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PostedDate: 02/16/2007 08:06:16 AM Recipients: David.Clark@bnsf.com,susan_morris@nmenv.state.nm.us,CN=James Turner/OU=R6/O=USEPA/C=US@EPA,RAhmed@TRCSOLUTIONS.com MailOptions: 0 SaveOptions: 1 From: CN=Katrina Coltrain/OU=R6/O=USEPA/C=US AltFrom: CN=Katrina Coltrain/OU=R6/O=USEPA/C=US Logo: StdNotesLtr22 useApplet: True tmpImp2: DefaultMailSaveOptions: 2 Query_String:

SendTo: David.Clark@bnsf.com CopyTo: susan_morris@nmenv.state.nm.us,CN=James Turner/OU=R6/O=USEPA/C=US@EPA,RAhmed@TRCSOLUTIONS.com BlindCopyTo: Subject: Fw: Hi DLs at GCC Albuq Encrypt: 0 Sign: 0 ReturnReceipt: 0 delTmpEncrypt: delTmpImportance: delTmpReturnReceipt: delTmpSign:

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David, Susan and I have read over the explanation provided by Tetra Tech. Based on the explanation, GCC and BNSF have come to the conclusion that these samples represent areas where prior activity associated with tram tracks, rail lines, and asphalt have resulted in data with high detection limits. Portions of the provided explanation have been separated for ease of response.

1. It appears that 12 of these samples had to be diluted during sample prep in the laboratory due to some form of sample matrix interference, which resulted in higher detection limits. In most cases these detection limits are above the NMED screening levels for the PAH constituents.We agree that the shallow samples exceed the site soil remediation goal for benzo(a)pyrene equivalents (7.8 mg/kg) (assuming the screening level mentioned above refers to the site SRG). During a conference call on January 30, 2007, NMED/EPA identified several locations where the reporting limits were high, the dilution factors were high, and the resultant concentration reported was non-detect. These location are
SB-39, SB-41, SB-42, SB-44, SB-45, SB-46, SB-47, SB-47B, SB-48, SB-49, SB-50, SB 52, SB-53, SB-54, and MH-1. Of the listed locations, only 4 (SB-47, SB-47B, SB-48, SB-49) had individual PAH reporting limits less than the SRG of 7.8 mg/kg; however, when the BAP equivalent is taken, these locations exceed the SRG of 7.8 mg/kg. Of the remaining locations of concern, the lowest reporting limit was listed as 18.6 mg/kg which is a little more than twice the SRG of 7.8 mg/kg. We agree that the data show these to be shallow areas and that contamination at depth was not identified. What does 'due to some form of sample matrix interference' refer too? What was the driver contaminant(s)?

2. The locations of the subsurface samples with high detection limits are limited to the southeastern portion of the site and the line of sample locations along the eastern site boundary. As reported in the Soil and Groundwater Investigation Report, these locations coincide with areas where tram track or rail lines were formerly present and where surficial deposits of hard, weathered, asphalt-like material were observed.

If these samples (as listed in the response to #2) represent an area where tram tracks, rail lines, and asphalt was located, then site photos and past documentation of use should be provided to us to support the determination that this is not creosote related contamination resulting from past operations. What was the location of the asphalt removed by BNSF? Was it all confined to the southeast 'dog-leg' as indicated in a conference call held on February 5, 2007? Has the BNSF rail car unloading facility recently resurfaced the parking lot, and therefore extra material was left along the eastern boundary? Supporting documentation is needed and can be provided in the summary report described in #3 below.

3. Because the data do not indicate contamination at depth and the locations generally coincide with the surficial deposits, we anticipate that the removal of the surficial material deposits, as recommended in the Report, will address the potential presence of PAH contamination.

Does statement #3 only refer to the location of sample MH-2? Or is it referring to all shallow locations where the SRG was exceeded as stated in #2 above? The GCC document discusses MH-2, but does not address/explain the 12 samples diluted during sample prep in the laboratory due to some form of sample matrix interference, which resulted in higher detection limits. If it does refer to all 12 locations and the soils are removed, samples should be taken to verify SRGs are met. During the conference call with BNSF and TRC on Feb. 5, 2007, EPA and NMED were informed that TRC had removed the soils near the manhole cover (MH-2), stockpiling the soils with the removed asphalt materials. EPA/NMED requested and BNSF/TRC agreed to supply a report on this removal activity to document the actions taken. In addition, this summary report should address the locations identified in #1 above.Katrina Higgins-Coltrain Remedial Project Manager USEPA Superfund Louisiana/New Mexico/Oklahoma Team (6SF-RL) 1445 Ross Avenue, Suite 1200 Dallas, TX 75202

