SIXTH FIVE-YEAR REVIEW REPORT FOR
AT&SF (CLOVIS) SUPERFUND SITE
CURRY COUNTY, NEW MEXICO



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SIXTH FIVE-YEAR REVIEW REPORT

ATSF (Clovis) SUPERFUND SITE
CURRY COUNTY, NEW MEXICO
EPA ID#: NMD043158591

This memorandum documents the U.S. Environmental Protection Agency's performance, determinations,
and approval of the AT&SF Superfund Site (Site) sixth five-year review under Section 121(c) of the
Comprehensive Environmental Response. Compensation, and Liability Act, 42 U.S. Code Section
9621(c), as provided in the attached Sixth Five-Year Review Report.

Summary of the Sixth Five-Year Review Report

The Sixth Five-Year Review of the AT&SF (Clovis) Superfund site located in Clovis. New Mexico was
completed from July 2022 through March 2023. Documentation from this Five-Year Review confirms the
remedy at the Site as set forth in the 1988 Record of Decision (ROD) has been implemented and is
protective of human health and the environment. No applicable or relevant and appropriate requirements
( ARARs) for groundwater were established for this Site. Groundwater monitoring is conducted every five
years and Onsite Storage Facility (OSF) inspections are conducted annually. There is no new evidence
that calls into question the protectiveness of the remedy.

One groundwater monitoring event occurred during this Five-Year Review period on October 27. 2022.
TPH-DRO (Total Petroleum Hydrocarbons - Diesel Range Organics) was detected in monitor wells
ranging in concentrations from 0.0240 (J) mg/L to 0.0495 (J) mg/L in three site monitor wells. There is no
Federal or State standard for TPH and the October 2022 concentrations are significantly lower than those
detected during the previous Five-Year Review period (0.9944 mg/L to 1.16 mg/L).

Environmental Indicators

Human Exposure Status: Current human exposure is controlled, and a protective remedy is in place.
Contaminated Groundwater Status: The contaminant groundw ater migration is under control.

Site-Wide Ready for Reuse: A Site-wide Ready for Anticipated Use (SWRAU) determination was made
on September 11. 2007. All remediation goals set forth in the ROD have been achieved for all media that
may affect current and reasonably anticipated future uses of the Site so that there are no unacceptable
risks. All necessary institutional controls specified in the ROD are in place and effective at protecting the
remedy.

The protectiveness of the remedy is anticipated to not be affected by climate change. See Section V,
Question C for additional information.

Potential for environmental justice concern per national and/or state averages based on EPA's
Environmental Justice Screening and Mapping Tool (EJScreen) does exist. The EJScreen Site report
indicates that the population within one mile of the Site meets or exceeds the 80th percentile when
compared to state. EPA region, or national averages for the follow ing environmental indicators:
particulate matter 2.5, ozone, traffic proximity, lead paint, risk management plan (RMP) facility
proximity, underground storage tanks, demographic index, people of color, low income, unemployment
rate, linguistically isolated, and less than high school education. The EJScreen reports are included in
Appendix B.


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Actions Needed

There are no actions needed for the remedy to be protective.

Determination

I have determined that the remedy for the AT&FS (Clovis) Superfund Site is protective of human health
and the environment. All remedial action objectives have been met for the Site. The former lake area is
isolated from surface water run-on. lake water has evaporated, lake-bottom sediments and soils from
beneath the lake-bottom sediments and beach area have been treated, all treated sediments are contained
in the OSF. the OSF has been capped, and the Site has been restored.

, ¦ * n r> ¦ *— Digitally signed by LISA PRICE

LISA PRICE Date: 2023.06.15 15:12:44

-05'00'

Lisa Price

Acting Director. Superfund and Emergency Management Division
U.S. Environmental Protection Agency Region 6


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ISSUES/RECOMMENDATIONS

SIXTH FIVE-YEAR REVIEW REPORT
AT&SF (CLOVIS) SUPERFUND SITE
CURRY COUNTY, NEW MEXICO
EPA ID#: NMD043158591

Issucs/Rccommcnd ill ions

OU(s) with Issues/Recommendations Identified in the Five-Year Review:
No Issues/Recommendations


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Table of Contents

LIST OF ABBREVIATIONS & ACRONYMS	2

I.	INTRODUCTION	3

FIVE-YEAR REVIEW SUMMARY FORM	4

II.	RESPONSE ACTION SUMMARY	4

Basis for Taking Action	4

Response Actions	5

Status of Implementation	6

Systems Operations/Operation & Maintenance	6

III.	PROGRESS SINCE THE 2018 REVIEW	7

IV.	FIVE-YEAR REVIEW PROCESS	7

Community Notification, Involvement & Site Interviews	7

Data Review	8

Site Inspection	8

V.	TECHNICAL ASSESSMENT	9

QUESTION A: Is the remedy functioning as intended by the decision documents9	9

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action

objectives (RAOs) used at the time of the remedy selection still valid9	10

QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy9	10

VI.	ISSUES/RECOMMENDATIONS	 1 1

OTHER FINDINGS	 1 1

VII.	PROTECTIVNESS STATEMENT	 1 1

VIII.	NEXT REVIEW	 1 1

APPENDIX A - REFERENCE LIST

APPENDIX B - EJSCREEN REPORT

APPENDIX C - DATA TABLES

APPENDIX D - FIGURES

APPENDIX E - SITE CHRONOLOGY

APPENDIX F - INTERVIEW FORMS

APPENDIX G - SITE INSPECTION CHECKLIST AND PHOTOS


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LIST OF ABBREVIATIONS & ACRONYMS

AOC

Administrative Order on Consent

ARAR

Applicable or Relevant and Appropriate Requirement

AT&SF

Atchison. Topeka and Santa Fe Railroad (became BNSF in 1996)

BNSF

Burlington, Northern and Santa Fe Railway Company

CERCLA

Comprehensive Environmental Response. Compensation, and Liability Act

CFR

Code of Federal Regulations

EPA

United States Environmental Protection Agency

FS

Feasibility Study

FYR

Five-Year Review

ICs

Institutional Controls

LNAPL

Light Non-Aqueous Phase Liquid

MCL

Maximum Contaminant Level

mg/L

milligrams per Liter

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NMED

New Mexico Environment Department

NMWQCC

New Mexico Water Quality Control Commission

NPL

National Priorities List

O&M

Operation and Maintenance

OSF

On-Site Storage Facility

PAH

Polycyclic Aromatic Hydrocarbons

PRP

Potentially Responsible Party

RAO

Remedial Action Objectives

ROD

Record of Decision

RPM

Remedial Project Manager

TBC

To be considered

TPH-DRO

Total Petroleum Hydrocabons-Diesel Range Organics


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I. INTRODUCTION

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings, and conclusions of reviews are documented in five-year review reports such as this one. In addition.
FY R reports identify issues found during the review, if any. and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this five-year review pursuant to the
Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA) Section 121, consistent
with the National Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)) and considering EPA policy.

This is the Sixth FYR for the AT&SF (Clovis) Superfund Site. The triggering action for this statutory review is
the completion date of the Fifth FYR. The FYR has been prepared since hazardous substances, pollutants, or
contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The response action at the Site included the placement of treated sediments and soils in an onsite storage facility

(OSF).

The AT&SF (Clovis) Superfund Site Five-Year Review was led by Mr. Brian Mueller, U.S. EPA Region 6
Remedial Project Manager (RPM) and Mr. Anthony McGlow n. New Mexico Environment Department (NMED)
Superfund Oversight Section (SOS) Project Manager. Participants included a representative from Burlington
Northern and Santa Fe (BNSF) Railway Company, a representative from BNSF's environmental contractor, and
NMED SOS Project Managers Ms. Martyne kieling and Ms. Gail Cooke. The review began on 7/1/2022.

Site Background

The Atchison. Topeka. and Santa Fe (AT&SF) Clovis Superfund Site (Site) is a natural playa lake located in
eastern New Mexico and is know n locally as Santa Fe Lake (the lake). The Site is located within a semi-rural
setting on the outskirts of the town of Clovis. in Curry County. See Appendix D. Figure 1 for Site location. The
lake received hopper car washing rinsate and other discharges from the AT&SF rail yard from the early 1900s
until 1990. The contaminants of concern (COCs) were primarily hydrocarbons, chromium, lead, and other heavy
metals.

Contamination at the Site is considered to be from contaminants discharged from the AT&SF (Clovis) Rail Yard.
Since the early 1900s, the AT&SF (Clovis) Site received storm water run-off and wastewater discharged from the
rail yard. The specific sources of wastewater have changed over time as the needs of the railway company
changed. Activities at the rail yard contributing to the discharge have included hopper car washing operations,
boiler blow dow ns, sanitary sewers, and the oil/water separators at the diesel fueling racks. The amount of
wastewater discharged is unknow n and has fluctuated over time.

The playa lake itself occupies approximately 45 acres in the west central portion of the property. The perimeter of
the playa lake is bordered by a berm that was constructed during remedial action in 1990 and prevents additional
surface water run-on to the playa basin. The capped OSF. containing treated soils and sediments from the
remedial action, occupies nearly six acres at the northeast corner of the Site property.


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FIVE-YEAR REVIEW SUMMARY FORM

Site Name: AT&SF (Clovis)

EPA ID:

NMD043158591

Region: 6

State: NM

City/County: Clo\ is/Curry County

NPL Status: Deleted

Multiple OUs?
No

Has the site achieved construction completion?

Yes

Lead agency: EPA

[If "Other Federal Agency", enter Agency name]:

Author name (Federal or State Project Manager): Brian Mueller, RPM

Author affiliation: U.S. EPA Region 6

Review period: 7/1/2022 - 3/28/2023

Date of site inspection: 11/3/2022

Type of rev iew: Statutory

Review number: 6

Triggering action date: 7/24/2018

Due date (five years after triggering action date): 7/24/2023

II. RESPONSE ACTION SUMMARY

Basis for Taking Action

According to the Record of Decision (ROD) for the Site, although no groundwater contamination was identified,
the potential threat to groundwater was the primary concern. Contaminated lake water, soils, and sediments
represented sources of contamination that required remediation to preclude contamination from potentially
migrating to groundwater. In addition, the Feasibility Study risk assessment assumed that the lakebed would
eventually dry completely due to natural evaporation since discharges to the playa were discontinued in 1990.
Therefore, exposures to dust in ambient air from sediments and soils from the dry playa bed were determined to
pose significant human health risk due to exceedance of EPA's risk management criteria for either the average or
the reasonable maximum exposure scenarios. The carcinogenic risks were highest for exposures to airborne dust
from chromium contaminated sediments. Non-carcinogenic risks were highest for exposure to dust from sediment
and soil contaminated with hydrocarbons. Exposure pathways were incomplete for groundwater and lake water.

