UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OSC REPORT
:MFJ!Gi7NCY REMOVAL ACTION
Pa»jano Salvage Yard
Valencia County
Los Lunas, New Mexico
Prepared By:
Gary W. Guerra
On-Scene Coordinator
f.:'PA Reyion Six
; 10, ^
-------
TABLE OF CONTENTS
I. SUMMARY OF EVENTS 2
A. Location of Hazardous Release 2
B. Cause of Release....' 2
C. Initial Situation 3
D. Efforts to Obtain Response by Responsible Parties 4
E. Organization of Response 4
F. Resources Commi tted 5
G. Effect on Natural Resources 5
H. Threat Abatement Acti on Taken 6
I. Treatment Methods Pursued and Followed 10
J. Community Relations Activities 11
II. EFFECTIVENESS OF REMOVAL ACTIONS TAKEN BY OTHER PARTIES 12
III. DIFFICULTIES ENCOUNTERED 12
A. Site Accessibility and Confined Working Space 12
B. DefauIt of Soi 1 s Laboratory 13
C. Changing Land Disposal Facilities 13
D. Additional Contamination 13
IV. RECOMMENDATIONS 14
-------
I. SUMMARY OF EVENTS
A. Location of Hazardous Release:
A release of Polychlorinated Biphenyls (PCBs) was documented in
the soils and nearby surface water. The PCBs existed over the
entire property, boundary to boundary, at levels in excess of the
cleanup level of ten (10) parts per million (ppm). While a
release has been documented to the nearby surface water sediments
(Peralta Drain), the levels were below those considered an
immediate threat to the local human health and environment.
The hazardous release is located at 102 Edeal Road, Los Lunas,
Valencia County, New Mexico. This address is approximately 1.0
mile south of the Edeal Road and Highway 49 intersection
(Attachment A1). The Village of Los Lunas (population = 3625),
is approximately 25 miles south of Albuquerque, New Mexico.
The release is located in a residential area, immediately
adjacent to the primary roadway (Edeal) that serves this
community. The area defined as the "site" is bounded as such:
Edeal Road (Valencia County) immediately along the entire East
border; State-owned property immediately adjacent to the South
and West borders, with a man-made creek along the West and
controlled irrigation ditch to the South; and a livestock pasture
(private property) immediately adjacent to the North (Attachment
B1 and B2).
B. Cause of Release:
As part of normal salvage operations, the operator purchased
salvageable materials which included transformers, capacitors and
55-gallon drums filled with waste oils. Upon placement of the
drums on-site, several of the transformers and capacitors leaked
fluids that contained high levels of PCBs, onto the soil.
Additionally, the operator reportedly utilized some of the fluids
as a fuel for enhancing the burning of insulated copper wire.
It was determined that the areas of highest concentration
coincided with those areas defined as "burn" areas and an area
directly related to the household septic system (drain field).
While the operator claims no knowledge of how the extensive
contamination (to depths of 5.5 ft) in the drain field occurred,
post-excavation sampling indicated a very definite pattern of
migration. The exact cause of this specific release is
unconfirmed at this time.
It appears that the migration of PCBs may have been caused by the
existence of PCBs in the septic system, thus encouraging the
depth contamination. Evidence gathered (sample data) confirmed
PCBs in the concrete septic tank and drain lines. This theory is
-------
supported with significant amounts of data and a pattern of
contamination that indicated "clean" at upper levels, then "hot"
at much lower levels. This pattern was not found anywhere else
except the drain field, and the highest levels mirrored the drain
line pattern. This theory is deemed the most probable cause for
a release at this depth.
C. Initial Situation:
The area described as the "site" (Section I-A) is actually
comprised of two property owners. The northern third of the site
is owned by Mr. Ben Smith. The southern two-thirds of the site
is currently owned by Mrs. Margaret Pagano (OWNER). The Smith
portion was leased to the Pagano's for many years and utilized
for salvage operations.
The Pagano Salvage Yard was established in the early 1960s by Mr.
Carmen Pagano. The company purchased scrap from several federal
facilities including White Sands Missile Range, Kirkland Air
Force Base, Rocky Mountain Arsenal and Sandia National
Laboratories (SNL). After November 2, 1982, and the death of Mr.
Pagano, the salvage operations were continued by the stepson, Mr.
David Peluchette (OPERATOR).
During mid-1983, the operator purchased a "lot" of salvage from
SNL that contained several transformers and capacitors. Several
of these containers leaked fluids containing PCBs onto the soils
of the site.
On September 10, 1984, a Resource Conservation and Recovery Act
site inspection was conducted by the New Mexico Environmental
Improvement Division (NMEID). Levels of PCBs in excess of the
EPA's Action Level of 50 ppm, were identified at that time.
After the operator notified SNL of his concern about receiving
the containers and the related contamination, SNL responded by
removing the capacitors on June 18, 1935, and also sampling drums
that allegedly were purchased in a lot from SNL. The analysis
confirmed PCBs in the drums as well. The drums were removed from
the site at a later date by SNL.
Following this action, the Superfund office revisited the site to
conduct a variety of assessment-type inspections. Starting in
September of 1985, the Field Investigative Team and Technical
Assistance Team (TAT) have shared duties sampling, analyzing,
ranking for inclusion on the National Priorities List (NPL) and
eventually assessing the immediate threat to the public health,
welfare and/or environment.
