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January 11 2006

Mr David Cobrain State of New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East Building One Santa Fe New Mexico 87505-6303

Reference Work Assignment No 06110270 State ofNew Mexico Environment Department Santa Fe New Mexico Support for the LANL Order of Consent Review of the Investigation Report for Material Disposal Area G Consolidated Unit 54-0 13(b)-OO at Technical Area 54 Los Alamos National Laboratory New Mexico Task 3 Deliverable

Dear Mr Cobrain

Attached please find a deliverable for the above-referenced work assignment The deliverable addresses the review of the Investigation Report for Material Disposal Area G Consolidated Unit 54-013(b)-00 at Technical Area 54 Los Alamos National Laboratory New Mexico

The review consisted of several steps First the technical completeness of the report was evaluated against Section XIC Investigation Report of the March 12005 New Mexico Environmental DepartmentLos Alamos National Laboratory (NMEDLANL) Order of Consent (herein referred to as the Order) Secondly the report was reviewed to determine whether the methodology and actions outlined in the Investigation Work Plan for Material Disposal Area G Solid Waste Management Unit 54-013(b)-99 at Technical Area 54 Revision 1 (herein referred to as the Work Plan) as approved with modifications were followed Finally a technical review of the information and data provided in the report was conducted As discussed the bulk of the review focused on the first two steps of the review

In the approval letter for the Work Plan (dated November 5 2004) Specific Comment Number 4 of the Attachment indicates that the air rotary drill method is not proposed or approved for drilling at this site While none of the boreholes were drilled using an air rotary rig boreholes 15-2 and 15-3 were drilled using this rig These boreholes were drilled to greater depths (up to 700 feet below ground surface) in order to characterize andor verify the presence ofperched groundwater It is assumed that this type of drilling device was required in order to drill at depth Specific Comment Number 13 of the Attachment indicates that the Permittees must choose drilling methods for boreholes that allow for detection of perched grountiwater Therefore it was assumed that use of an air rotary rig would be acceptable for drilling the deep boreholes and

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Mr David Cobrain January 11 2006 ~Te(hLaw Page 2

11 rI i r ( III t P r i )

that a violation of the Work Plan was not committed A comment has not been drafted concerning this issue however NMED may wish to further review this issue to determine compliance with the Work Plan and associated approval modifications

The Work Plan only required that the requirements outlined in Section XLC7fofthe Order for groundwater be met if groundwater was encountered during drilling As no groundwater (perched or regional aquifer) was encountered up to the 700 feet below ground surface the maximum depth of drilling no discussions on groundwater were provided in the report No comments were drafted concerning this issue

Sections XLEI and XLE2 ofthe Order require that a title page and table ofcontents be provided for the risk assessment However as the risk assessment was provided as an Appendix to the Investigation Report these requirements were deemed to have been fulfilled in the main body ofthe report and that repetition of this material was not necessary for the Appendix As such no comments were drafted concerning this and the Checklist is marked as Not Applicable However as this assumption required some interpretation of the requirements of the Order NMED may wish to reconsider our assumption and comment as warranted

The risk assessment only evaluated a non-intrusive industrial worker The Investigation Report indicates that if in the future the need for intrusive activities arises then the risks to the intrusive worker would be addressed at that time This is slightly contradictory to the requirements outlined in Section XIE6 of the Order In this section of the Order it specifically states that all current and reasonably foreseeable land use scenarios must be evaluated in the risk assessment It is not clear whether LANL assumes that land use controls will be placed on the site or whether they do not know future land uses Intrusive activities can be related to excavation construction andor remediation Since the one of the recommendations of the Investigation Report is to conduct a Corrective Measure Evaluation (CME) it seems that the future fate ofthe site is unclear Thus a comment (in Section 3 of the deliverable) has been drafted indicating that either stronger language indicating future land use is provided (including establishing and enforcement ofland use controls) or the risk assessment be revised to address the intrusive worker

There is some concern that the site has not been adequately characterized This statement is based upon the discussions provided in the risk assessment (Appendix G of the Investigation Report) The risk assessment both the industrial human health and ecological are based solely upon sediment data collected from the drainages It appears that no surface soil data has been collected outside ofthe drainage areas While drainages may represent a worst-case sample location as metals and radionuclides may tend to migrate via runoff and cumulate in the drainages the Investigation Report does not address this Several comments in Section 3 of the deliverable have been drafted concerning this issue

