be provided efficiently using solar thermal.

• Cleaning: Major cleaning chores such as washing a car might be more easily done at a location with better access
to water.

• Gardening: A small family plot might be provided

Many of these activities do not require potable water, so that a low-cost well might be used as a water supply if the nearest
piped water is too far away. The document "SanitationSolutionsBlack Falls.doc " available for download at

http://www.box.net/shared/static/x30sz1mdkb.doc

includes more information about this type of coop unit.

This may be a cost-effective method for providing basic services that would otherwise be unavailable for the remote
families. Experimentation is needed to understand the effectiveness and sustainability of this approach. This might be
supported by a program that funds pilot projects by community groups to build and operate units or otherwise expand the
range of services that can be available to remote families.

5. SANITATION

With assistance from the US EPA, the Black Falls families have been working with programs from the US IHS and other
agencies that build residential sanitation systems. The sanitation systems to be built under these programs follow
guidelines set by national IHS policy, but have been augmented by an innovative solar-powered cistern designed by the


local engineer. The finding and recommendations with respect to sanitation examine both the design of the systems under
these guidelines and the process through which families obtain these services. Both of these areas should be improved as
the program is scaled up to meet the national targets for reducing the number of Americans without sanitation or access to
safe drinking water by 50% by 2015.


5.1.1 DESIGN CONSIDERATIONS

Some of the guidelines mandated by IHS policies do not adequately take into consideration the unique challenges faced by
families that have to haul water, and these policies need to be adjusted at the national level. The design consists of several
components:

• Water Storage and Distribution - The solar cistern and the DC pumping system designed by the local IHS engineers
are ideally suited for the requirements of the off-grid families. As discussed in section 4.3.2, increasing the size of
the underground tank would reduce the costs of hauling water, so this change should be incorporated.

• Hot Water - The tankless propane heaters proposed by the local IHS engineer are an adequate solution for these
remote homes, as solar thermal systems are not cost effective for low usage levels.

• Showers - Water efficient showers can be achieved by selection of the shower head without conflicting with IHS
guidelines or affecting other aspects of system design. The long-term water delivery costs should be taken into
consideration when selecting the shower head.

• Toilets - IHS guidelines require the use of 1.6 gpf (gallons per flush) toilets. As shown in Appendix E, the annual cost
of hauling water to support a flush toilet could be as high as $5,887 in some scenarios. Even when water costs are
reduced to under $0.04/gallon in the best scenarios of section 4.2, the annual water cost will be over $500. These
costs can be significantly reduced using advanced technologies such as waterless toilets, but the maintenance
costs and usage issues need to be fully understood before large scale deployment takes place.

• Septic System - The septic system requirements depend on the type of toilet used, and the IHS guidelines need to
be flexible to accommodate multiple approaches. Water is a precious resource in these environments, and IHS
guidelines need to promote grey-water recycling systems so as to achieve maximum usage of every ounce.

In meeting targets for deploying sanitation by 2015, the participating federal and tribal agencies need to consider the long-
term costs of sustaining systems and not just initial construction. The deployment of new water-efficient technologies can
reduce these long-term costs for homes that lack access to piped water. In order to achieve these cost savings, the IHS and
other concerned agencies need to promote pilot programs immediately to evaluate long-term performance of various
design options for toilets, septic system design, and grey water systems.

5.1.2 SERVICE MODEL

For various historical reasons, residential sanitation systems are not provided as a coordinated government service, but
rather require the family to interface with multiple agencies. The IHS provides the core sanitation system including water
supply and plumbing, but the bathroom construction must be done by a separate agency, such as environmental engineers
from the Navajo Nation. Funding for the construction may be obtained through community block grants, USDA, or through
chapter house programs. Each agency requires a separate application process and enforces its own independent


admissions criteria. In most cases, the agencies usually do not advertise their services, provide a point of consumer contact,
or have a process through which consumers can find out the status of their accounts. The agencies do not provide a means
for the families to participate in the design or scheduling of the construction or to add monitoring, feedback, or
accountability to the process.