-------
The site scored sufficiently to be proposed for inclusion on the
NPL in June, 1988. The site was promulgated to the NPL in
October, 1989. Prior to promulgation, United States
Environmental Protection Agency (EPA) Emergency Response Branch
(ERB) conducted a series of site assessments to determine the
immediate threat posed by the site.
On March 23, 1989, the Regional Administrator approved ERB's
recommendation for a Time-Critical Emergency Removal Action at
this NPL site. Following enforcement activities (See Section
I-D), ERB initiated an on-site response on June 20, 1989.
D. Efforts to Obtain Response by Responsible Parties:
A Potentially Responsible Party (PRP) search was conducted which
identified seven PRPs. On March 29, 1989, notice letters were
sent to the PRPs allowing them the opportunity to participate in
the removal action. The PRPs declined to undertake the removal
action.
On June 8 1989, EPA issued a CERCLA §106 Unilateral
Administrative Order to the PRPs, requiring them to perform the
removal. Although none of the PRPs agreed to perform the
removal, some expressed an interest in funding the action.
Consequently, a preliminary agreement was negotiated whereby the
EPA would conduct the cleanup and the PRPs would eventually
reimburse the EPA for total project costs.
Negotiations continue between the PRPs and Regional Counsel at
the present time. U.S. Department of Justice has already
assigned an attorney to the case, and will pursue the potential
for total cost recovery.
E. Organization of Response:
While the NMEID did not actively participate in any on-site
activity, they remained updated on the status of the removal.
The primary participants for this response, and assigned duties
are listed below:
1. USEPA/ERB - Emergency Response Branch
- Gary W. Guerra; On-Scene Coordinator (OSC)
2. USEPA/ERT - Environmental Response Team
- Rodney Turpin; Site Safety Officer &
Inspector
- William A. Coakley; Quality Assurance
Officer
- Raj Singhvi; Laboratory Coordinator
- George Prince; Geologist, well
installation
-------
3. FEMA - Federal Emergency Management Agency
- Barry Hansen; Project Manager, relocation
4. ERCS - Emergency Response Contracting Services
- LeRoy Cassidey; Response Manager
5. TAT - Technical Assistance Team
- Matthew Kaarlela; Project Manager
F. Resources Committed:
On March 23, 1989, the Regional Administrator authorized
$1,275,750 for the ERCS and $1,690,000 for the entire project.
As the project progressed, it was determined that additional
funding would be necessary to complete the project, and a second
Action Memorandum requesting "Exemption From the $2 Million
Statutory Ceiling and Ceiling Increase" was developed for
Headquarters approval (OSWER).
The exemption and increase were approved December 12, 1989, thus
authorizing a new ERCS ceiling of $2.2 million and a total
project ceiling of $2.968 million. The OSC increased the ERCS
ceiling to $1.95 million in order to conserve funds. This
conservation of funds committed to a total project ceiling of
$2.472 million instead of the authorized limit of $2.968 million.
The following figures are the best estimates, as of the final
printing date of this report:
************************************************************
Committed Actual (X)
ERCS $1,950,000 $1,841,000 (94)
TAT $ 290,000 $ 280,000(97)
ERT & FEMA $ 132,000 $ 108,000 (82)
EPA $ 100,000 $ 99,000 (99)
Total...$2,472,000 $2,328,000 (94)
************************************************************
G. Effect on Natural Resources:
To date, no Federal or State, trustee reports or assessments
exist relating to injury or potential injury to the local natural
resources. It is the OSC's assessment, that the local natural
resources were not effected (i.e. - mineral deposits &
waterpower) due to this release.
-------
H. Threat Abatement Action Taken:
Primary Objective:
As originally proposed, the primary objective of this removal
action was to remove the source of contamination. Assuming that
this proposed abatement action could be achieved at the cleanup
level selected, ten (10) parts per million (ppm), the threats
posed by this site would be eliminated and thus requiring minimal
EPA remedial activity.
Phase Activity:
Due to many inherent physical, contractual and logistical
limitations, the work was conducted in "phases", such that
multiple tasks could be conducted simultaneously. "Phase"
activity was conducted in the following basic order:
1) Excavation:
- Site organized into "Sections" and "grids";
- "Sections" refer to arbitrary labelling of entire site;
while "grids" refer the 20'x20' square-shaped areas that
comprised the respective sections; both were utilized to
organize and track the excavation and sampling
processes;
- In some instances, the grids were "quadded" into four
smaller grids of 10*x10', in an effort to provide a more
defined quantification of contaminants and to ensure an
effective cleanup;
- Direction for excavation was defined by Section, grid
and quad where relevant.
NOTE: See Attachments C1 & D1 for detail on excavation
grids.
Also attached is a 3-dimensional (simulated) drawing
of the Base Map (Attachment E1); this provides a
perspective of the site sampling structure and of
the progression of phase activity.
2) Sampling and Analysis:
- Utilized a computer-designed sampling plan that
incorporated the use of 20'x20' squares to provide an
organized method for tracking the progress of the
project and provide a statistically valid method for
analyzing the samples representing the site soils
(Attachment D1);
-------
- EPA Environmental Response Team (ERT) provided an
on-site, 24-hour, laboratory complete with crew at the
OSC's request; the request was preceded by QA/QC
problems at a contracted laboratory;
- Samples could be immediately collected and analyzed in
the event that difficulties arose in the process.
3) Quality Assurance/Quality Control (QA/QC):
- ERT provided both on-site and off-site "checking" of
data packages in order to ensure that valid data would
be available prior to OSC's evaluation.