Table 1 identifies the parameters of concern. Although no AR ARs were established for the groundw ater at the
Site, the ROD states that the selected remedy will meet all primary State and Federal standards for drinking water.
Table 2 lists the Federal and State standards for drinking water.


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Table 1 - Parameters of Concern

Groundwater

Lake Water

Sediment

Soil

Chloride

Arsenic

Boron

Barium

Fluoride

Boron

Chromium

Boron

Magnesium

Cadmium

Hydrocarbons

Chloride

Sodium

Chloride

Lead

Hydrocarbons

Sulfate

Chromium

Phenolics

Phenolics

Total Dissolved Solids

Fluoride

Total Organic Carbon

Sulfate

Lead

Phenolics

Sulfate

Total Dissolved Solids

Total Organic Carbon

Table 2 - State and Federal Standard for Drinking Water

Analyte

Standard

(mg/L)

MCL

NMWQCC*

Arsenic

0.010

0.010

Barium

2

2

Cadmium

0.005

0.005

Chromium

0.1

0.05

Lead

0.015

0.015

Chloride

25 0A

250AA

Total
Phenolics



0.005AA

ANationaI Secondary Drinking Water Regulations

AANM Water Quality Control Commission (WQCC) Other Standards for Domestic Water Supply
* Amended NMWQCC groundwater standards took effect on December 21, 2018, and generally match EPA MCLs.

Response Actions

The September 23, 1988, ROD did not specifically state Remedial Action Objectives (RAOs); however, the
Feasibility Study describes primary and secondary objectives. The primary objective in the Feasibility
Study was to eliminate the human exposure pathway from inhalation of wind-blown sediments from the playa bed
assuming future evaporation of lake water. The secondary objectives for the selected remedies for the lake water,
sediment, and soil were intended to mitigate the potential future migration of contamination to groundwater. The
remedy for the AT&SF (Clovis) Superfund Site included remediation of three environmental media: lake water,
lake sediments, and soil. The remedy included the following actions:

•	Evaporation of lake water and construction of a dike around the lake to prevent run-on;

•	Treatment of contaminated soils and sediments to reduce total petroleum hydrocarbons (TPH)
concentrations to below 1,000 parts per million (ppm) or achieve soil stabilization; and

•	All treated sediments and soils with a TPH concentration greater than 1,000 ppm were excavated and
placed in the OSF.

The ROD specified that groundwater monitoring will continue semi-annually during remediation and annually
after remediation for the contaminants of concern for groundw ater.


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On March 17. 2003, a Restrictive Covenant was placed on the property to restrict access and prevent disturbance
to the OSF. Access to the property is restricted by a chain link fence and locked gate. The ROD did not
specifically require Institutional Controls (IC) but required a fenced area for the on-site storage facility. Fencing is
in place and BNSF has been maintaining the fence.

Status of Implementation

In the Administrative Order on Consent (AOC) signed with EPA on September 1, 1983, AT&SF agreed to
investigate the Site and pay costs for cleaning up the Site. The Remedial Design was conducted in conformance
with the ROD.

The Remedial Action took place in three phases. The first phase entailed the construction of a rainfall run-
on/runoff control system and a lake water evaporation system. The activities associated with this phase began in
November 1989 with the construction of the run-on/runoff control dike and were finished in March 1992 with the
completion of the irrigation system and spray evaporation system. The second phase entailed the bioremediation
of soil and sediments for organic contamination and included: 1) the evaporation of lake water; 2) dewatering and
excavation and ex-situ treatment of contaminated lake bottom sediments; 3) in-situ and ex-situ treatment of
contaminated soils from beneath the lake bottom sediments and from the beach area; 4) containment of all treated
sediments in the OSF; and 5) containment in the OSF of any treated soils not meeting the clean-up criteria. A total
of 57,245 cubic yards of treated sediment and 38,720 cubic yards of treated soil are stored in the OSF which
covers approximately six acres in the northeast part of the Site. The activities associated with this phase began in
June 1992 and were completed in October 1999. The third phase entailed restoration of the Site and included
capping of the OSF and establishment of native vegetation. The activities associated with this phase began in June
2000 and were completed in September 2000.

The Site achieved construction completion status when the Preliminary Close-Out Report was signed on
September 20, 2000. The Final Close-Out Report was signed on November 8, 2002, by the EPA Region 6
Superfund Division Director. The Site was deleted from the Nation Priorities List (NPL) on March 17. 2003.

Systems Operations/Operation & Maintenance

BNSF is conducting long-term monitoring and maintenance activities according to the post-closure operations and
maintenance (O&M) plan that was revised in May 2019 and again in March 2023. The 2019 revision to the O&M
plan documents the modification of the groundwater monitoring schedule from annual to every five years. The
2023 revision to the O&M plan slightly modifies the sampling and reporting schedule and changes the sampling
method to low -flow sampling. The primary O&M activities have been groundwater monitoring, inspections, and
maintenance of the OSF and lake basin. The primary activities associated with O&M include the following:

•	Visual inspection of the OSF cap with regard to vegetative cover, settlement, stability, and any need for
corrective action;

•	Inspection of the condition of groundwater monitoring wells; and

•	Groundwater monitoring of six monitoring wells every five years.

In May 2014, BNSF requested a groundwater sampling modification to the groundwater monitoring program to
update analytical methods. In January 2015, the EPA approved the modification to the annual groundwater
monitoring program. The modifications included approved test methods for the analysis of arsenic, chloride, total
phenols, individual phenols, and diesel range organics (DRO). Barium, cadmium, chromium, and lead were
eliminated from the groundwater monitoring program. Analytical methods performed in 2022 are shown in Table
3. Results from samples collected during the five-year review period are discussed in the Data Review section of
this document.

No issues related to the condition of the OSF cap. Site fencing, signage, or other surface infrastructure were
identified during this FYR period.


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Table 3 - Analytical Methods

Analyte

Method

Arsenic

SW846-6020

Chloride

EPA 300.0

TPH-DRO

EPA 8015

Total Phenolics

SW846-9066

Phenol ics

EPA 8270

III. PROGRESS SINCE THE 2018 REVIEW

This section includes the protectiveness determinations and statements from the 2018 five-year review, as well as
the recommendations from the 2018 five-year review and the status of those recommendations.

Table 4: Protectiveness Determinations/Statements from the 2018 FYR

OU#

Protectiveness
Determination

Protectiveness Statement

NA

Protective

The remedy at the AT&SF (Clovis) site is protective of
human health and the environment.

All remedial action objectives have been met for the
Site. The former lake area is isolated from surface water
run-on. lake water has evaporated, lake-bottom
sediments and soils from beneath the lake-bottom
sediments and beach area have been treated, all treated
sediments are contained in the OSF. the OSF has been
capped, and the site has been restored.

There were no issues or recommendations noted during the 2018 FYR.

IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews

A public notice was posted on August 21. 2022, in the Eastern New Mexico News stating that EPA was
conducting the Sixth FYR of the remedy, with the results of the review to be presented in a FYR report. The
public notice also invited the public to submit any comments to the EPA and stated the report would be made
available at the following Site information repository:

Go vis-Carver Public Library
701 North Main Street
Gov is. New Mexico 88101
librarvfg),cityofclovis.org

During the FYR process, interviews were conducted to document any perceived problems or successes to
date with the remedy that has been implemented. Interview records are included in Appendix F. The
results of these interviews are summarized below.

Curry County Manager Lance Pyle was emailed an interview questionnaire. Mr. Pyle recalled receiving
complaints about the fence at the site being dow n or people accessing the site. Those complaints were referred to
the Curry County Fire and Safety Director. Mr. Pyle recommended that routine annual reports be provided to the
Curry County Commission and the Clovis City Commission to keep the public informed about site activities.


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A Curry County District Commissioner was emailed an interview questionnaire. The Commissioner mentioned
complaints about the security of the site related to the fencing and gates. The Commissioner recommended more
frequent reporting on site activities and would like to see a greater maintenance presence at the site.

Mr. Kyle Desantis, Environmental Scientist for A read is U.S.. Inc. (contractor for BNSF). was emailed an
interview questionnaire. Mr. DeSantis stated that site is inspected monthly by BNSF contractor Hulcher Services
for fence damage and tumbleweed buildup and that BNSF police patrol around the site. Arcadis personnel also
conduct semi-annual inspections, during which the condition of the fence. OSF cap and general observations are
noted to identify any issues. Mr. DeSantis stated that the OSF cap vegetation is well established and no significant
issues have been observed during site walks. Mr. DeSantis discussed the change from three well volume sampling
to low flow sampling, due to declining water levels in monitoring wells. Mr. DeSantis also noted specific O&M
activities conducted during the FYR period, including minor slope maintenance, west side fence repairs due to
damage from vehicles from the nearby public road, and periodic mowing to control tumbleweed building and fire
hazard.

Mr. Thomas Jones. Environmental Remediation Manager for BNSF. was emailed an interview questionnaire. Mr.
Jones's responses were generally consistent with those provided by Mr. DeSantis.

Data Review

The current groundwater monitoring program involves sampling all six (6) on-site monitor wells. All six on-site
monitoring wells were sampled on October 27. 2022. Analytical methods and analytes conducted for the 2022
groundwater sampling are listed in Table 3.

Arsenic was detected in all wells, with concentrations ranging from 0.0011 (J) mg/L to 0.0252 mg/L. The detected
concentration of 0.0252 mg/L in monitoring well MW-D exceeded the Federal and State standard for arsenic of
0.01 mg/L; however, this concentration appears to be anomalous as it is inconsistent with previous arsenic
concentrations detected in MW-D and the other monitoring wells at the site.