There is concern that the sampling plan for each of the boreholes as discussed in the Work Plan was not followed It appears that fewer samples were collected than as proposed A comment in Section I ofthe deliverable discusses this concern

Overall the Investigation Report was administratively complete and followed the requirements

2

Mr David Cobrain January 112006~Tr(hLaw Page 3

J if (I ( l f I t Iii f r I 11

of both the Order and the Work Plan The attached deliverable has been fonnatted to allow easy review of each of the three steps of the review The first section of the deliverable addresses the comparison to the Work Plan as amended The second section addresses the administrative completeness and comparison to the Order In order to aid this part of the review a Checklist that provides a brief summary of the key elements of the Order has been provided The third and final section of the deliverable addresses any miscellaneous technical comments not previously addressed in the first two sections ofthe deliverable

This deliverable was emailed to you on January 11 2006 at DavidCobrainstatenmus to Ms Darlene Goering at DarleneGoeringstatenmus A fonnalized hard (paper) copy of this letter deliverable will be sent via mail If you have any questions please call me at (303) 763-7188 or Ms Paige Walton at (801) 451-2978

Sincerely

~-( yuj

P gram Manager shy

Enclosure cc Darlene Goering NMED

Ms Paige Walton TechLaw

3

TASK 3 DELIVERABLE

REVIEW OF INVESTIGATION REPORT FOR MATERIAL DISPOSAL AREA G CONSOLIDATED UNIT 54-013(B)-00 AT TECHNICAL AREA 54

Support for the LANL Order of Consent

Submitted by

TechLaw Inc 560 Golden Ridge Road

Suite 130 Golden CO 80401-9532

Submitted to

Mr David Cobrain State of New Mexico Environment Department

Hazardous Waste Bureau 2905 Rodeo Park Drive East

Building One Santa Fe New Mexico 87505

In response to

Work Assignment No 06110270

January 11 2006

REVIEW OF INVESTIGATION REPORT FOR MATERIAL DISPOSAL AREA G CONSOLIDATED UNIT S4-013(B)-00 AT TECHNICAL AREA S4

TABLE OF CONTENTS

10 Comparison to the Work Plan 1

20 Completeness Review 4

30 Technical Comments 15


COMPARISON TO THE WORK PLAN

Work Plan Requirements

The Investigation Report was reviewed to determine whether the methodology and actions outlined in the Investigation Work Plan for Material Disposal Area G Solid Waste Management Unit 54-013(b)-99 at Technical Area 54 Revision 1 (herein referred to as the Work Plan) as approved with modifications were followed The Work Plan discussed the results ofprevious investigations This material was read to provide a better understanding of the site however a technical review ofthis material was not conducted In addition it is noted that the scope ofwork in the Work Plan differs from that presented in the Order (summarized in Work Plan Table 3) However as the Work Plan was previously approved by NMED it was assumed that these deviations were acceptable and the Investigation Report was reviewed accordingly

A brief summary ofthe activities that were to be conducted include

Eleven (11) angled and nine (9) vertical boreholes Collection ofcontinuous core sample from each borehole Screening of core for radiation Logging ofboreholes Collection of Tuff samples at 20-foot vertical depth intervals Collections of subsurface pore gas at each borehole Analysis ofpore gas samples for volatile organic compounds (VOCs) and tritium Collection of 10 sediment samples in Canada del Buey and Collection of 10 sediment samples in Pajarito Canyon

Specific Comments

1 As noted in Specific Comment Number 6 in the Attachment to the approval letter for the Work Plan the revised Work Plan should provide a brief description of Standard Operating Procedure (SOP) 0633 Headspace Vapor Screening with a Photoionization Detector (PID) Upon review of the revised Work Plan (both the report as well as Appendix K) it does not appear that this has been provided In addition it does not appear that the Investigation Report contains either the SOP or a description of it It is noted that Section 30 ofthe Investigation Plan indicates that because ofuncertainties the use ofPIDs to determine the total depth of a borehole was terminated Therefore it is not clear whether the information related to the SOP was not provided as PIDs were not employed Please clarify whether PIDs were used and if so where in the Work Plan or Investigation Report either the description of the SOP or the SOP itself may be located If this was not provided revise the Investigation Report to contain this information related to headspace vapor screening using a photoionization detector