4) Evaluation:
- OSC evaluates all of QA/QC'd data prior to defining a
section, grid or quad "clean."
- Consideration was given to False/Negative Limitations
and the probability that values near 10 ppm would
statistically "average out."
NOTE: All sample chain-of-custody records, raw data
packages, QA/QC packages, Validation Packages,
OSC's Data Summary/Evaluation sheets and OSC/Site
log books, are available in the Removal File.
Initial Phases:
The entire site was excavated to a depth of 10 inches below
original grade. Analytical results from Phase One of sampling
indicated that approximately 33% of the surface area remained in
excess of 10 ppm.
Work continued through Phase Six at which time it was obvious
that the existing funds approved would not suffice for the
anticipated transportation and disposal requirements. At this
time all project personnel were temporarily demobilized until
funding could be procured by the OSC. The rationale to
demobilize was based on findings that the depth contamination,
that had already extended to over 2.5 feet in selected quads, may
extend even further.
The OSC's Data Summary/Evaluation indicated a digressive
quantitative progression (high to low PCB concentrations). As it
appeared that only a few stubborn grids and quads remained to be
"cleaned", significant changes in the progression were defined in
selected grids. The grids in question all were located within
and beneath the single residential septic system. The area would
henceforth be referred to as the "drain field", due to its
function.
-------
Just prior to demobilization of the entire crew, depth samples
(cores) were collected in "clean" and "hot" areas. As expected,
depth contamination was confirmed well below the Phase Six level
(2.5 feet below original grade). The extent of this migration
could not be defined specifically at this time, but the OSC
suspected that the drain field would ultimately be confirmed as
the location of the remainder of the PCS contaminated soils.
Second Phases:
When additional funding was approved through EPA Headquarters,
project activity resumed without incident. Phase Seven activity
included confirmational sampling and extensive core sampling in
areas strongly suspected of contamination. The resultant data
confirmed that extensive contamination, above the cleanup level,
existed at depths nearing six feet below the original grade.
All of the contamination followed the direct path of drain lines
and remained within the porous drain field material. Phase
activity continued as scheduled.
Phases Eight through Thirteen did not produce a massive number of
samples (as in 1-6), but did create some inherent time delays due
to new analytical arrangements. Since the ERT Lab could not be
set up on-site in a time and cost effective manner, samples were
mailed directly to the ERT Lab in Edison, New Jersey. Upon
evaluation, the grids were defined as "clean" and restoration
activities followed.
NOTE: A copy of the ERT's final report (QA/QC'd) on all samples
analyzed is provided with this OSC report.
A summary of the QA/QC'd data for all thirteen phases is
attached; see Attachment F1 (Soil Data Summary).
As noted earlier in this section, a 3-dimensional version
of each of the "phases" is attached; phase 13 is not shown
as no further excavation was required.
Restoration Activity:
Approximately 5100 tons of soil and debris were disposed of
off-site. Approximately 4900 cubic yards of native soil was
restored to as near original condition as possible. Truckloads
of material were off-loaded at the site in dump trucks of
variable sizes. The TAT and ERCS verified each load to confirm
quantities and associated costs. Various ERCS subcontractors
completed all restoration activities per the OSC's instruction.
During the process of excavation, several utilities were
disrupted or completely removed. All utilities (i.e. -
electrical, telephone, water, gas and septic system) were
8
-------
restored to original working conditions. In addition, personal
property that was damaged during the course of this removal
(i.e. - fence around yard) was replaced to original conditions
as best possible.
Additional Objectives:
The following items were additional project objectives:
1) Compliance, with the multitude of Federal, State, County,
and City regulations that affected this site (i.e., LDR,
OSHA, DOT);
2) Consistency, with any future remedial action (source
removal);
3) Confirmation, of "effectiveness" both during and after the
removal (i.e., QA\QC & sampling).
Compliance and consistency were ensured through pre-removal
planning and close communication between the EPA and respective
parties. A total source removal was consistent with remedial
plans for the future.
Confirmation of "effectiveness" was best demonstrated via
sampling. All effected media were addressed utilizing a variety
of methods. The resultant data has been summarized and attached
to this report. The following is a summary of the confirmation
or "characterization" sampling that was conducted during the
project:
1) Air:
- On-site Low-volume personal pumps (OSHA 1910.120)
- Off-site High-volume area monitors (PCBs only)
* QA/QC'd data available in Removal file
** see Attachment G1 for Hi-Vol data summary
*** see Attachment G2 for Hi-Vol location map
2) Soil:
- On-site Total HSL Metals (Hazardous Substance List) (11)
Lead (X-Ray Fluorescence - XRF) (HI)
- Off-site Full HSL scan (11)
(PCBs only) (J1)
* QA/QC'd data available in removal file
** see Attachments H1 & II & J1 for data summaries
*** see Attachments H2 & 12 & J2 for location maps
-------
Note: The on-site HSL samples were taken at depth (cores) and
in the areas that had indicated the greatest potential
for contamination. The off-site HSL samples were taken
at the surface.
The XRF readings were taken at surface levels, prior to
excavation. All of these areas were excavated during
the removal.
3) Groundwater:
- On-site Residential & monitoring wells (full scan)
- Off-site Residential & monitoring wells (full scan)
* ERT installed (5) monitoring wells
** ERT collected and analyzed all well samples
*** QA/QC*d data and maps are available in the ERT report
that is attached.
