UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 6 

SUPERFUND DIVISION 

LouisianalNew Mexico/Oklahoma Team 

1445 Ross Avenue 

Dallas, Texas 75202-2733 

December 3, 2007 

Mr. David C. Clark 

Director, Environmental Remediation 

BNSF 

920 SE Quincy, P.O. Box 1738 

Topeka, Kansas 66601-1738 

Re: Site Characterization and Remediation at GCC Parcel for the AT &SF Albuquerque 

Superfund Site, Albuquerque, New Mexico 

Dear Mr. Clark: 

The U.S. Environmental Protection Agency (EPA) and the New Mexico 

Environmental Department (NMED) have reviewed the document titled, Site 

Characterization and Remediation at GCC Parcel for the AT &SF Albuquerque Superfund 

Site, Albuquerque, New Mexico (Site) and have included comments. The document was 

submitted to EPA and NMED under the signature ofTRC Environmental Corporation, on 

behalfofBNSF, Railway Company (BNSF). However, consistent with the Consent 

Decree (CD) for the Site, I am responding directly to you. Please find enclosed with this 

letter, comments from the two Agencies. 

On the whole, the Agencies find this report poorly written. This document 

contains many editorial and technical errors that require attention. In the future, efforts 

should be made to ensure that documents are written and reviewed with the appropriate 

level of quality assurance and control such that multiple iterations are not necessary 

before the document can be finalized. Significant improvements on the quality of work 

are needed to reduce review time, reduce the need for re-submittals, and increase overall 

project efficiency and progress. Please ensure that all future documents are consistent, 

well written, and complete. 

Page 10f7 December 3,2007 

Site Characterization and Remediation at GCC Parcel for the AT &SF Albuquerque Superfund Site, Albuquerque, New 

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Please use the enclosed comments to revise the current draft document. Should 

you have any questions or concerns, please call me at 214-665-8 143. 

Enclosure 

cc: Riaz Ahmed, TRC 

David Mayerson, NMED 

Katrina Higgins-Coltrain 

Remedial Project Manager (6SF-RL) 

LAlNMlOK Team 

Page 2 of7 December 3,2007 

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000680
Enclosure: EPAINMED comments on the Site Characterization and Remediation at GCC 

Parcel for the AT &SF Albuquerque Superfund Site, Albuquerque, New Mexico 

December 3, 2007 

General comments: 

• Change all references to "surfacial" to "surficial" 

• Change all references to "superfund" to "Superfund." 

• Add a reference section at the end that would include the Record of Decision, the 

MFG report, the Site Health and Safety Plan and QAPP, relevant and cited NMED and 

EPA correspondence (e.g., comment letters), as well as any other documents cited. 

• Please include the relevant soil SRG concentrations on Tables for ease of comparison. 

• Data for the Soil confirmation samples (attached below), sent to the Agencies on 

March 22, 2007, by email, is not consistent with Table 2. The reporting limits 

presented in March 2007 show the BAP equivalent to be below the SRG, however 

based on the Lab Data, sample CS-G 1 0 had reporting limits that exceed the SRG 

(8.320) and sample CS-G07, when the reporting limit of 1.660 is used, the BAP 

equivalent exceeds the SRG. This needs further evaluation. 

Page Paragraph Line number NMED Comment 

number with respect to 

with paragraph 

respect to 

pa2e 

4 4B N/A Chane;e "A sphalt" to "Asphalt" 

6 3 N/A Please include a figure that shows the 

locations of the MFG borings cited herein. 

7 3 N/A Please show the locations of the 

temporary monitoring wells that were 

installed by the GCC contractor. 

7 4 N/A Please include a bullet that states soil 

exceeding the zinc SRG or 200 mglkg will 

be removed. SS-21 and SS-16. 

8 2 7 After "[F]our soil samples were obtained" 

add "(e.g., 0107-SB-N, 0107-SB-E, 0107-

SB-W, and 0107 -SB-S)."· Additionally, 

please include these locations on a 

separate figure. 

8 3 2 Please indicate that the clean fill was 

imported from offsite and discuss/include 

any sample data of the fill, if applicable, 

that supports the assertion that the fill 

meets SRGs. 

8 4 1 Please re-phrase 'fenced area south of the 

site' here and elsewhere in the report. 

Please indicate that the fenced area is not 

Page 3 of 7 December 3, 2007 

Site ~haracterization and Remediation at Gee Parcel for the AT &SF Albuquerque Superfund Site, Albuquerque, New 

MexIco 

000681
'south of the site' but is the southern 

portion of the site. 