In order to meet the federal targets for deploying sanitation by 2015, a service delivery system will have to be created that
provides a single point of consumer contact and account management. The delivery system will need to replace the
individual account management procedures in each participating agency with a unified system that provides monitoring
and evaluation of the program and accountability to the consumer. Section 3 proposes that this system be part of a unified
service delivery model also encompassing related services such as water hauling and outreach for various uranium
contamination programs.

5.2 DESIGN OF SANITATION SYSTEMS

A preliminary analysis of sanitation options was submitted to EPA and IHS in February, 2009, and can be found in
"SanitationSolutionsBlack Falls.doc " available on-line at http://www.box.net/shared/static/x30sz1mdkb.doc. The report
analyzed solar thermal hot water systems, but concluded that the high initial costs were not recouped for the low-volume
usage for homes that haul water. The report identified the high costs of using flush toilets for homes that haul water, but
raised concerns about the maintenance issues associated with waterless toilets. The report recommended the use of small
washeterias that could off-load major water uses such as laundry and showers.

The proposed IHS design for sanitation systems for Black Falls was discussed in a meeting in February, 2008 at the IHS
offices in Tuba City. The design featured an innovative solar cistern, which is the ideal approach for off-grid homes. The
analysis in section 4.3.2 suggests that the cost of water delivery could be reduced by increasing the tank size to 2000 or
2500 gallons. The pump, solar voltaic system, and other components all seemed well suited for the project.

The main area of concern was the proposed use of 1.6 gpf flush toilets. As shown in Appendix E, the costs of supplying
water for these units is at least $500/year under the lowest delivery cost projections and could be as high as $5,887 in some
of the scenarios. A partial reduction might be achieved using 1.0/0.5 gpf flush toilets that are being used effectively in arid
areas in Australia. A second option was to use a waterless separating toilet as a unisex urinal in conjunction with a normal
flush toilet. This could reduce water use as much as 90% while simultaneously satisfying IHS requirements to include flush
toilets. A third option is to use one of the waterless toilet systems which were evaluated in the February report. These
might eliminate the need for the full septic system so that the subsequent cost savings could help pay for the higher costs
of the toilets. Potential issues were identified with every option, and a recommended strategy would be to try several
competing approaches and evaluate consumer acceptance, maintenance costs, and other parameters.

Grey-water recycling was also discussed. When water is so costly, getting the most value from every ounce is important.
Recycling allows grey water to be used for garden irrigation. The IHS had deployed these systems in the past and
encountered some maintenance issues, and the current IHS guidelines do not cover the expense. If waterless toilets were
used, grey water recycling becomes particularly attractive, as it eliminates the need for constructing a septic system. As
with toilets, this is an area where field trials of competing strategies would be useful.


6. TEMPORARY WATER STORAGE AND DISTRIBUTION SYSTEM

The home water systems designed and deployed in the first phase of the project consisted of an external storage tank
feeding a sink/counter assembly.


The system provides an immediate and low cost way to transition families away from unsafe water sources. Provision of
these systems can be the entry point to connecting families to the full range of health care and sanitation services. The
findings from Black Falls include:

• Support water delivery services: A large on-site tank reduces the cost of operating a delivery service, as fewer
trips to each home are required. The recommended design for replication uses a 405 gallon tank, which can hold
more than the current monthly consumption of most of the families at Black Falls.

• Replaces unsafe storage systems: The system provides a closed storage and distribution system, which eliminates
the bacterial and chemical contamination associated with the buckets and improvised containers.

• Fast installation with limited training: The system was designed for quick on-site installation. If a stockpile of
parts and preassembled kitchen units is available, a house can be brought on line in a few hours. Minimal training
is needed to perform the on-site work, so that rapid up-scaling can be achieved using local labor.

• Efficient replacement: When a family subsequently obtains a cistern or access to piped water, the storage system
can be moved to another home, while the sink/counter can be used with the hot water and pressurized system
with few adjustments.