4) Surface Water:
- Off-site sediments in adjacent drain (full scan)
* QA/QC'd data available in removal file
** see Attachment J1 (PCBs only) for data summary
*** See Attachment J2 (PCBs only) for location map
All the data gathered confirm that all project objectives were
achieved. Evaluation of the data on-site, and the simultaneous
phase activity provided for a true challenge of performance for
all project personnel. All parties involved played an integral
and vital part towards the success of these threat abatement
actions.
I. Treatment Methods Pursued and Followed:
In evaluating which treatment method to utilize for this project,
several factors were considered. The primary factors evaluated
were: a) promotion of an efficient cleanup, b) consistency with
the proposed remedial action, and c) appropriateness with respect
to any potential threats.
Considering all of the preceding factors, it was determined that
landfill ing of the contaminated soil and debris would best meet
all of these factors, and provide the most cost and time
effective method for disposal. A National Variance would be
cited as the means by which the soil and debris would be allowed
into a landfill under the current Federal Land Disposal
Regulations.
10
-------
The extremely high costs for incineration of all site soils made
this option, undesirable. Technical difficulties between the
hydrogeological conditions and currently available technologies,
(i.e., K-Peg method), proved to be undesirable.
J. Community Relations Activities:
In an effort to establish a solid working relationship with all
parties that would potentially be affected during the course of
the removal action, the OSC and ERB Community Relations
personnel, made personal contact with a variety of groups prior
to the removal and continued this contact for the duration of the
project. The following is a list of groups contacted, and a
brief description of the agreement or understanding between the
OSC and respective group:
1. State of New Mexico:
a. Environmental Improvement Division - this site was
originally referred to the EPA via the State; the
OSC continues to provide updates.
b. Middle Rio Grande Conservacy Division - authorized
utilization of state-owned land that immediately bounded
the site.
c. Valencia County - authorized utilization of all
primary roadways for transportation of project material
(hazardous & non-hazardous) to and from the site;
authorized temporary restriction of traffic on Edeal
Road; provided all construction signs and barriers
for restricting traffic; provided several useful maps
and blueprints of the state, county and city.
d. Highway Patrol - provided OSC with recommended safe
routes of travel for disposal vehicles; acknowledged
potential dangers associated to this site.
2. Village of Los Lunas - acknowledged EPA's efforts and
offered any help if necessary.
a. Police Department - assisted by informing local
citizens; assisted in distribution of EPA information
flyers.
b. Fire Department - understood their role in the event
of an emergency; OSC reviewed safety aspects of -this
project.
c. Library - assisted in distributing EPA information
flyers to the general public.
11
-------
Per request of the OSC, ERB Community Relations personnel
prepared a bi-lingual information flyer relative to the site and
anticipated actions at the site. EPA personnel went door-to-door
to distribute flyers along the roadway that would be most
affected (Edeal Road). As the project progressed, the OSC
distributed maps of "detour routes" to any vehicles affected by
the periodic restriction of access. Overall public interaction
was very good.
II. EFFECTIVENESS OF REMOVAL ACTIONS TAKEN BY OTHER PARTIES
Since the entire removal action was conducted by Region Six -
ERB, there are no second or third party actions to be evaluated.
While the responsible parties, as a whole, declined to
participate in the on-site activity, pre-removal negotiations
provided for an up-front "agreement" for payment of the entire
project costs. As noted in Section I-D of this report, cost
recovery negotiations are currently being handled by the
Department of Justice and Regional Counsel.
III. DIFFICULTIES ENCOUNTERED
With respect to intergovernmental coordination, no major
difficulties were encountered with either the NMEID or the
Village of Los Lunas, for the entire project
The only local difficulty arose when the transportation company,
contracted for disposal of the contaminated soils, parked empty
tractor-trailer rigs in the Village of Los Lunas. Local
authorities and citizens were concerned that hazardous wastes
were being "stored" in their city without authorization and
without concern for their personal safety. This issue was
quickly resolved to everyone's satisfaction.
Several site-specific items are worthy of notice since they had a
direct impact on the time and cost effectiveness of the overall
project. The following list is a brief description of these
i terns:
A. Site Accessibility and Confined Working Space:
One primary road (Edeal Rd) served the immediate residents and
commercial businesses along this road. As the road is
immediately adjacent to the site, whenever earthwork activities
(excavation & loading of trucks) created sufficient airborne
contamination to be a potential health threat to passing traffic,
the roadway traffic was temporarily restricted. While the
majority of the people affected were understanding, a few
citizens were not so patient and "crashed" the road blocks that
12
-------
were manned by uniformed guards. In only one instance did the
OSC consider enforcement action against a repeat offender. The
control of access to the entire site was overall successful.
Since the site was surrounded by physical barriers, it required
unique handling practices and constant rescheduling of events on-
site. Edeal Road to the East, a private residence (farm) to the
North, a primary water drain (manmade creek) to the immediate
West, and seasonal irrigation ditch to the immediate South,
created a very confined working space for a large crew of workers
and several pieces of earth-moving equipment. These physical
barriers, combined with the confirmed contamination over the
entire site, required relocation of on-site salvage materials
multiple times for the duration of the project as well as
requiring a very "flexible" workplan.
B. Default of Soils Laboratory:
As the primary objective of this project was to remove the source
of contamination from the site, confirmation of this effort would
be essential to meeting this objective. As a result, minimum
QA/QC criteria for were established by the EPA for this specific
project. Evaluation of reports from the initial analytical lab
indicated QA/QC inadequacies which could not be corrected to the
standards required by EPA. Therefore, new services were obtained
and the project proceeded as planned.
