Principal: CN=Katrina Coltrain/OU=R6/O=USEPA/C=US 

$LangPrincipal: 

$AltPrincipal: 

ForwardedFrom: CN=Katrina Coltrain/OU=R6/O=USEPA/C=US 

ForwardedDate: 02/16/2007 07:03:57 AM 

$AutoSpell: 1 

InetSendTo: . 

InetCopyTo: .,Turner.James@epamail.epa.gov,. 

InetBlindCopyTo: 

$StorageTo: . 

$StorageCc: .,1,. 

$Mailer: Lotus Notes Release 6.5.1 January 21, 2004 

$MessageID: <OF051C5D52.7CB27364-ON86257284.0047CEA5-

86257284.004D71F5@LocalDomain> 

INetFrom: Coltrain.Katrina@epamail.epa.gov 

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: 

EnterSendTo: david clark 

EnterCopyTo: susan morris,CN=James Turner/OU=R6/O=USEPA/C=US,riaz ahmed 

EnterBlindCopyTo: 

$UpdatedBy: CN=Katrina Coltrain/OU=R6/O=USEPA/C=US 

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. 

000475
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. 

 

000476
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 higher 

000477
detection 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.com 

000478
 

From: 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? 

CONFIDENTIALITY NOTICE: 

This e-mail and any attachments contain information from 

the law firm of McKenna Long & Aldridge LLP, and are 

intended solely for the use of the named recipient or 

recipients. This e-mail may contain privileged 

attorney/client communications or work product. Any 

dissemination of this e-mail by anyone other than an 

intended recipient is strictly prohibited. If you are not a 

named recipient, you are prohibited from any further 

viewing of the e-mail or any attachments or from making any 

use of the e-mail or attachments. If you believe you have 

received this e-mail in error, notify the sender 

immediately and permanently delete the e-mail, any 

attachments, and all copies thereof from any drives or 

storage media and destroy any printouts of the e-mail or 

attachments. 

000479