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PostedDate: 08/14/2007 03:44:39 PM

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InheritedFrom: "Ahmed, Riaz \(Houston,TX-US\)" 

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CopyTo: allan.pasteris@state.nm.us,"Clark, David C \(Topeka\)" 

<David.Clark@bnsf.com>,David.Mayerson@state.nm.us,"Ahmed, Riaz 

\(Houston,TX-US\)" <RAhmed@TRCSOLUTIONS.com>

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Subject: Re: Sampling at GCC Property

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<David.Clark@bnsf.com>,David.Mayerson@state.nm.us,"Ahmed, Riaz 

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

Dave/Riaz, NMED/EPA have reviewed the proposed plan of action for the 

removal of soil exceeding the soil remediation goals and have the 

following requests and comments.

000486
1. Attached is a markup of the map which Riaz sent. Please verify that

the identified locations are correct. In the future, please provide 

figures showing locations of interest. In addition, this figure does 

not 

show the confirmation samples taken in May 2007 around areas represented

by SB-44, SB-47, SB-45, SB48, and SB-54. Please include these sample 

locations and include the SRG values for Zinc (200mg/kg) and BAP (7.8 

mg/kg).

2. Please indicate that the soils will be staged on the southern 

portion 

of the site property and will be stabilized and disposed in the WWR area

during remedial action.

3. Please provide a proposed schedule of activity as well as an 

assurance 

that this will not delay or affect the upper intermediate aquifer 

characterization activity. Please include field schedule and report 

submittal schedule.

4. Sampling of the CS-10 locations will be grab or composite? Will be 

taken at what depth?

5. What is 'HNU type instrument'?

6. During excavation please make efforts to GPS sample locations and 

extent of soil removal (horizontal and lateral) so that these activities

can be documented in the final report and shown accurately on maps.

7. For future reference, please provide the actual acreage, legal 

description, and land parcel map for GCC. My understanding is that this

is a 16 acre parcel rather than a 20 acre parcel. 

 - 20070810125941annotated.pdf

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)

"Ahmed, Riaz \(Houston,TX-US\)" <RAhmed@TRCSOLUTIONS.com> 

08/10/2007 03:13 PM

To

Katrina Coltrain/R6/USEPA/US@EPA, <David.Mayerson@state.nm.us>, 

<allan.pasteris@state.nm.us>, "Clark, David C \(Topeka\)" 

<David.Clark@bnsf.com>

cc

"Ahmed, Riaz \(Houston,TX-US\)" <RAhmed@TRCSOLUTIONS.com>

Subject

Sampling at GCC Property

000487
Here is the proposed plan of action to remove additional impacted soils 

from GCC area. If you all agree with the proposed plan, we would like to

accomplish first task ASAP, even before we mobilize on August 20.

BNSF is in the process of selling a 20 acre L shaped parcel north of the

fence to GCC Premium Transloaders (GCC). At locations, GCC observed 

several north-south linear surface expression of asphaltic like 

material. 

GCC requested that BNSF remove this material. The removal of this 

material 

was completed soon after. During this removal process , BNSF noted that 

certain areas seemed impacted based on visual and odor observations. The

impacted soil was also removed at the same time. Upon removal of all 

material, 10 composite sample were taken to verify that the bottom of 

the 

excavation met soil remediation goals(SRG). The attached figure shows 

areas of excavation and composite samples taken for verification 

purposes. 

Verification sampling showed three samples to exceed SRG. They are CSG04 

with Zinc at 372mg/kg, CS-G06 with BAP at 26.8 and CS-G10 with zinc at 

215. As evident from the attached figure, CS-G04 and CS-G06 are not 

composite samples. CS-G10 is a composite of three samples. 

First task will be to sample CS-G10-1, CS-G10-2, and CS-G10-3 for zinc 

and 

identify location(s) that have zinc above 200 mg/kg.

Second task will be to step out 10 feet ( can be adjusted in field based

on visual or odor observations) in all four direction . Excavate the 

entire area i.e. 20 ft by 20 ft to a depth of three feet. A soil sample 

will be taken at the center of each wall and analyzed for BAP in case of

CS-G06 and zinc for others. Step out will be continued till we obtain 

data 

that shows soil samples to be blow SRG. 