C. Changing Land Disposal Facilities:
Original arrangements for land disposal were at the Chemical
Waste Management (CWM) facility in Emelle, Alabama. However,
midway through the project, disposal of wastes from this site was
stopped by the State of Alabama due to recent changes in the
State's environmental regulations. The Alabama Department of
Environmental Management adopted an "incomplete" version of the
Federal Land Disposal Restrictions and land disposal of PCBs were
no longer allowed. When immediate resolution seemed unlikely,
the OSC opted to select an entirely new facility, in another
state. Similar arrangements were quickly made with the CWM
facility in Kettleman Hills, California.
D. Additional Contamination:
Original investigative sampling indicated that the extent of
contamination did not extend more than 10 inches below the
original surface of the site. This proved to be true for the
majority of the site, but grossly underestimated in others. In
an area previously identified as the "septic drain field",
contamination was confirmed in excess of the defined cleanup
level
13
-------
to depths of 6 feet below the surface. This additional
contamination significantly increased the time necessary to
complete the project and the associative costs for transportation
and disposal of the increased soil volume (excavation &
restoration).
IV. RECOMMENDATIONS
In order to best prevent this same event from recurring, the EPA
removed the source of this contamination from this site. The
only way that this specific event could recur, is if similar
"business practices" were followed by the salvage operator.
In an effort to prevent the recurrence of this specific event,
some form of assurance would be needed that the operator would no
longer accept containers that potentially contain PCBs. In
addition, if containers holding PCB fluids were accepted, assure
that the original "business practices" demonstrated by the
operator, are not duplicated.
Referencing Section I-C of this report, relative to the means by
which the material came to rest on this site, it is recommended
that Federal Agencies and associated Federal Contractors, who in
any way are responsible for the use, handling and eventual
disposal of any hazardous materials, be required to maintain
records defining specifically what these materials are and have a
pre-designated "plan" for their disposal. If these materials are
to be sold or auctioned, the potential owners must be made aware
of the liability associated to the receipt of these materials and
they must also be made aware of the potential environmental
damage that could be caused if these materials are not handled
properly.
There are no recommendations with respect to improvement of
response actions or changes to the National contingency plan,
Regional contingency plan or the OSC contingency plan.
14
-------
Attachment A1
-------
ATTACHMENT Al
FIGURE 1
% m 'M
.- / 23I '*"
%\ \ A' • *"/' li!
•feVX ."< sfe I II
«^\ ^ S* .••>'
.-:/•-
-------
Attachment B1
-------
5* HIGI
3:1
SLOPE
UNDERGROUND
DRAIN PIPE
at"
,._P >». . VC
WELL-1
WELL-2
WELL-3
WELL-4
WELL-5
4802.3
4802.1
4801.8
4801.7
4801.6
I
DATUM: 4800.00 ARBITRARY
(ESTIMATED FROM U.S.G.S.
7.5 MINUTE QUADRANGLE)
FARM
60
120
SCALE
r=6o"
UNDERGROUND-1
DRAIN PIPE
US EPA ENVIRONMENTAL RESPONSE TEAM
DKMEERM6 MO ANALYTICAL CONTRACT
08-09-3482
«
-------
Attachment B2
-------
PERALTA
fclVERSIDE
DRAIN
SMITH
ESIDENC
WITTWER LATERAL
WFU. ELEVATIONS
(TOP OF PVC CASINGS)
4802.3
4802.1
4801.8
4801.7
4801.6
ADQITOADV
WELL-1
WELL-2
WELL-3
WELL-4
WELL-5
PERALTA
RIVERSIDE
DRAIN
w
K>
-------
Attachment C1
-------
PAGANO SALVAGE YARD
Los Lunas, New Mexico
ATTACHMENT Cl
SAMPLING STRATEGY-GRID MAP
-------
Attachment D1
-------
ATTACHMENT Dl
PAGANO SALVAGE YARD
The sampling strategy utilized for PCS soil sampling involved
initial division of the site into 20x20 foot square "grids". A
composite soil sample was collected from each of the grids using
a 9-aliquot even distribution. All aliquots were combined and
homogenized to uniform particle size and a B-ounce sample was
submitted for analysis.
Sample analysis tested for aroclors 1254 and 1260 and separate
totals were calculated and recorded. These concentrations were
then combined to create a total which was compared to the
approved cleanup level of ten (10) parts per million. After the
initial phase of excavation, grids with totals significantly
higher than the cleanup level were further divided into 10x10
foot "quads". A sample of this design is illustrated below.
The tracking system was basically comprised of first, the SECTION
letter; second, the GRID number; and finally, the QUAD letter.
The quad letters were aligned as shown in the illustration below.
Excavation was completed when sample results for a grid were
below the cleanup level, quads within a grid were below a
cleanup level, or the average of quads within a grid was below
the cleanup level. All areas were defined as "clean" and
excavation "complete" at the OSC's discretion.
