UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 SUPERFUND DIVISION LouisianalNew Mexico/OklahomaTeam 1445 Ross Avenue Dallas, Texas 75202-2733

December3, 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

DearMr. Clark:

The U.S. Environmental Protection Agency (EPA) and theNewMexico Environmental Department (NMED) have reviewed the documenttitled, Site Characterization and Remediation at GCC Parcel for the AT &SF Albuquerque Superfund Site, Albuquerque, NewMexico (Site) and have included comments. The document was submitted to EPA and NMED underthe signature ofTRC Environmental Corporation, on behalfofBNSF, Railway Company (BNSF). However, consistentwith 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 toensure that documents are written and reviewed with the appropriate level ofquality assurance and control such that multiple iterations are not necessary beforethe document can be finalized. Significant improvements on the quality ofwork

are needed to reduce reviewtime, 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 December3,2007 Site Characterization and Remediation at GCC Parcel for the AT&SF Albuquerque Superfund Site,Albuquerque, New Mexico 

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----Please usethe enclosed commentsto revise the currentdraft document. Should you have any questions orconcerns, please call me at 214-665-8143.

Enclosure

cc: Riaz Ahmed, TRC David Mayerson, NMED Katrina Higgins-Coltrain Remedial ProjectManager(6SF-RL) LAlNMlOKTeam

Page 2 of7 December3,2007 Site Characterization and Remediation at GCC Parcel for the AT&SFAlbuquerque Superfund Site, Albuquerque, New MexicoEnclosure: EPAINMED comments on the Site Characterization and Remediation at GCC Parcel for the AT &SF Albuquerque Superfund Site, Albuquerque, NewMexico December3, 2007



### Generalcomments:

• 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 otherdocuments cited.

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

• 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-G1 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 equivalentexceedsthe SRG. This needs further evaluation.



### Page Paragraph Line number NMED Comment number with respectto

with paragraph respectto pa2e 4 4B N/A Chane;e "A sphalt"to "Asphalt" 6 3 N/A Please include a figure that shows the locations ofthe MFG borings cited herein. 

### 7 3 N/A Please showthe locations ofthe temporary monitoring wellsthatwere installed bythe GCC contractor. 7 4 N/A Please include a bulletthat states soil exceeding the zinc SRG or200 mglkg will be removed. SS-21 and SS-16. 8 2 7 After "[F]our soil sampleswere 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 thatthe clean fill was imported from offsite and discuss/include any sample data ofthe fill, ifapplicable, that supports the assertion thatthe fill meets SRGs. 8 4 1 Please re-phrase 'fenced area south ofthe site' here and elsewhere in the report. Please indicate thatthe fenced area is not

Page 3 of7 December3, 2007 Site**~haracterization** and Remediation atGee Parcel forthe AT&SF Albuquerque Superfund Site, Albuquerque, New MexIco'south ofthe site' but is the southern portion ofthe site. 

### 9 I 5 Please explainthereference to recycling the asphalt material, eitheronsite 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 sincethere is a CS-G03-2? Ifso, pleasecorrectthe 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 referencethe 'QAPP'? 

### 9 3 5 The BAPequivalent 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 odoronly could have been useful for delineation ofthe excavation sizes for CS-G04 and CS-G06. Please explain whatcriteriaguided the size ofthe excavation atCS-GIO-3. 10 4 5 Change "were"to "was." 12 5 

### 3 Change "were"to "was." 14 4 2 Please present a figure showingthe locations ofSS- 16 and SS-21.



### Table 1: I. The note atthe bottom should reflect that Y2 the reporting limitis used, notthe detection limit orthe method detection limit. These samplesrequired dilution and had matrix interferences which resulted in the higherreporting limits. In addition, please revise this and othertables to indicate where the reporting is used in calculatingthe BAP equivalent. 2. The note atthe bottom should indicatethat ifthe contaminant is non-detect, thenthe reporting limit is identified as a result and the BAPequivalent is expressed based on Y2 these limits.

Page 4 of7 December3,2007 Site Characterization and Remediation at GCC Parcel for the AT&SFAlbuquerque Superfund Site. Albuquerque. New Mexico3. Sample 0107-SB-W: the results for Benzo(k)fluoranthene and Dibenz(a,h)anthracene should be 

### Y2 1.660.

Table2: Referto comments 1and 2 listed underTable I. 2. Sample CS-GO1: 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 BAPequivalent should be recalculated. 4. Sample CS-G04: The reporting limit should be identified as .333. The BAP equivalent should be recalculated. 5. Sample CS-G1 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. SampleCS-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 makesthe BAP equivalentexceed the remediation goal. Again, referto the datatable attached. The BAP equivalent should be recalculated. 8. CS-G08: The reporting limit for all contaminants (exceptbenzo(a)anthracene and benzo(b)fluoranthene) should be 

### Y2 1.660. The BAP equivalent should be recalculated.

Table4B: Referto comments 1and 2 listed underTable 1. 1. Samples CS-G6-S and CS-G6-W should have the reporting limit identified as .330. The BAPequivalent should be recalculated.

Table

### 5: Referto comments 1and 2 listed underTable 1. 1. Sample CS-G10-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: Thezinc value is reported as 18.3.

Table6: Referto comments 1and 2 listed under Table I. 1. Sample 0407-SB-47: the reporting limits for benzo(k)fluoranthene and chrysene should be .0333.

Table7: The zinc value for SS-21-S should be 24.7.

Page 5 of7 December 3, 2007 Site Characterization and Remediation at GCC Parcel for the AT&SF Albuquerque Superfund Site,Albuquerque, New MexicoTable ofresults presented to the Agencies on March 22, 2007 through email. Documenttitled: 

### 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 of7 December3, 2007 Site Characterization and Remediation atGCC Parcel for the AT&SF Albuquerque Superfund Site, Albuquerque, NewMexicoSample 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 Factorfrom Remedial Investigation

b BAP Equivalence is the sum ofthe calculated equivalences (reported result concentration times equivalency factor). Ifall results were the lab reporting limit, then a concentration of0 was entered. Ifsomeresults were above the reporting limit, 112 the reporting limits (shaded values)

were entered for non-detected compounds for sake ofcalculation. BAP Equivalenceabove the Soil Remediation Goal of7.8 mg/kg areshown in bold, italics font. Zinc results abovethe Soil Remediation Goal of200 mg/kg areshown in bold, italics font.

Page 7 of7 December3, 2007 Site Characterization and Remediation at GCC Parcel for the AT &SFAlbuquerque Superfund Site, Albuquerque, NewMexico