• Service Networking: The deployment of the home system gets the families involved with the service delivery
system, so that they learn about safe use of water, obtain access to health and other services, and become
proactively involved with the agencies providing water and sanitation systems

• Sustainability through community ownership: The involvement of the families in the construction of the systems
enhances their ability to support and maintain the systems.

6.2 CONSTRUCTION DETAILS

The storage tank was mounted on a platform built from 4x4 timbers on top of concrete block pillars. The platform elevates
the tank so that the bottom is at least 8" above the sink faucet. The full design is included in the document "Temporary
Residential Water System.doc" which can be downloaded from

http://www.box.net/shared/static/nd1iroi8c2.doc


The key advantages of the design is that the platforms can be assembled and the tanks installed in less than two hours using
low-cost parts that can be 100% re-used at another site when a permanent cistern is installed. This allows systems to be
deployed as rapidly as qualified beneficiaries can be identified. The Black Falls project used 210 gallon white water
transportation tanks. These should not be used during replication for two reasons:

• black tanks should be used to prevent algae growth. The use of white tanks in Black Falls required the tanks to be
wrapped in black plastic, which creates a maintenance problem.

• tanks designed for fixed storage are cheaper than transport tanks and a larger tank can be provided at less cost.

For replication, a recommended tank would be a 405 gallon tank which is 52" diameter and 48" tall. This size stores more
than a one month supply for the families in Black Falls, which reduces the number of roundtrips for a tank truck. Larger
tanks in this class tend to be significantly taller, which complicates refilling since the base of the tank is already 4 feet above
the ground.

The black tanks are large enough so that freezing during winter is not an issue unless the tanks are nearly empty. 1.5" pipes
are used outside the home to reduce susceptibility to freezing, and the exterior plumbing is doubly wrapped in pipe
insulation. White tarps are provided to the families to prevent overheating of the tanks during summer.

The Black Falls project used a 72" counter on a 60" sink base for the in-home distribution system. While some cheaper
options were available, the extra cost of using these attractive units was not large and increased the level of involvement of
the families in the project. The counters were prefabricated and the sinks mounted at a central location to reduce the need
for experienced carpenters on each site. The standard sink plumbing fixtures, such as 3/8' feeds to the faucets, do not work
well for low pressure, so extra work was required to increase the pipe diameters to the faucet intakes. Even with these
customizations, the sink assemblies can be added installed and plumbed in a couple of hours. The temporary system does
not include a pump or hot water heater - those would be added as part of the permanent sanitation system.

The temporary system does not include sanitation. The water from the sink is typically piped directly to the outside, and the
pipe exits at a height sufficient to place a 5 gallon bucket underneath. The families then either dispose of the water or
recycle it for irrigation.

6.3 SYSTEM COST DETAILS:

The parts list is provided in Appendix E, where the totals come to:

Parts cost:
Platform & exterior plumbing $ 536.98
Sink/counter & interior plumbing $ 363.25
Total unit cost $ 900.23

The kitchen counters quoted in the parts list require prefabrication to add the end caps on the counter top and to cut out
for the sink and mount it in the hardware. The wood for the platform is pre-cut, so that no power tools are required on site
except possibly for the drill that might used to for the hole through the external wall. No extra budget is required for
transportation to the site as the materials for one home can be transported in one pickup truck load and brought on site by
the installation crew. The installation crew typical consists of a trained foreman, an apprentice being trained for further
replication, and at least one member of the family or local community to help with general labor.

Labor costs:
Skilled In-Training General labor & support


Prefabrication(off-site) 2.0 hours 2.0 hours --
Platform (on-site) 1.5 hours 1.5 hours 1.5 hours
Counter installation 2.0 hours 2.0 hours 2.0 hours
Transportation to/from site 1.0 hours 1.0 hours --
Total time 6.5 hours 6.5 hours 3.5 hours
Hourly rate (include benefits) 35 25 (in-kind contribution)
Total labor 227.50 + 162.50 = $ 390

Estimated program costs:
Parts $ 900.23
Labor $ 390.00
Subtotal $ 1,290.23
15% overhead $ 193.53
Total $ 1,483.76

These estimates are based on the costs for constructing 10 systems, and lower costs for both parts and labor could be
achieved in higher volume production.