QUAD
—10'-
1
1
10'
1
I
A
D
GR]
B
C
[D
•
20
I
I
N
-------
Attachment E1
-------
Ctfl El
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
zr=zo-
BASE MAP
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
•ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 1
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
r=50f
z r=2o •
•ascending areas are seated to represent actual
excavation depth relative to the base map
PHASE 2
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
SCALE
X.V T'rSO*
ZT=2O"
•ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 3
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
X,Y fr
zr=20"
•ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 4
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
r=5Of
zr=20r
•ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 5
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
SCALE
X.Y r=5ff
zr=ar
'ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 6
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
SCALE
X.Yt'cSO1
Zr=20"
•ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 7
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
X.Y
zr=ar
•ascending areas are scaled to represent actual
excavation depth relative to the base map
PHASE 8
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
zr=2O~
•ascemfing areas are scaled to represent actual
excavation depth relative to the base map
PHASE 9
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
zr=»-
*ascencHng areas are scaled to represent actual
excavation depth relative to the base map
PHASE 10
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
zr=ao-
•ascencBng areas are scaled to represent actual
excavation depth relative to the base map
PHASE 11
-------
EXCAVATION AREAS RELATIVE TO PHASED ACTIVITY
SCALE
x.vr=5a
zr=ar
*ascendmg areas are scaled to represent actual
excavation depth relative to the base map
PHASE 12
-------
Attachment F1
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE
SA-01
SA-02
A
B
C
D
SA-03
SA-04
A
B
C
D
SA-05
SA-06
SA-07
A
B
C
D
SA-08
A
B
C
D
SA-09
A
B
C
D
SA-10
A
B
C
D
SA-11
A
B
C
D
SA-12
A
B
1.97
14.61
1.32
0.51
3.45
7.51
1.35
131.01
—
—
-
-
2.45*
1.7fl*
18.33
2.95
6.06
4.73
9.16
9.53
14,41
17.11
11.41
21.01
25.91
32.41
6.55
18.61
53.41
21.65
3.54
3.26
4.05
1.22
125.01
-
»
•
-
210.01
•
~
35.91
12.11 3.97
21.61 4.21
15.41 17.31
9.71 31.31
NO
1.01
22.21
4.15
24.71 35.01
15.01 26.42
3.29
5.61
0.37
NO
14.61 208.01
1.52 NO
8.24
13.81
11.51
7.91
1/9
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 6
SA-13
A
B
SA-14
A
B
C
D
SA-15
SA-16
A
B
C
D
SA-17
A
B
C
D
SA-18
SA-19
SA-20
A
B
C
D
SA-21
A
B
C
D
SA-22
A
B
C
D
SA-23
A
B
C
D
SA-24
SA-25
A
'B
42.07
3.79
41.11
35.21
-
-
-
-
5.82
11.93
13.31
117.01
24.81
128.01
9.33
7.63
24.71
32.61
12.21
4.47
4.31
11.63
7.18
4.61
5.19
9.58
31.35
29.71
7.48
16.81
26.91
162.01
67.61
138.01
55.71
62.71
131.01
73.01
55.61
63.41
45.81
4.15
13.11
2.11
0.47
14.81
0.81
ND
84.91
19.31
1.91
4.53
26.41
48.31
ND
ND
ND
ND
1.41
35.11
9.02
15.01
30.21
67.41
136.01
58.11
65.41
83.41
59.91
69.71
53.41
ND
16.71
16.71
35.61
52.01
10.91
83.71
85.01
23.01
31.91
6.68
27.81
62.21
77.91
60.11
6.09
3.21
0.38
26.61 93.51
20.61
35.41
ND
ND
ND
ND
0.23
0.23
0.23
17.51 ND
17.51 9.52
1.08
2/9
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 5
SA-26 31.41
A
B
C
D
SA-27
A
B - 107.01 49.21 ND
C
D
SA-28
A - 11.11 39.41 2.08
B
C
D - 16.11 39.41 16.41
SA-29
A
B
C
D
SA-30
SA-31
SA-32
A
B
C
D
SA-33
SA-34
SA-35
A
B
C
D
SA-36
SA-37
SA-3B
SA-39
SA-40
SA-41
SA-42
SA-43
SA-44
SA-45
-
—
-
—
59.29
-
-
-
-
20.93
—
•
-
-
10.85
11.71
3.77
13.91
16.21
2.51
7.56
10.97
2.36
7.34