Chloride concentrations ranged from 52.8 mg/L to 476 mg/L. The detected concentration of 476 mg/L in MW-C
exceeded the secondary Federal standard and the NMWQCC "other standard for domestic water supply", which
are both 250 mg/L. Chloride concentrations have sporadically exhibited levels above Federal and State standards
at the Site. As noted in previous five-year reviews at this Site, pi ay a lakes are known to have elevated chloride
concentrations.

A total phenolics concentration of 0.0180 (J) mg/L was detected in MW-F, with no other detections above the
reported detection limit (0.00830 mg/L). The detection limit and the single detection in MW-F exceed the
NMWQCC "other standard for domestic water supply" of 0.005 mg/L. There is no Federal standard for total
phenolics. Individual phenol compounds were only detected in one well, MW-B, at concentrations that are
multiple orders of magnitude below screening levels.

TPH-DRO concentrations ranged from non-detect (with a reported detection limit of 0.0222 mg/L) to 0.0495 (J)
mg/L. The highest concentrations were detected in downgradient monitoring well MW-C at 0.0495 (J) mg/L and
in upgradient monitoring well MW-G at a similar concentration of 0.0481 (J) mg/L. There is no Federal or State
standard for TPH. The October 2022 concentrations are significantly lower than those detected during the
previous Five-Year Review period (0.9944 mg/L to 1.16 mg/L).

Site Inspection

The inspection of the Site was conducted on 11/3/2022. In attendance were Mr. Brian Mueller. EPA Region 6
RPM, Ms. Martyne kieling of the New Mexico Environment Department. Mr. Thomas Jones with BNSF and Mr.
Kyle DeSantis with ARCADIS. The purpose of the inspection was to assess the protectiveness of the remedy.


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Fencing and signage were observed to be in good repair at the time of the inspection. The site is routinely checked
by remediation contractor Hulcher Services. Vegetative cover was observed to be well developed over the entire
surface and slopes of the OSF. The OSF was observed to be in good condition with no issues identified during
this inspection.

The Site was observed to be clear of excess tumbleweeds or other vegetation identified as a potential fire hazard
in the previous FYR.

The Site monitoring wells were observed to be in good condition and were properly locked/secured at the time of
the inspection. Water levels have continued to drop each year, leaving minimal well volume for sample recovery
using the previous three well volume purge method. Low -flow methods were used to collect groundwater samples
beginning in 2022, following EPA approval.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents'.'

Question A Summary:

Review of sampling reports and results of the Site inspection indicate that the remedy is functioning as set forth in
the 1988 ROD. The remedy at the Site included the remediation of three environmental media: lake water, lake
sediments, and soil. Remediation at the Site included the follow ing:

•	Evaporation of lake water and construction of a dike around it to prevent run-on;

•	Treatment of contaminated soils and sediments to reduce TPH concentrations to below 1,000 ppm or
achieve soil stabilization; and

•	All treated sediments and soil with TPH concentrations greater than 1000 ppm were excavated and placed
in the OSF.

Remedial Action Performance

The remedial actions prepared at the Site are functioning as designed. The Site was deleted from the NPL on
March 17. 2003. The lake is dew ate red. and the ring dike prevents run-on to the lake. The contaminated material
is deposited in an on-site containment cell and the cap is intact and preventing exposure. Vegetation on the OSF is
established and prevents erosion from occurring. Groundwater monitoring data from this FYR period continue to
indicate that the groundwater exposure pathway is incomplete.

System Operations/O&M

The Site is inspected monthly by BNSF contractor Hulcher Services for fence damage and tumbleweed buildup.
ARCADIS also conducts semi-annual inspections, during which the condition of the fence. OSF cap and general
observations are noted to identify any issues. Native vegetation is well established on the OSF and throughout the
Site. The fire hazard from the excess growth of natural grasses and tumbleweed accumulation identified during
the previous FYR has been addressed. Due to declining water levels in Site monitoring wells, EPA approved a
change to low -flow groundw ater sampling methods in 2022.

Implementation of Institutional Controls and Other Measures

A locked gate and chain link fence surrounds the entire Site and restricts unauthorized access. There is a
restrictive covenant filed at the Curry County Clerk office, preventing disturbances to the OSF. The ROD
did not include institutional controls but did require a fenced area for the on-site storage facility. Fencing is in
place, and BNSF has been maintaining the fence.


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QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives
(RAOs) used at the time of the remedy selection still valid'.'

Question 6 Summary:

There were no changes to the exposure assumptions, toxicity data or clean up levels. The remedial action at the
Site is complete and the RAOs used at the time of the remedy are still valid. The September 23, 1988, ROD did
not specifically state RAOs; however, the Feasibility Study describes primary and secondary objectives. The
primary objective in the Feasibility Study was to eliminate the human exposure pathway from inhalation of wind-
blown sediments from the playa bed. assuming future evaporation of lake water. The secondary objectives for the
selected remedies for the lake water, sediment, and soil were intended to mitigate the potential future migration of
contamination to groundwater. Land use remains the same, and the Site is fenced to restrict unauthorized access.

Changes in Standards and TBCs

Amended NMWQCC groundwater standards took effect on December 21. 2018, and generally match federal
MCLs. Although no ARARs were established for the groundwater at the Site, the ROD states that the selected
remedy will meet all primary State and Federal standards for drinking water. Table 2 lists the Federal and State

standards for drinking water.

Changes in Toxicity and Other Contaminant Characteristics

There have been no changes in the toxicity factors for the contaminants of concern.

Changes in Risk Assessment Methods

There have been no changes to risk assessment methods.

Changes in Exposure Pathways

The exposure assumptions used to develop the Human Health Risk Assessment at this Site remain the same. Land
use at the Site has not changed. Access to the Site is restricted by a chain link fence and a restrictive covenant is
in place.

Expected Progress Towards Meeting RAOs

The remedy at the Site is complete. The RAOs have been met and will continue to be met if O&M continues. As
stated above, the ROD did not specifically state RAOs; however, the Feasibility Study describes primary and
secondary objectives.

QUESTION C : Has any other information come to light that could call into question the protectiveness of the
remedy'.'

CERCLA and the NCP require consideration of potential extreme weather/climate change impacts at the site. As
part of this FYR. EPA conducted a forward-looking climate change analysis to estimate whether extreme weather
could affect the protectiveness of the remedy, and what actions would be needed to ensure its resilience under
future climate conditions that could affect short term and long-term protectiveness. The breakdown of potential
conditions at the site indicates very low vulnerability to extreme temperature; annual, seasonal, and heavy
precipitation; dry days; inland flooding, sea level rise, and hurricane surge; wildfire, and landslides. The change
over current conditions assessment indicates potentially dangerous weather would not affect site operations or the
remedy. Climate change/extreme weather will continue to be evaluated at subsequent five-year review s to ensure
remedy resilience at the site.


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During this FYR no new information was discovered that calls into question the protectiveness of the remedy.

VI. ISSUES/RECOMMENDATIONS

Issues/Rccommcndations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:
No Issues/Recommendations

OTHER FINDINGS

In addition, the follow ing are recommendations that were identified during the FYR and may improve
performance of the remedy, reduce costs, improve management of O&M, conserve energy, promote
sustainability. etc.. but do not affect current and/or future protectiveness:

• None.

VII. PROTECTIVNESS STATEMENT

Silowidc I'rolecliMMiess Stalemonl

Protectiveness Determination:

Protective

Protectiveness Statement:

The remedy at the AT&SF (Clovis) Site is protective of human health and the environment. All
remedial action objectives have been met for the Site. The former lake area is isolated from surface
water run-on. lake water has evaporated, lake-bottom sediments and soils from beneath the lake-
bottom sediments and beach area have been treated, all treated sediments are contained in the OSF. the
OSF has been capped, and the site has been restored.

VIII. NEXT REVIEW

The next five-year review report for the AT&SF (Clovis) Superfund Site is required five years from the
completion date of this review.


-------
APPENDIX A - REFERENCE LIST

U.S. Environmental Protection Agency. September 1988. Supcrfund Record of Decision: Atchison/Santa
Fe/Clovis. NM.

U.S. Environmental Protection Agency (EPA). 2018. Ffifth Five Year Review Report for AT&SF (Clovis)
Superfund Site Curry County. New Mexico. CERCLIS ID # NMD043158591

U.S. Environmental Protection Agency (EPA). November 2022. Regional Screening Levels (RSLs).
Available online at https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables

Arcadis U.S.. Inc for BNSF Railway. Post Closure Operations and Maintenance Plan (Revised). Santa Fe
Lake Site. Clovis. New Mexico. May 2019.

Arcadis U.S.. Inc for BNSF Railway. Post Closure Operations and Maintenance Plan (Revised). Santa Fe
Lake Site. Clovis. New Mexico. March 2023.

Arcadis U.S.. Inc for BNSF Railway. Post Closure Operations and Maintenance End of Year Report -
2022, Santa Fe Lake Site. Clovis. New Mexico. March 2023.


-------
APPENDIX B - EJSCREEN REPORT


-------
Save as PDF |

EffH

EJScreen Report (Version 2.0)

1 mile Ring Centered at 34.397753,-103.207973
NEW MEXICO, EPA Region 6
Approximate Population: 6,576
	Input Area (sq. miles): 3.14	

Selected Variables

Percentile in State

Percentile in EPA Region

Percentile in USA

Environmental Justice Indexes

EJ Index for Particulate Matter 2.5

72

64

77

EJ Index for Ozone

62

77

85

EJ Index for 2017 Diesel Particulate Matter*

73

72

77

EJ Index for 2017 Air Toxics Cancer Risk*

69

63

76

EJ Index for 2017 Air Toxics Respiratory HI*

65

61

73

EJ Index for Traffic Proximity

80

81

84

EJ Index for Lead Paint

93

92

90

EJ Index for Superfund Proximity

37

53

65

EJ Index for RMP Facility Proximity

89

72

82

EJ Index for Hazardous Waste Proximity

55

57

65

EJ Index for Underground Storage Tanks

79

75

80

E J Index for Wastewater Discharge

N/A

N/A

N/A

~ Index for the Selected Area Compared to All People's Blockgroups in the State/Region/US

100

EJ Indexes

State Percentile Regional Percentile National Percentile
This report shows the values for environmental and demographic indicators and EJScreen indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of ozone in the air), and also shows what percentile each raw
data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that
only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and
uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJScreen documentation for discussion of these issues before using
reports.