2 As required in Specific Comment Number 13 in the Attachment to the approval letter for

1

the Work Plan all boreholes must be properly plugged and abandoned in accordance with the methods outlined in Section XD of the Order It is not clear from the Investigation Report whether any boreholes were plugged and if so what methods were employed It is not clear whether all boreholes remain open for the continued monitoring of volatile organic compounds and tritium vapor plumes For example Borehole 38 could not be completed and an additional borehole was drilled in new location to represent the area near Borehole 38 However the Investigation Report does not provide detail on the abandonment procedures Either provide the location in the Investigation Report that discusses borehole abandonment and compliance with Section XD of the Order or revise the Investigation Report to include this information

3 The Work plan required that 10 sediment samples (20 total) be collected in Canada del Buey and Pajarito Canyon Appendix K of the Investigation Report indicates that the data applied in the evaluation of the sediment data were collected in the years 2000 and 2004 It is noted that this Appendix references a previous draft version of the Work Plan (2003) and not the final June 2004 Work Plan However the Investigation Report (Section 30) indicates that field activities associated with the investigation were conducted in the year 2005 and Section 35 indicates that the canyon sediment samples were collected during the field investigations Based upon the information in the Investigation Report it appears that the required sediment samples should have been collected in 2005 Therefore it is not clear whether the samples collected in 2004 meet the requirements for sediment samples in these areas or whether additional sampling should have been conducted As the timeline concerning these samples is not clear please provide some clarification as to whether the sediment samples collected in 2004 were collected based upon the draft Work Plan or whether there remains a data gap with respect to these areas

4 Table 2 Summary of Proposed Borehole Drilling and Sampling at Area G of the Work Plan summarizes the type ofboring (vertical versus angled) location and depth for each of the proposed boreholes In reviewing both Table 33-1 and Appendix C of the Investigation Report there appear to be some discrepancies with the type of borehole drilled at several locations These discrepancies are noted below

Borehole Borehole TYQe Boreholes TYQe ID - Work Plan - Investigation

Report 2 Angle 45deg Vertical 90deg 3 Angle 45deg Vertical 90deg

11 Angle 45deg Vertical 90deg 14 Angle 45deg Vertical 90deg 16 Angle 45deg Vertical 90deg 17 Angle 45deg Vertical 90deg 18 Angle 45deg Vertical 90deg 19 Angle 45deg Vertical 90deg

Please clarify why a change in the type of boring was implemented in the Investigation

2

Plan and provide justification for these deviations in the approved Work Plan

5 There appears to be a major discrepancy between the number and locations ofproposed core sampling detailed in the Work Plan and the actual number and location of samples that were collected In reviewing Table 2 Summary ofProposed Borehole Drilling and Sampling at Area G a summarization of the core sampling is provided for each borehole However in reviewing the borelogs provided in Appendix C of the Investigation Report there does not appear to be a correlation in samples For example in Borehole No1 6 samples every 20 feet (between the base of the pit and the top of the Cerro Toledo interval) should have been collected However according the log the first sample was collected at 60-65 feet followed by the second sample at approximately 135-138 feet noting that the total depth of the borehole was completed above the Cerro Toledo interval This is just one example ofmany differences noted Please discuss any deviations in sampling from the Work Plan and provide justification for these deviations

3

REVIEW OF INVESTIGATION REPORT FOR MATERIAL DISPOSAL AREA G CONSOLIDATED UNIT 54-013(B)-OO AT TECHNICAL AREA 54

COMPLETENESS REVIEW

A completeness review of the Investigation Report against the March 12005 NMEDILANL Order on Consent (herein referred to as the Order) was conducted This review consisted of evaluating whether all of the sections required for an investigation report as listed in Section XLC (and associated sections as referenced in the Order) were included in the Investigation Report and whether the basic elements of each section as specified in the Order were included Below is a Checklist designed to follow the general requirements of the Order Where it is noted that a minimum required was not complete an explanation is provided in the comments following the checklist

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DISCUSSION AND JUSTIFICATION OF WHY A SECTION WAS DEEMED INCOMPLETE

Investigation Report

1 Introduction (XIC4) Unit Status A noted in Section XLCA ofthe Order the facility Investigation Reports introduction must include the status of each unit The report did not discuss whether the site is operational partially operational closed undergoing corrective action etc While the reports background section indicates the site is inactive this should be clearly stated in the Introduction Please revise the Introduction to include a discussion of the status of each unit