26.31
4.55
3.22
0.26
29.81
10.01 f
1.01
0.17
3.51
0.27
0.62
3.21
0.82
1.09
5.71
39.62
5.09
0.45
1.97
7.44
20.66
0.66
1.35
0.61
107.01
0.43
9.35
11.11
0.21
104.01
16.11
0.88
14.91 *
2.74
1.08
1.91
0.71
49.21
49.21
39.41
63.21
39.41
3/9
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 6
SA-46 8.94
A 22.11;
B 0.66*
C 0.37
0 ND
SA-47 1.39
SA-48 1.32
SB-01 0.64
53-02 0.99
SB-03 2.42
SB-04 21.74
A 51.01 6.43
B 1.35
C 44.01 5.78
D 27.21 9.01
SB-OS 7.39
SB-06 ND
SC-01 5.06
SC-02 3.65
SD-01 6.19
SD-02 33.39 1.77 *
A 8.55
B 28.45
C 34.28
D 12.86
SE-01 6.56
SE-02 1.01
SE-03 0.61
SE-Oo 0.94
SE-05 6.22
SE-06 0.67
SE-07 1.43
SE-Oa 3.44
SE-09 1.83
SE-10 11.66
A 1.96 1.68
B 4.22
C 8.81 1.28
SE-11 1.74
4/9
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 6
SE-12 9.41
A 5.61
B 11.41 NO
C 2.21
D 1.27
SE-13 0.94
SE-14 0.68
SE-15 0.38
SE-16 0.25
SE-17 4.73
SE-18 0.75*
SE-19 1.63
SE-20 4.79
SF-01 3.48*
SF-02 0.46*
SF-03 0.91*
SF-04 1.21*
SF-05 0.41
SF-06 3.79
SF-07 7.91
SF-08 0.78
SF-09 0.39
SF-10 5.18
SF-11 1.71 1.35
SF-12 10.61*
A 6.49
B 5.55
C 5.69
SF-13 2.66
SF-14 3.76
SF-15 2.11 *
SF-16 0.31 0.23
SF-17 0.54
SF-18 0.31
SF-19 1.39 0.91
SF-20 1.51
SF-21 4.77
SF-22 21.21
A 6.92
B 8.41
C 6.41
D 1.96
SF-23 ND
5/9
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 6
SG-01 0.83
SG-02 8.91
A - 5.65
B - 5.04
C - 5.67
D - 5.07
S6-03
S6-04
A
B
C
D
SG-05
S6-06
SG-07
SG-08
SG-09
A
B
C
D
SG-10
A
B
C
D
SG-11
A
B
C
D
SG-12
SG-13
SG-14
A - - - 8.51#
B ND
C ND
D ... - 4.76
56-15 3.52*
SG-16 2.15*
A 35.81 0.33
B 2.48
C 1.27
D 1.31
SG-17 6.61
SG-18 4.61
6/9
6.33
12.66
0.64
11.8
18.1
7.44
2.01
0.57
1.92
6.35
10.55
25.01
21.21
12.41
31.91
8.61
11.21
9.95
0.72
11.71
11.45
7.45
15.01
16.41
10.21
32.16
24.41
34.71*
0.91
0.91
0.91
0.91
14.31*
2.08
ND
ND
5.37
5.37
5.37
26.11
26.11
26.11
:;.3l
9.78#
34.81
5.24
5.24
5.24
17.88
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 6
SG-19 36.01 31.51
A - 38.61 4.06
B HD
5G-20 28.41 1.33
SH-01
SH-02
A
B
C
D
SH-03
SH-04
A
B
C
D
SH-05
A
B
C
D
SH-06
SH-07
A
B
C 9.83 38.01 35.31 5.88
D
SH-08
A
B
C
D
SH-09
A
B
C
0
SH-10
A
B
C
D
SH-11
SH-12
SH-13
7/9
13.91
20.11
70.61
2.76
9.13
59.11
0.64
17.81
20.51
8.51
1.86
2.52
12.61
36.51
19.71
3.66
23.41
3.41
21.81
1.28
32.14
9.83
0.89
10.01
66.01
17.21
6.21
43.91
14.41
38.71
13.31
4.28
19.71
2.96*
1.17
O.B3
4.47
3.91
2.64
1.89
0.53
0.89
7.67
7.67
7.67
1.57
1.57
1.57
1.57
0.66
12.21
3.74
38.01
8.56 #
1.83
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 PHASE 6
SI-01
SI-02
SI-03
SI-04
SI-05
SI-06
SI-07
SI-08
SI-09
SI-10
SI-11
SI-12
SI-13
SI-14
SI-15
SI-16
SJ-01
SJ-02
SJ-03
SJ-04
SJ-05
SJ-06
A
B
C
D
SJ-07
SJ-08
SJ-09
SJ-10
SK-01
SK-02
SK-03
YARD-EAST
B
C
YARD-WEST
A
D
7.28
4.69*
1.31*
0.55
1.11
3.98
2.28
0.58
1.15
3.76
4.08
0.38
ND
ND
7.26
3.54
ND
ND
ND
ND
ND
10.91
21.61
13.21
38.91
11.31
4.01
0.83
ND
ND
9.01*
3.51
0.41
34.37
75.03
0.29
16.59
20.85
59.41
1.93
0.86
282.01
2.01
11.21 #
8/9
-------
ATTACHMENT Fl
SOIL DATA SUMMARY
GRID #
SA-04D
SA-09C
SA-09D
SA-10A
SA-10B
SA-12A
SA-14D
SA-15A
SA-15B
SA-16C
SA-16D
SA-21C
SA-21D
SA-22A
SA-22B
SA-22C
SA-22D
SA-23B
SA-27B
SA-27D
SA-28C
SA-28D
PHASE 7 PHASE 8 PHASE 9 PHASE 10 PHASE 11 PHASE 12 ]
12.63 1.88
3.65
0.71
3.22
15.21
26.45
15.23
45.99
34.14
0.25
0.7
3.83
88.5
37.83
3.79
1.11
0.36
0.12
0.71
8.52
0.71
5.11
7.35
3.76
36.1 6.01
5.87
23.3 48.7 ND
0.24
68.6 2.72
22 16.3 36.3 13.7 10. 2#
20.2 46.4 67.1 13 21.7
0.48
8.27
15 . 5 ND
111
* - When Duplicate sample analysis was performed, the higher of
the two numbers was recorded.
# - Composited with surrounding 10x10' grids, the mean value of a
10x10* grid will be 10 ppm over a surrounding 20x20' area.