A	A unttdSutA

La/#\ fnvinymtnttlPictoettcn

VLrnim


-------
August 17, 2022

* Project 1

Search Result (point)

1:36.112

075

Mew Mex-co Slate University, City cf Clovts Texas ParKs & Wildlife,
Es'i, HERE. Garirin. SafeGraph. GeoTechnologies. Inc. METI/NASA,
USGS EPA, MPS. US Census Bureau, USDA

Sites reporting to EPA

Superfund NPL

0

Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)

0

Selected Variables

Value

State

EPA Region

USA

Avg. %tile

Avg. %tile

Avg. %tile

Pollution and Sources

Particulate Matter 2.5 (lig'm3)

6.33

5.58

86

9.32

4

8.74

6

Ozone (ppb)

51

56.2

1

41.1

91

42.6

88

2017 Diesel Particulate Matter* (|jg/m3)

0.209

0.208

61

0.219

50-60th

0.295

<50th

2017 Air Toxics Cancer Risk* (lifetime risk per million)

20

20

78

32

<50th

29

<50th

2017 Air Toxics Respiratory HI*

0.2

0.24

60

0.37

<50th

0.36

<50th

Traffic Proximity (daily traffic count/distance to road)

530

480

73

470

77

710

70

Lead Paint (% Pre-1960 Housing)

0.51

0.18

90

0.16

90

0.28

78

Superfund Proximity (site count/km distance)

0.0086

0.13

4

0.08

3

0.13

2

RMP Facility Proximity (facility count/km distance)

0.66

0.25

89

0.83

62

0.75

66

Hazardous Waste Proximity (facility counBkm distance)

0.1

0.82

35

0.8

22

2.2

16

Underground Storage Tanks (count/km2)

2.2

2.5

70

2

67

3.9

81

Wastewater Discharge (toxicity-weighted concentration/m distance)

N/A

4.6

N/A

0.5

N/A

12

N/A

Socioeconomic Indicators

Demographic Index

72%

52%

81

44%

85

36%

90

People of Color

76%

63%

69

52%

72

40%

81

Low Income

67%

41%

87

36%

90

31%

93

Unemployment Rate

11%

7%

78

5%

87

5%

86

Linguistically Isolated

15%

5%

89

6%

86

5%

89

Less Than High School Education

40%

14%

95

15%

91

12%

95

UnderAge 5

8%

6%

70

7%

63

6%

71

Over Age 64

9%

17%

17

13%

31

16%

22

*Diesel particulate matter, air toxics cancer risk, and air toxics respiratory hazard index are from the EPA's 2017 Air Toxics Data Update, which is the Agency's ongoing, comprehensive evaluation of air toxics in the United States. This effort aims to
prioritize air toxics, emission sources, and locations of interest for further study It is important to remember that the air toxics data presented here provide broad estimates of health risks over geographic areas of the country, not definitive risks to
specific individuals or locations. Cancer risks and hazard indices from the Air Toxics Data Update are reported to one significant figure and any additional significant figures here are due to rounding. More information on the Air Toxics Data Update
can be found at: https://www.epa.gov/haps/air-toxics-data-update. (https://www.epa.gov/haps/air-toxics-data-update)


-------
For additional information, see: www.epa.gov/environmentaljustice(https://www.epa.gov/environmentaljustice)

EJScreen is a screening tool for pre-decisional use only, it can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-making, but it may help identify potential areas of EJ concern.
Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level
information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJScreen documentation for discussion of these issues before using reports. This screening tool does not
provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJScreen outputs should be supplemented with additional information and local knowledge before taking any action to address
potential EJ concerns.


-------
APPENDIX C - DATA TABLES


-------
^AR

Analytical Results of the 2022 Groundwater Monitoring Program
BNSF Railway Company
Santa Fe Lake
Clovis, New Mexico

Well ID



MW

-B

MW-C

MW-D



MW-E



MW-F

MW-G

Field Blank

Sample Event



G2022-4

G2022-4

G2022-4



G2022-4



G2022-4

G2022-4

G2022-4

Sample ID



G-618

G-619

G-620

G-621

G-624

G-622

G-623

G-625

Duplicate of:

NMED

















G-621 (Duplicate)













Analyte

Criteria3

Result

SDL

Result

SDL

Result

SDL

Result

SDL

Result

SDL

Result

SDL

Result

SDL

Result

SDL

Arsenic

0.01 ob

0.00260

0.000180

0.00468

0.000180

0.0252

0.000180

0.00656

0.000180

0.00728

0.000180

0.00110J

0.000180

0.00232

0.000180

<0.000250

0.000180

Chloride

250

52.8

0.3790

476V
0.0495J

1.9

98.0

0.379

86.4

0.379

86.2

0.379

107

0.3790

177

0.3790

<0.379

0.379

TRPH-DRO

0.0167*

<0.0222

0.0222

0.0222

<0.0222

0.0222

<0.0222

0.0222

0.0240J

0.0222

<0.0222

0.0222

0.0481J

0.0222

<0.0222

0.0222

Total Phenolics

0.005

<0.00830

0.00830

<0.00830

0.00830

<0.00830

0.00830

<0.00830

0.00830

<0.00830

0.00830

0.0180J

0.00830

<0.00830

0.00830

<0.00830

0.00830

4-Ch I oro-3-m eth yl ph en ol

0.005d

<0.000263

0.000131

<0.000263

0.000131

<0.000263

0.000131

<0.000263

0.000131

<0.000263

0.000131

<0.000263

0.000131

<0.000263

0.000131

<0.000263

0.000131

2-Chlorophenol

0.091e

0.000771J

0.000133

<0.000283

0.000133

<0.000283

0.000133

<0.000283

0.000133

<0.000283

0.000133

<0.000283

0.000133

<0.000283

0.000133

<0.000283

0.000133

2,4-Dichlorophenol

0.0453s

0.000470J

0.000102

<0.000284

0.000102

<0.000284

0.000102

<0.000284

0.000102

<0.000284

0.000102

<0.000284

0.000102

<0.000284

0.000102

<0.000284

0.000102

2,4-Dimethylphenol

0.354s

<0.000624

0.000064

<0.000624

0.000064

<0.000624

0.000064

<0.000624

0.000064

<0.000624

0.000064

<0.000624

0.000064

<0.000624

0.000064

<0.000624

0.0000636

4,6- Din itro-2-m ethyl phenol

0.00152e

<0.00262

0.11200

<0.00262

0.11200

<0.00262

0.11200

<0.00262

0.11200

<0.00262

0.11200

<0.00262

0.11200

<0.00262

0.11200

<0.131

0.112

2,4-Dinitrophenol

0.0387s

<0.00325

0.00593

<0.00325

0.00593

<0.00325

0.00593

<0.00325

0.00593

<0.00325

0.00593

<0.00325

0.00593

<0.00325

0.00593

<0.00325

0.00593

2-Nitrophenol

0.005d

<0.00032

0.000117

<0.00032

0.000117

<0.00032

0.000117

<0.00032

0.000117

<0.00032

0.000117

<0.00032

0.000117

<0.00032

0.000117

<0.00032

0.000117

4-Nitrophenol

0.005d

<0.00201
<0.000313

0.00014

<0.00201

0.00014

<0.00201

0.00014

<0.00201

0.00014

<0.00201

0.00014

<0.00201

0.00014

<0.00201

0.00014

<0.00201

0.000143

Pentachlorophenol

0.001b

0.000313

<0.000313

0.000313

<0.000313

0.000313

<0.000313

0.000313

<0.000313

0.000313

<0.000313

0.000313

<0.000313

0.000313

<0.0156

0.0003

Phenol

5.76e

0.00916J

0.004330

<0.000433

0.004330

<0.00433

0.004330

0.00540J

0.004330

<0.00433

0.004330

<0.00433

0.004330

<0.00433

0.004330

<0.000334

0.004330

2,4,6-T richlorophenol

0.0119s

<0.000297

0.000100

<0.000297

0.000100

<0.000297

0.000100

<0.000297

0.000100

<0.000297

0.000100

<0.000297

0.000100

<0.000297

0.000100

<0.000297

0.000100

Footnotes:

All units reported as mg/L.

SDL - Sample detection limit.

TRPH DRO- Total Petroleum Recoverable Hydrocarbons, Diesel Range Organics
Detections are indicated in bold font. Exceedances are shaded.

a.	The criteria listed for the constituents are New Mexico Water Quality Control Commission (NMWCC) standards for domestic water supply unless otherwise indicated.

b.	United States Environmental Protections Agency (USEPA) maximum contaminant level (MCL).

c.	The NMED removed the screening criterion for TRPH-DRO in its June 2022 Risk Assessment Guidance. This value was retained in this table for comparative purposes.

d.	The NMWCC standard for phenols was used, because there is no MCL, NMWCC standard for this individual constituent, or screening level in the June 2022 Risk Assessment Guidance.

e.	Tap water screening levels in the June 2022 Risk Assessment Guidance.

J - Result is less than the Reporting Limit but greater than or equal to the Method Detection Limit and the concentration is an approximate value.

V- The sample concentration is too high to evaluate accurate spike recoveries.

J6 - The sample matrix interfered with the ability to make any accurate determination; spike value is low.

P1 -RPD value not applicable for sample concentrations less than 5 times the Reporting Limit.