9 I 5 Please explain the reference to recycling 

the asphalt material, either onsite or 

offsite. 

9 2 7 Change "discreet" to "discrete." 

9 2 8 Figure 2: Should sample location CS-G03 

be identified as CS-G-03-1 since there is a 

CS-G03-2? If so, please correct the 

figure. 

9 2 N/A Please explain why CS-G04 and CS-G06 

were not composite samples, as indicated 

by the nomenclature. 

9 3 3 As noted above, please include full 

reference citations for the Field Sampling 

Plan and QAP. Should this reference the 

'QAPP'? 

9 3 5 The BAP equivalent concentration for CSG06 is 26.'-, as shown in Table 2. 

10 2 3 Please include the lateral distance from 

the original CS-G locations. 

10 3 N/A Please include a separate figure for the 

additional soil removal that was done for 

areas surrounding CS-G04, CS-G06, and 

Cs-GIO. 

10 3 2 Change "were" to "was." 

10 3 3 Change "were" to "was." 

10 3 3 Discoloration and odor only could have 

been useful for delineation of the 

excavation sizes for CS-G04 and CS-G06. 

Please explain what criteria guided the 

size of the excavation at CS-GIO-3. 

10 4 5 Change "were" to "was." 

12 5 3 Change "were" to "was." 

14 4 2 Please present a figure showing the 

locations of SS-16 and SS-21. 

Table 1: 

I. The note at the bottom should reflect that Y2 the reporting limit is used, not the 

detection limit or the method detection limit. These samples required dilution and had 

matrix interferences which resulted in the higher reporting limits. In addition, please 

revise this and other tables to indicate where the reporting is used in calculating the BAP 

equivalent. 

2. The note at the bottom should indicate that if the contaminant is non-detect, then the 

reporting limit is identified as a result and the BAP equivalent is expressed based on Y2 

these limits. 

Page 4 of7 December 3,2007 

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000682
3. Sample 0107-SB-W: the results for Benzo(k)fluoranthene and Dibenz(a,h)anthracene 

should be Y2 1.660. 

Table 2: 

Refer to comments 1 and 2 listed under Table I. 

2. Sample CS-GO 1: The results for Benzo(k)fluoranthene, indeno( 1 ,2,3-cd)pyrene and 

Dibenz(a,h)anthracene should be Y2 1.660. The BAP equivalent should be recalculated. 

3. Samples CS-G02, -G03, -G05, and -G09: All results should have the reporting limit 

identified as 1.660. The BAP equivalent should be recalculated. 

4. Sample CS-G04: The reporting limit should be identified as .333. The BAP 

equivalent should be recalculated. 

5. Sample CS-G 1 0: The reporting limit should be identified as 8.320. This reporting 

limit is well above the soil remediation goal. This reflects the same issues as we had with 

soil samples taken by GCC, where the detection limits were above the remediation goals. 

These detection limits are not low enough. The tables presented to us during soil removal 

are not consistent with the table presented here. See attachment. The BAP equivalent 

should be recalculated. 

6. Sample CS-G06: The reporting limit for indeno(1,2,3-cd)pyrene and 

Dibenz(a,h)anthracene should be Y2 8.320. The BAP equivalent should be recalculated. 

7. Sample CS-G07: The reporting limit for indeno(I,2,3-cd)pyrene and 

Dibenz(a,h)anthracene should be Y2 1.660. Using the reporting limit makes the BAP 

equivalent exceed the remediation goal. Again, refer to the data table attached. The BAP 

equivalent should be recalculated. 

8. CS-G08: The reporting limit for all contaminants (except benzo(a)anthracene and 

benzo(b )fluoranthene) should be Y2 1.660. The BAP equivalent should be recalculated. 

Table 4B: 

Refer to comments 1 and 2 listed under Table 1. 

1. Samples CS-G6-S and CS-G6-W should have the reporting limit identified as .330. 

The BAP equivalent should be recalculated. 

Table 5: 

Refer to comments 1 and 2 listed under Table 1. 

1. Sample CS-G 10-N: The result reported for benzo(a)anthracene should be .0534. The 

BAP equivalent should be recalculated. 

2. Sample CS-G4-N: The reporting limit should be identified as .006. The BAP 

equivalent should be recalculated. 

3. CS-G6-N: The zinc value is reported as 18.3. 

Table 6: 

Refer to comments 1 and 2 listed under Table I. 