214-665-8143 214-665-6660 (fax)

"Clark, David C (Topeka)" <David.Clark@bnsf.com>
02/13/2007 08:31 AM

To Katrina Coltrain/R6/USEPA/US@EPA, susan_Morris@nmenv.state.nm.us

cc "Clark, David C (Topeka)" <David.Clark@bnsf.com> Subject FW: Hi DLs at GCC Albuq

Att'd FYI. BTW, I'm not planning on going to Aq for the drilling next week. I've got a lot of travel coming up the next 2 months and could use that time to get caught up. If you think I need to be there let me know. Otherwise I don't imagine I will be able to add much benefit at this point in the process.

Dave -----Original Message----- From: Longwell, Daryl -- Tetra Tech [mailto:Daryl.Longwell@tetratech.com] Sent: Monday, February 12, 2007 5:32 PM To: Seby, Paul; Clark, David C (Topeka); SZellmer@gcc.com; Clark, David C (Topeka) Cc: Ball, James A; Nehring, Pamela; Kellogg, John Subject: RE: Hi DLs at GCC Albuq

In response to the inquiry from the EPA regarding detection limits, I have prepared the following. Please let me know if you have any further questions.

All of the surface samples were analyzed for PAH SVOCs by Method 8270 SIM (selected ion monitoring) and while some of these samples required dilution during sample prep, the reporting limits were not significantly elevated (above screening levels) where non-detects were reported.

In accordance with the Work Plan, shallow subsurface samples were analyzed for the full suite of SVOCs by Method 8270C. It appears that 12 of these samples had to be diluted during sample prep in the laboratory due to some form of sample matrix interference, which resulted in higherdetection limits. In most cases these detection limits are above the NMED screening levels for the PAH constituents. For each of the samples where this occurred, a second deeper sample was collected (typically from the 2 to 3 foot depth range). The detection limits for the analyses of all of these deeper samples was less than the screening levels and no PAH contaminants were reported in these samples.

In hindsight, the re-analyses of some of the shallower subsurface samples by Method 8270 SIM may have resulted in a lower detection limit. However, re-analyses were not performed.

The locations of the subsurface samples with high detection limits are limited to the southeastern portion of the site and the line of sample locations along the eastern site boundary. As reported in the Soil and Groundwater Investigation Report, these locations coincide with areas where tram track or rail lines were formerly present and where surficial deposits of hard, weathered, asphalt-like material were observed.

Because the data do not indicate contamination at depth and the locations generally coincide with the surficial deposits, we anticipate that the removal of the surficial material deposits, as recommended in the Report, will address the potential presence of PAH contamination. Confirmation sampling following the removal effort can be used to verify complete removal (with analysis by Method 8270 SIM).

Daryl L. Longwell, P.E. | Senior Project Manager Tel 303.447.1823 | Fax 303.447.1836 Cell 303.588.0902 | Email daryl.longwell@tetratech.com

Tetra Tech 4900 Pearl East Circle, Suite 300W | Boulder, CO 80301

From: Seby, Paul [mailto:pseby@mckennalong.com] Sent: Friday, February 09, 2007 11:04 AM To: Clark, David C (Topeka); SZellmer@gcc.com; Clark, David C (Topeka); Longwell, Daryl -- Tetra Tech Cc: Ball, James A; Nehring, Pamela; Kellogg, John Subject: RE: Hi DLs at GCC Albuq

David- I am forwarding your question to MFG and asking that they reply to all on this email in response. Thanks

_______________________________________________________________ Paul M. Seby

Partner McKenna Long & Aldridge LLP 1875 Lawrence Street, Suite 200 Denver, Colorado 80202 http://www.mckennalong.com (303) 634-4000 FAX (303) 634-4400 pseby@mckennalong.comFrom: Clark, David C (Topeka) [mailto:David.Clark@bnsf.com] Sent: Friday, February 09, 2007 11:02 AM To: SZellmer@gcc.com; Seby, Paul Cc: Ball, James A; Nehring, Pamela; Clark, David C (Topeka) Subject: Hi DLs at GCC Albuq

After reviewing the GCC report EPA and NMED noticed that the lab had high detection limits on the samples in the SE corner of the GCC property sampling grid. They asked me to find out why.

I assume that since the high DLs were in just the surficial samples that they are due to the weathered asphalt. But EPA has asked me to contact the lab and see what they say.

How would you like me to progress the issue? Should I work thru

MFG?

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