9/9
-------
Attachment G1
-------
Attachment G1
PAGANO SALVAGE YARD
Confirmation Sample Summaries -
AIR: Off-site
ANALYSIS: PCBS
DATE COLLECTED: As Shown
STATION
PS-01
PS-02
PS-03
PS-04
PS-05
7/19/89
N/A
162
135
55
41
7/21/89
N/A
116
338
526
326
7/28/89
85
33
117
143
182
8/30/89
63
226
53
69
N/A
8/05/89
120
87
128
42
46
8/08/89
193
8
201
107
17
8/15/89
56
47
53
N/A
24
1/26/90
2
3
2
2
4
* results are rounded and shown in ng/M3
* locations are shown on Attachment G2
-------
Attachment G2
-------
DRAIN
5' HIGH
3:1
SLOPE
UNDERGROUND J
DRAIN PIPE
'UNDERGROUND
DRAIN PIPE
ATTACHMENT G2
SCALE
M-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE- 7/19/89
PAGAN0 SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
UhAlN
51 HIGH
3:1
SLOPE
'UNDERGROUND
DRAIN PIPE
UNDERGROUND -1
DRAIN PIPE
HI-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE 7/21/89
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
UNDERGROUND
DRAIN PIPE
^ ^- UNDERGROUNDJ
DRAIN PIPE
HI-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE 7/28/89
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
120
UNDERGROUND
DRAIN PIPR
UNDERGROUND -
DRAIN PIPE
HI-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE 8/03/59
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
HM/OLUME SAMPLING EQUIPMENT
LOCATION MAP DATE 8/05/89
UNDERGROUND
DRAIN PIPE
PAGAN 0 SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
UNDERGROUND
DRAIN PIPE
UNDERGROUND
DRAIN PIPE
t20
HI-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE- s/os/sg
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
DRAIN
UNDERGROUND
DRAIN PIPE
UNDERGROUND
DRAIN PIPE
SCALE
HI-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE 8/15/89
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
DF,™,
UNDERGROUND
DRAIN PIPE
UNDERGROUND -1
DRAIN PIPE
HI-VOLUME SAMPLING EQUIPMENT
LOCATION MAP DATE 1/26/90
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
-------
Attachment H1
-------
Attachment H1
PAGANO SALVAGE YARD
Confirmation Sample Summaries -
SOILS: On-site
ANALYSIS: Total Lead (Pb)/utilizing XRF
DATE COLLECTED: 8/10/90
SAMPLE
NUMBER
A-3
A- 30
A- 34
A-41
A-79
A-85
A-99
A- 125
A- 148
A- 163
B-16
B-17
RELATIVE
GRID
A-41
A-36
A-32
A-30
A-24
A-21
A-14
A-09
A-02
A-18
B-02
B-02
READING
93
13
163
70
3
77
1090
106
13
70
93
93
SAMPLE
NUMBER
C-02
H-13
H-23
H-26
1-03
1-06
1-15
J-03
J-05
J-10
J-13
RELATIVE
GRID
C-02
H-10
H-02
H-08
1-14
1-12
1-15
J-03
J-01
J-06
J-10
READING
33
37
0
13
13
13
27
0
33
77
40
* results shown in mg/kg or PPM
* locations are relative to Grid Map (Attachment C1)
and also shown on Attachment H2
-------
Attachment H2
-------
ATTACHMENT H2
PAGANO SALVAGE YARD
t
N
H-04 I WO W9 1-13/1-07
X-RAY FLUORESCENCE MODEL READINGS FOR LEAD 8/10/89
-------
Attachment 11
-------
Attachment 11
PAGANO SALVAGE YARD
Confirmation Sample Summaries -
SOILS: On-site
ANALYSIS: HSL Total Metals - Hazardous Substances List
DATE COLLECTED: 1/10/90
ELEMENT
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Si Tver
A-14D
2.20
102.00
0.20
9.40
4.40
0.10
1 .00
0.40
SAMPLE
A-16D
3.30
84.30
0.20
7.90
4.50
0.10
1 .00
0.40
LOCATION
A-22C
3.30
143.00 1
0.20
10.90
4.90
0.10
1.00
0.40
H-08D
9.20
80.00
0.20
12.60
7.40
0.25
1 .00
0.40
G-14A
2.30
125.00
0.20
9.80
5.20
0.10
1.00
0.40
* results shown in ug/1 or PPB
locations are relative to Grid Map (Attachment C1)
and also on Attachment 12
-------
Attachment 12
-------
ATTACHMENT 12
PAGANO SALVAGE YARD
HAZARDOUS SUBSTANCE LIST.TOTAL METALS ANALYSIS 1-10-90
-------
Attachment J1
-------
Attachment J1
PAGANO SALVAGE YARD
Confirmation Sample Summaries -
SOIL & SEDIMENTS: Off-site
ANALYSIS: PCBs
DATE COLLECTED: 1/25/90
Station
Location
west of sect. H
west of sect. A
1/4 mi le north
of sect. A
Sediment west
of sect. A-43
Sediment west
of sect. A-43
(duplicate)
Sediment 1/4
mile south of site
PCB Aroclors
1254 1260
1.90
0.38
0.32
0.37
0.40
0.39
0.69
10.00
0.32
0.3?
0.40
0.39
Total
Aroclors
2.59
10.38
0.64
0.74
0.80
0.78
* results shown in PPM
* locations are shown on Attachment J2
-------
Attachment J2
-------
SEDIMENT
MILE NORTH OF SITE
SEDIMENT
1/4 MILE SOUTH OF SITE
ATTACHMENT J2
120
SCALE
OFF-SITE
SOILS AND SEDIMENT SAMPLING FOR PCBs
PAGANO SALVAGE SITE
LOS LUNAS, NEW MEXICO
------- |