2 Background (XICS) Locations of Subsurface Features As required in Section XIC5 of the Order a labeled figure showing the locations of subsurface features including pipelines underground utility lines etc must be provided While it is noted that a geophysical survey was conducted to locate subsurface utilities (Section 32 or the report) it is not evident that a figure showing these subsurface features has been included in the report Upon further review of the report it appears that this map is provided in Appendix G For clarify and to aid in the review of the document please revise the text to indicate that this map is located in Appendix G

3 Background (XICS) Referenced Reports While this section was marked in the above Checklist as being complete there were some inconsistencies in the references As

11

required in Section XLCS of the Order please ensure that all references to previous report include the page table and figure number specifically being referenced No response to this comment is required

4 Exploratory Drilling or Excavation Investigations (XIC7b) Soil and Rock Classification System As required in Section XLC7b of the Order a description ofthe soil and rock classification system (eg Unified Soil Classification System USCS) that was used to describe the observed materials must be provided Please clarify what soil and rock classification system was used

5 Exploratory Drilling or Excavation Investigations (XIC7b) Decontamination of Equipment As required in Section XIC7b of the Order a discussion of the exploration decontamination procedures must be provided It is noted that the report discusses management of investigation-derived waste and it is briefly mentioned (Section 42) that auger flights and split-spoon sampling equipment were dryshydecontaminated with paper towels and brushes However it seems highly unlikely that the above were the only decontamination procedures applied especially with the sampling equipment Please clarify where in the report this information is located or revise the report to include a discussion ofthe decontamination procedures used on the explorationsampling equipment

6 Exploratory and Monitoring Well Boring Geophysical Logging (XIC7c) Merits and Limitations of Logging Methods As required in Section XIC7c of the Order a discussion on the relative merits and limitations ofeach geophysical logging method must be provided Please revise the report to include this information

7 Exploratory and Monitoring Well Boring Geophysical Logging (XIC7c) Merits and Limitations of Logging Methods As required in Section XIC7c ofthe Order a discussion of any conditions that may have been encountered that may have affected or limited the investigation should be provided It is noted that borehole Number (No) 38 had to be abandoned due to problems encountered but it is unclear whether any other limiting conditions were encountered Please clarify any conditions that may have been encountered that may have affected or limited the investigation

8 Subsurface Conditions (XIC7d) Pipelines and Utility Lines As required in Section XIC7d of the Order a description of subsurface features including pipelines underground utility lines etc must be provided While it is noted that a geophysical survey was conducted to locate subsurface utilities (Section 32 or the report) it is not evident that the report discusses these features Please clarify where in the report this information is provided or revise the report to include this information (It is noted that a map showing these features is provided in Appendix G)

9 Monitoring Well Construction and Boring or Excavation Abandonment (XIC7e) Borehole Abandonment As required in Section XD of the Order boreholes must be sealed in such a manner that the well cannot act as a conduit for migration of

12

contaminants from the ground surface It is not clear from the Investigation Report that boreholes were abandonment in accordance with these requirements

10 Soil Rock and Sediment Filed Screening Results (XIC9b) Field Screening Limitations As required in Section XLC9b of the Order the limitations offield screening instruments as well as any conditions that may have influenced the results of the field screening must be provided in the report While it is noted that the report does indicate some issues with variable radiological background readings there is no discussions concerning the other field screening equipment Either clarify where in the report this information is provide or revise the report to include a discussion ofthe limitations of field screening instruments as well as any conditions that may have influenced the results ofthe field screening

11 Air and Subsurface Vapor Filed Screening Results (XIC9k) Discussion of Results As required in Section XLC9k of the Order a discussion of the subsurface vapor field screening results must be provided While a summary table of the results is provided in the report the report does not specifically address the results of the field screening Please revise the report to include a discussion of the subsurface vapor field screening results

12 Air and Subsurface Vapor Filed Screening Results (XIC9k) Discussion of Results As required in Section XLC9k of the Order the limitations offield screening instruments as well as any conditions that may have influenced the results of the field screening must be provided in the report Either clarify where in the report this information is provide or revise the report to include a discussion ofthe limitations of field screening instruments as well as any conditions that may have influenced the results ofthe field screening