Since these areas have already been excavated to a certain extent, the 

following procedure will be used to determine the depth of excavation:1-

Around each excavation at least three elevation measurements will made 

on 

undisturbed land.2- The average of the three measurements will be used 

as 

reference elevation for that location.3- Reference elevation minus three

feet will be used as the target elevation of excavation at that 

particular 

000488
location. 

All work will be done as per Site Health and Safety plan and a HNU type 

instrument will be available at the site.

[attachment "20070810125941.pdf" deleted by Katrina 

Coltrain/R6/USEPA/US] 

000489
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Subject: Sampling at GCC Property

PostedDate: 08/10/2007 03:13:42 PM

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Thread_Topic: Sampling at GCC Property

Thread_Index: Acfbiu+IPqAnx4LtRCe9kG9jTnY00Q==

From: "Ahmed, Riaz \(Houston,TX-US\)" <RAhmed@TRCSOLUTIONS.com>

SendTo: Katrina Coltrain/R6/USEPA/US@EPA,<David.Mayerson@state.nm.us>,

<allan.pasteris@state.nm.us>,"Clark, David C \(Topeka\)" 

<David.Clark@bnsf.com>

CopyTo: "Ahmed, Riaz \(Houston,TX-US\)" <RAhmed@TRCSOLUTIONS.com>

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000490
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Here is the proposed plan of action to remove additional impacted soils 

from GCC area. If you all agree with the proposed plan, we would like to

accomplish first task ASAP, even before we mobilize on August 20.

BNSF is in the process of selling a 20 acre L shaped parcel north of the

fence to GCC Premium Transloaders (GCC). At locations, GCC observed 

several north-south linear surface expression of asphaltic like 

material. 

GCC requested that BNSF remove this material. The removal of this 

material 

was completed soon after. During this removal process , BNSF noted that 

certain areas seemed impacted based on visual and odor observations. The

impacted soil was also removed at the same time. Upon removal of all 

material, 10 composite sample were taken to verify that the bottom of 

the 

excavation met soil remediation goals(SRG). The attached figure shows 

areas of excavation and composite samples taken for verification 

purposes. 

Verification sampling showed three samples to exceed SRG. They are CSG04 

with Zinc at 372mg/kg, CS-G06 with BAP at 26.8 and CS-G10 with zinc at 

215. As evident from the attached figure, CS-G04 and CS-G06 are not 

composite samples. CS-G10 is a composite of three samples. 

First task will be to sample CS-G10-1, CS-G10-2, and CS-G10-3 for zinc 

and 

identify location(s) that have zinc above 200 mg/kg.

Second task will be to step out 10 feet ( can be adjusted in field based

on visual or odor observations) in all four direction . Excavate the 

entire area i.e. 20 ft by 20 ft to a depth of three feet. A soil sample 

will be taken at the center of each wall and analyzed for BAP in case of

CS-G06 and zinc for others. Step out will be continued till we obtain 

data 

that shows soil samples to be blow SRG. 

Since these areas have already been excavated to a certain extent, the 

following procedure will be used to determine the depth of excavation:1-

Around each excavation at least three elevation measurements will made 

on 

undisturbed land.2- The average of the three measurements will be used 

as 

reference elevation for that location.3- Reference elevation minus three

000491
feet will be used as the target elevation of excavation at that 

particular 

location. 

All work will be done as per Site Health and Safety plan and a HNU type 

instrument will be available at the site.

 - 20070810125941.pdf

000492
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Subject: RE: Sampling at GCC Property

PostedDate: 08/13/2007 10:06:47 AM

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Thread_Topic: Sampling at GCC Property

Thread_Index: Acfbiu+IPqAnx4LtRCe9kG9jTnY00QCLqeTg

From: "Mayerson, David, NMENV" <David.Mayerson@state.nm.us>

SendTo: Katrina Coltrain/R6/USEPA/US@EPA

CopyTo: "Pasteris, Allan, NMENV" <allan.pasteris@state.nm.us>

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000493
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Katrina: The following are NMED comments on the proposed plan of 

action 

for the GCC property that was submitted today by Riaz Ahmed.