Tables (EOY 2022)_Draft_02.10.23


-------
»ARCADIS

Summary of Post-Remediation Analytical Results of the Groundwater Monitoring Program

(last 13 sampling events)

BNSF Railway Company

Santa Fe Lake

Clovis, New Mexico



Sample



Duplicate

Arsenic

Chloride

TRPHa

TRPH-DRO3

Total Phenolics

Well ID

Sample ID

(mg/L)

(mg/L)

(mg/L)

(mg/L)

(mg/L)







Value

RL

Value

RL

Value

RL

Value

RL

Value

RL

MW-B

G2007-3

G-485





0.010

454

0.50



5.000





0.130



G2008-3

G-504





0.010

545

3.0



5.000







0.130



G2009-3

G-517





0.010

580

40.0



3.4







0.005



G2010-3

G-529





0.010

400

40.0

0.71J

3.0







0.005



G2011-3

G-541





0.010

510

40.0



3.1







0.005



G2012-2

G-553



0.020

450

5.0



5.300







0.040



G2013-4

G-564



0.0031 UB

0.001

600

10.0



5.494





0.022UB

0.040



G2014-3

G-575



0.0015

0.001

600

20.0

2.5J

5.154





0.012J

0.040



G2015-4

G-586



0.00228

0.002

451

10.0





0.277

0.100



0.040



G2016-4

G-594



0.00171 J

0.003

167

10.0





0.0379J

0.100

0.0474

0.040



G2017-4

G-602



0.00183J

0.003

44.5

1.0





0.0379J

0.100

0.0474

0.040



G2018-4

G-610



0.00182J

0.003

15.5

1.0







0.100



0.040



G2022-4

G-618



0.00260

0.002

52.80

1.0







0.100



0.040

MW-C

G2007-3

G-486





0.010

391

0.5

9.53 UB

5







0.13



G2008-3

G-505





0.010

534

3.0



5.000







0.130



G2008-3

G-510

G-505



0.010

530

3.0

23.1 J

5.00







0.130



G2009-3

G-518





0.010

460

40.0



3.40







0.005



G2010-3

G-530





0.010

590

40.0

0.41J

3.100







0.005



G2011-3

G-542





0.010

410

40.0



3.100







0.005



G2012-2

G-554





0.020

410

5.0



5.000







0.040



G2013-4

G-565



0.0031 UB

0.0010

470

10.0



5.555





0.013UB

0.040



G2014-3

G-576



0.0016

0.0010

300

10.0

0.740

5.263





0.010J

0.040



G2015-4

G-587



0.00251

0.0020

325

20.0







0.100



0.040



G2016-4

G-595



0.00198J

0.0025

204

20.0







0.100

0.0277J

0.040



G2017-4

G-603



0.00165J

0.0025

439

10.0







0.100



0.040



G2018-4

G-611



0.00184J

0.0025

501

10.0







0.100

0.0166J

0.040



G2022-4

G-619



0.00468

0.0020

476V

5.0





0.0495J

0.100



0.040

MW-D

G2007-3

G-487





0.010

73.4

0.5



5







0.13



G2007-3

G-488

G-487



0.010

72.9

0.5



5.000







0.130



G2008-3

G-506



0.071

0.010

72.7

3.0



5.000





0.247

0.130



G2009-3

G-519





0.010

73

4.0

1.2J

3.30







0.005



G2009-3

G-523

G-519

0.0034J

0.010

73

4.0



3.40







0.005



G2010-3

G-523





0.010

79

4.0

0.51 J

3.0







0.005



G2011-3

G-543



0.0035J

0.010

71

4.0



3.2





0.0026 UB

0.005



G2011-3

G-547

G-543



0.010

71

4.0



3.1







0.005



G2012-2

G-555





0.020

80

2.0



5.000





0.013J

0.040



G2013-4

G-566



0.0032UB

0.001

83

1.0



5.515





0.014UB

0.040



G2013-4

G-570

G-566

0.0035UB

0.001

83

1.0



5.376





0.0090UB

0.040



G2014-3

G-577



0.0022

0.001

84

1.0

1.6J

5.263





0.016J

0.040



G2014-3

G-582

G-577

0.0022

0.001

84

1.0

0.890J

5.555





0.011J

0.040



G2015-4

G-588



0.00306

0.002

88.2

10.0





0.00944J

0.100



0.040



G2016-4

G-596



0.00243

0.0025

89.3

10.0







0.100



0.040



G2017-4

G-604



0.00274

0.0025

83.4

2.0







0.100



0.040



G2018-4

G-612



0.00218

0.0025

79.4

2.0







0.100

0.0186J

0.040



G2022-4

G-620



0.0252

0.0020

98

1.0







0.100



0.040

MW-E

G2007-3

G-489





0.010

96

0.5

8.46 UB

5







0.13



G2008-3

G-507





0.010

95.6

3.0



5.000





0.157

0.130



G2009-3

G-520





0.010

93

4.0



3.30







0.005



G2010-3

G-532





0.010

95

4.0

0.51 J

3.0







0.005



G2011-3

G-544





0.010

80

4.0



3.1







0.005



G2012-2

G-556





0.020

84

1.0



5.0







0.040



G2013-4

G-567



0.0031 UB

0.001

97

2.0



5.6





0.015UB

0.040



G2014-3

G-578



0.0015

0.001

87

1.0

0.840J

5.3





0.018J

0.040



G2015-4

G-589



0.00273

0.002

115

1.0





0.0252J

0.100



0.040



G2015-4

G-592

G-589

0.00251

0.002

116

1.0





0.0448J

0.100

0.00930J

0.040



G2016-4

G-597



0.00201

0.002

124

1.0







0.100



0.040



G2016-4

G-600

G-597

0.00178J

0.002

122

1.0







0.100



0.040



G2017-4

G-605



0.00192J

0.002

133

2.0







0.100



0.040



G2017-4

G-608

G-605

0.00187J

0.002

133J

2.0







0.100



0.040



G2018-4

G-613



0.00178J

0.002

118

5.0







0.100

0.0161 J

0.040



G2018-4

G-616

G-613

0.00194J

0.002

120

5.0







0.100



0.040



G2022-4

G-621



0.00656

0.002

86.4

1.0







0.100



0.040



G2022-4

G-624

G-621

0.00728

0.002

86.2

1.0





0.0240J

0.100



0.040

Tables (EOY 2022)_Draft_0 2.10.23

1/2


-------
»ARCADIS

Summary of Post-Remediation Analytical Results of the Groundwater Monitoring Program

(last 13 sampling events)

BNSF Railway Company

Santa Fe Lake

Clovis, New Mexico



Sample



Duplicate

Arsenic

Chloride

TRPHa

TRPH-DRO3

Total Phenolics

Well ID

Sample ID

(mg/L)

(mg/L)

(mg/L)

(mg/L)

(mg/L)





Value

RL

Value

RL

Value

RL

Value

RL

Value

RL

MW-F

G2007-3

G-490





0.010

143

0.5



0.5





1.02

0.13



G2008-3

G-508





0.010

205

3.0

8.46 UB

5.000







0.130



G2009-3

G-521



0.0042J

0.010

120

4.0



3.3







0.005



G2010-3

G-534





0.010

140

4.0



3.3







0.005



G2011-3

G-546





0.010

120

4.0

0.71J

3.000





0.0025 UB

0.005



G2012-2

G-557



0.020

120

2.0



3.100







0.040



G2012-2

G-560

G-557

0.020

130

2.0



5.000





0.027J

0.040



G2013-4

G-568



0.0021

0.001

120

2.0



5.000





0.023J

0.040



G2014-3

G-579



0.0015

0.001

110

2.0



5.263





0.012J

0.040



G2015-4

G-590



0.00236

0.002

113

10.0









0.009J

0.040



G2016-4

G-598



0.00466

0.002

87.9

10.0











0.040



G2017-4

G-606



0.00153J

0.002

110

2.0











0.040



G2018-4

G-614



0.00183J

0.002

120

1.0









0.0198J

0.040



G2022-4

G-622



0.00110J

0.002

107

1.0







0.100

0.0180J

0.040

MW-G

G2007-3

G-491





0.010

297

0.5



0.500







0.130



G2008-3

G-509





0.010

333

3.0

16.0 UB

5.00





0.181

0.130



G2009-3

G-522





0.010

280

40.0



3.5







0.005



G2010-3

G-533



0.013

0.010

310

4.0



3.0







0.005



G2010-3

G-535

G-533

0.0034J

0.010

310

4.0

0.71J

3.0







0.005



G2011-3

G-545





0.010

210

40.0

0.61J

3.100







0.005



G2012-2

G-558





0.020

420

5.0



3.100





0.035J

0.040



G2013-4

G-569



0.0025UB

0.001

280

5.0

0.8J

5.000





0.016UB

0.040



G2014-3

G-580



0.0012

0.001

410

5.0



5.434





0.013J

0.040



G2015-4

G-591



0.00205

0.002

523

20.0





1.16

0.100

0.0259J

0.040



G2016-4

G-599



0.00161 J

0.002

313

20.0





0.615

0.100

0.0549

0.040



G2017-4

G-607



0.00142J

0.002

451

20.0





0.332

0.100







G2018-4

G-615



0.00150J

0.002

483

10.0







0.100







G2022-4

G-623



0.00232

0.002

177

1.0





0.0481J

0.100



0.040

Footnotes:

Value - Result value reported by laboratory. If no value shown, result was not detected.

mg/L - milligrams per liter.

RL - Reporting limit.

F - Analyte detected in the field blank.

B - Analyte detected in the associated Method Blank

J - Result is less than the RL but greater than or equal to the MDL and the concentration is an approximate value.

NA - Not analyzed. Sample broken prior to receipt by laboratory.

NS - Not sampled. Amount of water contained within well MW-A casing insufficient to provide sample. Sample G-442 not obtained due to pump failure.

UB - Analyte detected in associated blank sample.

a. USEPA Method 8015 was adopted for use at this site for total recoverable petroleum hydrocarbon (TRPH)-Diesel range organics (DRO) analysis beginning in 2015. Historic
data for this analyte prior to 2015 using Method 1664A are also recorded on this table, but are not be used in statistical analyses.