7. HEALTH CARE

As part of the Black Falls Water Project, the community organizers assisted the families in interfacing with various agencies
dealing with health issues that might be related to uranium contamination. This included the Radiation Exposure Screening
and Education Program (RESEP), NN EPA Radon Program, Agency for Toxic Substances and Disease Registry (ATSDR),
Radiation Exposure Compensation Program (RECP), Tuba City Hospital, and Navajo Community Health Representative
(CHR) Program. This section lists some findings and recommendations resulting from this work.

7.1 MEDICAL OUTREACH PERFORMED IN THE PROJECT

Black Falls has been identified as a high-risk area for uranium contamination for several reasons:

• abandoned uranium mines (AUMs) in the community

• contamination of ground water sources

• down-winder exposure to nuclear testing in the 1960s

• occupational exposure in the uranium mining industry

• possible contamination of homes due to use of uranium by-products in construction

• radon gas in dwellings

The initial needs assessment for the families in Black Falls asked if they had been screened for uranium exposure. None of
the families had been screened, nor had any ever even been asked by a physician whether they were subject to any risk
factors.


This medical outreach was adopted as a community project, so that the following efforts were made:

• Community presentations were organized for representatives of RESEP, RECP, and NN EPA Radon Program so that
they could describe their programs

• Project leaders assisted the families in setting up appointments at North Country Health Care and arranged for
transportation to the clinics.

• The EPA arranged for presentations by ATSDR at the Tuba City Hospital to train local physicians in awareness of
uranium related health issues

• Unsuccessful attempts were made to have homes checked for radioactive construction materials. Black Falls is on a
5 year wait list for a Geiger Counter test to determine possible radiation.

• Radon testing of homes was scheduled to begin in December, 2009. The people were also told to put aside money
to enable them to move out while their homes are fixed if they get a positive reading.

7.2 EXPLANATION OF FINDINGS AND RECOMMENDATIONS

7.2.1 FRAGMENTATION OF RESPONSE AND COMMUNITY OUTREACH:

Each of the agencies (RESEP, NN-EPA Radon Program, ATSDR, RECP, etc.) conducts its own separate outreach program. At
no point did any agency representative advise people about the existence of the other programs or facilitate contact with
them. None of the families had ever been contacted by tribal or chapter personnel with respect to any of the programs, so
that the experience at Black Falls suggests that these institutions may not be serving effectively as an aggregator for these
services. As a result, each family who might be in need of these services must individually identify each program and
contact its representatives. As was the case in Black Falls prior to the project, the families are often unaware that services
exist or how to go about interfacing with them.

In Black Falls, community representatives were able to identify programs, contact representatives, and serve as a facilitator
for the families. The community organizers were thus able to function as a service aggregator, presenting to the families a
comprehensive list of available services and facilitating the interface. The replication of this function across all the
communities in the Navajo Nation would allow each of the agencies to perform their mission more effectively.

7.2.2 TRAINING OF HEALTH CARE PROVIDERS

The training on uranium exposure systems, recognition to the doctor’s at Tuba City Hospital and conference on December
16, 2008 at the suggestion of the EPA was an excellent first step in training local health care providers about uranium
related issues. In discussions after this event, representatives from ATSDR and Dr Weiss suggested that further training is
required as well as monitoring of the program and facilitating interface of the physicians with the other programs. They
also suggested the creation of a community liaison person to interface between the doctors, the patients, and the
resources.

7.2.3. RESEARCH ON URANIUM CONTAMINATION

Research projects on the impact of uranium in drinking water are already underway at several institutions. One issue that
arose in Black Falls was the health impact of consuming livestock that have consumed uranium-contaminated water. At a


meeting on August 14, 2008, at Leupp Chapter, representatives from Navajo Nation EPA, US EPA, IHS, and the DiNEH
Project presented a preliminary study suggesting that the livestock may be serving as a bioaccumulator and the
consumption of their meat could be dangerous. The people in Black Falls practice a subsistence lifestyle where stopping
this consumption is not practical. A study on this issue that could provide guidelines would be beneficial.