13 Air and Subsurface Vapor Laboratory Analytical Results (XIC9l) Field Conditions As required in Section XLC9J of the Order any field conditions that may have affected laboratory results must be discussed Clarify whether any field conditions were encountered that could have affect the analytical results

14 Air and Subsurface Vapor Laboratory Analytical Results (XIC9l) Cleanup LevelsStandards As required in Section XLC91 of the Order a comparison to data emission standards or established cleanup or emission levels must be conducted Upon review of the risk assessment provided in Appendix G of the report it does not appear that a vapor analysis was conducted or that any emission standardscleanup levels for vapors were applied Please clarify where this comparison is located or revise the report to include a comparison to data emission standards or established cleanup or emission levels for the subsurface vapor data In addition please provide a table with the appropriate cleanup levelsemission standards for vapors utilized at this site

15 Figures (XIC13) As required in Section XLC13 ofthe Order a figure showing underground utilities must be provided Please provide this figure

13

Risk Assessment

16 Risk Assessment AbstractlExecutive Summary (XIE2) As required in Section XIE2 of the Order the risk assessment must contain an executive summary or abstract that provides a brief summary of the purpose and scope of the risk assessment as well as the conclusions of the risk assessment This information was not provided in the report namely in the risk assessment provided in Appendix G Please revise Appendix G to contain an executive summary or abstract that provides a brief summary 0 f the purpose and scope of the risk assessment as well as the conclusions of the risk assessment

17 Tables (XIE10) While it is noted that Appendix F contains the background screening values applied at the site the risk assessment (Appendix G) should also provide a summary table of the background values used in the screening portion of the risk assessment Section XIEl 0 of the Order also indicates that the risk assessment should include a table with background values used for the screening analysis Please revise Appendix G to include a table with the background reference values for each constituent of potential concern In addition this table should also indicate the screening value (eg maximum detected concentration) that was used for comparison to background

14


ADDITIONAL TECHNICAL COMMENTS

SPECIFIC COMMENTS

1 Section 10 Introduction page 1 The description of the site does not include a discussion of the size ofthe site As noted in the letter of approval to the Work Plan with modifications the size of Material Disposal Area (MDA) G encompasses a total of 100 acres Please revise the introductory materials (or the Background Section 20) to include a discussion of the size ofMDA G

2 Section 42 Exploratory Drilling Investigations page 10 The text indicates that augers and split-spoon sampling equipment were dry-decontaminated using paper towels window cleaner and brushes Upon review of Standard Operating Procedure (SOP) 0108 as provided in the Work Plan dry decontamination ofequipment is acceptable upon completion ofdrilling activities However Section 8221 of the SOP also specifically states that is dry decontamination is conducted the equipment should periodically be surveyed using radiation instruments and then upon completion of the decontamination a swipe sample should be collected and analyzed for contamination Only upon verification from the laboratory that the swipe sample is clean can the equipment be released Based upon the brief description of decontamination provided in the report it is not clear that the decontamination procedures outlined in SOP 0108 were followed Please provide a detailed description of the decontamination procedures used at the site In addition please note any deviations from SOP 0108

In addition after reviewing SOP 0108 it appears that decontamination of equipment after the completion of activities and decontamination of sampling equipment are not the same As noted in Section 8232 ofthe SOP if organics are suspected then a wet decontamination followed by rinsate blanks to verify decontamination should be conducted First it is not clear why a wet decontamination procedure (as outlined in the SOP) was not used Organic compounds were included for analysis and thus it is assumed that was plausible to assume that organics could be present Please discuss how the use of a window cleaner may have affected the analytical results For example Section 73 of the Investigation Report indicates that trace levels oforganics were detected in the soil and rock samples Is it possible that these trace levels are related to the window cleaner used for decontamination Second window cleaner contains organic chemicals Was a chemical analysis of the window cleaner conducted in order to assess whether or not trace levels of organics detected in soilrock samples could be the result of the decontamination procedures Third it does not appear that any evaluation of the sample equipment was conducted to ensure that cross contamination was not occurring Discuss how cross-contamination was prevented and also discuss whether the low levels of organics detected in samples could be the result of cross-contamination Finally it does not appear that radiation instruments were used to scan the sample equipment in between samples to verify that the sample equipment was free of radiological