Tables (EOY 2022)_Draft_0 2.10.23

2/2


-------
APPENDIX D - FIGURES


-------
SOURCE:

U.S.G.S. 7.5 MINUTE QUADRANGLE MAR
CLOVIS, NEW MEXICO; PROVISIONAL EDITION 1985
MIDWAY, NEW MEXICO; PROVISIONAL EDITION 1985
2000	0	2000

BNSF

CLOVIS, NEW MEXICO

SANTA FE LAKE SITE

SITE LOCATION

«ARCADIS

Design & Consultancy
lor natural and
built assets


-------
aS

3 *

LEGEND
MW-G ^ - MONITOR WELL LOCATION

200 400

SCALE IN FEET
1" = 400-0"

800

li

BNSF

CLOVIS, NEW MEXICO

SANTA FE LAKE SITE

MONITOR WELL LOCATIONS

^ARCADIS


-------

-------
APPENDIX E - SITE CHRONOLOGY


-------
Site Chronology of Events

Date

Event

1979

Initial discovery of problem or contamination

February 1, 1980

Official EPA Site Discovery Date

April 1, 1980

Preliminary Assessment and Site Investigation complete

September 1, 1983

Administrative Order on Consent Signature

September 8, 1983

NPL listing

August 1988

Remedial Investigation/Feasibility Study complete

September 23, 1988

ROD signature

December 16, 1988

Remedial design start

November 1992

Remedial design complete

November 1992

Phase I - Construction Began

March 1993

Phase I - Construction Completed

June 1993

Phase II - Bioremediation Began

October 1999

Phase II - Bioremediation Completed

June 2000

Phase III - Site Restoration Began

September 2000

Phase III - Site Restoration Completed

November 8, 2002

Final Close-out Report

March 17, 2003

Deletion from NPL

September 2, 1998

First Five-Year Review

September 2, 2003

Second Five-Year Review

September 2, 2008

Third Five-Year Review

September 9, 2013

Fourth Five-Year Review

July 24, 2018

Fifth Five-Year Review


-------
APPENDIX F - INTERVIEW FORMS


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INTERVIEW RECORD

Site Details

Name:

AT&SF Clovis Superfund Site

EPA ID:

NMD043158591

Subject:

Sixth Five-Year Review

Interviewer

Name:

Martyne Kieling
Brian Mueller

Title:

Project Manager
Remedial Project Manager

Affiliation:

New Mexico Environment Dept.
EPA R6

Individual Contacted

Name:

Kyle DeSantis

Title:

Environmental Scientist

Affiliation:

ARCADIS

Phone Number:
713-598-5801

Email Address:

Kyle.desantis@arcadis.com



Interview Details

Interview Format:

Email

Interview Location:

N/A

Interview Category:

Consultant

Interview Date:

November 23, 2022

Interview Time:

N/A



Questionnaire:

1.	What is your overall impression of the project'.'

Very little activity at site, monitoring for Post-Closure

2.	Is the remedy functioning as expected'.' How well is the remedy performing'.'

Yes. OSF cap vegetation is well established, have not observed any significant issues during site walks. Some
minor maintenance on slopes has been conducted.

3.	What does the monitoring data show? Are there any trends that show contaminant levels are decreasing'.'

Monitoring data was collected on 11/27/22. Data is currently being validated. Data results did not show any
significate changes from past sampling events.

4. Is there a continuous on-site O&M presence'.' If so. please describe staff and activities. If there is not a
continuous on-site presence, describe staff and frequency of site inspections and activities.


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There is no continuous on-site presence. The site is checked monthly by Hulcher personnel primarily checking
fence for damage and tumbleweed buildup. A read is personnel conducts a semi-annual inspections of site each
year. BNSF police patrol around site.

5.	Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five years? If
so. please give details.

West side fence repairs due to damage by vehicles from nearby public road. Periodic mow ing to control
tumblew eed buildup and fire hazard. Continue to monitor for animal burrow s on North side of cap.

6.	Have there been any significant changes in the O&M requirements, maintenance schedules, or sampling
routines since start-up or in the last five years? If so. do they affect the protectiveness or effectiveness of
the remedy'.' Please describe changes and impacts.

Due to water decline in wells sampling procedures have been changed from 3-well volume sampling to low-flow
sampling. This change should increase the ability to collect water samples for future sampling events.

7.	Have there been opportunities to optimize O&M. or sampling efforts'.' Please describe changes and
resultant or desired cost savings or improved efficiency.

Yes. As stated above, sw itching sampling method to Low-flow sampling.

8.	Do you have any comments, suggestions, or recommendations regarding the project'.'

9. Do you consent to have your name included along with your responses to this questionnaire in the five-
year review report'.'

Yes.


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INTERVIEW RECORD

Site Details

Name:

AT&SF Clovis Superfund Site

EPA ID:

NMD043158591

Subject:

Sixth Five-Year Review

Interviewer

Name:

Martyne kieling
Brian Mueller

Title:

Project Manager
Remedial Project Manager

Affiliation:

New Mexico Environment Dept.
EPA R6

Individual Contacted

Name:

Thomas Jones

Title:

Manager Environmental
Remediation

Affiliation:

BNSF Railway

Phone Number:
816-605-3495

Email Address:

thomas .j ones3 @bnsf.com



Interview Details

Interview Format:

Choose an item.

Interview Location:

N/A

Interview Category:

Consultant

Interview Date:

Click or tap to enter a date.

Interview Time:

N/A



Questionnaire:

1.	What is your overall impression of the project'.'

This is a post-closure maintenance and monitoring project with very little activity.

2.	Is the remedy functioning as expected'.' How well is the remedy performing'.'

Yes. The remedy appears to be performing very well as there have been no significant changes to conditions at
the site during the previous five-year reviews. The cap is stable and there are no impacts to groundwater from the
capped materials.

3.	What does the monitoring data show'.' Are there any trends that show contaminant levels are decreasing'.'

Monitoring data was collected the week prior to the site inspection and is currently undergoing validation.
Groundwater data will be included with the forthcoming monitoring/inspection report. The current, unvalidated
data is consistent with historical results and the overall trends appear to be stable or decreasing.


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4. Is there a continuous on-site O&M presence'.' If so. please describe staff and activities. If there is not a
continuous on-site presence, describe staff and frequency of site inspections and activities.

There is no continuous on-site presence. Staff from the nearby BNSF Clovis Yard (remediation contractor.
Hulcher Services) check the site on a monthly basis for signs of trespass and buildup of tumbleweeds along the
security fence. BNSF Resource Protection officers also drive by the site during routine patrols (frequency
unknown) to check for signs of trespass.

5.	Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five years? If
so. please give details.

A section of the fence was damaged and repaired in 2022. Portions of the site have been mow ed to
reduce fire hazard potential during the past five years. Brush and tumbleweed debris has been removed
from the fence line several times during the past five years.

6.	Have there been any significant changes in the O&M requirements, maintenance schedules, or sampling
routines since start-up or in the last five years? If so. do they affect the protectiveness or effectiveness of
the remedy'.' Please describe changes and impacts.

Continued decline of the water table has reduced the volume of water in the on-site monitoring wells to the point
where groundwater samples can no longer be collected via the dedicated pumps. EPA and NMED agreed to
change the groundwater sampling method from purging three well volumes to low-flow . A new SOP for low-
flow sampling will be included with the monitoring report for review and approval by EPA and NMED.

7.	Have there been opportunities to optimize O&M, or sampling efforts'.' Please describe changes and

resultant or desired cost savings or improved efficiency.

Yes. see question 6. Changing to low-flow sampling will improve sampling efforts due to the declining water
table and limited quantity of groundwater in the monitoring wells.

8.	Do you have any comments, suggestions, or recommendations regarding the project'.'

No.

9. Do you consent to have your name included along with your responses to this questionnaire in the five-
year review report'.'

Yes.


-------
INTERVIEW RECORD

Site Details

Name:

AT&SF Clovis Superfund Site

EPA ID:

NMD043158591

Subject:

Sixth Five-Year Review

Interviewer

Name:

Martyne kieling
Brian Mueller

Title:

Project Manager
Remedial Project Manager

Affiliation:

New Mexico Environment Dept.
EPA R6

Individual Contacted

Name:

Lance A. Pyle

Title:

County Manager

Affiliation:

Curry County. NM

Phone Number:

575-763-6016

Email Address:
lpyle @curry county .org



Interview Details

Interview Format:

Email

Interview Location:

N/A

Interview Category:

Local Agency

Interview Date:

December 5, 2022

Interview Time:

N/A



Questionnaire:

1.	What is your overall impression of the project'.'

This is the first time that I have been contacted to provide any input on this project. I am not
familiar enough to comment.

2.	Have there been routine communications or activities (site visits, inspections, reporting activities, etc.)
conducted by your office regarding the site? If so. please give purpose and results.

There has been no routine communication or activities by my office.

3.	Have there been any complaints, violations, or other incidents related to the site requiring a response by
your office'.' If so. please give details of the events and results of the responses.

If I recall correctly, we have received some complaints about the fence being down or people
accessing the site. Those complaints were referred to the Fire and Safety Director, Michael Booth,
and he can be reached at mhooth a curr\countv.or«.


-------
4. Do you feel well informed about the site's activities and progress'.'

I do not feel well informed about the site's activities and progress. I would recommend that routine
annual reports be provided to the Board of Curry County Commission and the Clovis City
Coin mission, which would keep the public informed as well.

5.	Do you have any comments, suggestions, or recommendations regarding the site's management or
operation'.'

As mentioned above, I would recommend annual reports to the governing bodies in the community;
City of Clov is and Curry County.

6.	Do you consent to have your name included along with your responses to this questionnaire in the five-
year review report'.'

I have no issue with having my name referenced in the report.


-------
APPENDIX F - SITE INSPECTION CHECKLIST AND PHOTOS


-------
I. SITE INFORMATION

Site name: ATSF (Clovis) Superfund Site

Date of inspection: November 3,2022

09:00-11:00

Location and Region: Curry County, Clovis, NM
(Region 6)

EPA ID: NMD043158591

Agency, office, or company leading the five-year
review: EPA and NMED

Weather/Temperature: sunny with clear skys, wind
0 mph, 50 F.

Remedy Includes: (Check all that apply)
X Landfill cover/containment
X Access controls

~	Institutional controls

~	Ground Water pump and treatment

~	Surface water collection and treatment

~	Monitored natural attenuation

~	Ground Water containment

~	Vertical barrier walls

X Other Continued groundwater monitoring.