1. Sample 0407-SB-47: the reporting limits for benzo(k)fluoranthene and chrysene 

should be .0333. 

Table 7: The zinc value for SS-21-S should be 24.7. 

Page 5 of 7 December 3, 2007 

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000683
Table of results presented to the Agencies on March 22, 2007 through email. Document titled: Gee Soil BAP Equivalency Table. 

Sample 

CS-G01 CS-G02 CS-G03 CS-G04 

Analyte BAP 

Equivalency Result BAP Result BAP Result BAP Result BAP 

PAHs Factor' (mg/kg) Equivalence (mg/kg) Equivalence (mg/kg) Equivalence (mg/kg) Equivalence 

Benzo(a) anthracene 0.1 4.18 0.418 <0.265 0 <0.265 0 0.053 0.0053 

Benzo(a) pyrene 1 1.86 1.86 <0.273 0 <0.273 0 0.0546 0.0546 

Benzo(b) fluoranthene 0.1 4.13 0.413 <0.277 0 <0.277 0 0.0554 0.00554 

Benzo(k) fluoranthene 0.01 0~15 0.0015 <0.300 0 <0.300 0 0.06 0.0006 

Chrysene 0.001 3.4 0.0034 <0.451 0 <0.451 0 0.0902 0.0000902 

Dibenz(a,h) anthracene 1 0.15 0.15 <0.300 0 <0.300 0 0.06 0.06 

Indeno(1,2,3-cd) pyrene 0.1 0.1405 0.01405 <0.281 0 <0.281 0 0.0562 0.00562 

BAP Equivalenceb 2.86 0.00 0.00 0.132 

Zinc 152 35.5 58.6 372 

Sample 

CS-G05 CS-G06 CS-G07 CS-G08 

Analyte BAP 

Equivalency Result BAP Result BAP Result BAP Result BAP 

PAHs Factor' (mg/kg) Equivalence (mg/kg) Equivalence (mg/kg) Equivalence (mg/kg) Equivalence 

Benzo(a) anthracene 0.1 <0.265 0 55.7 5.57 12.2 1.22 1.92 0.192 

Benzo(a) pyrene 1 <0.273 0 16.6 16.6 4.98 4.98 0.1365 0.1365 

Benzo(b) fluoranthene 0.1 <0.277 0 36.2 3.62 9.76 0.976 1.67 0.167 

Benzo(k) fluoranthene 0.01 <0.3.00 0 10.6 0.106 4.46 0.0446 0.15 0.0015 

Chrysene 0.001 <0.451 0 48.7 0.0487 10.9 0.0109 0.2255 0.000226 

Dibenz(a,h) anthracene 1 <0.300 0 0.75 0.75 0.15 0.15 0.15 0.15 

Indeno(1,2,3-cd) pyrene 0.1 <0.281 0 0.605 0.0605 0.1405 0.01405 0.1405 0.01405 

BAP Equivalenceb 0.00 26.8 7.40 0.661 

Zinc 35.8 34.7 24.7 29.2 

Page 6 of 7 December 3, 2007 

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000684
Sample 

CS-G09 CS-G10 

Analyte SAP 

Equivalency Result SAP Result SAP 

PAHs Factor' (mg/kg) Equivalence (mg/kg) Equivalence 

Benzo(a) anthracene 0.1 <0.265 0 <1.32 0 

Benzo(a) pyrene 1 <0.273 0 <1.37 0 

Benzo-<b) fluoranthene 0.1 <0.277 0 <1.38 0 

Benzo(k) fluoranthene 0.01 ,<0.300 0 <1.5 0 

Chrysene 0.001 <0.451 0 <2.25 0 

Dibenz(a,h) anthracene 1 ,~0~300',. 0 <1.5 0 

Indeno(1,2,3-cd) pyrene 0.1 <0.28,1 0 <1.4 0 

BAP Equivalenceb 0.00 0.00 

Zinc 131 215 

Notes: 

a BAP Equivalency Factor from Remedial Investigation 

b BAP Equivalence is the sum of the calculated equivalences (reported result 

concentration times equivalency factor). 

Ifall results were the lab reporting limit, then a concentration of 0 was entered. 

Ifsome results were above the reporting limit, 112 the reporting limits (shaded values) 

were entered for non-detected compounds for sake of calculation. 

BAP Equivalence above the Soil Remediation Goal of 7.8 mg/kg are shown in 

bold, italics font. 

Zinc results above the Soil Remediation Goal of 200 mg/kg are shown in bold, 

italics font. 

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000685