7.2.4. PROGRAMS TO ADDRESS URANIUM CONTAMINATION OF DRINKING WATER

Congress has enacted compensation and treatment programs to address radiation exposure from uranium mining and from
nuclear testing. The RESEP program provides comprehensive medical screenings that look for medical consequences of
airborne exposure. Black Falls is covered under this program, although several types of cancer need to be added to those
covered under the program. Exposure from drinking water is another consequence of the mining industry, so that a similar
effort is appropriate. One possible solution might be to extend the mandate of the RESEP program so that it covers the
health consequences of uranium exposure from drinking water.

8. CONCLUSION

The federal and tribal governments have launched a number of initiatives to address uranium contamination and lack of
sanitation and access to safe drinking water. What is missing is a program that can integrate these services into a delivery
system that effectively meets the needs of the target population. This paper outlines the basic functions that need to be
served by this program. More details can be provided upon request. This paper did not recommend a specific structure:
the key functions could be performed by a program within a federal, tribal, or private agency. The key point is that all
stakeholders need to look at the overall situation faced by these families from a holistic and consumer-oriented viewpoint
and then transform these many initiatives from disparate pieces into a weaving that achieves the goals of environmental
justice.


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APPENDIX :
APPENDIX A: COMMUNITY MAPPING PROJECT

HOMES WHERE WATER SYSTEMS ABANDONED URANIUM MINES:
INSTALLED IN THE PROJECT
TRUCK ACCESS POINTS: POTENTIAL DEPOT SITE FOR STORING
WATER

Wells: Red = EPA tested, contaminated; Orange = not tested


APPENDIX B: PROJECT PARTNERS AND CONTRIBUTORS


APPENDIX C: WATER DELIVERY COSTS - ANALYSIS OF DATA FROM ST BONAVENTURE MISSION

St. Bonaventure Delivery Costs
Truck cost 130,000
Rate for interest +amortization 0.2
Amortized annual cost 26,000

Annual expenses
Driver salary & benefits 25,000
Fuel 15,000
Maintenance 1,000
Tires 1,000
Insurance 500
Truck amortization 26,000
Total annual costs 68,500

Miles driven per year 84,000
Gallons per delivery 110
Number families served 200
Deliveries per year to each family 26
Gallons delivered annually 572,000
Number deliveries 5,200
Cost per delivery 13.17
Cost per gallon delivered 0.120
Cost per mile traveled 0.815
Average distance per delivery (RT) 16.154
Time/delivery in hrs (40 hr week) 0.400
Cost per hour 32.93

Administrative costs fee 0.15
Adjusted cost/hour 37.9
Adjusted cost/gal 0.138
Adjusted cost/mile 0.938


APPENDIX D: WATER DELIVERY COSTS - ANALYSIS OF COSTS TO SERVICE INDIVIDUAL HOMES IN
BLACK FALLS

Appendix D1: Estimated Time, Distance, and Cost for Deliveries to Black Falls homes
Estimated Time, Distance To maintained From there to Total x2 Ave Vehicle Total Cost
and Cost for Home road watering point: for roundtrip gallons cost per Annual
Delivey Miles Time Miles RteSave Time Miles Time deliver per hr cost gal cost
Jimmy & Irene Lee 11.1 0.74 0.6 0.0 0.02 23.4 1.8 210 25.00 45.50 0.22 2,600
Florabell Paddock 11.3 0.75 0.6 0.0 0.02 23.8 1.8 110 25.00 46.17 0.42 5,036
Alfred McCabe 7.2 0.48 2.5 0.0 0.08 19.4 1.4 210 25.00 35.67 0.17 2,038
Mary Knight 3.1 0.21 0.6 0.0 0.02 7.4 0.8 210 25.00 18.83 0.09 1,076
John Knight 3.1 0.21 0.6 0.0 0.02 7.4 0.8 210 25.00 18.83 0.09 1,076
Ronald Tohannie 1.1 0.07 9.6 5.0 0.15 11.4 0.8 726 43.40 32.70 0.05 540
Elsie Tohannie 1.1 0.07 9.6 5.0 0.15 11.4 0.8 726 43.40 32.70 0.05 540
Katherine Peshlakai 0.4 0.03 11.5 3.0 0.28 17.8 0.9 726 43.40 39.93 0.05 660
George Kee 2.1 0.14 4.8 0.0 0.16 13.8 0.9 726 43.40 39.06 0.05 646
Faye Willie 0.3 0.02 7.2 5.0 0.07 5.0 0.5 726 43.40 21.12 0.03 349
Average: 33.05 0.121 1456.24

