SITE INFORMATION AND CORRESPONDENCE

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EehW Nn p. D...Jn. omennm .usoxx,. � Maexew ROoxmuE: Water Boards Pmeewaxlx mmmnu Central Valley Regional Water Quality Control Board 23 April 2015 Mr, Mike Makerov, P.G. Manager Environmental Remediation BNSF Railway 740 E. Carnegie Drive San Bernardino, CA 92408-3571 CONDITIONAL CONCURRENCE WITH SOIL INVESTIGATION WORKPLAN, BNSF RAILWAY COMPANY MORMON YARD, 801 DIAMOND STREET, SAN JOAQUIN COUNTY On 21 October 2011, a locomotive derailed, puncturing the fuel tank and releasing about 1,400 gallons of diesel fuel at the Burlington Northern Santa Fe Railway (BNSF) Mormon Yard in Stockton. Disposal manifests show that BNSF captured 880 gallons of diesel and water, and on 22 October excavated about 80 cubic yards of soil. BNSF also obtained four soil confirmation samples from the excavated area which showed two samples contained 2,400 and 9,000 mg/kg total petroleum hydrocarbons as diesel (TPHd), and two samples contained 110 and 150 mg/kg TPHd. However, BNSF did not provide documentation identifying the location of j the release, the excavation, nor the location or depth of the confirmation samples. In response to California Regional Water Quality Control Board, Central Valley Region (Central Valley Water Board) request, BNSF has submitted the 27 March 2015 Soil Investigation Work Plan, BNSF Alonno�(17WorrPlan) prepsreci-bTK-6ff�yIJenks-Consultan . The Work Plan proposes to evaluate the vertical extent of the release to determine if additional remediation work will be required. Accordingly, 4 sample borings are proposed in the release area with soil samples to be obtained at depths of 5, 10, and 15 feet below ground surface (bgs). A background boring will be positioned beyond the spill zone to establish a basis of comparison with ambient conditions at the railyard. Soil samples are proposed to be analyzed for TPHd using silica gel preparation. Groundwater is not expected to be encountered at this depth, based on water surface elevations found at nearby remediation sites. i Silica gel preparation removes polar organic compounds from the analyte, which would be expected to be partially degraded petroleum. For site characterization purposes, BNSF needs to analyze soil samples by TPHd analysis without silica gel cleanup, which would not quantify differing amounts of fresh or degraded fuel. However, BNSF is welcome to run both analyses for comparison purposes. In regards to the location of the release, Ms. Laura Kennedy of Kennedy/Jenks Consultants discussed in a 21 April 2015 telephone call that she had spoken with a BNSF staff person who was present at the Mormon Yard when the release occurred. The location exhibited in the Work Plan is correct, the location of the sample points are approximately coincident with the October 2011 confirmation samples, and the inner two proposed sample locations are about where the KARL E. LONQ V SCD, P.E.,CRAIP I PAMELA G. CPEEDOR P.E., BCEE, EMiCU VE OFFICER 11020 0 San Center MVO SWO,Rancho Cerdma,CA 9597O I VAVW.WRtm Ogrde.Ca.00V/CenWVelley ("y xaoroExo w,nex