15

contamination Please clarify the exact decontamination procedures applied

Appendix G - Risk Assessment

3 Section G-10 Introduction page G-l This risk assessment addresses risks to human and ecological receptors via exposure to soil surrounding the actual disposal areas and does not address risk due to exposure to materials within the units The introduction should clearly state this and indicate that exposure to contaminants disposed in each of the disposal units would result in unacceptable risk and controls will be in place limiting direct contact with buried materials Please revise the report accordingly

4 Section G-22 Sampling Results page G-3 The risk assessment only evaluated a nonshyintrusive industrial worker The Investigation Report indicates that if in the future the need for intrusive activities arises then the risks to the intrusive worker would be addressed at that time This is slightly contradictory to the requirements outlined in Section XIE6 of the Order In this section of the Order it specifically states that all current and reasonably foreseeable land use scenarios must be evaluated in the risk assessment It is not clear whether land use controls will be placed on the site or whether there is uncertainty regarding the future land use Intrusive activities can be related to excavation construction andor remediation Since the one of the recommendations of the Investigation Report is to conduct a Corrective Measure Evaluation (CME) it seems that the future fate of the site is unclear Please provide a more detailed discussion of potential future land use for the site could be If there is any uncertainty that intrusive activities could occur at the site then the risk assessment must revised to address the intrusive worker

5 Section G-22 Sampling Results pae G-3 The second sentence of this section indicates that the risk assessment is based upon data obtained during 1994 and 1995 sampling events It is not clear why more recent data was applied in the risk assessment Discuss the rationale for using data from only 1994 and 1995

Section G-22 Sampling Results page G-3 Risks to the industrial worker are only assessed based upon data collected in the drainage ditches as no surface data collected on the mesa top were available This appears to be a major data gap in the assessment of site contamination First discuss whether any surface soil data has been collected since 1995 If so discuss why these data were not used in the risk assessment for evaluating industrial risk Second discuss the uncertainties associated with the site ifno surface soil data exist Specifically discuss how site characterization can be considered complete ifno surface soil data has been collected While it may be that the drainages represent a worstshycase sample location accounting for surface runoff ofmetals and radionuclides which could accumulate in the drainages the report does not provide any lines of evidence to indicate whether the lack of other surface soil data is or is not a concern Third please discuss the uncertainties associated with this assessment and address whether an intrusive scenario should have been conducted providing a better estimate of risk to characterized soil

16

6 Section G-22 Sampling Results page G-3 As noted in the above comment there is concern that the surface soil at the site has not been adequately characterized This concern also applies to the ecological risk assessment as only sediment data collected in the drainages was used to assess hazard Please discuss whether the use of the sediment data may under- or over-estimate risk and also discuss the uncertainties with site characterization as they relate to ecological risk

7 Section G-424 Screening Analysis Dae G-14 Volatile organic compound (VOC) pore gas data from only five (5) boreholes were used to assess hazard to burrowing animals The Investigation Report should provide some discussion as to why data from only five boreholes were used in the assessment (eg no other VOC data were collected in the 10-12 foot range in other boreholes) Discuss why only data from five boreholes were applied in the evaluation of risk via exposure of burrowing animals to subsurface VOCs

8 Section G-60 Conclusions and Recommendations page G-19 The conclusion of the risk assessment is that there are no unacceptable risks to surface or subsurface soil at the site However this statement is misleading as the risk assessment only addressed sediment in the drainages and did not address risks due to exposure to contamination in the disposal areas The conclusions should be revised to reflect the conclusion based upon what was evaluated in the risk assessment Please revise the text accordingly

Minor Comments

9 Section G-70 References Dae G-22 Please note that the reference for LANL May 2005 incorrectly references the report as (LANL 200488493) instead ofthe year 2005 Please modify accordingly No response to this comment is required

10 Table 61-1 Summary of Subsurface Soil and Rock Sampling at MDA G Please not that under the column of sample type for BH 2 there is a typographical error Metals is spelled netals No response to this comment is required

17

Mr David Cobrain January 11 2006 ~Te(hLaw

11 rI i r ( III t P r i )

that a violation of the Work Plan was not committed A comment has not been drafted concerning this issue however NMED may wish to further review this issue to determine compliance with the Work Plan and associated approval modifications

The Work Plan only required that the requirements outlined in Section XLC7fofthe Order for groundwater be met if groundwater was encountered during drilling As no groundwater (perched or regional aquifer) was encountered up to the 700 feet below ground surface the maximum depth of drilling no discussions on groundwater were provided in the report No comments were drafted concerning this issue