Appendix D2 : Adjusted estimates if Road Improvements allow 2000 gallon truck to all homes
Jimmy & Irene Lee 11.1 0.74 0.6 0.0 0.02 23.4 1.8 770 43.40 78.99 0.10 1,231
Florabell Paddock 11.3 0.75 0.6 0.0 0.02 23.8 1.8 770 43.40 80.15 0.10 1,249
Alfred McCabe 7.2 0.48 2.5 0.0 0.08 19.4 1.4 770 43.40 61.92 0.08 965
Mary Knight 3.1 0.21 0.6 0.0 0.02 7.4 0.8 770 43.40 32.70 0.04 510
John Knight 3.1 0.21 0.6 0.0 0.02 7.4 0.8 770 43.40 32.70 0.04 510
Ronald Tohannie 1.1 0.07 9.6 5.0 0.15 11.4 0.8 770 43.40 32.70 0.04 510
Elsie Tohannie 1.1 0.07 9.6 5.0 0.15 11.4 0.8 770 43.40 32.70 0.04 510
George Kee 2.1 0.14 4.8 0.0 0.16 13.8 0.9 770 43.40 39.06 0.05 609
Faye Willie 0.3 0.02 7.2 5.0 0.07 5.0 0.5 770 43.40 21.12 0.03 329
Average: 45.20 0.06 704.34


Apendix D3: Reduction in costs via road improvements and larger tanks
Jimmy & Irene Lee 11.1 0.74 0.6 0.0 0.02 23.4 1.8 1400 43.40 78.99 0.06 677
Florabell Paddock 11.3 0.75 0.6 0.0 0.02 23.8 1.8 1400 43.40 80.15 0.06 687
Alfred McCabe 7.2 0.48 2.5 0.0 0.08 19.4 1.4 1400 43.40 61.92 0.04 531
Mary Knight 3.1 0.21 0.6 0.0 0.02 7.4 0.8 1400 43.40 32.70 0.02 280
John Knight 3.1 0.21 0.6 0.0 0.02 7.4 0.8 1400 43.40 32.70 0.02 280
Ronald Tohannie 1.1 0.07 9.6 0.0 0.32 21.4 1.1 1400 43.40 47.16 0.03 404
Elsie Tohannie 1.1 0.07 9.6 0.0 0.32 21.4 1.1 1400 43.40 47.16 0.03 404
George Kee 2.1 0.14 4.8 0.0 0.16 13.8 0.9 1400 43.40 39.06 0.03 335
Faye Willie 0.3 0.02 7.2 0.0 0.24 15.0 0.8 1400 43.40 35.59 0.03 305
Average: 50.40 0.036 432.03

APPENDIX E: COST OF SUPPLYING WATER FOR FLUSH TOILETS IN BLACK FALLS

Cost of Flush Toilets

Flushes/day per person 8 adjustable model assumption

Number people / household 3 adjustable model assumption

Gallons/flush 1.6 standard high-efficiency toilet per IHS guidelines

Gallons/day 38.4 product of above cells

Gallons/year 14,016 Annual use

Lifetime gallons 420,480 30 years at annual use shown above

lifetime
cost/gallon cost/yr cost Reference:

St Bonaventure average
cost 0.12 $1,682 $50,458 Appendix C

Most expensive home 0.42 $5,887 $176,602 Appendix D1, Paddock

Average in best scenario 0.036 $505 $15,137 Appendix D3


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