Attachments: X Inspection team roster attached below ~ Site map attached
Attendance at Site Inspection:

Name	Title	Phone

Brian Mueller EPA RPM	214 665-7167	

Email

miieller.brian@epa. gov

Martvne Kieling NMED Project Manager

505-670-0691

martvne .kieling@env.nm. gov

Thomas F. Jones ESNSF Environmental Remediation Manager 816-605-3495 thomas.iones3@bnsf.com
Kvle DeSantis Arcadis Environmental Scientist 713-598-5801	

II. INTERVIEWS (Check all that apply)

1. O&M site manager: Thomas F. Jones

Name

BNSF Railway. Manager Environmental Remediation 11/3/2022
Title	Date

Interviewed X at site ~ at office ~ by phone Phone no. 816-605-3495 thomas.iones3@bnsf.com
Problems, suggestions; ~ Report attached X Interview response is attached in Appendix D	

2. O&M staff: Kvle DeSantis

Environmental Scientist. Arcadis
Title

November 3, 2022_
Date

Name

Interviewed X at site ~ at office ~ by phone Phone no. 713-598-5801 Kvle.desantis@arcadis.com
Problems, suggestions; ~ Report attached X Interview response is attached in Appendix D	


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3.

Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response
office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices, etc.) Fill in all that apply.



Agencv Curr\ Countv Commissioner

Contact Scth Martin Curry Countv Commissioner District 4 11/3/2022

575-763-0151



Name Title Date Phone no.

Problems; suggestions; ~ Report attached ~ Interview attached X Interview reauested but



documentation not provided bv countv commissioner.





Agencv Currv Countv Manager

Contact Lance Pvle Currv Countv Manager 575-763-6016





Name Title Date Phone no.
Problems; suggestions; ~ Report attached ~ Interview not received X Interview reauested but



documentation not provided bv countv manager.









4.

Other interviews (optional) ~ Report attached. ~ additional interviews attached







III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1.

O&M Documents

~	O&M manual ~ Readily available ~ Up to date
~As-built drawings ~ Readily available ~ Up to date

~	Maintenance logs ~ Readily available ~ Up to date
Remarks: Documents arc not kept on site.

XN/A
XN/A
XN/A

2.

Site-Specific Health and Safety Plan ~ Readily available ~ Up to date ~ N/A

~ Contingency plan/emergency response plan ~ Readily available ~ Up to date ~ N/A
Remarks: A health and safctv meeting was held bv Arcadis. The H&S Plan was on site and the



acknowledgement form was signed bv all in attendance.



3.

O&M and OSHA Training Records l_ Readily available ~ Up to date
Remarks: Training records were not reviewed.

XN/A







4.

Permits and Service Agreements

~	Air discharge permit ~ Readily available ~ Up to date

~	Effluent discharge ~ Readily available ~ Up to date

~	Waste disposal, POTW ~ Readily available ~ Up to date

~	Other permits ~ Readilv available ~ Up to date

Remarks:

XN/A
XN/A
XN/A
XN/A

5.

Gas Generation Records ~ Readily available ~ Up to date X N/A
Remarks










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6.

Settlement Monument Records ~ Readily available
Remarks

~ Up to date X N/A







7.

Ground Water Monitoring Records X Readily available
Remarks

~ Up to date ~ N/A







8.

Leach ate Extraction Records ~ Readily available
Remarks

~ Up to date X N/A







9.

Discharge Compliance Records

~	Air ~ Readily available

~	Water (effluent) ~ Readily available
Remarks:

~	Up to date X N/A

~	Up to date X N/A







10

Daily Access/Security Logs ~ Readily available
Remarks:

~ Up to date X N/A







IV. O&M COSTS

1.

O&M Organization

~	State in-housc ~ Contractor for State

~	PRP in-housc X Contractor for PRP

~	Federal Facility in-housc ~ Contractor for Federal Facility

~	Other:



2.

O&M Cost Records

~	Readily available ~ Up to date

~	Funding mechanism/agreement in place

~	Original O&M cost estimate NA ~ Breakdown attached
X Costs covered by RP

3.

Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: Not Applicable







V. ACCESS AND INSTITUTIONAL CONTROLS X Applicable UN/A

A. Fencing

1.

Fencing damaged ~ Location shown on site map X Gates secured ~ N/A

Remarks: Fencing was in good repair at time of inspection. It is checked bv BNSF Clovis Yard securitv



(remediation contractor. Hulcher Services) routinely.



B.

Other Access Restrictions



1.

Signs and other security measures ~ Location shown on site map ~ N/A

Remarks: Santa Fe Lake Site with Repository location is fenced bv six foot chain-link and topped with



three strand barbed wire. Placards arc located on Navaio Road and South Main Street gate. Signage



includes BNSF name and BNSF Police contact number and three additional contact phone numbers for



access.




-------
c.

Institutional Controls (ICs)

1.

Implementation and enforcement

Site conditions imply ICs not properly implemented ~ Yes ~ No ~ N/A
Site conditions imply ICs not being fully enforced ~ Yes ~ No ~ N/A

Type of monitoring (e.g., self-reporting, drive by) Drive by, property is owned by BNSF Railway.

Frequency

Responsible party/agency - Checked routinely by BNSF Clovis Yard security (remediation contractor.
Hulcher Services). Posted contacts.

Contact: Kvle DeSanis Arcadis Environmental Scientist 713-598-5801
BNSF securitv Hulcher Services 1-800-832-5452
Name Title Phone no.

Reporting is up-to-date X Yes UNo UN/A
Reports arc verified by the lead agency X Yes UNo UN/A

Specific requirements in deed or decision documents have been met X Yes ~ No ~ N/A
Violations have been reported ~ Yes ~ No ~ N/A
Other problems or suggestions: ~ Report attached

2.

Adequacy X ICs arc adequate ~ ICs arc inadequate ~ N/A
Remarks

D.

General

1.

Vandalism/trespassing ~ Location shown on site map X No vandalism evident
Remarks: Fence in good repair no vandalism evident or reported.

2.

Land use changes on site X N/A
Remarks: No land use changes.

3.

Land use changes off site X N/A
Remarks:


-------
VI. GENERAL SITE CONDITIONS

A.

Roads x Applicable UN/A



1.

Roads damaged ~ Location shown on site map X Roads adequate ~ N/A
Remarks: Entrance drive and road is in good shape.

B.

Other Site Conditions



Remarks:



VII. LANDFILL COVERS x Applicable

~ N/A

A.

Landfill Surface



1.

Settlement (Low spots) ~ Location shown on site map

A real extent Depth
Remarks

X Settlement not evident







2.

Cracks ~ Location shown on site map

Lengths Widths Depths

X Cracking not evident



Remarks









3.

Erosion ~ Location shown on site map

A real extent Depth

Remarks

X Erosion not evident







4.

Holes ~ Location shown on site map

A real extent Depth
Remarks

X Holes not evident







5.

Vegetative Cover X Grass X Cover properly established X No signs of stress
~ Trees/Shrubs (indicate si/c and locations on a diagram)

Remarks: Some cacti arc established along the slopes. Grass, w ildflowcrs and vegetative cover is well



devcloDcd over the entire surface and sloocs of reoositorv cover.









6.

Alternative Cover (armored rock, concrete, etc.) ~ N/A

Remarks: Armored rock sloocs and drainages are in place.









7.

Bulges ~ Location shown on site map

A real extent Height

Remarks

X Bulges not evident














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8.

Wet Areas/Water Damage X Wet areas/water damage not evident

~	Wet areas ~ Location shown on site map A real extent

~	Ponding ~ Location shown on site map A real extent

~	Seeps ~ Location shown on site map A real extent

~	Soft subgrade ~ Location shown on site map A real extent
Remarks







9.

Slope Instability ~ Slides ~ Location shown on site map X No evidence of slope instability

A real extent

Remarks







B.

Benches ~ Applicable ~ N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined

channel.)

1.

Flows Bypass Bench ~ Location shown on site map ~ N/A or okay
Remarks: !nternal berm/moat around the lake perimeter designed to carry away excess overland flow
and to prevent run-in is in place.

2.

Bench Breached
Remarks

~ Location shown on site map X N/A or okay







3.

Bench Overtopped
Remarks

~ Location shown on site map X N/A or okay







C.

Letdown Channels ~ Applicable X N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)

1.

Settlement

A real extent

~ Location shown on site map ~ No evidence of settlement

Depth



Remarks









2.

Material Degradation
Material type

~ Location shown on site map ~ No evidence of degradation

A real extent



Remarks









3.

Erosion
A real extent

~ Location shown on site map ~ No evidence of erosion

Depth



Remarks









4.

Undercutting
A real extent

~ Location shown on site map ~ No evidence of undercutting

Depth



Remarks










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5.

Obstructions Type ~ No obstructions

~ Location shown on site map A real extent

Size

Remarks

6.

Excessive Vegetative Growth Type

~	No evidence of excessive growth

~	Vegetation in channels docs not obstruct flow

~	Location shown on site map A real extent
Remarks

D.

Cover Penetrations ~ Applicable X N/A

1.

Gas Vents ~ ActiveU Passive

~	Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition

~	Evidence of leakage at penetration ~ Needs Maintenance

~	N/A
Remarks

2.

Gas Monitoring Probes

~	Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition

~	Evidence of leakage at penetration ~ Needs Maintenance ~ N/A
Remarks

3.

Monitoring Wells (within surface area of landfill)

~	Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition

~	Evidence of leakage at penetration ~ Needs Maintenance X N/A
Rcmarks:_ All monitor wells at the Site arc ground water monitor wells and arc discussed in Section IX
Groundwater Section of this inspection report.

4.

Leachate Extraction Wells

~	Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition

~	Evidence of leakage at penetration ~ Needs Maintenance X N/A
Remarks

5.

Settlement Monuments ~ Located ~ Routinely surveyed X N/A
Remarks

E.

Gas Collection and Treatment ~ Applicable X N/A

1.

Gas Treatment Facilities

~	Flaring ~ Thermal destruction ~ Collection for reuse

~	Good conditionU Needs Maintenance
Remarks

2.