Sections XLEI and XLE2 ofthe Order require that a title page and table ofcontents be provided for the risk assessment However as the risk assessment was provided as an Appendix to the Investigation Report these requirements were deemed to have been fulfilled in the main body ofthe report and that repetition of this material was not necessary for the Appendix As such no comments were drafted concerning this and the Checklist is marked as Not Applicable However as this assumption required some interpretation of the requirements of the Order NMED may wish to reconsider our assumption and comment as warranted

The risk assessment only evaluated a non-intrusive industrial worker The Investigation Report indicates that if in the future the need for intrusive activities arises then the risks to the intrusive worker would be addressed at that time This is slightly contradictory to the requirements outlined in Section XIE6 of the Order In this section of the Order it specifically states that all current and reasonably foreseeable land use scenarios must be evaluated in the risk assessment It is not clear whether LANL assumes that land use controls will be placed on the site or whether they do not know future land uses Intrusive activities can be related to excavation construction andor remediation Since the one of the recommendations of the Investigation Report is to conduct a Corrective Measure Evaluation (CME) it seems that the future fate ofthe site is unclear Thus a comment (in Section 3 of the deliverable) has been drafted indicating that either stronger language indicating future land use is provided (including establishing and enforcement ofland use controls) or the risk assessment be revised to address the intrusive worker

There is some concern that the site has not been adequately characterized This statement is based upon the discussions provided in the risk assessment (Appendix G of the Investigation Report) The risk assessment both the industrial human health and ecological are based solely upon sediment data collected from the drainages It appears that no surface soil data has been collected outside ofthe drainage areas While drainages may represent a worst-case sample location as metals and radionuclides may tend to migrate via runoff and cumulate in the drainages the Investigation Report does not address this Several comments in Section 3 of the deliverable have been drafted concerning this issue

There is concern that the sampling plan for each of the boreholes as discussed in the Work Plan was not followed It appears that fewer samples were collected than as proposed A comment in Section I ofthe deliverable discusses this concern

Overall the Investigation Report was administratively complete and followed the requirements

2

Mr David Cobrain January 112006~Tr(hLaw Page 3




Sincerely

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TASK 3 DELIVERABLE



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Mr David Cobrain January 112006~Tr(hLaw




Sincerely

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3

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Table

nlt bullbull_~_ m

f-- _--=------------shy








___ 91 a m~p(~i~~~ ________ _____ _______ _







N_ P~~1ti~y~f~~ing re~~~ __ _________ ________ ___ __




~


9

















---- 1-____middot__m -










10

_ __f--_-___ ___ _ _ I

---_bull


N Tables

Y

Y A






11








12








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17

I






yJ~~pJ~~91~~~i~poundl~I~~~1~~___ _ i


i






--shy ----- shy ------ -_


NA

ltl1tI1no results




~_~~ m_~~_____~m_


or isoconcentration


I~ 10 ~~-~

8

I

I

Table

nlt bullbull_~_ m

f-- _--=------------shy








___ 91 a m~p(~i~~~ ________ _____ _______ _







N_ P~~1ti~y~f~~ing re~~~ __ _________ ________ ___ __




~


9

















---- 1-____middot__m -










10

_ __f--_-___ ___ _ _ I

---_bull


N Tables

Y

Y A






11








12








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17

I

Table

nlt bullbull_~_ m

f-- _--=------------shy








___ 91 a m~p(~i~~~ ________ _____ _______ _







N_ P~~1ti~y~f~~ing re~~~ __ _________ ________ ___ __




~


9

















---- 1-____middot__m -










10

_ __f--_-___ ___ _ _ I

---_bull


N Tables

Y

Y A






11








12








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17

















---- 1-____middot__m -










10

_ __f--_-___ ___ _ _ I

---_bull


N Tables

Y

Y A






11








12








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17

_ __f--_-___ ___ _ _ I

---_bull


N Tables

Y

Y A






11








12








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17








12








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17








13

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17

Risk Assessment



14



SPECIFIC COMMENTS




15







16




Minor Comments



17



SPECIFIC COMMENTS




15







16




Minor Comments



17







16




Minor Comments



17




Minor Comments



17

Q/I (/ i (-: Ii',~ I I I 0 0 '>

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