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ARCADIS <br /> ARCADIS U.S.,Inc. <br /> Infrastructure, environment, buildings 1410 Rocky Ridge Drive <br /> Suite 330 <br /> Roseville <br /> California 95661 <br /> Ms. Kathryn Dominic Tel 916.786.0320 <br /> Fax 916.78 <br /> Engineering Geologist <br /> www.arcadis-us.is-us.com <br /> California Regional Water Quality Control Board, Central Valley Region <br /> 11020 Sun Center Drive#200 <br /> Rancho Cordova, CA 95670-6114 <br /> ENVIRONMENT <br /> Subject: <br /> Response to Comments—"Biotreatment Beds Post Remediation Investigation <br /> Report, Union Pacific Railroad Company, Former Tracy Maintenance Facility" <br /> Tracy, CA—Maintenance Facility <br /> Date: <br /> November 5, 2010 <br /> Contact: <br /> Dear Ms. Dominic: <br /> James Eisert <br /> ARCADIS U.S., Inc. (ARCADIS) has prepared this response to comments letter on Phone: <br /> behalf of the Union Pacific Railroad Company (UPRR)for the Former Tracy 916-786-1871 <br /> Maintenance Facility located at 720 East 6th Street in Tracy, California ("the Site"; <br /> Figures 1 and 2). This letter presents responses to comments received from the Email: <br /> California Regional Water Quality Control Board (RWQCB) regarding the James.Eisert@arcadis-us.col <br /> "Biotreatment Beds Post Remediation Investigation Report, Union Pacific Railroad Our ref: <br /> Company, Former Tracy Maintenance Facility," prepared by ARCADIS and dated RC000709.0002.00007 <br /> August 24, 2010 ("the 2010 Investigation Report"; ARCADIS 2010). The RWQCB <br /> provided comments regarding the 2010 Investigation Report to UPRR in a letter <br /> dated August 24, 2010. <br /> Response to Comments <br /> ARCADIS has prepared responses to the RWQCB's comments as presented below. <br /> RWQCB Comment: Soil TPHd concentrations should not exceed the de minimis 1 in <br /> a-million excess cancer risks for inhalation of dust, dermal contact(including workers <br /> and children), and sensitive ecological receptors. <br /> Response: It is not possible to assess potential cancer risk associated with Total <br /> Petroleum Hydrocarbons (TPH)-diesel range organics (TPH-d). Regulatory agencies <br /> including the United Stated Environmental Protection Agency (USEPA) and the <br /> California Environmental Protection Agency (CaIEPA), Office of Environmental <br /> Health Hazard Assessment(OEHHA) have not classified TPH-d as a carcinogen or <br /> Imagine the result <br /> p:\arcadis data\projects-active\union pacific railroad\rc709-tracy mnt facility\deliverables\2010-11 biotreatment bed response to <br /> rwgcb\biotrtmnt_beds_rtc_Itr(11-05-10).docx <br />