Gas Collection Wells, Manifolds and Piping
~ Good conditionU Needs Maintenance
Remarks


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3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good conditionU Needs Maintenance ~ N/A
Remarks

F.

Cover Drainage Layer

~ Applicable X N/A

1.

Outlet Pipes Inspected

~ Functioning ~ N/A



Remarks









2.

Outlet Rock Inspected

~ Functioning ~ N/A



Remarks









G.

Detention/Sedimentation Ponds

~ Applicable X N/A

1. Siltation Areal extent	 Depth		UN/A

~ Siltation not evident

Remarks

2. Erosion	Areal extent	 Depth

~ Erosion not evident

Remarks

3. Outlet Works

~ Functioning

~ N/A

Remarks







4. Dam

~ Functioning

~ N/A

Remarks







EL Retaining Walls

~ Applicable

XN/A

1. Deformations	~ Location shown on site map ~ Deformation not evident

Horizontal displacement	 Vertical displacement	

Rotational displacement	

Remarks

2. Degradation	~ Location shown on site map ~ Degradation not evident

Remarks

I. Perimeter Ditches/Off-Site Discharge	X Applicable ~ N/A

1. Siltation	~ Location shown on site map X Siltation not evident

Areal extent	 Depth	

Remarks

2. Vegetative Growth ~ Location shown on site map ~ N/A
~ Vegetation docs not impede flow

Areal extent	 Type	

RcinarksVegitative growth is excellent within the swale and on the Hanks.


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3.

Erosion ~ Location shown on site map X Erosion not evident

A real extent Depth

Remarks

4.

Discharge Structure ~ Functioning X N/A

Remarks

VIII. VERTICAL BARRIER WALLS U Applicable XN/A

1.

Settlement ~ Location shown on site map ~ Settlement not evident

A real extent Depth

Remarks

2.

Performance Monitoring Type of monitoring
~ Performance not monitored

Frequency U Evidence of breaching
Head differential

Remarks

IX. GROUND WATER/SURFACE WATER REMEDIES X Applicable UN/A

A. Ground Water Extraction Wells, Pumps, and Pipelines ~ Applicable XN/A

1.

Pumps, Wellhead Plumbing, and Electrical

~ Good conditionU All required wells properly operating ~ Needs Maintenance ~ N/A

Remarks





2.

Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good conditionU Needs Maintenance

Remarks

3.

Spare Parts and Equipment

~ Readily available ~ Good conditionU Requires upgrade U Needs to be provided
Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable X N/A

1.

Collection Structures, Pumps, and Electrical
U Good conditionU Needs Maintenance

Remarks

2.

Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
U Good conditionU Needs Maintenance

Remarks

3.

Spare Parts and Equipment

U Readily available U Good conditionU Requires upgrade U Needs to be provided
Remarks


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c.

Treatment System ~ Applicable X N/A

1.

Treatment Train (Check components that apply)

~	Metals removal ~ Oil/water separation ~ Biorcmediation

~	Air stripping ~ Carbon adsorbers

~	Filters

~	Additive (e.g., chelation agent, flocculent)

~	Others

~	Good condition ~ Needs Maintenance

~	Sampling ports properly marked and functional

~	Sampling/maintenance log displayed and up to date

~	Equipment properly identified

~	Quantity of ground water treated annually

~	Quantity of surface water treated annuallv
Remarks:

2.

Electrical Enclosures and Panels (properly rated and functional)
~ N/A ~ Good condition ~ Needs Maintenance
Remarks:

3.

Tanks, Vaults, Storage Vessels

~ N/A ~ Good condition ~ Proper secondary containment ~ Needs Maintenance
Remarks: .

4.

Discharge Structure and Appurtenances

~ N/A ~ Good condition ~ Needs Maintenance

Remarks: Containment tank and secondary containment for produced soil vapor water and transfer

hoses and pump arc in good working condition.

5.

Treatment Building(s)

~	N/A ~ Good condition (esp. roof and doorways) ~ Needs repair

~	Chemicals and equipment properly stored

Remarks:	Haz/ard placards and emergency contact numbers require updates or replacement.

6.

Monitoring Wells (pump and treatment remedy)

~	Properly secured/locked ~ Functioning ~ Routinely Sampled ~ Good condition

~	All required wells located ~ Needs Maintenance ~ N/A
Remarks:	


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D. Monitoring Data X Applicable ~ N/A

1.

Monitoring Data

X Is routinely submitted on time ~ Is of acceptable quality

2.

Monitoring data suggests:

X Ground Water plume is effectively contained X Contaminant concentrations arc declining

E. Monitored Natural Attenuation: X Applicable

1.

Monitoring Wells (natural attenuation remedy)

X Properly secured/locked ~ Functioning X Routinely sampled X Good condition

X All required wells located ~ Needs Maintenance ~ N/A

Remarks: Sampling schedule is switching to a fivc-vcar collection cvclc. Water levels in site monitor

wells continues to drop, leaving minimal well volume for water level recovery after the three volume
purge and difficulty obtaining the rcciuircd sample collection volume. The sample method is switching
from 3 purge volumes to low flow in order to compensate for the regional drooping water table.

X.

OTHER REMEDIES

If there arc remedies applied at the site which arc not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.

XI. OVERALL OBSERVATIONS

A.

Implementation of the Remedy



Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).



The rcmcdv as designed is to prevent migration of contaminated soil encased in the repository from
migrating off site or into the former Santa Fe lake bottom area. The bcrms surrounding the former Santa
Fe lake edge arc placed to prevent sheet wash run in of rainfall into the former lakebed. The rcmcdv is
effective and functioning as designed. Groundwater monitoring on site confirms that there is no longer a
contributing contaminant source.

B.

Adequaey of O&M



Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protcctivcncss of the remedy.



During the site inspection the site was clear of excess of tumbleweeds and repository surface was free of
burrows. Fences and gates were in good shape, and all rock armor the repository slopes was in good
shape.


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c.

Early Indicators of Potential Remedy Problems



Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs, that suggest that the protcctivcncss of the remedy may be
compromised in the future.



There arc no problems with the remedy that is in place. The fencing, signage, armor slopes, bernis.
repository cover and vegetative cover arc in verv good shape.

D.

Opportunities for Optimization



Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.



The onlv optimization currently undcruav is the sample method is switching from three purge volumes
to low flow in order to compensate for the regional dropping water table. Samples will be collected carlv
in the fourth vcar of the five vcar review cvcle in order to have results available for the next five vcar
review.


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Surface vegetation with repository slope and old irrigation line.
View to the north.

ATSF (Clovis) Superfund Site Inspection, November 3, 3022
Photographed by Martyne Kieling, NMED-SOS

Site entrance along S. Main St. at Navajo Road. Placards on gate.

Site entrance aiong S. Main St. at Navajo Road. Placards on gate.
View to the west.

Site entrance along S. Main St. at Navajo Road. Placard on gate

Road, vegetation, and lake bottom in mid photo. View to the west

Road, storage shed, brush pile and lake bottom mid right half of
photo. View to the south southwest.

trespassing on

RAILWAY PROPERTY
IS ILLEGAL

NOTICE ^

THIS IS PRIVATE PROPERTY
TRESPASSERS WILL BE
PROSECUTED

1-800-832-5452 BNSF POUCE


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ATSF (Clovis) Superfund Site Inspection, November 3, 3022
Photographed by Martyne Kieling, NMED-SOS

Perimeter mowed with thick vegetation on the repository slope.
North fence line right side of photo. View to the west.

Perimeter mowed with thick vegetation on the repository slope.
North fence line left side of photo. MW-E along repository north
side. View to the east.

Monitor well MW-D is located on the west side of the repository.
Thick vegetation and stable slope. View to the east.



Monitor well MW-E is on the northeast side of repository.


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ATSF (Clovis) Superfund Site Inspection, November 3, 3022

Monitor well MW-D is located on the west side of the repository.

Monitor well MW-F in mid-photo is on the south side of the
repository. The repository slope is along the left side of the photo.
View to the east.

ci

Mowed road along west side of repository. Berm surrounding lake
bottom is topped with light yellow vegetation. Swale is in center
of photo. Well established thick vegetation apparent. View to the
south.


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6/15/23, 12:20 PM

Manage your flows | Power Automate

R6RB: Approval Requested f... x

Overview

Requester
w* Wiley, Adina

Received

Jun 13, 04:06 PM (1 d ago)

Completed

Jun 15,12:18 PM (1 min ago)

Outcome
Approved

Link

Review the Document(s)

Details

Request: Five Year Review Report for
ATSF Clovis Site

Routing History: - Sent to Mueller, Brian on
6/13/2023 4:06 PM for Step 6 Review.

•	Approved by Malone, George on
6/13/2023 4:04 PM. Comments:

•	Sent to Malone, George on 6/13/2023
8:51 AM for Step 5 Review.

•	Approved by Salinas, Amy on
6/13/2023 8:50 AM. Comments:

•	Sent to Salinas, Amy on 6/7/2023 1:15
PM for Step 4 Review.

•	Approved by Luschek, Robert on
6/7/2023 1:14 PM. Comments: minor
edits using track changes

•	Sent to Luschek, Robert on 6/5/2023
3:07 PM for Step 3 Review.

•	Approved by Atkins, Blake on
6/5/2023 3:06 PM. Comments: A few
grammatical edits provided in Word
document, using track changes.

•	Sent to Atkins, Blake on 6/5/2023 1:04
PM for Step 2 Review.

•	Approved by Mueller, Brian on
6/5/2023 1:03 PM. Comments:

•	Sent to Mueller, Brian on 6/5/2023
1:01 PM for Step 1 Review,

•	Routing for ATSF Clovis FYR started
on 6/5/2023 1:01 PM.

•	Request: Five Year Review Report for
ATSF Clovis Site

Activity

Created

Wiley, Adina
Jun 13, 04:06 PM (1 dago)

Responded: Approve

Mueller, Brian
Jun 13, 04:06 PM (1 d ago)

https://make.gov.powerautomate.us/environments/Default-88b378b3-6748-4867-acf9-76aacbeca6a7/approvals/history

1/1


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