____________________________________

Attached is a markup of the map which Riaz sent. I would ask that BNSF

verify that I have identified the locations correctly. In the future, 

I 

would appreciate if BNSF could provide such visual aids in its 

submittals.

Second, for those of us who are still trying to catch up with the Site 

history, please request that BNSF confirm that the SRG numerical values

are still as documented in the ROD, section 9.2, i.e., 

 Zn 200 mg/kg

 BAP 7.8 mg/kg

NMED would also appreciate if future workplan submittals also include 

such values, and reference their origins, when appropriate.

Third, please request BNSF provide a proposed schedule for the conduct 

of 

the activities under this workplan.

Fourth, please request BNSF to provide assurance that the conduct of 

these activities will not affect the proposed upper intermediate 

aquifer 

characterization program that is scheduled to begin on 8/20/2007.

Please let me know if you have any concerns or questions about this.

David L. Mayerson

New Mexico Environment Department

Ground Water Quality Bureau

Superfund Oversight Section

1190 St. Francis Drive #N2312

Santa Fe, NM 87502

(505) 476-3777 (telephone)

(505) 827-2965 (fax)

david.mayerson@state.nm.us

Normal hours: M-Th 0700-1730

From: Ahmed, Riaz (Houston,TX-US) [mailto:RAhmed@TRCSOLUTIONS.com] 

Sent: Friday, August 10, 2007 14:14

To: Coltrain.Katrina@epamail.epa.gov; Mayerson, David, NMENV; Pasteris,

Allan, NMENV; Clark, David C (Topeka)

Cc: Ahmed, Riaz (Houston,TX-US)

Subject: Sampling at GCC Property

000494
Here is the proposed plan of action to remove additional impacted soils

from GCC area. If you all agree with the proposed plan, we would like 

to 

accomplish first task ASAP, even before we mobilize on August 20.

BNSF is in the process of selling a 20 acre L shaped parcel north of 

the 

fence to GCC Premium Transloaders (GCC). At locations, GCC observed 

several north-south linear surface expression of asphaltic like 

material. 

GCC requested that BNSF remove this material. The removal of this 

material was completed soon after. During this removal process , BNSF 

noted that certain areas seemed impacted based on visual and odor 

observations. The impacted soil was also removed at the same time. Upon

removal of all material, 10 composite sample were taken to verify that 

the bottom of the excavation met soil remediation goals(SRG). The 

attached figure shows areas of excavation and composite samples taken 

for 

verification purposes. Verification sampling showed three samples to 

exceed SRG. They are CS-G04 with Zinc at 372mg/kg, CS-G06 with BAP at 

26.8 and CS-G10 with zinc at 215. As evident from the attached figure, 

CS-G04 and CS-G06 are not composite samples. CS-G10 is a composite of 

three samples. 

First task will be to sample CS-G10-1, CS-G10-2, and CS-G10-3 for zinc 

and identify location(s) that have zinc above 200 mg/kg.

Second task will be to step out 10 feet ( can be adjusted in field 

based 

on visual or odor observations) in all four direction . Excavate the 

entire area i.e. 20 ft by 20 ft to a depth of three feet. A soil sample

will be taken at the center of each wall and analyzed for BAP in case 

of 

CS-G06 and zinc for others. Step out will be continued till we obtain 

data that shows soil samples to be blow SRG. 

Since these areas have already been excavated to a certain extent, the 

following procedure will be used to determine the depth of 

excavation:1- 

Around each excavation at least three elevation measurements will made 

on 

undisturbed land.2- The average of the three measurements will be used 

as 

reference elevation for that location.3- Reference elevation minus 

three 

feet will be used as the target elevation of excavation at that 

particular location. 

All work will be done as per Site Health and Safety plan and a HNU type

instrument will be available at the site.

000495
______________________________________________________________________

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 - 20070810125941annotated.pdf

000496